ML20023B403

First Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence

ML20023B403
Person / Time
Site:	Washington Public Power Supply System
Issue date:	05/03/1983
From:	Reynolds N DEBEVOISE & LIBERMAN, WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION
References
ISSUANCES-CPA, NUDOCS 8305050019
Download: ML20023B403 (9)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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WASHINGTON PUBLIC POWER )

SUPPLY SYSTEM ) Docket No. 50-460-CPA

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(WPPSS Nuclear Project No. 1) )

LICENSEE'S FIRST SET OF INTERROGATORIES AND REQUESTS -

TO PRODUCE TO INTERVENOR Pursuant to 10 C.F.R. $$2.740b and 2.741, the Washington Public Power Supply System (Licensee) hereby serves Applicant's First Set of Interrogatories and Requests to produce upon the Coalition for Safe Power (intervenor).

Each interrogatory shall be answered fully in writ-ing, under oath or affirmation, and include all pertinent information known to intervenor, its officers, directors or members as well as any pertinent information known to its employees, advisors, representatives or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of intervenor, its officers, directors or members as well :s its em-ployees, advisors, representatives or counsel. In answer-ing each interrogatory and in responding to each request, 13 8305050019 830503 PDR ADDCK 05000460 0 PDR

y recite the interrogatory or request preceding each answer or response. Also, identify the person providing each-answer or response.

These interrogator'_es and requests shall be continu-ing in nature. Thus, any time intervenor obtains informa-tion which renders any previous response incorrect or indicates that a response was incorrect when made, inter-venor should supplement its previous response to the ,

appropriate interrogatory or request to produce. Inter-venor should also supplement its. response as necessary with respect to identification of each person expected to be called at the hearing as a witness, the subject matter of his or her testimony and the substance of that testi-mony. Licensee is particularly interested in the names and areas of expertise of intervenor witncsses, if any.

Identification' of such witnesses is necessary if Licensee is to be afforded adequate time to depose them. The 7t enn

" documents" shall include any writings, drawings, graphs, charts, photographs and other data compilations from which information can be obtained. Licensee requests that at a date or dates to be agreed upon, intervenor make available for inspection and copying all documents subject to the requests set forth below.

3 REQUESTS FOR DOCUMENTS Pursuant to 10 C.F.R. $2.741, Licensee requests intervonor by and through its representative or attorney to make available for inspection and copying at a time and location to be-designated, any and all documents identi-fied in the responses to the Licensee's interrogatories below including, but not limited to:

(1) any written record of any oral commu-nication between or among intervenor, -

its advisors, consultants, representa-tive, and/or any other persons, in-cluding but not limited to the NRC Staff, the Licensee, and their advi-sors, consultants, agents, and/or any other persons; and (2) any documents, correspondence, letters, memoranda, notes, diagrams, reports, charts, photographs, or any other writing, including but not limited to work papers, prior drafts, and notes of meetings.

If intervenor maintains that some documents should not be made available for inspection, it should specify the documents and explain why such are not being made available. This requirement extends to any such docu-ments, described above, in the possession of intervenor, its advisors, consultants, representatives, or attorney.

q INTERROGATORIES Pursuant to 10 C.F.R. $2.740b, the Licensee requests intervenor by and through its representative or attorney to answer separately and fully in writing, under oath or affirmation, by persons having knowledge of the informa-tion requested, the following interrogatories.

1. State the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof he or ~

she answered.

2. Identify each and every person you are considering calling as a witness in the event a hearing is held in this proceeding and with respect to each of these witnesses:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a senmary of the grounds for each opinion; and

c. Describe the witness's educational and profes-sional background.

3. Is your contention based upon conversations, consultations, correspondence or any other type of communications with one or more individuals? If so,

a. Identify by name and address each of these indi-viduals.

b. State the educational and professional background of each of these individuals, when each communi-cation occurred, and identify all other indivi-duals involved.

c. Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.

d. Describe the information received from such indi-viduals and explain how it provides a basis for your contention.

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e. Identify each letter,. memorandum, tape, note or other record related to.each conversation, consultation, correspondence or other communica-tion with such individual.

4. Please identify and provide a copy of the current charter, bylaws, articles of incorporation and/or all other organic docanents pursuant to which intervenor-is organized.

5. Have the documents identified and provided in inter-

.rogatory 4 amended and/or superceded any earlier charters, bylaws, articles of incorporation and/or organic documents pursuant to which intervenor was organized? If so:

a. Identify and provide each of these amended and superceded douments.

b. Explain why these documents were amended and/or superceded.

c. Identify and provide all documents in which the actions explained in interrogatory 5(b) are dis-cussed.

6. Explain the organizational goals of intervenor.

7. What is the complete basis for your statement that Licensee's " decision in April, 1982 to ' defer' con-struction for two to five years, and subsequent ces-sation of construction'at WNP-1 was dilatory."

l 8. Please explain fully what you mean by the word

! " defer" as used in your contention.

9. Please explain fully what you mean by the word

" dilatory" as used in your contention.

10. What is the basis for your response to interroga-l tories 8 and 97

11. Why do you contend that Licensee has failed to estab-lish good cause for an extension of the WM?-l con-struction permit?

i 12. What are the reasons you believe Licensee offered to L NRC in support of a showing of " good cause" as l~

required by 10 C.F.R. $50.55(b)?

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13. What is the basis for your response to interrogatory 12?

14. Do you contend that the reasons offered by Licensee to support a showing of good cause are factually -

incorrect?

15. What is the basis for your response to interrogatory 14?

16. Do you contend that the reasons offered by Licensee to support a showing of good cause are not in fact the reasons Why Licensee has requested an extension of its construction permit?

17. If your response to interrogatory 16 is yes, Why do you believe that Licensee has (a) sought an extension of its construction permit and (b) deferred construc-tion at WNP-l?

18. What is the basis for your response to interroga-tories 16 and 177 19 . -- What is the basis for your statement that the

~" modified request for extension of completion date to 1991 does not constitute a ' reasonable period' of time provided for in-10 C.F.R. 50.55(b)?"

20. 'Please explain fully What you mean by a " reasonable period of time" as used in your contention.

21. What factors do you contend should be considered When determining if a requested construction permit ex-l tension is for a " reasonable period of time"?

22. What do you contend would constitute a " reasonable period of time" in the case of WNP-l?

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23. What is the basis for your response to interroga-tories, 20, 21 and 227 Respec ul y submitted, b S. Reynolds Nicholp Sanfordl L. Martman DEBEVQ1 E& LIBERMAN 1200S$vep'henthSt., N. W.

WashingtoY, D. C. 20036 202/859-9817 .

Counsel for Licensee May 3, 1983 wi---- * ---g-% v-- gw----w e-- ,.e-

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5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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WASHINGTON PUBLIC POWER ) Docket No. 50-460-CPA SUPPLY SYSTEM )

)

(WPPSS Nuclear Project No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing

" Licensee's First Set of Interrogatories and Requests to Produce to Intervenor" in the captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid this 3rd day of May, 1983:

Herbert Grossman, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mitzi A. Young, Esq.

Mr. Glenn O. Bright Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Chairman, Atomic Safety and Dr. Jerry Harbour Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

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'r Mr. Gerald C. Sorensen Nicholas D. Lewis, Chairman Manager of Licensing. .

. Energy Facility Site Washington Public Power Evaluation Council e Supply System F'. ate of Washington L'~

3000 George Washington Way hail Stop PY-ll Richland, Washington 99352 Olympia, Washington 98504 1 s

Mr. Scott W. Stucky Mr. Eugene Rosolie -

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Docketing & Service Branch Coalition for Safe Power-- g b

U. S. Nuclear Regulatory. Suite 527 Commission 408 Sodth West 2nd Washington, D. C. 99352 Portland, Oregon 97204

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