ML19341C491

Request That ASLB Accept Witness List Even Though 810121 Deadline Passed.Unanticipated Personal Difficulties Arose. Also Failed to Realize Existing Witness List Would Be Erased.Related Correspondence

ML19341C491
Person / Time
Site:	Summer
Issue date:	02/23/1981
From:	Bursey B AFFILIATION NOT ASSIGNED
To:	Grossman H, Hooper F, Lindenburger G Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8103030636
Download: ML19341C491 (2)

Text

i ggLHED C.ORRESPOEM Brett Bursey Intervenor "

Rt. 1, Box 93-C '

Little Mountain, S.C. 29075 February 23, 1981 Atomic Safety & Licensing Board @ g d' 4

Herbert Grossman

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o // f Dr. Frank Hooper coo o B g[ /

Gustave Lindenburger 2 N 49 09 '

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, g SOUTH CAROLINA ELECTRIC AND GAS

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C0fiPANY, ET AL.

• 4 Docket No. 50-395 OL

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(Virgil C. Summer Nuclear )

Station, Unit I )

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Gentlemen: .

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Having missed the January 21 deadline for renewing my list of witnesses in the -

above captioned proceeding, I petition the board to accept this document and 1 allow my affirmative case to proceed. #.

I did not anticipate that the existing list of uitnesses would be erased, and due to unanticipated personal difficulties (including an automobile a,ccident, January 28th) I chose to go with the list of ;itnesses on record.

Mr. Knotts had agreed to work with me to review the witnesses and documents on file, but I was never provided with the agreed upon information.

I continue to submit that my contentions are simple and clearly stated in the  :

{1.2 record of this proceeding and hope that the board will accept this response to their December 30 Order.

LIST OF WITNESSES EMERGENCY PLANS E County Emeraency Medical and Law Enforcement Personnel: to testify as to their specific state of r' joiness to respond to all contingencies. _.

Residents of the 10 mile emeraency zone: Local residents will testify as to -

their understanding of the emergency plans and the efficacy of the plan.

Alden Richardson: Co-ordinator of the Richland County Citizens Committee for Nuclear Preparedness. Mr. Richardson has been monitoring the development and E implementation of the emergency plan for the Intervenor. [

m Dr. Michio Kaku: Dr. Kaku, a nuclear physicist, will review accident scenarios and health impacts. Dr. Kaku is a professor of nuclear physics at City College of New York,138th St. at Convent Ave. , New York City, N.Y.10031.

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Page 2,,Intervenor's List of Witnesses Jane Lee, Rt. - 3,183 Val. ley Rd. , Etters, Pennsylvania 17319, a farmer and  ::4 Three Mil.e Island reside'nt., will testify from the vantage point of experiences as i::. ;;:

to specific shortcomings in the V.C. Summer plant Emergency Plans.

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HEALTH EFFECTS

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The long term health effects of operating the V.C. Summer plant will be presented $f5"

.by Dr. - Helen Caldicott, M.D. (1445 Commonwealth, West Newton, Mass. 02165); Dr.

Chauncy Kepford, chemist, will testify as to the health effects of the nuclear $"1 ic;m ,

fuel cycle of the V.C. Summer plant (University of Pennsylvania 16802). [.19 t:n...:.

Bob Alvarez: Mr. Alvarez is the Director of the Nucelar Program for the Environ-mental Policy Center, 317 Pennsylvania Ave. Washington, D.C. 20003. "7 '"""

SEISMIC 55 Dr. John Carpenter, geologist, will be called to testify as to geologic problems facing the V.C. Summer plant (Geology Dept. , University of South Carolina 29208).,

ANTICIPATED TRANSIENTS WITHOUT SCRAM (ATWS),

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e-Testimony about the ATWS question is being prepared by the Intervenor. Brott B urs ey.

FINANCIAL QUALIFICATIONS _

Attorney Robert Guild will testify to the financial qualifications of the applicant to safely operate, maintain and decommission the V.C. Summer plant.

QUALITY CONTROL i=

Past and cresent emoloyees of the aoolicant and their subcontractors will testify [."

as to the quality assurance. of construction of the V.C. Summer plant. 'i!=

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Brett Bursey .

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cc: All parties of record .;

Appeal Board Governor Richard Riley h.. . .

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