Text

Response to Licensee Interrogatories
	ML20053A395
Person / Time
Site:	Indian Point
Issue date:	05/18/1982
From:	Hartzman R, Miles J, Salzman L; FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY
To:	; CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
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ML20053A390	List: ML20053A389; ML20053A395;
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	ISSUANCES-SP, NUDOCS 8205260051
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Louis J. Carter, Chairman 4

Frederick J. Shon l

Dr. Oscar H.

Paris I

X In the Matter of Docket Nos.

X CONSOLIDATED EDISON COMPANY OF NEW YORK, x

50-247 SP i

INC. (Indian Point, Unit No. 2) 50-286 SP X

POWER AUTHORITY OF THE STATE OF NEW YORK May 18, 1982 (Indian Point, Unit No. 3) l X

X 4

ANSWERS TO LICENSEE'S INTERROGATORIES BY FRIENDS OF THE EARTH, INC. AND NEW YORK CITY AUDUBON SOCIETY We currently do net intend to present evidence with regard to the following interrogatories and have thus not answered them:

2, 4-9, 13-36, 38, 40, 42-45, 47-49, 51, 52, 54-75, 77-92, 95,98-112, 114, 116, 117, 121, 122, 128-136, 138-153, 157, 160-179, 184.

1.

Assuming that emergency planning is capable of adequately 2

protecting the public, which we claim is not the case, the Indian Point emergency plans are defective and inadequate in the follow-ing ways:

In general, in that there are no provisions for respond-1 ing to, mitigating and cleaning up environmental damage,

.e.,

s l

effects on buildings, soils, waters, agricultural and recreational lands, and wildlife, resulting from an accident at Indian Point.

j Nence, the Indian Point emergency plans fail to meet the standards a

of H50.47(a) (1) and all sixteen criteria of H50.47(b).

The Indian Point emergency plans are further defective in that the 10 mile radius of the plume exposure pathway EPZ used for the plan h

8205260oTl

r 3

is insuff'7ient. (FOE /Audubon shall not address the inadequacy of exist. ug plans within the EPZ, except for environmental 3

i damage.)

In addition, the I.ndian Point emergency plans are i

inm equate and fail to meet the standards of BS50.47 (a) (1), (b)

I and appendix E to 10 CFR Part 50, in that there are no emergency I

plans for New York City.

The emergency plans do not recognize I

i or take into account the geographic extent and persistence of radioactive contamination.

References:

WASH 740, revised, 1965 WASH 1400, 1974 l

Richard Webb, the Accident Hazards of Nuclear Power Plants, 1976 l

Information Bulletin from the New York City Energy Project, " Potential Consequences of Nuclear Reactor Accidents Referenced to the Indian Point Reactors, April 7, 1980 3.

Again assuming that emergency planning is capable of I

]

adequately protecting the public, which we claim is not the case, the emergency plans do not delineate any relationship with:

(a) Those local agencies in New York City which would be involved with evacuation or other emergency measures in that locale.

Said 4

agencies sould, at a minimum, include the following departments:

police, health, education, environmental protection, buildings, I

sanitation, ports, Metropolitan Transportation Authority, Port Authroity, Triborough Bridge and Tunnel Authority, and parks and recreation.

We are not able to identify at this time what state l

agencies or support organizations would also have to be involved l

l in emergency planning for New York City.

Relationships with the i

above agencies are necessary to prepare for evacuation and/or sheltering, proteccive measures, treatment, identification of i

l contamination of resources such as water, air,. buildings, and i

i.

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e and recreational areas, and means of decontamination.

(b) The New York State Department of Agriculture with regard to long term contamination of agriculture lands and re, sources.

(c) New York State Department of Environmental Conservation, New York City Department of Environmental Protection, West-chester and Rockland County water departments, and. local water departments, with regard to water contamination.

(d) State and local parks and recreational departments with regard to contamination and prohibition of use of their facilities.

10.

The criterion which should be used is that, if adequate resources cannot be assured for response to serious accidents at Indian Point, that facility should not be permitted to operate.

11.

The source of this criterion is rational decision theory.

We have no knowledge as to whether emergency plans for other nuclear plants in the United States assure adequate resources for response to a serious nuclear accident.

12.

The more efficient and productive use of available services and resources provided for in the Indian Point emergency plan will, in any case, fail to assure adequate resources to res-pond to a serious accident.

37.

The topography of the Indian Point area is such that l

low level wind is channeled in a North-South direction.

This has l

possible implications for emergency plannning measures.

References:

Draft EIS by U.S.

A.E.C.,

related to operation of Indian Point Nuclear l

Generating Plant, No.

3, con Ed Docket No. 50-286, Oct. 1973 Consolidated Edison Co, of N.Y.,

Inc.,

Indian Point Nuclear Generating Unit No.

3, Preliminary Safety Analysis Report, Docket No. 50286--1, 1/15/68

" Turbulent Diffusion in Complex Terrain",

j Bruce Egan, Env. Res, & Tech., Inc.,

j In Chapter 4 of Lectures on Air and l

Environmental Impact Analysis 3

1

s 39.

Due to the great geographic extent and nature of environmental contanimation expected from a serious nuclear accident at Indian Point, protective actions of the type considered in the emergency. plans are irrelevant and inappro-priate.

41.

Emergency response planning as currently done, is relevant only to short term public health measures, and even thers may be inadequate.

It does not address at all the problems of long term contamination of water resources, agricultural lands and hence, of food supplies, or of long term contamination of buildings, other property and recreational lands, and the necessity of decontamination prior to resumption of use.

So called protective actions are incapable of dealing with the problems of long term contamination which will have a public health impact for an indeterminate period.

46.

Decontamination facilities, equipment, supplies, and trained personnel cannot even minimally respond to the long term contamination which would result from a serious accident at Indian Point.

Even sites which have been contaminated to a far lesser degree than would occur following a serious accident at Indian Point, have not been successfully decontaminated, and the attempts which have been made at those sites would not be appropriate for the densely populated urban region and infra-structure surrounding Indian Point.

In 1966, an American plane carrying four hydrogen bombs collided with another aircraft and crashed near Palomares,. Spain, dispersing plutonium.

Crops were removed over a five square mile area and the soil plowed to a depth of 25 centimeters to bury the dispersed plutonium.

Soil and vegetation were removed 4

entirely from the worst contaminated area and shipped back to the United States for burial.

But the dry Spanish climate, high wind velocities, and farming have disturbed the remaining soil and resulted in the resuspension of plutonium particles.

Two years later, a similar accident occurred near Thule, Greenland, with similar results and cleanup efforts.

IIundreds of Marshall Islanders from Bikini, who had been removed from their homes to permit U.S. nuclear weapons testing in the 1950's were permitted to return in 1968, after having suffered serious health effects frot the nuclear testing, even when relocated - especially thyroid tumors.

To permit their return, topsoil was removed and new tress planted, and in 1975 the U.S.

performed radiological testing on Bikini which found that the island still exceeded Federal radiation guidelines.

Their chief food, the coconut crab, was contaminated with strontium 90 and soon restrictions were placed on the islander's movements, with coconuts, their chief food, being banned entirely.

Food grown there had become contaminated with large amounts of plutonium and by 1978 the Bikinians were shown to have internal radiation levels twice the U.S. maximum recommended concentrations.

Soon after,they were evacuated from the island for a second time.

In the Ural region of the Soviet Union, in late 1957 or early 1958, an accident involving dispersal of stored radioactive wastes occurred which contaminated a geographic area of thousands of square miles, including its watershed, vegetation, and many populated villages.

The entire area was placed off limits, with no entrance permitted.

The radioisotopes that contaminated the animal and food chains and plants and water resources included 5

k 1

large amounts 'of strontiwn 90, especially in plankton, aquatic vegetation and lake fish.

Huge quantities of foodstuffs were destroyed and new supplies brought in by truck.

All available buildings were converted to health and evacuation centers.

The major highway through Kyshtym was closed for 9 month and when it reopened, it had signs on it telling motorists to drive l

l through for 20 miles with closed windows and at top speed.

Ten l

years later local doctors still advised pregnant women to obtain 4

e abortions.

The area was dotted with huge dumps for irradiated topsoil, fishing was forbidden, and food was still being analyzed for radioactivity.

\\

Unlike these accidents in relatively sparsely populated i

areas, the difficulties of decontamination in the New York 1

i Metropolitan region, with its urban infrastructure, reservoirs, buildings, and skyscrapers with their ventilation systems, etc.,

would be multiplied beyond comprehension.

I 1

References:

Virginia Brodine, Radioactive Contamination, 1975 John.Gofman, Radiation and Human Health, 1981 l

Zhores Medvedev, Nuclear Disaster in the i

Urals, 1979 50.

Medical and health facilities are incapable of l

responding to the effects of long term contamination.

In the i

i absence of evacuation of the population, individuals will be cubject to reexposure to readioactivity from particle resuspen-sion, surface and soil deposition, food and water contamination, 1

and recirculation in building ventilation systems.

Once individuals have been exposed to radiation, there is no rever-sibility or mitigation of health consequences.

There can be merely treatment of symptoms (which occur only at extremely high 1

6

doses) and decontamination of the individual and his clothing.

But as soon as an individual reenters the contaminated environ-ment, he is subject to recontamination.

Nevertheless, over the short term, following an accident, it is to be expected that large numbers of people will seek medical advice and treatment.

Although we do not have precise numbers of hospital and medical facilities in the region surrounding Indian Point, it is our information and belief that they can accomodate far fewer individuals than the number who would be subject to radioactive contamination following a serious accident.

53.

Return af the general public to areas affected by a nuclear accident at Indian Point must be contingent upon decon-tamination of soils, water and property, to the point that radiation levels do not exceed pre-accident radiation levels or the EPA exposure standard for the nuclear fuel cycle of 25 millirems per year for whole body dose (42 F.R. 2558-61, Jan. 13, 1977).

76.

The emergency plans do not take account of the long term contamination of non-human organisms, physical structures and natural resources, particularly from persistent radio-nuclides of strontium, cesium and plutonium, and their physical and biological pathways.

The emergency plans do not address the need for planning evacuation of the millions of individuals in the New York City metropolitan area and their relocation for varying periods of time up to several decades and more.

Nor does emergency planning account for the need for substitute financial and communications centers should New York City have to be evacuated.

7

93.

The probabilities are indeterminate, i

f 94.

Precipitation during plume passage will cause 1

i higher deposition And thuc higher duoes to the pcpulaticr..

I The emergency plans do not adequately protect against these i

higher doses.

In addition, the emergency plans may not 4

i adequately incorporate increased evacuation times during pre-cipitation.

j 96.

Doses may be higher than expected on elevated terrain due to lower effective plume rise.

The emergency plans 1

do not adequately protect against these higher doses.

Emergency I

plans may also not adequately consider wind channeling or 1

increased evacuation times in hilly terrain.

]

97.

Doses may be higher than expected under inversion 1

j or other adverse mereorology.

The evergency plans do not 1

adequately protect against these higher doses.

ML20053A395

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