ML20147F191

Interrogatories to Greene County,Towns of Catskill & Athens & Villages of Catskill & Athens Contentions.Contention States That Possible Consequences of Blasting in Vicinity of Cementon Site Not Well Evaluated

ML20147F191
Person / Time
Site:	Green County
Issue date:	10/02/1978
From:	Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML20147F156	List: ML20147F148 ML20147F159 ML20147F169 ML20147F179 ML20147F191
References
NUDOCS 7810190024
Download: ML20147F191 (3)

Text

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UNITED STATES OF AMERICA .4 NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of POWER AUTHORITY OF THE STATE OF NEW YORK Docket No. 50-549 (Greene County Nuclear Power Plant)

NRC STAFF INTERROGATORIES TO GREENE COUNTY ET'AL.

Pursuant to 10 CFR 52.740 of the Comission's Rules of Practice, the ,

NRC Staff hereby requests that Greene County et al. (Intervenor) answer separately and fully in writing under oath or affirmation the interrog- ,

atories set forth below. .

Insofar as any answer is based on information other than the personal knowledge of the individual subscribing to the answers, the source of .

';ch information shall be disclosed. When the source of the information is another individual, such disclosure is to be in the form of the indi-

~

vidual's name, address, and relationship with the Intervenor, if any. -

Where the source of info,rmation is a writing of some kind, it shall be -

identified.

The interrogatories set forth below are to be considered the Intervenor's -

continuing obligation. Accordingly, if, after the Intervenor has answered these interrogatories, additional information comes to its attention with respect to one or more of the answers, the answers should 1

) be amended to provide such additional information.

,4 7 Frlot1 o 6 2-y

Greene County, Town of Catskill, Village of Catskill, Town of Athens and Village of Athens Unstipulated Contention I-C*

The impact or possible consequences of blasting in the vicinity of the Cementon site has not been adequately evaluated in the PSAR and the Power Authority of the State of New York's purported description of the geology of the Cementon site is not, in fact, a description of this site but relates to an area located approximately fifteen miles away.

1-1 a. Upon what person or persons do you rely to substantiate your case on the above contention?

b. Provide the addresses and educational and professional qualifications of any person named in your response to ~

a. above.

c. Identify which of the above persons you intend to call as witnesses on this con'ention in this proceeding.

l l d. Identify which of those persons identified in c. above you anticipate will appear voluntarily and which under subpoena.

l e. Identify each document upon which this contention is based.

i 1-2 Indicate the deficiencies in the Staff's evaluation of the effects on the proposed facility from blasting operations conducted close to the site by local industries. Indicate any data, sources of data, assumptions, reasons for the assumptions used in performing any calculations.**

• / The wording of this contention conforms to the wording accepted by the Atomic Safety and Licensing Board in its Memorandum and Order dated February 14, 1977, at 32 and 33.

• / We desire this information in sufficient detail to allow replication of the results of your calculations.

1-3 Indicate with bases how the specific deficiencies noted in your response to 1-2, above, could impact the Staff's con-clusions regarding the stability of the Cementon site.

1-4 To the extent that Intervenor's case on this contention will rely on cross-examination of witnesses presented by other parties to this proceeding, identify any material to be relied upon during such cross-examination.

1-5 Identify all documentary or other material which you intend to offer as exhibits on this contention in this prnceeding.

Respectfully submitted, up HenriJIMcGurren Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of October,1978 _