ML20147F409
| ML20147F409 | |
| 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 7810190206 | |
| Download: ML20147F409 (7) | |
Text
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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 INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, GREENE COUNTY ET AL.
The Nuclear Regulatory Commission (NRC) Staff hereby requests that Greene County, Town and Village of Catskill and Town and Village of Athens (Inter-venor), pursuant to 10 CFR 12.740b, 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.
For each response to the interrogatories listed below, identify the person l
or persons who prepared, or substantially contributed to the preparation of 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 one or more of the answers, the answers should be amended in a timely manner to provide such additional information.
7i(OI90A.04
, The NRC Staff further requests that the Intervenor, pursuant to 10 CFR
!i 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.
N l
l
, General Interrogatories 1/
A.
G-1 State whether or not you intend to call any person or persons as witnesses in the NRC proceeding in support of (a) Stipulated Contention 1.A (b) Stipulated Contention I.B and provide the names, addresses, educational backgrounds and profes-sional 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) Stipulated Contention I.A (b) Stipulated Contention I.B will appear voluntarily or under subpoena.
G-3 Provide sumaries of the views, positions or proposed testimony on (a) Stipulated Contention I.A (b) Stipulated Contention I.B of all persons named in response to interrogatory G-1 that you intend to present during this preceeding.
G-4 Identify by author, title, date of publ, cation and publisher, all books, documents and papers that you intend to imploy or rely upon in presenting your direct case on (a) Stipulated Contention I. A 1/ Interrogatories in this section should be a.7swered 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.
, (b) Stipulated Contention I.B and provide copies of, or make available for Staff inspection and copying, these items.
G-5 If the representations made in (a) Stipulated Contention I.A (b) Stipulated Contention I.B 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 docu-ments, 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) Stipulated Contention I. A (b) Stipulated Contention I.B.
I
, B.
Interrogatories Related to Stipulated Contention I. A - Security I.A-1 Identi'v the specific requirements of 10 CFR Part 73 which you contei would not be satisfied by a facility located at the site as proposed by the Applicant.
I.A-2 Do you contend, in Stipulated Contention I.A, that the proposed site cannot comply with the security requirenents of 10 CFR Part 73?
If so, state specifically the bases for your assertion in this regard.
I.A-3 State specifically the reasons why "the easy access to the site from the Hudson River and the resulting exposed nature" of the proposed site will preclude compliance with the security require-ments of 10 CFR Part 73.
I.A-4 With regard to "the easy access to the proposed site from the Hudson River and the resulting exposed nature" of the proposed site:
(a) state specifically the manner in which the proposed site differs from other nuclear power plants in the United States which are similarly situated on rivers or other open waterways; and (b) describe how the differences identified in response to part (a) of this interrogatory preclude compliance with the requirements of 10 CFR Part 73.
, C.
Interrogatories Related to Stipulated Contention I.B -
Financial Oualifications I.B-1 State specifically the bases for the assertion in Stipulated Contention I.B.1 that "the State of New York has recently experienced problems in raising capital," identify the " problems" referred to, and identify any documents, studies or reports upon which you rely to support your response.
I.B-2 State specifically the bases for the assertion, implied in Stipulated Contention I.B.1, that the " problems in raising capital" experienced by the State of New York, can be expected to apply as well to the Applicant itself and identify any docu-ments, studies or reports upon which you rely to support your response.
I.B-3 What is meant by the phrase " funds necessary to construct the plant" used in Stipulated Contention I.B.1?
I.B-4 For each fecility and project referred to in Stipulated Conten-tion I.B.2, state the " funds" which you assert the Applicant has committed as well as the "further maintenance requirements" to which you refer in this Contention. State specifically the bases for your assertion that, because of these committed funds, there is no reasonable assurance that the Applicant is financially qualified to engage in the proposed activities in accordance with the Comission's regulations.
I I.B-5 What is your understanding of the meaning of the phrase " financially qualified to engage in the proposed activities in accordance with the regulations" as that phrase is used in 10 CFR S 50.40 with regard to the construction permit stage of the licensing process for nuclear plants?
Respectfully submitted, os h R. Gra
/
Counsel for NRC Staff
/7
~l$"1 K.
y
/ Ja A. Axel d Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of Septembar,1978 l
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