ML20034F628
| ML20034F628 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/19/1993 |
| From: | Repka D PACIFIC GAS & ELECTRIC CO., WINSTON & STRAWN |
| To: | FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE) |
| References | |
| CON-#193-13648 OLA-2, NUDOCS 9303040063 | |
| Download: ML20034F628 (10) | |
Text
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PRATED CORRESPONDENCE q
DOCKEiED February 19,Nhh3~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E-In the Matter of:
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Docket Nos. 50-275-OLA _
2._-
Pacific Gas and Electric Company
.) 323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
j PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R.
SS 2.740, 2.740b, and 2.741, as modified by the Atomic Safety and Licensing Board's February 9,
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- 1993, Memorandum and Order regarding discovery and hearing.
schedules, Pacific Gas and Electric Company.
("PG&E")
hereby requires the San Luis Obispo Mothers.for Peace ("MFP") to respond to the following interrogatories and produce the documents-l requested below.
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INSTRUCTIONS AND DEFINITIONS A.
Each interrogatory should be answerod separately. _The I
responses shall include ~all pertinent information known-to MFP, as defined below.
B.
Each interrogatory shall be answered fully, in writing, under oath or affirmation.
To the extent that MFP does i
not have spc.;1fic, complete, and accurate information 9303040063 930219 PDR ADOCK 05000275 j$0i C-PDR
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4 with which to answer any interrogatory, MFP should so
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state, and the interrogatory should be answered to the.
extent information is available.
i C.
Requests for documents should be answered by providing a
- list, organized by request
- number, identifying - all documents responsive to the request.
In addition, MFP should produce a copy of each document requested.
The copy should be in the form and condition in which the document exists on the date of service of'this request,.
and shall include all comments, notes, remarks, and other-material (including handwriting) that may have been added to the document af ter its initial preparation. Documents produced in response to the requests below should be
'l mailed to the undersigned counsel for PG&E.-
D.
The word " document" as used herein means any. written
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matter, whether produced, reproduced or stored on paper,
- cards, tapes,
- disks, belts,
- charts, film,
' computer -
storage devices or any other medium and shall include, 1
l without limitation, books, reports, studies, statements, speeches, notebooks, agreements, appointment calendars, working papers,. manuals, memoranda, notes, procedures, l
- orders, instructions, directions, records,.
correspondence,
- diaries, plans,
- diagrams, drawings,.
periodicals,.
- lists, telephone'
- logs, minutes, and
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i photographs, and 'shall= also include, without limitation, i
t originals, copies (with.or without notes or. changes '
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thereon) and drafts.
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t E.
"MFP" means in the context of this' discovery. request: The' l
San Luis Obispo Mothers For Peace, or any of its agents, i
employees, consultants, contractors, technical advisors, representatives or other persons acting for or on behalf of all or any of them, or at their direction and control, or in concert with or assisting them -- whether paid-or unpaid.
3 F.
" Identify" when used in reference.to a natural person f
1 means to set forth the following:
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a.
name; b.
last known residential address; c.
last known business address; d.
current or last employer; e.
title or position; a
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-f.
area of responsibility; and l
g.
office held in MFP or business, professional, ori other relationship with MFP.
i G.
" Identify" when used in reference to a. document means to set forth the following:
l a.
its title; l
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b.
its subject matiter; f
.i c.
its date;
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its author; e.
its addressee; f.
its files designation or other
' identifying?
designation; and i
g, its present location and present custodian.
j
't H.
The words "and" and "or" shall be construed either
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.q conjunctively or disjunctively so as to bring within the scope of these discovery requests any information tha't might otherwise be construed to be outside their scope.
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I.
Wherever appropriate, the singular form of.a word shall-'
be; interpreted'in the plural,. and vicel versa,.xso.as to l
T bring within the scope of these discovery requests any-
-information that. might otherwise be - construed to be outside their scope.
j J -.
If MFP objects to any interrogatory or document request, in whole or in part, or seeks to withhold documents.or l
information because of the alleged proprietary or other
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nature of the data, please set forth all reasons and the-underlying factual basis for the objection:in sufficient i
detail'to permit the Atomic Safety and Licensing ~ Board to -
q determine the validity of the objection.
This
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description'by.MFP should _ include. with respect. to.'any,
document:
(1) author, addressor, addressee, andt
- j recipients of indicated and " blind" copies, together with'-
their job titles; (2) date of' preparation; (3). subject
. matter; (4) purpose for which the document was prepared';-
(5) all persons to whom distributed, shown, or explained; (6) present custodian; (7) all persons believed to have i
a copy of the document; and (8) the nature of the objection asserted.
~
K.
For any document or part of a document that was at one time, but is.no longer, in MFP's possession, custody, or control, or which is no. longer in existence, or which cannot be located or produced, identify the document,.
state where and how it passed out of existence or why it 1
can no longer be located and the: reasons therefore, and identify each person 'having knowledge concerning such a
disposition or loss and the-contents of the document, and t
identify each document evidencing its prior existence i
I and/or any fact concerning its nonexistence or loss.
L.
These interrogatories and document requests shall be continuing in nature as required by 10 C.F.R. S 2.740 (e).
l Thus, any time MFP obtains information that renders any-j f
previous response incorrect-or incomplete, or which-l i
indicates that.a response was incorrect or incomplete j
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- L when made, MFP musi supplement its ' previous response.
Such supplements should be provided)in a timely fashion.
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'I INTERROGATORIES /REOUESTS FOR DOCUMENTS A-1 Identify the name,. profession, ' employer, and area of professional expertise' of each person whom MFP expects to?
call as a witness, including any expert witness, at the hearing on this matter.
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A-2 Identify the contentions relating to which and specific.'
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to the subject matter on which each witness is expected
'I to testify at the hearing.
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A-3 Identify all documents, and all pertinent pages or parts thereof, that each witness has been shown.to date and any.
j other documents the. witness will rely. upon' or ' will' l
1 otherwise use for his/her. testimony at the hearing.
}
.i A-4 Provide copies of all documents identified in response to.
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A-3 above that are not documents provided to MFP by PG&E and that are not otherwise available to PG&E.
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l A-5 Identify the educational and professional experience 6f each witness identified in A-1 above.
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A-6 Identify all persons known to MFP, and with whom MFP will' l
consult or ' rely; or with whom MFP has consulted or relied upon,. regardless of. whether. they willi be called as.a witness, who have knowledge.with respect' to Contentions I and V, as admitted in the Licensing. Board's Prehearing Conference
- Order, dated January 21,
- 1993, (and as clarified in the Memorandum and Order dated February.9,.
i i
1993).
-1 A-7
'dith respect to all persons identified in response' to A-6' above:
~l A-7.1 Describe the nature of each communication, l
conversation,.
or consultation with._
such i
individual, and when it occurred.
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A-7.2 Describe all 'information - received from such -
individual.
'i A-7.3 Identify each letter,. memorandum, tape,.noto
.t or other record related to each conversation, 1
consultation, correspondence or other communication with such individual.
A-7.4 Provide a copy of any document identified in response to A-7.3 i ;
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Respectfully. submitted,
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.w Joseph B.
Knotts,--Jr)
- j
. David A...Repka-
- l Kathryn M. Kalowsky' WINSTON~& STRAWN 1400 L Street,-N.W.
Washington, D.C.
20005 (202) 371-5700
. Attorneys foriPacific Gas and' Electric Company'
' Dated at Washington, D.C.
this.19th day of February, 1993.
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4 UNITED STATES OF AMERICA L
i NUCLEAR REGULATORY COMMISSION BEFORE 'THE ATOMIC SAFETY AND LICENSING BOARD 93 F0B 22 M2 :06 lr;to aMiht 4 In the Matter of:
)
bacMide L (iv!CT
)
Docket Nos. 50-275-OLANP Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Power
)
Recapture)
Plant, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "FACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS" 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 (*),
by Federal Express, this 19th day of February, 1993:
Charles Bechhoefer, Chairman Frederick J.
Shon Administrative Judge Administrative Judge Atomic Safety and' Licensing Board Atomic Safety and Licensing Board U.S.
Nuclear Regulatory. Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Office of the Secretary Office of Commission Appellate U.S. Nuclear Regulatory Commission Adjudication Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn:
Docketing and Service Washington, DC 20555 Section (original + two copies)
Adjudicatory File Ann P. Hodgdon, Esq.
Atomic Safety and Licensing Office of the General Counsel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC' 20555 Nancy Culver
- Peter Arth, Jr.
Prasident, Board of Directors Edward W.
O'Neill San Luis Obispo Mothers for Peace Peter G.
Fairchild 192 Luneta Street California Public Utilities San Luis Obispo, CA 93401 Commission 505 Van Ness Avenue San Francisco, CA 94102 Jerry R. Kline Truman Burns Administrative Judge California Public Utilities Atomic Safety and Licensing Board Commission U.S.
Nuclear Regulatory Commission 505 Van Ness, Rm. 4103 Washington, DC 20555 San Francisco, CA 94102
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Christopher J. - Warner,: Esq.
Robert R. Wellington, Esq.
Richard F. Locke, Esq..
Diablo Canyon Independent Safety Committee Pacific Gas &. Electric Company l
857 Cass Street, Suite D 77 Beale Street Monterey,.CA 93940 San Francisco, CA. 94106' Robert Kinosian California Public Utilities Commission k9 102 Sa Fr n
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a.,xA A Nersk i
David A.
Repka
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Counsel for Pacific Gas &
Electric Company-
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