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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20063M6241982-09-0707 September 1982 First Set of Interrogatories Re Contentions 14,29,30 & 35. Certificate of Svc Encl.Related Correspondence ML20063M3321982-09-0101 September 1982 First Set of Interrogatories.Related Correspondence ML20063M3351982-09-0101 September 1982 First Set of Interrogatories.Related Correspondence ML20063M3391982-09-0101 September 1982 First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML19210E0631979-10-30030 October 1979 Interrogatories Directed to Applicant Re San Juan Islands Seismic Profiles Produced by Western Geophysical in 1971. Related Documents Should Be Presented on 791126.Questions Possible Matl False Statement by Applicant ML19210E0681979-10-30030 October 1979 Interrogatories to NRC Re San Juan Islands Seismic Profiles Produced by Western Geophysical in 1971.Related Documents Should Be Produced & Presented on 791126.Questions Possible Matl False Statement by Applicant.Certificate of Svc Encl ML19254F0561979-09-14014 September 1979 Interrogatories & Requests for Production of Documents, Directed to Applicant Re Bechtel Rept of Geological Investigations in 1978-79. Documents Should Be Delivered on 791001.Certificate of Svc Encl ML19209A7081979-08-21021 August 1979 Interrogatories & Document Requests to Util Submitted by Intervenor Skagitonians Concerned About Nuclear Power. Includes Questions Re Basis for Design of Blowdown Flow & Silica Content of Water.Certificate of Svc Encl ML19209A6991979-08-13013 August 1979 Response to Util Interrogatories & Document Requests.Submits Answers Re Source of Info,Witnesses,Publication of Repts & Availability of Documents.Supporting Documentation & Certificate of Svc Encl ML19261E7591979-06-25025 June 1979 Interrogatories & Document Requests Submitted by Intervenor Skagitonians Against Nuclear Plants to Applicants. Requests Info Re Jointly Owned Independent Subsidiary. Seattle Times 790607 Article & Certificate of Svc Encl ML19246B7931979-06-19019 June 1979 Answers Submitted by Puget Sound Power & Light Co to Skagitonians Concerned About Nuclear Power 790524 Document Requests & Interrogatories.Submits Info Re Bechtel Site Investigation,Financial Matters & Geological Surveys ML19246B8001979-06-19019 June 1979 Answers Submitted by Puget Sound Power & Light Co to Skagitonians Concerned About Nuclear Power 790530 Document Requests & Interrogatories for Pacific Power & Light Co. Certificate of Svc Encl ML19241B5001979-06-18018 June 1979 Answer to Skagitonians Concerned About Nuclear Power 790530 Interrogatories & Document Requests.Responds to Questions Re Financial Matters.Certificate of Svc Encl ML19246B7071979-06-14014 June 1979 Answer to Skagitonians Concerned About Nuclear Power 790530 Interrogatories & Document Requests.Util Has No Documents Containing Info on Min Capacity for Spent Fuel for 1978 ML19241A6301979-05-31031 May 1979 Interrogatories & Document Requests,Submitted for Intervenor Skagitonians Concerned About Nuclear Power by Util.Questions Concern Geological Features,Design & Const of Plant,Names of Witnesses & Emergency Plans.Certificate of Svc Encl ML19246B2921979-05-30030 May 1979 Interrogatories & Document Requests to Pacific Power & Light,Submitted by Skagintonians Concerned About Nuclear Power.Requests Include Info Re Form 10-K for 1978,environ Effects of Plant & Activities of Employees & Consultants ML19246B2961979-05-30030 May 1979 Interrogatories & Document Requests to Portland General Electric,Submitted by Skagitonians Concerned About Nuclear Power.Requests Include Info Re 790227 Prospectus, Coal Contracts,Bank Credit & Activities of Employees ML19276G5781979-05-29029 May 1979 Interrogatories & Document Requests to Nrc,Submitted by Intervenors Skagitonians Concerned About Nuclear Power. Requests Include Info Re Thermal Pollution & Salmonids, Earthquakes & Generic Safety Issues Raised by TMI ML19246B3021979-05-29029 May 1979 Interrogatories & Document Requests to Wa Power Co,Submitted by Intervenors Skagitonians Concerned About Nuclear Power. Requests Include Info Re Const Costs,Operation Costs & Estimated Cost of Power.Certificate of Svc Encl ML19224C8031979-05-29029 May 1979 Interrogatories & Document Requests for Puget Sound Power & Light Co Submitted by Skagitonians Concerned About Nuclear Power.Questions Concern Bechtel Reinvestigation of Site Area & Evacuation Plans ML19259B3081979-01-0909 January 1979 Interrogatories Submitted by Intervenors to Nrc.Queries Concern Info Used in Preparation of Certain Documents,Scope of Instructions to Employees & Acoustical or Seismological Studies.Certificate of Svc Encl ML20150A9071978-10-0202 October 1978 State of Wa Water Power Co Response to Intervenor Scanp 780913 Interrogatories & Request for Production of Documents Re Siting & Costs of Proposed Facility,Cost of Mills,Pkh of Installed Capacity & Identification of Documents 1982-09-07
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7881983-11-23023 November 1983 Withdrawal of OL Application.Certificate of Svc Encl ML20082F7771983-11-23023 November 1983 Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding ML20080L9431983-09-28028 September 1983 Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl ML20080G0731983-09-13013 September 1983 Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl ML20071Q7201983-06-0303 June 1983 Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl ML20071M0781983-05-25025 May 1983 Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl ML20023C4571983-05-12012 May 1983 Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl ML20023C3741983-05-12012 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1 ML20023C3691983-05-12012 May 1983 Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists ML20023C6971983-05-12012 May 1983 Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl ML20064N6681983-02-10010 February 1983 Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs ML20071A6671983-02-10010 February 1983 Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210 ML20070T0661983-02-0404 February 1983 Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc ML20083N8101983-01-31031 January 1983 New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20083N1991983-01-26026 January 1983 Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl ML20028F1831983-01-25025 January 1983 Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl ML20028E9701983-01-19019 January 1983 Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc ML20072A6731983-01-18018 January 1983 Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl ML20028C9581983-01-0505 January 1983 Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc ML20028C9501983-01-0505 January 1983 Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents ML20028C3221983-01-0303 January 1983 Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue ML20070L5411982-12-27027 December 1982 Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded ML20070L4901982-12-27027 December 1982 Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl ML20079J6021982-12-23023 December 1982 Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl ML20023B3081982-12-20020 December 1982 Response to 821201 Discovery Requests.Certificate of Svc Encl ML20079H3711982-12-13013 December 1982 Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl ML20070D1181982-12-10010 December 1982 Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land ML20070C9121982-12-10010 December 1982 Notice of Counsel New Law Firm Affiliation,As of 820901 ML20070C8181982-12-10010 December 1982 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB ML20070C7981982-12-10010 December 1982 Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation ML20070C7691982-12-10010 December 1982 Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210 ML20028B9251982-12-0101 December 1982 Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl ML20028B8971982-12-0101 December 1982 Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence ML20028B2631982-11-26026 November 1982 Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site ML20066L0101982-11-22022 November 1982 Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl ML20066K9761982-11-22022 November 1982 Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue ML20023A8301982-10-15015 October 1982 Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence ML20023A8141982-10-14014 October 1982 Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl ML20027C1591982-10-0606 October 1982 Response to 820917 First Set of Interrogatories ML20063P4011982-10-0606 October 1982 Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding ML20071N3791982-10-0404 October 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20065H5481982-09-29029 September 1982 Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20065H5451982-09-29029 September 1982 Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions ML20065J1601982-09-28028 September 1982 Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20069F9491982-09-23023 September 1982 Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl ML20069F9541982-09-23023 September 1982 Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl ML20137F8001982-09-17017 September 1982 Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project ML20027B5661982-09-17017 September 1982 Response to First Set of Interrogatories.Certificate of Svc Encl ML20027B5631982-09-17017 September 1982 First Set of Interrogatories ML20027B5571982-09-15015 September 1982 Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl 1983-09-28
[Table view] |
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Q -- =*f- ,gy UNITED STATES OF AMERICA ss e "
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al. ) 50-523
)
(Skagit Nuclear Power Project, ) May 31, 1979 Units 1 and 2) )
APPLICANTS' INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO INTERVENOR SCANP TO: SKAGITONIANS CONCERNED ABOUT NUCLEAR PLANTS (SCANP) and Roger M. Leed, its attorney.
Pursuant to 10 CFR S 2.740 (b) , Applicants propound the fol-lowing interrogatories to Intervenor SCANP, to be answered by a duly authorized officer or agent fully in writing under oath or affirmation within 14 days.
Pursuant to 10 CFR S 2.741, Applicants request that you produce and permit Applicants' counsel to inspect and copy, within 20 days, at the offices of Applicants' counsel during normal business hours, the documents designated below. Docu-ments which have previously been produced for Applicants' coun-sel need not be produced pursuant to this request, r.
- 310 046 D0700oofy .
1
1
- As used herein, the term " document" means all writings and recordings of every type in the possession or control of SCANP or its directors, officers, members, employees, attorneys, consultants, agents or representatives, including, but not limited to, memoranda, correspondence, reports, surveys, charts, books, photographs, maps, notes, studies, drawings, writings, minutes, nctes of telephone conversations, notes of meetings or other conversations, and all other records.
INTERROGATORY NO. 1: With respect to the statement by Mr. Leed at the conference on April 24, 1979 (Tr. 11,894) re-garding " earthquakes which have occurred in the Skagit Valley more recently than those which were discussed at the last hearing",
- a. Identify each such earthquake by date and approximate time of occurrence,
- b. State all facts known to you regarding each such earthquake, including, but not limited to, its loca-tion, magnitude and focal depth, and any fault plane solutions, any studies attempting to correlate fault plane solutions for earthquakes in the Skagit Valley, or other seismic analysis.
310 041
- c. Identify all documents that refer to any such earthquake.
- d. Identify by name, address and occupation all persons having knowledge of facts regarding any such earthquake.
INTERROGATORY NO. 2: With respect to the statement by Mr. Leed at the conference on & ril 24, 1979 (Tr. 11,894) about "the continuing investigations that have been undertaken by a number of parties including seven (sic?) other dockets on the Straight Creek Fault",
- a. Identify each such continuing investigation.
- b. State all facts known to you regarding each such con-tinuing investigation, including, but not limited to, the person or organization that performed or is per-forming the investigation, the scope of the investiga-tion, the information gathered in sucb investigation, and any report written or presented orally on the investigation,
- c. Identify all documents that relate to any such con-tinuing investigation.
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t
- d. Identify by name, address and occupation all persons
- having knowledge of facts regarding any such investigation.
INTERROGATORY NO. 3: With respect to the question by Mr. Leed at the conference on April 24, 1979 (Tr. 11,894) regarding an updating of information on faulting associated with the trend identified by Dr. Ch'ney, what he has called the Bellingham Bay Fault, including information from Canadian sources and publications",
- a. Identify all such information, including that from Canadian sources and publications.
- b. Identify all documents that refer to or set forth any such information.
- c. Identify by name, address and occupation all persons having knowledge of such information.
INTERROGATORY NO. 4: Identify all. geologic mapping and other field work in relation to the Skagit Nuclear Power Pro-ject that has been performed by or for SCANP or its attorneys,
-4_ .
!>\0 DAS
agents, employees, consultants or any other persons acting on its behalf. If any such work has been performed,
- a. Identify by name, address and occupation the persons who performed the work.
- b. Indicate the number of hours or days spent on the work.
- c. Describe in detail the scope of work performed, the geographical areas coverea and findings of such work.
- d. Identify all documents prepared in connection with the work,
- e. Identify and summarize any oral reports made in connection with the work.
INTERROGATORY NO. 5: Identify all geological, seismo-logical, geophysical, or geotechnical studies, analyses, evaluations, reviews or other work in relation to the Skagit Nuclear Power Project which have been conducted by or for SCANP or its attorneys, agents, employees, consultants or any other persons acting on its behalf. With respect to each such study, analysis, evaluation, review, or work,
- a. Identify by name, address and occupation the persons who conducted it.
310 069
- b. State all facts regarding it including a detailed description af its nature, purpose, scope and findings,
- c. Identify all documents prepared in connection with it.
- d. Identify and summarize any oral reports made in con-nection with it.
INTERROGATORY NO. 6: Identify all studies, analyses, evaluations, reviews or other work regarding the design, con-struction, operation er reliability of the Ranney Collectors and any associated environmental impacts for the Skagit Nuclear Power Project known to you that have been or are being con-ducted, except those conducted for Applicants or the NRC Staff. With respect to each such study, analysis, evaluation, review or other work,
- a. Identify by name, address and occupation the persons who conducted it, and for whom the work was performed.
- b. State all facts regarding it including a detailed description of its nature, purpose, scope and findings.
- c. Identify all documents prepared in connection with it.
- d. Identify and summarize any oral reports made in con-nection with it.
310 051
INTERROGATORY NO. 7: Identify by name, address and occupation each person whom SCANP intends to call as a witness on the subject of availability of coal, especially British Columbia coal. As to each such person,
- a. Describe in detail all studies, analyses, evaluations or other work performed by that person on the referenced subject and for whom such work was performed.
- b. Identify all documents prepared by such person on the referenced subject.
INTERROGATORY NO. 8: With respect to the statement by Mr. Laed at the conference on April 24, 1979 (Tr. 11,849) that, "We are considering making a formal motion to the Board to reopen aquatic impacts in light of newly-available information,"
- a. Identify all such " newly-available information."
- b. Identify all documents regarding such " newly-available informati6n."
- c. Describe in detail all studies, analyses, evaluations, reviews or other work regarding the aquatic impacts of operation of the Skagit Nuclear Power Project that 310 051
have been conducted, are being performed, or are planned, other than those for Applicants or the NRC Staff. Identify by name, address and occupation the persons.who have done or will be doing such work.
Identify the person or organization for when tcy such work was, is or will be performed. Identify all docu-ments that refer to or have been prepared in connec-tion with such work.
INTERROGATORY NO. 9: Describe in detail all studies, analyses, evaluations, reviews or other work on the subjects of the suitability of the site for development of an evacuation plan or the adequacy of the emergency evacuation plan which have been or are being conducted by or for SCANP or its attorneys, agents, employees, consultants or other persons act-ing on its behalf. With respect to each such study, analysis, evaluation, review or work,
- a. Identify by name, address and occupation the persons who have conducted or are conducting it,
- b. State all facts regarding it including a detailed des-cription of its nature, purpose, scope and findings.
- c. Identify all documents prepared in connection with it.
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- d. Identify and summarize any oral reports made in con-nection with it.
- e. Identify by name, address and occupation all persons whom CCANP intends to call as witnesses on the subject of emergency evacuation ptar.s.
INTERROGATORY NO. 10: Identify by name, address and occupation all persons whom SC4NP intends to call as witnesses on the subject of financial qualifications of Applicants. As to each such person,
- a. Describe in detail all studies, analyses, evaluations, reviews, or other work performed by that person on the subject of financial qualifications of Applicants,
- b. Identify each and every document prepared by such per-son on the referenced subject.
INTERROGATORY NO. 11: Identify by name, address and occupation all persons whom SCANP intends to or may call as witnesses at hearings on Applicants' application for construc-tion permits for the Skagit Nuclear Power Plant. As to each such person, 310 053
- d. Identify and summarize any oral reports made in con-nection with it.
- e. lientify by name, address and occupation all persons whom SCANP intends to call as witnesses on the subject of emergency evacuation plans.
INTERROGATORY NO. 10: Identify by name, address and occupation all persons whom SCANP intends to call as witnesses on the subject of financial qualifications of Applicant.3. As to each such person,
- a. Describe in detail all studies, analyses, evaluations, reviews, or other work performed by that person on the subject of financial qualifications of Applic ints.
- b. Identify each and every document crepared by such per-son on the referenced subject.
INTERROGATORY NO. 11: Identify by name, address and occupation all persons whom SCANP intends to or may call as witnesses at hearings on Applicants' application for construc-tion permits for the Skagit Nuclear Power Plant. As tn each such person, 310 056'
- a. Deberibe in detail the subject matter on which that person is expected to testify and the substance of his/her tes*i. mony.
- b. Describe in detail all studies, analyses, evaluations, reviews or other work performed by that person in con-nection with the subject matter on which he/she is expected to testify.
- c. Identify all documents prepared by that person or to be offered into evidence by that person on the subject matter en which he/she is expected to testify.
REQUEST FOR PRODUCTION NO. ;: Produce for inspection and copying by Applicants all documents which are ideatified in your answer to the preceding .nterrogatories.
REQUEST FOR PRODUCTION NO. 2: Produce for inspection and copying by Applicants all communications and other documents pertain'ng in any way to geology and seismology in relation to the Skagit Nuclear Power Plant that have passed between SCANP, its attorneys, agents, employees, consu)* nts or any other per-sons acting on its behalf including, in particular, all com-munications and other documents that have passed between Dr. Eric S. Cheney and any of the following:
310 056
A. L. C. Bennett, Jr.
B. Timothy P. Lovseth C. P. R. Carroll D. William A. Brewer E. J. W. Murray F. W. G. Milne G. W. R. Schell H. R. S. Crosson I. Bruce A. Stoker J. Anthony Qamar K. R. H. Blunden L. John Whetten M. Fred Pessl N. Stewart Smith O. Steven Malone P. The NRC, its employees or consultants Q. The U.S. Geological Survey, its employees or consultants R. Any other person or organization, including without limitation, those situated in Canada.
310 057;
DATED this 3/Sf day of May, 1979.
Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WIL AMS B J l'// /.s?H/W F. Theodore Thomsen i
By hf/b> -
xJog41as S. Little Attorneys for Applicant 1900 Washington Building Seattle, Washington 98122 Phone (206) 682-8770 Of Counsel:
Lowenstein, Newman, Reis, Axelrad and Toll 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 Phone (202 862-8400 310 053
UNITED STATES OF" AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PUGET SOUND POUER & LIGHT COMPANY,) DCCKET NOS.
et al. )
) 50-522 (Skagit Nuclear Power Project, ) 50-523 Units 1 and 2) )
)
CERTIFICATE OF SERVICE I hereby certify that the following:
APPLICANTS' INTERROGATORIES A::D RECUESTS FOR PRODUCTION OF DOCUMENTS TO INTERVENOR SCANP in the above-captioned proceeding have been served upon the persons shown or the attached list by depositing copies thereof
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in the United States mall on May 31, 1979 with proper postage affixed for first class mail.
DATED: May 31, 1979
- V D g ad/ S . Little Couisel for Puget Sound Power &
Light Company 1900 Washington Building Seattle, Washington 98101
. 310 05%
Date: May 31, 1979 Valentine B. Deale, Chairman Robert C. Schofield, Director Atomic Safety and Licensing Board Skagit County Planning Department 1001 Connecticut Avenue, N.W. 218 County Administration Building Washington, D. C. 20036 Mount Vernon, WA 98273 Dr. Frank F. Hooper, Member Richard M. Sandvik, Esq.
Atomic Safety and Licensing Board Assistant Attorney General School of Natural Resources 500 Pacific Building University of Michigan 520 S.W. Yamhill Ann Arbor, MI 48109 Portland, OR 97204 Gustave A. Linenberger, Member Roger M. Leed, Esq.
Atomic Safety and Licensing Board Room 610 U.S. Nuclear Regulatory Commission 1411 Fourth Avenue Building Washington, D. C. 20555 Seattle, WA 98101 Alan S. Rosenthal, Chairman CFSP and FOB Atomic Safety and Licensing E. Stachon & L. Marbet Appeal Board 19142 So. Bakers Ferry Road U.S. Nuclear Regulatory Commission Boring, OR 97009 Washington, D. C. 20555 Robert Lowenstein, Esq.
Dr. John H. Buck, Member Lowenstein, Newman, Reis, Axelrad Atomic Safety and Licensing & Toll Appeal Board 1025 Connecticut Avenue, N.W.
U.S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Warren Hastings, Esq.
Michael C. Farrar, Member Associate Corporate Counsel Atomic Safety and Licensing Portland General Electric Company Appeal Board 121 S.W. Salmon Street U.S. Nuclear Regulatory Commission Portland, OR 97204 Washington, D. C. 20555 Richard D. Bach, Esq.
Docketing and Service Section Rives, Bonyhadi, Drummond & Smith Office of the Secretary 1400 Public Service Building U.S. Nuclear Regulatory Commission 920 S.U. 6th Avenue Washington, D. C. 20555 Portland, OR 97204 (original and 20 copies)
Canadian Consulate General Richard L. Black, Esq. _ Donald Martens, Consul Counsel for NRC Staff 412 Plaza 600 U.S. Nuclear Regulatory Commission 6th and Stewart Street Office of the Executive Legal Seattle, WA 98101 Director Washington, D. C. 20555 Nicholas D. Lewis, Chairman Energy Facility Site Evaluation Council 820 East Fifth Avenue Olympia, WA 98504 Thomas F. Carr, Esq.
Assistant Attorney General Temple of Justice Olympia, WA 98504 310-{h 5/16/79}}