ML20033C466
| ML20033C466 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/02/1981 |
| From: | Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | WISCONSIN'S ENVIRONMENTAL DECADE |
| References | |
| NUDOCS 8112030284 | |
| Download: ML20033C466 (4) | |
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12/02/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 0 In the Matter of
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WISCONSIN ELECTRIC POWER COMPANY
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Docket Nos. 50-266
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50-301
.(Point Beach Nuclear Plant,
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/fb NRC STAFF INTERROGATORIES T0 g
INTERVEN0R WISCONSIN'S ENVIRONMENTAL DECADE k
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The NRC Staff hereby requests that Intervenor Wisconsin's s,
Environmental Decade (WED), pursuant to 10 C.F.R. E 2.740b and in
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accordance with instructions provided by the Licensing Board during the on-the-record telephone conference held on November 17, 1981 (Tr. 763-765), answer separately and fully, in writing under oath or affirmation, the following interrogatories.
In its " Memorandum and Order Concerning the Admission of a Party and its Contentions" (Order) dated October 13, 1981, the Board ordered the parties to explain the purpose of each set of discovery requests.
Order at 9.
The purpose of these interrogatories is two-fold:
1.
To identify the specific issues which WED seeks to litigate and to identify the basis for each issue with reasonable specificity; 2.
To identify the person or person who WED will use in present-ing its case, along with the documents relied upon.
For each response to the interrogatories set forth below, identify the person or persons who prepared or substantially contributed to the preparation of the response.
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..~ The NRC Staff further requests that Intervenor WED, pursuant to 10 C.F.R. 5 2.741, provide copies of, or make available for Staff inspection and copying, those documents designated by CNRS in response to the accompanying interrogatories.
Contention During the on-the-record telephone converence held on October 20, 1981, the Board stated that the single broad contention in this proceeding is as follows (Tr.165):
Wisconsin Electric Power Company has not demon-strated that its sleeving program for the Point Beach Nuclear Plant Units 1 and 2 can be conducted without endangering the health and safety of the public, and will be conducted in compliance with the Commission's regulations.
Interrogatories 1.
Within the Board's broad contention, state the particular issues which WED intends to litigate in this proceeding, and identify the factual basis for each issue.
2.
State the names, address and professional qualifications of the person or persons upon whose views WED relies to substantiate each issue, identified in response. to Interrogatory 1, and/or whom WED will present as an expert witness at hearing.
3.
State by author, title, date of publication and publisher all books, tests and papers upon which each person named in the response to Interrogatory 2 and WED relies to substantiate his or her views.
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. 4.
Describe all independent calculations, physical and mathematical I
models upon which each person named in Interrogatory 2 or WED relies to substantiate that person's views.
5.
Provide summaries of the views, positions or proposed testimony
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of each person named in Interrogatory 2 whom WED will present as an expert witness at hearing.
6.
State by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with each issue.
Respectfully submitted, x$-
Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of December, 1981.
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-266 l
50-301 WISCONSIN ELECTRIC POWER COMPANY
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(Point Beach Nuclear Plant,
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(Repair to Steam Generator Tubes)
Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF INTERROGATORIES TO INTERVEN0R WISCONSIN'S ENVIRONMENTAL DECADE 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 2nd day of December,1981.
Peter B. Bloch, Chairman
- Bruce Churchill, Esq.
Administrative Judge Gerald Charnoff, Esq.
Atomic Safety and Licensing Board Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regciatory Commission 1800 M Street, N.W.
Washington, DC 20555 Washington, DC 20555 Dr. Hugh C. Paxton Atomic Safety and Licensing Board Administrative Judge Panel
- 1229 - 41st Street U.t Nuclear Regulatory Commission Los Alamos, New Mexico 87544 Washington, DC 20555 Dr. Jerry R. Kline*
Atomic Safety and Licensing Appeal Administrative Judge Panel (5)*
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Docketing and Service Section (1)*
Kathleen M. Falk Office of the Secretary Wisconsin's Environmental Decade U.S. Nuclear Regulatory Commission 114 North Carroll Street Madison, WI 73703 p
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c Richard G. Bachmann Counsel for NRC Staff 1
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