ML20064N717

Affirmation in Opposition to Licensee 830201 Motion for Expedited Order Compelling Production of Witness C Perrow Documents.No Portion of Witness Testimony Draws Upon Draft Manuscript Info

ML20064N717
Person / Time
Site:	Indian Point
Issue date:	02/08/1983
From:	Hartzman R FRIENDS OF THE EARTH
To:
Shared Package
ML20064N682	List: ML20064N679 ML20064N691 ML20064N717
References
ISSUANCES-SP, NUDOCS 8302160318
Download: ML20064N717 (2)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P. Gleason , Chairman Dr. Oscar H. Paris Frederick J. Shon ,

x In the Ma.tter of x x Docket Nos.

CONS sIDATED EDISON COMPANY OF x NEW YORK (Indian Point Unit 2) x 50-247-SP x 50-286-SP POWER AUTHORITY OF THE STATE OF x NEW YORK (Indian Point Unit 3) x February 8, 1983

. x

'X  :

AFFIRMATION IN OPPOSITION TO LICENSEES' FEBRUARY 1, 1983 MCYPION FOR EXPEDITED ORDER COMPELLING PRODUCTION OF DOCUMENPS I, RICHARD HARTZMAN, an attorney at law admitted to practice in the State of New York, and being aware of the penalties for perjury, do hereby affirm:

1. The statements made herein are based upon personal knowledge or upon information ar#d belief; such information and belief being based upon conversations I have had with DR. CHARLES PERROW.

2. I represent FOE /Audubon in the above-captioned matter.

3. DR. CHARLES PERROW will appear as a FOE /Audubon witness in the above-captioned matter.

4. DR. CHARLES PERROW has not relied nor will he rely in the testimony he will give in the above-captioned matter upon two incomplete, unrevised and unpublished chapters, or any part thereof, of a larger work in progress.

6302160318 B30208 PDR ADOCK 05000247 PDR

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. .o

5. At the deposition of DR. PERROW on January 24, 1983, one of the chapters at issue was consulted by DR.

PERROW to refresh his recollection of a list of factors contained in the concept of " tight coupling", which factors appear on page 3 of Dr Perrow's prefiled testimony.

The list in the manuscript was not relied upon by DR.

PERROW in his testimony but appears in parallel fashion ,

in both documents.

6. No portion of DR.PERROW's testimony draws upon i

anything in the manuscripts. Rather portions of the draft manuscript and the-full testimony of DR. PERROW are derived from other sources which have been made know or provided to thd licensees.

7. The chapters at issue are unrevised portions of a book that DR. PERROW is under contract to prcpare for publication and have been kept confidential. They are part of a work in progress and are therefore, by definition, in a less developed state than the testimony Dr. Perrow will give in this proceeding.

Affirmed this 8th day of February, 1983, CYc4Y _L Richard M. Hartzman, Esq.

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