ML20214P279

Joint Intervenors Third Set of Interrogatories Propounded to Pg&E.* Util Requested to Answer Under Oath to Listed Interrogatories within 14 Days.Proof of Svc Encl.Related Correspondence

ML20214P279
Person / Time
Site:	Humboldt Bay
Issue date:	05/28/1987
From:	Fielder S FIELDER, S.L., JOINT INTERVENORS - HUMBOLDT BAY
To:	PACIFIC GAS & ELECTRIC CO.
References
CON-#287-3623 86-536-07-LA, 86-536-7-LA, OLA, NUDOCS 8706030290
Download: ML20214P279 (7)

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1 SCOTT L. FIELDER 2{((hf Attorney at Law 2 517 Third Street, Suite 14 Eureka, California 95501 '87 JE -1 P2 :00 3 Telephone: (707) 444-3331 4 Attorney for the Joint Intervenors j((g' .

Douglas H. Bosco, Wcaley Chesbro, 5 Daniel E. Hauser, Barry Keene, The Redwood Alliance, Ralph Kraus, Nona 6 Kraus, Gaye M. Barr and the League of Women Voters of Humboldt 7 County 8 UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION 10 1] ) Docket No. 50-133-OLA

) (Dacommissioning) 12 )

) ASLBP No. 86-536-07 LA 13 )

) JOINT INTERVENORS' THIRD 14 In The Matter Of ) SET OF INTERROGATORIES Pacific Gas and Electric ) PROPOUNDED TO THE LICENSEE 15 Company (Humboldt Bay Power ) PACIFIC GAS AND ELECTRIC Plant, Unit No. 3) ,

) COMPANY 16 17 1. PROPOUNDING PARTY: The Joint Intervenors LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, 18 DANIEL E. HAUSER, BARRY KEENE, DOUGLAS H. BOSCO, WESLEY CHESBRO, REDWOOD ALLIANCE, RALPH KRAUS, 19 NONA KRAUS and GAYE M. BARR 20 21 2. SET NUMBER: THREE 22 3. RESPONDING PARTY: The Licensee, PACIFIC GAS AND ELECTRIC COMPANY 23 24 YOU ARE HEREBY REQUESTED to answer under oath the 25 following interrogatories within fourteen (14) days from the 26 time service is made upon you, in accordance with 10 Code of 27 Federal Regulations section 2.740(b).

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.1 GENERAL PROVISIONS 2

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- .The interrogatories ask not only for your own knowledge

! 5 and the contents of your books'and records, but also-the- ,

6 knowledge of.all other persons of whom inquiry may-reasonably l-7 be made :and the contents of your books and records, and those .

g available to you for examination. Your answers to these g interrogatories.should be based on all of the aforementioned 10 sources.

11 If, following your exercise of due diligence to answer-12 any interrogatory, you are still unable to provide the.informa-13 tion requested, please state in detail:

(a) Your answer to the fullest extent possible; 14 15 (b) Why you are unable to answer more fully; 16 (c) What efforts you have made to answer fully; 17 (d) The anticipated date of your completion of such 18 investigation and discovery necessary to answer 19 fully.

20 When an interrogatory asks you to identify a writing,-

g] you may, in lieu of answering that interrogatory, attach a copy 22 of that writing with a statement in answer to.the interrogatory 23 that such co'py is attached and such copy is a true copy of the 24 original of the writing. If you refuse to voluntarily attach 25 a copy of that writing, then identify each such writing in 26 detail so that it may be produced by you in response to a 27 Notice tc Produce or other discovery devices.

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II 2 DEFINITIONS

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When used in these interrogatories and-for purposes 3

5 thereof:

4 6 (a) Licensee means and refers to Pacific' Gas and 7 Electric Company, its agents, employees, servants, representa-4 8 tives, and anyone acting on its behalf or at its request.

9 (b) Facility means and refers to the Humboldt Bay-10 Power Plant, Unit No. 3.

i 11 (c) Writing means. handwriting, typewriting, printing, 12 photostating, photographing, and every other means of recording

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upon any tangible thing any form of communication or representa-

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14 tions including letters, words, pictures, sounds, or symbols, 15 or combination thereof.

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17 18 19 INTERROGATORY No. 160 20 For aach Contention which has been' admitted by the

. 21 Licensing Board in the Prehearing Conference Order, dated jl 22 December 3, 1986, in the above-captioned proceeding, state the l 23 following:

24 a. The identity of each person expected to be called 25 as a witness at the hearing;

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26 b. The subject matter on which the witness is expected 27 to testify; 28 c. The substance of the witness's testimony; and, 1

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1 1 d. The witness's professional or other qualifications to 2 testify on the subject matter on which the witness 3 will eeseify, 4

5 cated: 6// 2 8/3 7

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Respectfully submitted, 6

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SCOTT L. FIELDER 0 Attorney for the Intervenors 10 11 12 13 14 15 16 17 18 19 20 21 22 23 .

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9,:. r PROOF OF SERVICE

'87 JJi -1 P2 :00 I am a resident of the County of_H.umboldt. I am over the age of eighteen years and not a g reat,'. y,to the within action. My business address if 517 Third '

Suits 14, Eureka, California, 95501.

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(9 F7 , I served the within JOINT TNTEDVENnDC' muTon egm OF INTERROGATORTER punonnMnpn TO THE LICENRFP DAPTFTc cne nun erygmpeg gg,s77;m on the interested parties in said action by:

(X) placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Eureka, California, addressed as listed below;

( ) personally delivering a true copy thereof to the persons listed below.

I declare under penalty of perjury that the foregoing is true and correct.

Exc uted at Eureka, California, on (1.M i f h.

b CLAUDETTE C. SMITH DROOP OF SERVICE SEE ATTACHMENT 4

w 1-ATTACHMENT United-States Nuclear Regulatory Commission Public' Document Room 1717 "H" Street NW Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D. C. 20555 Richard F. Locke Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94120 Mr. Bruce Norton c/o~ Richard F. Locke Pacific Gas & Electric Company P. O. Box 7442 San Francisco, CA 94120 Mitzi Young, Esq.

Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D. C. 20555-Secretary United States Nuclear Regulatory Commission Washington, D. C. 20555 Robert M. Lazo, Esq.

Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C. 20555 Dr. James H. Carpenter, Member Atomic Safety & Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Peter A. Morris, Member Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission

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1 Washington, D. C. 20555 Ralph and Nona Kraus 2479 Wrigley Road Eureka, California 95501

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.i ATTACHMENT (Continued)

Honorable Dan Hauser Assemblyman, 2nd District 1334 Fifth Street-Eureka, California 95501 Honorable Barry Keene Second Senate District 533"G" Stree Eureka, California 95501 Honorable Doug Bosco ,

U. S. congressman 517 7th Street Eureka, California 95501 Honorable Wesley Chesbro Supervisor, Third District P. O. Box 4661 Arcata, California 95521 Redwood Alliance P. O. Box 293 Arcata, California 95521 Gaye M. Barr 1217 Searles St.

Eureka, CA 95501 Kathleen Maloney, Attorney at Law PUC Legal Division 505 Van Ness Ave.

San Francisco, CA 94102 I

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