ML19206A734
| ML19206A734 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/18/1976 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7904200391 | |
| Download: ML19206A734 (8) | |
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10/18/76 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN BEFORE THE ATCMIC SAFETY AND LICENSING EOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-320.
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Unit 2)
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.s Q :.T. j, f -L NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS EY INTERVENORS CITIZENS FOR A SAFE ENVIRONMENT / YORK COMMITTEE FOR A SAFE ENVIRCTMENT Pursuant to 10 CFR S 2.740b. of the Commission's Rules of Practice, the Nuclear' Regulatory Commission Staff (Staff) hereby requests that the Intervenors Citizens t
for a Safe Environment / York Committee for a Safe Environment (Intervencrs) answer separately and fully, in writing and under oath, the interrogatories set forth below.
Pursuant to 10 CFR S 2.741 of the Commission's Rules of Practice, the Staff here-by requests that the Intervenors provide or produce for inspection and copying the documents designated in the Interrogatories and replies thereto.
As used herein, the term " documents" means all writings and records of every type in the possession, control cr custody of the Intervenors, its directors, members, officers, employees, counsel, consultants, or agents, including, ' cut not limited to, memoranda, correspondence, reports, surveys, tabulations, fly 7904200 3 9 60 294
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charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, ledgers,
transcripts, computer printouts, vouchers, engineering diagrams, recordings,
telephone and telegraphic communications, speeches, and all other records,
written, electrical, or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custodj, or control of the Intervenors, and every copy of a dccument which contains handwritten or other notations or which otherwise dees not duplicate the original or any other copy.
The interrogatories attached are to be considered the Intervenors' continuing obligation. Accordinglf, if, after the Intervenors have answered these interro-gatories, additional information comes to its attention with respect to one or.more o
of the answers, then the answers should be amended to provide such additional information.
The numbering of the contentions is that used by the Licensing Board in its Pre-s hearing Conference Order, dated November 6,1975.
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_3 INTERRCGATORIES Contentien 5 1.
Identify, by name and address, each individual whom you intend to call as a witness with respect to this contention and state the edu-cational and professional qualifications of each st... individual.
2.
Identify each document upon which this contention is based.
3.
Identify each document which you intend to rely upon, either in your direct case or as basis for cross-examination, with regar2 to this contention.
4.
Specifically icientify the bases for the averment: "(b]oth the Boeing t
747 and the Lcckheed C-5A are reasonably expected to frequent Harrisburg International Airpcrt and greatly exceed the kinetic energy set for the design considerations."
C_ontention 6 1.
Identify, by name and address, each individual whom fou intend to call as a witness with respect to this contention and state the edu-cational and professional qualifications of each such individual.
2.
Identify cach document upon which this contention is based.
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3.
Identify each document which you intend to rely upon, either in your direct case or as basis for cross-examination, with regard to this contention.
Contention 7 1.
Identify, by name and address, each individual whom you intend to call as a witness with respect to this contention and state the edu-cational and professional qualifications of each such individual.
2.
Identify each document upon which this contention is based.
3.
Identify each document which you intend to rely upon: either in your direct case or as basis for cross-examination, with regard to this con-r tention.
4.
Identify the "... intentional c: forts cf man to effect weather modification' which render historical ficod data of questionable value. Specify for each such intentional effort of man the basis for the assertion that such effort will render historical ficod data of questionable value.
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~ Contention 8 Identify, by name and address, each individual whom you intend to 1.
call as a witness with respect to this contention and state the edu-cational and professional qualifications of each such individual.
Identify each document upon which this centention is based.
2.
Identify each document 'ehich you intend to rely upon, either in your 3.
direct case or as basis for cross-examination, with regard to this contention.
Contentien 9 Identify, by name and address, each individual whom you intend to 1.
call as a witness with respect to this contention and state the edu-cational and professional qualifications of each such individual.
Identify each document upon which this contention is based.
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3.
Identify each document which you intend to rely upon, either in your direct ense or as basis for cross-examination, with regard to this contention.60-298 ee -
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6-Contention 11 Identify, by name and address, each individual whom you intend to 1.
call as a witness with respect to this contention and state the edu-cational and professional qualifications of each such individual.
Identify each document upon which this contention is based.
2.
3.
Identify each document which you intend to rely upon, either in 'four direct case or as basis for cross-examination, with regard to this contention.
Identify the interaction between the gaseous releases of radioactivity 4.
and the cooling tower plumes that can increase the thyroid dose by the cow-milk pathway by up to a factor of 10 and with respect to the factor of 10, provide youi calculations specifying the basis for each assumption.
Respectfull'j submitted, dQ
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/ Henry J. McGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day o'f Oc.tober,1976.
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