ML20086K023

Response to Preliminary Set of Initial Interrogatories & Request for Production of Documents Re Contentions 1-4. Certificate of Svc Encl.Related Correspondence

ML20086K023
Person / Time
Site:	Hope Creek
Issue date:	01/18/1984
From:	Remis S NEW JERSEY, STATE OF
To:	Public Service Enterprise Group
References
ISSUANCES-OL, NUDOCS 8401260183
Download: ML20086K023 (6)

Text

-

d RELl. TID COE2rFFC:II: ICE I-DOCKETED USNRC UNITED STATES OF AMERICA '8 4 J yj 2 3 g g g g NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and LiceSEin%SBdard

.v .

3g g; Public Service Electric and )

Gas Company Docket No. 50-354-OL (Hope Creek Generating )

Station) )

THE PUBLIC ADVOCATE OF NEW JERSEY'S RESPONSE TO THE APPL 1 CANTS' PRELIMI-NARY SET OF INITIAL INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

1. The Public Advocate currently intends to present expert witnesses on Contentions one through four.

(a) Contentions one through three l

The Public Advocate will inform the applicant of the identities of all experts to be called to testify l on Contentions one through three as soon as we complete l

l the consultant selection and contract negotiation pro-cess. The.Public Advocate anticipates that this will be accomplished in the near future.

(b) Contention four .

i The identities of the Public Advocate's experts on Contention four are Doctors Richard R. Perizek, P.G.,

8401260183 840118 PDR ADOCK 05000354 0 PDR

g503

c- v.

l and Gary W. Peterson of Penn State University. Since

~

D the applicant recently deposed both Dr. Perizek and Dr. Peterson on January 13, 1984, the applicant is now aware of information requested in the remainder of this question.

The Public Advocate further intends to rely on witnesses presented by the State of. Delaware on Contention four.-

2. The Public Advocate has no.present intention

- to submit any fact witnesses on Contentions one through four. The Public Advocate will inform the applicant of the identities and locations of such j

' witnesses, together with the subject matter and substance of said testimony if and when the Public Advocate chooses to present fact witnesses.

3. The Public Advocate relies upon the documents and publications cited and discussed in the Public ,

!- Advocate's proposed contention, which the Public Advocate believes the applicant possesses. As provided i

l by the rules of the Commission, 10 C.F.R. 2.740(e),

=.

the Public Advocate will supplement this response, D as warranted, with more information when additional documents or publications are discovered by the Public Advocate.

Document Recuest The Public Advocate believes that the applicant possesses all the documents relied upon in Contentions one through four, with the exception of two papers As counsel knows, recently prepared by Dr. Perizek.

(given to these papers did not appear on his C.V.

but he the applicant at the January 13 deposition) ,

agreed to forward them to applicant's counsel immediately upon returning to his office at Penn State.

I~

=

When documents besides those contained, cited, M

or excepted in the Public Advocate's contentions are g -

identified, the Public Advocate will be pleased to consider, as an alternative arrangement, identifying c

F(:

a reasonable time and place for inspection and copying,

.!5 e

>5 t

~

a i

as kindly suggested by applicant's counsel.

4 Respectfully submitted, JOSEPH H. RODRIGUEZ The Public Advocate of the State of New Jersey e, ',

By: D.v m MC SUSAN REMIS Division of Public Interest Advocacy January 18, 1984 l

l j

i i

M 8

i DOCKETEre UStac

'84 JAN 23 Pl2:28  !'

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  ! '

WIH.i & 3EL:n J .~

uCCXETING & srpeytt": 3 Before the Atomic Safety and LicensingEBog14  !

1 Public Service Electric and )

Gas Company )

)

)

(Hope Creek Generating )

Station) ) Docket No. 50-354-OL CERTIFICATE OF SERVICE I hereby certify that copies of "The Public Advocate of New Jersey's. Response to the Applicants' Preliminary Set of Initial Interrogatories and Request for Production of Documents" dated January 18, 1984 in the captioned matter has been served upon the following by deposit in the United States mail this 18th day of January, 1984:

The Hon. Marshall E. Miller Theodore Granger, Esq.

Chairman Dept. of the Public Atomic Safety and Licensing Advocate Board Panel Division of Rate Counsel U.S. Nuclear Regulatory Ccmm. 744 Broad Street 1717 "H" Street, N.W. 29th and 30th floors Washington, DC 20555 (2 copies) Newark, NJ 07102

?

Dr. Peter A. Morris Atomic Safety and Licensing, Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Comm.

U.S. Nuclear Regulatory Comm. 1717 "H" Street, N.W.

1717 "H" Street, N.W. Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Dr. James H. Carpenter Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Comm.

Board Panel 1717 "H" Street, N.W.

U.S. Nuclear Regulatory Comm. Washington, DC 20555 1717 "H" Street, N.W. (5 copies)

Washington, DC 20555

~. .- '

B ' 9 2

i:t uz' 55 lii .

MR Carol Delaney, Esq.

j@j

.aua Docketing and Service Deputy Attorney General Section Deparrment of Justice

.(gg Office of the Secretary ur. U.S. Nuclear Regulatory Comm. State Of fice Building

%.% ~

1717 "H" Street, N.W.

8 th . floor E5i Washington, DC 20555 820 N. French Street 55 ~

-Wilmington, Delaware 19801

%*= Lee Scott Dewey, Esq.

C22 33.

Office of the Executive Legal Director

_Ei U.S. Nuclear Regularoy Comm.

$$?

1717 "H" Street, N.W.

15[: Washington, DC 20555 23

'"'"" (2 copies) un:

a= Richard Fryling, Jr. , Esq.

m==

nr2 Associate General Counsel Ef3 Public Service Electric "Se and Gas Co.

PO Box 570 (T5E)

Newark, NJ 07101

' '".1 w ww Director, Division of Environmental Control

$7;3;3 Tatnell Building Dover, Delaware 19901

___]~

=: Troy B. Conner, Jr., Esq.

Conner and Wetterhahn

=

.m==

4 1747 Pennslyvania Avenue, NW Washington, DC 20006 0: - - Hon. Irwin R. Kimmelman Attorney General of ,

, . = --a New Jersey o 7..7 Justice Complex p =::~::,1:t:.*:;,~

'"'" "ee 25 Market Street Trenton, NJ 08625 33:5 "g.~

January 18, 1984 n= r c u :n l

' E v,., . . y,

.= SUSAN REMIS

. . =..._

Division of Public Interest

[.;.. n Advocacy l 2sgl Department of the Public

! ' N:t-2 -

Advocate jiTf " '"s"i

c. n G' u