ML20052D155

Ucs/Ny Pirg First Set of Interrogatories & Request for Production of Documents Directed to Con Ed & PASNY

ML20052D155
Person / Time
Site:	Indian Point
Issue date:	04/28/1982
From:	Blum J, Holt J, Potterfield A PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
EP, ISSUANCES-SP, RS, NUDOCS 8205060319
Download: ML20052D155 (19)

Text

- -

-

• UNITED STATES OF AERICA NUCLEAR REGULATORY COMISSION

'CcqET BEFORE THE ATOMIC SAFETY AND LICENSING BOARD p py ._5 pa :rn In the Matter of )

) l CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos.<50'-247iSRo (Indian Point Unit 2) C 50'-286 SP Q f/

dpril28,']982' 3'

POWER AUTHORITY OF THE STATE OF NEW YORK >a -

(Indian Point Unit 3) , -

,u ,l d1982 r b f {llShn ,

UCS/NYPIRG FIRST SETF OF INTERROGMORIES AND REQUEST ICR PRODUCTICN T

'IO CCE.EDISCN AND PASNY

'Ihe New York Public Interest Research Group /tJnion of Ocncerned Scientists (NYPIIE/DCS) serves on Con Edison and PASNY the interrogatories and requests for production of h=mts that appear below. A sworn respuuse to them must

, be provided to NYPIIG/DCS in accordance with the terms of 10 TR Section

2.740(b) and 2.741(d) and in accordance with the Board's order of April 23, 1982. If the answer to any question is not known when the response is filed, the answer nust be provided as soon as the missing information Mn== available.

As used in the interrogatories and request for producticn of h=nts, the follcwing definitions apply as indicated:

1. " Con Edison and PASNY" means Otm Edison, PAShY, their officers, agents, s playees, and consultants.

2. " Facts," include the calculational or other asstmptions, if any, underlying various assertions of fact. " Including" and " include," as used in these interrogatories, mean " including but not limite:I to."

2 95033 8205060319 820428 PDR ADOCK 05000247 [ (/

C PDR

. . .o r

l

3. " Document" or "doctments," mean any handwritten, typed, printed, recorded or graphic matter however produced or reprM v,M, including t

material stored for use in autmatic data processing systerm, whether or not in the possession, custody or control of PASNY and/or Con Edison and whether or not claimed to be privileged against discovery on any ground including: reports; records; lists; m moranda; correspondence; telegrams; schedules; photographs; sound recordings; films; hand, machine and atmputer calculations; cmputer codes; data; and written statments of witnesses or other persons having knowledge of the facts.

4. " Studies or observations," incitrie physical, ertpirical, calculational, asstmptional, and other types of work, whether recorded in writing or not.

Please provide answers to the following questions:

1.) Identify all-individual (s), that you intend to present as witnesses in this proceeding on the subject matter of any of the order's questions.

The identification should ii:alude the following:

a. What is the person's full name?

b. What is the person's address?

c. What is the person's present or last known position and business i affiliation?

d. What is the person's field of expertise?

c. On what date did Con Edison and/or PASNY first contact or consult the person? -

4

f. W at are the dates of all subsequent contacts or consultations with the person?

g. Were any reports made to (bn Edison and/or PASNY try the person?

h. If the answer to question lg is anything other than a sinple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written or oral; and (3) whether the report was subnitted by the person while acting in an advisory capacity, as a prospective witness, or both.

i. Miat is the subject matter of the witness' testimony?

j. Miat are the facts and/or opinions to which the witness will testify and the grounds for eadt fact or opinion?

2.) Provide a reasonable descriptim of all th-nts that will be relied upon in the testimony presented by each witness.

3.) Identify by author, title, date of publication and publisher,

, all books, documents, and papers you intend at this time to employ or rely upon in conducting your cross-exanination of prospective NYPIIE/UCS witnesses testifying in connection with NYPIIE/DCS cmtentict.s.

4.) Is it Con Edison and/or PASNY's position that the carbined off-site mergency plans of the licensees, local and state officials are required to be in full cxmpliance with the emergency planning measures set forth in 10 CFR 50, Appendix E and 10 CFR 50.47 whidt W= effective on Novenber ,

3,1980, including each of the criteria set forth in NUREG-0654, Rev.  !

1, dated November 1980 in order for the Indian Point plants to operate?

S.) If the answer to 4 is anything other than a sinple affirmative, list each requirement of the regulations which is not applicable and, for ea&, provide ead study, observatim, or h=nts whid Con Edison and/

or PASNY rely on to support that conclusion.

6.) Do(es) Con Edison and/or PASNY contend that the cmbined off-site mergency plans of the licensees, local, and state officials are now in full conpliance with the emergency planning measures set forth in 10 CFR 50, Appendix E, and 10 CTR 50.47 which W- effective on November 3,1980, including ead of the criteria set forth in NURBG-0654, Rev.1, dated November 19807 7.) If the answer to 6 is a sinple affirmative, provide ead study, observation, or h = nt which Con Edison and/or PASNY rely on to support this conclusion including copies of the relevant licensee, local, and state mergency plans.

8. ). If the answer to 6 is anything other than a single affirmative, list ead requirment of the regulations which is not currently emplied with, and for ea&, provide each study, observation, or h-nts whid Con Edison and/or PASNY rely on to support this conclusion.

9.) For each of the requirements listed in 8, provide a s&edule which sets forth the date when (bn Edison and/or PASNY believe the non-ompliance will be corrected.

10.) Is it the position of Con Edison and/or PASNY that the ten-mile (radius) EPZ for the pitme exposure pathway is appropriate for Indian Point?

11.) If the answer to lois a sinple affirmative, provide each site-specific and generic site study, observation, or doc ment on which Con Fdiscm and/or PASNY rely to support this conclusion with regard to the following considerations:

a. Demography

b. Meteorology

c. Terugdry

d. Land use characteristics l

e. Access routes

f. Iocal jurisdictional boundaries

g. Release time characteristics 12.) If the answer to 101s anything other than a sinple affirmative, provide the dimensions and a detailed diagram and description of the plume exposure pathway EPZ that Cbn Edison and/or PASNY believe is appropriate for Indian Point.

13.) For the plune exposure EPZ set forth in12, provide each site-specific and generic site study, observation, or docunent which PASNY and/or Con Edison relies on to support this conclusion, with regard to the following considerations:

4

a. Demography

. b. Meteorology

c. Topography

d. Land use characteristics

e. Access routes

f. Local jurisdictional boundaries

g. Rt. lease time characteristics 14.) Does Con Edison and/or PASNY contend that a 50-mile (radius) ingestion pathway EPZ is appropriate for' Indian Point?

15.) If the answer to 14 is a sinple affirmative, provide each site-specific and generic site study, observaticn, or docunent which PASNY and/or Cbn Edison rely on to support this conclusion, including all of the preceding which address

the following:

a. Daivy@y

b. Meteorology

c. 'Ibpography

d. Land use characteristics

e. Time of year of release 16.) If the answer to 14 is anything other than a sinple affirmative, provide the dimensions and a detailed diagran and description of the ingestion pathway EPZ that Con Edison and/or PASNY believe is appropriate for Indian Point.

17.) For the ingestion pathway ::PZ set forth in 16, provide eadi site-specific or generic site study, observation, or docment which Con Edison and/or PASNY rely on to support this conclusion, including all of the preceding which address the following: ,

a Dmograpliy

b. Meteorology

c. Topography

d. Iand characteristics

c. Time of year of release 18.) With regard to the responses provided by Con Edison and/or PASNY to the above fourteen interrogatories who are the persons, if any, on whose opinicms and/

or knowledge of facts Con Edison and/or PASNY

a. now relies; and

b. expects to rely during the Indian Point hearings?

l t

. . -7_

Following the stbstantive response to eacts of the stbsequent interrogatories posed by NYPIRG/DCS, identify all h_mwmts ard sevWs relied upon by you in providing the answers to that inter-togatory. 'Ihe identificaticn should be specific to the portion of the h=nt or study relied upon. Studies shall include observations, calculatims, literature and other types of work, whether recorded in writing or not, which consist of an examination or mialysis of a phenmencm.

I Following the substantive response to each of the subsequeat interrogatories posed by NYPIBG/UCS, identify by name and affiliation each individual who has knowledge which served as the basis for the ,

answer to that interrogatory. ,

19.) Miat letters of mgetsient, other than those listed in the August,1981 versicm of the plans, have been obtained frm indiviaula and organizaticns, both public and private, assigned duties in the plans?

20.) Have any other methods been used to determine the willingness and ability of the above-nentioned indiviamla and organizaticmJ to participate as outlined in the plans? If so, please specify l the methods and the full extent of their application.

21.) What criteria will be used for determining the most efficient and most productive use (in terms of protecting the public health and safety) of available services and resources should such services and resources W wholly or partially unavailable or should such services and resources be inadequate to respond to a parHrmlar emergency situation?

I 22.) Have resources reocamended and available ever been tabulated ,

against any specific hypothetical accident consequence scenario to

detemine adequacy? If not, how were resource baselines detemined?

23) Has any study been done of phone <=eity in the EPZ to detemine the likelihood of phone overload during a massive emergency?

24.) Wat percent of the population within the 10-mile EPZ would require mass care?

25.) mat percent of the population within the 10-mile EPZ is in some way handicapped (i.e. blind, chaf, mentany inpaired, enotionany inpaired, or physically inpaired)? How were these figures determined?

26. . ) Nhat percent of the at-risk population is axn English speaking?

27.) mat arrangements have been made for notifying and ocumunicating with the non-English speaking sector of the population?

28.) Has the pronpt notificaticn system, including all tone alerts, been fully installed, tested and determined adequate?

29. . ) Have " deaf spots" in the above system been identified?

30. . ) If the answer to the above questions is yes, how will these deaf spots be covered? Has it been determined how many personnel win be required to acocmplish caplete notification of this sector?

31. ) List the significant equipnent and the staffing to be in place in the 'Ibchnical Support Center and the Emergency Operations Feility during an emergency. Wich of this equipnent and staffing win be in place before an emergency?

32.) mat has been dcne to inprove the achinistration of the cm-site cmergency preparedness program since Boyce Grier's (Director, NIC <

Hegion 1) August 21, 1981 letter caning such achinistration ineffective?

33.) How have the on-site emergency facilities been otherwise upgraded since the above-menticned letter?

34.) Wat protection is available for emergency workers in order for those workers to safely perform accident assessments and other activities which require direct exposure to radiation?

1 1

35.) ht study has been ckne of the sheltering capabilities of buildings within the pime EPZ? Specifically, what analysis was done of the sheltering factor of the structures at Ossining State Prison in order to determine the pitclusion of evacuation under any cire mstances?

36.) What methods, if any, for permanent record-keeping of emergency response personnel radiation exposures have been developed?

37.) Describe the deomtaminaticn facilities available. Where are they? Ikw are they presently equipped?

38.) Identify the transportation resources available to transport irradiated and contaminated persons to appropriate medical or decon-taminaticn facilities. Have agreenents been made with the drivers of the vehicles that are to carry such omtaminated individuals?

39.) ht is the method to be enployed for periodically estimating the total populaticm exposure to radiaticn during an emergency?

40.) Are there any objective criteria upon which to base decisions regarding the return of the general public to areas affected by a nuclear _ power" plant accident'at Indiah Polht?

41.) ht provisicns are there for updating evacuation time estimates to accomt for new construction, long-term unavailability of major routes dm to repair work, changes in the population, etc?

42.) State whether any protective gear has been purchased to protect National Guardsmen and other emergency persmnel in the event of an

! cmergency.

c e, , -

1

43.) Provide an accurate estimate of the population of all livestock in the ten, twenty, and fifty mile radius of Indian Point, providing the population for eadi major species of livestock. Describe in detail the source of the data used in ccupiling six:h estimates. Provide an estimate of the econcxnic value of the above livestock.

44.) Describe in detail the process relied upon by licensee in ocm-puting the probability of any given accident sequence. Provide detailed and thorough justificaticn for this computatimal method, paying parti-cular attenticm to the repective role of htsnan (operator) error as

<mm_ red to roles of equipnent and instrinnentaticm information mal-function. Ibr each of the above-identified three ocuponents of error (operator, equipnent, and instrumentaticm-information) demonstrate the extent to whidi the assined probabilities are based on past experience is used as a . basis for probability estimates, state whether the estimate is based on past experience with identical reactors and control room designs to Indian Point, if not, state what methods are relied tpon to take into accotnt the specific reactors and control ruc.a-J=gedent characteristics of Indian Point, as well as the quality and effectiveness, of operator training and emergency procedures at Indian Point; if there is no such consideration of Indian Point - specific perineters of prob-ability in detennining accident probability, prcrdde a full and i:horough justificaticn why such consideration is not needed. If estimates other i

than those based cn past experience are utilized in calmlating prob-abilities, provide a detailed justification and basis for these estimates.

45.) In the event that voltmtary personnel did not respcmd to your j requests for aid in tines of an mergency, please state how you would l respcmd to the situaticm.

r c

.v

. . x gf _11_ ,

46. ) Specifically state the pmmises and grounds on which Licensee ,

answered the pn M.ig interrogatory. If there are studies available,

?. >L .

please 4w:licate the existance of those studies and attain a copy of'the +

i studies that you have in your possession.

. M 47.) aw Ull1 the public beyond the 10 mile EPZ be inforned of the travel of a plume?  ;

i

46. ) How has 'the emergency plan addressed the protectim of the populatfor$, beyond the 10 mile EPZ, for instance ti e sheltering suggested

,, - 1 '

, in NUNCC,-0b967 s -

4 9,.) ' Ibv will novement of evacuees through. the 50 mile EPZ affect the w .. g ability of.the people in this area to inplement their own protectim i in the event of exposure to the plume? '

50.) For each agmcy or organization withhhich Licensee has a letter i of agreement and tmderstanding, provide docxents whiE specify what assistanm is to be rendered and list nutually ameptable' criteria for the inplamentation of these types of assistance. '

51.) Prdwide dcxamentation indicating the qualificatims of hospital and medical perscrael who are relied upon by Licensee to provide emergency services tp accmodate rrdiological emergencies, especially to injured persons who may also be radioactively contaminated.

52..) mat assurance is there that licensee Emergency Action Iavels constitute a sufficient set of perineters and action levels for all possible accidents?

53.) mat assurance is there that the licensee Emergency Action Ievels adequately account for the lead times necessary to inpleent those protect!- e actienc whi.ch will be necessary in response to the energencies which caused the EAL's to be declared?

i .

54 .) Provide a detailed simnary of a y ;and all h=mts that have been prepared or atmnissioned by Licensee a:moerning the manangement ability of Licensee. (In particular, for each such doctanent, identify

- the author (s) and their qualifications, and describe any evidence in such doctznents that points towards evidence of lack of adequate management ability on behalf of licensw.)

55.) Wat determinations has the Licensee made, if any, as to the existance in the environs surrounding Indian Point of conditions such as denography, topography, climate, land characteristics, access routes, and local jurisdictional' boundaries that warrant departure frm a circular EPZ defined uniformly by a 10 mile radius frm the plant?

56.) Describe fully the instrumentation the licensee intends to install in its off-site Emergency Operations Center in terms of the specific ,

l itens of infornaticn (i.e. rraiation nonitoring; essential plant status perimeters such as pressure and tenperature) such infonnation will be )

able to furnish.

57 .) Identify the provisions in the licensees' Emergency Plans which either sirsjularly or collectively are intended to prevent damage to property such as livestock in the area surrotnding the plant site. Explain how each contributes to the achievement of this goal.

58.) Identify each step that nust be taken from the time an off-site radiaticn monitoring survey team is dispatched to the time the findings of such a monitoring effort are made available for .ose assessment calculations.

a.) How nuch time is required for the above-described process to take place?.

b.) How would the answer be affected by the installation of off-site nonitoring devices that could be remotely read either onsite or at the Emergency Operations Facility?

y c.) Explain the basis for the Licensees' belief that offsite nonitoring devices that cannot be renotely read onsite pzkwide arbvluate accident assessment capability.

59 ) What arrangements are necessary for special deliveries of gasoline to service stations along evacuation routes?

60.) Do such arrangements presently exist?

61.) Ebr each of the four (4) "at risk" counties describe the otxmun-icaticns system presently in effect between the' county sYau.pcy operaticns center and local EOC's.

62.) Describe the extent to which any such system is not operable (i.e., local ccntact not available) on a 24-hour basis.

63.) What is the time required for the rmoval of seats from the buses whidi will be used to evacuate nursing home wheel chair patients?

64.) What is the time required for the evacuation of each of the hospitals located within a 10-mile radius of Indian Point? Explain fully the reasons for the time given in each case.

65.) Identify all assurptions used in arriving at evacuation time estimates, such as road' capabilities and traffic volume over given egress routes.

66. . ) How would sd. estimates be affected by each of the following conditions: (1) Inclement weather, including snowstorm, (2) Rush-hour congesticn, and (3) traffic accidents?

67. ) Ichntify any and all documents that have been prepared or ommissioned by or for the licensees to investigate the credibility, as perceived by the public within the general vicinity (whether that '

1 be a ten mile radius, surromding townships or counties, or other bomdary) of Indian Pc> int, of Liccasee, or acyants of Licensee, whether l

l that credibility be off a general nature, or specifically in respect to the accuracy of reported occurances, offsite radiaticn levels, etc.

_14- . .

Identify the authors of each sus rh-nt, and their qualificatm.

68,) Identify any and all reports known to the Licensee, including reports in newspapers and media in the Indian Point area, that show evidence that there is, or ever has been, any substantial lack of 1

public trust in the credibility of the Indian Point licensees.

69.) How have the differences of nuclear emergency from other kinds of disasters been defined and evaluated in assessing public performance in a real nuclear disaster?

70.) Will the public relations efforts of utilities to gain acceptance of nuclear power have an effect on the willingness of the 'public to evacuate during various stages of an emergency?

71.) Does the Licensee ocnsider "spontmeous" evacuation outside the 10 mile EPZ a possibility?;

72.) If the answer to i'm above question is yes, have the Licensees, or their agents, done any research into the effects of sudi a " spontaneous" evacuation on the evacuation efforts within the EPZ? Is so, what are the results of this researdia 73 1 Do the emergency response plans take into consideration the likelihood 4

of " spontaneous" evacuation outside the 10 mile EPp 74.) ub what extent are the evacation time estimates dependent on the ~

assunption of prior mobilization and stationing of emergency forces from the state and comties? If it is assuned that no prior nobilizaticn and stationing, or only partial mobilizaticn and stationing is possible prior to the evacuation order going out, how nudi longer could the evacuation require?

75.) Have Licensees' emergency plansand inplementing procedures been i reviewed regarding the abi]ity of Licensee to collect environmental radiation sanples under adverse weather conditions? How many 4-wheel

' drive' vehicles, snowmobiles, boats, and helicopters does Licensee possess?

+ * .

76.) Identify any and all medical facilities known to the Licensees that are within 75 miles of Indian Point, and that possess the capability to accept and treat persons who might becme exposed to radioactive con-tamination (and other injuries) resulting frm an accident at Indian Point.

For each such medical facility, provide an estimate of the neber of such persons who could be treated; describe the radiological measuring instruments available; describe the contingency plans that have been prepared by that facility for a radiological accident at Indian Point; describe the capability

- e.g. staff, appropriate supplies, etc. that are available for such treatment; and identify the chief medical officer of each facility.

77.) Identify any and all facilitice for Radioactive dectntamination of persons who might be exposed to an accident at Indian Point, and are beyond 75 miles from the plant.

a. For each such facility, provide an estimate of the nmber of such

, persons who could be treated; describe the radiological measuring instruments available; describe the contingency plans that have been prepared by that facilityforaradiologicalaccidentatIndianPoint;descrikethecapability-e.g. staff, appropriate supplies, etc. that are available for such treatment; and identify the chief medical officer of each facility. Stamarize the contingency plan for transportation of persons frm within the EPZ to the decontamination facility.

7d.) Please provide the draft report (s) by Parsons Brinckerhoff explaining how evacuation times in the preparedness plans were obtained.

79.) Please provide the basis for Parsons Brinckerhoff's conclusions, regarding the method used to convert population to passenger car' equivalents and how the' nmbers of passenger car equivalents changed as a function of time of day.

~

80.) Please provide the ntxnerical asstmptions utilized by Parsons-Brinckerhoff to convert buses to passenaer car equivalents.

81.) Please provide the asstmptions utilized by Parsons Brinckerhoff in fonnulating the time estimate studies regarding how and where the population was loaded on the network, particularly asstmptions about rate of loading. I 82.) Please provide the asstmptions utilized by Parsons Brinckerhoff about " terminal" time and/or the time needed to reach the network. ..

83.) Please provide the choices made and assimptions utilized by Parsons- 1 Brinckerhoff about evacuation routes and road capabilities.

84.) Please provide the estimates of the percentage of persans evacuated fran the EPZ and each ERPA as a function of time.

85.) Describe any and all information in the possession of the licensees pertaining to the intervenor organizations and to individual msnbers of intervenor organizations and describe the measures by which such information was obtained. Also describe the purpose for which sudi information was obtained.

86.) Describe any and all public information, public relations, and adver-tising programs currently underway to inform or reassure the public about the risk of accidents at Indian Point, the potential consequences of accidents, and the adequacy of energency preparedness to mitigate these corsequences.

87.) Describe any and all visits the licensees, their attorneys, or any representative of the licensees and/or their attorneys have made to the offices of the intervenors, and for what purpose. Please identify the names of those people.

~

88. mat is the licensees' positicm on the prnhnhi1ity of an accident as described in the scenario of the Indian Point joint -

exercise of March 3,1982?

89. Provide all notes, reports, and h_= wits relating to the licensees' preparation for and assessments of drills preceding the Indian Point joint exercise of March 3,1982.

90. Provide all drafts, letters, h _= nts, etc. used in the licensees' role in the preparation of the scenario used for the joint exercise of March 3, 1982. Identify personnel involved and provide their credentials.

91. What is the licensees' position, and what has it been, on the necessity of sounding the sirens during the joint exercise of March 3, 19827 Provide detailed information on the post-exercise testing program of the sirens. -

92. Provide all notes, reysrts, h = nts, etc. presented in all meetings participated in by the licensees and their consultants in preparation for and subsequent to the Indian Point exercise of March 3, 1982.

93. What was the total cost to licensee ratepayers of licensee i

personnel's and their ccmsultants' paricipation in all activities relating to the Indian Point exercise of March 3, 1982?  !

1 l

l

94. What is the licensees' position on inprovements needed for i

~

future exercises at the Indian Point site?

95. Identify all licensee personnel, their consultants and lawyers, who participated in or observed the Indian Point exercise of March 3, 1982. Include their s oacuniala.

96. Provide all notes, reports, h==nts, etc. relating to licensees' participation in and cioservation of the March 3,1982 exercise, including all contributions by licensee personnel, con-sultants, and attorneys.

97. Wat is licensees' position on the adequacy of palic infcrmation brochures at the time of the exercise? Provide all drafts, letters, h==nts, etc. used in preparation of the current brochure.

If considered inadequate, what is licensees' timetable for improving and redistributing the brochures?

98. mat was the timetable for alerting and mobilizing licensee personnel during the exercise?

99. Wat is the licensees' position on the adequacy of public and media relations as demonstrated in the exercise, and if inadequate, what is its timetable for Mvating the press and public?

. , ~

- l Dated: April 29, 1982 New York, New York F .

1

) ,

)

b GLA L* 11 Ltn am ~ ;f {1\ \,ESQ.

' [ l il fdr onofConcerned}'i Scientists New York University Law School 323 Vanderbilt Hall 40 Washington Square South ,

New York, New York 10012 212-598-3452 v6 HOLT, PInTECE DIRECIOR Nei i

Public Interest Research

, Inc.

5 Beekman Street New York, New York 10038

212-349-6460 l

<'Mi L G L -

M@N R PCTITERFIEID, ESQ. V Counsel for New York Public Interest Research Group, Inc.

Box 384 Village Station

' New York, New York 10014 212-227-0265 l

l 1

o

== /

-