ML19241A630
| ML19241A630 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 05/31/1979 |
| From: | Little D, Thomsen F PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN |
| To: | |
| References | |
| NUDOCS 7907090009 | |
| Download: ML19241A630 (14) | |
Text
. .
~ ~ _. ;_
,\1 02 r S
Nv
~7
~ th u-b jj,, f13T3Z'}
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.
.
)/U C L/}'
-
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.
bf0 Q
'
.
- 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
~
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}}