ML20054L799

Addl Response to Interrogatories Under Commission Questions 3 & 4 Per ASLB 820625 Order.Certificate of Svc Encl

ML20054L799
Person / Time
Site:	Indian Point
Issue date:	07/01/1982
From:	Hartzman R FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
ISSUANCES-SP, NUDOCS 8207080489
Download: ML20054L799 (3)

Text

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- UNITED STATES OF AMERICA

/ NUCLEAR REGULATCRY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon x

In the Matter of x x Docket Nos.

CONSOLIDATED EDISON COMPANY OF x NEW YORK (Indian Point Unit 2) x 50-247-SP x 50-286-SP POWER AUTHORITY OF THE STATE OF x NEW YCRK (Indian Point Unit 3) x July 1, 1982 gc x

ADDITIONAL RESPONSE OF FOE /AUDUBON TO LICENSEES' INTERROGATCRIES UNDER COMMISSION QUESTIONS 3 AND 4 PURSUANT TO BOARD ORDER OF JUNE 25, 1982 FOE /Audubon has not presented contentions, allegations or claims, nor is lead or contributing intervenor with regard to the following interrogatories: 2, 4-9, 13-36, 38, 40, 42-45, 47-49, 51, 52, 54-75, 77-92, 95,98-112, 114, 116, 117, 121, 122, 128-136, 138-139, 141-143, 146-153, 157, 160-179, 184.

Licensees', in their motion papers of June 3, 1982, made assertions with respect to FOE /Audubon concerning the following interrogatories: 140, 144, 145, 154, 158, and 159.

Response to interrogatories Nos. 140 and 144:

The only information FOE /Audubon has on these matters is that contained in the responses to interrogatories of other intervenors and in the direct evidence submitted in this proceeding by other intervenors and by Rockland and West-chester Counties.

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Response to interrogatory No. 145:

FOE /Audubon is not aware of any such studies.

Further response to interrogatories Nos. 154 and 158:

The previous responses to these interrogatories are based upon logic and common sense. Further information regarding these matters is contained in the direct testimony of Drs.

Pisello and Piccioni submitted in this proceeding.

Response to interrogatory No. 159:

Contrary to licensees' assertion, this was answered in the FOE /Audubon response of May 18, 1982.

Affirmed this 1st day of July, 1982

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Richard M. Hartzman, Esq.

Counsel for FOE /Audubon Friends of the Earth, Inc.

208 West 13th Street New York, New York 10011

- UNITED STATES OF AMERICA 6 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Louis J. Carter, Chairman Dr. Cscar H. Paris Frederick J. Shon x

In the Matter of x x Docket Nos.

CONSOLIDATED EDISON COMPANY OF x NEW YORK (Indian Point Unit 2) x 50-247-SP x 50-286-SP POWER AUTHORITY OF THE STATE OF x July 1, 1982 NEW YORK (Indian Point Unit 3) x x

x CERTIFICATE OF SERVICE This is to certify that I have served copies of ADDITIONAL RESPONSE OF FOE /AUDUBON TO LICENSEES' INTERROGATORIES UNDER COMMISSION QUESTIONS 3 AND 4 PURSUANT TO BOARD ORDER OF JUNE 25, 1982 by personal delivery to the offices of licensees' attorneys, Shea & ~ Gould , and Brent Brandenburg , Esq., and by first class mail on the NRC Docketing and Service Branch. Service upon the Board and other parties to this proceeding will be made personally upon resumption of the hearing on July 6, 1982.

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Richard M. Hartzman, Esq.

Counsel for FOE /Audubon

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