ML20083G562

Preliminary Set of Initial Interrogatories & Request for Production of Documents.Certificate of Svc Encl

ML20083G562
Person / Time
Site:	Hope Creek
Issue date:	01/03/1984
From:	Conner T CONNER & WETTERHAHN, Public Service Enterprise Group
To:	DELAWARE, STATE OF
References
ISSUANCES-OL, NUDOCS 8401060279
Download: ML20083G562 (5)

Text

- __

I DOLKETED l!9 % c UNITED STATES OF AMERICA 84 JNI-5 40:49 NUCLEAR REGULATORY COMMISSION EM_7 ?E t;> -

t Before the Atomic Safety and Licensing Boards A SG

, M: q Public Service Electric and )

Gas Company )

) Docket No. 50-354-OL (Hope Creek Generating )

Station) )

APPLICANTS' PRELIMINARY SET OF INITIAL INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE PUBLIC ADVOCATE AND AND THE STATE OF DELAWARE Pursuant to the Rules of Practice of the Nuclear '.

Regulatory Commission ("NRC") , 10 C.F.R. S2.740b, and the Atomic Safety and Licensing Board's Special Prehearing Conference Order (December 21, 1983) (slip op. at 19-20),

Public Service Electric and Gas Company, et al ("Appli-cants") hereby propound the following preliminary interroga-tories to the Public Advocate of the State of New Jersey and the State of Delaware to be answered fully in writing, under oath, and to be served on Applicants on or before January 18, 1984.

Additionally, pursuant to 10 C.F.R. 52.741, Applicants request that'intervenors produce for inspection and copying (or provide copies of) the documents requested below.

These requests are preliminary in nature in order to ascertain the identity of those deponents who will be examined by Applicants in accordance with the Licensing 8401060279 840105 PDR ADOCK 05000354 G PDR'

)

J o

Board's Special Prehearing Conference Order. Further interrogatories and document requests will be made subse-quently as to specific contentions.

Interrogatories

1. State whether you intend to present any expert witnesses on the subject matter at issue in Contentions 1 through 4. If so, identify each such expert witness and further state (a) his professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each ,

opinion; (e) the expert's business and residential address-es. Identify by court, agency, or other body, each proceed-ing in which such individual rendered testimony on this (these) subject (s).

2. State whether you intend to present any fact witnesses on the subject matter at issue in Contentions 1 through 4. If so, identify each such fact witness and further state (a) his business and residential addresses; (b) the subject matter on which the witness is expected to testify; (c) the substance of the factual testimony which the witness is. expected to offer.

3. Identify by title, author, publisher and date of issuance or publication, all documents that you rely upon as a basis for your contentions or that you intend to use (by way of reference or evidentiary prof fer) in presenting your direct case on Contentions 1 through 4 and all documents to

which you intend to refer in conducting cross-examination of other witnesses who may testify in connection with any such contentions.

Document Request Please attach to your answer (s) to the interrogatories listed above a ccpy of all documents identified in the answers above, or upon which you otherwise intend to rely in the presentation of your direct case or in the cross-examination of other witnesses. Alternatively, state that all such documents will be produced at a reasonable time and place to be agreed upon by the Applicant for inspection and copying.

CONNER & WETTERHAHN, P.C.

v Tro 3 %sp Conner, Jr.

Counsel for the Applicant January 3, 1984 U

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Public Service Electric and )

Gas Company )

) Docket No. 50-354-OL (Hope Creek Generating )

Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Preliminary Set of Initial Interrogatories and Request for Production of Documents to the Public Advocate and the State of Delaware," dated January 3, 1984 in the captioned matter has been served upon the following by deposit in the United ,

States mail this 3rd day of January, 1984: .

Marshall E. Miller Atomic Safety and Chairman Licensing Appeal Panel

• Atomic Safety and U.S. Nuclear Regulatory Licensing Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris U.S. Nucl' ear Regulatory Atomic Safety and Commission Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Docketing and Service Washington, D.C. 20555 Section Office of the Secretary Dr. James H. Carpenter U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission . - Richard J. Goddard, Esq.

Washington, D.C. 20555 Office of the Executive Legal Director Theodore C. Granger U.S. Nuclear Regulatory Deputy Public Advocate Commission Department of the Public Washington, D.C. 20555 Advocate Division of Rate Counsel 744 Broad Street 30th Floor Newark, New Jersey 07102

4 Richard Fryling, Jr., Esq.

Associate General Counsel Public Service Electric &

Gas Company P.O. Box 570 (TSE)

Newark, NJ 07101 R. William Potter, Esq.

Susan C. Remis, Esq.

State of New Jersey Departmen+. of the Public Advocate CN 850 Trenton, New Jersey 08625 Carol Delaney, Esq.

Deputy Attorney General Department of Justice State Office Building 8th Floor 820 N. French Street ,

Wilmington, DE 19810 .

)

(

g g Robert M. Rader

• Federal Express i