ML20052D217

First Set of Interrogatories & Request for Production of Documents Directed to Utils,Per ASLB 820423 Memorandum & Order.Certificate of Svc Encl.Related Correspondence

ML20052D217
Person / Time
Site:	Indian Point
Issue date:	05/03/1982
From:	Toscani K PARENTS CONCERNED ABOUT INDIAN POINT
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK, WESTCHESTER COUNTY, NY
Shared Package
ML20052D213	List: ML20052D212 ML20052D217
References
EP, ISSUANCES-SP, NUDOCS 8205060372
Download: ML20052D217 (9)

Text

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. RELATED CORRESPO.VDN UNITED STATES OF AMERICA E3fE3E ,

NUCLEAR REGULATORY COMMISSION 82 GY -5 N1:t6 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD __

In the Matter of )

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CONSOLIDATED EDISON COMPANY OF NEW YORK) Docket Nos. 50-247 SP (IndianPointUnit2) ) 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point Unit 3) )

PARENTS CONCERNED ABOUT INDIAN FOINT'S FIRS? SET OF REU PRODUCTION OF DOCUMENTS AND INTERROGATORIES Pursuant to the rules of the Atomic Sefety and Licensing Board of the Nuclear Regulatory Commission, please respond to the reonest ,

for production of documents and the interrogatories by May 31, 1982. .

Recuest

1. for Production of Documents to con Edison /PASNY Please make available each draft of the evacuation clan trior to the present plan and all documents used to draw it up at the home ofNew on-Hudson, KathyYorkToscani 10520 at 15 Finev Point Avenue, Croton-on May 13, 1982, 9 a.m.

Interrogatories to be Answered by Con Edison /PASNY $

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1. e Submit stntistics cnd procedures used to determine the number of i people to be efacuated by bus within the 10 mile EPZ.

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Identify each bus company and the number of buses available to- 6 participate in an evacuation of school children and trans-portation-dependent 8

5 children and adults in the 10 mile EPZ. ]

3 2 How did you determine how long it would take for buses to j evacuate school children portation-dependent and then return to evacuate the trans-population? s E

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4. 55 Submit will contracts guarantee the between bus drivers and bus comnanies which U p nuclear emergency. particination of bus crivers in case of a =

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Submit contreets between the bus companies and the utilities E in case county and/or to ensure of a nuclear the particitation of the bus companies emergency. @

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Pag,3 2 Request for Production of Documents and Interrogatories by Parents Concerned About Indian Point May 3, 1982 6.

Identify bus drivers who live within the 10 mile EPZ and who have contracted to drive buses in case of an emergency. Inclub their addresses.

7. Identify all bus drivers whollive outside the 10 mile EPZ who

'have contracted to drive buses in case of an emergency. Include their addresses.

8. What procedures have been taken to insure that bus drivers living outside the 10 mile EPZ will be allowed inside the 10 mile EPZ?'

9. ?ihat procedures have been taken to insure that bus drivers can be activated during an evacuation?

10.

What procedures have been taken to insure that all buses are maintained and available 100% of the time?

11.

Have con Edison after school while/EASNY identifiedwork?

their parents children who are home alone (a) if so, describe the procedure by which such children have been identified and the number and ages of such ' children in the 10 mile EPZ.

(b) if not, set forth any procedures which will be used to identify and safely evacuate these children should evacuation become necessary.

12. Submit all studies, research, exnert testimony, etc. which shows thatcapability cal children under 18 have to evacuate the mental, emotional and psychologi-themselves.

13 Has Con Edison /PASNY identified those children home unsupervised g after school who are handicapped? If so, submit such statistics.

14. Has Con Edison /PASNY identified the number of children in g various programsT c,upervised after school athletic, religious nnd culturd .

(a) if so, state the programs and number of children enrolled d in each. h (b) state the responsibility of the nault in charge of each =

program programs.

in terms of evacuating the children in their (c) stateinstructed.

the method by which these persons have been identified =

and E (d) have these adults and/or organizations submitted their q plans for the evacuation of their children?' h)

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Pa&Q 3 3R:ou;st for Production of D'oeuments and Interrogatorics by Parcnts Conecrnca About Indian Point May 3, 1982 15 Submit any studies and/or partinent research which nas used to determine that the format of the cmergency planning booklet and the information given is sufficient to prepare the unblic for an evacuation.

16.

16. Submit any studies which were used to determine whether the general public has the literacy level and map skills necessary to read the directions, follow the directions and read the maps in the emergency planning booklet.

17~. . What mailing list (s) was used to identify who would receive the emergency planning booklets?

18. What procedures have been set up to ensure that newconers receive emergency planning booklets?

19. . Describe procedures and submit statistics used to identify and give emergency planning information to illerate adults and non-

'20. Identify physically disabled persons who are to receive suecial provisions as per page 8 in the emergency planning booklet.

21. Submit evidence that the emergency planning booklet has been received, read and understood by every person in the 10 mile EPZ.

22. Why was a three day figure suggested in the emergency n1anning booklet to plan for in case of a urolonged radiation release?

How was this figure arrived at?

23 Identify all people who particiuated in responding to each interrogatory by name, title and business address.

24. Identify any documents utilized in answering interrogatories by title, date author and recipient.

25 What are your procedures for informing reception centers, school reception centers and congregate care centers as to their role and responsibility during an evacuation?

26. What is your procedure for an on-going evaluation of the status of the reception centers, school reception centers, and con-gregate care centers?

27 What are your procedures for informing new personnel at receution centers, school reception centers and congregate care centers as to their role and responsibility during an evacuation?

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H quest for,pr: duction of Documsnto and Interrogatoriec by par:nts Conecrned about Indian point M y 3,1982

28. What are your procedures for informing the Red Croos as to its role and responsibility during an evacuation?

29 What are your procedures for determining whether Red Cross ' ,

personnel are adequately trained in decontamination urocedures? l

30. Submii3our procedures for determining whether Red Cross personnel are adeauately trained to recognize and treat radiation sickness.

31. Submit evidence that reception centers have decontamination eauip-ment.

32. Submit evidence that you will have on-going evaluations of decon-tamination equipment.

33 Describe procedures used to determine whether sunplies for a prolonged stay are at the congregate care centers' or not.

If not, why do you feel these supplies are unnecessary?

34 Identify procedures used to determine how many Red Cross personnel would be necessary to accomodate the number of evacuees.

35 What were your procedures for determining how many evncuees would need the services of the congregate core center?'

36. What is your program for informing new bus drivers as to the location and routes to schools to be evacuated, school recention centers and congregate care centers?

37. What were your trocedures for determing whether school reception centers con evacuate their population in sufficient time to allow evacuees to enter?

38. Have you identified the short-term effects of radiation poisioning?

If so, what are these effects?

39 Have you identified radiation disaster training for the teachers who are chcrged with the care of school children in the school?

On the buses? At the host centers?

40. Have manuals been devised to inform and train teachers in deeling with the physiological symptoms of radiation voisoning?

41. Have manuals been devised to inform and train teachers how to deal with the psychological problems of children under extremely stressful situations?

42. Have you identified how children react in stressful situations?

Show evidence of that and how adults, esnecially teachers, react in stressful situations.

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, Rcquast for,yroduction of Documents and Interrogatorios

. by parents Concerned About Indian point May 3, 1982

43. Submit contracts between yourselves and the teachers within the 10 mile EPZ obliging them to accompany the evacuating children-on the school buses.and to stay with the children once at the host centers.

44. Submit evidence that you have made supplies available to the teachers for administering radiation disaster treatment.

45. Have you any evidence detailing the ability of teachers to administer radiation disaster treatment if they themselves are suff.ering from radiation poisoning.

46. Have you identified any information proving distressed and dis-tracted teachers' abilities to care for their school children,

- when their own children are in serious danger at a different location within the 10 mile EPZ?

Interrogatories to be Answered by Westchester County

1. Identify and submit names and addresses of family dqf care homes in the Westchester County section of the EPZ.

2. How many children are in family day care in the Westchester County section of the EPZ.

4 Res tfully ,yubmitted, 0

fahy/h'oscaniM4tlQg[

P. O. Box 125 Croton-on-Hudson, N.Y. 10520 Service List attached 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ~~~ !E C ~'

AR EU "#0 BEFORE THE ATOMIC SAFETY AND LICENSING tr:

Ii?. ; - -

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 )

. (Indian Point Unit 3) )

1. Dated: May 3, 1982

2. Heading: Certificate of Service 3.

Introduction:

I hereby certify that copies of PARENTS CONCERNED ABOUT INDIAN POINT'S FIR 3T SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES have been served on the following by denosit  ;

in the United States mail, first class, this 3rd day of May,1982.

Louis J. Carter, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Vlashington, D. C. 20555 Mr. Frederick J. Shon Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Brent L. Brandenburg, Esq.

Assistant General Counsel l Consolidated Edison Co. of New York Inc.

4 Irving Place New York, N.Y. 10003

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Pag 2 d;rtificatoofScuvicelisth o . .- ,

Paul P. Calarulli, Esq .

Joseph J. Lefin, Jr., Esq.

Pamela S. Horowitz, Esq.

Charles Morgan, Jr., Esq.

Morgan Associates, Chartered 1899 L Street, N.W.

Washington, D. C. 20036 Charles M. Pratt, Esq.

Thomas R. Frey, Esq. -

Power Authority of the State of New York 10 Columbus Circle New York, N.Y. 10019 Ellyn R. Weis, Esq. ,

William S. Jordan, III, Esq.

Harmon & Yteiss 1725 I Street, N.W., Suite 506 Washington, DC 20006 Joan Holt, Project Director Indian Point Project New York Public Interest Research Group 5 Beekman St. '

New York, N.Y. 10038 Charles A. Scheiner, Co-Chairperson Westchester People's Action Coalition, Inc.

P. O. Box 488 White Plains, N.Y. 10602 Alan Latman, Esq.

44 Sunset Drive Croton-on-Hudson, N.Y. 10520 Lorna Salzman Mid-Atlantic Representative Friends of the Earth, Inc.

208 #est 13th Street New York, N.Y. 10011 Zipporah S. Pleisher West Branch Conservation Association 443 Buena Vista Road New City, N.Y. 10956 Docketing and Service Section office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20535 Mayor George V. Begany Village d Buchanan 236 Tate Avenue .

Buchanan, N.Y. 10511 3 .y ,+ s o

paga 3 dortificatoof Sarvico Lioti

- I Judith Kccs1cr, Coordinator Rockland Citizens for Safe Energy 300 New Hempstead Rodd New City, N.Y.10956 Jonathan L. Levine, Esq.

Rockland Citisens for Safe Energy P. O. Box 74 New City, N.Y.10956 Marc L. Parris, Esq.

County Attorney .

County of Rockland 11 New Hempstead Road New City, N.Y.10956 i e

Geoffrey Cobb Ryan B Conservation Committee Chairman, Director g New York City Audubon Society 3 j

71 West 23rd St., suite 1828 New York, N.Y.10010 3 i

Greater New York Council on Energy c/o Dean R. Corren, Director Fe New York University $

26 Stuyvesant Street 8 New York, N.Y.10003 Atomic Safety and Licensing Board Penel U. S. Nuclear Regulatory Commission 'T

.7ashington, D. C. 20555 d

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Atomic Safety and Licensing Appeal Board Panel C U1 S. Nuclear Regulatory Commission E Washington, D. C. 20555 15

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tw Honorable Richard L. Brodsky 5 Member of the County Legislature y W0stchester County 5;g County Office Building $

White Plains, N. Y. 10601

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John Gilroy, .Vestchester Coordinator  :=:S Indian Point Pro ject ii N:w York Public Interest Research Group @

gg 240 Central Avenue =$

White Plains, N.Y. 10606 "

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Jeffrey M. Blum, Esq.

N;w York University Law School F.:==-

ME 423 Vanderbuilt Hall 5, 40 Washington Square South !E N;w York, N.Y.10012 E5%

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. , PGg 4 d:rtificato of Scrvico Listi

. Charloo J. Maikish, Esq.

Litigation Division The Port Authority of New York and New Jersey One World Trade Center New York, N.Y. 10048 .

David H. Pikus, Esq.

Richard F. Czaja, Esq.

330 Eadison Avenue New York, N.Y. 10017 E=r.a I. Bialik, Esq.

Steve Leipsiz, Esa.

Environmental Protection Bureau New York State Attorney General's Office Two World Trade Center New York, N.Y. 10047 Alfred B. Del Bello

'Vestchester ' County Executive Westchester County 148 Eartine Avenue White Plains, N.Y. 10601 Stanley B. Klimberg -

General Counsel New York State Energy Office 2 Rockefeller State Plaza

. Albany, N.Y. 12223 Honorable Ruth Messinger Member of the Council of the City of New York '

District #4 City Hall New York, N.Y. 10007 Janice Moore, Eso.

Counsel for NRC Staff Office of the Executive Legal Director U. S. Nuclear Regulatory Commission

?Inshington, D. C. 20555 Andrew S. Roffe, Esc..

New York State Aseembly Albany, N.Y. 12248 Ms. Amanda Potterfield, Esq.

P. O. Box 384 Village Station .

New York, N.Y. 10014 Margaret Oppel, Esq.

Larens R. Schwartz, Esq.

Paul Chessin, Esq.

Renee Schwartz Esa.

Botein, Hays, Sklar & Herzberg 200 Park Avenue New York, N.Y. 10166