ML20235M155
| ML20235M155 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 05/28/1987 |
| From: | Fiedler S FIELDER, S.L. |
| To: | Lazo R Atomic Safety and Licensing Board Panel |
| References | |
| CON-#387-4041 OLA, NUDOCS 8707170082 | |
| Download: ML20235M155 (1) | |
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~ SCOTT L FIELDER Attorney At Law 517 Third Street. Suite 14 DOLKETED Eureka. Cahfornia 95501 U5NRC (707) 444-30 31 '87 JUL 15 A7:48 May 28, 1987 .;rrn CG C y,- K' rr w Robert M. Lazo, Esq. Chairman Atomic Safety and Licensing' Board United States. Nuclear Regulatory Commission Washington, D. C. 20555 Re: Humboldt Bay Proceeding Docket No. 50-133-OLA (Decommissioning) Request for Discovery and for Preservation of Deposition Rights
Dear Mr. Lazo:
Pursuant to 10 CFR 2.720 (h) (2) (i)-(iii), the Interveners request an order, if it is necessary, that the NRC Staff be required by the ASLB-to answer.the questions contained in the attached inter-rogatories. It is the desire of the Interveners, after obtaining the answers-to the aforementioned interrogatories, to also preserve their right to take deposition (s) of the identified NRC Staff witness (es). The Interveners also desire to preeerve their right to take-the depositions of the witnesses the Licensee will call at the time of hearing. As of yet, the Licensee, despite earlier request,.has not disclosed their witnesses, and the Interveners are not aware of which witness (es) the NRC Staff may call. This presents a logistical problem for the Interveners inasmuch as the Board has set a discovery deadline of 30 days after the receipt of the FES/SER. i Therefore, the Interveners respectfully request that the NRC l Staff be required to answer the enclosed interrogatories, and that the~ Interveners' right to take the depositions of the NRC Staff and I Licensee's witnesses be extended until 30 days after disclosure of same. 1 Respectfully, N ~ ll l } i i / Yh! ) T ),/-{/, \\ / SCOTT L. FIELDER Attorney for the Interveners SLF/ccs enc. cc: all parties of record 00$ f l
l j \\' 1 . SCOTT L'. FIELDER Attorney at Law 2 517 Third Street, Suite 14 Eureka, California 95501 3 Telephone:- (707) 444-3031 4 Attorney for the Joint Interveners Douglas H. Bosco, Wesley 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 County 7 8 UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION 10 )) ) Docket No. 50-133 OLA ) (Decommissioning) 12 ) ) ASLBP No. 86-536-07 LA l 13 In The Matter Of ) Pacific Gas and Electric ) JOINT INTERVENERS' FIRST SET OF 14 Company (Humboldt Bay ) INTERROGATORIES PROPOUNDED TO Power Plant, Unit No. 3) ) THE NRC STAFF 15 16 1. PROPOUNDING PARTY: The Joint Interveners LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, 17 DANIEL E. HAUSER, BARRY KEENE, i DOUGLAS H. BOSCO, WESLEY CHESBRO, 18 REDWOOD ALLIANCE, RALPH KRAUS, NONA KRAUS and GAYE M. BARR 19 2. SET NUMBER: ONE 20 3. RESPONDING PARTY: NRC STAFF 21 22 YOU ARE HEREBY REQUESTED to answer under oath the follow-23 ing interrogatories within fourteen (14) days from the time ser-24 vice is made upon you, in accordance with 10 Code of Federal I 25 Regulations section 2.740(b). 26 // 27 // 28 // 4, a, n g, J r PJ 7 o
T* -Q I l 1 t 2 GENERAL PROVISIONS 3 The interrogatories ask not only for your own knowledge 4 5 and the contents of your books and records but also the knowledge 6 of all other persons of whom inquiry may reasonably be made and 7 the contents of your books and records, and those available to 8 you.for examination. Your answers to these interrogatories 9 should be based on all of the aforementioned sources. 10 If, following your exercise of due diligence to answer 11 any interrogatory, you are still unable to provide the informa-12 tion requested, please state in detail: 13 (a) Your answer to the fullest extent possible; 14 (b) Why you are unable to answer more fully; 15 (c) What efforts you have made to answer fully; 10 (d) The anticipated date of your completion of such 17 investigation and discovery necessary to answer 18 fully. 19 When an interrogatory asks you to identify a writing, attach a copy 20 you may in lieu of answering that interrogatory, 21 of that writing with a statement in answer to the interrogatory 22 that such copy is attached and cuch copy is s true copy of the 23 original of the writing. If you refuse to voluntarily attach 24 a copy of that writing, then identify each such writing in 25 detail so that it may be produced by you in response to a 26 Notice to Produce or other discovery devices. 27 // 28 // __
I. 1 II 2 DEFINITIONS 3 4 When used in these interrogatories and for purposes 5 thereof: 6 (a) Licensee means and refers to Pacific Gas and 7 Electric company, its agents, employees, servants, 8 representatives, and anyone acting on its behalf 9 or at its request; 10 (b) Facility means and refers to the Humboldt Bay Il Power Plant, Unit No. 3; 12 (c) Writing means handwriting, typewriting, printing 13 photostating, photographing,.and'every other means 14 of recofding upon any tangible thing any form of 15 communication or representation including letters, 16 words, pictures, sounds, or symbols, or combination 17 thereof. 18 10 20 INTERROGATORY No. 1 21 For each Contention which has been admitted by the i 22 Licensing Board in the Prehearing Conference Order dated December 23 3, 1986, in the above-captioned proceeding, list the following: 24 (a) The identity of each person expected to be called 25 as a witness at the hearing; 26 (b) The subject matter on which the witness is expected l 27 to testify; 28 (c) The substance of the witness's testimony; and, j 1 (d) The witness's professional or other qualifications 2 to testify on the subject matter on which the 3 witness will testify. 4 Respectfully submitted, j 5 Dated: -3/23 /y'/ 6 / / - ,.? y 8 ./ ' hkb Ng' y% SCDTT L. FIELDER O Attorney for the Interveners i i 10 11 12 13 14 15 16 17 18 10 20 21 l 22 23 24 25 26 27 28 ~
t- .h l PROOF OF SERVICE I am a resident of the County of Humboldt; I am over the age of eighteen years and not a party to the within action,e my i business address is 517 -- 3rd Street, suite 14, Eureka, Cal.ifornia, 95501. On (1 M I served the withi'n; I JOINTINT$:RVENORS' FIRST SET OF INTERROGATORIES PROPOUNDED TO THE NRC STAFF on the interested parties in said action j l (xx) By placing a true copy thereof enclosed in a sealed en - velope with postage thereon fully prepaid, in the United f States mail at Eureka, California, addressed as listed below. ( ) By personally delivering a true copy thereof to the persons listed below. I declare under penalty of perjury that the foregoing is true and correct. b Executed at Eureka, California, on itt t 1 CLAUDETTE C. SMITH t SEE ATTACHMENT j ) l
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United States Nuclear Regulatory Commission Public Document Room 1717 "H" Street NW . Washington, D.C. 20555 l I 3 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 i Dr. James H. Carpenter, Member Atomic Safety & Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C. 20555 I Dr. Peter A. Morris, Member ' Atomic Safety and Licensing Board Panel ' United States Nuclear Regulatory Commission 1 Washington, D. C. 20555 Ralph and Nona Kraus 2479 Wrigley Road Eureka, California 95501 1 i l p
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i-... H ' Lt ] l ' ATTACHMENT (Continued) 1 1 l Honorable Dan Hauser l Assemblyman, 2nd District 1334 Fifth Street Eureka, California 95501 \\ i Honorable Barry Keene 1 Second Senate District ) 533"G" Stree Eureka, California 95501 j 3 l Honorable Doug Bosco j U. S. congressman 517.7th Street-Eureka, California 95501 Honorable Wesley Chesbro Supervisor, Third District P. 0.. Box 4661 Arcata, California 95521 Redwood Alliance P. O. Box 293 Arcata, California 95521 l Gaye M. Barr 1 1217.Searles St. 1 Eureka, CA 95501 Kathleen Maloney, Attorney at Law PUC Legal Division 505 Van Ness Ave. San Francisco, CA 941u2}}