ML20052D196

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Ucs/Ny Pirg First Set of Interrogatories to & Request for Documents from Ny State Energy Ofc.Certificate of Svc Encl
ML20052D196
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/30/1982
From: Blum J, Holt J, Potterfield A
PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS
To:
NEW YORK, STATE OF
References
ISSUANCES-SP, NUDOCS 8205060351
Download: ML20052D196 (29)
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UNITED STATEL 0F AMERICA NUCLEAR REGULATORY COMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

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In the Matter of )) hsy.

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i CONSOLIDATED EDISON COMPANY OF NEW YORK ) ' Docket Nos. 50-247 SP (Indian Point Unit 2) ) x. ~~

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POWER AUTHORITY OF THE STATE OF NEW YORK ) April 30, 1982 (Indian Point Unit 3) )

UCS/NYPIRG's FIRST SET OF INTERROGATORIES TO AND REQUEST FOR DOCUMENTS FORM NEW YORK STATE ENERGY OFFICE, IN ITS OWN CAPACITY AND AS A REPRESENTATIVE  ;

OF ALL OTHER NEW YORK STATE SUBDIVISIONS, DEPARTMENTS, [

COMMISSIONS, AGENCIES, AND CONSULTANTS IN POSSESSION OF THE INFORMATION REQUESTED HEREIN

'Ihe New York Public Interest Ibsearch Group, Inc. and the l

Union Of Con rned Scientists serves on New York State the interrogatories and request for production of documents that appear below. A sworn response to them must be provided to the New York Public Interest Research Group, Inc. and the Union of Concerned Scientists at 5 Beekman Street, New York, New York 10038 in accordance with the Order of the Atomic Safety and Licensing Board of April 23, 1982. If the answer to any question is not known when the response is filed, the answer must be provided as  ;

I soon as the missing information beccmes available.

As used in the interrogatories and request for production of documents, the following definitions apply:

1

1. " Con Edison" and "PASNY" mean Consolidated Edison Company of New York and Power Authority of the State of New York, respect- i l

ively, their officers, agents, employees, and consultants. l l

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2. "NY State" or " state" means New York State, or any subdivision, department, agency, commission or con- -

sultant thereof that you are aware of that is involved with planning, preparing, maintenance and possible implem-entation of the New York State Radiological Emergency Response Plan as'it would relate to an accident at Indian )

Point. Such divisions and agencies include but are not necessarily limited to Disaster Preparedness Commission, Department of Health, Nuclear Emergency Planning Group.

3. "NYSRERP" or " plans" or " emergency plans" means the New York State Radiological Emergency Respcnse Plans and all of its appendixes, attachments and revisions, including all other documents or plans referenced in the New York State Radiological Emergency Response Plans 6e In(Ub" 0
4. " Facts" include the calculations or other assump-tions, if any, underlying various assertions of fact.
5. " Include" and " including," as used in these interrogatories, mean " including, but not limited to."
6. " Document" means any handwritten, typed, printed, recorded or graphic matter however produced or reproduced, including material stored for use in automatic data processing systems, shether or not in the possession, custody or control of New York State or any of its agencies or consultants and whether or not claimed to be privileged against discovery on any ground, including: reports; records; lists; memoranda;

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. Please provide answers to the following questions:

1. ht is the position of NY Skate on the ocupliance of the Indian Point emergency plans with eads of the sixteen mandatory standards 7 set forth in 10 C.F.R. 50.47(b), and with the standards set forth in Appendix E to 10 C.F.R Part 50? State all opinions and docunents on whidt i l

the position is based, and identify the person or persons who far=ilated i

the opinions and /or developed the h= ants. ,

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2. Provide copies of any and all docunents referred to in the answer l to Interrogatory 1.
3. What is the position of NY Sbate on the assunptions about '

i the response of the public and of utility enployees utilized by or underlying l the ocnclusions of the persons who developed the emergency plans and evacuation l time estimates for Indian Point 7 State all opinions and h= ants on idtich the l position is based, and identify the person or persons who fonoulated the l opinions and/or developed the docunents. I i

4. Provide copies of any and all h= ants referred to in the answer [

l to Interrogatory 3.

5. What is the position of NY State on the present estimates of evacuation times, ha=vi on NUREG 0654 and shrWat by CONSAD M a rch Corporation ,

and by Parscms, Brinckerhoff, Quade & Douglas, Inc? State all opinions and '

cbcunents on which the position is based and identify the pei.swi or persons who fonatlated the opinions and/or devalmaa the h=nts.

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D correspondence; telegrams; schedules; phobographs; sound .

recordings; films; hand, machine or comput'er calculations; computer codes; data; and written statements of witnesses or other persons having knowledge of the facts.

7. " Studies or observations" include physical, empirical,

, calculational, assumptional, and other types of work whether recorded in writing or not.

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10. Provide copies of any and all h==nts referred to in the answer to Interrogatory 9.
11. What evaluations or review of the present time estimates for Indian .

l Point have been done by NY State, and what person or persons participated j in the review or evaluations? Were the raw data for the present tine estimates ,

i obtained, evaluated and/or double-checked by NY State .or for NY l State? By what person or persons?

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12. What evaluations or review of the present emergency plans for the State of New York have been done by NY State, and dat person or persons participated in the review or evaluations? Were the raw data or conputer models for the plans obtained, evaluated and/or double-checked by NY State or for NY State? By what person or persons?
13. khat is the position of NY State on the rollability of . . .

Con Edison and/or PASNY to notify the proper authorities of an emergency prmptly and accurately? State all opinims and A v'mants t on which the l

position is based and i&ntify the person or persons who fornulated the opinions and/or developed the docments. What information does NY State have or has NY State had about the performance of Con Edison and/or PASNY with regard to notifying authorities of an emergency at Indian Point? l l

14. Provi& copies of any and all docments referred to in the answer to Interrogatory 13.
6. Provide copies of any and all documents referred to in the answer to Interrogatory 5.
7. Wat is the position of NY State on the -- --6_nna contained i

in the present estimates of evacuation times for Taiian Point? State all opinions and documents on Wtich the position is hamad and identify the :=m or persons wto familated the opinions anct/ar den =1naarl the doceants.

8. Provide copies of any and all doceents referred to in the aw to Interrogatory 7.
9. Mat is the position of NY 5 tate on the methodologies t#i14W by CX)NSAD Research Cug& tion and by Parsons, Brfr L- heff, Quade & Douglas, Inc.

and in NUREG-0654 in preparing the present estinates of evacuation times fo;.

Indian Point? State all opinions and docunents on which the position is hamad and identify the persCE Or persons We feenilated the opininna and/or develdped the h = nts. i

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- 20. . Interrogatory ii 20 ommited.

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21. What is the position of NY State on the appropriateness i

of the present plune exposure pathway EPZ for Indian Point? State all opinions and h = nts on which the position of 6 tW Stato is based ,

and identify the person or persons who fontulated the opinions and/or Javeloped the doctrents.

22. Provide copies of any and all doctanents referred to in t'm ,

answer to Interrcgatory 21.

23. W at is the position of NY State on tae proviii6n of potassitun iodide to the residents of the EPZ of the Indian Point plants?

State all opinions and hwnts on which the position of NY State  ;

is based and identify the person or persons who fourulated the opinions and/ or developed the doctanents.

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24. Provide copies and any and all doctanents referred to in the '

answer to Interrogatory 23.

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25. mat is the position of NY State on the sheltering capability in the EPZ of the Indian Point plants? State all opinions and h = nts on which the position of NY State is based and identify the person or j persons who fornulated the opinion and/or developed the doctrnents.  ;
26. Provide copies of any and all documents referred to in the answer q (- *'7 *
15. ht is the position of NY Stato on the range of accident scenarios and meteorological conditions taken into account in the emergency plans and proposed protective actions for Indian Point? Specify tie..

FNt scenarios and meteorological canditions that are taken into account in the emergency plans and proposed protective actions for Indian Point.

State all opinions and <h'=mts on which the position of NY Stato is based and identify the person or persms who fornulated the opinions and/or developed the doctanents.

16. Provide copies of any and all docunents referred to in the answer to Interrogatory 15.
17. Does the State have an independent set of standards for what constitutes an acceptable radiation dose resulting from an accident at Indian Point, or does the State adopt the' l

federal standards? Describe and explain fully.

18. Are there any federal radiation standards which the State currently believes are insufficient to protect the public health and safety of the citizens of New York State? Explain.
19. Provide copies of any and all documents referred to in the answer to Interrogatory 17 and 18.

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to Interrogatory 25.~

27. What is the position of NY State on the effect of adverse weather canditicns on the roadway network described in the emergency plans for Indian Point? What weather conditions result in what changes in the evacuation capabilities of the roadway network around Indian Point in the opinion of NY State. State all opinions and hnents on which the position of NY State is based and identify the person or persons who fornulated and/or designed the docunents.
28. Provide copies of any and all hnents referred to in the answer to Interrogatory 27.
29. What is the position of NY State on the es+-ah14ahnent of .

conditions on the licenses of Con Edison and PASNY relevant to evacuation capabilities of the road network around Indian Point? State all opinions documents on which the position of NY State is based and identify the' parson or persons who formulated and/or develop'ed the documents.

30. Please provide copies of any and all docunents referred to in the answer to Interrogatory 29.
31. What is the position of NY State on the feasibility of and need for upgrading tha roadway network at Indian Point to permit successful evacuation of all residents in the EPZ before the plune arrival time? State all opinions ard documnts on which the position of NY State is based and identify the

person or persons @ fmmilated the :qpinions and/or devalmari h=mts.

32. Provide copies of any and all hunants referred to in the answer to Interrogatory 31.
33. Wiat is the position of NY State on the feasibility of and need for tpgrading of the emergency plans for the Indian Point plants to take into account the w i=1 twwin of wi=1 grotps and par +4mlarly those who are dependent on others for their W14ty? What specific measures could and/or should be taken in this respect? Stata all opinions and doctanents on which the position of NY State is Maarl and identify the person or persons who formulated the opinion ancVor dew 1mari the h=nant.
34. Provide copies of any and all hunants referred to in the answer to Interrogatory 33,
35. Wiat is the position of NY State on the faanihility of and need for specific steps to be taken by NBC, State and local officials to p.wube a public awareness that nuclear power plant accidents with substantial offsite risks are possible at Indian Point? Wiat specific steps have been or are ,

being contenplated or considered by NY State ? State all opinions and hunants on which the position of NY State is haaari and identify the person or persons @ fornulated the opinion and/ or dew 1mari the h =nant.

36. Provide copies of any and all doctznents referred to in the answer to Interrogatory 35.
37. What is the position of NY State on the feasibility of and C _ _ . - - _ _ - _ - - - _ _.

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need for the es+-ahliahnent of a neximm acceptable level of radiation  !

l exposure as an objective basis for umawing the Hwmr of energency j planning at Indian Point? &at levels of radiation exposure have been or are being considered by NY State as acceptable in the event of an accidental release of radiaticm? State all opinions and docunents on Wich the positicm of NY State is hamad and identify the person or persons d o formulated the opinion and/or developed the docunent.

-38. Provide copies of any and all atvm_=nts referred to in the answer to Interrogatory 37.

39. Wat is the position of NY State on the feanihility of and need for the emergency planning brochure to give more attention to problens asso"iated with persons who are deaf, blind, too young to understand the instructions, or 20 do not speak English? What specific additional inprovenents are necessary in the simpcy planning brochure in the opinion of NY State in this regard? State all opinions and

+v,= nts on which the position of NY State is hamad and identify the person or persons who fornulated the opinion and/or dewlerad the atv'=nt.

40. Provide copies of any and all docunents referred to in the answer -

to Interrogatory 39.

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41. Provide copies of all reports, draft or final, result-ing from the emergency planning exercise of March 3, 1982 at Indian Point.
42. What is the position of NY State on the performance of the employees and agents of NY State and the four Counties during the emergency planning exercise of March 3, 1982? 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.
43. Is it the State's independent position that the combined off-site emergency plans of the licensees, local and state officials are required to be in full compliance with the emergency planning measures set forth in 10 CFR 50, Appendix E, 10 CFR 50.47 and NUREG-0654, Rev. 1, as a condition of operation for the Indian Point plants?

a.) If yes, does the State believe that the licensees should not be allowed to operate their plants when any component of the emergency plans are not in full compliance?

b.) If no, which planning measures set forth in 10 CFR 50, Appendix E and 10 CFR 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 State?

44. Are there any additional emergency planning requirements the state believes should be imposed upon the Indian Point licensees

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as a condition of operation? Please list and describe fully.

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45. Please indicate upon what independent NY State studies, documents, standards, and criteria the responses to Interrogatories 43 and 44 are based, or whether NY State is relying upon the NRC and/or FEMA positions.
46. Provide copies of any and all documents referred to in the responses to Interrogatory 45.
47. What contacts did NY State have with the utilities and

-their consultants, EDS Nuclear and Parsons Brincherhoff Quade and Douglass, Inc., who wrote the County portions of the NYSRERP?

Please describe these fully, including dates, participants, and content, and provide copies of any and all documents arising out of and about these contacts.

48. What evaluations or reviews of the County portion of the NYSRERP for around Indian Point have been done by NY State, and what person or persons participated in these reviews or evaluations?

Were the raw data or computer models for the plans obtained, eval-uated and independently verified by NY State? If so, by which

-person or persons? Please provide all documents used in answering <

this question.

49. What State Age ' f es, Groups, Departments, and/or Commissions ^

were or are involved in developing coordinating, and maintaining the NYSRBRP? ~1 1

50. Provide all revisions, appendices,. and attachments to the NYSRERP from August, 1981 to date.
51. Continue to provide any further revisions, appendices and attachments to NYSRERP to UCS/NYPIRG throughout current proceeding and until further notice.
52. Provide all contracts and agreements which New York State has entered into with Con Edison, PASNY, Con Edison's and PASNY's consultants, and independent consultants, relating to development, preparation, maintenance, and rr .sion of the NYSRERP.
53. Identify State equipment and personnel available for the following tasks:
a. Verification of radiological releases.
b. Monitoring of radiation plume.
c. Radiation dose assessment.
d. Communications between State Emergency Operations Center (EOC),

and State or other personnel in the field carrying out tasks a-c.

e. Communications between New York State, the Counties involv2d and Con Edison and/or PASNY Emergency Operation Facilities.

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54. Identify location and condition of all equipment mentioned in Question 53.
55. What is the State's estimated deployment time for the

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. State's emergency personnel? Please be specific as to areas of responsibility and geographic location, i.e., how long until monitoring teams reach predesignated sites near or far from the plant, how long will it take for full EOC mobilization in Albany or Poughkeepsie, and so forth?

56. What procedures are in place to notify needed state personnel of a radiological emergency at Indian Point?
57. Describe in detail any changes in these procedures ,

that would follow a declaration of a State of Emergency at Indian Point.

58. Provide all New York State responses to the April, 1981 and December, 1981 FEMA Radiological Assistance Committee's Reviews. In response to this interrogatory provide the following:
a. All revisions to specific portions of NYSRERP which the RAC criticizes.
b. All documents arising out of any response to or comments upon the RAC Review.
59. What memoranda of understanding or any other type of '

letter of agreements exist which explains and outlines each NY State Department or agency's role, including responsibilities and personnel involvement, in any radiological emergency? Please attach copies of all such documents. If these memos are not finalized, please outline what problems remain to be resolved.

60. According to the December 31, 1981 REMA RAC Review of

element J.10.1., the RAC noted the NYSRERP's missing Appendix -

4, prepared by the licensee's consultant, Parsons Brinckerhoff Quade and Douglass. Assuming that the State has received the consultants work, please forward a copy of the consultant's report, and include any other documents that the State has received from the utilities' consultants.

4 61 Provide time estimates for the implementation of all recommendations included in the State 708 Report. Identi fy the sourceof cuch estimates by author, publication and date.

62. Delineate each interim measure the State is taking in order to improve its level of preparedness until all of the recommendations from the State 708 Report are implemented.
63. Provide any available time estimates for the implementation of these interim measures. Identify the source of such estimates by author, publication and date.
64. Provide copies of all legislation or drafts of legislation being proposed to facilitate implementation of all recommendations in the State 708 Report.

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65. List and describe all recommendations of the State delineated in the 708 Report. Number items in this list according to their relative importance for protecting the public health and safety. Start with the most important recommendation and end with the least important.

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66. Which items listed above do the State telieve are

. ' required in order for the utilities to comply with the NRC Emergency Planning _ Regulations and Guidelines.

67. Which items listed above does the State believe are necessary to protect the public health and safety.
68. Provide all drafts and documents upon which preparation of the final 708 Report was based.
69. Is it the State's position that a site-specific consequence study is necessary in order to better predict and plan for emergency planning needs for the Indian Point site?
70. Has the State prepared or is it planning to prepare such a study referred to in the above question. Provide a copy of this study, if complete, or state an estimated timetable for accomplishing such a study.
71. Identify all people upon whom the state of New York or its agents relied in the preparation of the 708 Report. The identification should include the following:
a. What is the person's full name?
b. What is the person's address?
c. What is the person's last known position and business affilia-tion?
d. What is the person's field of expertise?
e. If the person is not a state employee, on what date did NY State first contact or consult the person?

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f. What are the dates of all subsequent contacts or consultations with the person? ,

.g. Were any reports made to NY State by the person?

h. If the answer to question 71g is anything other than a simple negative, indicate for cach 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?
j. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
72. Is the State considering adopting extended Emergency Planning Zones in order to protect the population residing beyond the 10 miles from Indian Point?
73. Is it the position of the State that ad hoc emergency procedures would be adequate to protect the health and safety of populations beyond 10 miles of Indian Point?
74. Is it the position of the State that ad hoc emergency -

procedures would be adequate to protect the health and safety of l the population of New York City should an accident occur at Indian

-Point?

75. Please indicate uhether the State is relying upon NRC and FEMA's positions on this matter or has the State undertaken any independent study to determine whether ad hoc procedures would l

be adequate to protect the health and safety of the population of i

N;w York City. Plon o cupply copioc of cuch ctudios.

76. Itas the State undertaken or does it plan to undertake any systematic study of the New York City's residents in order to determine their likely range of responses in the event of an accident at Indian Point? Provide copies of a such study or planned study.
77. Provide copies of all documents, studies, data, etc.

provided by the State to consultants of the licensees for use in the preparation of the emergency plans for Indian Point, including but not limited to data and information pertaining to the road capacity, traf fic flows, accident patterns and statistics within and beyond the 10 mile Emergency Planning Zone.

78. Provide all notes, reports, documents relating to preparation for and assessments of drills preceding the Indian Point joint exercise of March 3, 1982.
79. Provide all drafts, letters, documents, etc. used in the State's role in the preparation of the scenario, both on and off-site, for the joint exercise of March 3, 1982.
80. What is the State's position and what has it been on the necessity of sounding the sirens during the exercise of March 3, 1982. What is the State's position on adequacy of post'-exercise siren testing?
81. What is the State's position on the adequacy of the

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StOto Emerg:ncy Br:cdccot Syst:a'c performanca during tha March 3, 1982 jcint exercise? .

82. Provide notes, reports, documents, etc. presented in all meetings participated in by the State and its consultants in preparation for and subsequent to the Indian Point exercise of March 3, 1982.
83. What was the total cost to State taxpayers of State officials'and their consultants' participation in all activities relating to the Indian Point exercise on March 3, 19827
84. What is State's position on improvements needed for future exercises at the Indian Point site?
85. Identify all Stato personnel and State consultants who participated in or observed the Indian Point exercises of March 3, 1982. Include their credentials and training.
86. What is the State's position on the intervenors' representatives who oix;ewed the Indian Point exercise of March 3,193z, accordinj 6 tbc term; of the ;stomic Safety and licensing Board. Include in your resconse details regarding s xx.ific effects on the drill, if any, you attribute to the intervenor observors.

87, What modeled information was used by State participants in the exercise as a basis for protective action decisions for the public including " recovery and re-entry" phases both within and outside the 10 mile zone?

88. What is the State's position on adequacy of public

- information brochures at the time of the drill? If found inadequate, what is the State's position on improving their content?

89. What was the timetable for alerting and mobilizing State officials and staff in the exercise?
90. What is the State's position on the adequacy of public and media relations as demons,trated in the exercise and if inadequate, what timetable does it propose to educate the press and public?
91. Has the State developed or does it intend to develop any plans for the decontamination of land and property beyond 10 miles in the event that contamination levels following an accident at Indian Point require such measures? Please provide copies of any such plans or procedures, or a timetable for developing such plans and procedures.
92. Has the State developed or does it plan it develop any specific procedures for providing information and instructions to populations beyond 10 miles for use during a radiological emergency at_ Indian Point? Describe fully and provide all relevant documents.
93. Has the State developed or does the State plan to i develop a public education program for populations beyond 10 miles? Describe fully and provide all relevant documents.
94. Does the State intend to develop emergsncy procedurac for radiation monitoring, public education information, and ,

measures to protect the public beyond 50 miles of Indian Point?

Describe fully and provide all relevant documents.

95. Please provide full information on the professional qualifications, and relevant training of all ir.dividuals with lead responsibilities for developing, maintaining, and carrying out the NYSRERP.
96. With respect to the responses provided by NY State to any of the interrogatories contained in this document, who are the persons upon whose opinions and/or knowledge of facts NY State expects to rely during the Indian Point evidentiary hearings?

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97. 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 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 affiliation?
d. What is the person's field of expertise?
e. If the person is not a state employee, on what date did NY State 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 NY State by the person?
h. If the answer to question 979 is anything other than a -

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simple negative, indicate for each such report:

(1) the date of the report; (2) whether the report was written cr orali 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?
j. What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
98. Provide a reasonable description of all documents that will be relied upon in the testimony presented by each witness.
99. 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-examination of prospective NYPIRG/UCS witnesses testifying in connection with NYPIRG/UCS contentions.

Dated: April Ja,1982 New York, New York h ,

Ll? W 'i 11 Ltn ,

um' ' T1i\ l, ESQ.

'/ / I tl :!dr onofConcerned(

Scientists New York University Law School 323 Vanderbilt Hall 40 Washington Square South ,,

New York, New York 10012 i 212-598-3452 Nei

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HOLT, PIOJECT DIRECIOR Public Interest Researdi i

Group, Inc.

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

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AMANIR POITERFIEID, ESQ. V Counsel for New York Public Interest Research Group, Inc.

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

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. UNITED STATES OF AMERICA , . _ .

NUCLEAR REGULATORY CO MISSION +

'02 iBY -5 f.!0 :51 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CONSOLIDATED EDIS0N COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2)

) 50-286 SP

)

POWER AUTHORITY OF THE STATE OF NEW YORK ) May 3, 1982 (Indian Point Unit 3) )

Certificate of Service I hereby certify that copies of; ME/AUDUBON'S FIRST SET OF INIERROGMORIES AND DOCUMDE RECUESTS 'IO NBC STAFF, INDIAN POINT 2 AND 3 IJCENSEES AND THE NEW YORK STATE ENEPGY OFFICE UCS/NYPIRG FIRST SET OF Ihn2eOGNIORIES AND REUEST MR PRODUCTICE OF DCCUMEIES 'IO CCN ED AND PASNY UCS/NYPIRG FIRST SET OF INfERROGMORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 'IO ROCKIRO COUIEY UCS/NYPIRG FIRST SET OF INTERROGMORIES AND REuldi FOR PRCOUCTICN OF DOCUMDES 'IO NBC STAFF UCS/NYPIRG FIRST SET OF IknaeOGMORIES AND REQUEST FOR PRODUCTICN OF DOCUMDES 'IO h7SICHESTER COUNTY UCS/NYPIRG'S FIRST SET OF INTERROGA'IORIES 'IO AND REQUEST EOR DOCUMENTS FRCM NEW YORK STME ENERGY OFFICE, IN ITS CM CAPACITY AND AS A REPRESDEATIVE OF ALL OIEER NEW YORK STME SUBDIVISIONS, DEPARIMENTS, CC1HISSICNS, AGENCIES, AND CCNSULTANPS IN PTMRSICN OF THE INFORMATICN REQUESTED HEREIN has been served on the official mininun service list for the above captioned prWiog by depositing in the United States mail, first class, this 3rd day of May, 1982, 7

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_ _ _ _ _ . _ _ , ______.________D__.

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.CT4vt Amanda Potterfield, Esq.9 Joar/ lt P.O. Box 384 New( rk Public Interest Research Group, Inc Village Station 5 Street New York, New York 10014 New York, New York 10038 1

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: Docket Nos. 50-247 SP CONSOLIDATED EDISON COMPANY OF 50-286 SP NEW YORK (Indian Point, Unit 2)

POWER AUTHORITY OF THE STATE OF NEWYORK(IndianPoint, Unit 3) )

l SERVICE LIST Docketing and Service Branch Paul F. Colarulli, Esq.

Office of the Secretary Joseph J. Levin, Jr., Esq.

U. S. Nuclear Regulatory Comission Pamela S. Horowitz, Esq.

Washington, D.C. 20555 Charles Morgan, Jr., Esq.

Morgan Associated, Chartered Louis J. Carter, Esq., Chairman 1899 L Street, N.W.

Administrative Judge _ _ _

Washington, D.C. 20036 7300 City Line Avenue Philadelphia, Pennsylvia 19151-Charles M. Pratt, Esq.

- - , - - . - - - Thomas R. Frey, Esq.

Power Authority of the Dr. Oscar H. Paris State of New York Administrative Judge 10 Columbus Circle Atomic Safety and Licensing Board New York, N.Y. 10019 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ellyn R. Weisf Esq.

William S. Jordan, III, Esq.

Mr. Frederick J. Shon Harmon & Weiss Admipistrative Judge 1725 I Street, N.W., Suite 506 Atomic Safety and Licensing Board Washington, D.C. 20006 i U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Joan Holt, Project Director Indian Point Project Janice Moore, Esq. New York Public Interest Counsel for NRC Staff Research Group Office of the Executive 5 Beekman Street Legal Director New York, N.Y. 10038 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John Gilroy, Westchester Coordinator l

Indian Point Project Brent L. Brandenburg, Es.q. New York Public Interest Assistant General Counsel Research Group i f Consolidated Edison Co. 240 Central Avenue  !

of New York, Inc. White Plains, New York 10606 4 Irving Place New York, N.Y. 10003

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Jeffrey M. Blum, Esq. NrcDPNisNsq.

New York University Law School County Attorney

, 423 Vanderbdilt Hall County of Rockland 40 Washington Square South 11 New Hemstead Road New York, N.Y. 10012 New City, N.Y. 10010 i Charles J. Maikish, Esq. Geoffrey Cobb Ryan l Litigation Division Conservation Comittee The Port Authority of Chairman, Director New York and New Jersey New York City Audubon Society One World Trade Center 71 West 23rd Street, Suite 1828 New York, N.Y. 10048 New York, N.Y. 10010 Ezra I. Bialik', Esq. Greatei New York Council on Energy Steve Leipsiz, Esq. c/o Dean R. Corren Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y. 10003 Two World Trade Center New York, N.Y. 10047 . Atomic Safety and Licensing Board Panel Alfred B. Del Bello U.S. Nuclear Regulatory Comission Westchester County Executive Washington, D.C. 20555 Westchester County 148 Martine Avenue Atomic Safety and Licensing 4

, New York, N.Y. 10601 Appeal Board Panel J U.S. Nuclear Regulatory Comission Andrew S. Roffe, Esq. Washington, D.C. 20555 New York State Assembly Albany, N.Y. 12248 Honorable Richard L. Brodsky Member of the County Legislature Renee Schwartz, Esq. Westchester County Botein, Hays, Sklar & Herzberg County Office Building Attorneys for Metropolitan White Plains, N.Y. 10601 Transportation Authority 200 Park Avenue . Pat Posner, Spokesperson New York, N.Y. 10166 Parents Concerned About Indian Point Stanley B. Klimberg P.O. Box 125 General Counsel Croton-on-Hudson, N.Y. 10520 New York State Energy Office 2 Rockefeller State Plaza Charles A. Scheiner, Co-Chairperson Albany, New York 12223 Westchester People's Action 1 Coalition, Inc.

Honorable Ruth Messinger P.O. Box 488 Member of the Council of the White Plains, N.Y. 10602 i City of New York District #4 Alan Latman, Esq.

City Hall 44 Sunset Drive New York, New York . 10007 Croton-on-Hudson, N.Y. 10520

),

Lorna Salzman Mid-Atlantic Representative Friends of the Earth, Inc.

208 West 13th Street New York, N.Y. 10011 Zipporah S. Fleisher West Branch Conservation Association 443 Buena Vista Road -

New City, N.Y. 10956 Mayor George V. Begany Village of Buchanan 236 Tate Avenue Buchanan, N.Y. 10511 Judith Kessler, Coordinator Rockland Citizens for Safe Energy 300 New Hemstead Road New City, N.Y. 10956 David H. Pikus, Esq.

Richard F. Czaja, Esq.

330 Madison Avenue -

New York, N.Y. 10017 l r

Ms. Amanda Potterfield, Esq.

P.O. Box 384 Village Station New York, New York 10014 Mr. Donald L. Sapir, Esq.

60 East Mount Airy Ibad RFD 1, Box 360 Croton-on-Hudson, New York 10520 j i

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