ML20053E790
| ML20053E790 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/26/1982 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | PARENTS CONCERNED ABOUT INDIAN POINT |
| Shared Package | |
| ML20053E791 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206100093 | |
| Download: ML20053E790 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO!!
BEFORE THE ATOMIC SAFETY AND LICEtiSIllG BOARD In the Matter of
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CONSOLIDATED EDISON C0f1 pally OF NEW
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Docket Hos'. 50-247 SP YORK, IllC. (Indian Point, Unit No. 2) )
50-285 SP
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POWER AUTHORITY OF THE STATE OF NEW
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May 26,1982 YORK (Indian Point, Unit No. 3)
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f4RC STAFF INTERR0GATORIES T0, AND REQUEST FOR DOCUMENTS FROM PARENTS REGARDING QUESTION 6 C0!4TENTIONS INTRODUCTION The NRC Staff hereby requests that Parents Concerned About Indian Point (Parents) pursuant to 10 C.F.R. 5% 2.740b and 2.7F.
answer separately and fully, in writing under oath or affirmation, the follow-ing interrogatories and produce or make available for inspection and copying all documentary material identified in responses to the interrogatories below.
INSTRUCTIONS AND DEFINITIONS j
1.
Information sought in these Interrogatories shall include information within the knowledge, possession, control or access of any agents, employees and independent contractors of Parents.
2.
Answer each Interrogatory separately (by part) in writing under cath or affirmation of the individuals who contributed thereto. Documents produced shall indicate in response to which specific request the docu-ments are being produced, i.e., 1(a).
For all references requested in
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m these 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 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 subsection of said Interrogatory is not possible, such Interrogatory, section or subsection 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 (by part) 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 hesis 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. Q 2.740(e) these Interrogatories and requests for documents require prompt supplemental answers should M
Parents 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 Parents 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 Parents, 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 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 Parents.
INTERROGATORIES Interrogatory 1 Identify all documentary or other material that you intend to use during this proceeding to support Contention 6.2 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 Contention 6.2?
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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 Contention 6.2.
Interroaatory 3 (Refer to Contention 6.2)
Specifically identify the aspects of the childrens " physical environment" that will be improved by permanently shutting down the Indian Point Huclear Power Station.
DOCUMENT REQUESTS Provide for inspection and copying by the NRC Staff all documents identified in Parents' answers to Interrogatories 1 through 3 above.
Re ectfully submitted,
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y Hen y J. McGurren Co'unsel for NRC Staff Dated at Bethesda, Maryland this 26th day of May,1982 t
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