ML20069L213
| ML20069L213 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/22/1983 |
| From: | Brandenburg B, Morgan C CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20069L215 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8304280100 | |
| Download: ML20069L213 (6) | |
Text
,.
00CKETED UNITED STATES OF AMERICA U W E NUCLEAR-REGULATORY COMMISSION ATOMIC SAFETY AND LICENSIEO Bb Rb'
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Before Administrative Judges:
.i James P.
Gleason, Chairman- __
b Frederick P.
Shon Dr. Oscar H.
Paris
x In the Matter of CONSOLIDATED EDISON COMPANY OF Docket Nos.
NEW YORK, INC.
(Indian Point, Unit No. 2) 50-247 SP 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK April 22, 1983 (Indian Point, Unit No. 3)
x LICENSEES' MOTION FOR ADMISSION INTO EVIDENCE OF EPZ TOUR DOCUMENTS ATTORNEYS FILING THIS DOCUMENT:
Charles Morgan, Jr.
Brent L.
Brandenburg i
Joseph J.
Levin, Jr.
CONSOLIDATED EDISON COMPANY OF Paul F.
Colarulli NEW YORK, INC.
MORGAN ASSOCIATES, CHARTERED 4 Irving Place 1899 L Street, N.W.
New York, New York 10003 Washington, D.C.
20036 (212) 460-4600 l
(212) 466-7000 l
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8304280100 830422 b
PDR ADOCK 05000247 G
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Preliminary Statement Consolidated Edison Company of New York, Inc.
24.
(" Con Edison"),l licensee of Indian Point Station, Unit No. 2 and New York Power Authority
(" Power Authority"), licensee of f
Indian Point 3 Nuclear Power Plant (collectively the "licen-sees"),_hereby move the Board to identify and receive into evidence as Exhibits CE-ll, CE-llA and CE-llB, respectively, theLannexed affidavit of Michael S. Della Rocca sworn to April 19, 1983 (CE-ll); a five-page document entitled " Tour of Indian Point EPZ, April 13, 1983, Itinerary" (CE-llA); and a map entitled " Roadway Tour of Indian Point EPZ and County EOCs" (CE-llB).
Nature of the Documents Exhibit CE-ll Exhibit CE-ll is an affidavit sworn to on April 19, 1983 by Mr. Della Rocca, an employee of Parsons, Brincker-
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hoff, Quade & Douglas; Inc. under whose direction and super-I-
vision Exhibits CE-llA and CE-llB were prepared.1 This l'd affidavit authenticates Exhibits CE-llA and CE-llB, sets L?
forth Mr. Della Rocca's qualifications, and explains the
_ circumstances under which these exhibits were prepared.
1 Mr. Della Rocca appeared as a witness in this proceeding on March 25, 1983.
m Exhibit CE-llA
- - Exhibit'CE-llA identifies each roadway section traveled by_the Board during the April 13, 1983 tour-of the
[
It also sets forth-the range of.
anticipated evacuation volumes for the -primary evacuation routes traveled, together with the average two-way daily volume of such routes, where available, from state and county sources.
Exhibit CE-llB Exhibit CE-llB is a map delineating the roadways traveled by the Board on April 13, together with all other
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primary evacuation routes and the EPZ boundary.
Grounds for Admission The annexed exhibits constitute the only record memorializing the route of the Board's tour of the plume 7
exposure pathway EPZ on April 13, in which numerous parties,
intervenors, and interested states also participated.
- Hence, I b' these exhibits will not only be valuable to the Board and hearing participants, but also are important to ensuring a l[
complete record.2
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Because.the participants did not reach final agreement on
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the route of the tour until shortly before the tour date, (footnote continued)
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The exhibits are clearly reliable, since the Board and participants had these items in their possession during
-the tour, and could then or now independently verify their accuracy.3 The data underlying the evacuation volume statis-tics was provided to the hearing participants at licensees' document production on June 1, 1982.
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Copies of the annexed exhibits are being provided to all addressees on the official service list, and three
. copies will be provided to the reporter upon receipt into evidence.
't (footnote continued from previous page) it was not possible for the licensees to distribute the exhibits or move them into evidence prior to the tour.
3 As Mr. Della Rocca points out at page 2 of his af fidavit, Exhibit A contains two corrections to the material dis-tributed on the April 13 tour.
Respectfully submitted, AL4 /L1 aulu k.
Ifrent L.
Brandenburg (27 Charles Morgan,(fr.' (/ p Paul F.
Colarulli Joseph J.
Levin, Jr.
CONSOLIDATED EDISON COMPANY MORGAN ASSOCIATES, CHARTERED OF NEW YORK, INC.
1899 L Street, N.W.
Licensee of Indian Point Washington, D.C.
20036 Unit 2 (202) 466-7000 4 Irving Place New York, New York 10003 Stephen L.
Baum (212) 460-4600 General Counsel Charles M.
Pratt Assistant General Counsel NEW YORK POWER AUTHORITY Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D.
Fischman Michael Curley Richard F.
Czaja David H.
Pikus SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000
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. 11 Dated:
April 22, 1983 f
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