ML20053E796
| ML20053E796 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/26/1982 |
| From: | Mccgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | WEST BRANCH CONSERVATION ASSOCIATION |
| Shared Package | |
| ML20053E791 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206100100 | |
| Download: ML20053E796 (4) | |
Text
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UNITED STATES OF iERICA PI, ',
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEllSING BOARD In the Matter of
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CONSOLIDATED EDIS0N COMPANY OF NEW
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Docket Nos.- 50-247 SP YORK, INC. (Indian Point, Unit No. 2) 50-286 SP POWER AUTHORITY OF THE STATE OF
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May 26, 1982 flew YORK (Indian Point, Unit No'. 3)
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i NRC STAFF INTERR0GATORIES T0, AND
,3 REQUEST FOR DOCUMENTS FROM WBCA i(*,
REGARDING QUESTI0ft 6 CONTENTIONS The NRC Staff hereby requests that West Branch Conservation Association (WBCA) 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 trall documentary material identified in responses to the interrogatories b
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INSTRUCTIONS AND DEFINITIONS 1.
Information sodght in these Interrogatories shall include j
information within the knowledge, possession, control or access of any agents, employees and independent contractors of WBCA.
2.
Answer each Interrogatory separately (by part) in writing under oath 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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_2 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
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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 1
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.
S.
If any Interrogatory or part thereof is cbjected 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 basis for the assertion of l
privilege, and the present location of the document.
7.
If any document requested is unavailable, explain the i
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 i
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e 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 i
requested that oral clarification be requested of the undersigned Staff
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Any word, term, or phrase is to have its gene' rally 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, transcripts, microfilm, accounting state-ments, 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.
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INTERROGATORIES i
INTERROGATORY 1
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Identify all documentary or other material that you intend to use during this proceeding to support Contention 6.1 and that you may offer as exhibits l
on these contentions or refer to during your cross-examination of witnesses l
presented by Consolidated Edison Company of New York, Inc., Power Authority of the State of New York, or the NRC Staff.
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INTERROGATORY 2 a)~ Upon what person or persons do you rely to substantiate in whole or in part your case on Contention 6.1?
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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 6.1.
INTERR0GATORY 3 (Refer to Contention 6.1) 4 Identify the unit (s) on the Orange and Rockland Systems (0 & R) that will be available to provide 300 MW of replacement power for the Indian Point Station.
For the unit (s) identified specify:
1 (a) The years of availability of each unit identified.
(b) The MWe of each unit identified.
(c) The type of fuel utilized by each unit identified.
t (d) An estimate of fuel and variable operation and maintenance (0 & M) cost per KWh for each unit i
identified.
INTERROGATORY 4 If any of the units identified in your response to Interrogatory 3, above, are not oil-fired units explain the basis for making such capacity avail-able to Con Ed and/or PASHY.
In your answer to this Interrogatory, indi-cate whether making such capacity available to Con Ed and/or PASNY will increase production costs to be borne by the Orange and Rockland Systems and, if so, estimate by how much such production costs will be increased.
_ INTERROGATORY 5 Quantify the specific economic benefits occuring to Rockland County through the sale of the 300 MW of replacement power.
DOCUMENT REQUESTS Provide for inspection and copying by the NRC Staff all documents identified in WBCA's answers to Interrogatories 1 through 5 above.
Respectfully submitted, Henry J. McGurren Coun'el for NRC Staff Dated at Bethesda, Maryland this 26th day of May, 1982.
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