ML20069D087

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

ML20069D087
Person / Time
Site:	Indian Point
Issue date:	03/14/1983
From:	Morgan C MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8303180245
Download: ML20069D087 (4)

Text

r-t l

e ^?l_:n,;E

- T E ?

UNITED STATES OF AMERICA '83 MR 17 N0 :54 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARDgj g,(f".,

Before Administrative Judges: .Hu Ncq James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris

---

x In the Matter of ) Docket Nos.

50-247 SP CONSOLIDATED EDISON COMPANY OF NEW YORK, ) 50-286 SP INC. (Indian Point, Unit No. 2)

) -March 14, 1983 POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit No. 3) )

---

x POWER AUTHORITY'S MOTION FOR WAIVER OF EXHIBIT DISTRIBUTION ATTORNEYS FILING THIS DOCUMENT:

Charles Morgan, Jr.

Paul F. Colarulli Joseph J. Levin, Jr.

MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.

Washington, D. C. 20036 i (202) 466-7000 l

8303180245 830314 PDR ADDCK 05000247 G PDR

Preliminary Statement Power Authority of the State of New York (" Power Authority"), licensee of Indian Point 3 Nuclear Power Plant, hereby moves for an order waiving the requirement of 10 CPR S 2.743(f) for distribution of copies to each party of the Indian Point 3 Emergency Plan and Emergency Planning Imple-mentation Procedures Document (collectively the "on-site plans").

Request for Waiver 10 CFR S 2.743(f) requires a party to furnish each other party with a copy of any written exhibit offered into evidence, unless "the presiding officer directs otherwise."

In connection with the testimony to be presented by the Power Authority's on-site emergency planning panel (John C. Brons, Linda Lomonaco.:;and Dennis Quinn), we presently intend to of-fer the on-site plans into evidence as exhibits.

The on-site plans are bulky, voluminous documents several hundred pages in total length. The furnishing of a i

copy for each party would be extremely expensive and does not appear to be necessary. A waiver of S 2.743(f) is appro-priate for these reasons. The Power Authority further notes that these documents are on file with the Commission as pub-i i

O 1

e  :

lic documents, and were produced for all parties at licen-sees ' document production on June 1, 1982.

In lieu of now furnishing a copy to each party, the Power Authority proposes to furnish one copy to each Board member, to the reporter, and to each table of parties when the on-site panel is presented. In addition, the Power Authority would make a copy available for inspection by ap-pointment at the offices of counsel, Shea & Gould, New York, New York.

Finally, we note that certain information, princi-pally names . of individuals and confidential telephone numbers, will be redacted for security reasons in all furnished copies of the on-site plans.

i F

t

\

Respectfully submitted, j s CharlesMorgan,Jr.g Paul F. Colarulli Joseph J. Levin, Jr.

MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.

Washington, D.C. 20036 (202) 466-7000 Stephen L. Baum General Counsel Charles M. Pratt Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D. Fischman Michael Curley Richard F. Czaja David H. Pikus SHEA & GOULD 330 Madison Avenue New York, New York 10017 l (212) 370-8000 l

l Dated: March 14, 1983 l

l