ML20028B911
| ML20028B911 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/04/1982 |
| From: | Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8212070209 | |
| Download: ML20028B911 (3) | |
Text
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,_s UNITED STATES OF NAERICA DCL$I NUN
- AR REGULATORY COMMIS510N,' F ATOMIC SAFETY AND LICENSING,gg.g gj %2 Administrative Judges:
James G1eason, Chairman Ticcdi[t.(
Dr. Oscar H. Paris In the Mattee of Frederick 3. Shon
/
CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit 2) 50-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK, December 4, 1982 (Indian Point, Unit 3)
WEST BRANCH CONSERVATION ASSOCIATION'S REPLY TO MOTION OF<THE LICENSEES OF DECEMBER 1 TO DISMISS CERTAIN CONTENTIONS We received Licensees' motion on December 2 as well a telephone call from Ruthanne Miller, Esq. in which she as suggested there would be a conference call at 1:30 PM on Dec.
3.
Both the President and Vice-President of WBCA had another matter to attend on that date and time but we could-be avail-(
able from 9-11 AM.
However, the time of the call was not changed but we did hear from Miss Miller that we should reply to the motion.
We are unhappy about having to do so on a Saturday.
Regarding New Contention 2.2(b) which the Board's Order of October 1 redefined.
That Order did not state how the conten-tion would be handled.
In early 1982 we had suggested that em-brittlement was a safety ralated problem.
We did not offer to address it as it is now written nor did we know until after for West Branch Conservation Association l
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s the Novembar conforancas of the 3rd tnd 4th, that wa would I
not be able to have all the materials available to us. We cannot offer to pay for the printed materials because we don't know how much they would total and there is no time for such correspondence under the present calendar.
We have no option.
for interrogatory on a new subject, 2.2.1 as well as 2.2(b).
If the object is to drive away the public intervenors in-tentionally or not, that is the resultant effect.
Therefore, since the Board rewrote contention 2.2(b) we expect it to assume the burden and transfer the requirements to the Staff and licensees just as it has done with other new questions, see #7 on page 41 of Order of October 1, 1982.
Since the Board gave good reasons for redrawing the question, ibid p. 21, we strongly urge the Board to clarify the responsibility.
WBCA intends to address, under question 2, contention 2.2(a), the only remaining contention of the four we were originally granted.
We would like to address 2.2.1 and 2.2(b) if we can be given any information as we cannot go forward with the new question 2.2.1 when the materials are so difficult to obtain, as described in ours of November 24.
The studies that are available to the NRC and licensees are not available to the public parties.
We urge the Board to deny the motion of December 1 for the reasons stated above.
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y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10y3. g
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ATOMIC SAFETY AND LICENSING 80ARD Be fore Administ rative Jygg($)-6 All :42 James Gleason Chairman Frederick J. Shon'
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In the Matter of Dr.' Oscar H. Paris
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CONSOLIDATED EDISON COMPANY OF
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NEW YORK, INC. (Indian Poine,
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Unit No. 2)
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Docket Nos. 50-247-SP
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> 50-286-SP POWER AUTHORITY OF THE STATE OF
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NEW YORK, (Indian Point,
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I)ecember 4, 1982 Unit No. 3)
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CERTIFICATE OF SERVICE THIS IS TO CERTIFY THAT I HAVE MAILED BY FIRST CLASS, A COPY OF WEST BRANCH CONSERVATION ASSOCIATION'S REPLY TO LICENSEES' MOTION OF DECEMBER 1 AND A!OTION TO COMPEL DISCOVERY TO THOSE MARKED WITH AN ASTERISK IN LIST BELOW c
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20555 443 Buena Vista Road, New City, N.Y. 10956 914/634-2327 g f, g by 21pporah S.
Fleisher Secretary s.