ML20052D198
| ML20052D198 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/28/1982 |
| From: | PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| To: | WESTCHESTER COUNTY, NY |
| References | |
| ISSUANCES-SP, NUDOCS 8205060353 | |
| Download: ML20052D198 (2) | |
Text
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.^,.O UNITED STATES OF AMERICA 00@UCD I' "
NUCLEAR REGULATORY C0W11SSION i
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3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9
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'aD M rQP CONSOLIDATED EDISON COMPANY OF NEW YORK
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Docket Nos. 50-247 SPL '
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50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK
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(Indian Point Unit 3)
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UCS/NYPIRG's FIRST SI:T OF INIERROGA'IORIES 'IO AND REQUEST EOR DOCUMENIS FBOM WESIUit:51tx COUNIY The New York Public Interest Research Group, Inc. and the Union of Concerned Scientists serves on Westchester County the first set of interrogatories and request for production of documents that appears below.
A sworn response to them must be provided to the New York Public Interest Research Group, Inc. and the Union of Concerned Scientists at 5 Beekman Street, New York, New York 10038 in accordance with the terms of 10 C.F.R. 2.740(b) and 2.741(d) and in accordance with the Order of the Atcmic Safety and Licensing Board of April 23, 1982. If the answer to any question is not known when the response is filed, the answer must be provided as soon as the missing information beccnes available.
As used in the interrogatories and request for production of doctnents, the following definitions apply:
- 1. "Westchester County" is meant to include its officers, agents, enployees, l
and consultants.
2.
" Facts" include the calculational or other assumptions, if any, underlying various assertions of fact.
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" Include" and "incluiing," as used in these\\tertugatories, mean 3.
" including, but not limited to."
4.
"Docunent" means any handwritten, typed, printed, recorded or graphic matter, however prwhrwi or run.cAvwl, including material stored for use in automatic data processing systems, whether or not in the possession, custody or control of the Comty and whether or not cininv_1 to be privileged against discovery on any ground, including: reports; records; lists; menoranda; cor-respondence; telegrams; schedules; photographs; sound recordings; filns; hand, machine and conputer calculations; ocmputer codes; data; and written statements of witneses or other persons having knowledge of the facts.
5.
" Studies or observations" include physical, enpirical, calculational, assuietional, and other types of work whether recorded in writing or not.
6.
" Emergency plans" or "the plans" refers to the Radiological Emergency Besponse Plans for the County and, where applicable, for New York State.
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