ML20003C157
| ML20003C157 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 02/17/1981 |
| From: | Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP |
| To: | Cole R, Lazo R, Luebke E Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20003C158 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8102260723 | |
| Download: ML20003C157 (1) | |
Text
. . _ _ _. ._______ _
BMATED CCRRESPONDEMO-
}f GROU% E1\ ROP w ,,
49l.nJDY.g GROUP
- ff*
G S
Judge Robert Lazo Dr. Emmeth: Luebke fG 2 3 Jgg} .,po$ket Nos. 50-369-OL Dr. Richard Cole 9 u.umu, , ,C- 50-370 Atomic Safety and Licensi. BoaiS& m a ,,,g/
4 A Gentlemen: 9 Please find enclosed the maaor part of the technical testimony which CESG will present in regard to contentions 1 and 2.
l In several areas CESG has been unable to find witnesses free from conflicts of interest: employment by the NRC or nuclear utilities, employment by public agencies such as hospitals.
Academic people are disinclined to testify in view of the pervasive role of the Applicant in local educational facilities.
CESG will therefore request from this Board subpoenas for such qualified witnesses. We will, at an appropriate time, present material relating to the area of testimony of the witness and a list of the questions to be asked in direct examination.
We will by this means present evidence in the areas of human factors, stress and physiological response, the determination of levels of risk, cognitive dissonance, and operational problems in the nuclear industry.
We anticipate having Dr. Ernest Sternglass as a witness in regard to infant mortalities attributable to releases during the TMI accident; Dr. Jan Beyea regarding the use of potassium iodide ina radiological emergency; and M. Rockestroh in regard to the atmospheric behavior of aerosols. We will also seek to enter an account of the emergency evacuation of Missasauga by Fire Chief Bentley.
This filing, on February 17, is later than the February 13 filing ordered by the Board. Duke provided its final round of discovery at 5:50 PM on February 13 The Board had not specified a last date for filing discovery responses. 3.A..Sendia National Laboratory report on work commissioned by the M d2"under, cover of l
RobertTedesco'sletterofFebruary11,wasreceithdby, mail' CESG requests that the Board, find'thii I^*
midday February lk. ' ' "'
- filing aceptable in view of the circumstances.
Res ectfully bmitted, g nocKETED cc: service list J sse g7/. Riley, reside useC L. FEB 191981 P og.ce et the W go Dochsti"E &#
~ , 3 {3L- C) 8fh #
81022607.13: -
y T
854 HENLCY PLACE CHARLOTTE NORTH CAROLINA 98907 - (704) 375-4349