ML20052C515
| ML20052C515 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/03/1982 |
| From: | Hassell D, Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | WESTCHESTER PEOPLES ACTION COALITION, INC. |
| Shared Package | |
| ML20052C512 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8205050072 | |
| Download: ML20052C515 (4) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0f1 MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of
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CONSOLIDATED EDISON COMPANY OF NEW
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Docket Nos. 50-247 SP YORK IllC. (Indian Point, Unit No. 2)
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50-286 SP
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POWER AUTHORITY OF THE STATE OF NEW
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May 3, 1982 YORK (Indian Point, Unit No. 3)
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NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR DOCUMENTS FROM WESPAC INTRODUCTION The NRC Staff hereby request that WESPAC pursuant to 10 C.F.R.
$$ 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying all documentary material identified in responses to the interrogatories below.
INSTRUCTIONS AND DEFINITIONS 1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any f
agents, employees and independent contractors of WESPAC.
2.
Answer each Interrogatory separately in writing under oath or affirmation of the individuals who contributed thereto.
Documents produced shall indicate in response to which specific request the docu-
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ments are being produced. For all references requested.in these 8205050072 820503 PDR ADOCK 05000247 0
interrogatories, identify them by author, title, date of publication and publisher if the reference is published; and if it is not published, identify the document by the author, title, the date it was written, the qualification of the author relevant to this proceeding, and where a copy f
of the document may be obtained.
7 3.
In your answer, repeat each Interrogatory set forth herein and then set forth an answer thereto separately and fully. As to any Interrogatory, section or subsection of said Interrogatory that you refuse to answer for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or sub-section of said Interrogatory is not possible, such Interrogatory, section or sub-section of said Interrogatory should be answered to the extent possible and a statement made indicating the reason for the partial answer.
4.
Identify any documents used as the basis for the answer to the Interrogatory.
5.
If any Interrogatory or part thereof is objected to, state separately the objection and basis therefor.
6.
If privilege is claimed as to any document, identify what is being withheld, the date of the document, the sender (s), the recipient (s) of all copies, the privilege claimed, the basis for the assertion of privilege, and the present location of the document.
7.
If any document requested is unavailable, explain the circumstances of such unavailability.
8.
In accordance with 10 C.F.R. % 2.740(e) these Interrogatories and requests for documents require prompt supplemental answers should
r WESPAC obtain or identify supplemental information or documents which call into question the correctness of earlier answers.
9.
In the event any word, term, or phrase is unclear to WESPAC it is requested that oral clarification be requested of the undersigned Staff counsel. Any word, term, or phrase is to have its generally accepted meaning.
10.
" Documents" means all writings and records of every type in the possession, control or custody of WESPAC, its directors, officers, attorneys, employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting i
statements, telephone and telegraphic communications, speeches, and all f
other records, written, electrical, mechanical or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of tha WESPAC.
INTERR0GATORIES Interrogatory 1 Identify all documentary or other material that you intend to use during this proceeding to support Contentions 3.1, 3.2, 3.4, 3.6, 3.9 4.3, 4.4 and 4.7 and that you may offer as exhibits on these contentions or refer to during your cross-examination of witnesses presented by Consolidated Edison Company of New York Inc., Power Authority of The State of New York, or the NRC Staff.
Interrogatory 2 a) Upon what person or persons do you rely to substantiate in whole or in part your case on Contentions 3.1, 3.2, 3.4, 3.6, 3.9 4.3, 4.4 and -
4.7?
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-4 b) Provide the address and education and professional qualifications of any persons named in your response to 2a. above.
c)
Identify which of the above persons or any other persons you may call as witnesses on the contentions referenced in 2a. above.
Interrogatory 3 (Refer to Contention 4.4) a)
Identify the "special groups with special needs" (Contention 4.4) and " groups" (WESPAC Contention 6) and location of such groups that you believe require that "the emergency plans should be upgraded".
b) Specify, making reference to the groups identified in your answer to Interrogatory 3a. above, how the emergency plans should be upgraded to "take into account" (WESPAC Contention 6) these groups.
DOCUMENT REQUESTS 1.
Provide for inspection and copying by the NRC Staff all documents identified in WESPAC's answers to interrogatories 1 through 3 above.
2.
Provide for inspection and copying all by the NRC Staff documents within the possession or control of WESPAC which relate to emergency planning (State, local, or on-site plans) for Indian Point Units 2 and 3.
Resp tfully submitted, l
/
Qf ya.
Donald F. Hassel Counsel for NRC Staff O
J enrhd.McGurren
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Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of May, 1982.
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