ML20077H728

Third Set of Interrogatories & Second Request for Production of Documents.Related Correspondence

ML20077H728
Person / Time
Site:	Diablo Canyon
Issue date:	08/04/1983
From:	Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO.
To:	CALIFORNIA, STATE OF
Shared Package
ML20077H729	List: ML20077H728 ML20077H736
References
NUDOCS 8308110249
Download: ML20077H728 (6)

Text

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8 1 UNITED STATES OF AMERICA { 3 19 g 3 A g_t; 2 NUCLEAR REGULATORY COMMISSION .7 3 #ce t$. '

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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

' 5 6

7 In the Matter of )

8 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 i

9 )

Diablo Canyon Nuclear Power Plant ) (Reopened Hearing --

10 Units No. 1 and 2 ) Design Quality

) Assurance) 11

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12 13 14 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S THIRD SET OF INTERROGATORIES TO GOVERNOR DEUKMEJIAN 15 AND SECOND REQUEST FOR PRODUCTION OF DOCUMENTS 16 17 18 I 19 INTERROGATORIES 20 1. Identify each and every person you . intend to 21 or may call as a witness during these proceedings. As to 22 each such witness, state:

23 (a) Name, occupation, occupational address and i

! 24 telephone number. l l

l 25 (b) lWhether the - witness will render. expert 26 testimony.

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l 1 (c) If the witness will render expert testimony, 2 please list each specific subject matter about which the 3 witness will be expected to testiify.

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4 (d) If the witness will be called to give expert

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5 testimony, please list the specific qualificatiions of the

6 witness that you contend would qualify the witness to give

7 opinion testimony on each specific subject matter about i

l 8 which the witness will testify.

I j 9 (e) List each and every professional article, 10 book, or the like, if any, the witness has authored or

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l 11 co-authored concerning each specific subject matter set i

j 12 forth in your answer to 1(c).

i l 13 (f) Identify each and every document the witness i

14 will rely on to reach any opinion testimony and specifically

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f 15 corollate each such document (by page and paragraph number) 16 to each specific subject matter on which the witness will

! 17 render an opinion.

18 (g) As to each specific subject matter identified 19 in your answer to 1(c), identify by docket number and case 20 name each Nuclear Regulatory Commission licensing proceeding 21 where the witness has previously given expert testimony 22 concerning each specific subject matter.

23 (h) As to each proceeding identified in your 24 answer to 1(g), please state:

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1 (i) The date(s) the expert testimony was 2 given.

3 (ii) Whether you have a copy of the testimony i

4 given.

5 (iii) Whether you have a copy' of the 6 transcript covering any or all of the witness' 7 examination and/or cross-examination for each such 8 proceeding.

9 (iv) Whether you hav6 a copy of any notes 10 which. the witness made in preparation for, or 11 utilized during, the witness' examination or 12 cross-examination in each such proceeding.

13 (i) As to each specific subject matter identified 14 in your answer to 1(c), identify by docket number and court 15 name each legal proceeding where the witness has previously 16 given expert testimony concerning each specific subject 17 matter.

18 (j) As to each proceeding identified in your 19 answer to 1(i), please state:

i 20 (i) The date(s) the expert testimony was 21 given.

I 22 (ii) Whether you have a copy of the 1

23 transcript covering any or all of the witness' 24 examination and/or cross-examination for each such 25 Proceeding.

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. e 1 (iii) Whether you have a copy of any notes 2 which the witness made in preparation for, or

! 3 utilized during, the witness' examination or l

4 cross-examination in each such proceeding.

5 (k) As to each specific subject mattier identified 6 in your answer to 1(c), identify committees and 7 organizations where the witness has previously given 8 testimony concerning each specific subject matter.

I 9 (1) As to each committee or organization -

10 identified in 1(k), please state:

, 11 (i) The date(s) the testimony was given.

I

! 12 (ii) Whether you have a copy of the testimony 13 given.

14 (iii) Whether you have a ' copy of the 15 transcript covering any or all of the witness' 16 examination and/or cross-examination for each such 17 proceeding.

18 (iv) Whether you have a copy of any notes 19 which the witness made in preparation for, 'or

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20 utilized during, the witness' testimony and/or 21 examination and/or cross-examination in each such 22 proceeding.

23 2. Please set forth with particularity each and l

l 24 every exhibit you intend to mark for identification at the 25 reopened hearings on design quality assurance. '

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e 1 3. List specifically, including page and section 2 number, each and every license commitment set forth in the 3 Diablo Canyon FSAR which you allege has not been complied 4 with.

5 4. For each license commitment identified in 6 your response to the preceding interrogatory, state in 7 detail each and every fact- upon which you base your 8 allegation that the license commitment has not been met.

9 5. Specifically identify each and every document 10 which you claim supports each fact set forth in your 11 response to the preceding interrogatory and correlate each I

12 such document (by page and paragraph number) with each such 13 fact.

14 II 15 REQUEST FOR PRODUCTION OF DOCUMENTS 16 1. Pursuant to C.F.R. 52.241, you are requested 17 to produce each document identified in the answers to the 18 interrogatories above and in the answers to Licensee's l 19 Second Set of Interrogatories to Governor Deukmejian dated i

! 20 July 27, 1983.

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-u 1 The documents should be produced on September 5, 2 1983 at 9:30 a.m. at the 31st floor conference room, 3 77 Beale Street, San Francisco.

4 5

6 .

7 Respectfully submitted, 8

ROBERT OHLBACH 9 PHILIP A. CRANE, JR.

RICHARD F. LOCKE 10 Pacific Gas and Electric Company P.O. Box 7442 11 San Francisco, California 94120 (415) 781-4211 12 ARTHUR C. GEHR 13 Snell & Wilmer 3100 Valley Center 14 Phoenix, Arizona 85073 (602) 257-7288 15 BRUCE NORTON 16 Norton, Burke, Berry & French, P.C.

P.O. Box 10569 17 Phoenix, Arizona 85064

(602) 955-2446

! 18 Attorneys for 19 Pacific Gas and Electric Company l

20 By 0 22 Bruce ~Norton 23 24 DATED: August 4, 1983.

l 25 26

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