ML20083Q368

Motion for Preservation & Production of Certain Documents Re 830309 Emergency Exercise.Record Essential to Give Accurate Picture of Any Exercise Evaluation Results

ML20083Q368
Person / Time
Site:	Indian Point
Issue date:	02/22/1983
From:	Holt J PUBLIC INTEREST RESEARCH GROUP, NEW YORK
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20083Q370	List: ML20083Q368 ML20083Q382 ML20083Q393 ML20083Q408 ML20083Q428 ML20083Q442 ML20083Q448 ML20083Q474 ML20083Q489 ML20083Q499 ML20083Q505 ML20083Q523
References
ISSUANCES-SP, NUDOCS 8302250372
Download: ML20083Q368 (3)

Text

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..>.n UNITED STATES OF AMERICA '83 FEB 24. A!0:25 NUCLEAR REGULATORY COMilSSION 3 Metw i si 4 SERV;re .-- - _ ~

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9 _.. . -m _

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CONSOLIDATED EDISON COMPANY OF NEW YORK )' Docket Nos. 50-247 SP g (Indian Point Unit 2) ) 50-286 SP

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POWER AUTHORITY OF THE STATE OF NEW YORK ) .

(Indian Point Unit 3) .) February 22, 1983 NYPIRG Motion for-4 Preservation and:Productionc of Certain Documents Relevant:.to the _ Exercise -

of March 9, 1983 I

NYPIRG and other .intervenons have entered into -negotiations with local governments, including Westchester and Putnam. Counties, to: allow .

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I intervenor representatives to observe the activities of the:r'espective' local gove'nments during the exercise of the-Radiological Emergency Response Plan '

' for Indian Point Unit 2, scheduled for March 9,1983..When these agreements' are complete, they will be submitted to the Board in the form.of a Motion .

for Approval;of Stipulation. However, during'the months of January and

. February, activities have been taking place involving the NRC, . FEMA, local govern-ments, and the licensees in preparation for the exercise. Anrecord;ofithese activities is essential to give an accurate picture of any evaluatiori of the results of the exercise.

Therefore, NYPIRG moves for an order requiring each party and 4 participant to preserve and produce all record or documents, of the . kinds listed in 10 C.F.R. 2.4(q), prepared by them, their representatives, or their contractors, which pertain to preparation for the emergency-planning exercise or to verification of the components of the Emergency Response Plans for New York State and the four affected counties, Westchester, Rockland, Putnam, and Orange. -

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Specifically, NYPIRG requests that documents relating to a meeting with the Wesschester Department of Health and the New York

' " . State-Radiological Emergency-Preparedness Group on January 24, 1983 be ,

preserved and produced; Documents relating to a meeting with school administrators and the REPG held on January 27, 1983, be preserved and produced; Documents relating'to a tabl6 top drill involving Westchester County officials on February 17, 1983, be preserved and produced; Logs of phone calls made to reception centers, nursing horhes, special facilities, or any other institution assigned a role in the. Plan, by ,

the Argonne National Laboratories, or any other contractor engaged by FEMA to verify portions of the Radiological Emergency Preparedness Plans, be preserved and produced; _ .-

These are only a few of- the preparatory activities which have oc-comedd in an attempt to assure the success of the. March 9 exercise and to ascdrtain the status of emergency preparedness in case of a radiological ,

emergency at the Indian Point Nuclear Power Station'. NYPIRG reserves the right to request the preservation and production of documents _ relating to any other activity.in preparation for the March 9 exercise of which it

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becomes. aware. All these reports and documents will be of value to the Board in adressing questions 3 and 4 of the Comission'.s Memorandumaand Order of January 8,1981.

WHEREFORE, NYPIRG prays for an order directing t: The NRC Staff FEMA and its contractors, Westchester, Rockland, Orange and Putnam County officials, New York State Radiological Emergency Preparedness Group, the Power Authority of the State of'New York, and Consolidated Edison, to:

(a) Preserve all reports and drafts of reports prepared by them in connection with the emergency planning exercise scheduled for March 9,1983, together with any additional documents which relate directly to or help explain or provide background for the-information contained ~inusu* c h reports; (b) Prepare a list of all documents required to be preserved under

~(a) above by title, or by subject matter if untitled, and serve copies of the list on the Board and the part'ies to this proceeding, with updated copies to be served if and when new documents are prepared or become available;

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(c) Designate a custodian.of. the listed documents and cause the custodian to maintain a repository o'f readable copies of the documents.

The name and address of the custodian should be provided with the initial list.

The Board has the authority to grant the requested relief

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e . _ . _. . . ; udder 10 C.F.Rf-2.V18(e): "A presidinggofficer .:nhas all -powers ~necessary ~~

d tc those ends, including the power to... regulate the course of the hearings and the conduct of the participants."

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NYPIRG has moved directly to the Commission for an order requiring the licensees to permit representatives of the intervenors in this.

matter to observe the emergency planning exercise from the control room of Indian Point Unit 2; the control room of Indian Fbint Unit 3; and .the near site emergency operations facility.

Respectfully submitted Date'd: New York City Joan Holt February 22, 1983 Project Director New York Public Interest Research Group, Inci-

-- 9 Murray Street New York City 10007 (212) 349-6460

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