ML20031G549
| ML20031G549 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/21/1981 |
| From: | Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CALIFORNIA, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8110230212 | |
| Download: ML20031G549 (5) | |
Text
r 10/21/81
(:D UNITED STATES OF AMERICA 8
[}J DCT22199;w L
'IIl u-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD EDc
/'s
,,s In the Matter of 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 GOVERN 0R EDMUND G. BROWN, JR.
Pursuant to 10 C.F.R. 92.740(b), the NRC Staff serves the following interrogatories on Governor Edmund G. Brown, Jr.
INSTRUCTIONS AND DEFINITIONS 1.
Information sought in these interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Governor Brown.
2.
As used hecein, " document" includes, but is not limited to papers, photographs, criteria, standards of review, recordings, 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, DESIGNATED ORIGINAL hbk kohk o!o00b5 Certified By 7; 7/L
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-2 designs, drawings, manuals, notebooks, 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, ano 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 infonnation 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, d.
Give the name and professional qualifications of any individual who will testify on behalf of Governor Brown as to the answer given in the interrogatory.
Include a statement of professional qualifications for any identified individual, 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 will serve as advisor, witness or consultant to Governor Brown on the issue addressed in each interrogatory.
t.
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 have made.
2.
For each fact stated in answer to interrogatory number 1 above, please cross-reference such fact to any applicable subparagraphs 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, h1 rN William J. M mstead Deputy Chief Hearing Counsel Dated at Bethesda, liaryland this 21st day of October, 1981.
. ~. -
f UNITED STATES OF A': ERICA NUCL EAR REGULATORY C0:GISSION 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 ccpies of NRC STAFF'S THIRD SET OF INTERR0GATORIES TO GOVERNOR EDMUND G. BROWN, JR. 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 Judae 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
- l Arthur C. Gehr, Esq.
l Elizabeth Apfelberg Snell & Wilmer i
1415 Cozadero 3100 Valley Center l
San Luis Obispo, California 93401 Phoenix, Arizona 95073 1
Philip A. Crane, Jr., Esq.
Paul C. Valentine, Esq.
l Pacific Gas and Electric Company 321 Lytton Avenue P.O. Box 7442 l
San Francisco, California 94120~ -~~
Palo Alto, California 94302 l
Bruce Norton, Esq.
I Mr. Frederick Eissler 3216 North 3rd Street l
Scenic Shoreline Preservation Suite 202 Conference, Inc..
Phoenix, Arizona 85012 4623 More Mesa Drive Santa Barbara, California 93105 Andrev Baldhin, Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 l
1920 Mattie Road Shell Beach, California 93449
" 6 John R. Phillips, Esq.
Atomic Safety and Licensing Appeal Simon Klevansky, Esq.
Panel Margaret Blodgett, Esq.
U.S. fluclear Regulatory Cournission Marion P. Johnston, Esq.
Washington, D.C.
20555
- Joel Reynolds, Esq.
Center for Law in the Public Atomic Safety and Licensing Board Interest Panel 10203 Santa Monica Boulevard U.S. fluclear Regulatory Commission Los Angeles, California 90067 Washington, D.C.
20555
- Byron S. Georgiou Docketing and Service Section Legal Affairs Secretary U.S. fluclear 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. Bo_x 1178 1111 Howe Avenue Ok_lahoma_ City,.0k.lahoma 73101 Sacramento, California 95825 Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 f
John Marrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Herbert H. Brown Hill, Christopher & Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Harry M. Willis Seymour & Willis 601 California St., Suite 2100 San Francisco, California 94108 Janice E. Kerr, Esq.
Lawrence Q. Carcia, Esq.
350 McAllister Street San Francisco, California 94102 Mr. James 0. Schuyler W liam J. Olmstead fluclear Projects Engineer De.uty Chief Hearing Counsel Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106
.