ML20147F376
| ML20147F376 | |
| Person / Time | |
|---|---|
| Site: | Green County  |
| Issue date: | 09/29/1978 |
| From: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20147F381 | List: |
| References | |
| NUDOCS 7810190197 | |
| Download: ML20147F376 (10) | |
Text
10 DOCUMENT Roog b
er 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N
In the Matter of 1
6 4 g%D POWER AUTHORITY OF THE STATE OF Docket No. 50-54!C g3 %}
NEW YORK (Greene County Nuclear' Power Plant))
k@,L.
A CERTIFICATE OF SERVICE I hereby certify that copies of:
(1) "NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, SHIRLEY A. BRAND AND MID-HUDSON NUCLEAR OPP 0NENTS";
(2) "NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, CEMENTON CIVIC ASSOCIATION";
(3) "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, CITIZENS TO PRESERVE HUDSON VALLEY";
(4) "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, COLUMBIA COUNTY";
-i (5) "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, GREENE COUNTY ET AL.";
(6) "NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, LEHIGH PORTLAND CEMENT COMPANY";
(7) "NRC STAFF INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, ARTHUR L. REUTER AND THE COLUMBIA COUNTY SURVIVAL COMMITTEE"; and (8) " NOTICE OF APPEARANCE" for Jane A. Axelrad in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd day of Octobtr.1978:
Andrew C. Goodhope, Esq., Chairmcn*
Ms. Rosemary S. Pooler Atomic Safety and Licensing Bortrd Executive Director 3320 Estelle Terrace New York State Consumer Wheaton, Maryland 20906 Protection Board 99 Washington Avenue Dr. George A. Ferguson Albany, New York 12210 Professor of Nuclear Engineering Howard University Lewis R. Bennett, Esq.
Washington, D. C.
20001 Assistant General Manager -
General Counsel Dr. Richard F. Cole
- Power Authority of the State Atomic Safety and Licensing Board of New York U.S. Nuclear Regulatory Commission 10 Columbus Circle Washington, D. C.
20555 New York, New York 10010 7Triof9ot97
~
$ e t-i ig o George J. Pulver, Jr., Esq.
Anthony Scott, Mayor Bagley, Chadderdon, Pulver Village of Athens
& Stiefel 93 N. Washington Street 302 Main Street Athens, New York 12105 P. O. Box 486 Catskill, New York 12414 Mr. John Nickolitch Cementon Civic Association Citizens to Preserve the Hudson 70 Short Street Valley Cementon, New York 12415 c/o Robert J. Kafin, Esq.
115 Maple Street Vito J. Cassan, Esq.
Glens Fall, New York 12801 Assistant General Counsel Power Authority of the State Michael Curley, Esq.
of New York Deputy Comissioner and Counsel 10 Columbus Circle New York State Atcmic Energy New York, New York Council 99 Washington Avenue Edward G. Cloke, Esq.
Albany, New York 12245 Steenbergh & Cloke 28 Second Street Douglas Lutzy, Esq.
Athens, New York 12015 Dr. Sury Putta Michael Flynn, Esa.
Jeffrey Cohen, Esq.
Nancy Spiegel, Esq.
New York State Energy Office Staff Counsel Swan Street Building State of New York Core 1, Second Floor Public Service Commission Albany, New York 12223 Empire State Plaza Albany, New York 12223 Daniel Riesel, Esq.
Winer, Neuburger & Sive Village of Catskill 425 Park Avenue c/o Daniel K. Lalor, Esq.
New York, New York 10022 Meadow, Ruf and Lalor, P.C.
8 Reed Street Mr. John Lenny Coxsackie, New York 12051 Public Information Officer Power Authority of the State Algird F. White, Jr., Esq.
of New York DeGraff, Foy, Conway and
, Catskill Motor Lodge Holt-Harris Catskill, New York 90 State Street Albany, New York 12207 Albert K. Butzel, Esq.
Butzel and Kass William J. Spampinato, Esq.
45 Rockefeller Plaza Rosenberg & Spampinato Suite 2350 443 Warren Street New York, New York 10020 Hudson, New York 12534
Honorable Edward C. Cohen Atomic Safety and Licent;ing Board Presiding Examiner Panel
- Public Service Commission U.S. Nuclear Regulatory Cemission Empire State Plaza Washington, D.C.
2055F Agency Building Albany, New York 12223 Atomic Safety and 1icensing Appeal i
Panel (5)
Edward R. Patrick, Esq.
U.S. Nuclear Regulatory Commission Assistant Counsel for Energy Washington, D.C.
20555 Carl G. Dworkin, Esq.
New York State Department of D$cketing and Service Section (3)
Environmental Conservation Of"!ce of the Secretary l
50 Wolf Road
~.S. Nuclear Regulatory Commission Albany, New York 12233 Washington, D.C.
20555 I
Honorable Donald Carson Town of Athens Associate Hearing Examiner c/o Alan Francis Ruf, Esq.
Department of Environmental Meadow, Ruf and Lalor, P.C.
Conservation 8 Reed Street 50 Wolf Road Coxsackie, New York 12051 Albany, New York 12233 Columbia County Survival Arthur L. Reuter, Esq.
Committee j
Attorney at Law c/o Robert J. Kafin, Esq.
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Sharpe's Landing 115 Maple Street 4
Germantown, New York 12526 Glens Falls, N.Y.
12801 I
Mr. Peter D. G. Brown Chairman Mid-Hudson Nuclear Opponents P.O. Box 666 New Paltz, New York 12561 7
e1
@ bph. Gray
/
/
C uns for NRC Staff
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i, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
POWER AUTHORITY OF THE STATE OF
)
Docket No. 50-549 NEW YORK
)
)
(Greene County Nuclear Power Plant) )
NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, SHIRLEY A. BRAND AND MID HUDSON NUCLEAR OPP 0NENTS The Nuclear Regulatory C<anission (NRC) Staff hereby requests that Shirley A. Brand and Mid-Hudso's Nuclear Opponents (Intervenor), pursuant to 10 CFR S 2.740b, answer separately and fully, in writing under cath or affirmation, the following interrogatories within 14 days after service hereof in accord-ance with the Atomic Safety and Licensing Board's Order of August 1,1978.
For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the rcsponse, the address of the individual and the individual's relation-ship with the Intervenor, if any.
The interrogatories attached are to be considered the Intervenor's continuing obligation. Accordingly, if, after the Intervenor has answered these iner-rogatories, additional information comes to its attention with respect to one or more of the answers, the answers should be amended in a timely manner to provide such additional information.
i 2
The NRC Staff further requests that the Intervenor, pursuant to 10 CFR S 2.741, provide copies of, or make available for Staff inspection and copying, the documents designated by the Intervenor in response to cer-tain of the accompanying interrogatories.
'O
/
e )
A.
General Interrogatories G-1 State whether or not you intend to call any person or persons as l
witnesses in the NRC proceeding in support of
]
(a) Contention 1(a)
(b) Contention 1(b)
(c) Contention 1(c)
(d) Contention 3(d) l and provide the names, addresses, educational backgrounds and profes-sional qualifications of those persons you intend to call.
7 l
G-2 Indicate whether those persons identified in response to interrogatory l
G-1 in support of l
(a) Contention.'(a)
(b) Contention 1(b)
(c) Contention 1(c)
(d) Contention 3(d) wi '-
3 pear voluntarily or under subpoena.
G-3 p summaries of the views, positions or proposed testimony on (e
antention 1(a)
(b) Contention 1(b)
(c) Contention 1(c)
(d) Contention 3(d) of all persons named in response to interrogatory G-1 that you intend to present during this proceeding.
.l./ Interrogatories in this section should be answered with respect to each contention specified in the interrogatories. The designation of conten-tions corresponds to that set forth in the Atomic Safety and Licensing Board's Memorandum and Order of February 14, 1977.
E_-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__o
, G-4 Identify by author, title, date of publication and publisher, all books, documents and papers that you intend to employ or rely upon in presenting your direct case on (a) Contention 1(a)
(b) Contention 1(b)
(c) Contention 1(c)
(d) Contention 3(d) and provide copies of, or make available for Staff inspection and copying, these items.
G-5 If the representations made in (a) Contention 1(a)
(b) Contention 1(b)
(c) Contention 1(c)
(d) Centention 3(d) are based in whole or in part on any documents prepared by the Applicant or the NRC Staff which you contend are deficient, specify which document, and the particular portions thereof, you regard as deficient, and explain specifically and in detail why they are deficient, citing any documents, studies or reports which form the bases for your assertions.
G-6 Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with (a) Con;ention 1(a)
(b) Contention 1(b)
, (c)' Contention 1(c)
(d). Contention 3(d).
B.
Interrogatories Related to Contention 1 - Emergency Procedures 1 -1 Specifically define what is meant by " sufficient information to satisfy the Commission's construction permit requirements regarding measures to be taken in the event of an emergency at'the proposed facility" with regard to (a) notification of the general pubitc.
(b) adequacy of highways and public transportation within the vicinity of the plant site, (c) ' adequacy of medical facilities for emergency treatment.
1-2 State whether you have any information to support an assertion that it would not be possible prior to issuance of an operating license to develop (a) adequate highways and public transportation within the vicinity of the plant site to effect evacuation of persons within the LPZ.
(b) adequat'e medical facilities for emergency treatment.
1(b)-1 Are you asserting that the highways and public transportation within the vicinity of the plant are now inadequate to effect the evacuation of persons within the LPZ of the proposed facility? If the answer i
to the above question is yes, state specifically the basis for that assertion and identify any documents, studies or reports upon which you rely as the basis for this assertion.
'9
. 1(c)-1 Are you asserting that the medical facilities in the vicinity of the plant are now inadequate to provide emergency treatment in the i
event of an emergency at the proposed facility? If the answer to the above question is yes, state specifically the basis for that assertion and identify any documents, studies or reports upon which you rely as the basis for this assertion.
4 C.
Interrogatories Related to Contention 3(d) -
Radiological Releases 3(d)-1 Describe qualitatively and quantitatively the " radiological...
discharges from the proposed facility" which are referred to in
-1 Contention 3(d) and identify any reports, studies or papers on which you rely for the description prosided.
3(d)-2 Identify the specific sources within the proposed facility of the
)
radiological discharges referred to in Contention 3(d) and state specifically the basis for the assertion that such discharges j
will occur.
3(d)-3 State specifically the basis for the assertion in Contention 3(d) that the radiological discharges described in response to inter-rogatory 3(d)-1 will have adverse effects on the ecology and the biological communities of the Hudson River and identify any reports, studies or papers on which you rely to support this assertion.
3(d)-4 Contention 3(d) asserts that the Applicant has inadequately assessed the adverse effects of radiological discharges from the proposed
, facility.
Identify the Applicant's assessment referred to in this Contention, describe the particular inadequacies asserted to exist, and state specifically the basis for your assertion that these particular a5pects of the Applicant's assessment are inadequate.
Respectfully submitted, v
Y Jos h R. Gray Counsel for NRC Staff YV W
[ Jane A. Axelrad Coursel for NRC Staff Dated at Bethesda, Maryland this 29th day of September,1978 h
.