ML20054J107
| ML20054J107 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/21/1982 |
| From: | Blum J, Potterfield A NEW YORK UNIV., NEW YORK, NY, POTTERFIELD, A., PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20054J075 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206280135 | |
| Download: ML20054J107 (17) | |
Text
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UNITED STATES OF AMERIC.\
NUCLEAR REGULATORY COMMIStION BEFORE THE ATOMIC SAFETY AND LICENflNG BOARD In the Matter of )
)
CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2) ) 50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK )
(Indian Point Unit 3) ) June 21, 1982 UCS/NYPIIG fol' ION EDR AN ORDER C0iPFJLTNG LICENSEES TO PIGDUCE CERTAIN DOCLNENIS REQUESTED IN EDINAL AND INEDINAL DISCOVERY AND 1D RESPOND TO UCS/NYPIIG IbnucOGATOIE NLNBER 67 The Union of Concerned Scientists (UCS) and the New York Public Interest Research Group, Inc. (NYPIIG) hereby rtove the Atcmic Safety and Licensing Board (Board) pursuant 'to 10 C.F.R. 2.740(f) (1) to issue an order capelling the Licensees to produce doctanents requested in UCS/NYPIBG First Set of Interrogatories to Licensees, Interrogatory 867, and requested again in NYPIlU's letter to David Pikus, Esq. dated June 3, 1982. The original interrogatory, the objection to the interrogatory by Licensees, the letter of June 3, 1982 and the response from David Pikus, Esq. and Brent Brandenburg, Esq. dated June 11, 1982, are annexed hereto as Appendix A.
In addition to the writtert exchanges between the parties regarding the infornution sought, counsel for NYPIIG attstpted to negotiate the production of the documents and information with David Pikus, Esq. during recesses of the pre-hearing conference on June 17, 1982,0 and by telephone on June 21, 19d2. It is only after the the failure of our efforts to reach some' agreement, or obtain even B206280135 820616 PDR ADOCK 05000247
limited informtion, through the informal and foul requests, that UCS and NYPI!G make this notion to conpel discovery,
'Ihe Information and Docturents Sought As is apparent fran Appendix A, the original interrogatory nunber 67 request the licensees to identify and produce doctanents prepared to investigate the credibility of licensees by the public, in general and specifically with regard to the accuracy of reported occurrences, off-site radiation levels, etc.
'Ihe licensees objected on three grounds: that the interrogatory was too vague; was beyond any contention on which UCS/NYPIIG was lead or contributing intervenor; and was beyond the scope of the Conmission's Questions. See Interrogatory and Response, at A-1.
By letter dated June 3,1982, annexed at A A-4, NYPIIG amended interrogatory 67 to more clearly specify the information it sought, and indicated that the interrogatory referred to contention 3.4, relating to the reliability 'of licensees to prenptly and accurately notify authorities of an cmergency. A-3.
Again, the Licensees objected on the ground that neither IXE nor NYPIIG was contributing or lead intervenor on contention 3.4. See, letter of June 11, 1982, at A-6. Licensees' second objection was that the information sought did not relate to contention 3.4 nor to any other board contention.
During the negotiating session with Mr. Pikus on June 17, 1982, counsel.for NYPIIG conceded that NYPIIG was neither lead nor contributing intervenor on contention 3.4, but asserted that the interrogatory was asked on behalf of Ibckland Citizens for Safe Energy. (IGSE) . Judith #essler, representative of RCSE confirmed that, due to her time problans duri.m a .. . .
._____________________--2___________ l
_I the discovery period, she relied upon UG and NYPIIG to co-onlinate interrogatories for contentions assigned to IC3E with those for
- contentions assigned to UCS and NYPIIG. Mr. Pikus;mviewed the r
brief interrogatories actually filed by BCSE and re;-affirmed the licensecs' objections to the discovery request. ' ~
Finally, on June 21, 1982, munsel for NYPIIC related to Mr.
i ,
Pikus additional informtion obtained about thevinfonaation sought, ,
, t particularly that the connunity people whojeported being interviewed stated that the questions asked for their responses to hypthetical
/
$c informtion about emergency i'lanning and about,the yet to be released cmergency plcnning brochure. Armed with this'information, counsel for
/ 'y NYPIIG argued to Mr. Pikus that the informtion and doctrnents related to-l wntention 3.2 as well as to contention 3.4. UCS and NYPIIU are lead intervenors on contention 3.2. #
Mr. Pikus responded that his position remained firm on the issue of the relevance of the informtion sought to the Board mntentions.
/
l The Information and Documnts Sought are Reasonably calculated to j Icad to the Discovery of Admissible Evidence and are Appropriate for Discovery by UCS and NYPIIG.
1
- 'Ibe licensecs' credibility with respa ; to notification of occurrences t
j and off-site radiation levels and h tun 3 tor the degree of credibility
^
i are relevant to contentions 3.4 a.a 3.2. Board contention 3.2 relates l
to falso assunptions about the response of the public and of utility l coployees in an aTergency. UG and NYPIIU are lead intervenors.
- Doard contention 3.4 relates to the reliability of licenses to perform their notification responsibilities accurately and prutptly. RCSE is lead l intervenor on contention 3.4.
/
r Licensees beg the questions of reliability and response of utility enployees by arguing that the public's perception of their reliability and the appropriateness of their response is not relevant. If the documents and information sought by UCS and NYPITC exist, their relevance to the intervenors' efforts to present a cmprehensive case is o',vious.
l l
l 2 e alternative, of course, is for intervenors to fight to present a niltitude of witnesses to testify to the licensees' reliability and response as viewed by the public.
%e scope of discovery, as defined in the NPC regulations is any informtion that " appears reasonably calculated to lead to the discovery of admissible evidence". 10 C.F.R. 2.740 (b) (1) . %us if the informtion sought in UCS and NYPIIC interrogatory 67 is not directly relevant to contentions 3.2 and 3.4, it mnifestly could lead to relevant evidence and is within the scope of discovery.
Licensecs' refusal to even hint at the informtion sought on the ground it was requestal by the wrong party is but another effort to obstruct the efforts of intervenors to discovery the information in the hands of the licensees. W ey read the third decretal paragraph of the order of April 9th, on page 16, as a limitation on the usual discovery rule that:
Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject mtter involved in the proceeding, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party ...
10 C.F.R. 2.740 (b) (1) (Enphasis supplied.)
UCS and NYPIIQ contend that the information sought relates to contention 3.2., to which they are assigned lead intervenors. However, even if the infornation could only reasonably relate to contention 3.4, to
which ICSE is lead intervenor, discovery on the mtter by UCS and NYPIIC is appropriate under the rules of discovery quoted above. 'Ihe order of April 9th mkes clear that discovery is not to be limited to lead intervenors, and cannot reasonably be interpreted to constitute a limitation on the scope of discovery prescribed in the regulations.
WIERENRE, it is respectfully requested that Licensees be required to answer Interrogatory 67 and identify and produce the documents sought therein.
Dated: t w York, New York June 21, 1982 6:Y M./BIIN, ESQ. L unsel to Union of (bncerned Scientists 423 Vanderbilt Hall 40 Washington Square South New York,.New York 10012 212- 98-3452 nL Mk' AMANDA POITERFIEID, 50./
(bunsel to New York Public Interest
[ Research Group, Inc.
l Box 384 Village Station
4 I
t"m
- 67. I!3TCRROGATORY :
Identify any and all documents that have been prepared or commissioned by or for the licensees to investigate the credibility, as perceived by the public within the general vicinity (whether that be a ten mile radius, surrounding town-ships or counties, or other boundary) of Indian Point, of Licensee, or' agents of Licenses, whether that credibility be of a general nature, or specif>.c 11y in respect to theetc. accuracy of reported occurrences, of f-site radiation levels, RESPO11SE:
The licensees object to Interrogatory 67 on the grounds that:
- a. it is too vagua for response;
- b. it' appears to arise beyond any contention for which UCS/t1YPIRG has been assigned lead or contributing intervenor status; and
- c. it is beyond the scope of the Commission's Questions.
A4
l 1
NEW york publIC INTEREST RESEARCb CgROUp,INC.
NYP!HG
>S$RoheXtch%MHk* Now York, N.Y X fM * (212) 349 6460 ,
um ...,o- s. =s,.==.w.
om.. U- .. , :n#_2---Murray n-.v.n.e, Street,ton.ew York, New York 10007
/
7 June 3, 1982 David Pikus, Esq.
Shea and Gould 330 Madison Avenue ew York, New York Re: Indian Point Units 2 and 3 NRC Docket Nos. 50-247 SP and 50-286 SP
Dear Mr. Pikus:
With reference to our discussion during the production of Licensees' documents which took place on June 1, 1982, I request your production of the following documents that were not available on that date:
1.) Aldrich, D.C. and Ericson, D.M., Jr., Public Protection Strategies in the Event of a Nuclear Reactor Accident: Multi-Compactment Ventilation Model for Shelters, SAND 77-1559, Jan. 1978.
2.) Aldrich, D.C., Ericson, D.,M.,Jr. and Johnson, J.D.,
Public Protection strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures,' SAND 77-1725, Feb.,
1978.
These two documents were referred to in your answer to UCS/NYPIRG Interrogatory #35, and are unavailable in the Public Document Rooms of the N.R.C.
3.) Institute for Nuclear Power Operations, "I.P.-3 Evaluation Report", October 1981.
4.) Yankelovich, Skelly and White, "A Report on Temporary llousing Related to Evacuation of the Indian Point Power Plant Area", June 1980.
The New York Pubhc interest Research Group, Inc. (NYPIRG) es a not-for proht nonpartisan research and advocacy orgaruzation estabhshed, directed and supported by New York State conegs, and untversity students NYPIRG's staff of lawyers, researchers, scientists and orgaturers works with students and other citizens, developeng citizenship sk*lls and shapsog pubhc poleCy. Consumer protection, higher education, energy, hScal responsebehty, (w%tecal reform and 50Clal gustice are NYPIRG's princspal areas of concern
~
David Pikus, Esq.
Shea and Gould
/ June 3, 1982 Page 2 Documents numbers three and four were referred to in your answer to UCS/NYPIRG Interrogatory 12, as among the documents upon which the Parsons Brinckerhoff witnesses intend to rely.
We request the production of these documents on Monday, June 7, 1982, before the deposition of these witnesses scheduled for June 8, 1982.
In addition, the'information produced by the Licensees in the course of informal discovery relating to the Parsons Brinckerhoff evacuation time estimates indicates that those estimates relied heavily on a document' entitled Highway Capacity Manual. We request the production of this document on Monday, June 7, 1983, before the deposition of the Parsons Brinckerhoff witnesses scheduled for June 8, 1982.
With respect to UCS/NYPIRG Interrogatory $67 to the Licensees, to which the Licensees objected in their Answers to UCS/NYPIRG First Set of Interrogatories, UCS/NYPIRG amend the interrogatory to provide the specificity requested by the Licensees, as follows:
UCS/NYPIRG Interrogatory 967:
Identify and produce any and all documents that were prepared or commissioned by and for the licensees to investigate the credibility, as perceived by the public within the general vicinity (whether that be a ten mile radius, surrounding townships or counties, or other boundary) of Indian Point, of licensees or agents of licensees, whether that credibility be of .a general nature, or specifically in respect to the accuracy of reported occurrences, off-site radiation levels, etc.
The basis for asking the interrogatory is reports from the community surrounding Indian Point that individuals were interviewed by a polling firm sometime befor June
.1981 about their views of the credibility of licensees.
Further, reports have been made to the office of NYPIRG of a study commissioned by or produced by Con Edison sometime during the fall and winter 1981 and-1982 regarding the credibility of Con Edison with the public apparently in conjunction with dispute over summer-winter rate dif ferentials.
Objections (b) and (c) to the interrogatory are answered by reference to Board Contention 3.4 relating to the unreliability of Licensees to notify the proper authorities of an emergency promptly and
- accurately.
3 _ - - _ _ - - - - - - - - - - - - - -
, David Pikus, Esq.
Shea and Gould June 3, 1982 Page 3 W( look forward to your cooperation in discovery so that the expedited schedule can be met without unnecessary expenditures of time and ef fort.
Very truly yours, Amanda Potterfield cc: Official Minimum Service List for Indian Point Investigatory Proceeding, to be mailed June 7, 1982 4
4
(C( bI
(-ll YI O POWER AUTHORITY OF THE STATE OF NEW YORK (7 "
10 COLUMBUS CIRCLE NEW YORK, NEW YORK 10019 CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
4 1RVING PLACE NEW YORK, NEW YORK 10003 June 11, 1982 Amanda Potterfield, Esq.
New York Public Interest Research Group, Inc.
9 Murray Street New York, New York 10007 Re: Consolidated Edison Company (Indian Point, Unit 2); Power Authority of the State of New York (Indian Point, Unit 3);
Docket Nos. 50-247-SP; 50-286-SP
Dear Ms. Potterfield:
We have your letter of June 3 regarding supplemental requests for document production.
A. Additional documents requested by UCS/NYPIRG.
Licensees have no objection to producing the following additional documents:
- Aldrich, D.C. and Ericson, D.M., Jr., Public Protection Strategies in the Event of a Nuclear Reactor Accident: Multi-Compactment Ventilation Model for Shelters, SAND 77-1559, Jan. 1978.
- Aldrich, D.C., Ericson, D.M., Jr. and Johnson, J.D., Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Con-cepts with Existing Public and Private Structures, SAND 77-1725, Feb., 1978.
- Yankelovich, Skelly and White, "A Report on Tempgrary Housing Related to Evacuation of the Indi,an Point Power Plant Area", June 1980.
Please feel free to call me to arrange a mutually convenient time to inspect these documents at our office. We do not presently 4
m- . ii i nn si if .. ..
Amanda Potterfield, Esq.
June 11, 1982 Page Two have available copies of Aldrich & Ericson studies but we expect to have them within the next week.
At the depositions of Dr. Dynes and Dr. Lecker last week, we advised you that the Highway Capacity Manual should be avail-able at a variety of public repositories in New York. A complete citation to this work appears at p. 7 of the January 1981 Parsons Brinckerhoff methodology document, which was made available to you on May 17. Our consultants subsequently confirmed our belief, and suggest that you contact the New York University Library, the Columbia University Library, the Brooklyn Polytechnic Institute Library, local offices of the New York City and State Departments of Transportation, or the New York City Public Library, all of which are likely to have uopies.
The licensees do not intend to produce either the Institute for Nuclear Power Operations ("INPO") Evaluation Report or documents requested in UCS/NYPIRG Interrogatory 67. The INPO report was and erroneously included in licensees' response to inad'ertently'nterrogatory UCS/NYPIRG I 2; our response is being amended accordingly. Neither the licensees nor Parsons Brinckerhoff Quade & Douglas have relied upon the INPO report in preparing their testimony, and its contents are beyond the scope of any contention for which UCS/NYPIRG has been assigned lead or contributing intervenor status and not within the scope of discovery as defined by 10 CFR S2.740(b). We regret any inconvenience occasioned by our error.
We also maintain our objections to UCS/NYPIRG interrogatory
- 67. Your amended interrogatory is not only untimely, but re-mains too vague for response. Moreover, UCS/NYPIRG's reliance on Board Contention 3.4 to support its request is misplaced for two reasons.
First, UCS/NYPIRG has not been assigned lead or contributing intervenor status for this contention. In its Memorandum and Order (Formulating Contentions and Designating intervenor Re-sponsibilities) dated April 9, 1982, the Board expressly limited discovery for each contention to the lead and contributing in-tervenors thereon.
Second, there is no connection between subjective of the " credibility" of the licensees and public perceptioq)ilities the licensees' ab to effect proper notification in the event of an emergency. Hence we object to your document L_
Amanda Potterfield, Esq.
June 11, 1982 Page Three request as beyond the scope of Board Contention 3.4 or any of the Commission's Questions.
B. Documents requested by licensees.
As you may recall, at the document production at the NYPIRG offices on May 26, we noted the absence of the documents cited in UCS/NYPIRG responses to Licensees' interrogatories 71, 74, 83, 112, 124, and 131. You had agreed to attempt to ob-tain these documents for our inspection. We reques t that those documents, as well as the " studies" referred to in UCS/NYPIRG response to Licensees' interrogatory 78, be produced at or prior to our supplemental document production.
Finally, we renew our request for copies of the prior tes-timony of UCS/NYPIRG wi4nesses, originally requested in Licen-sees' Interrogatory 180 and the accompanying document request.
In particular, we note that Dr. Beyea, at his deposition, stated that such testimony was in his custody.
C. Copies of documents.
At the request of UCS/NYPIRG, va have copied various docu-ments produced at our offices on June 1. We are prepared to f urnish these copies to you at your convenience, and to re-ceive the documents which you have copied at our request.
We look forward to expeditious completion of all of these discovery matters.
Very truly yours, David H. Pikus
.. W Brent L. Brandenburg cc: Service List i
L_1
..'-~
- PO UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CONSOLIDATED EDIS0N COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2) ) 50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK ) June 21, 1982 (Indian Point Unit 3) )
IXs/NYPIIU LIST T WrINESSES WI'INESS APPLICABLE BOARD COtfrINTIONS A. CONSIDERATION T MJLL IWEE T ACCIDENT SCENARIOS AND MEIE0lOIOGICAL OCNDITIONS REQUIRE EXPANSION T 'IHE PIINE EPZ AND RE-ESTIMATION T EVACUATION TIMES
- 1. BrianPalenik,NationalAbdubonSociety's 3.3, 3.6, 4.1, 4.6 Policy Research Department, and Dr. Jan Beyca, Senior Energy Scientist, National Atrlubon Society
- 2. Donald J. Pizzarello, M.D., Professor of 3.1, 3.3, 3.6, 4.1, 4.6 Radiology, NYU Medical School ,
B. DEFICIENCIES IN PUBLIC INEDBMATION, PRIMARY ALERP !<.anCitTION SYSTIM AND MEDIA NOTIFICATION
- 3. Richard Jay Altschuler, Statistics for 3.1, 3.2, 4.5 Business
- 4. Lynn C. Gunzenhauser, resident, Croton-on- 3.1 Iludson
- 5. Karen llenqs, parent, (brtlandt 3.1, 3.2, 3.3, 4.2
- 6. Agata Craig, parent, Croton-on-Iludson 3.1, 4.2
- 7. Lawrence Kaagan, Senior Research Associate, 3.2, 4.5 Yankelovich, Skelly and White, Inc.
- 8. Dr. Donald D. Smith, Professor of Mass 3.1, 3.2 ctumunication in the School of Journalism, University of Iowa A. . . . . . . . . . . . . . .
WI'INESS APPLICABLE BOARD COffENTIOE C. IOCAL OFFICIAIS' TESTIbONY REGARDIIG GENERAL DEFICIENCIES IN DEICEtCf PIRNIIG, ESPECIALLY PROBLDS WI'III DE BOADS, IACK OF EQUIPMEtif AND IIMDEDUATE TRAINING
- 9. Sonny Hall, Vice-President, Transport 3.1 Workers Union, Ircal 100 D. DEFICIENCIES IN DERGENCY PLANNDG WIMI RESPECT 'IO HEALUI AND FEDICAL RESOURCES
- 10. Janes L. Murphy, M.P.lf., Public Health 3.1 Specialist, New York Public Interest Research Group, Inc., White Plains
- 11. Joan Harding King, registered nurse and 3.1, 3.6 parent, New City, and Jannelise Galdone, photographer and parent, New City E. UNRELIABILITY OF EVACUATION TIME EST] MATES AND PROBLEMS WIMI HIE BOADS
- 12. Ibbert L. bbrris, Consultant in Traffic 3.1, 3.3, 3.6 and Transportation F. DEFICIDGES IN EMERGENCY PIRMING EUR 'ITE HANDICAPPED AND MOBILITY IMPAIRED
- 13. Samuel W. Anderson, Ph.D., President, New 3.1, 3.6, 4.1 York State Coalition of People with Disabilities G. DEFICIENCIES IN DERGEtCf PLANNING -FOR 'ITE EVACUATION OF OIIIDREN NOf IN SCIOOL
- 14. Phyllis V. Ibdriguez, recreational art 3.1, 3.2, 3.3, 3.6, 4.2 teacher and parent, Croton-on-Hudson II. DEFICIENCIES IN DEFGENCY PLANNING EUR ME EVACUATION OF OIIIDREN IN SOIOOL, ESPECIALLY REGARDDG INSTI'IUfIOE 04I'ITED FRCM 'ITE PIANNING i
- 15. David Siegel, Superintendent of Schools, 3.1, 4.5 :
Croton-Hanton School District !
l
- 16. Ibbert W. Hare, Pastor, Scarborough 3.1, 3.2, 4.1, 4.5 Presbyterian Church, and parent
- 17. Cleland S. Cbnklin, Superintendent of 3.1, 3.2 Buildings, Grounds and Transportation, South Orangetown School District a
WI'INESS APPLICABLE BOARD ENTENTIONS I. DEFICIEPCIES IN EMEIGENW PIANNING: ASSGPTIONS ABOUT 'IffE RESPONSE OF QIIIDREN
- 18. Jerome Kagan, Ph.D. , Professor of 3.2 Ilman Develognent, liarvard University, and J. DEFICIENCIES IN EMEIGENW PIANNING: ASSGPTIONS ABOUT 'IHE RESPONSE
_ OF BUS DRIVDtS
- 19. Fern Narod-Shick, school bus driver, 3.1, 3.2, 3.3, 4.6 bhhopac school district, Westchester, and, Seth Corwin, 01appaqua Bus (b. , Inc. ,
and, Ttm Turner, Vanguard Bus Co., and Albert A. Johnson, resident, Stony Point K. DEFICIDCIES IN EMEIGEtCY PIANNING: ASSLNPTICNS ABOUP 'IIIE RESPONSE OF TEAOIERS
- 20. Joan C. Livingston, teacher, Carrie E. 3.1, 3.2, 4.5
'Ibnpkins Elmentary School, Croton -
on- IIudson
- 21. Eleanor Kahn, special education teacher, 3.1, 3.2, 4.1 Robert E. Bell Middle School, and parent, Chappaqua L. DEFICIDCIES IN EMEIGENCY PIANNING: ASSINPTIONS ABOUT RESPONSE OF PARENIS
- 22. T. Derry Brazelton, M.D., Professor of 3.2 Pediatrics,liarvard Medical School
- 23. Mary P. Bulleit, parent, Croton-on - 3.1, 3.2 Iludson, and, Susan M. Teasdale, parent, Peekskill
- 24. IIelga Ancona, parent, Stony Point 3.1, 3.2, 3.3, 4.1
- 25. Myra Spiegelman, parent, Croton-on-iludson, 3.1, 3.2 and Kathleen 'Ibscani, parent, Croton-on-IIudson
- 26. Ellen Burgher, parent, Pleasantville 3.1, 3.3, 4.1, 4.5
- 27. Sari Eklundo Fggnt, Croton-on-IIudson 3.1, 3.2 j
WI' MESS APPLICABLE DOARD OJNTENTION
- 28. Eileen FtGovern, parent, 'Itmkins 3.2, 4.5 (bve
- 29. Ervine Idnnerling, psychotherapist and 3.1, 3.2 parent, Croton-on-Hudson, and
'Iheodora Dyer, parent, Croton-on-Hudson M. DEFICIDCIES IN DERGENCY PIANNDE: ASSCMPTIONS ABOUT HENAN RESPONSE IN GENEPAL AND ESPECIAILY 'IllOSE ABOUT EfEIKM NORKERS
- 30. Kai T. Erikson, Professor of Sociology 3.2 and Editor, Yale Ibview, Yale Univer-sity N. DEFICIDCIES IN DERGENCY PIANNING: ASSENPTION 'IIIAT A RADIOIOGICAL EMERCENCY IS LIKE OIIER DETCENCIES
- 31. Ibbert Jay Iifton, M.D., Ebundations Fund 3.2 Research Professor of Psychiatry, Yale School of hkxlicine O. DEFICIENCIES IN DERGENCY PIANNDE: ASSENPTICNS ABOUT 'ITE RESPONSE OF MEDICAL AND HEAL'III WORKERS
- 32. Edward J. (bnnelly, Emergency Medical 3.2 Technician and Member, Ossining Volunteer Ambulance Corps
- 33. Gristopher buxwell, Director, Respira- 3.1, 3.2 tory 'Iherapy, (bumnity General Osteopathic Hospital, Harrisburg Pennsylvania, and Julie Palmer, M.D., Piermont P. DEFICIENCIES IN EMEIGENCY PIANNING: ASSENPTIONS ABOUP 'ITE EVICUATION OF VERY YOUNG OIIIDREN
- 32. Albert J. Solnit, M.D., Director, Yale 3.2 University Child Study Center
- 33. Phyllis Mendelsohn, Teacher-Director, 3.1, 3.2, 3.3 Croton Conmunity Nursery School, and Abby Perl, nursery school teacher, Croton-on-Hudson, and Judith Glass, teacher, Croton Ommunity NurseryaSchool, and parent
- 34. Paula Myers, kindergarten teacher, Carrie 3.1, 3.2 E. 'Itmpkins Elenentary School, Croton-on-Hudson Q. DEFICIENCIES IN DERGENCY PIANNItG: ASSENPTIONS ABOUT 'IIIE RESPONSE OF ADULTS AND OITERS
- 35. Murray Melbin, Ph.D., Professor of 3.2 Sociology, Boston University 4 m
WI'ITESS APPLICABIE DOARD ONITNTICNS
- 36. Bela and Ingra Cseh, residents, Croton- 3.2 on-Iludson R. 'llE NEED FOR CDNSIDEPATICN T DE FULL RlWGE T ACCIDENT SCENARIOS EXPANSIN T 'I1E PIINE EXPOSURE EMERGENCY PIANNING ZONE AND DIE ESTABLISINENT T A MAXDiM ACCEPTABIE DOSE IEVEL
- 37. Victor W. Sidel, M.D., Chairman, 3.6, 4.1, 4.6 Department of Social Medicine, Montefiore llospital and Medical Center Dated: New York, New York June 21, 1982 dm'Et;f M. BIIN, ESQ.
Counsel for the Union of (bncerned Scientists New York University Law School 423 Vanderbilt Hall 40 Washington Square South New York, New York 212-598-3452 AMANDA PCTITERFIEID, ESQ.
Counsel for the New York Public Interest Research Group, Inc.
Box 384 , Village Station New York, New York 10014 212-227-0265 6 - - -
. .s