ML20058G816
| ML20058G816 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/30/1982 |
| From: | Chavez D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20058G822 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8208030426 | |
| Download: ML20058G816 (2) | |
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July 30, 1982 1an-2ma.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.... n BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-454 OL l
50-455 OL (ByronStation, Units 1 and 2)
INTERVENOR DAARE/ SAFE'S MOTION TO SUPPLEMENT -
ITS ANSWER TO COMMONWEALTH EDISON COMPANY'S AND NRC STAFF'S MOTIONS FOR
SUMMARY
DISPOSITION OF INTERVENOR'S CONTENTIONS 2 and 2a; On July 19, 1982, Intervenor filed with the Board an Answer to Staff's and Applicant's Motions for Summary Disposition.
As part of the Answer to the Motions with respect to Contentions 2 and 2a, Intervenor cited short and concise statements of material facts as to which exist a genuine issue to be heard.
A major part of those statements related to the health effects of airborne radiologic releases, under both nomal operating conditions and under., accidetaal conditions.
Also on July 19, 1982, Dr. E.J. Sternglass, Prof, of Radiological Physics, indicated to Intervenor that he had 8206030426 820730 PDR ADOCK 05000454 g1
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knowledge of recent information that is directly pertinent to Contention 2 and 2a, and that he would on that' day provide an affidavit describing the information.
Since the information contained in the affidavit was not available to Intervenor on the date of filing, is directly pertinent to Intervenor's Contentions, and consists of data only recently available to the scientific community such that it could not have been incorporated into Applicant's risk assessments. Intervenor respectfully requests that the Board permit Intervenor to supplement its Answer with respect to Contentions 2 and 2a with the enclosed affidavit of Dr. Sternglass.
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In support of its Motion to Supplement, Intervenor points both to Dr. Sternglass's outstanding educational, experience, and scholarly backgrounds, as well as h['s frequent testimony before the ACE /NRC: and to the serious health consequences to a uniquely high-risk population, namely new-born infants, which Dr. Sternglass identifies.
Diane Chavez Sinnissippi Alliance for the Environment 2