ML20052E569

Interrogatories Directed to Con Ed,Pasny,Nrc & Ny State Energy Ofc.Certificate of Svc Encl.Related Correspondence

ML20052E569
Person / Time
Site:	Indian Point
Issue date:	05/03/1982
From:	Kessler J ROCKLAND CITIZENS FOR SAFE ENERGY
To:	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 8205110238
Download: ML20052E569 (8)

Text

?

f( SEIATED CORBMMEC UNITED STATES OF APIRICA  ! ."! FF E t MUCLEAR REGULATORY CorciISSIni -"' ^

ATOMIC SAFETY MID LICENSING BOARD ec 2 .3.M, -7 91 :,,

Before Administrative Judges:

Iouis J. Carter, Chairman

~~

g Dr. Oscar H. Paris (

Frederick J. Shon In the Matter of )

) Docket :;os.50-247-SP CONSOLIDATED EDISON CO:!PNIY OF ) 50-286-SP NEW YORK (Indian Point Unit No.2 )

) D POWER AUTHORITY OF THE STATE OF )

May 3, 19 O NEW YORK (Indian Point Unit No.3 )

> RECEEVED MAY101982w '

'p; mw er. - == [m nArntiuRIMis -

INTERROGATORIES GE: f OF OL A y.

,y, ROCKI AND CITIZENS FOR SAFE EN'ERGY Oy j , g-Pursuant to 10 C.F.R. 2.740, Intervenor Rockland Citi: ens for Safe Energy (hereinafter referred to as RCSE) requests that t.hese interrogatories be answered fully in writing and under oath by any enplcyees or representa-tives of Consolidated Edison Company and Power Authority of the State of New York (the Licensees), of the NRC Staff, and of the New York State Energy Office who have personal knowledge of the facts and issues in cuestion. Each of the parties named is requested to answer all of the interrogatory. The l

answer to each interrogatory should contair. the name anci identification of each Derson supplying or contributing to the answer, whether or not he or she has verified the answer. The answer should also explain the rcle of each individual i in preparing the answer.

l DEFINITIONS NID INSTRUCTIQlS l

i I Unless otherwise indicated, the following definitic:ns shall apply to t

these interrogatories:

I l (1.) The Licensees shall include not only con Eciiscn and the power i

Authority, but also all agents, employees, attorneys, i=vestigators, contract-l -

820511023882050f7 DR ADOCK 05000g l _ _

PDR 0 $lI l

l l

\

ors and all other persons directly or indirectly subject to the control of i

)

the Licensee, especially including any contractors specifically hired to pre-pare any emergency planning material.

(2.) The word " person" or " persons" shall mean, without limitation, all entities, including any predecessors in interest, individuals, associations, companies, partnerships, joint ventures, corporations, subsidiaries, depart-ments, bureaus, public agencies and boards.

(3.) " Documents" shall mean all written or recorded material of any kind or character known to the parties or in the possession, custody or control, including, but not linited to letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records of notations of tele-phone or personal conversations or conferences, interoffice communications, microfilm, bulletins, circulars, pa.tphlets, studies, notices, summaries, reports, books, articles, worksheets.

(4.) When used with respect to a document, " identify" means, without limitation, to state its date, type of document, the author and addressee, the present location and custodian, and a description of its contents.

(5.) When used with respect to a person, " identify" means, without limi-tations, to state his or her name, address, occupation and professional qualifications.

! (6.) If any of the information contained in the answer to any of these interrogatories is not within the personal knowledge of the person signing the responre to that interrogatory, so state and identify each person, document f and communication on which he or she relies for the information contained in  :

E the answers not based solely on personal knowledge. t 5

(7.) If the party cannot answer a portion of the following interroga-tories in full after exercising full diligence to secure the information to do [

I so, so state and answer to the extent possible specifying the inability to an-  :

F swer the remainder and stating when the party expects to be able to answer the f r r i

I

, unancwer d porticna.

(8.) These interrogatories are continuing interrogatories and reauire supplemental answers if the party obtains further information between the time the answers are served and the time of an initial decision in this proceeding.

INTERROGATORIES (1.) Please state the party's position with respect to each of RCSE's contentions 3.1, 3. 3, 3. 4 , 4 . 2 and 4 . 7 .

(2.) With respect to each of RCSE's contentions, please (a.) ider;tify each person whom the party expects to call as an ex-pert witness concerning the contention; (b.) state the subject matter on which the expert witness is ex-pected to testify; (c.) state the substance of the fact and opinion to which the expert witness is expected to testify and summarize the grounds for each opinion; (d.) identify all documents relied upon or examined by the expert witness in answering (c.) above; (e.) identify all documents not identified in response to (d.)

above which the expert witness expects to put into evidence or to rely upon in support of his or her testimony in this proceeding.

(3.) Please identify all other persons whom the party expects to call as witnesses concerning the issues raised by the RC3E contentions and in response to Commission questions 3 and 4. Please answer interrogatory (2.) (a.) through (e.) with respect to each potential witness identified by the party in response to this interrogatory.

(4.) Uith respect to all persons identified by the party in response to interrogatory (2) and (3) above, please (a) provide a complete bibliography of all articles, books or

scholarly works published or presented by each person, including a brief description of the substance of each; (b) identify and provide appropriate citations for all proceedings 4

in which the person has previously. appeared as a witness .

(5.) Identify all documents that the party expects to introduce into evi-dence or to use for impeachment or other cross-examination purposes in this proceeding other than those identified in response te other interrogatories.

(6.) What equipment, manpower and training shortfalls does Rockland County have with respect tc compliance with 10 C.F.R. 50.47 b(6) and (7) and NUREG 0654 Sec. II F and II G? What equipment, manpower and training would be needed by Rockland County to comply with 10 C.F.R. 50.47 . (b) (6) and (7) and NUREG 0654 Sec. II F and II G? Please identify any and all deficiencies in com-plying with the evaluation criteria of NUREG 0654 Sec. II F and II G with res-pect to Rockland County.

(7.) With respect to contention 3.3, please provide a listing of all evacuation plan estinate studies done by CONSAD Research Corporation and Parsons, Brinckerhoff, Quade and Douglas, Inc., and any other time estimate studies done for the Indian Point site, any working papers and documents per-

! taining to these studies, and updates of the studies, including the date of i

all such documents and updates. The NRC Staff is requested to provide a copy of the aforementioned documents to RCSE without charge.

(8.) Please identify which version, if any, of the Rockland County Radio-logical Emergency Response Plan was relied upon in each of the studies or up-dates. Please identify what studies were made of traffic patterns immediately outside of the 10 edleEPZ and of their effects upon traffic egress from the i

10 mile EPZ. Pleate identify the " level of service" assumptions used in com-puting the evacuation time estimates in any known studies and the reasoning for selection of those levels of service in Rockland County.

(9.) Please identify all bottlenecks revealed by any evacuation time

s estimate studies done for Rockland. State any time estfrates that have been computed regarding traffic flow that does not progress in the optimal manner according to the plan.

(10.) Please state the date and time of any and all events which would be classified as unusual events, site alerts, site emergencies or general energencies under current regulations in the operating history of Units 2 and 3. For each of the preceding events, state whether and at what exact time Rockland County and others were notified officially of the event and of its nature. Please supply all documents pertaining to the NRC investigation of the October 1980 fan cooler leak accident.

(ll.) Please identify any studies on sheltering capability within the EPZ in Rockland County. Please identify any standards known for sheltering fac-tors in radiological emergencies. It is requested that the NRC Staff provide any documents and testimony related to sheltering and air turnover rates in buildings.

(12.) tirnat proportion of the population within the Rockland County EPZ is known to be deaf, blind, too young to under stand instructions in the Emer-gency Planning brochures or unable to speak English? What special provisions have been taken to inform these populations of an emergency?

Respectfully submitted, k/ *

) '

udith Kessler, Coordinator Rockland Citizens for Safe Energy 14ay 3,1982

UNITED STATES OF AMERICA @jp NUCLEAR RCGULA'IORY Co!CIISSIG; ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judgest

'g g NI .*44 Louis J. Carter, Chairman ,_ ,_

Dr. Oscar H. Paris /i, Frederick J. Shon " , _

• if , :,i In the Matter of )

)

CONSOLIDATED EDISON CCMPANY OF ) Docket Nos. 50-247-SP NEW YORK (Indian Point Unit No. 2) ) 50-286-SP

)

POWER AUTHORITY OF THE STATE OF )

NEW YORK (Indian Point thit No. 3) ) May 3, 1982

)

CERTIFICATE OF SERVICE I hereby certify that I have served copies of INTERROGATORIES oF ROCKLAND CITIZENS FOR SAFE ENERGY on the following parties by first class mail, postage paid, this third day of May, 1982:

Louis J. Carter, Esq., Chairman Janice Moore, Esq.

Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Board Office of the Executive 7300 City Line Avenue Legal Director Philadelphia, Pennsylvania 19151 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Frederick J. Shon Administrative Judge Brent L. Brandenburg, Esq.

Atomic Safety and Licensing Board Assistant General Counsel U.S. Nuclear Regulatory Commission Consolidated Edison Company 20555 of New York, Inc.

Washington, D.C.

4 Irving Place New York, New York 10003 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing Board Ellyn R. Weiss, Esq.

William S. Jordan, III, Esq.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Harmon and Weiss 1725 I Street, N.W., Suite 506 Docke, ting and Service Branch Washington, D.C. 20006 Office of the Secretary U.S. Nuclear Regulatory Commission Charles A Scheiner, Co-Chairperson 20555 Westchester People's Action Washington, D.C. Coalition, Inc.

Joan Holt, Project Director P.O. Box 488 Indian Point Project White Plains, New York 10602 New York Public Interest Research Alan Latman, Esq.

Group 5 Beekman Street 44 Sunset Drive New York, New York 10038 Croton-On-Hudson, New York 10520

4 .

John Gilroy Ezra I. Bialik, Esq.

Westchester Coordinator Steve Leipzig , Esq.

Indian Point Project Environmental Protection Bureau New York Public Interest Research New York State Attorney Group General's Office 240 Central Avenue Two World Trade Center White Plains, New York .

10606 New York, New York 10047 Jeffrey M. Blum, Esq. Alfred B. Del Bello New York University Law School Westchester County Executive 423 Vanderbilt .all .

Westchester County

~ 40 Washington Square South 148 Martine Avenue New York, New York 10012 White Plains, New York 10601 Charles J. Maikish, Esq. Andrew S. Roffe, Esq.

Litigation Division New York State Assembly The Port Authority of New York Albany, New York 12248 and New Jersey One World Trade Center Marc L. Parris, Esq.

New York, New York 10048 Eric Thorsen, Esq.

County Attorney ,

County of Rockland Pat Posner, Spokesperson 11 New Hempstead Road Parents Concerned About Indian New City, New York 10956 Point P.O. Box 125 Stanley B. Klimberg, Esq.

Croton-on-Hudson, New York 10520 General Counsel Renee Schwartz, Esq. New York State Energy Office Botein, Hays, Sklar and Herzberg 2 Rockefeller State Plaza Attorneys for Metropolitan Albany, New York 12223 Transporation Authority 200 Park Avenue I Atomic Safety and Licensing New York, New York 10166 Board Panel U.S. Nuclear Regulatory Commission Honorable Ruth W. Messinger Washington, D.C. 20555 Member of the Council of the City of New York Atomic Safety and Licensing District #4 Appeal Board Panel City Hall U.S. Nuclear Regulatory Commission New York, New York 10007 Washington, D.C. 20555 Greater New York Council Honorable Richard L. Brodsky on Energy Member of the County Legislature Westchester County c/o Dean R. Corren, Director County Office Building New York University White Plains, New York 10601 26 Stuyvesant Street New York, New York 10003 Zipporah S. Fleisher Geoffrey Cobb Ryan West Branch Conservation Conservation Committee Chairman Association Director, New York City 443 Buena Vista Road New City, New York 10956 Audubon Society 71 West 23rd Street, Suite 1828 New York, New York 10010 M yor George V. Begany Village of Buchanan 236 Tate Avenue Buchanan, New York 10511

~

f~ 7.. .

m4_' -' '

...[* ,' ' , M ***' ,.# ,N '

M " " *

$*- '* , *- .f" -

.[

p

• 4 f.7 q ,

Paul F. Colarulli, Esq. David H. Pikus, Esq.

Joseph 3. Levin, Jr., Esq. Richard F. Czaja, Esq.

Pamela S. Horowitz, Esq. 330 Madison Avenue Charles Morgan, Jr., Esq. New York, New York 10017 Morgan Associates, Chartered 1899 L Street, N.W. Ms. Amanda Potterfield, Esq.

Washington, DC 20036 ,

P.O. Box 384 i Village Station Charles M. Pratt, Esq. New York, New Yorx 10014 Thomas R. Frey, Esq.

Power Authority of the State of New York 10 Columbus Circle Lorna Salzman New York, NY 10019 Mid-Atlantic Representative Friends of the Earth, Inc.

205 West 13th Street New York, New York 10011 Respectfully submitted, d$f} d.Cb?- ~

Jtfdith Kessler, Coordinator Rocklan:1 Citizens for safe Energy l Huntsville, Alabama May 3, 1982 l

l I

\ _ ._ _