ML20147F159

Interrogatories to Cementon Civic Assoc Contentions That Staff & Applicant Failed to Fully Assess Geological Data & Evaluations Sufficiently to Determine Site Geological Stability Re Operation of Three Cement Plants

ML20147F159
Person / Time
Site:	River Bend, 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 7810190015
Download: ML20147F159 (3)

Text

i O UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD In the Matter of POWER AUTHORITY OF THE STATE OF NEW YORK' Docket No. 50-549 l (GreeneCountyNuclearPowerPlant) )

NRC STAFF INTERROGATORIES TO THE CEMENTON CIVIC ASSOCIATION Pursuant to 10 CFR S 2.740 of the Commission's Rules of Practice, the NRC Staff hereby requests that the Cementon Civic Association (Inter-venor) answer separately and fully in writing under oath or affirmation the interrogatories 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 such information shall be disclosed. When the source of the information is another individual, such disclosure is to be in the form of che indi-vidual's name, address, and relationship with the Intervenor, if any.

Where the source of information 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 be amended to provide such additional information.

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Cementon Civic Association Contention I C. U C. The Petitioner contends that the Staff and Applicant have failed to fully assess the geological data and evaluation sufficiently to determine the site's geological stability, particularly with regard to the extensive quarrying operations of the three local and contiguous cement plants.

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 contention in this proceeding.

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

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

1-2 a. Is it your contention that the geological data assessed by the Staff is incomplete? In your response to this interrogatory address both the sufficiency of the data used by the Staff with regard to the Cementon site's l geological stability in general as well as the geolo-gical stability as affected by quarrying.

b. If your answer to Interrogatory 1-2a is yes identify the data which was not considered by the Staff.

U The wording of this contents- conforms to the wo iing accepted by the Atomic Safety and Lic^. .. Board in its Memorandum and Order dated February 14, 1977, at .'.

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c. Indicate the deficiencies (aside from that noted in

b. above) in the Staff's evaluation of the site's geological ' stability.

d. Indicate how the specific deficiencies noted in your response to c. above and the data noted in your response to b. above could impact the Staff's con-clusion regarding the stability of the Greene County site. .

1-3 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. ,

1-4 Identify all documentary or other material which you' intend to offer as exhibits on this contention in'this proceeding.

Respectfully submitted, 11, Henry J. McG1rren Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of October,1978 J

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