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 TMIML19276G578 |
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Skagit |
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Issue date: |
05/29/1979 |
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From: |
Leed R LEED, R.M. |
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To: |
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References |
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NUDOCS 7907130045 |
Download: ML19276G578 (6) |
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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
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NRC PImLIC ImCmfENT ROmf k p W 7 UNITED STATES OF AMERICA gJg> p NUCLEAR REGULATORY COMMI SSION REFOPE THE ATOMIC SAFETY AND LICENSING APPEAL B0ARD In the Matter of )
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PUGET SOUND PONER & LIGHT ) DOCKET NOS. STN 50-522 COMPANY, et al., ) 50-523
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(Skaai t Nuclear Power P roject , )
Units 1 and 2) )
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INTERVENOR SCAND' S INTEPROGATORIES AND REOURSTS P3 R PRODUCTION TO STAFF OF MAY 29, 1979.
In accordance with 10 CFR, S2.740R and 10 CFR S2.741, clease answer the followina Interroaatories and respond to the accompanvino Pequests for Production.
Documents to be. produced should be presented at the offices of undersioned counsel at 9:00 a.m. on the 20 th day af ter service of this discovery, or at such other time and olace as may be acreed upon.
INTERROGATORY NO. 1. Since Januarv 1, 1978, has eny information concerning research or studies come to the at-tention of the S taf f, or any of its consultants regardina any of the followina:
(a) The svneraistic, lethal, or sublethal effects of thermal nollution, chlorine, or heavv metals uoon sa.1monids at anv staae of their lif e evcle?
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(b) Whether an attraction phenomenon has been ob-served with resoect to salmonids, particularly juveniles, and thernal discharaes.
I f so, olease describe such information, study or re-oort in detail, and state whether such information justi-fies alterino anv of the conclusions regardino fisheries irroacts of the project stated in the EIs, or in the tes ti-mony on fisberies presented by Staff.
ANSWER:
- 2. Please describe in detail and with particular-ity, all studies, reports, information, data anel other information of any kind which S taf f has re ce i ve<34 , other than in this docket, and which certain in any way to the Strait Creek Pault and the 1972 earthquake in the state of Washington. You may furnish cocies of documents in lieu of describing them.
ANSWER:
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- 3. Please describe all oublications and other docu-ments, whether or not publi clv disseminated, which certain to staf f and commission review and analvsis of the follow-inq subjects:
(a) The Three Mile Island accident of 1979.
(b) Actual or potential generic safety questions affecting the desian of the type of General Electric re-actor which is proposed for the Skagi t Plants.
(c) Evacuation plans and emercency plannina.
AN SWE R:
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4 Please describe speci fically all documents, nans, photocraphs, and other data or information of any kind which was furnished to you at, or displayed to you at, the conf erence between S taf f, USGS, and the Applicant, which took place in Landover, Maryland on April 18, 1979.
ANSWER:
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- 5. Request for Production No. 1. Please produce for inspection and copyino on the 21st dav after the date of service of these requests for production uoon you, at the offices of intervenor's counsel all documents described in your answers to the forecoing interroaatories at 9 :0 0 a. m.
or at such other time or place as may mutually be agreed upon.
- 6. Peauest for P roduction No. 2 Please produce for inspection and copying at the of fi ce of intervenor 's counsel on the 21st day after the service of these inter-rocatories and requests for production upon you, at 9:00 a.m., or at such other time and nlace as may be mutually aareed uoon the following:
All work paners , work ing files, notes, memoranda, includino intra-aaency memoranda, of voor consultants, employees of the US Geolooical Survey, who hava reviewed and who are reviewino the site safety asnects of the Skaci t Plant, including Dr. William Havs and Mr. D evi ne.
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Interrocatorv No. 5. How many drafts have been pre-pared for the PSEP and the SER for the Skacit Project, and who has custody of those drafts? Please describe the date of each such drafts, and oive the number of paces it contains. Also, please produce each draft for inspection and copying in accordance with Recuest for Production No.
I above.
AN SWE R :
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Interrocatorv No. 6. Please describe all notes, work-ino papers, calculations, tables, data, and other materials of any kind or nature relied upon by Dr. J acques Read in connection with the oreparation of the testimony which he offered herein. Please produce all such documents for in-spection and copvino in accordance with Recuest for Pro-duction No. 1 above.
ANSWER:
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Interrnaatory No. 7 Please describe all documents and records, includina maps, chotoaraohs, memoranda, corresoon-dence, and field notes, which certain in any way to the staf f's analysis and review of alternative sites for the Skapi t project. Please produce all such documents for inspection and conving in accordance with Request for Production No. 1.
DATED thi s "? day of flav , 1979.
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/$bt ROGER M. LEED Counsel for Intervenor SCANP
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