ML20052D156

From kanterella
Jump to navigation Jump to search
Ucs/Ny Pirg First Set of Interrogatories to & Request for Documents from NRC
ML20052D156
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/28/1982
From: Blum J, Holt J, Potterfield A
PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
EP, ISSUANCES-SP, NUDOCS 8205060320
Download: ML20052D156 (18)
v • d • e


Text

_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

UNITED STATES OF AERICA P Of" NUCLEAR REGULATORY CONilSSION

  • p" nY-5

"" l W ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CONSOLIDATED EDIS0N COMPANY OF NEW YORK Docket Nos. 50-247 SP (IndianPointUnit2) 50-286 SP POWEP AtJTHORITY OF THE STATE OF NEW YORK April 28,/1582 (Ir  : int Unit 3) fy <3 fit UCS/NYPIIG'S FIRST SET OF INIERROGMORIES %- ,,,, ,

"I AND REQlEST EDR DOCGWIS FIM ' DIE NRC S'IRPFs y LLu 5 7932 * '2o g ,

=) g eA

'Ihe New York Public Interest Daaaarch Grotp, Inc. and' the Unionyp(x w , _ J, i of Concerned Scientists serves on the NBC' Staff the interrogatories aiil request for production of h= ants that appear below. A sworn response to the nust be provided to the New York Public Interest Researdi Grotp, Inc. and the Union of Concerned Scientists at 5 Beekman Street, New York, ,

i New York 10038 in accordance with the terms of 10 C.F.R. 2.740(b) and 2.741(d) and in accordance with the Order of the Atmic Safety and Licensing Doard of April 23, 1982. If the answer to any question is not known when the response is filed, the animer nust be provided as soon as the missing information becomes availabla.

As used in the interrogatories and request for production of r M = ants, the following definitions apply:

1. " Con Edison"and"PASNY"mean Consolidated Edison Cmpany of New York and Power Authority of the State of New York, respectively, their_ officers, agents, enployees, and consultants.
2. " Facts" include the calculaticm1 oA othar assunptions, if any, underlying vario.is assertions of' fc.ct. %C3 ~

, s i i 8205060320 820428 6

/ [

PDR ADOCK 05000247 PDR ,s g

5; .

\

[ '

/ ( ,

l

?

I

3. " Include" and " tar inding", as uand in thsee la+=mtorias, mean t "lachahng, but not limited to".

i

4. "Doctamnt" means acy hanbritten, typed, printed, recorded or graphic unttar housvar per*r=d or repraAM, inchxEng material stored flor une in autzamatic data ya-:- --ing systems, whether or not in the ------ -taa, custody or control of the staff and teether or not n lai=ad to be privileged against

- discovery on any ground, including: reports; records; lists; ===nrandar l

/ -:- - s .-:---gie; telegrams; sciraths stobographs; sotsid swJings; filmst hand, mactiina and camputer r=1m1=tions; ocaputse codass datar and imitten

. statements of witraraus or other person hmri ng krinu ld a ya of the facts.

5. "Shdiam er abnerations" include physical, empirical, calculational,

--- - 23 anal, and other types of work whether recorded in writing or not.

6. *NYSRERP" or "energency plans" or " plans" means the New York State Radiological Dnergancy Response Plans for Indian Point, ircluding all appendices, attachnents, revisions, and other h==nts or plans referescod in the state or county plans.

c o

4

(

I , ,

u ,

9 l

S

.9 I

l ,e r

- .- _i

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 include the ,

l 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 busineus affiliation?
d. What is the person's field of expertise?
e. If the person is not 'a Staff employee, on what date did pt sic;f first contact or consult the person? .
f. What are the dates of all subsequent contacts or consult-ations with the person?
g. Were any reports made to Staff by the person?

If the answer to question 19 is anything other than a I h.

simple 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 submitted by the person while acting in an advisory capacity, as a prospective witness, or both.

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

l j. What are the facts'and/or opinions to which the witness will testify and the grounds for each fact or opinion?

2. Provide a reasonable description of all documents that will be relied upon in the testimony presented by each witness.
3. Identify by author, title, date of publication and i publisher, all books, documents, and papers you intend .at this time to employ or rely upon in conducting your cross-examination of.prospectivt NYPIRG/UCS witnesses testifying in connection with NYPIRG/UCS contentions. .

)- - ~ ,, %s - _ _ - - - -

-e

4. H o ths NRC Staff conduct 0d en ind: pendant rGview cnd ,

evaluation of the NYSRERP for Indian Point?

5. Please provide copies of any and all documents, reports, working papers and notes portaining to or arising out of Staff 9

reviews and evaluations of the NYSRERP for Indian Point.

6. What is the position of the Staff on the compliance of the Indian Point emergency plans with each of the sixteen mandatory standards set forth in 10 C.F.R. 50.47(b), and with the standards set forth in Appendix E to C.F.R. 50, and with the criteria set forth in NUREG-0654? State all opinions and documents upon which the position is based, and identify the person or persons who formulated the opinions and/or developed the documents.
7. Provide copies of any and all documents referred to in ,

the answer to Interrogatory 7.

8. What assumptions does the NRC Staff make regarding human responses during radiological disasters which may occur at Indian Point? Please indicate how the Staff assumes such human responses would be the same as and different from human responses expected ,

during radiological disasters which may occur at other nuclear power plants, and how the Staff assumes such human responses would be the same as and different from human responses expected during non-radiological disasters, natural or man-nade. State all opinions and documents upon which the response to this question is based and identify the person or persons who formulated the opinions and/or developed the documents.

9. Provide copies of any and all documents referred to in the answer to Interroga. tory 8.

4 l

. *n21

^

10. Describe in detail any and all attempts made by NRC Staff to identify and to determine the validity of human response

.. assumptions incorporated into the NYSRERP for Indian Point. State all opinions and documents upon which the response to this question is based, and identify the person or persons who formulated the opinions and/or developed the documents.

11. Provide copies of any and all documents referred to in the answer to Interrogatory 10. ,
12. What is the position of the NRC Staff on the present estimates of evacuation times, based on NUREG-0654 and studies by CONSAD Research Corporation and by Parsons, Brinckerhoff, Quade & Douglas, Inc? State all opinions and documents on which the position is based and identify the person or persons who formulated the opinions and/or developed the documents.
13. Provide copies of any and all documents referred to in the answer to Interrogatory 12.

{,.

14. What is the position of the NRC Staff on the assumptions contained in the present estimates of evacuation times for Indian Point, including assumptions about human responec during a radiological emergency at Indian Point? State all opinions and documents.upon which the position is based and identify the person or persons who formulated the opinions and/or developed the documents.
15. Provide copies of any and all documents referred to in the answer to Interrogatory 14.

16.ht is the position of the NRC Staff on the methrAningies utilized by CONSAD Research Corporation and by Parsons, Brinckerhoff, Quade & Douglas, Inc.

and in NUREG-0654 in preparing the present estimates of evacuation tines for 4

E :r ? h

Indian Point? State all cpinions and documents on which the position is, i

had and identify the person or persons Mc fm-lated the opinions and/or developed the <h,==nts.

17. Provida copies of any and all documents referred to in the answer to Int ausatory 16.
18. mat evaluations or review of the present time estimates for Indian Point have been done by the NIC Staff, and what person or persons participated in the review or evaluations? mre the raw data for the present time estimates
  • obtained, evaluated arxVor dr+1N by the NIC Staff or for .the.MBC Staff? By Wat person or persons?
19. mat evaluations or review of the present emergency plans fior the State of New York have been done by the NEC Staff, and WWat person or persons participated in the review or evaluations? Were the raw data or mM M1=

for the plans obtained, evaluated anyor <hala-char +ad by the NIC Staff or for the NIC Staff? By what person or persons?

20. mat is the position of the NEC Staff on the wd4=h414ty of ...

Con Minnn an#or PASW to notify the proper authorities of an emergency p @ y and accurately? State all opinions and documents on Wtich the position is based and identify the person or persons de *w-lated the opinions an#or developed the documents. mat infonnation does the NIC Staff have or has the NIC Staff had about the perfonnance of Oon M4=nn and/or PAsE with regard to notifying authorities of an emergency at Indian Point?

21. Provide copies of any and all <h'==nts referred to in the answer to Interrogatory 20.

i

---___m- - _ . _ _ '

22. Wat is the position of the NHC Staff on the range of widant scenarios and neteorological conditions taken into account in the energency plans and sq-M protective actions for Indian Point? Specify the..

Wdant scenarios and meteorological conditions that are taken into account l in the emergency plans and prw protective actions for Indian Point.

State all opinions and doctrnents on which the position of the NRC Staff is haand and identify the person or persons who fornulated the opinions and/or developed the doctznents.

23. Provide copies of any and all doctanents referred to in the answer to Interrogatory 22.
24. mat is the position of the NRC Staff on the ways in Wildt the and other special populations problems of evacuating children /frtxn threatened areas have been addressed in the present emergency plans for Indian Point? State all opinions and devmnants on which the position of the NBC Staff is based and identify the person or persons who fornulated the opinions and/or devalemd the doctanents.
25. Provide copies of any and all dev'nants referred to in the answer to Interrogatory 24.
26. hhat is the position of the Staff on the adequacy of the road system in the vicinity of Indian Point for accmplishing a timely evacuation?

What is Staff's definiticn of "tinely" and what specific objective criteria does Staff apply in determining whether evacuation tine estimates for Indian Point are " timely"? State all opinions and docunents on which the response to this interrogatory is based and identify the person or persons who fornulated the opinions and/or developed the documenta.

O n , . - -

l 1

27. Provide copias of any and all h===ts referred to in the answer to D*=- _-y-Lu.y ~26.
28. ht is the position of the NRC Staff on the w ur. lateness of the present pluss exposure pathuey EPZ for Indian Point? State all T nir=

i and documents on whidt the position of the imC Staff is based and identify the pornan or persons who fr==ilated the opinions and/cc developed the docu ents.

. 29. Provide copies of any avi all documents referred to in the answer to Interrcgatory 28.

30. mat is the position of the IEC Staff on Ein provision of potassium indida to the residents of the EPZ of the Indian Point plants, and to populations beyond 10 miles, including New York City, residents?

State all opinions and documents on whidt the positim of tne NIIC Staff is h=ad and identify the person or persms who fonealated the opinions any or developed the docunents.

31. Provide copies and any and all docunents referred to in the answer to Interrogatory 30.
32. mat is the position of the NRC Staff en the sheltering ceility in the EPZ of the Indian Point plants? Stata all opinions nnd documents an which the position of the NRC Staff is Maad and identify the person or persons d e fo - lated the opinion and/or deva 1W the docunents.

l i

33. Provide copies of any and all h== ants referred to h h m l

(O

to Int:errogatory 32.

34. ht is the position of the NBC Staff on the effect of adverse weather conditions on the Irwhy network described in the emergency plans for Indian Point? ht weather conditions result in what changes in the evacuation Ph ilities of the roadway network around Indian Point in the opinion of the NBC Staff? State all opinions and hmts on which the position of the NBC Staff is based and identify the person or persons who formlated and/or designed the docunents.
35. Provide copies of any and all Avmmts referred to in the answer to Interrogatory 34.

.36. ht is the positicn of the NBC Staff on the eshhliad inent of .

limitationson the licenses of Con Edison and PASNY relevant to evacuation capabilities of the road network around Indian Point?

State all opinions and docunents on which the positicn of the NBC Staff is based and identify the person or persons who formlated .

and/or developed the docunents.

37. Please provide copies of any and all docunents referred to in the answer to Interrogatory '36. '
38. ht is the position of the NBC Staff on the feasibility of and need for upgrading the roadway network at Indian Point to permit successful evacuation of all residents in the EPZ before the plune arrival tine? State all opinions and docutents on whi c h the position of the NBC Staff is based and identify the

person or persons idio far=ilated the :gpinions and/or devalmad doctments. -

39. Prwide copies of any and all rinmaants referred to in the answer to Interrogatory 38.
40. What is the position of the NRC Staff on the faanihility of and need for tpgrading of the energency plans for the Indian Point plants to take into account the special needs of wi=1 grotps and par +imlarly those idio are dependent on others for their =nhility? %enat specific measures could and/or should be taken in this respect? State all opinions and doctments on which the positics of the NRC Staff is based and identify the person or r

persons @ fornulated the opinion and/or deva 1H the document.

41. Provide copies of any and all doctments referred to in the answer to 5

Interrogatory 40.

42. %eiat is the position of the NRC Staff an the fannihility of and need for specific steps to be taken by NRC, State and local officials to p.umite a public awareness that nuclear power plant accidents with substantial offsite risks are possible at Indian Point? itiat specific steps have been or are being contenplated or considered by the NRC Staff? State all opinions and (betnents on which the position of the NRC Staff is haaad and identify the person or persons idio fornulated the opinion and/ or developed the doctnent.
43. Provide copies of any and all doctnents referred to in the answer to Interrocptory 42.
44. Wat is the position of the NRC Staff on the feasibility of and l -

I

neb for the establishment of a maximum acceptable level of radiation exposure as an objective basis for measuring the adequacy of emergency planning at Indian Point? mat levels of radiation exposure have been or are being considered by Staff as acceptable for especially vulnerable population groups as well as for average populations in the event of an s accidental release of radiation frcm Indian Point? State all opinions and docuuents on which the position of die Staff is based and identify the person or persons who formulated the opinion and/or developed the document.

45. Provide copies of any and all documnts referred to in the answer to Interrogatory 44.
46. mat is the position of theE Staff on the faanihility of and need for the emergency planning brochure to give more attention to problems associated with persons dx) are deaf, blind, too young to understand the instructions, or Wx) do not speak English? m at specific additional inprovements are necessary in the energency planning brochure in the opinion of the NRC Staff in this regard? State all opinions and docunents on which the position of the NRC. Staff is hamad and identify the.

person or persons Wx) fornulated the opinion and/or devaltv=1 the document.

47. Provide copies of any and all h=nts referred to in the answer to Interrogatory 46.

4 and all

48. Describe the substance of any/comunications, oral or written, between Boyce Grier and Brian Grimes or any other person ancedated with the NRC Staff pertinent to the Staff's deliberations, evaluations and decisions with regard to the deficiencies identified in the Indian Point energency plans in April 1981 and the cmmencesuent and termination of the 120-day enforcement clock, w ,

d s

Identify the person or persons who participated in each cxxmunication and provide a copy of each written ocumunication.

49. Wat deficiencies identified in the April,1981 PAC review of the state and 1 mal emergency plans for Indian Point have been corrected? Of the remaining deficiencies, which, in the opinion of Staff, are significant and which are not? Which, in the opinion of Staff, nust be corrected as a condition of operation for Indian Point 2 and 37 By what spcific date?

e State all opinions and doctrnents upon which the responses to this interrogatory are based, and identify the person or persons who fornulated the opinions and/or developed the doctments.

50. Provide copies of any and all documents referred to in the answer to Interrogatory 49.

4

$1. What deficiencies identified in the Wr,1981 RAC review of the state and local emergency plans for Indian Point have been corrected?

Of the remaining deficiencies, which, in the opinion of Staff, are significant and which are not? Which, in the opinion of Staff nust be corrected as a condition of operation for Indian Point 2 and 3? By what specific date?

State all opinions and doctruents upon which the responses to this interrogatory are based and identify the perscn or persons who fornulated the opinicns and/or developed the doctments.

52. Provida copies of any and all doctrnents referred to in the answer to Interrogatory 51.
53. Is it the position of the NBC Staff that the off-sita emergency plans for Indian Point were inplemented by April 1,1981 in accordance with the August,1980 Dnergency Planning Rule? Is it the position of the Staff that the off-sita emergercy plans for Indian Point have been inplenented to date? Explain and provide Staff's definition of the term "inplenented" as

used in the August,1980 Energency Planning Rule which required that plans be "inpleented" by April 1,1981. State all opinions and doc ments upon which the responses to this interrogatory are based, and identify the person or persons who formulated the opinions and/or developed the documents.

54. Provide copies of any and all docunents ' referred to in the answer to Interrogatory 53.
55. Is it the Staff's position that the off-site emrgency plans for Indian Point are required to be in full ccxtpliance with the emergency planning neasures set forth in 10 TR 50, Appendix E,10 CFR 50.47 and NUREG-0654, Rev.1, as a condition of operation?
a. If yes, does the Staff believe that the licensees should not be permitted to operate their plants when any ccxtponent of the emergency plans are not in full conpliance
b. If no, which planning measures set forth in 10 TR 50, Appendix E, and 10 TR 50.47, and including each of the criteria set forth in NUREG-0654, Rev.1, need not be met as a condition of operation,in the opinion of the staff?
56. Are there any additional emergency planning requirements the Staff lelieves should be inposed upon the Indian Point licensees as a condition of operation? Please list and describe fully.
57. Is it the position of the Staff that ad hoc energency procedures would be adequate to protect the health and safety of populations beyond 10 .

miles of Indian Point? Explain fully and docment.

58. Is it the position of the Staff that ad hoc emergency procedures would be adequate to protect the health and safety of the populaticn of New l York City should a worst-case accident occur at Indian Point with winds blow-l l ing toward NYC? Explain fully and document.

l l

l l

59. Is it the position of the Staff that the Indian Point site poses unique problems for errergency planning because of the dense population rusiding within the 10-mile EPZ and because of the increasingly dense population beyond the 10-mile EPZ, especially in New York City? Explain fully. State all opinions and doctments upon which the response to this interrogatory is based and identify the person or persons who fornulated the opinions and/or developed the doctrrents.
60. Provide copies of any and all doctraents referred to in the answer to Interrogatory 59.
61. What is the position of the NRC Staff on the performance of the ertployees and agents of Con Edison and PASNY during the emergency planning exercise of burch 3,1982?
62. What is the basis of NRC - FEMA judgment of whether the exercise of burch 3, 1982 is adequate to daronstrate the capability of amergency plans around Indian Point to reasonably assure that the public health and safety will be protected in the event of a radiological accident?
63. Provide all drafts, letters, doctments, etc. reflecting NRC - FEM's role in the preparation of the scenario used for the

[ joint exercise of burch 3,1982. Identify the personnel involved L

and provide their qualifications and training.

64. Provide detailed infontntion on the NRC - FDR role in post-exercise testing of the alert notification systen around Indian Point. What is the NRC - FDR interpretation of the March 1,~ 1982 I

daadline for Wl-ntation of this systen, cc regards the type of testing NRC - FDR considers adequate to ensure its anticipated func-tioning?

65. Provide all notes, reports, h w nts, etc. presented in all meetings participated in by NRC - FDR in preparation for and sub-sequent to the Indian Point exercise of March 3,1982.
66. What is NRC - FDR's position on inprovements needed for future exercises at the Indian Point site?

s

67. Identify all NBC - FDR personnel who participated in or observed the Indian Point exercise of March 3,1982. Include their qualifications and training.
68. Provide all notes, reports, manos, etc. subnitted by all NRC - FDR observer / participants as the basis for assessments of the exercise of March 3, 1982.
69. What studies have NBC - FDR done to ensure that the public is adequately infatmed about what they are to do in the event of a radiological accident at Indian Point? If they have not been conducted, when are they to be conducted? Provide copies of the studies or surveys to be used and any results found to date.
70. What is the NRC - FDR position on relations with the media that were demonstrated during tne Indian Point exercise? If cxmsidered inadequate, has NBC - FDR contenplated education of the nedia?
  • )=

l

71. What is the staff's position on the intervenors' repre-sentatives who observed the Irdian Point exercise of March 3,1982 l

according to the terms of the Atcanic Safety and Licensing Board? ,

Include in your response details regarding specific effects on the drill, if any, you attribute to the intervenor observors.

72. Wiat measures does the NBC Staff believe need to be taken to test I and verify the licensees' claim that the public information pamphlet has adequate readability and intelligibility for all persons in the pitne EPZ?
73. What measures does the NBC Staff believe need to be taken to test and verify the licensees' claim that present methods of distribution of the public information partphlet actually put the panphlet into the hands of all persons who would need it in case of an accident?
74. What particular types of persons does the Staff believe need not be notified in case of an emergency at Indian Point (e.g., transients, persons with sensory handicaps, persons listening through earIhones to tapes or radios, people out of range of sirens)?
75. If Staff accepts a standard of less than 100% of the population that nust be notified in ,the event of an emergency at Indian Point, what is that standard?

g

76. What measures does the Staff believe need to be added to the present '

mergency plans for Indian Point to achieve 100% notification of all persons within the plme EPZ?

N

77. mat measures will be taken to test and verify the claims of the licensees and their consultants who prMmA the emergency plans for Indian e ,

Point that 100% of the population will be notified within 15 minutes by the presently provided means? Explain fully.

78. Wat is the NBC Staff's position on the status of Con Edison's  ;

and PASNY's cortpliance with all of the relevant NBC regulations and require-ments regarding their on-site emergency plans and procedures for Indian Point Units 2 and 3 respectively. Please be specific and detailed regarding which requirements have been fulfilled and which have not to date. With respect to any deficiencies in on-site planning or preparedness please indicate a specific and detailed time-table by which each of these deficiencies will be required to be corrected.

79. Provide copies of any and all d tvmmnts relevant to your response to Interrogatory 78.
80. With respect to the responses provided by the NBC Staff to any of the interrogatories contained in this doctnent, who are the persons on whose opinions ancVor knowledge of facts the NBC Staff expects to rely during the Indian Point evidentiary hearings?

l l

l

a Dated: April 29, 1982 New York, New York F .

^

) Y. i,)

b GAA 'L'i 111.tA arry 1 % Blyl, ESQ. ~j I el fdr Union of Concerned (j' Scientists New York University Law School 323 Vanderbilt Hall 40 Washington Square South ,

New York, New York 10012 212-598-3452

. , v6 JO7 HOLT, PIOJECP DIRECIOR NerjYork Public Interest Researdt i

/ Group, Inc.

5 Beekman Street New York, New York 10038 212-349-6460

'Q* Loh AMANDA PuntarnaD, ESQ.

th f/

l Counsel for New York Public Interest Research Group, Inc.

Box 384 Village Station New York, New York 10014 212-227-0265 l

- i l

Retrieved from "https://kanterella.com/w/index.php?title=ML20052D156&oldid=2542899"