ML20052D151

Interrogatories Directed to Utils Re Commission Order, Questions 3 & 4 Re Radiological Emergency Response Plan. Certificate of Svc Encl.Related Correspondence

ML20052D151
Person / Time
Site:	Indian Point
Issue date:	04/29/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8205060316
Download: ML20052D151 (10)

Text

--

REIATED COmpogy r

. UNITED STATES OF AMERICA -:ggiE?

^

NUCLEAR REGULATORY COMMISSION '5?:7 l

ATOMIC SAFETY AND LICENSING BOARD g7 Eg -3 P2 s o -

Before Administrative Judges:

Louis 3. Carter, Chairman -

1.

@L _

g~q Frederick 3. Shon ... l'_r l Dr. Oscar H. Paris l

i' In the Matter of ) ,

) l CONSOLIDATED 2DISON COMPANY OF ) l NEW YORK, INC. (Indian Point, )

. Unit No. 2) s } Docket Nos. 50-247-SP

) 50-286-SP POWER AUTHORITY OF THE STATE OF ) .

I 19, April 29, 1982 ,

NEW YORK, (Indian Point, )

Unit No.-3)

) N -

N' -

) o. mqY

, scc' + }

[? , n, G " J ;( --

INTERROGATORY TO THE LICENSEES FROM c- *

'e WEST BRANCH CONSERVATION ASSOCIATION - s. ,

[ -

m?y Attached are interrogatories covering Questionso ltN(6; 7 3 and 4 of the Commission's Order, addressed to the two licensees. Kindly reply either singly or as one but we are unable to divide the questions.  !

"Rockland Co.unty RERP' in the text stands for l

Radiological Emergency Response Plan. " General emer-gency'is as described in Appendix 1 of NUREG-0654,  !

t

~ ~~

Rev. 1, pages 1-16 through 1-19.

l submitted for We t gn servation Association by Q. S. Fleisher, Secretary 3 443 Buena Vista Road ~

$)ScD f New City, N.Y. 10956  :

914/634-2327 7 8205060316 820429  ;

PDR ADOCK 05000247  :

G PDR *

- I

50-247-SP, 50-286-SP WBCA INTERROGATORY

} WBCA-3.2-1 What provisions have been made in the Rockland County RERP to make it safe for operating per-sonnel to remain in the generating station at Lovett? and at Bowline? during a " general emer-gency"? Please answer for a 2 mile evacuation, a 5 mile evacuation and a 10 mile evacuation.

WBCA-3.2-2 Up to what level of radiation exposure will the employees be allowed in order to maintain opera-tion? Who will make the decisioniin the RERP?

Have you the informed consent of the employees who are expected to remain at Indian Point?

If so, please supply a consent form sample or the text of any letters of agreement.

What percent of the employees needed on the site during an emergency have signed agreements? Are there enough such employees on all shifts to con-tinue operation of the plants at Indian Point?

WBCA-3.2-3 What onsite provisions are there to decontaminate i emergency personnel at Lovett and Bowline?

Have they dosimeters or film badges?

L WBCA-3.2-4 '

l l Have the above described emergency personnel re-l ceived Radiological Emergency Response training?

If so, to what level of training? On what date or dates? For O&R'statio,ns? For Indian Point?

l

WBCA-3.2-5 o

Please reply to 3.2-2 above as applied to emergency personnel expected to remain in Indian Point #2 and #3  !

generating stations during a " general emergency."

WBCA-3.2-6 Ref er to NUREG-0654,Rev.1, page 35 Evaluation Criteria

2. Are employees of the licensees informed and have they given consent to the extent that a full comple-ment of shift workers is available at all times?

If not, how will such volunteers who have consented reach the plant to assist in an emergency? Within what time frame can a full complement be assembled?

Can each licensee meet the requirements of Table B-1 on pages 37 and 38 of NUREG-0654,Rev.l?

If not, in what numbers are each short?

WBCA-3.3-1 Please provide methodology used to arrive at Tables A-4, A-5, A-6 and A-7 on pages A-67, A-68, A-69 and A-70 in Rockland County'RERP. Copies of working pa?ers to show what populations are assumed and for what situ-ations. List " operational strategies" referred to in footnote (1) below each of the tables.

WBCA-3.3-2 Kindly provide total population estimated to be in Rockland County within the 10 mile EPZ.

l In Rockland County RERP Appendix G please designate l which sectors' zones were used to define the boun-dary of Rockland County.

l i

i l'.-_.-__ - - . . -.-.

o UBCA-3.9-1 What studies were made of road evacuation routes and characteristics as shown in EUREG-0654,Rev.1, pages 4-15 and 16, Tables 1 and 2 for Rockland?

What studies were made for the above under different weather conditions such as 1, rain; 2, snow; 3, ice and 4, f og'on Rockland's evacuation routes ?

Show if studies did or not include width of roads, shoulder conditions, room for disabled vehicles to pull over, crest down center of road.

Which roads were actually traveled?

Why are the road names in the brochure not correct where road names change? Were all directions in the brochure checked for correct names? For correct turns?

Please explain why there are errors on the brochure map for southern Rockland within the EPZ.

How was the capacity determined for each road?

Were any field counting stndies made during commu-ting hours? 7-8:30 AM? 5-7 PM? If so,.please list where, under what conditions and on what dates.

How was capacity integrated with population and road characteristics :within the EPZ?

WBCA-4.3-1 Please list the most difficult to solve patterns and the roads involved. Those that were the least amen-able to their burden, from 1, the worst, through 10 and relate if they vary in difficulty on a 1-10 scale.

i l

• I At what locations is there potential for serious congestion? Is it due to road configuration? Due to the amount of vehicles using the road? Or both? -

Please explain.

WBCA-4.4-1 Please supply a copy of each emergency assistance l

card sent to the "Four County Nuclear Safety Com-

. mittee from the brochures by residents of Rockland County.

WBCA-4.4-2 Did you determine how many uheelchair users there 10 mile are in Rockland'saEPZ? If so, what number did you determine and how did you arrive at it?

WBCA-4.4-3 The Rocklar.d County RERP page Trl 24 lists Helen Hayes Hospital. The new building is now open, the lower line of occupants applies. Only 14 are ambu-latory. The vehicles shown are insufficient to move f the patients. Please provide a corrected figure f and explain from where the transportation might be j i expected. '

l WBCA-4.4-4 i The Rockland County REPP page Tr1 20 lists Camp  :

Jowonio. It has 350 students at a session. 70 are f 1

in wheelchairs, 35 in crutches or braces, 245 are ambulatory but slow. Its bus capacity totals 18 l

wheelchairs. .How will the wheelchairs be moved c in the event of a general emergency?

x

( .

WBCA-4.4-5 What transportation plans are there for citizens who are permanently disabled and who live at home?

WBCA-4.4-6 What is the length of time used to determine the ability to move a uheelchair patient into a van?

WBCA-4.4-7 Much of the PLm expects to provide several trips to and from one location to evacuate the disabled, or even the school population. How will buses be i

able to return to the assigned pick-up place on l roads clogged with evacuees?

How have you determined the use of police and sheriffs to cover all these tasks? What numbers?

WBCA-4.4-8

, Before the National Guard can be of assistance it I

will have to be mobilized and moved. These guards-men may be otherwise occupied. In a " general emer-gency" how could they be mobilized in sufficient time to assist the police and sheriffs? What calcu-lations were made to determine when they could be on the scene and in what numbers? Please supply data.

WBCA-4.4-9 Please provide text of questionnaire used by door-I to-door survey teams in Rockland County preparatory

any opinion study. How many homes or apartments j were visited where interviews were completed?

4 Please provide totals or tallies of results of replies to the questions asked.

WBCA - 4.4-10 How many buses did Red and Tan Lines offer for an evacuation of the ten mile EPZ in Rockland?

How many school buses would be needed for a worst case emergency of a plume passing through Rockland County 10 mile EPZ?

What is the total number of buses that would be needed from outside the 10 mile EPZ in a worst case emergency?

How many drivers of school buses do you count on being available if a general emergency is declared during a week-day during working hours, 8 AM - 6 PM7 Absent letters of ag?eement with drivers how do you expect to rely on their willingness to cooperate?

What survey did you make of drivers' attitudes?

If any, please supply dates, numbers of drivers interviewed and responses.

WBCA-4.4-11 How many accidents or illnesses have you figured would occur on the roads during a " general emer-1 gency" that would require ambulance service.

)

Per hour? Per sector? Would ambulances be avail-able if the mode was to be moving the sick and l 1

those " dependent on others for their mobility"?

l

- 7-m? "

~

~

. WBCA-4.7-1 ,

4 Why wasn't the brochure printed in Spanish to be provided to the more than 6,000 Spanish speaking residents within the Rockland County 10 mile EPZ?

How much would it cost for 2,000 copies? What is the total printing bill for the present brochure for four counties?

What mailing list was used for the brochure's dis-tribution? Have you any estimate of how many resi-dents within the 10 mile EPZ were missed?

WBCA-4.7-2 Describe the structure of the "Four County Nuclear Safety Committee". How often has it met in 1980, 1981 and 1982? Who are its officers? How were they elected? How many people from each of the four counties are on.the Committee? Is there a' Board of Directors? If so, how many are on it and how are they elected? Who may speak for it? By what grant of authority? Is it incorporated? If so, where?

Respectfully submitted, b

Zipporah S. Fleisher copies to parties list Secretary

~ .

=

UNITED STA-"ES OF AMERICA g . .

NUCLEAR REGULATORY COME1ISSION C C: n.- r .

i ATOMIC SAFETY AND LICENSING BOARD "'

1 Administrative 3udges:

• gp W -3 pg q9 Louis 3. Carter, Chairman Dr. Oscar H. Paris E - A yr Frederick 3. Shon "N.: . dy ,j;

. .. n In the Matter of CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit 2) 50-236-SP POWER' AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3) ___ .

CERTIFICATE OF SERVICE I hereby certify that I have placed in the U. S. mails, l first class, a copy to all parties listed below, of the Interrogatory to the Licensees and of WBCA Reply to PASNY's Notice of Appeal to Granting Intervention...of April 19,1982 on this 30th of April, 1982.

Docketing and Service Branch Brent L. Brandenburg, Esq.

Office of the Secretary . Assistant General Counsel U.S. Nuclear Regulatory Commission Consolidated Edison Company of New York,Inc.

Washington, DC 20555 vmg Pla Y 10003 Janice E. Moore, Esq.

Henry 3. McGurren, Esq. Paul F. Colarulli, Esq.

NRC Staff Counsel 3 seph J. Levin, Jr., Esq.

Office of the Executive Legal Director Pamela 5. horowitz, Esq.

U.S. Nuclear Regulatory Commission Charles Morgan, Jr., Esq.

Washington, DC 20555 M rgan Associates., Chartered 1899 L Street, N.W.

Louis 3. Carter, Esq., Chairman Washington, DC 20036 Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq.

7300 City Line Avenue mas R. Frey, Esq.

Philadelphia, Pa. 19151

' **# ^" # *Y ** **** I **

10 Columbus Circle Dr. Oscar M Paris New York, NY 10019 Administrative Judge .

Atomic Safety and Licensing Board Ellyn R. Weis, Esq.

U.S. Nuclear Regulatory Commission William S. Jordan, III, Esq. -

Washington, DC 20555 Harmon & Weiss 1725 I Street, N.W., Suite 506 Mr. Frederick 3. Shon Washington, DC 20006 Administrative Judge Atomic Safety and Licensing Board Joan Holt, Proj.ect Director U.S. Nuclear Regulatory Commission Indian Point Project Washington, DC 20555 New York Fublic Interest Research Group .

5 Beekman Street >

New York, NY 10038 t .

. Greater New York Council on Encrgy -

• '**' c/o Dcan R. Corren, Direc ce John Gilroy, Westchest:;r Coordinator Ncw York University g Indian Point Project 26 Stuyvesant Street l New York Public Interest Research Group New York, NY 10003

( 240 Central Avenue White Plains, NY 10606 Atomic Safety and Licensing Boarc Panel l

U.S. Nuclear Regulatory Commission Jeffrey M. Blum, Esq. Washington, DC 20535 New York University Law School " " ASL Appeal Board Panel 423 Vanderbilt Hall Pat Posner, Spokesperson 40 Washington Square South Parents Concerned About Indian Point New York, NY 10012 P. O. Box 125 Charles 3. Malkish, Esq.

Litigation Division Charles A. Scheiner, Co-Chairperson Port Authority of New York and New Jersey Westchester People's Action Coalition, Inc.

One World Trade Center p,o,gax 433 New York, NY 10043 White Plains, NY 10602 Alfed B. DelBello Alan Latman, Esq.

Westchester County Executive 44 Sunset Drive Westchester County Croton-on-Hucson, NY 10520 148 Martine Avenue White Plains, NY 10601 Lorna Salzman Mid-Atlantic Representative Ezra I. Bjalik, Esq.

, Friends of the Earth, Inc.

Steve Leipsiz, Esq. . 208 West 13th Street Environmental Protection Bureau New York, NY 10011

~

New York State Attorney General Two World Trade Center New York, NY 10047 Judith Kessler Rockland Citizens for Safe Energy Renee Schwartz, Esq. P. O. Box 74 Botein, Hays, Sklar & Herzberg New City, NY 10956 Attorneys for Metropolitan Transportation Auth. Mayor Gg V. Be'v 200 Park Avenue Village of Buchanan New York, NY 101066 236 Tate Avenue Buchanan, NY 10511 Stanley B. Klimberg General Counsel Fion. Richard Brod' sky New York State Energy Office County Legislature Agency Building #2 County Office Building Empire State Plaza White Plains, N.Y. 10601 Albany, NY 12223 .

andrew S. Roffe, Esq.

Honorable Ruth Messinger N. Y. State Assembly A any, N.Y. 12248 f Member of the Council of the-City of New York .

8 ty H !

Ms. Amanda Potterfield, Esq.

New York, NY 10007 _.

hi ia St tion Marc L. Parris, Esq. , Eric Thorsen,Esq, New York, New York 10014 County Attornev County of Rockiand David H. Pikus ,Esq. , Richard Czaja, Esg 11 New Hemps.ead Road 330 Madison Avenue New City, NY 10956 New York, N.Y. 10017 Geoffrey Cobb Ryan by Zipporah S. Fleisher i

Conservation Committee Chairman, Director Secretary New '(ork City Auducon Society 71 West 23rd Street, Suite 1323 New York, NY 10010