ML20071B332

Objection to NRC 830204 Proposal for Receiving Evidence on Commission Questions 3 & 4.Opposes Proposal to Limit Time of NRC Witness Urbanik.Certificate of Svc Encl

ML20071B332
Person / Time
Site:	Indian Point
Issue date:	02/19/1983
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:
References
ISSUANCES-SP, NUDOCS 8302280163
Download: ML20071B332 (5)

Text

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UNITED STATES OF AMERICA nut" " AR REGULATORY CCMMISSION .

ATOMIC SAFETY AND LICENSING BOARD 'U FE 24 kl0:27 Administr.:ive Judges:

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James Gleason, Chairman , ,;9-~

Dr. Oscar H. Paris In the Matter of Frederick 3. Shon CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos. 50-247-SP -

(Indian Point, Uni: 2) ) 50-236-SP

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POWER ACTHORITY OF THE STATE OF NEW YORK ) - February 19,1983 (Indian Point, Unit 3) )_

WEST BRANCH CONSERVATION ASSOCIATION'S OBJECTION TO"NRC STAFF'S PROPOSAL FOR RECEIVING EVIDENCE ON COMMISSION

_____________________9M!Ii9E!_!_eED_f"___________________

West Branch Conservation Association (WBCA) takes exception to Staff's above titled proposal of date of February 4 on page 2 regarding the limit of time for Staff's witness _

Dr. Urbanik.

WBCA is co_ lead intervenor on Question 3.9. Dr. Urbanik is consultant to the Staff on roads, as well as on other con-tentions. Staff may be guided by his assessments. He could -

not stay over to be cross examined by.WBCA and we were pro-mised that he would return. Whatever time anyone has already consumed interrogating Dr. Urbanik has no bearing on the time that WBCA is entitled to.

At this writing we would anticipate requiring 1h to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without sharing with all other parties but UCS/NYPIRG who has already cross examined Dr..Urbanik. That cross did not refer to the roads in Rockland County.

for West Branch Conservation Association 1eeC y 1 f2Y L 0 W 914/634-2327 f 'g'ipporah S. Fleisher Secretary 8302200163 830219 PDR ADOCK 05000247 0 PDR

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UNITED'5TATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD ..

.n Fefore Administrative Judgest 20 James Gleacon , Chairman Frederick J. Shon c #'

In the Matter of Dr. Cscar H. Paris

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y CONSOLIDATED EDISON COMPANY OF )

NEW YORK, INC. (Indian Point, )

Unit No. 2) } Docket Nos. 50-247-5P '

) 50-286-SP -

i'0WER AUTHORITY OF TH: STATE OF )

NEW YORK, (Indian Point, February 21, 1983 Unit No. 3) * )) '

CERTIFICATE OF SFRVICE This is to certif3 that I have this day placed in the fi st class U.S. mail a copy to each of those listed below of !,: s t Branch ConservationResume Association's and Summary MotionofTe Frank Reinstate FischerPs?>i~

testimony ana Objection To Staff's Proposal to limit er ie of Contention 43 2,

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. . - im, FOR West Branch Conservation Association 443 Buena Vista Road

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,v i n UdCYE bLb oy Zipporah 3 ?;eisher Secretary

r ORANGE AND ROCKLAND UTILITIES,INC.

cre ble N# azo. peod re. new york.10965 9M-352-eID  !

var s sw da nfrce- '63 914-627-2424 ~0 24 (tg,.g7

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's . i ' 'h July 19, 1982-BY HAND Mrs. Z. S. ?leischer West Branch Conservation Association 443 Buena Vista Road -

New City, New York 10956

Dear Mrs. Fleischer:

The following are the responses to the questions which you directed to Stephen L. Baum in your letter of May 26, 1982.

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Question 1. Does each plant require people to operate it or can one or both operate for a period of time without personnel?

Please advise the time limits.

Answer Each plant requires operators whenever it is in service. The plants cannot be operated without any personnel present.

Question 2. If an emergency took place and an operator at one or both plants felt the need to leave to evacuate his family could ne call in a replacement? Is' there an arrangement for eaergency personnel to report to the plants upon hearing the sirens? What other ways d you have to communicate with outside personnel not on the premises? How long would it take to be sure that the plants have a proper complement capable of running the plants?

Answer Sufficient operators are assigned to each plant at all times to assure their safe and reliable operation. Operators must remain on duty until properly relieved, either by another operator or by a supervisor in an emergency. If additional personnel are required because of the unavailability of personnel on duty,

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. Mrb . Z . S. Fleischar '

i Page 2 l July 19, 1982 ,

they are called in by the supervisors-by telephone. A sufficient number.of personnel.are scheduled for duty at all times to insure that the proper complement capable of running the plant-ir slways available.

Question 3. What assurance, letters of agreement or contracts do you have from employees that

.they will either stay on the job or report for work? Please supply sample copy of such agreement.

Answer Employees under the Collective Bargaining Agreement agree to report to work and to remain

, on the job until properly relieved.

Question 4. If either or both plants were to' shut down for any reason during such an emergency what auto-matic. substitute would come on the line? How many MW would be supplied from the Pool and for-how long?

Answer If it were necessary to evacuate all personnel from either or both plants they would be shut down prior to the evacuation of. personnel.

High voltage transmission interconnections to the New York Power Pool .would be capable of supplying the power requirements of the Orange and Rockland system during this period. The cost of operation would be significantly higher than it would be if the energy were provided from our own plants l but the electric system would be capable of continuing operation in this mode.

Question 5. Is there any radiation monitoring equipment

, available to personnel at either plant in j the event of an accident at Indian Point?

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4

Mrs. Z. S. Fleischer Page 3 July 19, 1982 Is there any protective clothing for those who choose to remain at their jobs? Is there any dosimeter for each employee or radiation badge?

Answer There are no radiation monitoring or

• protective equipment at either plant for the usp of personnel during an emergency.

Instructions on the evacuation of these plants will be received from the Civil authorities in accordance with the Emergency Plan in effect at the time.

When ordered to do so by the competent authorities, the personnel of the plant will be evacuated.

As Mr. Frank E. Fischer discussed with you in a previous telephone conversation, he is prepared to support these responses at the NRC hearings, if so requested by you.

Very truly yours, Victor A. Roque -

Senior Attorney VAR /amr cc: F. E. Fischer s

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