ML20052D246

Interrogatories in Response to ASLB 820423 Memorandum & Order.Permission to File Addl Interrogatories After 820503 Deadline Requested.Related Correspondence

ML20052D246
Person / Time
Site:	Indian Point
Issue date:	05/03/1982
From:	Scheiner C WESTCHESTER PEOPLES ACTION COALITION, INC.
To:	PORT AUTHORITY OF NEW YORK & NEW JERSEY
References
EP, ISSUANCES-SP, NUDOCS 8205060399
Download: ML20052D246 (3)

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i * . REINIEUCO k-' UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION g l ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: 22 /My -S l Louis J. Carter, Chairman AlllJY)

Mr. Frederick J. Shon 2 Dr. Oscar H. Paris '. . -

_w In the Matter of  !

Consolidated Edison Company of  ! Docket Numbers50-247SP New York (Indian Point Unit 2)  !50-286SP Power Authority of the State of  ! May 3, 1982 ,- g New York (Indian Point Unit 3)  ! - - n

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, , 1 WESPAC'S INTERR0GATORIES FOR {

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THE PORT AUTHORITY OF NEW YORK AND NEW ' JERSEY' [iiUf" [j

$71.l ?

On April 23, 1982 the Atomic Safety and Licensing Board issued a Memorandum and Order Formulating Contentions, Assigning Intervenors, and ,

Setting a Schedule for the above-captioned proceeding. The Board ordered that formal discovery was to begin on April 26, and that all interroga-tories on " matters under Conunission Questions 3 and 4" be filed by May 3, although " discovery on matters to be heard later than the week of June 22 shall continue." (Board 4/23 order at 22, footnote 5). WESPAC received this order on the evening of April 28, two working days before the filing deadline.

WESPAC hereby requests that the Port Authority of New York and New Jersey answer each of the following interrogatories in accordance with the foregoing and in line with the Federal Rules of Civil Procedure as soon as possible, but in no event later than May 31, 1982.

1. List any transportation- facilities (including railroads, automobile 93 roads, highways, airports, bridges, tunnels, or other parts of a road i network) under the jurisdiction of the Port Authority that are wholly jQ or partly within Westchester or Putnam County. Where facilities are -

run by other agencies but are related to the Port Authority, include them.

8205060399 B20503 '

PDR ADOCK 05000247 G PDR

%. . ;s b WESPAC INTERR0GATORIES FOR PORT AUTHORITY PAGE 2

2. Indicate which, if any, of the items listed in (1) are within the currently-defined Emergency Planning Zone for Indian Point.

3. Indicate which, if any, of the items listed in (1) are involved in any of the evacuation routes for the Indian Point Radiological Emergency Plan.

4. Supply copies of any reports, telephone calls, memoranda, or other I communication between the Port Authority and PASNY, Con Edison, the Four-County Nuclear Safety Committee, or the two consultants (Parsons, Brinkerhoff, Quade, & Douglas and EDS Nuclear) relative to the use of MTA facilities in the offsite emergency plan. Such reports should include at minimum the following:

(i) Any information requested as to road capacity, traffic control i personnel, and other transportation network data, whether or not the Port Authority was able to supply it, and the Authority's response.

(ii) The requirements for Authority personnel to participate in j emergency response.  ;

(iii) Training of At.thority personnel as to their roles in emergency I response to an Indian Point accident.  !

5. Please list all closings or delays in the Port Authority facilities .i listed in (2) or (3) due to construction, breakdowns, labor actions, operator error, or adverse weather for the past five years. Include the cause, I effect, and duration of the disruption of service.

Indicate what steps were taken to compensate. If the records are  ;

available, list all such closings since 1962, the year Indian Point  ;

Unit 1 began operation. l

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1. ' WESPAC INTERROGATORIES FOR PORT AUTHORITY PAGE 3

6. For the Trans-Hudson crossings under Port Authority Control (George Washington Bridge, Holland Tunnel, and Lincoln Tunnel), give the number of cars per lane per hour for normal and peak traffic times.

How much does one lane blockage affect that number? If an accident at Indian Point were to cause self-evacuation from Manhattan which would double the normal number of cars using these facilities above an average rush hour, how long would it take for this number of cars to cross the river? Please provide the methodologies and/or references used in making these calculations.

6. Is the Port Authority confident that the transportation facilities it is involved with would perform satisfac- torily in the event of an accident at Indian Point? If not, what improvement would the Authority like to see?

Respectfully Submitted, T I Charles A. Scheiner Co-Chairperson Westchester People's Action Coalition, Inc.

P.O. Box 488 White Plains, New York 10602 914/682-0488 May 3, 1982 J

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