ML20215K937
| ML20215K937 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 05/01/1987 |
| From: | Fielder S JOINT INTERVENORS - HUMBOLDT BAY |
| To: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#287-3378 86-536-07-LA, 86-536-7-LA, OLA, NUDOCS 8705120042 | |
| Download: ML20215K937 (6) | |
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SCOTT L. FIELDER Attorney at Law 2
517 Third Street, Suite 14 Eureka, California 95501
'87 MAY -5 P5 :42 3
Telephone:
(707) 444-3031 4
Attorney for the Joint Intervenors 0FFKE U :! L,.f tt, t Douglas H. Bosco, Wesley Chesbro, DMjyg
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Daniel E. Hauser, Barry Keene, The Redwood Alliance, Ralph Krause, 6
Nona Krause, Gaye M. Barr and the League of Women Voters of Humboldt 7
County UNITED STATES OF AMERICA g
NUCLEAR REGULATORY COMMISSION g
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Docket No. 50-133-OLA gj
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(Decommissioning) 12
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ASLBP No. 86-536-07 LA 13 In The Matter Of
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Pacific Gas and Electric)
JOINT INTERVENORS' RESPONSE TO FIRST
}4 Company (Humboldt Bay
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SET OF INTERROGATORIES PROPOUNDED BY Power Plant,
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THE NRC STAFF 15 Unit No. 3)
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16 17 1.
PROPOUNDING PARTY:
NRC Staff jg 2.
SET NUMBER:
One
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RESPONDING PARTY:
The Joint Intervenors LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, DANIEL E.
20 HAUSER, BARRY KEENE, DOUGLAS H. BOSCO, 21 WESLEY CHESBRO, THE REDWOOD ALLIANCE, 22 RALPH KRAUSE, NONA KRAUSE, and GAYE M.
23 DARR.
24 It should be noted that this responding party has not 25 fully completed its investigation of the facts relating to this 26 case, has not fully completed its discovery in this action and i
27 has not completed its preparation for the trial.
All of the 2g 8705120042 870501
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PDR ADOCK 05000133
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Q PDR answers contained herein are based only upon such information 1
and documents which are presently available to and specifically 2
3 known to this responding party and disclose only those contentions 4
which presently occur to such responding party.
It is anticipated 5
that further discovery, independent investigation, legal research, 6
and analysis will supply additional facts, add meaning to the known facts, as well as establish entirely new factual conclusions 7
and legal contentions, all of which may lead to substantial g
9 additions to, changes in, and variations from the contentions 10 herein set forth.
The following interrogatory responses are
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given without prejudice to responding party's right to produce evidence of any subsequently discovered fact or facts which 12 13 this responding party may later develop.
Responding party accordingly reserves the right to change any and all answers
}4 herein as additional facts are ascertained, analyses are made, 15 16 legal research is completed and contentions are made.
The answers contained herein are made in a good faith effort to 17 supply as much factual information and as muc'h specification jg of legal contentions as is presently known but should in no way jg be to the prejudice of the joint intervenors in relation to 20 further discovery, research, or analysis.
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Responses to Interrogatories
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(A)
The joint intervenors have not yet decided which persons 3
they expect to call as witnesses at the hearing as of this date.
4 However, when witnesses are settled upon by the joint intervenors, 5
thin information will be provided.
6 1.
(B)
The joint intervenors have not yet decided which persons 7
they expect to call as witnesses at the hearing as of this date.
8 However, when witnesses are settled upon by the joint intervenors, 9
this information will be provided.
10 1.
(C)
The joint intervenors have not yet decided which persons 11 they expect to call as witnesses at the hearing as of this date.
12 However, when witnesses are settled upon by the joint intervenors, 13 this information will be provided.
14 1.
(D)
The joint intervenors have not yet decided which persons 15 they expect to call as witnesses at the hearing as of this date.
16 However, when witnesses are settled upon by the joint intervenors, 17 this information will be provided.
18 19 Dated:
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SCOTT D.
FIELDER 22 Attorney for The Joint Intervenors 23 24 25 26 27 28 -
DOCKETED USNPC PROOF OF SERVICE 17 MM -5 P5 :42 I am a resident of the County o f umboldt.% I'am Ek$$36theC'ithin V
over the age of eighteen years and not a My business address if 517 Third Streek,', Suite 14, action.
Eureka, California, 95501.
I served the On MAY 1, 1987 within RESPONSE TO THE FIRST SET OF INTERROGATORTER PRnpot1Mnrn BY THE NRC STAFF on the interested parties in said action by:
(xy 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;
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personally delivering a true copy thereof to the persons listed below.
I declare under penalty of perjury that the foregoing is true and correct.
Executed at Eureka, California, on ll\\fltt_
Ih 9 4
dlL CLAUDETTE C. SMITH DROOF OF SERVICE e
SEE ATTACHMENT I
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 and Electric Company P. O. Box 7442 San Francisco, CA 94120 Mr. Bruce Norton
'f c/o Richard F. Locke Pacific Gas and 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 and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C. 20555
ATTACHMENT (con't)_
Dr. Peter A. Morris, Member.
Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.C.
20555 Ralph and Nona Krause 2479 Wrigley Road Eureka, California 95501 Hono'rable. Dan Hauser Assemblyman, 2nd District 1334 Fifth Street Eureka, California 95F01 Honorable Barry Keene Second Senate District 533 "G" Street Eureka, California 95501 Honorable Doug Bosco U.S. Congressman 517 Seventh Street Eureka, California 95501 Honorable Wesley Chesbro Supervisor, Third District Post Office Box 4661 Arcata, California 95521 Redwood Alliance Post Office Box 293 Arcata, California 95521 i
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