Motion Requesting Initiation of Studies on Human Response to Radiological Emergencies,Risks to Individuals Living Near Site & Difficulty of Evacuation in EmergencyML20073R347 |
Person / Time |
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Site: |
Indian Point ![Entergy icon.png](/w/images/7/79/Entergy_icon.png) |
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Issue date: |
04/26/1983 |
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From: |
Potterfield A PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
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To: |
Atomic Safety and Licensing Board Panel, NRC COMMISSION (OCM) |
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Shared Package |
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ML20073R287 |
List: |
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References |
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ISSUANCES-SP, TAC-44117, TAC-44118, TAC-46259, TAC-46260, TAC-48851, TAC-48852, NUDOCS 8305030641 |
Download: ML20073R347 (8) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARJPN-99-029, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors ML20212E4181999-09-15015 September 1999 Petition Per 10CFR2.206 Requesting OL for Unit 2 Be Modified or Suspended to Prevent Restart Until Reasonable Assurance That Licensee in Substantial Compliance with Terms of OL & Has Proper Consideration for Public Health & Safety JPN-99-022, Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds1999-06-22022 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds ML20202J6321999-01-20020 January 1999 Transcript of 990120 Meeting in Peekskill,Ny Re Decommissioning.Pp 1-132.With Related Documentation ML20198E9721998-12-21021 December 1998 Order Prohibiting Involvement in NRC-Licensed Activities. Orders That Wh Clark Prohibited for 1 Yr from Engaging in NRC-Licensed Activities JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects ML20198L2731998-12-21021 December 1998 Comment Supporting NEI Re Proposed Rules 10CFR50, 52 & 72 Re Changes,Tests & Experiments JPN-98-050, Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20238F5271998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 IA-98-261, Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-461998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 ML20238F5241998-05-0606 May 1998 Transcript of 980506 Enforcement Conference Held in King of Prussia,Pa Re Con Edison,Indian Point.Pp 1-75 JPN-97-037, Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated1997-12-0101 December 1997 Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated ML20148M6471997-06-19019 June 1997 Comment Opposing Porposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems ML20133N0511997-01-0505 January 1997 Comment Opposing Proposed Rule 10CFR50, Draft Policy Statement on Resturcturing & Economic Deregulation of Electric Util Industry ML20149M4621996-12-0909 December 1996 Comment Opposing Proposed Rule 10CFR50 Re Draft Policy Statement on Restructuring & Economic Deregulation of Electric Utility Industry ML20077G3481994-12-0808 December 1994 Comment on Proposed Rule 10CFR2,51 & 54 Re Nuclear Power License Renewal ML20070P0561994-04-19019 April 1994 Comment Supporting Proposed Rule 10CFR50 Re NRC Draft Policy Statement on Use of Decommissioning Trust Funds Before Decommissioning Plan Approval ML20029C5771994-03-11011 March 1994 Comment on Proposed Rule 10CFR20 Re Draft Rule on Decommissioning.Informs That 15 Mrem/Yr Unreasonably Low Fraction of Icrp,Ncrp & Regulatory Public Dose Limit of 100 Mrem/Yr ML20059C3031993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Definition of Commercial Grade Item ML20045H8751993-07-19019 July 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule ML20045F2451993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria ML20044F5681993-05-20020 May 1993 Comment on Draft Commercial Grade Dedication Insp Procedure 38703,entitled Commercial Grade Procurement Insp. Endorses NUMARC Comments Dtd 930517 JPN-02-034, Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl1992-07-0606 July 1992 Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants1991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants JPN-91-005, Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended1991-01-28028 January 1991 Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended ML20066G4411991-01-23023 January 1991 Comments on Proposed Rule 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Substantive Typo in 901015 Filing on Behalf of Licensee Noted ML20058G6341990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty Program JPN-90-068, Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS1990-10-22022 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20065H7541990-10-15015 October 1990 Comment Re Proposed Rules 10CFR2,50 & 54 on Nuclear Power Plant License Renewal.Commission Assessment of Four Alternatives Should Be Expanded to Include Not Only Safety Considerations But Other Atomic Energy Act Objectives JPN-90-067, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC1990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR1990-07-0909 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR JPN-90-050, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary ML20012C6491990-03-0909 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against PTS Events. Any Utilization of NRC Proposed Application of Reg Guide 1.99, Rev 2,would Be Inappropriate W/O re-evaluation by NRC ML20005F6521989-12-13013 December 1989 Comment on Proposed Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Concurs w/industry-wide Position Presented by NUMARC & Offers Addl Comments ML20246P6061989-07-0707 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Significant & Independent Industry Efforts Already Underway to Address Issue ML20245K1941989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235V9011989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Supports NUMARC Position.Proposed Rule Will Hinder Important Initiatives to Improve Maint JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments ML20205L8521988-10-21021 October 1988 Comment Opposing Proposed Rule 10CFR20 Re Cleaning or Disposing of Nuclear Waste.Incineration of Radwaste Oil Should Not Be Allowed JPN-88-015, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site1988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site JPN-88-002, Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed1988-01-25025 January 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed JPN-87-062, Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex1987-12-31031 December 1987 Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex JPN-87-053, Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection1987-10-15015 October 1987 Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl ML20235Y9911987-07-20020 July 1987 Notice of Issuance of Director'S Decision Under 10CFR2.206 Re Emergency Planning for School Children in Vicinity of Indian Point.* Request to Suspend OLs Denied ML20151C5061987-02-18018 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20093H6421984-10-15015 October 1984 Comments on Staff Presentation at Commission 841002 Meeting. Commission Should Conclude Proceedings Due to Inescapable Conclusion That Facility Safe to Operate & Poses No Undue Risk to Public.Certificate of Svc Encl ML20098D2721984-09-26026 September 1984 Comments on Commission 840905 Meeting Re Facilities,Per Sj Chilk 840911 Memo.Licensee Agrees W/Staff That Further Mitigative Features or Plant Shutdown Unnecessary Due to Low Risk.Certificate of Svc Encl 1999-09-20
[Table view] Category:PLEADINGS
MONTHYEARML20212E4181999-09-15015 September 1999 Petition Per 10CFR2.206 Requesting OL for Unit 2 Be Modified or Suspended to Prevent Restart Until Reasonable Assurance That Licensee in Substantial Compliance with Terms of OL & Has Proper Consideration for Public Health & Safety ML20094J7571984-08-13013 August 1984 Responses to 840730 Unpublished Order Directing NRC & Inviting Other Parties to Submit Views on Judge Gleason Dissent Re ASLB Recommendation Concerning Accident Probability.Certificate of Svc Encl ML20094J8781984-08-13013 August 1984 Response to Commission 840730 Order Permitting Comments from Parties Re Chairman Gleason Dissent to ASLB Recommendations to Commission.Certificate of Svc Encl ML20094J8971984-08-13013 August 1984 Comments on ASLB Chairman Gleason Dissent in Recommendations of Special Proceeding.Significant Risk Reduction Already Accomplished at Facility.Certificate of Svc Encl ML20084J8521984-05-0404 May 1984 Response Opposing New York Pirg (Nypirg) Petition for Suspension of Operation.Nypirg Fosters Discord Which Inhibits Coordination of Emergency Planning Efforts. Certificate of Svc Encl ML20088A4711984-04-0606 April 1984 Petition for Suspension of Operation to Relieve Unacceptable Risk to Area School Children.Issue of Emergency Planning for Schools Must Be Resolved.Certificate of Svc Encl ML20024C3731983-07-0707 July 1983 Memorandum Opposing Pirg of New York Motion for Reconsideration of Commission 830610 Order.Pirg Should Not Be Permitted to Relitigate Arguments Fully Considered & Ruled Upon by Commission ML20024C3761983-07-0707 July 1983 Response Opposing Pirg of New York Motion for Reconsideration of Commission 830610 Order.Motion Untimely, Identifies No Matters of Fact or Law & Improperly Raises New Issues.Certificate of Svc Encl ML20072E8211983-06-23023 June 1983 Response Supporting Pirg of Ny Motion for Reconsideration of Commission 830609 Decision,Permitting Facility Operation W/O Restriction Despite Continued Noncompliance W/Emergency Planning Requirements.Certificate of Svc Encl ML20072D6241983-06-22022 June 1983 Motion for Immediate Reconsideration of Commission 830610 Order CLI-83-16 Permitting Continued Plant Operation. Commission Did Not Consider Current Status of Emergency Planning in Decision.Certificate of Svc Encl ML20072H5781983-06-22022 June 1983 Request 2-wk Extension to File Findings of Fact for Commission Questions 3 & 4.Atty Familiar W/Case Resigned ML20072E8241983-06-22022 June 1983 Answer Opposing Intervenor Motion for Extension of Time to Submit Proposed Findings.Motion Is Attempt to Delay Hearings.If Intervenor Motion Granted,Exemption Should Apply to All Parties.Certificate of Svc Encl ML20072D6291983-06-21021 June 1983 Motion for Extension Until 830711 to File Proposed Findings of Fact.Time Needed Since Intervenors Filing Consolidated Findings & One Atty Suffered Death in Family. Certificate of Svc Encl ML20071P3111983-06-0303 June 1983 Response Opposing Friends of the Earth/New York City Audubon Soc Request to File I Levi Affidavit.Testimony by Affidavit Improper Since No cross-examination Possible.Certificate of Svc Encl ML20071L5421983-05-24024 May 1983 Response Opposing Licensee Motion for Reconsideration of ASLB Denial of Licensee Motion to Admit Dp McGuire Testimony Before Trial ML20023D9341983-05-20020 May 1983 Response Opposing Util 830509 Motion for Reconsideration. Deposition Inadmissible as Evidence Under Federal Rules ML20071G9761983-05-20020 May 1983 Motion for Leave to Submit Written Comments on NRC 830505 Order to Suspend Facility Operations.Deficiencies Determined to Be Significant by FEMA Are Not Sufficiently Deficient to Require Suspending Operations ML20023D0941983-05-13013 May 1983 Motion for Opportunity to Address Issues Outlined in Commission 830505 Order CLI-83-11 Establishing Procedures for Decision on Enforcement Action.Intervenor Entitled to Participate as Matter of Right.Certificate of Svc Encl ML20074A4541983-05-11011 May 1983 Motion for Extension of Deadline (to 830615) for Filing Corrections to Transcripts & Deadline (to 830624) for Filing Comments.Certificate of Svc Encl ML20074A4461983-05-0909 May 1983 Motion for Reconsideration of Ruling Denying Licensee Motion to Receive Dp McGuire Deposition Transcript Into Evidence. Licensees Entitled to Place Deposition in Record. Certificate of Svc Encl ML20073S8781983-05-0909 May 1983 Motion for Opportunity to Address Issues Outlined in Commission 830505 Order CLI-83-11,establishing Procedures for Decision on Enforcement Action on Emergency Planning Issues.Certificate of Svc Encl ML20073S8801983-05-0606 May 1983 Motion for Extension of Deadline Until 830627 for All Parties to Submit Proposed Opinion,Findings of Fact & Recommendations Re Enforcement Action on Emergency Planning Issues.Certificate of Svc Encl ML20204G2681983-04-27027 April 1983 Motion to Amend Svc List to Add Sp Wasserman & Delete P Chessin,Lr Schwartz & M Oppel.Notice of Appearance & Certificate of Svc Encl ML20073R3471983-04-26026 April 1983 Motion Requesting Initiation of Studies on Human Response to Radiological Emergencies,Risks to Individuals Living Near Site & Difficulty of Evacuation in Emergency ML20073R3531983-04-25025 April 1983 Motion Requesting Completeness of Record on NRC Questions 3 & 4 Re Emergency Planning Issues,Including Capability for Handling Phone Calls in Emergency Planning Zone During Emergency ML20069L1181983-04-22022 April 1983 Motion to Strike Selected Intervenor Testimony Re 830309 Emergency Exercise.Testimony Cumulative,Repetitive, Conclusory,Lacks Adequate Foundation & Irrelevant. Certificate of Svc Encl.Related Correspondence ML20069L2131983-04-22022 April 1983 Motion for Admission Into Evidence of EPZ Tour Documents, Exhibits CE-11,CE-11A & CE-11B ML20204G3251983-04-22022 April 1983 Motion to Strike Portions of 830309 Emergency Drill Testimony Under Commission Questions 3 & 4 Filed by Witnesses for Various Intervenors.Certificate of Svc Encl.Related Correspondence ML20069K6031983-04-20020 April 1983 Motion to Compel Deposition of FEMA Witnesses P Mcintire, J Keller,R Kowieski & RW Krimm & to Preclude Witnesses from Presenting Testimony at 830426-29 Hearings Outside Scope of 830309 Exercise.W/Certificate of Svc ML20073G0351983-04-12012 April 1983 Motion for Approval of Encl Stipulation Re Intervenor Observation of 830309 Radiological Preparedness Exercise ML20073G1271983-04-12012 April 1983 Motion for Extension to Submit Testimony on Contention 6.2. Expert Witnesses a Stewart,B Brazelton & D Bohning Will Not Be Able to Testify Until Late May 1983.Findings of Fact Should Be Due 10 Days After Testimony.W/Certificate of Svc ML20073G1461983-04-11011 April 1983 Further Response in Opposition to Licensee 830407 Motion to Impose Sanctions.Motion Unrelated to Discovery.Draft Testimony Privilege Not Waived by Submitting Testimony Early.Certificate of Svc Encl ML20073B7361983-04-0707 April 1983 Further Suppl to Motion to Impose Sanctions on Greater New York Council on Energy.Komanoff Comments on Study & Aug-Sept 1982 Version of Study Must Be Produced.Use of Oct 1982 Study Should Be Precluded.W/Certificate of Svc ML20073L6361983-04-0707 April 1983 Further Suppl to Motion to Impose Sanctions on Greater New York Council on Energy,D Corren & Energy Sys Research Group, Inc.Depositions & Ltr Support Conclusions of Intentional Frustration of Util Discovery Rights.W/Certificate of Svc ML20072R7441983-04-0101 April 1983 Response to New York Pirg 830329 Motion for Order Requiring Production of Documents Re 830309 Emergency Planning Exercise.Exercise Evaluations Sought Should Be Regarded as Privileged.Certificate of Svc Encl ML20073C6581983-04-0101 April 1983 Motion for Submission,Under Commission Question 5,of Bl Cohen 830124 Testimony on Commission Question 1.ASLB Refused to Admit Testimony Under Question 1 But Testimony Is Relevant to Question 5.Certificate of Svc Encl ML20072N2641983-03-25025 March 1983 Response Opposing Licensee Motion for Sanctions Against D Corren,Greater New York Council on Energy & Esrg,Inc. Council Did Not Intentionally Withhold Discoverable Matls. Clarifies Misunderstandings.Certificate of Svc Encl ML20069H5671983-03-24024 March 1983 Response to Licensee Motion to Compel Under Commission Question 6.Resources Unavailable to Develop Study on Health Effects.Parents Concerned About Indian Point Does Not Bear Burden of Proof.W/Certificate of Svc.Related Correspondence ML20072K0991983-03-23023 March 1983 Suppl to Motion to Impose Sanctions Against D Corren,Greater Ny Council on Energy & Energy Sys Research Group,Inc for Failure to Produce Oct 1982 Study, Economics of Closing Indian Point Nuclear Power Plants. Related Correspondence ML20072L4521983-03-21021 March 1983 Motion to Strike Portions of Testimony of Some Rockland County Witnesses on Questions 3 & 4.Testimony Conclusory & W/O Supporting Factual Basis.Foundation Does Not Exist for Factual Matl Introduction.Certificate of Svc Encl ML20069F5191983-03-18018 March 1983 Motion for Time to Present Evidence Re 830309 Radiological Emergency Response Planning Exercise.Presentation Needed to Complete Record.Certificate of Svc Encl ML20069F4861983-03-17017 March 1983 Motion to Impose Sanctions Against D Corren & R Rosen of Greater Ny Council on Energy & Energy Sys Research Group,Inc for Failure to Respond to Interrogatories.Certificate of Svc Encl ML20069B8281983-03-14014 March 1983 Motion to Strike Certain Intervenor Prefiled Testimony Under Commission Questions 3 & 4 Re Emergency Planning Filed on 830311.Licensees Denied Any Meaningful Right to Discovery from Witnesses.Certificate of Svc Encl ML20069D0141983-03-14014 March 1983 Response Opposing Licensee Motion to Compel Greater Ny Council on Energy Further Response to Interrogatories.Motion Inappropriate & Unnecessary.Interrogatories Were Unclear & Burdensome.Certificate of Svc Encl ML20069C9481983-03-14014 March 1983 Answer Opposing PASNY Motion to Strike KT Erikson Testimony. Testimony Relevant to Contentions 3.2 & 3.7 & Is Based on Erikson Personal Knowledge ML20069D0871983-03-14014 March 1983 Motion for Waiver of Requirement to Distribute Indian Point 3 Emergency Plan & Emergency Planning Implementation Procedures Document to All Parties.Plans Are Voluminous & Expensive to Produce ML20069D1441983-03-14014 March 1983 Motion to Compel West Branch Conservation Assoc & Parents Concerned About Indian Point Further Responses to Licensee First Set of Interrogatories Under Commission Question 6.W/ Certificate of Svc.Related Correspondence ML20069D0491983-03-14014 March 1983 Motion to Strike Selected Intervenor Testimony.Objects to Intervenor 830311 Witness List for Commission Questions 3 & 4,presenting 99 Witnesses in 5 Days.Testimony Is Cumulative, Conclusory,Hearsay or W/O Foundation.W/Certificate of Svc ML20071F0001983-03-11011 March 1983 Motion to Amend Svc List to Include AP O'Rourke,New Westchester County Executive.Certificate of Svc Encl ML20071E5321983-03-0909 March 1983 Response Opposing Intervenor 830228 Motion for Extension of Deadlines to Complete Record on Emergency Planning Issues in Commission Questions 3 & 4.ASLB Resolved Scheduling Question.Certificate of Svc Encl 1999-09-15
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM4ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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- CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos. 50-247 SP j (Indian Point Unit 2) ) 50-286 SP z
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POWER AUTHORITY OF THE STATE OF NEW YGRK )
(Indian Point Unit 3) ) April 26 , 1983 i
i AFFIDAVIT OP KAI T. ERIKSON AND AIBERT J. SOINIT IN SUPPORT OF UNION OF ENCERNED SCIENTISTS, NEW YORK PUBLIC INTEREST RESEARCH GROI;P, AND PARENTS CONCERNED ABOUT INDIAN POIhT l
l l
State of Cbnnecticut Cbunty of IkN Haven I,
Kai T. Erikson, Ph. D.
Professor of Sociology and American Studies, and Editor, Yale Review Yale University and I, e Albert J. $ 1 nit, M.D.
Sterling Professor of Pediatrics and Psychiatry, and Director, Child Study Center Yale University being duly sworn, state the followirg:
8305030641 830419 gDRADOCK 05000247 PDR EXHIBIT A
page 2
- 1. During March 1983, each of us separately appeared, gave testimony, and was cross-exantined before the Atmic Safety and Licensing Board on behalf of Parents Concerned About Indian Point, the New York Public Interest Besearch Group, and the Union of Cbncerned Scientists, intervenors in the ASIB's special investigation of Indian Point.
- 2. Each of us has read portions of the Indian _ Point Padiological Dnergency Besponse Plan (RERP), the public information booklet, " Indian Point Dnergency Planning and You," ard testimony and transcripts of cross-examination of sme other witnesses in the ASIB proceeding (including the direct testmeny and the cross-examinaticn of Drs. Russell Dynes and Sidney Iecker, witnesses for the licensees).
- 3. Each of us is aware of proposed revisions to the Westchester RERP which would result in setool children being subject to "early dismissal" instead of evacuation to reception centers outside the 10-mile Dnergency Planning Zone (EPZ) in the event of an accident at Indian Point.
- 4. It is apparent to each of us that the develognent and evaluation of off-site mergency plans for Indian Point has rested largely on theories and assumptions about h m an response to emergencies which, though applicable in part, do not provide a sufficient basis for predicting how the people arourd Indian Point are likely to respoM to a radiological accident at the plant-nor, therefore, for concluding that the plans will work as designed,
- 5. Indian Point mergency planners assume (1) that residents of the 10-mile EPZ will respond in prescribed and prelictable ways to instructions issued prior to and during a nuclear mergency, (2) that local officials and mergency personnel will fulfill the roles assigned to the in the plans,
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and (3) that people living or working outside the 10-mile EPZ will res nd r I
amw iately r to ad hoc reassurances and instructions and will not omplicate i or inpede energency procedures for those closer to the plant.
- 6. Proponents of the "early dismissal" plan for school children assume i (1) that sending children hme during a radiological emergency is equivalent -
to releasing then during a snowstorm or when a school heating system breaks !
down, (2) that rapid notification of responsible adults (parents or pre-designated surrogates) for each and every child is possible, (3) that a
) sufficient nunber of school buses can be rounded up at a moment's notice l
l during school hours, end (4) that, whetter by bus or on foot, all school children will arrive hme quickly, safely, and to a waiting adult.
! 7. Existing emergency plans have been based primarily on observation of human behavior in non-radiological energencies, remote in time and place 1
- fran Indian Point. It is the judgenent of each of us that such data are ,
j relevant and applicable only in part, and cannot form a sufficient basis for
}
predicting how residents, officials, and energency personnel in the region surrounding Indian Point are likely to respond during a radiological energency.
- 8. 'Ihough there are sme similarities among different sorts of l emergencies, each is in sme respects different frm others. Studies of ;
the accident at 'Ihree Mile Island, for example, indicare that a large proportion of the affected population behaved in ways that could not have been predicted fran a knowledge of the entire literature on non-nuclear disasters.
- 9. Each of us believes that there is ample reason to expect that the t
people at risk will respond to an accident at Indian Point in unique ways, L _ _ _ _ _ _ _ _ _ _ _ _ - - -
1 page 4 influenced by site-specific, regional characteristics such as the nature of the local terrain, the ret. work of local roads, th: populaticr. density, etc.
- 10. 'Ihough the existing body of non-nuclear disaster literature can provide theories and leads, only studies of the persons now living within the region at risk frun Indian Point can supply the data needed to test the theories and predict the range of responses likely to occur to an accident at the plant. 'Ibese studies can be designed in such a way as to elicit, anong other things, information about how respondents have reacted to and behaved during other emergencies they may have experienced in the past.
- 11. No one research method is empletely reliable for predicting future behavior. When forecasting human response, a prudent behavioral scientist will gather and make use of all relevant and available information:
extrapolation of past trends and experience taken in conjunction with data collected by means of sophisticated survey and interview techniques.
- 12. 'Ihe techrology of survey research-including statistical sampling, interviewing, and cmputer analysis-has been highly developed over four decades of acadmic research and ccmnercial application. The success and value of this technology is generally recognized and routinely utilized by government, acadmia, the press, and business-including the nuclear power industry. Cbn Fdison and the Power Authority have th mselves ocmnissioned and made use tf several sample surveys.
- 13. It is the professional judgment of each of us, therefore, that a series of survey and interview stulies should be performed in the region potentially affected by an accident at Indian Point in order, first, to test the validity of mergency planning assuuptions, and second, to provide
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the site-specific information essential for realistic energency planning.
Irvka, it is the view of each of us that mergency planning for Indian Point should have begun with such studies, and that adequate and workable j plans cannot be attained until a proper human response data base exists.
- 14. In the absence of the data such studies would provide, each of us subnits that there does not now exist a proper or valid basis for concluding that the Indian Point emergency plans are " adequate to prctect public health'and safety."
- 15. Brief descriptions of the studies each of us believes to be necessary follow:
I. A survey of the information, attitudes, and inter 31ons of residents of the region, including but not limited
! to the 10-mile EPZ. 'Ihis stix 3y should include the kinds
! of questions asked in the Suffolk (bunty survey, the
> Westchester Cbunty survey conducted by Richard Altschuler, and parts of the survey done by Yankelovich, Skelly and
- White in June 1981. One major objective would be to j predict the proportion of people,at various distances up to 50 or nore miles frm the plant, who would attempt to evacuate spontaneously under various circurstances.
II. A survey of the information, attitudes, and intentions of the sergency workers, including bus and ambulance drivers, both those living within the 10-mile EPZ and those who live outside but who are expected to partici-pate in an evacuation. This study should focus on the issue of whether they can and will fulfill the roles assigned to them in the plans, and possible obstacles
! to such participation. 'Ibe principal obstacle to be assessed would be the belief of sme that their primary and overriding obligatien is to the safety of their own families. Other factors to be explored would be their i
awareness of the availability of necessary training, l equignent, vehicles, monitoring devices, and the like.
1 1
III. A three-part study relevant to planning for the evacuation of school children. The first, attitudinal part, would study parents, teachers, and school administrators to ascertain their information, attitudes and beliefs regarding school evacuation to help predict their behavior in and l
1 i
page 6 preference for alternative plans: (a) to dimiss scnool children at the alert stage of an accident, (b) to evacuate chileiren direc:tly frm schools to reception centers, (c) to be prepared to htpleent either of the preceding plans depending on the courw of the accident, or (d) other possibilities which may merge frcm suggestions nvxle by the respondents out of their detailed knowledge of the concrete probles involved.
> 'Ihe second part of the school study would be a derographic
! study of households containing children focused on obtain-i ing factual data of the following kinds: (a) the nature of the fcmily situation during school hours (adult at hee or I
at work; where parents may he contacted and how; availability
! of relative or neigd or willing and able to take charge; car at hme or not; marbers of family outside EPZ whose
, childre attend school inside EPZ, and vice versa), (b) how i
the children termally get hme (walk, bas, other), and (c) how many children in each family attend which schools and
! knowledge of designated rel#caticn centers.
'Ihe third part of the study should include (a) a review of the actual past experience of each school in early dismissal situations, and (b) a feasibility test in a representative
> sample of schools to determi.~2 how many parents (or their surrogates) can be contacted without advance warning during j
a school day, and how long it takes to do so.
Eps in pediatrics, child develo; rent, and other relevant professions should be utilized at every step--in the design and implementation of the
( research, in the interpretation and reporting of the results, and in the l
ultimate application of the finds) to emergency plans for the schools.
n
- 16. It is the conclusion of each of us that until the above studies are conducted, the Atmic Safety and Licensing Board and the Nuclear Regulatory Chmiission lack a sufficient basis to determine either the workability of the Indian Point Radiological Dnergency Besponse Plan cr the adequacy at any given time of preparedness to protect the public in case of an accident at Indian Point.
0 ~
i j
' I<ai T. Erikson 1
{ Subscribed and Sworn to i *e before me this /Mday of April, 1983. ~ ~Alber1;]J."Solnit w AJL,A l i" 1 * ? % te m s
i AFFIDAVIT l STATE OF NEW YORK )
) SS:
COUNTY OF NEW YORK)
I
- 1. I, Robert R. Holt, first being duly sWrn, depose and say: I am Professor of Psychology at New York University; ray specialittes are i
clinical and social psychology. Before obtaining my Ph.D in psychology at Harvard University, I worked as an interviewer for the Ilmo Roper organizaticn and briefly ran a small independent polling organization, the New England Public Opinion Research Association. $ first post-Ph.D.
job was as a Study Director in the Division of Program Surveys, B. A. E.,
f in the U.S. Department of Agriculture (for ray publications in this field, i
! see Nos. 2, 6, and 25 in my bibliography, attached). After World War II, I learned clinical psychology at the Menninger Foundation in Topeka, Kansas, where I subsequently became Director of the Psychological Staff.
Since 1953, I have beer. at New York University, where I founded the i Research Center for Mental Health, and directed it for about fifteen years. A principal theme of ray scientific work has been the prediction of hutaan behavior, on which I have published several papers and a book, Methods in Clinical Psychology, Vol. II: Prediction and Research, New York: Plenura (1978). During recent years, I have renewed my interest in ,
survey research. $ 1980 paper (no.118 in bibliography) reports results i
I :
EXHIBIT B
prge 2 of a national survey done in collaboration with Daniel Yankelovich, for whose firm I have been a consultant concerning several other surveys.
- 2. My recent work has also brought me to the study of stress (see no.123 in my bibliography). I participated in the discussion of ;
psychological stress in the vicinity of the Three Mile Island nuclear power plants, held by the MITRE Corporation in McLean, Virginia, and was f asked to prapare a commentary on that discussion presenting my theory of i the impact of radiological accidents on psychological health. This !
commentary was submitted to the Nuclear Regulatory Commission and appears !
j in NUREG/CP-0026 (no.122 in bibliography). I also made a thorough study i of the relevant research on human response to the TMI accident, and most !
t
- recetly was invited to present a survey of that material at the .
International Forum on Nuclear Energy in Middletown, Pa., March 28-30, 1983.
! 3. I make this affidavit at the request of the Union of Concerned Scientists and the New York Public Interest Research Group Inc., to j
- comaent on the utility of sample surveys as means of predicting human behavior in general, and of predicting the responses of people to an l l
I accident at Indian Point in particular. I have been given to read the
- testimony presented in this proceeding on these subjects by Drs. Lecker and Dynes.
- 4. Surveys typically collect several types of data:
a) factual information that can be directly reported (for example, "Have you received an information brochure about l t
Indian Point?");
i l
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I page 3 b) knowledge possessed by the respondent, indicating his or her degree of acquaintance with relevant data (for example, "What are you supposed to do if you hear a siren warning of an accident at Indian Point?");
c) beliefs (for example, "Have you received a dangerous dose of radiation?");
d) attitudes (for example, "How much trust do you have in statements about ndClear power made by Con Edison?");
e) values (for example, "Which is more important, a man's duty to his job, or to his family?");
f) statements of intention (for example, "What do you plan to do to prepare your family for a possible evacuation of this area?"); and, g) stateuents of probable future behavior under hypothetical circumstances (for example, "What would you do if there were an accident at Indian Point and people within 5 miles were advised to stay indoors with windows shut?")
- 5. It should be evident that no sharp dividing lines can be drawn between these classes of questions, or the kinds of data they provide.
Moreover, tne aoove listing is not exhaustive or definitive. My point is to illustrate some of the many kinds of data that can be obtained from surveys, and to suggest some of the different ways in which they are useful in a scientific attempt to predict behavior.
- 6. Consider the issue of greatest interest, behavior at the time of a possible accident serious enough to require the evacuation of a given I