ML20235M241
| ML20235M241 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 05/28/1987 |
| From: | Fiedler S FIELDER, S.L., JOINT INTERVENORS - HUMBOLDT BAY |
| To: | NRC |
| References | |
| CON-#387-4042 86-536-07-LA, 86-536-7-LA, OLA, NUDOCS 8707170119 | |
| Download: ML20235M241 (7) | |
Text
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.3c]7g3 pcmTED fr.'AM4T!iUh3S COLKETED 3 6"C 1
SCOTT L. FIELDER Attorney at Law 2
517 Third Street, Suite 14
,87 JL 15 A7 :48 Eureka, California 95501 3
Telephone:
(707) 444-3031 CP 4
Attorney for the Joint Interveners OGCr Douglas H.
Bosco, Wesley Chesbro, l
5 Daniel E.
Hauser, Barry Keene, The f
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
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10 f
1]
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Docket No. 50-133-OLA
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(Decommissioning) 12
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ASLBP No. 86-536-07 LA 13
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JOINT INTERVENERS' THIRD l
14 In The Matter Of
)
SET OF INTERROGATORIES Pacific Gas and Electric
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PROPOUNDED TO THE LICENSEE 15 Company (Humboldt Bay Power
)
PACIFIC GAS AND ELECTRIC Plant, Unit No. 3)
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COMPANY 16 17 1.
PROPOUNDING PARTY:
The Joi,nt Interveners LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY,
]8 DANIEL E.
HAUSER, BARRY KEENE, DOUGLAS H.
BOSCO, WESLEY CHESBRO, 19 REDWOOD ALLIANCE, RALPH KRAUS, NONA KRAUS and GAYE M.
BARR 20 21 2.
SET NUMBER:
THREE 22 3.
RESPONDING PARTY:
The Licensee, PACIFIC GAS AND ELECTRIC COMPANY 23 YOU ARE HEREBY REQUESTED to answer under oath the g4 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).
28
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8707170119 870528 PDR ADOCK 0500 1 3 9
o T
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GENERAL PROVISIONS 2
3 The interrogatories ask not only for your own knowledge 4
5 and the contents of your books and records, but also the 6
knowledge of all other persons of whom inquiry may reasonably be made and the contents of your books and records, and those 7
g available to you for examination.
Your answers to these 9
interrogatories should be based on all of the aforementioned l
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:
14 (a)
Your answer to the fullest extent possible; 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 J
19 fully.
20 When an. interrogatory asks you to identify a writing, j
in lieu of answering that interrogatory, attach a copy 21 you may, 22 of that writing with a statement in answer to the interrogatory 23 that such copy 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 to Produce or other discovery devices.
28
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l 4,
w
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,. representa-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.
1]
(c)
Writing means handwriting, typewriting, printing, 12 photostating, photographing, and every other means of recording 13 upon any tangible thing any form of communication or representa-
]
14 tions including letters, words, pictures, sounds, or symbols, 15 or combination thereof.
16 17 18 19 INTERROGATORY No. 160 20 For each Contention which has been admitted by the 1
21 Licensing Board in the Prehearing Conference Order, dated I
22 December 3, 1986, in the above-captioned proceeding, state the
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23 following:
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l 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 27 to testify; 28 c.
The substance of the witness's testimony; and, t
l l
l I
d.
The witness's professional or-other qualifications to 2
testify on the subject matter on which the witness 3
will testify.
4 5
Dated:
6/123/37 Respectfully submitted,
/
6 L..., ' / f'>l.
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7
.i,
/ eb (L
8 SCOTT L.
FIELDER O
Attorney for the Interveners 10
-11 12 13 14 15 16 17 18 19 i
20 21 22 23 24 25 26 27 28 i
acixttte UWC PROOF OF SERVICE
'87 JLL 15 A7 :49 I am a resident of the County of Humboldt.- :I.am' over the age of eighteen years and not a party f6Cithe within't action.
My business address if 517 Third Street, Sui e"-14, Eureka, California, 95501.
N
/3 C I served the On 5
/
within JOINT INTPRVEMnRA' TMTon eg7 OF INTERROGATORTER P RnpnfiMnpn TO THE LICPN9FF PArTPTc nne nun er pc7p r,,
,,9,u p,s u u 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 State's mail at Eureka, California, addressed i
l 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.
l Executed at Eureka, California, on ht g
L 1
)
CLAUDETTE C.
SMITH i
DROOF OF SERVICE l
1 SEE ATTACHMENT i
i ATTACHMENT United States. Nuclear Regulatory Commission Public Document Room i
1717 "H" Street NW i
Washington, D.C.
20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.
C.
20555 l
i 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 l
P.
O. Box 7442 l
San Francisco, CA 94120 l
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
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Dr. Peter A.
Morris, Member Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D.
C.
20555 Ralph and Nona Kraus 2479 Wrigley Road Eureka, California 95501 u___-__----_______
A-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 L
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