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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:OTHER LEGAL DOCUMENT
MONTHYEARML20155F4561998-08-26026 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 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 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 ML20098E6531984-09-25025 September 1984 Comments on Staff 840905 Briefing Re Pra.Ucs Requests Decision on Proceeding.Certificate of Svc Encl ML20094P5421984-08-13013 August 1984 Comments on Dissenting Views of Chairman Gleason Re Safety of Plant Mods.Certificate of Svc Encl ML20091P6521984-06-0909 June 1984 Suppl to Joint 840406 Petition for Immediate Suspension of Operation ML20087P8641984-04-0101 April 1984 Addl Attachment to 840204 Comments on ASLB Recommendations to Commission.Testimony on Encl Attachment G Reveals Emergency Planning Transportation Woefully Lacking & Grossly Inadequate ML20080D5401984-02-0606 February 1984 Comments on ASLB 831024 Recommendations to Commission Re Emergency Planning,Plant Risk & Comparative Risk.Continued Operation Recommended.Certificate of Svc Encl ML20080B7871984-02-0606 February 1984 Comments on ASLB Recommendations Re Facilities.Commission Urged to Focus on Fact That Serious Release Would Be Catastrophe of Far Greater Dimensions than Event at Any Other Sites.Certificate of Svc Encl ML20080C5581984-02-0606 February 1984 Addition to Parents Concerned About Indian Point 840202 Comments on ASLB Recommendations ML20086L3351984-02-0404 February 1984 Comments on ASLB Recommendations to Commission.Aslb Improperly Placed Burden of Persuasion on Plant Opponents, Failed to Conduct Thorough Investigation & Failed to Conform Conclusions W/Findings of Fact ML20086L0591984-02-0202 February 1984 Comments on ASLB Recommendations for Evacuating School Children ML20080B4071984-02-0202 February 1984 Comments Responding to ASLB 831024 Recommendations to Commission Re Safety Issues.Commissioners Invited to Attend Next Emergency Response Drill ML20080C5421984-02-0202 February 1984 Comments on Recommendations of ASLB Re Continued Operation of Facility While Problems Util Should Correct Remain Unresolved or Inconclusive.Aslb Urged to Admit go-home Plan Leaves Major Problems W/Protection of School Children ML20080H1761984-01-30030 January 1984 Response to ASLB 831024 Recommendation to Commission ML20072D6981983-06-20020 June 1983 Response to Pj Amico to ASLB & Analysis of PRA Testimony.Areas in Which Addl Testimony Recommended Do Not Present Issues Materially Affecting Record & Are Too Costly.W/Certificate of Svc ML20024A0831983-06-10010 June 1983 Response to ASLB Consultant,Pj Amico,830502 Ltr Re Issues on Accident Probability Requiring Addl Testimony.New York City Audubon Soc/Friends of the Earth Comments Endorsed. Certificate of Svc Encl ML20071Q9081983-06-0808 June 1983 Recommendations for Emergency Planning Process.Plans Should Originate at Local Govt Level & Should Be Supported & Enforced at State & Federal Govt Levels ML20071Q9191983-06-0808 June 1983 Statement on Role of Federal,State & Local Govts & Utils in Planning,Testing & Executing Emergency Response Procedures ML20072A0711983-06-0808 June 1983 Statement Before House of Representatives Subcommittee on Energy Conservation & Power Re Emergency Planning.Public Must Be Involved in Planning & Testing Process ML20071H3631983-05-23023 May 1983 Submission Addressing Commission 830505 Order on Possible Facility Closing.Requests Oral Presentation on 830526 Re Economic Inpact of Facility Shutdown.Economic Impact Is Not Compelling Reason for Continued Operation ML20071H2031983-05-23023 May 1983 Submission Re Commission 830505 Order CLI-83-11.Emergency Planning Must Be Well Developed & Detailed W/Special Emphasis on Health & Safety of Children ML20071H1981983-05-23023 May 1983 Comments on Commission Order CLI-83-11 Establishing Procedures for Decision on Enforcement Action.Emergency Planning Deficiencies Fundamental.Adequate Interim Compensating Measures Impossible.Certificate of Svc Encl ML20071H4861983-05-21021 May 1983 Submission Re Commission 830505 Order on Intention to Shut Down Facility on 830609 If Emergency Preparedness Problems Not Resolved.Adequate Protective Action in Case of Radiological Emergency Cannot Be Guaranteed by 830609 ML20071H1541983-05-20020 May 1983 Views Re Radiological Emergency Planning in Response to Commission 830505 Order.Fema & NRC Should Rule That Plants No Longer Have Significant Deficiencies Based on Improvement & Interim Compensating Actions ML20071H1601983-05-20020 May 1983 Opinion on NRC 830505 Order Re FEMA Rept on Licensee Emergency Planning & Preparedness & Possible Suspension of Plant Operations.Immediate Shutdown Urged ML20071H0181983-05-20020 May 1983 Response to Commission 830505 Order Establishing Procedures for Decision on Enforcement Action.Emergency Planning Deficiencies Not Significant.Nrc Enforcement Action Unwarranted & Improper.W/Certificate of Svc ML20071H1761983-05-16016 May 1983 Citizens Advisory Committee Progress Repts Re Nuclear Evacuation & General Disaster Preparedness Plan ML20069K6221983-04-21021 April 1983 Notice of 830425 Deposition in New City,Ny Re 830309 Emergency Planning Exercise.Certificate of Svc Encl.Related Correspondence ML20069K6131983-04-21021 April 1983 Notice of K Toscani,K Felt & L Culpepper 830422 Depositions in Croton-on-Hudson,NY Re 830309 Emergency Planning Exercise.Related Correspondence ML20073M8971983-04-15015 April 1983 Notice of 830421 Deposition of FEMA Witnesses P Mcintire,J Keller & R Koweiski by Licensees in New York,Ny.Certificate of Svc Encl.Related Correspondence ML20073H4621983-04-12012 April 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20072J9821983-03-22022 March 1983 Notice of DA Schlissel 830413 Deposition in New York,Ny Re Testimony Under Commission Question 6.Related Correspondence ML20072J9921983-03-22022 March 1983 Notice of Deposition of V Taylor & All Other Witnesses Testifying on Behalf of Ucs/Pirg of Ny & Greater Ny Counsil on Energy on Commission Question 6,in New York,Ny.Related Correspondence ML20072K0001983-03-22022 March 1983 Notice of Deposition of Witnesses Testifying on Behalf of NRC on Commission Question 6.Certificate of Svc Encl.Related Correspondence ML20072J9711983-03-22022 March 1983 Notice of B Commoner & R Schrader 830324 Deposition in New York,Ny Re Testimony Under Commission Question 6.Related Correspondence ML20072J9621983-03-22022 March 1983 Notice of 830330 Deposition of R Rosen & Other Witnesses Testifying on Behalf of Greater Ny Counsil on Energy on Commission Question 6,in New York,Ny.Related Correspondence ML20072K0111983-03-22022 March 1983 Notice of Deposition of All Persons Testifying for Parents Concerned About Indian Point on Commission Question 6. Certificate of Svc Encl.Related Correspondence ML20072G4191983-03-21021 March 1983 Cross-examination Plan for Wk Commencing 830322.County Will cross-examine D Davidoff Representing Ny State & Parsons, Brinckerhoff,Quade & Douglas Representing Licensees. Affidavit of Svc Encl ML20069F5951983-03-18018 March 1983 Proposed Order of Testimony.Affidavit of Svc Encl.Related Correspondence ML20069C8221983-03-14014 March 1983 Forwards Intervenor Refined Witness List for Commission Questions 3 & 4 for Presentation on 830315-18 & 22.List Does Not Include Witnesses Subj to Stipulation by Licensees & NRC ML20071F0231983-03-11011 March 1983 Intervenors Joint List of Witnesses to Be Presented on 830315-18 & 22 Re Commission Questions 3 & 4 ML20071E4451983-03-0808 March 1983 Notice of Appearance in Proceeding ML20071D2781983-03-0303 March 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20072B6791983-03-0101 March 1983 Notice of F Rowsome,R Blond & Other Unidentified Witnesses Deposition Re Testimony on Commission Question 5.Certificate of Svc Encl ML20072B6561983-03-0101 March 1983 Notice of Sholly & Other Unidentified Witnesses Deposition Re Testimony on Commission Question 5.Certificate of Svc Encl ML20072B7791983-02-28028 February 1983 Memorandum Re Scheduling of Testimony on Commission Questions 3 & 4 ML20071C4171983-02-25025 February 1983 Notice of Meshnick 830226 Desposition in New York,Ny Re Testimony on Commission Questions 3 & 4.Certificate of Svc Encl ML20071C4101983-02-25025 February 1983 Notice of D Gurin,J Friedman & R Mccarthy 830228 Deposition in New York,Ny Re Testimony on Commission Questions 3 & 4. Related Correspondence 1998-08-26
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMt1ISSIOli .-r -
ny ATOMIC SAFETY AND LICENSIrlG BOARD --
Before Administrative Judges:
Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H. Paris
x In the Matter of :
CONSOLIDATED EDISO!! COMPANY OF Docket Nos. 50-247 SP NEW YORK, INC. (Indian Point, : 50-286 SP Unit No. 2)
POWER AUTHORITY OF Ti!E STATE OF June 14, 1982 flew YORK, (Indian Point, :
Unit tio. 3)
x CONSOLIDATED EDISOtD'S CROSS EXAMI!1ATION PLANS FOR PROPOSED WITNESSES OF COUNTY OF ROCKLAND, NRC STAFF, FEMA, AND STATE OF NEW YORK REGARDING ISSUES RELATED TO COMMISSION QUESTIONS 3 and 4 ATTORNEY FILING THIS DOCUMENT:
Brent L. Brandenburg
{)$O g CONSOLIDATED EDISON COMPAt1Y OF NEW YORK, INC.
4 Irving Place tiew York, New York 10003 (212) 460-4333 8206180257 820614 PDR C
ADOCK 05000247 PDR
. I
. s-CONSOLIDATED EDISON'S CROSS EXAMINATION PLANS FOR PROPOSED WITNESSES OF COUNTY OF ROCKLAND, NRC -
STAFF, FEMA, AND STATE OF NEW YORK REGARDING ISSUES RELATED TO COMMISSION QUESTIONS 3 and 4 INTRODUCTION Pursuant to this Board's April 23, 1982 Order (p.22)
Consolidated Edison (Con Edison), Licensee of Indian Point, Unit No. 2, hereby submits its cross examination plans for 1
the captioned witnesses in this proceeding . While this filing represents Con Edison's current expectations regarding the areas into which it may inquire at the upcoming hearings, it is ob-viously impossible to foresee what course the cross examination by ourselves, the Power Authority, the other parties and the Board will take. Accordingly, Con Edison reserves the right to conduct additional cross examination beyond that indicated in the filed plans should such examination be warranted in our judgment by subsequent events.
- 1. The remaining intervenors in this case, Union of Concerned 3cientists, New York Public Interest Research Group (UCS/NYPIRG),
Rockland Citizens for Safe Energy (RCSE), Parents Concerned About Indian Point, West Branch Conservation Association (WBCA), West-chester People's Action Coalition, Inc.(WESPAC), and Friends of the Earth /New York City Audubon Society (FOE /Audubon), and one participant pursuant to 10CFR S2.715(c), the Attorney General of the State of New York, have collectively filed 157 separate pieces of proposed " testimony" which they apparently seriously intended to introduce as evidence in this proceeding regarding Commission Questions 3 and 4. In addition, they seek leave of this Board for the untimely filing of the testimony of an addi-tional 14 witnesses. These submissions are addressee' in a separate joint motion of Con Edison and the Power Auenority of the State of New York, Licensee of Indian Point, Unit No. 3 for an order striking the proferred testimony, dated June 14, 1982.
Pending the Board 's ruling on that motion, Con Edison is not presently submitting cross examination plans dealing with any of the submissions referred to supra.
Further, the filing of these plans in no way consti-tutes a concession on the part of Con Edison that any of the
filed testimony is admissible in evidence, and we reserve the right to make any objections availaole to us with regard to proferred testimony or any part thereof, including the right to make motions to strike all or any portion of each document sought to be offered as evidence by any party.
SUBJECT MATTER OF EXPECTED CROSS EXAMINATION OF ROCKLAND COUNTY WITNESSES
- 1. Professional Qualifications.
a) Experience b) Education N c) Training d) Process by which testimony was prepared e) Other
- 2. Knowledge of special conditions in Rockland County referred to in testimony.
- 3. Familiarity with New York State and Rockland County radiological emergency plans and revisions thereto.
a) Familiarity with process by which these plans were' developed and Rockland County's participation in that process.
- 4. Knowledge of Rockland County's plans and generic capabi-lities for response to emergencies, including arrangements under Article 2-B of the Executive Law.
- 5. Knowledge of Rockland County's radiological emergency pre-paredness capabilities.
- 6. Knowledge of Rockland County residents who would be transit dependent in the event of an emergency evacuation.
- 7. Knowledge of NRC and State emergency preparedness criteria.
A
- g. _ - _ . . _
- 8. Knowledge of evacuation time estimates for Rockland County and assumptions on which they are based.
a) Basis for opinions that evacuation time estimates are incorrect or inaccurate.
- 9. Knowledge of behavioral response of emergency personnel during emergencies.
- 10. Documents, studies, etc., upon which witness' testimony is based.
- 11. Clarification of certain portions of testimony which may be unclear.
SUBJECT MATTER OF EXPECTED CROSS EXAMINATION OF NRC AND FEMA
- 1. Clarification of certain portions of testimony which may.
be unclear.
- 2. Basis for identification by FEMA of alleged deficiencies in State and County emergency plans.
- 3. Discussions with State emergency preparedness officials regarding resolution of alleged deficiencies in State and County emergency plans. .
- 4. Uniformity of application of emergency response criteria from region to region and site to site.
SUBJECT MATTER OF EXPECTED CROSS EXAMINATION OF STATE OF NEW YORK WITNESSES l
- 1. Clarification of certain portions of testimony which may be unclear.
- 2. Discussions with FEMA officials regarding resolution of alleged deficiencies in State and County emergency plans.
l .
~ ~ ~
- y*
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/ , .
e Pf' ' i
- 3. Comparison of State and County emergency response capabi-lities prior and subsequent to. promulgation and interpre- '
tation of new NRC/ FEMA emergency planning criteria.
- 4. Participation in . emergency planning exercises at other. New -
York nuclear facilities.
Respectfully submitted, Brent L.' Brandenburg g
i ' ,
~
r
. CONSOLIDATED EDISON COMPANY-
' OF NEW YORK, INC. f, Licensee.Of Indian Point /
Unit 2 4 Irving Place
' New York, New York 10003 J (212) 460-4333 -
. l -
1 i
. ./. -
Of Counsel, 'I
. Stephen M. Schinki, Dated: t{ew York, Ne'W York June 14, 1982 4
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UNITED STATES OF AMERICA
>g NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon .,
x CONSOLIDATED EDISON COMPANY OF : Docket Nos. 50-247-SP N EW YORK , INC. (Indian Point, 50-286-SP Unit No. 2) :
POWER AUTHORITY OF THE STATE OF :
NEW YORK, (Indian Point, Unit.No. 3) :
x CERTIFICATE OF SERVICE I certify that I have served copies of " Consolidated Edison's Cross; Examination Plans For Proposed Witnesses of County Of Rockland, NRC Staff, FEMA, And State of New York Regarding Issues Related to Commission Questions 3 and 4", -
on the following parties b'y deposit in the United States mail, postage prepaid, this 14th day of June, 1982.
Docketing and Service Branch Dr. Oscar H. Paris Office of-the Secre'tary Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commis'sion Board Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Louis J. Carter, Esq., Chairman Washington, D. C. 20555 Administrative Judge Atomic Safety and Licensing Mr. Frederick J. Shon Board Administrativ'e Judge 7300 City Line Avenue - Suite 120 Atomic Safety and Licensing Philadelphia, Pennsylvania 19151 Board
. U.S. Nuclear Regulatory Commission Washington,.D. C. 20555
I e .
Janice !!oore, Esq. Charles J. Maikish, Esq.
Office of the Executive Litigation Division 1 Legal Director The Port Authority of U.S. Nuclear Regulatory New York and New Jersey Commission One World Trade Center Washington, D. C. 20555 New York, New York 10048 Paul F. Colarulli, Esq. Ezra I. Bialik, Esq.
Joseph J. Levin, Jr., Esq. Steve Leipsiz, Esq.
Pamela S. Horowitz, Esq. New York State Attorney Charles Morgan, Jr., Esq. General's Office Morgan Associates, Chartered Two World Trade Center 1899 L Street, N.W. New York, New York 10047 Washington, D. C. 20036 Alfred B. Del Bello Charles M. Pratt, Esq. Westchester County Executive Thomas R. Frey, Esq. 148 !!artine Avenue ,
Power Authority of the State White Plains, New York 10601 of New York 10 Columbus Circle Andrew S. Roffe, Esq.
New York, New York 10019 New York State Assembly Albany, New York 12248 Ellyn R. Weiss, Esq.
William S. Jordan, III, Esq. Renee Schwartz, Esq.
Harmon & Weiss Paul Chessin, Esq.
1725 I Street, N.W., Suite 506 Laurens R. Schwartz, Esq.
Washington, D. C. 20006 Botein, Hays, Sklar & Herzberg 200 Park Avenue Joan Holt, Project Director New York, New York 10166 Indian Point Project New York Public Interest Stanley B. Klimberg Research Group New York State Energy Office 9 flurray Street 2 Rockefeller State Plaza New York, New York 10007 Albany, New York 12223 John Gilroy, Westchester Ruth !!essinger Coordinator Member of the Council of the Indian Point Project City of New York New York Public Interest District #4 Research Group City Hall 240 Central Avenue New York, New York 10007 White Plains, New York 10606
!! arc L. Parris, Esq.
Jeffrey M. Blum County Attorney New York University Law School County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road Washington Square South New City, New York 10010 New York, New York 10012
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Joan Miles Alan Latman, Esq.
- Indian Point Coordinator 44 Sunsent Drive
Lorna Salzman -
Greater New York Council on Friends of the Earth, Inc.
Energy - -
208 West 13th Street c/o Dean R. Corren, Director New York, New York '10011 New York University 26 Stuyvesant Street Zipporah S. Fleisher New York, New York 10003 West Branch Conservation Association Atomic Safety and Licensing 443 Buena Vista Road Board Panel New City, New York 10956 U.S. Nuclear Regulatory Commission Mayor F. Webster Pierce Washington, D. C. 20555 Village of Buchanan 236 Tate Avenue Atomic Safety and Licensing Buchanan, New York 10511 Appeal Board Panel U.S. Nuclear Regulatory Judith Kessler, Coordinator Commission Rockland Citizens for Safe Washington, D. C. 20555 Energy 300 New Hempstead Road Richard L. Brodsky New City, New York 10956 Member of the County Legislature Westchester County David H. Pikus, Esq.
County Office Building Richard F. Czaja, Esq.
White Plains, New York 10601 330 Madison Avenue New York, New York 10017 Pat Posner, Spokesman Parents Concerned About Amanda Potterfield, Esq.
Indian Point Box 384 P.O. Box 125 Village Station Croton-on-Hudson, New York 10520 New York, New York 10038 Charles A. Scheiner, Co-Chairperson Ruthanne G. Miller, Esq.
Westchester People 's Action Atomic Safety and Licensing Coalition, Inc. . Board Panel P.O. Box 488 U.S. Nuclear Regulatory White Plains, New York 10602 Commission Washington, D. C. 20555 Dated: June 14, 1582 New York, New York N
ThhdasJ. FarrpIly
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