ML20053B876
| ML20053B876 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/24/1982 |
| From: | Brandenburg B, Levin J, Pikus D, Remshaw R, Specter H CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY |
| References | |
| ISSUANCES-SP, NUDOCS 8206010307 | |
| Download: ML20053B876 (31) | |
Text
's t
RELATED COMUEPONDENCE
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- s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
't ATOMIC SAFETY AND LICENSING BOARD ggg Before Administrative Judges:
Louis J. Carter, Chairman Frederick J.
Shon Dr. Oscar H.
Paris
x In the Matter of Docket Nos.
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (Indian Point, Unit No. 2) 50-247 SP 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit No. 3)
May 24, 1982 l
x LICENSEES' RESPONSES TO INTERROGATORIES OF FRIENDS OF THE EARTH /NEW YORK CITY *AUDUBON SOCIETY ATTORNEYS FILING THIS DOCUMENT:
Brent L. Brandenburg Charles Morgan, Jr.
CONSOLIDATED EDISON COMPANY MORGAN ASSOCIATES, CHARTERED OF NEW YORK, INC.
1899 L Street, N.W.
4 Irving Place Washington, D.C.
20036 New York, New York 10003 (202) 466-7000 (212) 460-4600
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1 PRELIMINARY STATEMENT Consolidated Edison Company of New York, Inc.,
(" Con Edison"), licensee of Indian Point Station, Unit No. 2, and Power Authority of the State of New York (the " Power Authority"), licensee of Indian Point 3 Nuclear Power Plant (collectively the " licensees"), submit these responses to the
" Interrogatories of Friends of the Earth /New York City Audubon i
Socie ty (" FOE /Audubon"). "
The following are general comments or objections applicable to interrogatories of FOE /Audubon.
A.
Emergency Planning Responsibilities 1
The FOE /Audubon interrogatories in many instances reflect a fundamental misapprehension as to the various responsibilities for radiological emergenc'y pl'anning both generically and at Indian Point in particular.
Although the Commission ultimately maintains licensing jurisdiction over
. nuclear power planta, the licensees' responsibility for and jurisdiction over emergency planning terminates at the site l
boundary.
Pursuant to State law and consistent with federal regulations, the State of New York maintains primary responsibility for offsite radiological emergency planning (see l
l N.Y.
Executive Law, Art. 2-B).
Radiological emergency response plans and procedures ("RERP's" or " plans") for the ' four counties j
surrounding Indian Point are annexed to the State plan.
Accordingly, many of the interrogatories relating to offsite emergency planning were misdirected to the licensees.
The information sought, if available, would be more appropriately l 1 l
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obtained from the governmental authorities responsible for off-site emergency response.
Nevertheless, much of the information sought may be found in the offsite emergency plans themselves, with which the licensees are familiar.
Accordingly, where information is known on such a basis, we have attempted in an effort to expedite discovery to respond to the interrogatories concerning those plans, primarily by reference to portions of the plans.*
We continue to note, however, that the offsite authorities are more appropriate sources for this type of information.
)
This approach is analogous to the general principle of re-sponding to interrogatories, which permits reference to documents as an answer where the answer may be derived or ascertained from s.uch documents.
- See, e.g., Fed.
R.
Civ.
P.
33(c), which states:
Option to Produce Business Records.
Where the answer to an interrogatory may be darived or ascertained from the business records of the party upon which the interrogatory has been served or from an examination, audit or inspection of such business records, including a compilation, abstract or summary thereof, and the burden of deriving or ascertaining the answer is substantially the same for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to af ford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.
A specification shall be in suf ficir.nt detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained.
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6 B.
Document Production In a number of instances FOE /Audubon has served interrogatories which are, in effect, requests for production of documents.
We note that while 10 CFR S 2.740(b) requires responses to interrogatories within 14 days, 10 CFR S 2.741 allows 30 days for responses to document requests.*
Accordingly, the licensees do not intend to produce documents or make objections, except as otherwise specified, at this time.
We are prepared, while reserving any claims of privilege or other objections to such production, to consider a future time and location for the production of documents, in accordance with 10 CFR Part 2 and the convenience of the parties.
In fact, since the licensees believe that documents FOE /Audubon has requested may also be encompassed by other intervenors' document requests, it may be in the interest of all parties to coordinate such requests.
Of course, where the due date for document production lies beyond the Board's May 31, 1982 date for close of discovery under Commission Questions 3 and 4, the May 31 date should control.
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4 RESPONSES TO INTERROGATORIES 1.
INTERROGATORY:
a)
Identify by title, author and date of produc-tion all studies, reports, investigations, and other documents produced, consulted or commissioned by you with regard to pos-sible 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 factories.
V.
Means of transport, including but not limited to, roads, bridges, tunnels, cars, trucks, trains, railways, ships, ports, airplanes and airports.
VII.
Crops, livestock, packaged and processed foods.
VIII.
Household and consumer goods, including but
,not limited to, clothing, furnishings, appliances and personal items.
i IX.
Wildlife.
RESPONSE
The modes of possible damage to or contamination of plant surroundings are in general not unique to the Indian Point
(
site and were considered by the NRC( AEC) on a generic basis in formulating the siting review criteria for all nuclear plants.
l The application of these criteria to Indian Point was based on the specific hydrology and land use characteristics in the vicinity of the site.
It is impossible to specify all documents of this sort " consulted" by licensees.
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The following are the principal documents that were produced, consulted or commissioned by the licensees with regard to possible damage or contamination as a result of a nuclear accident at Indian Point:
State Emergency Plan Part 1 - Section III - Subsections 5 and 6 Part III - Section I - Procedure G
" Radio-logical Exposure Control Procedures" IP -2 Site Emergency Plan Section 6 Procedures:
IP-10ll Repair and Corrective Action IP-1038 Emergency Personnel Exposure IP -3 Site Emergency Plan Section 6 Procedures:
IP-1025 - Repair and Corre'ctive Action Teams IP-1027 - Emergency Personnel Exposure County Emergency Plans (Westchester, Putnam, Orange, Rockland)
Volume 1 - Section III. H.
6 - Isolation of Ingestion Pathways and Sources Volume 2 - Section 3 - Health Other Documents IP-2 Final Safety Analysis Report, Docket No.
50-247 IP-3 Final Safety Analysis Report, Docket No.
50-286 IP-2 Environmental Report, Docket No. 50-247 IP-3 Environmental Report, Docket No. 50-286
- Hine, G. J. and Brownell, G.
L.,
- editors, Radiation Dosimetry, Academic Press 1956
- Morgan, K.
Z.,
and Turner, J.
E.,
- editors, Principles of Radiation Protection, John Wiley & Sons, Inc. 1967
- Booth, R.
S., and Kaye, S.
J.,
"A Preliminary System Analysis Model of Radioactivity Transfer to Man from Deposition in a Terrestrial Environment", ORNL-TM-3135, Oak Ridge National Laboratories, Oak Ridge, Tennessee (1971)
U.S.
Department of Agriculture, Agriculture Statistics Annual 1.
INTERROGATORY:
b)
For each item listed in response to the request above, please attach a copy if available without a charge, or if unavailable, state place and time at which said item may be inspected and copied.
RESPONSE
Asterisked documents will be produced by the Licensees.
See page 4 concerning the production of documents.
Other documents may be inspected and copied at the White Plains Public Library.
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2.
INTERROGATORY:
a)
Identify by title, author and date of produc-tion 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 radio-active contamination of the materials listed in the Interrrogatory 1(a) above.
RESPONSE
Licensees' capability for monituring the area around the Indian Point nuclear power plants for released radio-activity, for following and predicting its movement and spread, and for assessing its potential health hazard is addressed in Appendix H of the Indian Point Site Radiological Emergency Response Plans.
Additional monitoring and assessment to be performed by qualified county and state personnel is described in Section III of the counties' response plans.
The following documents discuss, propose or further elaborate upon plans.for monitoring the types, levels and geographic extent of radioactive contamination of the materials listed in Interrogatory 1(a) above.
Specific references are as follows:
State Emergency Plans Part I - Section III - Subsections 5 and 6 Part III - Section I - Procedure G - Radiological Exposure Control Procedures IP-2 Site Emergency Plan Section 6.2 Procedures:
IP-1013 Recommendation of Protective Actions l
for Offsite Population IP-1004 Post Accident Offsite Environmental Surveys, Sampling and Counting 1
4 a
IP-1006 Site Perimeter Surveys IP-104 2 In-Plant Radiological Surveys and Sampling IP-1015 Mobilization and Operational Procedure for Offsite Monitoring Teams-Immediate
Response
IP-1034 Mobilization and Operational Procedure for Offsite Monitoring-Supplemental
Response
IP-1020 Airborne Iodine-131 Determination Using SAM-2/RD-22 or RM-14/HP-210 IP-3 Site Emergency Plan Section 6.3 Procedures:
IP-1017 - Recommendation of Protective Actions for Offsite Population IP-1018 - Post Accident Environmental Sampling and Counting IP-1010 - In Plant / Site Perimeter Survey IP-10ll - Offsite Monitoring Team IP-1015 - Airborne Iodine - 131 Determination Using S AM-s/RD-22 or RM-14/HP-210 County Emergency Plans Volume 1 - Section III. G. - Assessment and Evaluation of Protective Action Response Options
- Appendix J.
Nuclear Environmental Monitoring System Volume'2 - Section 3 - Health
- Section 14 - Radiological Equipment
- j
- Putnam County Plan has Section 13 as Radiological Equipment.
Other Documents IP Final Safety Analysis Report, Docket No. 50-247 IP Final Safety Analysis report, Docke t No. 50-286 IP-2 Environmental Report, Docket No. 50-247 IP-3 Environmental Report, Docket No. 50-286 l
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S 2.
INTERROGATORY:
b)
For each item listed in response to request 2(a) above, please attach a copy if available without charge, or if unavailable, state place and time at which item may be inspected and copied.
RESPONSE
These documents may be inspected and copied at the White Plains Public Library.
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3.
INTERROGATORY:
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 rsult of an accident at Indian Point.
RESPONSE
Medical and scientific procedures for treating onsite personnel who may have been exposed to radioactivity or who may have ingested radioactive materials as a result of an accident at Indian Point are discussed in the followirc documents.
These procedures have been considered or proposed by the licensees or consultants or experts with whom the licensees have communicated.
IP-2 Site Emergency Plan Plan-Appendix D Procedures:
IP-1012 On-site Medical Emergency IP-1008 Personnel-Radiological Check and Decontamination IP-1005 Use of SAM-2/RD-22 to Determine Thyroid Burdens IP-3 Site Emergency Plan Plan - Appendix D Procedures:
IP-1012 - Radiological Medical Emergency IP-1022 - Transport of Contaminated Injured Personnel Between Units 3 and 1 IP-1060 - Personnel Radiological Check and Decontamination IP-1065 - Use of SAM 2/RD-22 to Determine Thyroid Burdens Other Documents IP Environmental Report, Docket No. 50-247 IP Environmental Report, Docket No. 50-286 l
ICRP 28, " Principles and General Procedures for. _ _
t Handling Emergency and Accidental Exposure of Workers", Pergamon Press, Annals of ICRP Vol.
2, No. 1, 1978 NCRP No. 65, " Management of Persons Accidently Contaminated With Radionuclides" l
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3.
INTERROGATORY:
b)
Identify specifically the locations, facili-ties, and personnel that would be available for treatment identi-fled in response to 3(a) and indicate as accurately as possible the capacity of such facilities.
RESPONSE
1.
Con Edison clinic and decontamination suite at Indian Point 1 and 2.
2.
Power Authority decontamination suite at Indian Point 3.
3.
Peekskill Community Hospital (PCH) 114 beads 180 Crompond Road Peekskill, New York 10566 4.
Northern Westchester Hospital (NWH) 250 beds 400 East Main Street Mount Kisco, New York 10549 5.
Brookhaven National Laboratories Associated Universities Inc.
Upton, New York 11973
3.
INTERROGATORY:
c)
If documents are cited in response to requests 3(a) or 3(b) above, please append a copy of the rele-vant pages if available without charge, or provide a concise
~
summary of the pertinent portions of said documents.
RESPONSE
These documents, with the exception of ICRP 28 and NCRP No. 65, are available for inspection and copying in the White Plains Public Library. ICRP 28 and NCRP No. 65 will be produced by the Licensees.
See page 4 above concerning production of documents by licensees.
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4.
, INTERROGATORY:
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 car-rying out procedures described in the responses to 4(a) above.
RESPONSL':
The methods and degree of decontamination necessary will vary greatly depending on the postulated level of contamina-tion and the structures, items and portions of the environment involved.
While it is not within the jurisdiction of the licensees to specify and implement decontamination procedures dealing with public properties or private properties outside the licensees' control, we would expect that a large percentage of the area postulated to be contaminated would be at a very icw concentration such that dispersion and removal by natural environmental and decay processes would be sufficient and appro-priate.
The following documents describe such procedures.
IP-2 Site Emergency Plan See response to number 1(a), 2(a), and 3(a) plus Procedures:
IP-1009 Radiological Check and Decontamination of Vahicles IP-1017 Issuance and Use of Radiological Equip-ment Stored in the Command Guard House IP-3 Site Emergency Plan See response to numbers 1(a), 2(a) and 3(a) plus Procedures:
IP-1063 - Vehicle Radiological check and
- 1. )
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4 Decontamination IP-1079 - Issuance and Use of Radiological Equip-l ment Stored in Command Guard House County Emergency Plans See response to numbers 1(a), 2(a) and 3(a) i 1
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4.
INTERROGATORY:
c)
If documents are cited in response to requests 4(a) or 4(b) above, please append a copy of the relevant pages if avialable without charge, or provide a concise summary of the pertinent portions of said documents.
RESPONSE
t These documents may be inspected and copied at the White Plains Public Library.
e
5.
INTERROGATORY:
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.
RESPONSE
All radioactivity contaminated materials must be stored, handled, transported and disposed of in compliance with current NRC and DOT regulations.
Storage / disposal must be at an approved licensed site.
Regulations addressing disposal of such material are now being revised and will soon be published as 10 CFR Part 61.
There are now three licensed sites in the States of Washington, South Carolina and Nevada.
Subsequent to January 1, 1986, siting of such shallow land burial sites will be on a regional basis thus, at that time or' shortly thereafter, a low level radioactive waste burial site will be available in the northeast part of,the country.
Licensing of the site in compliance with 10 CFR Part 61 will assure proper structures for possible storage and care and maintenance of the sites.
L 5.
INTERROGATORY:
b)
Describe specifically any plans within your knowledge or under consideration by you or your consultants with regard to:
I.
Transport of contaminated materials to the sites.
II.
Types of structures that would be used for the containment of contaminated materials.
III.
Care and maintenance of the site.
RESPONSE
See response to 5(a) above.
With regard to trans-port of radioactive materials, 10 CFR Part 71 and applicable Department of Transportation regulations apply.
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5.
INTERROGATORY:
c)
If documents are cited in response to 5(a) or 5(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.
RESPONSE
Not applicable.
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6.
INTERROGATORY:
a)
Describe all estimates within your knowledge of the time that would be required to decontaminate radioactive oojects and sites sufficiently to resume normal use and access by human beings without posing a threat to their health and safety.
RESPONSE
We are not aware of any generic or Indian Point specific estimates addressing time requirements for decontamina-tion.
Such estimates would require a great many assumptions and, therefore, would probably be of very limited value.
The time required to reduce any contamination encountered to acceptable leveln will be strongly incident-specific and will be highly dependent on the proposed schedule for decontamination and ac-ceptance criteria.
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6.
INTERROGATORY:
b)
If estimates cited in response to request 6(a) above are based upon any studies, reports, investigations or other documents, please append a copy of the relevant pages, or provide a concise summary of the pertinent portions of said documents.
RESPONSE
Not applicable.
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[
e 7.
INTERROGATORY:
a)
Identify by title, author and date of produc-tion all studies, reports, investigations and other documents produced, consulted or commissioned by you with regard to:
I.
The difficulties of emergency evacuation posed by the existing network of road-Ways in Westchester and Rockland counties.
II.
The possibilities of mitigating these dif-ficulties by expanding, improving or upgrading roadways, b)
For each item listed in response to request 7(a) 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 number where said difficulties and possibilities are discussed.
RESPONSE
The evacuation time estimates prepared by Parsons Brinckerhof f took int,o account the existing roadway network.
No studies or reports have been prepared with regard to the diffi-culties of emergency evacuation posed by the existing network of roadways in Westchester and Rockland counties.
Similarly, no reports or studies have been prepared with regard to the l
possibilities of mitigating any such difficulties by expanding, l
improving or upgrading roadways.
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8.
INTERROGATORY:
a)
Identify by name any witnesses you plan to have testify at the hearings with regard to any aspect of on-site or of f-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.
Address.
II.
Occupational Title.
III.
Place of Employment.
IV.
Business Address and Telephone Number.
V.
Times Within Your Knowledge at Which Said Witnesses Will be available for-Deposition.
c)
State briefly the matters about which each witness identified in request 8(a) is expected to testify.
RESPONSE
See Licensees' Response to UCS/NYPIRG Interrogatory Number 1.
With regard to item 8(b)V above, Licensees believe that depositions are neither contemplated nor useful in a proceeding of this sort.
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As to Answers:
CONSOLIDATED EDISON COMPANY OF d YORK, INC.
By ' (.s %'
/"
01Ak" duv Richard P.
Remshaw Project Manager - Indian Point Hearings POWER AUTHORITY OF THE STATE OF NEW YORK By Herschel Spectet W
Protect Manager - Indian Point Hearings As to Objections:
CONSOLIDATED EDISON COMPANY OF NEW YORK INC.
/
By f
(f}))
Brent '%. B'randen6ur~g '
/
Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK MORGAN ASSOCIATES, CHARTERED By h,
,h.
Jo# phIJ. LeWin, Jr.
'U SHEA & GOULD By David H.
Pikus Attorneys for Power Authority of the State of New York
O VERIFICATION STATE OF NEW YORK
)
- SS.:
COUNTY OF NEW YORK
)
RICHARD P. REMSHAW, being duly sworn, deposes and says:
That he is the Project Manager - Indian Point Hearings for Consolidated Edison Company of New York, Inc., licensee of Indian Point Nuclear Generating Station, Unit No. 2; that he is authorized to make this verification on behalf of said corporation; and that the foregoing answers to interrogatories were prepared under his direction and supervision and are true and correct to the best of his knowledge, information and belief.
(241 % W
/G
+d RICHARD P.
REMBHAW Sworn to before me this 24th day of May, 1982 k
Notary Public PETER A. IRWIN Notary Public. Srste et New York No. 31 4509945 Qualified in New York Term Expires March 30, NS
VERIFICATION STATE OF NEW YORK
)
SS.:
COUNTY OF NEW YORK )
HERSCHEL SPECTER, being duly sworn, deposes and says:
That he is the Manager, Indian Point 3 Hearings, Technical Support for Power Authority of the State of New York, licensee of Indian Point 3 Nuclear Power Plant; that he is authori::ed to make this verification on behalf of said Authority; and that the foregoing answers to interrogatories were prepared under his direction and supervision and are true and correct to the best of his knowledge, information and belief.
A HERSCHELkPECTER
(
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Sworn to before me this l
24th day of May, 1982.
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Notary Public DOREEN PISCO Nctary Public. State of New Yort No.17373?3 Cuahtied in Westcracstet form Empi:es Mucn 30,1
9 ff Respectfully submitted, I
(f M
%9W.
Brent L.
Brandenburg Charles Morgan, J(J
'V Joseph J.
Levin, Jr.
b Paul Colarulli 1899 L Street, N.W.
CONSOLIDATED EDISON C PANY washington, D.C.
20036 OF NEW YORK, INC.
(202) 466-7000 Licensee of Indian Point Unit 2 Thomas R.
Frey 4 Irving Place General Counsel New York, New York 10003 Charles M.
Pratt (212) 460-4600 Assistant General Counsel 10 Columbus Circle New York, New York 10019 (212) 397-6200 MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.
Washington, D.C.
20036 SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point l
Unit 3 l
10 Columbus Circle New York, New York 10019 l
Dated:
May 24, 1982 l
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UNITsu STATES OF AMERICA NUCLEAR REGULATORY COMMISSION L:
P ATOMIC SAFETY AND LICEdSING BOARD B:;. _
Before Administrative Judges:
Louis J.
Carter, Chairman Frederick J. Shon Dr. Oscar H.
Paris
x CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (Indian Point, Docket Nos. 50-247-SP Unit No. 2) 50-286-SP POWER AUTHORITY OF THE STATE OF May 24, 1982 NEW YORK, (Indian Point, Unit No. 3)
x CERTIFICATE OF SERVICE I certify that I have served copies of the " Licensees' Responses to Interr'ogatories of Friends of the Earth and New York City Audubon Society on the following parties by first class mail, postage prepaid, this 24th day of May 1982.
Docketing and Service Branch Dr. Oscar H.
Paris Of fice of the Secretary Administrative Judge U.S.
Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Louis J.
Carter, Esq., Chairman Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Mr. Frederick J. Shon Board Administrative Judge l
7300 City Line Avenue - Suite 120 Atomic Safety and Licensing l
Philadelphia, Pennsylvania 19151 Board i
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 l
l I
1 Janice Moore, Esq.
Charles J. Maikish, Esq.
Counsel for NRC Staff Litigation Division Office of the Executive The Port Authority of Legal Director New York and New Jersey U.S. Nuclear Regulatory One World Trade Center Commission New York, N. Y.
10048 Washington, D.C.
20555 Ezra I.Bialik, Esq.
Paul F. Colarulli, Esq.
Steve Leipsiz, Esq.
I Joseph J.
Levin, Jr., Esq.
Environmental Protection Bureau l
Pamela S. Horowitz, Esq.
New York State Attorney l
Charles Morgan, Jr., Esq.
General's Office Morgan Associates, Chartered Two World Trade Center 1899 L Street, N.W.
New York, N.Y.
10047 Washington, D.C.
20036 Alfred B.
Del Bello Charles M.
Pratt, Esq.
Westchester County Executive Thomas R.
Frey, Esq.
Westchester County Power Authority of the 148 Martine Avenue State of New York White Plains, New York 10601 10 Columbus Circle New York, N.Y.
10019 Andrew S. Roffe, Esq.
New York State Assembly Ellyn R. Weiss, Esq.
Alhany., N.Y.
12248 William S. Jordan, III, Esq.
Harmon & Weiss Renee Schwartz, Esq.
1725 I Street, N.W.,
Suite 506 Paul Chessin, Esq.
Washington, D.C.
20006 Laurens R.
Schwartz, Esq.
Botein, Hays, Sklar & Herzberg Joan Holt, Project Director Attorneys for Metropolitan Indian Point Project Transportation Authority New York Public Interest 209 Park Avenue Research Grour, New York, N.Y.
10166 5 Beekman Group New York, New York 10038 Stanley B.
Klimberg General Counsel John Gilroy, Westchester New York State Energy Office Cordinator 2 Rockefeller State Plaza Indian Point Project Albany, N.Y.
12223 New York Public Interest Research Group Honorable Ruth Messinger 240 Central Avenue Member of the Council of the White Plains, New York 10606 City of New York District #4 Jeffrey M.
Blum City Hall New York University Law School New York, N.Y.
10007 423 Vanderbilt Hall Washington Square South Marc L.
Parris, Esq.
New York, New York 10012 County Attorney County of Rockland 11 New Hempstead Road New City, N.Y.
10010 Alan Latman, Esq.
44 Sunsent Drive Joan Miles Croton-on-Hudson, N.Y.
10520 Indian Point Coordinator New York City Audubon Society Richard M. Hartzman, Esq.
71 W.
23rd Street, Suite 1828 Lorna Salzman New York, N.Y.
10010 Mid-Atlantic Representative Friends of the Earth, Inc.
Greater New York Council on Energy 208 West 13th Street c/o Dean R.
Corren, Director New York, N.Y. 10011 New York University 26 Stuyvesant Street Zipporah S.
Fleisher New York, N.Y.
10003 West Branch Conservation Association Atomic Safety and Licensing 443 Buena Vista Road Board Panel New City, N.Y.
10956 U.S. Nuclear Regulatory Commission Mayor George V. Begany Wr~hington, D.C.
20555 Village of Buchanan 236 Tate Avenue Atomic Safety and Licensing Buchanan, N.Y.
10511 Appeal Board Panel U.S. Nuclear Regulatory Judith Kessler, Coordinator Commission Rockland Citizens for Safe Washington, D.C.
20555 Ener~gy 300 New Hempstead Road Richard L.
Brodsky New City, N.Y.
10956 Member of the County Legislature Westchester County David H. Pikus, Esq.
County Office Building Richard F. Czaja, Esq.
White Plains, N.Y.
10601 330 Madison Avenue New York, N.Y.
10017 Pat Posner, Spokesman Parents Concerned About Amanda Potterfield,Esq.
Indian Point Box 384 P.O.
Box 125 Village Station Croton-on-Hudson, N.Y.
10520 New York, New York 10038 Charles A.
Scheiner, Co-Chairperson Westchester People's Action Coalition, Inc.
P.O.
Box 488 White Plains, N.Y.
10602 l
l Dated:
May 24, 1982 New York, New York 7% ). Gwl, Thoma# J.
Farrelly /