ML20147F402
| ML20147F402 | |
| 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 7810190204 | |
| Download: ML20147F402 (6) | |
Text
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.o..
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-b49 NEW YORK (Greene County Nuclear Power Plant)
NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, COLUMBIA COUNTY The Nuclear Regulatory Comission (NRC) Staff hereby requests that Columbia County (Intervenor), pursuant to 10 CFR 5 2.740b, answer separately and fully, in writing under oath or affirmation, the following interrogatories within 14 days after service hereof in accordance with the Atomic Safety and Licensing Board's Order of August 1,1978.
l For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of i
the response, the address of the individual and the individual's relation -
ship with the Intervenor, if any.
l The interrogatories attached are to be considered the Intervenor's continuing obligation. Accordingly, if, after the Intervenor has answered these inter-rogatories, additional information comes to its attention with respect to l
one or more of the answers, the answers should be amended in a timely manner to provide such additional information.
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
~1 tIol 9 0 2 0Y
2 copying, the documents designated by the Intervenor in response to certain of the accompanying inte.'rogatories.
1
, A.
General Interroaatories G-1 State whether or not you intend to call any person or persons.as witnesses in the NRC proceeding in support of (a) Contention I with regard to the effects of radiation, /
2 and (b) Contention 2 with regard to radiological releases from plant operation and provide the names, addresses, educational backgrounds and professional qualifications of those persons you -intend to call.
G-2 Indicate whether those persons identified in response to interrogatory G-1 in support of (a) Cont:n+1on 1 with regard to the effects of r' tiation, and (b) Contention 2 with regard to radiological releases from plant operation will appear voluntarily or under subpoena.
G-3 Provide summaries of the views, positions or proposed testimony on (a) Contention 1 with regard to the effects of radiation, and (b) Contention 2 wi % *egard to radiological releases from plant operation of all persons named in response to interrogatory G-1 that you intce.a to present during this proceeding.
E Interrogatories in this section should be answered with respect to each contention specified in the interrogatories.
The description of contentions corresponds to that set forth in the Atomic Safety and Licensing Board's Memorandum and Order of February 14, 1977.
Although Contention 1 itself does not explicitly refer to the effects of radiation from the proposed facility, Intervenor claims in its basis for Contention 1 and as support for its assertion that the effects on terrestrial ecology in Columbia County should be considered, that "radi-ation... can be easily carried to terrestrial areas in Columbia County with the same intensity as to land areas in Greene County."
i l
, l 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 with regard to the effects of radiation, and (b) Contention 2 with regard to radiological releases from plant operation and provide copies of, or make available for Staff inspection and copying, these items.
G-5 If the representations made in (a) Contention 1 with regard to the effects of radiation, and 1
(b) Contention 2 with regard to radiological releases from plant operation 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 documnts, studies or reports which form the basis for your assertions.
I G-6 Identify by author, title, date of publication and publisher, all books, I
documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in l
connection with (a) Contention 1 with regard to the effects of radiation, and (b) Contention 2 with regard to radiological releases from plant operation.
, B.
Interrogatories Related to Contentions 1 and 2 with Regard to the Effects of Radiation and Radiological Releases 1/2-1 Describe qualitatively and quantitatively the radiological releases from the proposed plant which are referred to in the basis for Con-tention 1 and explicitly in Contention 2 and identify any reports, studies or papers on which you rely for the description provided.
1/2-2 Identify the specific sources within the proposed facility of the radiological discharges referred to in the basis for Contention 1 and explicitly in Contention 2 and state specifically the basis for the assertion that such discharges will occur.
1/2-3 Do you contend in Contention 1 and 2 that radiological releases from the proposed plant described in response to interrogatory 1/2-1 will have significant adverse effects on the health and safety of the public?
1/2-4 If the answer to interrogatory 1/2-3 is "yes," describe the "significant adverse effects" which you assert will occur, state specifically the bases for your assertion that such adverse effects will occur, and identify any reports, studies or. papers on which you rely to support your assertion.
1/2-5 Do you contend, in Contention 2, that increased deposition of radioactivity on fruits and vegetables will have significant adverse effects on the health and safety of the public?
l t
i 1/2-6 If the answer to interrogatory 1/2-5 is "yes," describe the "significant adverse effects" which you assert will occur and the manner in which such adverse effects will result from 1
)
increased deposition of radioactivity on fruits and vegetables, 1
l state specifically the bases for your assertion that such adverse effects will occur, and identify any reports, studies or papers on which you rely to support your assertion.
I Respectfully submitted,
'f?
Jos ph R. Gray Counsel for NRC Staff YbE fV Jan A. Axelra Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of September,1978
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