ML20028C706
| ML20028C706 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/07/1983 |
| From: | Hassell D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20028C707 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8301140024 | |
| Download: ML20028C706 (7) | |
Text
V i-UNITED STATES OF AMERICA NUCLEAR REGULATORY COPMISSION BEFORE THE ATOMI,C, SAFETY AND LICENSING BOARD In the Matter of
)
CONSOLIDATED EDISON COMPANY OF Docket Nos. 50-247-SP NEW YORK (Indian Point, Unit 2)
.)
50-286-SP POWER AUTHORITY 0F THE STATE OF
)
January 7, 1983 NEW YORK (Indian Point, Unit 3)
)
NRC STAFF CRnSS-EXAMINATION PLAN FOR WESTCHESTER COUNTY WITNESSES TESTIMONY-UNDER COPNISSION OUESTIONS 3 AND 4 Pursuant to the Licensing Board's Memorandum And Order of November 15, 1982, the Staff submits the following cross-exanination plan concerning the testimony of witnesses for Westchester County. This cross-examination plan represents the Staff's anticipation of the primary areas it intends to examine. Should subsequent events warrant it, the Staff reserves its right to conduct further cross-examination which may be necessary to develop an adequate record. The Staff's primary objective on cross-examination will be to investigate the bases and or validity of the conclusions and opinions set forth in the testimony.
In some instances, it may be necessary to conduct limited voir dire of witnesses to deter-mine their qualifications to testify on certain subject matter contained in their testimony. The Staff plans to investigate the following areas on cross-examination.
DESIGN 5 ED OPTOINAL Certified By 8301140024 830107 7
PDR ADOCK 05000247 O
.-'i 4.
1 Alfred B. DelBello' i
Pre-filed Testimony of June 16, 1982 Pages 3-4 Evacuation of all of Westchester County residents in 30 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (Derivation of estimate)
Safety of residents during major offsite release (sheltering - appropriate protec-tiveaction) l l
Supplement Testimony of December 30, 1982 Page 1 Unique problems which remain unsolved Page 2
$1.8 million minimum budget (Derivation of estimate)
Page 3 Risks associated with continued operation (Bases)
Raymond S. Jurkowski Pre-filed Testimony of June 16, 1982 Page 3 Leases with private bus companies Page 4 490 vehicles and driver required (Bases)
Plan has bus companies assigned for special facilities Significant number of bus drivers are part-time employees (Bases)
a '
Driver will.rurt volunteer (Bases)
Page 5-6 Training assistance offered by State of New York Page 7 Prior experience with parents when evacuating schools in an emergency T
Pages 8-9 Have identified concerns been addressed Page 11 Responsibility for notifying school districts outside EPZ Page 12 Have identified errors been addressed Persons will seek information from Department (Bases)
Supplemental Testimony of December 30, 1982 96ge 2 Time needed to mobilize National Guard (Bases)
NOTE:
The Staff may move to strike Attachment 1 to Supplemental Testimony as hearsay.
Dr. Anita S. Curran Pre-filed Testimony of June 16, 1982 Page 4 Training assistance provided by State of New York in identified areas Supplemental Testirony of December 30, 1982 Page 1
" Equipment deficiency" (essential to nerform function) 4
,,., - ~ - - -
naniel P. Guido Pre-filed Testimony of June 14, 1982 Page 3 Telephone capacity at County warning point inadequate (Bases)
Page'4 Additional information for judgment concerning implementing evacuation Supplemental Testimony of December 30, 1982 Pages 1-2 Distribution of low range dosimeters to County agencies (see page 1 of. Dr. Curran's supplemental testimony)
General Other emergency plans for hazards (ability tocommunicate)
Anthony M. Marasco Supplemental Testinony of December 30, 1982 General Supplemental testimony supersedes earlier pre-filed testimony Page 2 Spotty reply received from announcements andadvertisements(Bases)
No progress in notification of transients j
(Bases) l Page 3 Insufficient information to private schools (Bases) i
J e'
5-Communications by telephone unreliable in
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Page 4 the event of incident (Bases) --' experience with other emergencies Responsibilities of County for recovery /
reentry operations -- Plan provisions, NUREG-0654 calls for " general plans and-procedures" No provision for evacuation of mobility -
impaired individuals (Bases)
NOTE Staff may move to strike Attachments A & B since they 'nay be hearsay.
Charles W. Bates Pre-filed Testimony of June 14, 1982 Number of persons requiring services and Page 2 staffing needed -- within or beyond 10 mile EPZ Plans for staff notification outside normal Page 3 working hours (other disasters)
Communication system during exercise inade-quate(Bases)
L
Supplemental Testimony of December 30, 1982 Page 1 Scheduling of training course for staff Completion of planning for staffing 6 reception centers Frank C. Bohlander Pre-filed Testimony of June 16, 1982 Page 2 Meaning of " communication forms" (part of systen for disseminating information to public contained in initial and follow-up messages from licensee - NUREG-0654, II E.5)
William G. Borghard Pre-filed Testimony of June 16, 1982 Page 2 Past experience regarding necessity for manually cleaning bar screens for pumping stations and plants Michael Kaminski Page 2 Volunteer ambulanca personnel refusal to respond in past emergencies Plans for training Emergency Medical Techni-cians
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i Page'3 Decontamination training for ambulance personnelinadequate(Bases)
Page 4 Establishment of decontamination facilities closertopatienthostfacilities-(Bases).
Page 5
" Nuclear disaster" victims (relevance)
Lack of dosimeters for ambulance personnel Inr. Curran's Supplemental Testimony state
.providing dosimeters).
Ronald Goldfarb Pre-filed Testimony of June 16, 1982 Page 1 Ineffectiveness of low band radio frequency in emergency (Bases / Experience with past
. emergencies)
Page 3 Evacuation would cause mass panic for schools and nursing homes (Bases)
Respe fully submitted, y
/h Donald F. Hassell Counsel for NRC Staff Dated at Bethesda, Maryland this 7th day of January,1983 i
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