ML20083E506

First Round Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14-15 & 18. Certificate of Svc Encl

ML20083E506
Person / Time
Site:	Catawba
Issue date:	12/22/1983
From:	Carr A, Mcgarry J DEBEVOISE & LIBERMAN, DUKE POWER CO.
To:	CAROLINA ENVIRONMENTAL STUDY GROUP, PALMETTO ALLIANCE
References
NUDOCS 8312290245
Download: ML20083E506 (8)

Text

m 00CHETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 83 DEC 27 All:07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD uh lit OF EED Ge C00 SITING i SE;.e:

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In the Matter of )

)

DUKE POWER COMPANY, et al. ) Docket No. 50-413

) 50-414 (Catawba Nuclear Station )

Units 1 and 2) )

APPLICANTS' FIRST ROUND OF INTERROGATORIES AND REQUESTS TO PRODUCE TO CAROLINA ENVIRONMENTAL STUDY GROUP AND PALMETTO ALLIANCE REGARDING PALMETTO ALLIANCE'S AND CAROLINA ENVIRONMENTAL STUDY GROUP'S EMERGENCY PLANNING CONTENTIONS 1,3,6,7,8,9,11,14,15, AND 18 Pursuant to 10 C.F.R. SS2.740b and 2.741, Duke Power Company, et al.

(" Applicants") hereby serve Applicants' Interrogatories and Requests to Produce upon Intervenors Palmetto Alliance and Carolina Environmental Study Group ("CESG") regarding Emergency Planning Contentions 1,3,6,7,8,9, 11, 14, 15, and 18.

Each interrogatory shall be answered fully 4n writing, under oath or affirmation, and include all pertinent information known to CESG/ Palmetto Alliance, its officers, directors, or members as well as any pertinent information known to its employees, ad'isors, v representatives or counsel. In any case in which the answer by CESG i; different from the answer by Palmetto Alliance, separate answers should be provided. Each request to produce applies to pertinent documents which are in the possession, custody or control of CESG/ Palmetto Alliance, its officers, directors or members as well as its employees, advisors, representatives or counsel. In answering each interrogatory and in responding to each request, recite the 4

interrogatory or request preceding each answer or response.

8312290245 831222 03 DR ADCCK 05000413

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PDR __ _ _ _ _

t These interrogatories and requests shall be continuing in nature. Thus, any time CESG/ Palmetto Alliance obtains information which renders any previ-ous response incorrect or indicates that a response was incorrect when made, CESG/ Palmetto Alliance should supplement its previous response to the appro-priate interrogatory or request to produce. CESG/ Palmetto Alliance should also supplement its, responses as necessary with respect to identification of each person expected to be called at the hearing as a witness, the subject matter of his or her testimony, and the substance of that testimony. Appli-cants are particularly interested in the names and areas of expertise or factual knowledge of CESG/ Palmetto Alliance witnesses, if any. The term

" documents" shall include any writings, drawings, graphs, charts, photo-graphs, and other data compilations from which information can be obtained.

We request that at a date or dates (within the time provided for discovery) to be agreed upon, CESG/ Palmetto Alliance make available for inspection and copying all documents subject to the requests set forth below.

REQUESTS FOR DOCUMENTS Pursuant to 10 C.F.R. 52.741, Applicants request CESG and Palmetto Alli-ance by and through their representative or attorney to make available for inspection and copying, at a time and location to be designated, any and all documents of whatsoever description identified in the responses to the Applicants' interrogatories below; including, but not limited to:

. (1) any written record of any oral communication between or among Intervenors, their advisors, consultants, agehts, attorneys, and/or any other (2)

persons, including but not limited to the NRC Staff, the Applicants, and their advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letters, memoranda, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.

If CESG or Palmetto Alliance maintains that some documents should not be made available for inspectio.*, they should specify the documents and explain why such are not being made available. This requirement extends to any such documents, described above, in the possession of CESG or Palmetto Alliance, their advisors, consultants, representatives, or attorneys.

INTERROGATORIES pursuant to 10 C.F.R. 92.740b, the Applicants request CESG and Palmetto Alliance by and through their representatives or attorneys to answer sepa-rately and fully in writing, under oath or affirmation, by persons having knowledge of the information requested, the following interrogatories as to each of the Emergency Planning Contentions admitted as an issue in contro-versy in this proceeding.

1. State the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof

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he or she answered.

(3)

2.- Identify each and every person you plan to call or are considering calling as a witness at the hearing in this matter on this contention, and with respect to each such person:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a summiry of the grounds for each opinion; and

c. Describe the witness's educational and professional background.

3. Is the contention based on one or more studies (including calculations and analyses)?

a. Describe each study and identify any documents setting forth su.ch study.

b. Indicate who performed each study.

c. Indicate when each study was performed.

d. Describe each parameter used in such study and each value assigned to the parameter, and describe the source of your data.

e. Indicate the results of each study.

f. Explain in detail how each study provides a basis for the issue.

4. Is the contention based upon conversations, consultations, correspondence or any other type of communications with one or more individual? If so:

a. Identify by name and address each such individual.

. b. State the educational 6nd professional background of each such individual, including occupation and institutional affiliations.

c. Describe the natu're of each communication with (4)

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

d. Describe the information received from such individuals and explain how it provides a basis for the issue.

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

Respectfully submitted,

. W M

• dr f J. Michael McGarry, III DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9833 Albert V. Carr, Jr.

Ronald V. Shearin DUKE POWER COMPANY P. O. Box 33189 Charlotte, North Carolina 28242 (704) 373-2570 Attorneys for Duke Power Company, et al.

December 22, 1983 (5)

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- 00LKETED US!!R" UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '83 DEC 27 All:07 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FF:t- 0F SL.rt_.;

00CrEiiNG & SE?e BRANCH In the Matter of )

)

DUKE POWER COMPANY, et al. ) Docket No. 50-413

) 50-414 (Catawba Nuclear Station )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' First Round Of Interrogatories and Requests To Produce to Carolina Environmental Study Group And Palmetto Alliance Regarding Palmetto Alliance's and Carolina Environmental Study Group's Emergency Planning Contentions 1,3,6,7,8,9,11,14,15, And 18" in the above captioned matter have been served upon the following by deposit in the United States mail this 22nd day of December, 1983.

James L. Kelley, Chairman Richard P. Wilson, Esq.

Atomic Safety and Licensing Board Assistant Attorney General Panel State of South Carolina U. S. Nuclear Regulatory Commission P. O. Box 11549 Washington, D. C. 20555 Columbia, South Carolina 29211 Dr. Paul W. Purdom Robert Guild, Esq.

235 Columbia Drive Attorney-at-Law Decatur, Georgia 30030 P. O. Box 12097 Charleston, South Carolina 29412 Dr. Richard F. Foster Palmetto Alliance P. O. Box 4263 2135 1/2 Devine Street Sunriver, Oregon 97702 Columbia, South Carolina 29205 Chairman Jesse L. Riley Atomic Safety and Licensing 854 Henley Place Board Panel Charlotte, North Carolina 28207 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman Henry A. Presler Atomic Safety and Licensing 945 Henley Place Appeal Board Charlotte, North Carolina 28207 U. S. Nuclear Regulatory Commission Washingten, D.C. 20555

George *E. Johnson, Esq. Karen E. Long Office of the Executive Legal Assistant Attorney General Director N. C. Department of Justice U. S. Nuclear Regulatory Commission P. O. Box 629 Washington, D.C. 20555 Raleigh, North Carolina 27602 Scott Stucky Don R. Willard Docketing and Service Section Mecklenburg County U. S. Nuclear Regulatory Department of Environmental Commission Health Washington, D.C. 20555 1200 Blythe Boulevard Charlotte, North Carolina 28203 L ag v. n a Ronald V. Shearin

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DUKE POWEIt GOMPANY

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Robert Guild, Esquire Attorney for Palmetto Alliance Post Office Box 12097 Charleston, South Carolina 29412 -

Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 Re: Duke Power Company, et al. (Catawba Nuclear Station, Units I and 2), Docket Nos. 50-413 and 50-414 Gentlemen:

Enclosed are our initial interrogatories on emergency planning contentions. Through these general interrogatories, we are seeking information on anticipated witnesses and documents to be relied upon as to each contention so that we can pursue further discovery and begin preparation for trial.

As indicated in our letter to you of Decemoer 9, 1983, we have available for your review, inspection, and/or copying a number of documents requested at our informal discovery conference. Please advise us as to when you would like to review these documents.

Very truly yours,

&&W Ronald V. Shearin Assistant General Counsel RVS/dm Encl.

c: Service List -

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