ML20147F414
| ML20147F414 | |
| Person / Time | |
|---|---|
| Site: | Green County  |
| Issue date: | 09/29/1978 |
| From: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | LEHIGH PORTLAND CEMENT CO. |
| Shared Package | |
| ML20147F381 | List: |
| References | |
| NUDOCS 7810190212 | |
| Download: ML20147F414 (4) | |
Text
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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POWER AUTHORITY OF THE STATE OF
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Docket No. 50-549 NEW YORK (Greene County Nuclear Power Plant) )
NRC STAFF INTERR0GATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, LEHIGH PORTLAND CEMENT COMPANY The Nuclear Regulatory Connission (NRC) Staff hereby requests that Lehigh Portland Cement Company, pursuant to 10 CFR H 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.
For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response, the address of the individual and the individual's relationship 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 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.
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, The NRC Staff further requests that the Intervenor, pursuant to 10 CFR 5 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.
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,,. 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 Stipulated Conten-tion 2 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 Stipulated Contention 2 will appear voluntarily or under subpoena.
G-3 Provide summaries of the views, positions or proposed testimony on Stipulated Contention 2 of all persons named in response to inter-rogatory G-1 that you intend to present during this proceeding.
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 Stipulated Contention 2 and provide copies of, or make available for Staff inspection and copying, these items.
G-5 If the representations made in Stipulated Contentien 2 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 documents, and the par-ticular portions thereof, you regard as deficient, and explain specif-ically and in detail why they are deficient, citing any documents, studies or reports which form the basis for your assertions.
11 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.
, B.
Interrogatories Related to Stipulated Contention 2 -
Emergency Procedures 2-1 Specifically define what is meant by the phrase " reasonable probability" as that phrase is defined in Contention 2.
2-2 Specifically define what is meant by the phrase " appropriate measures" as that phrase is used in Contention 2.
2-3 State whether it is your assertion that Highway 9W is inadequate to evacuate employees of Lehigh in the event of an emergency at the proposed facility.
If the answer to the above question is yes, state the basis for your assertion and identify any documents, studies or reports upon which you rely as the basis for this assertion.
2-4 Assume that the location of existing Highway 9W were changed as proposed by the Applicant in its Environmental Impact Assessment, Access Improvements - Cementon Site, Greene County Nuclear Power Plant, prepared by Parsons Brinckerhoff Quade and Douglas, Inc.,
August, 1977. For each option proposed by the Applicant in that study state whether you would still assert that Highway 9W is inadequate to evacuate the employees of Lehigh in the event of an emergency at the proposed facility.
Res ectfully submitted, se R. Gray /
ou sel for NRC Staff
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Ja e A. Axelrad Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of September,1978
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