ML20083Q393

Motion to Permit Entry on Licensee Controlled Land to Observe 830309 Emergency Planning Exercise from Control Rooms & near-site Emergency Operations Facility

ML20083Q393
Person / Time
Site:	Indian Point
Issue date:	02/22/1983
From:	Holt J PUBLIC INTEREST RESEARCH GROUP, NEW YORK
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20083Q370	List: ML20083Q368 ML20083Q382 ML20083Q393 ML20083Q408 ML20083Q428 ML20083Q442 ML20083Q448 ML20083Q474 ML20083Q489 ML20083Q499 ML20083Q505 ML20083Q523
References
ISSUANCES-SP, NUDOCS 8302250383
Download: ML20083Q393 (3)

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~ UNITED STATES OF AMERICA- ,

NUCLEAR REGULATORY COMISSION BEFORE THE C'OMMISSIONERS In the Matter of

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

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POWER AUTHORITY OF THE STATE OF NEW YORK ) February 22, 1983 (Indian Point Unit 3) )

NYPIRG MOTION FOR DISCOVERY PURSUANT TO 10 CFR 2.741(a)

(2) '"O PERMIT ENTRY UPON LAND IN CONTROL OF THE' LICENSEES The New. York Public Interest Research Group request the.

Commissioners -to issue an order requiring the Licensees, CONSOLIDATED EDISON COMPANY OF NEW YORK, and the POWER AUTHORITY OF THE STATE OF NEW YORK, to permit representatives of intervenors in this matter to observe the emergency planning exercise scheduled for the Indian Point site on March 9, 1983.

This motion has been presented directly to the Commissioners because of the unique circumstances and prior history of this' proceeding.

A similar motion regarding the March 1982 exercise at Indian Point was ultimately decided by the Commissioners, and it being likely that this motion would also likely be so lecided, the brief time remaining before the-exercise requires that the usual procedural steps by supervened.

The emergency planning exercise scheduled for March 9, 1983 is 8302250383 830222 PDR ADOCK 05000247PDR G

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WWM d# relevant.to'CommissioFQu'estiontThree and to Board' Contentions'thiereN5MM-t under and is well within the scope of discovery.10 CFR 2.740(b)(1).

The circumstances surrounding the upcoming exercise are substantially different than those of the 1982 emergency planning exercise. The Indian Point emergency plans have been found by FEMA to have significant deficiencies and the March exercise and subsequent FEMA evaluation will be critical. evidence in this matter concerning emergency planning issues' under Cosmission Question 3 and Board t'

Contentions thereunder. But FEMA evaluations of emergency planning at Indian Point have come under critical scrutiny during this investigation.

Thus, the observations of intervenor representatives will prove necessary in order to test the FEMA findings resulting from the emergency exercise.

NYPIRG appreciates the need for the drill to be conducted without hindrance and obstruction, and intend by this request to gain relevant information in the most efficient and least burdensome manner to all parties. Observers can be positioned where they can see and

• hear but cannot interfere with the operation. Intervenor observers vill agree to stay behind barriers which permit visual and auditory observation and will refrain from speaking to exercise participants or distracting talk. The NRC Staff, in~its March 2, 1982~ RESPONSE TO LICENSING BOARD'S CERTIFICATION OF ITS RULING, noted that the presence of intervenor observers would not cause immediate, serious, irreparable harm. . (RESPONSE at p. 6)

WHEREFORE, the New York Public Interest Research Group requests the Commissioners to issue an order requiring the Licensees ~ to permit two intervenor representatives or consultants to:

(1) observe the March 1983 exercise from the control room of Indian Point Unit 2 (Con Edison);

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- (2)_. observe-the' March 1983 exercise from.the control room s E . , _ . - _-,

of Indian Point Unit 3 (PASNY);

.(3) observe the March 1983 exercise from the near-site emergency operations facility.

Respectfu y submitted, JOAN H

LT, Project Director New rk Public Interest Research Group, Inc.

9 Murray Street l New York, New York 10007 (212) 349-6460 e

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