ML20073G386
| ML20073G386 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/11/1983 |
| From: | Bielawski A COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Callihan A, Cole R, Smith I Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20073G389 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8304180269 | |
| Download: ML20073G386 (3) | |
Text
e ISHAM, LINCOLN & BEALE COUNSELORS AT LAW C M !#EIU THREE FIRST NATIONAL PLAZA CHICAGO ILUNO:56cm02 EDWWID S ISHAM. 1872 1902 WASHINGTON OFFICE G E E 1 tw WASHINGTON O C 20036 ma nnem April 11, 1983 i
Mr. Ivan W.
Smith Dr. Richard F. Cole Adminstrative Judge Atomic Safety and Licensing
& Chairman Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission Room 428 Washington, D.C.
20555 East West / West Towers Bldg.
4350 East West Highway Bethesda, MD 20114 Dr. A. Dixon Callihan Union Carbide Corporation P.O.
Box Y Oak Ridge, Tennessee 37830 Re:
Commonwealth Edison Company (Byron Nuclear Power Station Units 1 and 2)
Docket Nos. 50-454 OL and 50-455 OL Gentlemen:
Pursuant to the Stipulation of the parties, I am filing the enclosed testimony of the six witnesses that Licensee intends to call at the hearings on those portions of the amended emergency planning contention that the parties have agreed to litigate, that is, paragraphs 2 (c), 2(e),
2(k),
3, 8,
10, and 13.
As such, the testimony addresses only the concerns raised in those paragraphs.
(The remaining paragraphs of the amended emergency planning contention will be dealt with outside of the hearing process in accordance I
with the Stipulation.)
Licensee hereby withdraws the previously filed testimony of Messrs. John C. Golden, E.
Erie Jones, David L.
Smith and David D. Ed which addressed the original emergency planning contentions of DAARE/ SAFE Contention 3 and League of Women Voters Contentions 19 and 108.
(The original 8304180269 830411 PDR ADOCK 05000454 T
PDR L
Administrative Judges r
April 11, 1983 Page 2 emergency planning contentions have been withdrawn pursuant to the Stipulation of the parties.)
The same four witnesses have filed new testimony which is enclosed.
In addition, two new witnesses, Ms. Jean L. McCluskey and Dr. Thomas J.
Horst have filed joint testimony.
Because of the expense and burden involved with duplicating the voluminous exhibits which were filed with the original testimony and now make up part of the exhibits to the new testimony, we ask your assistance in compiling the exhibits for the new testimony as follows:
1.
Testimony of Ms. McCluskey and Dr. Horst.
At-tachment 1 to their testimony, " Evacuation Time Estimates Within the Plume Exposure Pathway Emergency Planning Zone for the Byron Nuclear Generating Station," was previously served as Exhibit 3 to the old testimony of Dr. John C. Golden.
2.
New testimony of Dr. Golden.
Exhibits 1 and 2,
" Generic GSEP" and " Byron Station Emergency Plan Annex of GSEP" were previously served as Exhibits 1 and 2, respectively, of the old testimony of Dr.
Golden.
In addition, Dr. Golden has 4 new exhibits, Exhibits 3-6, which are attached to the new testimony now being served.
3.
New testinony of David D. Ed.
Attachments 1-5 of Mr. Ed's old testimony now constitutes Attachments 1-5 of his new testimony.
Figure 1 and Maps 1-3 of his old testimony may be discarded.
Mr. Ed has no new attachments.
4.
New testimony of David L. Smith.
Exhibit A to Mr.
Smith's testimony, (his resume), is attached to the new testimony.
Exhibit B, IPRA Volume 6, was served as Exhibit B to Mr. Smith's old testimony.
Exhibits C and D are new and attached to the enclosed testimony.
5.
New testimony of E. Erie Jones.
Exhibit 1, Mr.
Jones' resume, is attached to the new testimony.
Exhibit 2, IPRA Volume 1, was served as Exhibit 2 to Mr. Jones' old testimony.
l
i Administrative Judges April 11, 1983 Page 3 At the time these individuals are called to the witness stand, we will provide the court reporter with a complete 4
copy of all the testimony with exhibits.
We intend to present the witnesses at the hearing
- However, in the order set forth in the proceeding paragraph.
?
there are two possible conflicts which we would like to bring to the attention of the Board.
Dr. Golden will not be available on April 20 because of his involvement in a Also, Mr.
court proceeding involving personal matters.
Jones has numerous responsibilities as Director of the Illinois Emergency Services Disaster Agency and will only be i
available on April 21.
We request that Applicant be per-mitted to present the witnesses in an order that will accommodate their schedules.
The enclosed testimony is being served by mail on In addition, I will hand all parties on the service list.
deliver copies to the Board and the parties at the hearings in Rockford, Illinois on April 12, 1983.
Please be informed that the prior notice concerning and IPRA the copies of IPRA Volume 1 (Jones Exhibit 2)
Volume 6 (Smith Exhibit 2) are still in effect, i.e. these copies are provided only as an accommodation for review in litigation and are not to be copied in any form nor dissemenated We request that the copies provided be returned at further.
the conclusion of the litigation.
Sincerely
[
l k
A an P[ B*e awski One of e Attorneys for Commonwealth Edison Company APB:mbn I
cc:
Service List E. Erie Jones David L. Smith David D.
Ed Jean L. McCluskey Thomas J.
Horst
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