ML19296D049

First Set of Interrogatories Directed to Met Ed.If Info Not Available,Revised Answers Should Be Provided Prior to End of Discovery

ML19296D049
Person / Time
Site:	Three Mile Island
Issue date:	02/15/1980
From:	Cunningham J FOX, FARR & CUNNINGHAM
To:	METROPOLITAN EDISON CO.
Shared Package
ML19296D052	List: ML19296D049 ML19296D060
References
NUDOCS 8002290288
Download: ML19296D049 (3)

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j UNITED STATES OF AMERICA c3 g 8 i NUCLEAR REGULATORY COSD!ISSION L Cy I

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I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD n

i IN THE MATTER OF:  :

METROPOLITAN EDISON COMPANY  : Docket No.

l (Three Mile Island Nuclear -

(Restart) l Station, Unit No. 1)  :

j NEWBERRY TOWN 3 HIP TMI STEERING CO>DIITTEE'S FIRST SET OF INTERROGATORIES ll TO LICENSEE METROPOLITAN EDISON i

i These Interrogatories are filed by the Newberry Township TMI Steering Committee pursuant to 10 C.F.R. $2.740b, which requires that the I

i Interrogatories be answered separately and fully in writing and under oath l or affirmation. With respect to those Interrogatories for which complete and responsive : nformation is not now available to Metropolitan Edison, the Committee requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979, First Special Prehearing Conference Order.

I Any reference to the " Licensee" or " Met Ed" shall be deemed to I

l l include any sister or parent corporation of Met Ed. When knowledge or information of Met Ed is requested, such request includes knowledge or i

information of Met Ed's members and, unless privileged, its attorneys (if o

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1, DEFINITIONS'~ i 4 l 1 .

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i A. " Document"means any writ ten, recorded, transcribed, taped, I t

filmed, or graphic matter, however produced or reproduced, to which the i

responding party has or has had access.

l B. " Study" means any written, recorded, transcribed, taped, l

l filmed, or graphic matter, however produced or reproduced, to which the t

l; responding party has access which considers, either formally or informally, h

'lj a particular issue or situation, in whatever detail, whether or not the

! consideration of the issue or situation is in a preliminary stage and whether l

or not the consideration was discontinued prior to completion.

C. " Person" means any natural person, corporation, professional corporation, partnership, association, joint venture, proprietorship, firm, i

j or other business enterprise or legal entity.

i D. "You" or "your" means the party to the proceeding to whom these

'i information requests are addressed.

E. " Identify" or " identity" used in reference to a natural person

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means te state his or her full name and residence address, present cr last known position and business af filiation, and position and business I

affiliation at the time in question.

l F. " Identify" or " identity" when used in reference to a document l

means to state the date or dates, author or originator, subject matter, all  !

l h addresses and recipients, type of document (e.g., letter, memorandum, l

! telegram, chart, etc.), number or code number thereof or other means of i

j identifying it, and its present location and custodian. If any such l

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I document sas, but is no longer in your possession, or subject to your control, state what disposition was made of it.

G. " Identify" or " identity" when used in reference to a business entity means to state its full name, the address of its principal office, and the type of entity.

l H. "And" and "or" are both conj unctive and disj unctive.

l l 1. Words in the singular include the plural, and words in the t

l plural include the singular. "Each" and "any" are both singular and plural.

h J. Words in the past tense include the present, and words in i

the present tense include the past.

i K. Words in the masculine gender include the feminine gender and l! words in the feminine gender include the masculine gender.

II I INSTRUCTIONS L. If any matter is evidenced by, referred to, reflected by, j represented by, or recorded in any document identify or produce for discovery and inspection each such document.

l M. These information requests are continuing in nature, and information which the responding party later becomes aware of or has access l to and which is responsive to any request is to be made available to l

, Newberry Township.

N. Unless otherwise expressly provided, each information request 0

' should be construed independently and not with reference to any other, H

Il' information request herein for purpose of limitation.

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