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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20215K1421987-06-16016 June 1987 NRC Staff Response to Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20214P2791987-05-28028 May 1987 Joint Intervenors Third Set of Interrogatories Propounded to Pg&E.* Util Requested to Answer Under Oath to Listed Interrogatories within 14 Days.Proof of Svc Encl.Related Correspondence ML20235M2411987-05-28028 May 1987 Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* NRC Requested to Answer Under Oath Following Interrogatories within 14 Days.W/Proof of Svc.Related Correspondence ML20214N3801987-05-20020 May 1987 Answers to Licensee First Set of Interrogatories Re Facility Decommissioning.Proof of Svc Encl.Related Correspondence ML20213G1081987-05-0505 May 1987 PG&E Supplemental Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Forwards Attachment 2 in Response to Info Requested Re Interrogatory 148.W/ Certificate of Svc.Related Correspondence ML20215K9371987-05-0101 May 1987 Joint Intervenors Response to First Set of Interrogatories Propounded by NRC Staff.* List of Witnesses Will Be Provided When Settled Upon.Proof of Svc Encl.Related Correspondence ML20215K9221987-04-24024 April 1987 NRC Staff First Set of Interrogatories to Joint Intervenors.* First Set of Interrogatories Re Decommissioning of Facility.Certificate of Svc Encl. Related Correspondence ML20204B7351987-03-17017 March 1987 Licensee PG&E Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Cover Will Be Installed Over Spent Fuel.Related Documentation & Certificate of Svc Encl.Related Correspondence ML20212N5201987-03-0606 March 1987 Licensee PG&E First Set of Interrogatories & Request for Production of Documents to Joint Intervenors.* Certificate of Svc Encl.Related Correspondence ML20212F8551987-02-26026 February 1987 Joint Intervenors Second Set of Interrogatories Propounded to Licensee Pg&E.* Proof of Svc Encl.Related Correspondence ML20210E5561987-02-0202 February 1987 Licensee PG&E Response to First Set of Interrogatories Propounded by Joint Intervenors.* Certificate of Svc Encl. Related Correspondence ML20207Q0181987-01-13013 January 1987 Joint Intervenors First Set of Interrogatories Propounded to Licensee Pg&E.* First Set of Interrogatories Cover Spent Fuel Pool,Earthquake Magnitude & Fault in Support of Plant Decommissioning 1987-06-16
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company ML20246M2251989-08-22022 August 1989 Exemption from Requirement of 10CFR50.54(w) Re Reduction to Required Min Amount of Primary Property Damage Insurance ML20246M1531989-08-11011 August 1989 Exemption from Requirements of 10CFR50.54(w) Re 890609 Request for Reduction in Required Min Amount of Primary Property Damage Insurance ML20235T3311989-02-23023 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. NRC Failed to Demonstrate That There Is Industry Maint Problem & Therefore Lacks Justification for Rule ML20206K6081988-11-18018 November 1988 Temporary Exemption from 10CFR50.54(w)(5)(i) Re Increase in Amount of Onsite Property Damage Insurance Required by Power Reactor Licensees & Insurance That Prioritize Insurance Proceeds for Stabilization & Decontamination After Accident ML20149F0871988-02-0909 February 1988 Order (Dismissing Contentions & Terminating Proceeding).* Licensee Motion to Dismiss Contentions & Terminate Proceeding Granted.Nrr Authorized to Make Appropriate Findings & Conclusion Contained in Ser.Served on 880209 ML20237L6881987-08-26026 August 1987 NRC Staff Response to Licensee Motion to Dismiss Contentions & Terminate Proceeding.* Board Granting of Licensee Motion to Dismiss Contentions,Terminate Proceedings & End Jurisdiction Over Amend Requested.W/Certificate of Svc ML20236N9541987-08-0707 August 1987 Motion to Dismiss Contentions & Terminate Proceeding.* Parties Agreed to Withdrawal of All Contentions Per Encl Stipulation.Dismissal of All Contentions,Issuance of License Amend & Termination of Proceeding Requested ML20236N9881987-07-23023 July 1987 Stipulation for Withdrawal of Contentions.* Parties Request That Contentions Be Withdrawn Based on Terms of Encl 870608 Mou.W/Certificate of Svc ML20215K1421987-06-16016 June 1987 NRC Staff Response to Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20235M2411987-05-28028 May 1987 Joint Intervenors First Set of Interrogatories Propounded to NRC Staff.* NRC Requested to Answer Under Oath Following Interrogatories within 14 Days.W/Proof of Svc.Related Correspondence ML20214P2791987-05-28028 May 1987 Joint Intervenors Third Set of Interrogatories Propounded to Pg&E.* Util Requested to Answer Under Oath to Listed Interrogatories within 14 Days.Proof of Svc Encl.Related Correspondence ML20214N3801987-05-20020 May 1987 Answers to Licensee First Set of Interrogatories Re Facility Decommissioning.Proof of Svc Encl.Related Correspondence ML20213G1081987-05-0505 May 1987 PG&E Supplemental Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Forwards Attachment 2 in Response to Info Requested Re Interrogatory 148.W/ Certificate of Svc.Related Correspondence ML20215K9371987-05-0101 May 1987 Joint Intervenors Response to First Set of Interrogatories Propounded by NRC Staff.* List of Witnesses Will Be Provided When Settled Upon.Proof of Svc Encl.Related Correspondence ML20215K9221987-04-24024 April 1987 NRC Staff First Set of Interrogatories to Joint Intervenors.* First Set of Interrogatories Re Decommissioning of Facility.Certificate of Svc Encl. Related Correspondence ML20206T5221987-04-17017 April 1987 Notice of Appearance.* Author Enters Appearance in Proceeding.W/Certificate of Svc ML20204B7351987-03-17017 March 1987 Licensee PG&E Response to Second Set of Interrogatories Propounded by Joint Intervenors.* Cover Will Be Installed Over Spent Fuel.Related Documentation & Certificate of Svc Encl.Related Correspondence ML20212N5201987-03-0606 March 1987 Licensee PG&E First Set of Interrogatories & Request for Production of Documents to Joint Intervenors.* Certificate of Svc Encl.Related Correspondence ML20212F8551987-02-26026 February 1987 Joint Intervenors Second Set of Interrogatories Propounded to Licensee Pg&E.* Proof of Svc Encl.Related Correspondence ML20212C9951987-02-23023 February 1987 Notice of Author Withdrawal from Proceeding.Name Should Be Deleted from All Svc & Distribution Lists.W/Certificate of Svc ML20210E5561987-02-0202 February 1987 Licensee PG&E Response to First Set of Interrogatories Propounded by Joint Intervenors.* Certificate of Svc Encl. Related Correspondence ML20207Q0181987-01-13013 January 1987 Joint Intervenors First Set of Interrogatories Propounded to Licensee Pg&E.* First Set of Interrogatories Cover Spent Fuel Pool,Earthquake Magnitude & Fault in Support of Plant Decommissioning ML20214Q4921986-12-0303 December 1986 Order Consolidating Joint Intervenors,Admitting Contentions 1,2,5,6,7 & 8 for Adjudication,Rejecting Contentions 3 & 4 & Setting Period for Discovery from 861215 Until 30 Days After Issuance of Staff SER & Fes.Served on 861204 ML20211G5791986-10-27027 October 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20197B2461986-10-21021 October 1986 Transcript of 861021 Prehearing Conference in Eureka,Ca. Pp 1-141.Supporting Documentation Encl ML20211C0361986-10-14014 October 1986 Answer to Amended Petition to Intervene of Redwood Alliance, DG Bosco,W Chesbro,De Hauser & B Keene & ASLB Notice That Prehearing Conference Would Be Held in Eureka,Ca on 861021-22.Certificate of Svc Encl ML20203P0471986-10-10010 October 1986 Response Advising That Petitioners Adequately Demonstrated Standing to Intervene,Proffered at Least One Admissible Contention & Should Be Admitted as Parties to Proceeding. Certificate of Svc Encl ML20215D6931986-10-0909 October 1986 Response Opposing League of Women Voters late-filed Request for Hearing & Petition for Leave to Intervene Re Amend to Decommission Facility.Petitioners Fail to Satisfy five-factor Test for Late Intervention.W/Certificate of Svc ML20215C4691986-10-0606 October 1986 Answer to Petition to Intervene in License Amend Proceedings of League of Women Voters of Humboldt County & Gm Barr. Certificate of Svc Encl ML20210T1251986-10-0303 October 1986 Response to Petition to Intervene in License Amend Proceedings,Request for Hearing & Further Relief.Proposed Contentions 2,5,6 & 7 Should Be Admitted as Changed & Contentions 1,3,4 & 8 Rejected.Certificate of Svc Encl ML20214T6061986-09-26026 September 1986 Amended Petition of Redwood Alliance for Leave to Intervene & Request for Hearing.Proof of Svc Encl ML20214T6261986-09-19019 September 1986 Petition of League of Women Voters of Humboldt County to Join Petition to Intervene in License Amend Proceedings, Request for Hearing & Request for Further Relief.W/ Certificate of Svc ML20214P8141986-09-17017 September 1986 Supplemental Petition of Dh Bosco,W Chesbro,De Hauser, B Keene & Redwood Alliance for Leave to Intervene & Request for Hearing.Proof of Svc Encl ML20209G1511986-09-0909 September 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20212N1871986-08-26026 August 1986 Notice of 861021 Prehearing Conference in Eureka,Ca to Permit Identification of Key Issues in Proceeding,Consider Petition for Leave to Intervene & Establish Schedule for Completing Hearings.Served on 860827 ML20203L8811986-08-26026 August 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20212M7561986-08-22022 August 1986 Response to Redwood Alliance,W Chesbro,Dh Basco,B Keene & DE Hauser 860802 Joint Petition for Leave to Intervene & Request for Hearing.Addl Info Requested Re Standing & Interest of Parties Except DE Hauser.W/Certificate of Svc ML20203L2301986-08-18018 August 1986 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20203L2321986-08-18018 August 1986 Answer to Petitions to Intervene & Request for Hearing. Redwood Alliance,Dh Bosco & B Keene Petitions Should Be Denied,Per 10CFR2.714 Requirements.De Hauser & W Chesbro Petitions Acceptable.Certificate of Svc Encl ML20203K1751986-08-0101 August 1986 Petition of W Chesbro,Sl Fielder,D Hauser,D Bosco,B Keene & Redwood Alliance for Leave to Intervene & Request for Hearing.W/Proof of Svc ML20204F9281986-07-30030 July 1986 Testimony of Rt Nelson & Le Vincent Before Subcommittee on Investigations & Oversight & Subcommittee on Energy Research & Production on 860730 Re Alternative Methods for Decommissioning Plant ML20137F1041986-01-14014 January 1986 Order Granting Licensee 801231 Motion to Withdraw Application to Permit Resumption of Power Operation & Granting NRC 851011 Motion Seeking Order Dismissing Proceeding.Proceeding Terminated.Served on 860115 ML20133Q3071985-10-28028 October 1985 Response to NRC 851011 Motion to Terminate Proceeding.Motion Should Be Granted.Certificate of Svc Encl ML20133H1501985-10-11011 October 1985 Motion to Terminate Proceeding Re Withdrawal of Application for License Amend.Submission of Decommissioning Plan Renders Amend Application & Any Issue Concerning Contested Application Moot.Certificate of Svc Encl ML20125C9721984-09-10010 September 1984 Transcript of ACRS Subcommittees on Humboldt Bay Project & Reactor Radiological Effects 840910 Meeting in Eureka,Ca Re Review of Util Decommissioning Plan.Pp 1-144 ML20055B5711982-07-21021 July 1982 Order Extending Time Until 820820 for Commission to Act to Review Director'S Decision DD-82-7 ML20054M8201982-07-0707 July 1982 Decision Denying R Guenther Request to Decommission Facility ML20054M9761982-06-29029 June 1982 Exemption from Requirement for Obtaining Property Damage Insurance 1996-10-18
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1 SCOTT L. FIELDER 2{((hf Attorney at Law 2 517 Third Street, Suite 14 Eureka, California 95501 '87 JE -1 P2 :00 3 Telephone: (707) 444-3331 4 Attorney for the Joint Intervenors j((g' .
Douglas H. Bosco, Wcaley Chesbro, 5 Daniel E. Hauser, Barry Keene, The Redwood Alliance, Ralph Kraus, Nona 6 Kraus, Gaye M. Barr and the League of Women Voters of Humboldt 7 County 8 UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION 10 1] ) Docket No. 50-133-OLA
) (Dacommissioning) 12 )
) ASLBP No. 86-536-07 LA 13 )
) JOINT INTERVENORS' THIRD 14 In The Matter Of ) SET OF INTERROGATORIES Pacific Gas and Electric ) PROPOUNDED TO THE LICENSEE 15 Company (Humboldt Bay Power ) PACIFIC GAS AND ELECTRIC Plant, Unit No. 3) ,
) COMPANY 16 17 1. PROPOUNDING PARTY: The Joint Intervenors LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, 18 DANIEL E. HAUSER, BARRY KEENE, DOUGLAS H. BOSCO, WESLEY CHESBRO, REDWOOD ALLIANCE, RALPH KRAUS, 19 NONA KRAUS and GAYE M. BARR 20 21 2. SET NUMBER: THREE 22 3. RESPONDING PARTY: The Licensee, PACIFIC GAS AND ELECTRIC COMPANY 23 24 YOU ARE HEREBY REQUESTED to answer under oath the 25 following interrogatories within fourteen (14) days from the 26 time service is made upon you, in accordance with 10 Code of 27 Federal Regulations section 2.740(b).
28 // 8706020290 B70528 PDR ADOCK 05000133 G PDR
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- .1 GENERAL PROVISIONS 2
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- .The interrogatories ask not only for your own knowledge
! 5 and the contents of your books'and records, but also-the- ,
6 knowledge of.all other persons of whom inquiry may-reasonably l-7 be made :and the contents of your books and records, and those .
g available to you for examination. Your answers to these g interrogatories.should be based on all of the aforementioned 10 sources.
11 If, following your exercise of due diligence to answer-12 any interrogatory, you are still unable to provide the.informa-13 tion requested, please state in detail:
(a) Your answer to the fullest extent possible; 14 15 (b) Why you are unable to answer more fully; 16 (c) What efforts you have made to answer fully; 17 (d) The anticipated date of your completion of such 18 investigation and discovery necessary to answer 19 fully.
20 When an interrogatory asks you to identify a writing,-
g] you may, in lieu of answering that interrogatory, attach a copy 22 of that writing with a statement in answer to.the interrogatory 23 that such co'py is attached and such copy is a true copy of the 24 original of the writing. If you refuse to voluntarily attach 25 a copy of that writing, then identify each such writing in 26 detail so that it may be produced by you in response to a 27 Notice tc Produce or other discovery devices.
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II 2 DEFINITIONS
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When used in these interrogatories and-for purposes 3
5 thereof:
4 6 (a) Licensee means and refers to Pacific' Gas and 7 Electric Company, its agents, employees, servants, representa-4 8 tives, and anyone acting on its behalf or at its request.
9 (b) Facility means and refers to the Humboldt Bay-10 Power Plant, Unit No. 3.
i 11 (c) Writing means. handwriting, typewriting, printing, 12 photostating, photographing, and every other means of recording
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upon any tangible thing any form of communication or representa-
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14 tions including letters, words, pictures, sounds, or symbols, 15 or combination thereof.
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- 17 18 19 INTERROGATORY No. 160 20 For aach Contention which has been' admitted by the
. 21 Licensing Board in the Prehearing Conference Order, dated jl 22 December 3, 1986, in the above-captioned proceeding, state the l 23 following:
24 a. The identity of each person expected to be called 25 as a witness at the hearing;
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26 b. The subject matter on which the witness is expected 27 to testify; 28 c. The substance of the witness's testimony; and, 1
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1 1 d. The witness's professional or other qualifications to 2 testify on the subject matter on which the witness 3 will eeseify, 4
5 cated: 6// 2 8/3 7
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Respectfully submitted, 6
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SCOTT L. FIELDER 0 Attorney for the Intervenors 10 11 12 13 14 15 16 17 18 19 20 21 22 23 .
24 25 26 27 28 i
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9,:. r PROOF OF SERVICE
'87 JJi -1 P2 :00 I am a resident of the County of_H.umboldt. I am over the age of eighteen years and not a g reat,'. y,to the within action. My business address if 517 Third '
Suits 14, Eureka, California, 95501.
On 4 M /
(9 F7 , I served the within JOINT TNTEDVENnDC' muTon egm OF INTERROGATORTER punonnMnpn TO THE LICENRFP DAPTFTc cne nun erygmpeg gg,s77;m on the interested parties in said action by:
(X) placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Eureka, California, addressed as listed below;
( ) personally delivering a true copy thereof to the persons listed below.
I declare under penalty of perjury that the foregoing is true and correct.
Exc uted at Eureka, California, on (1.M i f h.
b CLAUDETTE C. SMITH DROOP OF SERVICE SEE ATTACHMENT 4
- w 1-ATTACHMENT United-States Nuclear Regulatory Commission Public' Document Room 1717 "H" Street NW Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D. C. 20555 Richard F. Locke Pacific Gas & Electric Company P. O. Box 7442 San Francisco, California 94120 Mr. Bruce Norton c/o~ Richard F. Locke Pacific Gas & Electric Company P. O. Box 7442 San Francisco, CA 94120 Mitzi Young, Esq.
Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D. C. 20555-Secretary United States Nuclear Regulatory Commission Washington, D. C. 20555 Robert M. Lazo, Esq.
Chairman Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C. 20555 Dr. James H. Carpenter, Member Atomic Safety & Licensing Board Panel United States Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Peter A. Morris, Member Atomic Safety and Licensing Board Panel United States Nuclear Regulatory Commission
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1 Washington, D. C. 20555 Ralph and Nona Kraus 2479 Wrigley Road Eureka, California 95501
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.i ATTACHMENT (Continued)
Honorable Dan Hauser Assemblyman, 2nd District 1334 Fifth Street-Eureka, California 95501 Honorable Barry Keene Second Senate District 533"G" Stree Eureka, California 95501 Honorable Doug Bosco ,
U. S. congressman 517 7th Street Eureka, California 95501 Honorable Wesley Chesbro Supervisor, Third District P. O. Box 4661 Arcata, California 95521 Redwood Alliance P. O. Box 293 Arcata, California 95521 Gaye M. Barr 1217 Searles St.
Eureka, CA 95501 Kathleen Maloney, Attorney at Law PUC Legal Division 505 Van Ness Ave.
San Francisco, CA 94102 I
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