ML20052D202

Friends of the Earth & Ny City Audubon Soc First Set of Interrogatories & Document Requests Directed to Nrc,Licensee & Ny State Energy Ofc

ML20052D202
Person / Time
Site:	Indian Point
Issue date:	05/01/1982
From:	Ryan G, Salzman L AFFILIATION NOT ASSIGNED, FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY
To:	AFFILIATION NOT ASSIGNED, CONSOLIDATED EDISON CO. OF NEW YORK, INC., ESGNYE, NEW YORK, STATE OF, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
EP, ISSUANCES-SP, NUDOCS 8205060357
Download: ML20052D202 (6)

Text

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UNITED STATES OF AMERICA O'; .F

! NUCLEAR REGULATORY COMMISSION

'82 MY -5 m SJ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CONSOLIDATED EDIS0N COMPANY OF NEW YORK ) Docket Nos. 5(J-2 R (Indian Point Unit 2) ) 2  %

POWER AUTHORITY OF THE STATE OF NEW YORK ) May 1, id' 2 * 'C 2m '

(Indian Point Unit 3) ) T .

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FOE /AUDUBON'S FIRST SET OF INTERROGATORIES' d6 g AND DOCUMENT REQUESTS TO NRC STAFF,\rINDIAN' POINT 2 AND 3 LICENSEES AND THE NEW'YORKy ip STATE ENERGY OFFICE Q 'l'I . \

1. a.) Identify by title, author and date of production all studies, reports, investigations, and other doctrients produced, consulted or commissioned by you with regard to possible damage to or contamination of the following within a fifty mile radius as a result of a nuclear accident at Indian Point:

I. Agricultural soils II. Recreational lands and wildlife areas III. Water supplies, including but not limited to, streams, rivers, reservoirs and wetlands.

IV. Private and public buildings including but not limited to homes, schools, hospitals, places of worship, businesses and tactories.

V. Means of transport including but not limited to roads, bridges, tunnels, cars, trucks, trains, j railways, ships, ports, airplanes-and airports. $D - l A

8205060357 820501 PLR ADOCK 05000247 C PDR

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m. i VI. Utility systems and fuel supplies.

VII. Crops, livestock, packaged and processed foods.

VIII. Household and consumer goods including but,not limited to clothing, furnishings, appliances and. personal items.

IX. Wildlife b.) For each item listed in response to the request above, please attach a copy if available without charge, or if unavailable, state place and time at which said item may by inspected and copied.

2. a.) Identify by title, author and date of production all studies, reports, investigations or other documents known to you, discussing, proposing or further elaborating upon plans for monitoring the types, levels and geographic extent of radioactive contamination of the materials listed in Interrogatory 1(a) above.

b.) For each item listed in response to request 2(a) above, please attach a copy if available without chargo, or if unavailable, state place and time at which said item may be inspected and copied.

3. a.) Describe all medical and scientific procedures considered or proposed by you or any consultants or experts with whom you have communicated or received information that would be used to treat humans who have been exposed to radioactivity or have ingested radioactive materials as a result of an accident at Indian Point.

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.g a b.) Identify specifically the locations, facilities and personnel that would be available for treatment identified in' response to 3(a) and indicate as accurately as possible the capacity of such facilities.

c.) If documents are cited in response to requests 3(a) or 3 (b) above, please append a copy of the relevant pages if availabe without charge, or provide a concise summary of the pertinent portions of said documents.

4. a.) Describe all procedures that you or any-experts with whom you have communicated have considered or proposed with regard to the decontamination of each of the materials listed in Interrogatory 1(a) above.

b.) Identify _specifically the equipment that would be available and the personnel that would be responsible for carrying out procedures described in the response 4(a) above.

c.) If documents are cited in response to requests 4(a) or 4 (b) above, please append a copy of the relevant pages if available without charge, or provide a concise summary of the pertinent portions of said' documents.

5. a.) Identify the location, size and nature of all sites considered or proposed by you or any experts with whom you have communicated for the use of storage or disposal of materials contaminated as a result of an accident at Indian Point.

b.) Describe specif.cally any plans within your knowledge

or under . consideration by you or your consultants with regard to:

I. Transport of contaminated materials to the sites.

e II. Types of structures that would be used for the containment of contaminated materials.

III. Care and maintenance of the sites.

c.) If documents are cited in response to 5 (a) or i

5 (b) above, please append a copy of the relevant pages if available without charge, or provide a con-  !.

I cise summary of the pertinent portions of said l t

documents.

6. a.) Describe all estimates within your knowledge of

the time that would be required to decontaminate

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radioactive objects and sites sufficiently to resume normal use and access by human beings without posing

a threat to their health and safety. .

b.) If estimates cited in response to request 6(a)  !.

I above are based upon any studies, reports, investi-gations or other documents, please append a copy of the relevant pages, or provide a concise summary of i the pertinent portions of said documents. i

7. a.) Identify by title, author and date of production

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all studies, reports, investigations and other docu- '

monts produced, consulted or commissioned by you with regard to:

I. The dif ficulties of emergency evacuation posed by the existing network of roadways in Westchester and Rockland counties.

II. The possibilities of mitigating these' difficulties '

by expanding, improving or upgrading roadways.

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b.) For each' item listed in response to request 7(a) l

above, please attach a copy if available without charge, or if unavailable, state place and time at which said item may be inspected and copied.

c.) For each item listed in response to request 7(a) above, state specifically the page numbers where said difficulties and possibilities are discussed.

8. a.) Identify by name any witnesses you plan to have testify at the hearings with regard to any aspect of on-site or off-site emergency planning procedures, or any other matter pertinent to Commission Questions 3 or 4.

b.) Provide the following information with regard to '

the witnesses identified in 8(a) above:

i.

I. Address  :

t II. Occupational title

III. Place of employment I IV. Business address and telephone number i V. Times within your knowledge at which said I witnesses will be available for deposition.

c.) State briefly the matters about which each witness ]

identified in request 8(a) is expected to testify. l 1

a

k. . - , _

May 3, 1982 New York, New York '

Respectfully submitted, Lorna Salzman, Mid-Atlantic Director Friends of the Earth, Inc.

f

/l[ l Geoffrey Cobb Rybn, Directob W

New York City Audubon Society, Inc.

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