ML20063M339

First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20063M339
Person / Time
Site:	Skagit
Issue date:	09/01/1982
From:	Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO.
To:	National Resources Defense Council
Shared Package
ML20063M334	List: ML20063M332 ML20063M335 ML20063M339
References
NUDOCS 8209100264
Download: ML20063M339 (8)

Text

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q g.:1 h\ 50 sCEE}kk 0FF 00 E .^CEge [g [th SER UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter'of )

PUGET SOUND POWER & LIGHT COMPANY, ) Docket Nos. STN 50-522 et al. ) STN 50-523 (Skagit/Hanford Nuclear Project) )

) Date: September 1, 1982 APPLICANTS' FIRST SET OF INTERROGATORIES TO NATURAL RESOURCES DEFENSE COUNCIL Applicants hereby serve their First Set of Interrogatories to the Natural Resources Defense Council (NRDC) pursuant to 10 C.F.R. 5 2.740b. Each interrogatory is to be answered fully in writing, under oath or affirmation, by an officer or agent of NRDC and is to include all pertinent information known to NRDC.

Each answer should clearly indicate the interrogatory to which it is intended to be responsive.

Under NRC regulations (10 C.F.R. $ 2.740(e)) parties are required to supplement responses to interrogatories under certain circumstances when new and/or different information becomes

.available. NRCD is obligated to comply with this requirement with respect to its answers to Applicants' First Set of Inter-rogatories.

l 8209100264 820901 PDR ADOCK 05000522 l C PDR I

l "NRDC" shall include all agents, employees, attorneys, in-vestigators, and all other persons directly or indirectly subject to NRDC's control in any way. "You" and "Yours" refers to NRDC.

" Documents" means all written or recorded material of any kind or character known to NRDC or in its possession, custody, or control, including, without limitation, letters, correspondence,

, telegrams, memoranda, notes, records, minutes, contracts, agree-ments, records or notation of telephone or personal conversations or conferences, inter-office communications, microfilm, bulle-tins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings, computer printouts, and work-sheets.

When used with respect to a document, " identify" means, with-out limitation, to state its date, the type of document (e.g.,

letter, memorandum, telegram, chart, photograph, sound reproduc-tion, etc.), the author and addressees, the present location and custodian, and a description of its contents.

When use with respect to a person, " identify" means, without limitation, to state his or her name, address and occupation.

If NRDC cannot answer any portion of any of the interroga-tories in full, after exercising due diligence to do so, so I state, and answer to the extent possible, specifying the inabil-ity to answer the remainder and stating when NRDC expects to be f able to answer the unanswered portions.

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INTERROGATORIES

1. With respect to the NRDC contentions as phrased and ad-mitted by the Licensing Board in its Memorandum and Order of July 6, 1982, identify all of NRDC's bases for each contention.

1

2. With respect to each basis identified in your answer to Interrogatory 1, state whether the basis is supported by:

A. One or more documents.

B. Any type of study, calculation, or analysis.

C. Research.

D. Conversations, consultations, correspondence, or any other type of communications with one or more individuals.

3. If your answer to Interrogatory 2 is one or more docu-ments:

A. Identify each such document.

B. Identify the information in each document which supports the basis.

C. Explain how such information provides support for the basis.

4. If your answer to Interrogatory 2 is any type of study, calculation, or analysis:

A. Describe the nature of the study, calculation, or analysis and identify any documents which discuss or describe the study, calculation, or analysis.

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B. When and where was the study, calulation or analy-sis performed?

C. Identify the person [s] who performed the study, calculation, or analysis.

D. Describe the results of each study, calculation, or analysis.

E. Explain how such study, calculation, or analysis provides support for the basis.

5. If your answer to Interrogatory 2 is research:

A. Describe all such research and indentify each docu-ment discussing or describing such research.

B. When and where was the research conducted? '

C. Identify the person (s) who conducted the research.

D. Explain how such research provides support for the basis.

6. If your answer to Interrogatory 2 is conversations, con-sultations, correspondence, or any other type of communications with one or more individuals:

A. Identify each such individual.

B. State the educational and professional background of each such individual, including occupation and institu- j tional affiliations.

C. Describe the nature of each communication with each (

such individual, when it occurred, and identify all other individuals involved.

D. Describe the information received from each such individual and explain how it provides support for the basis.

E. Identify each letter, memorandum, tape, note or other record related to each conversation, correspondence, or other communication with such individual.

' 7. Does NRDC intend to offer the testimony of any witnesses at the evidentiary hearings in this proceeding? If yes, A. Identify each such witness.

B. State the educational and professional background of each such witness, including occupation and institutional aff.liations.

C. Specify the sul aatter, by contention and basis, upon which each suen witness will testify.

8. Does NRDC intend to offer any documents for introduction into evidence at the evidentiary hearings in this proceeding? If yes, A. Indentify each such document.

B. Specify the subject matter, by contention and ,

basis, to which each such document relates.

C. Identify the 'information in each such document ^

which relates to the contention and basis.

D. Explain how the information identified in Inter-rogatory 8.C provides support for the contention and basis.

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9. Does NRDC intend to offer any evidence in the evidenti-ary hearings in this proceeding which is not identified in your answer to Interrogatory 7.A or 8.A? If yes,

> A. Identify the nature of each such evidence.

B. Specify the subject matter, by contention and basis, to which each such evidence relates.

C. Explain how such evidence provides support for the contention and basis.

DATED: September 1, 1982 Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WILLIAMS

--f C/1 F. Theodore Thomsen Attorneys for Applicants 1900 Washington Building Seattle, Washington 98101 Phone (206) 682-8770 Of Counsel:

David G. Powell Steven P. Frantz Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W-Washington, D.C. 20036 (202) 862-8400 l ,

r e Uht C UNITED STATE F' Ihn h.9 NUCLEAR REGULA. Y OMMISSION BEFORETHEATOMICSAFSTYICBED5ITMfSINGBOARD 00CW%Cii In the Matter of )

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PUGET SOUND POWE2 & LIGHT COMPANY, ) DOCKET NOS.

et al. )

) STN 50-522 (Skagit/Hanford Nuclear Project, ) STN 50-523 Units 1 and 2) )

)

CERTIFICATE OF SERVICE 1

I hereby certify that the following:

1. Applicants' First Set of Interrogatories to the Coalition for Safe Power;

2. Applicants' First Set of Interrogatories to NWF/OEC; and

3. Applicants' First Set of Interrogatories to Natural Resources Defense Council, in the above-captioned proceeding have been served upon the persons shown on the attached list by depositing copies thereof in the United States mail on September 1, 1982 with proper postage affixed for first class mail.

DATED: September 1, 1982 1 "

F. Theodore Thomsen

! Attorney for Puget Sound Power &

Light' Company l 1900 Washington Building Seattle, Washington 98101

cAYE september 1, 1982 SKAGIT/flANFO?S NUCLEAR PIGJECT NRC Sarvics Lict Dockst Nos. STN 50-522 cnd ETN 50-523 COMMISSION NRC STAFF APPLICANTS (cont.)

Secretary of the Commission Richa rd L. Black, Esq.

Docketing and Service Branch Warren G. Hastings, Esq.

Counsel for the NRC Staf f Associate Corporate Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Executive Legal Portland General Electric Company Director 121 S.W. Salmon Street LICENSING BOARD Portland, OR 97204 Washington, D.C. 20555 John F. Wolf, Esq., Chairman Richard D. Bach, req.

INTERESTED STATES AND COUNTIES Stoel, Rives, Boley, Fraser & Wyse Administrative Judge Atomic Safety and Licensing Board 2300 Georgia Pacific Building 3409 Shepherd Street Washington Energy Facility Site 900 S.W. Fifth Avenue Evaluation Council Portland, OR 97204 Chevy Chase. MD 20015 Nicholas D. Lewis, Chairman Mail Stop PY-Il OTNER Dr. Frank F. Hooper Olympia, WA 98504 Administrative Judge Nina Bell, Staff Intervenor Atomic Safety and Licensing Board Kevin M. Ryan, Esq. Coalition for Safe Power School of Natural Resources Washington Assistant Attorney Suite 527, Governor Building University of Michigan General Ann Arbor, MI 48190 40G S.W. Second Avenue Temple of Justice Portland, OR 97204 Olympia, WA 98504 Mr. Gustave A. Linenberger Ralph Cavanagh, Esq.

Administrative Judge Frank W. Ostrander, Jr. , Esq. Natural Resources Defense Council Atomic Safety and Licensing Board Oregon Assistant Attorney General 25 Kearny Street U.S. Nuclear Regulatory Commission 500 Pacific Duilding San Francisco, CA 94108 Washington, D.C. 20555 520 S.W. Yamhill Portland, OR 97204 Terence L. Thatcher, Esq.

APPEAL BOARD NWF and OEC Bill Sebero, Chairman 708 Dekusa Building Alan S. Rosenthal, Chairman Benton County Commissioner Atomic Safety and Licensing P.O. Box 470 519 S.W. Third Avenue Appeal Board Portland, OR 97204 Prosser, WA 99350 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPLICAfffS Attorney for Columbia River Inter-Tribal Fish Cormaission Dr. John H. Buck, Member F. Theodore Thomsen '

Atomic Safety and Licensing Perkins, Cole, Stone, N Sandy Blvd.

Appeal Board Olsen & Williams Portland, OR 97220 U.S. Nuclear Regulatory Cossaission 1900 Washington Building Washington, D.C. James B. Hovis 20555 Seattle, WA 98101 Yakima Indian Nation Michael C. Farrar, Member c/o Hovis, Cockrill & Roy David G. Powell, Esq. 316 North Third Street Atomic Safety and Licensing Lowenstein, Newman, Reis & Axelrad Appeal Board 1025 Connecticut Avenue N.W. P.O. Box 48] ,

Yakima, WA 98907 U.S. Nuclear Regulatory Conunission Washington, D.C. 20036 Washington, D.C. 20555 James W. Durham, Esq.

Canadian Consulate General Donald Martens, Consul Senior Vice President 412 Plaza 600

• General Counsel and Secretary 6th and Stewart Street Portland General Electric Company Seattle, WA 98101

• 121 S.W. Salmon Street Portland, OR 97204 -

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. 7-26-82