ML20054F927

List of Documents Licensees Have No Objection to Producing. Documents Absent at 820526 Document Production Requested. Various Documents Have Been Copied & Await Receipt

ML20054F927
Person / Time
Site:	Indian Point
Issue date:	06/11/1982
From:	Brandenburg B, Pikus D CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Potterfield A PUBLIC INTEREST RESEARCH GROUP, NEW YORK
References
ISSUANCES-SP, NUDOCS 8206180214
Download: ML20054F927 (3)

Text

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POWER AUTHORITY OF THE STATE OF NEW YORK 10 COLUMBUS CIRCLE NEW YORK, NEW YORK 10019 ._ ,,

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.

4 IRVING PLACE g

NEW YORK, NEW YORK 10003 _

June 11, 1982 Amanda Potterfield, Esq.

New York Public Interest Research Group, Inc.

9 Murray Street New York, New York 10007 Re: Consolidated Edison Company (Indian Point, Unit 2); Power Authority of the State of New York (Indian Point, Unit 3);

Docket Nos. 50-247-SP; 50-286-SP

Dear Ms. Potterfield:

We have your letter of June 3 regarding supplemental requests for document production.

A. Additional documents requested by UCS/NYPIRG.

Licensees have no objection to producing the following additional documents:

- Aldrich, D.C. and Ericson, D.M., Jr., Public Protection Strategies in the Event of a Nuclear Reactor Accident: Multi-Cocpactment Ventilation Model for Shelters, SAND 77-1559, Jan. 1978.

- Aldrich , D.C. , Ericson, D.M. , Jr. and Johnson, J.D., Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Con-cepts with Existing Public and Private Structures, SAND 77-1725, Feb., 1978.

Yg[$

- Yankelovich, Skelly and White, "A Report on Temporary Housing Related to Evacuation of the Indian Point Power Plant Area", June 1980.

Please feel free to call me to arrange a mutually convenient time to inspect these documents at our office. We do not presently 06180214 820611 R ADOCK 05000247 PDR

1 e

Amanda Potterfield, Esq.

June 11, 1982 Page Two have available copies of Aldrich & Ericson studies bbt we expect to have them within the next week. ,

At the depositions of Dr. Dynes and Dr. Lecker last week, we advised you that the Highway capacity Manual should be avail-cble at a variety of public repositories in New York. A complete citation to this work appears at p. 7 of the January 1981 Parsons Brinckerhof f methodology document, which was made available to you on May 17. Our consultants subsequently confirmed our belief, and suggest that you contact the New York University Library, the Columbia University Library, the Brooklyn Polytechnic Institute Library, local offices of the New York City and State Departments of Transportation, or the New York City Public Library, all of which are likely to have copies.

The licensees do not intend to produce either the Institute for Nuclear Power Operations ("INPO") Evaluation Report or documents requested in UCS/NYPIRG Interrogatory 67. The INPO report was inadvertently and erroneously included in licensees' response to UCS/NYPIRG Interrogatory 2; our response is being amended accordingly. Neither the licensees nor Parsons Brinckerhoff Quade & Douglas have relied upon the INPO report in preparing their testimony, and its contents are beyond the scope of. any contention for which UCS/NYPIRG has been assigned lead or contributing intervenor status and not within the scope of discovery as defined by 10 CFR S2.740(b). We regret any inconvenience occasioned by our error.

. We also maintain our objections to UCS/NYPIRG Interrogatory

67. Your amended interrogatory is not only untimely, but re-mains too vague'for response. Moreover, UCS/NYPIRG's reliance on Board Contention 3.4 to support its request is misplaced for two reasons.

First, UCS/NYPIRG has not been assigned lead or contributing intervenor status for this contention. In its Memorandum and Order (Formulating Contentions and Designating Intervenor Re-sponsibilities) dated April 9, 1982, the Board expressly limited discovery for each contention to the lead and contributing in-tervenors thereon.

Second, there is no connection between subjective public perceptions of the " credibility" of the licensees and the licensees ' abilities to effect proper notification in the event of an emergency. Hence we object to your document

i Amanda Potterfield, Esq. .

June 11, 1982 Page Three .

request as beyond the scope of Board Contention 3.4 or any of the Commission's Questions.

B. Documents requested by licensees.

As you may recall, at the document production at the NYPIRG offices on May 26, we noted the absence of the documents cited in UCS/NYPIRG responses to Licensees' Interrogatories 71, 74, 83, 112, 124, and 131. You had agreed to attempt to ob-tain these documents for our inspection. We request that those documents, as well as the " studies" referred to in UCS/NYPIRG response to Licensees' Interrogatory 78, be produced at or prior to our supplemental document production.

Finally, we renew our request for copies of the prior tes-timony of UCS/NYPIRG witnesses, originally requested in Licen-sees' Interrogatory 180 and the accompanying document request.

In particular, we note that Dr. Beyea, at his deposition, stated that such testimony was in his custody.

C. Copies of documents.

At the request of UCS/NYPIRG, we have copied various docu-ments produced at our offices on June 1. We are prepared to f urnish these copies to you at your convenience, and to re-ceive the documents which you have copied at our request.

We look forward to expeditious completion of all of these discovery matters.

~'

very truly yours, i

David H. Pikus Brent L. Brandenburg cc: Service List i