ML20052C519
| ML20052C519 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/03/1982 |
| From: | Hassell D, Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | WEST BRANCH CONSERVATION ASSOCIATION |
| Shared Package | |
| ML20052C512 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8205050077 | |
| Download: ML20052C519 (8) | |
Text
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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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CONSOLIDATED EDISON COMPANY OF NEW
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Docket Nos. 50-247 SP YORK INC. (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 SJAFF INTERR0GATORIES T0, AND REQUEST FOR DOCUMENTS FROM WBCA INTRODUCTION The NRC Staff hereby request that WBCA pursuant to 10 C.F.R. 66 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 agents, employees and independent contractors of WBCA.
2.
Answer each Interrogatory separately in writing under oath or affirmation of the individuals who contributed thereto. Do.cuments 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 8205050077 820503 PDR ADOCK 0500024'7 G
interrogatories, identify them by author, title, date of publication and publisher if the reference is published; and if it is not pt.blished, 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 of the document may be obtained.
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 privi'ege claimed, the basis for the assertion of privilege, and the present location of the document.
7.
If any doctment requested is unavailable, explain the circumstances of su;h unavailability.
l 8.
In accordance with 10 C.F.R. 9 2.740(e) these' Interrogatories l
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l and requests for documents require prompt supplemental answers should s
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WBCA 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 WBCA 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 WBCA, its directors, officers, attorneys, employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, trenscripts, microfilm, accounting statements, telephone and telegraphic communications, speeches, and all 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 the WBCA.
INTERR0GATORIES Interrogatory 1 Identify all documentary or other material that you intend to use during this proceeding to support Contentions 3.2, 3.3, 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 3.2, 3.3, 3.9, 4.3,.4.4, and 4.7?
l 4-t 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 these contentions referenced in 2a. above.
Interrogatory 3 (Refer to Contention 3.2) a)
In your filing of January 11, 1982, you state "0 range and Rockland Utilities cannot be sure that key personnel will not abandon their posts."
Identify the " key personnel" you refer to, specify the County where they are employed and identify their employer.
b) With regard to Contention 3.2, define what is meant by " utility employees".
DOCUMENT REQUESTS 1.
Provide for inspection and copying by the NRC Staff all documents identified in WBCA's answers to interrogatories 1 through 3 above.
2.
Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to emergency planning (State, local, or on-site plans) for Indian Point Units 2 and 3.
Respec-ully submitted, t
c Donald F. Hassell Counsel for NRC Staff b'
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J. McGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of May,1982.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSOLIDATED EDISON COMPANY
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Docket Nos. 50-247-SP 0F NEW YORK (Indian Point, Unit 2 50-286-SP POWER AUTHORITY OF THE STATE OF
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NEW YORK (Indian Point, Unit 3)
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t NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 5 2.713(b),
10 C.F.R. Part 2, the following information is provided:
Name:
Donald F. Hassell U.S. Nuclear Regulatory Commission Address:
Office of the Executive Legal Director Washington, DC 20555 Telephone Number Area Code (301) 492-7543~
Admissions:
Supreme Court of the United States of America; U.S. District Court for the Western District of Pennsylvania; Supreme Court of Pennsylvania NRC Staff Name of Party Lb
\\ M Donald F. Hassell
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Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of May, 1982 i
p DESIGNATED OR10!NAI).s Certified By k
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UNITED STATES OF AMERICA Obd9 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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/ '\\% MG, CONSOLIDATED EDIS0N COMPANY Docket Nos. 50-247-0F NEW YORK (Indian Point, Unit 2 50-286 #
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POWER AUTHORITY OF THE STATE OF
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0 NEWYORK(IndianPoint, Unit 3)
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I CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES T0, AND R DOCUMENTS FROM PARENTS", "NRC STAFF INTERR0GATORI2S T0, AND REQUEST FOR FROM WESPAC", "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM UCS/
NYPIRG" and "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM WBCA" and " NOTICE OF APPEARANCE" for Donald F. Hassell in the above-captioned proceeding.
have been sarved on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 3rd day of May, 1982:
Louis J. Carter, Esq., Chairman Paul F. Colarulli, Esq.
Administrative Judge Joseph J. Levin, Jr., Esq.
Atomic Safety and Licensing Board Pamela S. Horowitz, Esq.
7300 City Line Avenue Charles Morgan, Jr., Esq.
Philadelphia, PA 19151-2291 Morgan Associates, Chartered 1899 L Street, N.W.
Dr. Oscar H. Paris Washington, D.C.
20036 Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq.
U.S. Nuclear Regulatory Commission Thomas R. Frey, Esq.
Power Authority of the State Washington, D.C.
20555
10019 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Ellyn R. Weiss, Esq.
William S. Jordan, III, Esq.
Washington, D.C.
20555
- Harmon & Weiss Brent L. Brandenburg, Esq.
1725 I Street, N.W., Suite 506 Assistant General Counsel Washington, D.C.
20006 Consolidated Edison Co. of New York, Inc.
Joan Holtr. Project Director 4 Irving Place Indian Point Project New York. N.Y.
10003 New York Public Interest Research Group DN2 Mayor George V. Begany 5 Beekman Street
.r Village of Buchanan New York, N.Y.
10038 236 Tate Avenue
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Buchanan, N.Y.
10511
John Gilroy, Westchester Coordinator Stanley B. Klimberg Indian Point Project General Counsel New York Public Interest New York State Energy Office Research Group 2 Rockefeller State Plaza 240 Central Avenue Albany, N.Y.
12223 White Plains, N.Y.
10606 Marc L. Parris, Esq.
Jeffrey M. Blum, Esq.
Eric Thorsen, Esq.
New York University Law School County Attorney, County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road 40 Washington Square South New City, N.Y.
10956 New York, N.Y.
10012 Geoffrey Cobb Ryan Charles J. Maikish, Esq.
Conservation Committee Litigation Division Chairman, Director The Port Authority of New York City Audubon Society New Yerk and New Jersey 71 West 23rd Street, Suite 1828 One World Trade Center New York, N.Y.
10010 New York, N.Y.
10048 Greater New York Council on Ezra I. Bialik, Esq.
Energy Steve Leipsiz, Esq.
c/o Dean R. Corren, Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y.
10003 Two World Trade Center New York, N.Y.
10047 Honorable Richard L. Brodsky Member of the County Legislature Alfred B. Del Bello Westchester County Westchester County Executive County Office Building Westchester County White Plains, N.Y.
10601 148 Martine Avenue White Plains, NY 10601 Pat Posner, Spokesperson Parents Concerned About Andrew S. Roffe, Esq.
Indian Point New York State Assembly P.O. Box 125 Albany, N.Y.
12248 Croton-on-Hudson, N.Y.
10520 Renee Schwartz, Esq.
Charles A. Scheiner, Botein, Hays, Sklar & Herzberg Co-Chairperson Attorneys for Metropolitan Westchester People's Action Transportation Authority Coalition, Inc.
200 Park Avenue P.O. Box 488 New York, N.Y, 10166 White P1ains, N.Y.
10602 Honorable Ruth Messinger Lorna Salzman Member of the Council of the Mid-Atlantic Representative City of New York Friends of'the Earth, Inc.
District #4 208 West 13th Street City Hall New York, N.Y.
10011 New York, N.Y.
10007 e
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Alan Latman, Esq.
Ms. Amanda Potterfield, Esq.
44 Sunset Drive P.O. Box 384 Croton-on-Hudson, N.Y.
10520 Village Station New York, NY 10014 4
Zipporah S. Fleisher West Branch Conservation Renee Schwartz, Esq.
Association Paul Chessin, Esq.
443 Buena Vista Road Laurens R. Schwartz, Esq.
New City, N.Y.
10956 Margaret Oppel, Esq.
Botein, Hays, Sklar & Hertzberg Judith Kessler, Coordinator 200 Park Avenue Rockland Citizens for Safe Energy New York, NY 10166 300 New Hempstead Road New City, N.Y.
10956 David H. Pikus, Esq.
Richard F. Czaja, Esq.
330 Madison Avenue New York, N.Y.
10017 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 P
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' Donald F. Hassel'l Counsel for NRC Staff 8
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