ML20031G548
| ML20031G548 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/21/1981 |
| From: | Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| ISSUANCES-OL, NUDOCS 8110230211 | |
| Download: ML20031G548 (5) | |
Text
O 10/21/81 ih O /[
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L UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD p.
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Docket Nos. 50-275 0.L.
PACIFIC GAS AND ELECTRIC COMPANY 50-323 0.L.
(Diablo Canyon Nuclear Power Plant Unit Nos. I and 2)
NRC STAFF'S THIRD SET OF INTERR0GATORIES TO JOINT INTERVENORS Pursuant to 10 C.F.R. Q2.740(b), the NRC Staff serves the following interrogatories on Joint Intervenors.
INSTRUCTIONS AND DEFINITIONS 1.
Infonnation sought in these interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Joint Intervenors.
2.
As used herein, " document" includes, but is not limited to papers, photographs, criteria, standards of review, recordings, l
l memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-agency or interagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, formulas, DESIG?iATED ORIGINAL Certiggeg 3, L)',
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designs, drawings, manuals, notebacks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) from the original.
3.
Each interrogatory should be answered in five parts as follows:
a.
Answer the direct question asked or provide the information requested.
b.
State completely any documents used as the basis for the answer to the interrogatory.
c.
State completely any documents consulted, but not relied upon as a basis for preparation of your response to the interrogatory.
l d.
Give the name and professional qualifications of any individual who will testify on behalf of Joint Intervenors as to the answer given in the interrogatory.
Include a statement of professional qualifications for any identified individual.
l e.
Give the name and address of any individual, corporation, business, professional association, state or local official, or other organization which served, serves, or it is planned 1
l will serve as advisor, witness or consultant to Joint Intervenors on the issue addressed in each interrogatory.
l
Interrogatories 1.
If your answer to any Request for Admission contained in NRC Staff's Request for Admissions by Governor Edmund G. Brown, Jr., is in the negative, please state, separately as to each such response, each and every fact currently available to you which you believe refutes the request for admission and/or supports the response you havu made.
2.
For each fact stated in answer to interrogatory number 1 above, please cross-reference such fact to any applicable subparagraohs of 10 CFR 950.47(b), and planning standards and evaluation criteria in NUREG-0654, to which you believe such fact is relevant.
Respectfully submitted, NA/41%/
William J. Olmstead Deputy Chief Hearing Counsel Dated at Bethesda, Maryland this 21st day of October, 1981.
4
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UNITED STATES OF A" ERICA NUCLEAR REGULATORY C0" MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant Unit Nos. 1 and 2 CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF'S THIRD SET OF INTERROGATORIES TO JOINT INTERVENORS in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 21st day of October, 1981.
John F. Wolf, Esq., Chairman Richard E. Blankenburg Administrative Judge Co-publisher Atomic Safety and Licensing Board Wayne A. Soroyan, News Reporter U.S. Nuclear Regulatory Commission South County Publishing Company Washington, D.C.
20555
- P.O. Box 460 Arroyo Grande, California 93420 Glenn 0. Bright, Esq.
Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Dr. Jerry Kline Mr. Gordon Silver Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commission San Luis Obispo, California 93401 Washington, D.C.
20555
- Arthur C. Gehr, Esq.
Elizabeth Apfelberg Snell & Wilmer 1415 Cozadero 3100 Valley Center San Luis Obispo, California 93401 Phoenix, Arizona 95073 Philip A. Crane, Jr., Esq.
Paul C." Valentine, Esq.
Pacific Gas and Electric Company 321 Lytton Avenue P.O. Box 7442 Palo Alto, California 94302 San Francisco, California 94120 Bruce Norton, Esq.
Mr. Frederick Eissler 3216 North 3rd Street Scenic Shoreline Preservation
' Suite 202 Conference, Inc..
Phoenix, Arizona 85012 4623 More Mesa Drive Santa Barbara, California 93105 Andrew Baldsin, Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 1920 Mattie Road Shell Beach, California 93449
John R.'Phillips, Esq.
Atomic Safety and Licensing Appeal Simon Klevansky, Esq.
Panel Margaret Blodgett, Esq.
U.S. fluclear Regulatory Commission Marion'P. Johnstoy Esq.
Washington, D.C.
20555
- Joel'Rcynolds, Esq.
Center for Law in the Public Atomic Safety and Licensing Board
. Interest Panel 10203 Santa Monica Boulevard U.S. ?!uclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555
- E,yron S. Georgiou Docketing and Service Section Legal. Affairs Secretary U.S. t!uclear Regulatory Commission Governor's Office Washington, D.C.
20555
- State Capitol Sacramento, California 95814 Mark Gottlieb California Energy Comission David S. Fleischaker, Esq.
MS-18 P.O. Box 1178 1111 Howe Avenue Oklahoma City.,_0klahoma.73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 John t'arrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Herbert H. Brown i
Hill, Christopher & Phillips, P.C.
1900 M Street, N.W..
Washington, D.C.
20036 Harry M. Willis i
Seymour & Willis 601 California St., Suite 2100 l
San Francisco, California 94108 l
l Janice E. Kerr, Esq.
Lawrence Q. Carcia, Esq.
350 McAllister Street San Francisco, California 94102 Mr. Janes 0. Schuyler fluclear Projects Engineer Wi)11amJ.
1mstead Deputy Chief Hearing Counsel Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 i
.,..