ML20055A990

First Set of Interrogatories & Request for Documents Re Commission Question 1

ML20055A990
Person / Time
Site:	Indian Point
Issue date:	07/16/1982
From:	Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	PARENTS CONCERNED ABOUT INDIAN POINT
Shared Package
ML20055A991	List: ML20055A990 ML20055A996 ML20055A998
References
ISSUANCES-SP, NUDOCS 8207200221
Download: ML20055A990 (4)

Text

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UNITED STATES OF .oNERICA NUCLEAR REGULATOP.Y COMMISSION  ;

i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l l

l In the Matter of )

)

CONSOLIDATED EDIS0N COMPANY OF ) Docket Nos. 50-247 SP NEW YORK, INC. (Indian Point, ) 50-286 SP Unit No. 2)

POWER AUTHORITY OF THE STATE OF ) July 16, 1982 NEW YORK (Indian Point, Unit No. 3))

NRC STAFF FIRST SET OF INTERR0GATORIES TO AND REQUEST FOR DOCUMENTS FROM PARENTS CONCERNING COMMISSION QUESTION 1 INTRODUCTION The NRC Staff hereby requests that Parents Concerned About Indian Point (Parents) pursuant to 10 C.F.R. 5% 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 all documentary material identified in responses to the interrogatories below.

INSTRUCTIONS AND DEFINITIONS

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 oath or affirmation of the individuals who contributed thereto.

Documents produced shall indicate in response to which specific request the documents are being produced, i.e., 1(a). For all references requested in these interrogatories, identify them by author, title, date 8207200221 820716 501

{DRADOCK 05000247 PDR

of publication and publisher if the reference is published; and if it is not published, identify the document by the author, title, the dcte 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 receipient(s) of all cnpies, the privilege claimed, the basis 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. 5 2.740(e) these Interrogatories and requests for documents require prompt supplemental answers should Parents obtain or identify supplemental information or documents which l call into question the correctness of earlier answers.

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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" mean 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 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 Parents.

INTERROGATORIES Interrogatory 1 Identify all documentary or other material that you intend to use during this proceeding to support Contention 1.1 and that you may offer as exhiaits on this contention 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 1.l?

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 these contentions referenced in 2a. above.

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Interrogatory 3 Provide the basis for your statement in Parents Contention I that

" children within the ten mile plume exposure pathway Emergency Planning Zone are particularly susceptible to the physical effects of radiation."

Identify all documents referenced or relied upon in response to this interrogatory.

Interrogatory 4 Provide the basis for your statement in Parents Contention I, basis 1, that the " radiation dose absorption rate for children is significantly higher than for adults." Identify all documents referenced or relied upon in response to this interrogatory.

DOCUMENT REQUESTS

1. Provide for inspection and copying by the NRC Staff all documents identified in Parents' answer to Interrogatories 1 through 4 above.

2. Provide for inspection and copying by the NRC Staff all documents within the possession or control of Parents which relate to the susceptibility of children to the physical effects of radiation.

Respectfully submitted, c CuttiGX N\fDW Janice E. Moore Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of July, 1982.

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