ML20053B912
| ML20053B912 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/24/1982 |
| From: | Brandenburg B, Morgan C CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | PARENTS CONCERNED ABOUT INDIAN POINT |
| Shared Package | |
| ML20053B913 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206010338 | |
| Download: ML20053B912 (34) | |
Text
r 3
j HEIATED CORRFSM?mTMC
- i
' l *l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 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,
)
50-247 SP INC. (Indian Point, Unit No. 2) 50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK May 24, 1982 (Indian Point, Unit No. 3)
)
________________________________________________x LICENSEES' RESPONSES TO PARENTS CONCERNED ABOUT INDIAN POINT'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES l
l l
ATTORNEYS FILING THIS DOCUMENT:
I Charles Morgan, Jr.
Brent L.
Brandenburg i
MORGAN ASSOCIATES, CHARTERED CONSOLIDATED EDISON COMPANY 1899 L Street, N.W.
OF NEW YORK, INC.
Washington, D.C.
20036 4 Irving Place io (202) 466-7000 New York, New York 10003 (212) 460-4600 l
3503 l
120e0 1o use sloIi cm
TABLE OF CONTE 11TS Page 1
PRELIMINARY STATEMENT...................................
RESPONSES TO INTERROGATORIES 5
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 Parents Concerned About Indian Point's First Set of Requests for Production of Documents and Interrogatories.
The following are general comments or objections applicable to nultiple interrogatories.
A.
Emergency planning responsibilities Parents' interrogatories in many instances reflect a fundamental misapprehension as to the various responsibilities for radiological emergency planning both generically and at Indian Point in particular.
Although the Commission ultimately maintains licensing jurisdiction over nuclear power plants, the i
licensees' responsibility for and jurisdiction over emergency planning terminates at the site boundary.
Pursuant to State law and consistent with federal regulations, the State of New York maintains primary responsibility for off-site radiological l
emergency planning (see N.Y.
Executive Law, Art. 2-B).
Radio-I logical emergency response plans and procedures ("RERP's" or I%
"pians") for the four counties surrounding Indian Point are annexed to the State plan.
t l
l L
Accordingly, most of the interrogatories relating to off-site emergency planning were misdirected to the licensees.
The information sought, if available, would be more appropri-ately obtained from the governmental authorities responsible for off-site emergency response.
tievertheless, much of the information sought may be found in the off-site emergency plans themselves, with which the licensees are familiar.
Accordingly, where informatic.a 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.*
This approach is analogous to the general principle of responding to interrogatories, which permits reference to documents as an answer where the answer may be derived or ascertained from such documents.
- See, e.g.,
Fed.
R.
Civ.
P.
33(c). which states:
Option to Produce Buciness Records.
Where the answer te an interrogatory may be derived or as-certained from the business records of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, including a compilation, ab-stract or summary thereof, and the burden of deriving or ascertaining the answer is substanti-ally the same for the party serving the in-terrogatory as 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 afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, (footnote continued) r We continue to note, however, that the off-site authorities o
are the more appropriate sources for this type of information.
B.
Discovery assignments In some instances, Parents served interrogatories relating to contentions for which it has not been assigned lead or contributing intervenor status.
In its Memorandum and Order (Formulating Contentions and Designating Intervenor Responsi-bilities) dated April 9, 1982 (the " April 9 Order"), the Board limited discovery for each contention to the lead and contribut-ing intervenors thereon.
Accordingly, the licensees have objected to all interrogatories which fail to comply with such requirement.
(footnote continued) compilations, abstracts or summaries.
A specifica-tion shall be in sufficient 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.
Parents has requested identification of persons who "partici-pated in responding to each interrogatory."
In instances in which the licensees have responded by reference to the plans or other documents, of course, such identification is inappropriate.
. L
C.
Document production In many instances Parents has served interroga-tories which are, in effect, requests for production of docu-ments.
We note that while 10 CFR S2.740b requires responses to interrogatories within 14 days, 10 CFR 52.741 allows 30 days for responses to document requests.*
Accordingly, the licen-sees 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 Parents requests may also be encom-passed 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.
l.-.
RESPONSES TO INTERROGATORIES O
1.
INTERROGATORY:
Submit statistics and procedures used to deter-mine the number of people to be evacuated by bus within the 10 mile EPZ.
RESPONSE
The procedure to determine the number of people to be evacuated by bus within the 10 mile EPZ varied for the general population, school children, and special facilities.
The ambulatory general population without automo-biles would be evacuated by bus.
The statistics and procedures used to determine the number of these people are discussed in Section III B - Permanent Resident Population - in the draft document " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone."
The number of school children to be evacuated by bus was determined from enrollment data provided by the schools and/or school districts.
In the case of high schools, students with cars were assumed to evacuate by car to the school reception center or to other pre-arranged locations; all other students would travel by bus to the school recep-tion center.
For special facilities, the facilities provided data regarding their population (subdivided into ambulatory, -.
wheelchair, and stretcher-bound) and self-evacuation capabili-ties (e.g., number and type of facility-owned vehicles).
Deficiencies in self-evacuation capabilities were remedied by assigning vehicles from outside sources to the facility.
Ambulatory residents were assigned to buses, or where more efficient, vans.
Additional infcrmation is contained in Appendix H to the county RERP's.
2.
INTERROGATORY:
Identify each bus company and the number of buses available to participate in an evacuation of school children and transportation-dependent children and adults in the 10 mile EPZ.
RESPONSE
The bus companies and the number of buses designated to participate in an evacuation of school children and transportation-dependent children and adults in the plume EPZ are listed in a table entitled " Bus Company Assignments."
This table is located in Attachment 1 of the Transportation Procedure for each of the four county RERP's.
3.
INTERROGATORY:
How did you de ermine how long it would take for buses to evacuate school children and then return to evacut.te the transportation-dependent population?
RESPONSE
The general methodology to estimate evacuation travel times is discussed in the draft document " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone," November 1981.
A specific discussion of how travel times were estimated for school buses during a school-in-session evacuation is found in Section IV.E. (Compo-nents of the Evacuation Travel Time) of that report.
4.
INTERROGATORY:
Submit contracts between the bus drivers and bus companies which will guarantee the participation of bus drivers in case of a nuclear emergency.
RESPONSE
The licensees do not have knowledge of such con-tracts, for either radiological or non-radiological emergencies.
If such arrangements are in place, they would be between the bus companies and their employees.
l See p.
4, above, concerning responses to document requests.
5.
INTERROGATORY:
(
i Submit contracts between the bus companies and the utilities and/or county to ensure the participation of the bus companies in case of a nuclear emergency.
RESPONSE
See p.
4, above, concerning responses to document requests.
6.
INTERROGATORY:
Identify bus drivers who live within the 10 mile EPZ and who have contracted to drive buses in case of an emergency.
Include their addresses.
RESPONSE
Licensees do not have such information.
(See pp.
1-3 above concerning responsibilities for off-site emergency planning.)
7.
INTERROGATORY:
Identify all bus drivers who live outside the 10 mile EPZ who have contracted to drive buses in case of an emergency.
Include their addresses.
RESPONSE
Licensees do not have such information.
(See pp.
1-3 above concerning responsibilities for off-site emergency planning.)
8.
INTERROGATORY:
What procedures have been taken to insure that bus drivers living outside the 10 mile EPZ will be allowed inside the 10 mile EPZ?
l
RESPONSE
Procedures regarding bus transportation are contained in the county Plans, Appendix A, Attachment 2, Section B. -
9.
INTERROGATORY:
What procedures have been taken to insure that bus drivers can be activated during an evacuation?
RESPONSE
Such procedures are addressed in county Emergency Plans, Procedure 5, Attachment 1.
10.
INTERROGATORY:
What procedures have been taken to insure that all buses are maintained and available 100% of the time?
RESPONSE
Such procedures are addressed in county Emergency Plans, Appendix A, Attachment 3.
11.
INTERROGATORY:
Have Con Edison /PASNY identified children who are home alone after school while their parents work?
(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.
RESPONSE
The licensees themselves have not identified children who are home alone after school while their parents work. --
(a)
Not applicable.
(b)
The brochure, " Indian Point, Emergency Planning and You," which was mailed to residents of the plume EPZ, contained a postage-paid response card; the card included instructions that people who anticipate needing assistance in the event of a recommendation to evacuate mail the card in order to make their needs known to appropriate governmental officials.
12.
INTERROGATORY:
Submit all studies, research, expert testimony, etc. which shows that children under 18 have the mental, emotional and psychological capability to evacuate themselves.
RESPONSE
See p.
4, above, concerning responses to document requests.
13.
INTERROGATORY:
Has Con Edison /PASNY identified those children home unsupervised after school who are handicapped?
If so, submit such statistics.
RESPOHSE:
The emergency planning brochures distributed within the plume EPZ contain reply postcards for submission to the appropriate off-site govermental authorities by persons with special needs in the event of a radiological emergency.
F i
14.
INTERROGATORY:
Has Con Edison /PASNY identified the number of children in various supervised after school athletic, religious and cultural programs?
(a) if so, state the programs and number of children enrolled in each.
(b) state the responsibility of the adult in charge of each program in terms of evacut ting the children in their programs.
(c) state the method by which these persons have been identified and instructed.
(d) have these adults and/or organizations submit-ted their plans for the evacuation of their children?
RESPONSE
The licensees have not themselves identified the number of children in various supervised after school programs.
(See response to Interrogatory 12, above).
\\
15.
INTERROGATORY:
Submit any studies and/or pertinent research
'which was used to determine that the format of the emergency planning booklet and the information given is sufficient to prepare the public for an evacuation.
RESPONSE
See p. 4, above, concerning responses to document requests.. _.
16.
INTERROGATORY:
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.
RESPONSE
See p.
4, above, concerning responses to document i
requests.
17.
INTERROGATORY:
What mailing list (s) was used to identify who would receive the emergency planning booklets?
RESPONSE
Mailing lists of the electric utilities that service the plume EPZ were used.
(See also response to WESPAC Interrogatory 20).
C 18.
INTERROGATORY:
What procedures have been set up to ensure that newcomers receive emergency planning booklets?
RESPONSE
NUREG-0654 provides for updating of the brochures annually.
Planned annual redistributions will provide copies to new residents.
19.
INTERROGATORY:
Describe procedures and submit statistics used to identify and give emergency planning information to illerate [ sic]
adults and non- [ sic]
f^
RESPONSE
Licensees cannot respond to this interrogatory, as it is incomplete and unintelligible.
20.
INTERROGATORY:
Identify physically disabled persons who are to receive special provisions as per page 8 in the emergency planning booklet.
RESPONSE
The licensees do not themselves have such infor-mation.
The names of physically disabled persons in need of special provisions should have been submitted via the postcards in the Indian Point emergency planning booklet to the Four County Nuclear Safety Committee as stated at p. 8 of the booklet.
21.
INTERROGATORY:
Submit evidence that the emergency planning booklet has been received, read and understood by every person in the 10 mile EPZ.
t
RESPONSE
Based upon the number of brochures " returned to sender," licensees believe that substantially all residents and businesses in the plume EPZ have received the brochure.
The licensees do not themselves have evidence that every person has read and understood the brochure, but believe that the brochure is readily comprehensible.
22.
INTERROGATORY:
Why was a three day figure suggested in the emergency planning booklet to plan for in case of a prolonged radiation realease?
How was this figure arrived at?
RESPONSE
Licensees object to this interrogatory on the ground that it arises outside of any contention for which Parents has been assigned lead or contributing intervenor status.
23.
INTERROGATORY:
Identify all people who participated in respond-ing to each interrogatory by name, title and business address.
RESPONSE
The following persons principally prepared re-sponses to interrogatories:
Michael Della Rocca (Senior Planner)
Bruce E. Podwal (Vice President)
Peggy L. Rosenblatt (Senior Planner)
Parsons Brinckerhoff Quade & Douglas, Inc.
One Penn Plaza New York, New York 10119 (Interrogatories 1, 2,
3, 25, 35 and 37)
Counsel
( All interrogatories)
Dr. Sidney Lecker 320 East 65th Street New York, New York 10021 (Interrogatories 41 42 and 46)
See also p.
3, n.
(*),
above.
3 24.
INTERROGATORY:
Identify any documents utilized in answering interrogatories by title, date author and recipient.
RESPONSE
See response to UCS/NYPIRG Interrogatory 2.
25.
INTERROGATORY:
What are your procedures for informing reception centers, school reception centers and congregate care centers as to their role and responsibility during an evacuation?
RESPONSE
The New York State Radiological Emergency Pre-paredness Group ("REPG") is responsible for training or over-seeing that training is conducted for those agencies, organi-zations and/or facilities that have a role in the functioning of reception and school reception centers.
The American Red Cross is responsible for designating and training personnel to run congregate care centers.
26.
INTERROGATORY:
What is your procedure for an on-going evalua-tion of the status of the reception centers, school reception centers, and congregate care centers?
RESPONSE
The licensees do not have such procedures.
On-going evaluation of the status of reception centers and con-gregate care centers is provided for in the County Emergency Plans as follows:
l l
Procedure 3 Attachment 1; Appendix E.
27.
INTERROGATORY:
What are your procedures for informing new personnel at reception centers, school reception centers and congregate care centers as to their role and responsibility during an evacuation?
RESPONSE
The licensees do not have such procedures.
Procedures for training new personnel at school and congregate care centers are contained in the State and county plans as follows:
State plan Part I,Section II - 13 to 14, Part III,Section I, Procedure F - 3; County plansSection II.B.5, Procedure 13, Section 4.2.
(Putnam Procedure 12, Section 4.2).
28.
INTERROGATORY:
What are your procedures for informing the Red Cross a? to its role and responsibility during an evacuation?
RESPONSE
i Information about the role of the American Red Cross in responding to a radiological emergency is found in the State and county Plans as follows:
State plan Part I,Section III; county PlansSection III.C.4; county Procedures 3 and 6.
l l
See pp.
1-3, above, regarding responsibilities for off-site emergency planning.
29.
INTERROGATORY:
What are your procedures for determining whether Red Cross personnel are adequately trained in decontamination procedures?
RESPONSE
Licensees do not themselves have such procedures.
(See also response to Interrogatory 28, above.)
30.
INTERROGATORY:
Submit your procedures for determining whether Red Cross personnel are adequately trained to recognize and treat radiation sickness.
RESPONSE
l See responses to Interrogatories 28 and 29, above.
l 31.
INTERROGATORY:
Submit evidence that reception centers have l
decontamination equipment.
RESPONSE
Licensees object to this interrogatory on the ground that it arises outside of any contention for which Parents has been assigned lead or contributing intervenor status.
l 32.
INTERROGATORY:
Submit evidence that you will have on-going evaluations of decontamination equipment.
RESPONSE
Licensees object to this interrogatory'on the ground that it arises outside of any contention for which Parents has been assigned lead or contributing intervenor status.
33.
INTERROGATORY:
Describe procedures used to determine whether supplies for a prolonged stay are at the congregate care centers or not.
If not, why do you feel these supplies are unnecessary?
RESPONSE
Licensees object to this interrogatory on the ground that it arises outside of any contention for which Parents has been assigned lead or contributing intervenor status.
34.
INTERROGATORY:
Identify procedures used to determine how many Red Cross personnel would be necessary to accomodate [ sic] the number of evacuees.
RESPONSE
See response to Interrogatory 28, above.
35.
INTERROGATORY:
What were your procedures for determining how many evacuees would need the services of the congregate care center?
RESPONSE
A survey was conducted by Yankelovich, Skelly and White, Inc. during Spring 1980 to determine temporary housing needs related to evacuation of the Indian Point power plant area.
The results of the survey indicated that approximately 24% of the residents within the 10-mile radius of the plants would require temporary housing in a public shelter.
Subsequent to the survey, the New York State Office of Disaster Prepared-ness issued guidelines to be used in the development of county Radiological Emergency Response Plans and Procedures.
These guidelines required that f acilities for mass care (to be provided by the American Red Cross) be planned for 50% of the population potentially evacuating the plume EPZ.
36.
INTERROGATORY:
What is your program for informing new bus drivers as to the location and routes to schools to be evacu-ated, school reception centers and congregate care centers?
RESPONSE
Education and training of bus drivers has been as'sumed by the State.
(Licensees do not have such a program.)
37.
INTERROGATORY:
What were your procedures for determining whether school reception centers can evacuate their population in sufficient time to allow evacuees to enter?
RESPONSE
If school reception centers are required during an evacuation, it is expected that the host schools will implement the sane early closing procedures they use under other circumstances.
To the extent that 100% of the host school students have not left at the time evacuated students arrive, any remaining host school students can be grouped in a portion of the school (e.g.,
a cafeteria, auditorium or gymnasium) designated by the host school officials.
38.
INTERROGATORY:
Have you identified the short-term effects of radiation poisioning?
If so, what are these effects?
RESPONSE
Licensees object to this interrogatory on the ground that it arises outside of any contention for which Parents has been assigned lead or contributing intervenor status.
39.
INTERROGATORY:
Have you identified radiation disaster training for the teachers who are charged with the care of school children in the school?
On the buses?
At the host centers?
RESPONSE
Radiation training information is contained in the plans as follows:
Procedure 13, Attachments 2, 3, 4 and 5 of the Emergency Plans for Westchester, Rockland and Orange Counties; Procedure 12, Attachments 2, 3, 4 and 5 of the Putnam County Emergency Plan.
40.
INTERROGATORY:
Have manuals been devised to inform and train teachers in dealing with the physiological symptoms of radiation poisoning?
RESPONSE
The licensees do not have knowledge regarding such manuals.
41.
INTERROGATORY:
Have manuals been devised to inform and train teachers how to deal with the psychological problems of children under extremely stressful situations?
RESPONSE
Yes.
42.
INTERROGATORY:
Have you identified how children react in stress-ful situations?
Show evidence of that and how adults, especial-ly teachers, react in stressful situations.
RESPONSE
Children generally react to stressful situations by (a) looking to adults, such as parents or caretakers, who show leadership; and/or (b) productive use of optimistic antici-pation.
Children generally react better than adults to stress-ful situations.
Adults generally mobilize physically and psycho-logically to cope with stress.
In most instances, they react by responding obediently to leaders and sources of authority, and to instructions, particularly in the event of an emergency.
Evidence of such reactions has been provided by the licensees' psychiatric and sociological consultants, based on their training, experience and research.
43.
INTERROGATORY:
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.
RESPONSE
Licensees do not themselves have such contracts with teachers.
44.
INTERROGATORY:
Submit evidence that you have made supplies available to the teachers for administering radiation disaster treatment.
RESPONSE
Licensees do not have such evidence.
- However, no supplies are necessary for the type of minimal radiation disaster treatment teachers might be called on to administer.
See also pp. 1-3, above, regarding responsibilities for off-site emergency planning.
45.
INTERROGATORY:
Have you any evidence detailing the ability of teachers to administer radiation disaster treatment if they themselves are suffering from radiation poisoning.
RESPONSE
Licensees know of no such analysis.
46.
INTERROGATORY:
Have you identified any information proving distressed and distracted 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?
RESPO!!SE:
Licensees have no evidence that teachers, whether distracted or not, will not or cannot adequately care for their school children.
5 As to Answers:
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
By
[
L -s y
Richard P.
Remshaw Project Manager - Indian Point Hearings POWER AUTHORITY OF THE STATE OF NEW YORK
,D r k By B?u Herschel Spect(c Project Manager - Indian Point Hearings As to Objections:
CONSOLIDATED EDISON COMPANY OF NEW YORK INC.
By g,1 Brent L. Brandenburg g
Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK MORGAN ASSOCIATES, CHARTERED By 7Qpjn Jr.
Jotyph (JJ Levj, SHEA & GOULD
~
By David H. Pikus Attorneys for Power Authority of the State of New York
VERIFICATION STATE OF NEW YORK
)
ss.:
COUNTY OF NEW YORK )
RICIIARD P. REMS!!AW, being duly sworn, deposes and says:
That he is the Project flanager - Indian Point liearings 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.
~
i jv q
- /7]i/) A w RICHARD P.
REtiSilAW l
Sworn to before.me this 24t[dayof'n 1
ttay, 1982.
. J.'
( /4A\\
ikT
~
i NotaryPQlic THOMAS LOVE Motary Public State of New York No. 312409638 QuaDfied in New York C%nty Commission Expires March Ja,1M1
VERIFICATION STATE OF NEW YORK
)
SS.:
COUNTY OF NEW YORK )
HERSCHEL SPECTER, being duly sworn, deposes and says:
That he is the flanager, 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 authorized 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.
owc l
HERSCHEL # SPECTER Suorn to before me this l
24th day of May, 1982.
Notary Public DAV0 H.TeKUS Notary Pwtt:0. Stek ei N:v, Ye;k No.31/7? 7l,C Quah! cd in New Y:.4 Covety Corr.r.cctka E.:pt.we 9:.r:$ 00.1203
Respectfully submitted, M
a,
'7
[ 9?'<
.~Brahdenburg h j Charles Morgan,'/f, Jr. @'
<?
_m Brent L.
r.
Joseph J.
Levin Paul Colarulli 1899 L Street, N.W.
CONSOLIDATED EDISON COMPANY Washington, D.C.
20036 OF N EW 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 Unit 3 10 Columbus Circle New York, New York 10019 Dated:
May 24, 1982 I
f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Louis J.
Car ter, Chairman Frederick J. Shon Dr. Oscar H.
Paris
)
In the Matter of
)
Docket Nos.
)
CONSOLIDATED EDISON COMPANY OF NEW YORK, )
50-247 SP INC. (Indian Point, Unit No. 2)
)
50-286 SP POWER AUTHORITY OF Tile STATE OF NEW YORK )
(Indian Point, Unit No. 3)
)
May 24,198 2
)
CERTIFICATE OF SERVICE I hereby certify that copies of LICENSEES' RES PONSES TO PARENTS CONCERNED ABOUT INDIAN POINT'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 24th day o f May, 19 8 2.
Docketing and Service Branch Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, E sq.
U.
S.
Nuclear Regulatory Harmon & Weiss Commission 1725 I Street, N.W.,
Suite 506 Washington, D,C.
20555 Washing ton, D.C.
20006 Louis J.
Carter, Esq., Chairman Joan Holt, Project Director Administrative Judge Indian Point Project Atomic Safety and Licensing New York Public Interest Board Research Group 7300 City Line Avenue 5 Beekman Street Philadelphia, Pennsylvania 19151 New York, N.Y.
10038
(
Dr. Oscar H.
Paris John Gilroy, Westchester Administrative Judge Coordinator Atomic Safety and Licensing Indian Point Project U.S. Nuclear Regulatory New York Public Interest Commission Research Group Washington, D.C.
20555 240 Central Avenue White Plains, New York 10606 Mr. Frederick J.
Shon Janice Moore, Esq.
Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Office of the Executive Board Legal Director U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Jeffrey M.
Blum, Esq.
New York University Law School 423 Vanderbilt Hall 40 Washington Square South New York, N.Y.
10012 Marc L.
Parris, Esq.
Charles J.
Maikish, Esq.
Eric Thorson, Esq.
Litigation Division County Attorney The Port Authority of County of Rockland New York and New Jersey 11 New Hemstead Road One World Trade Center New City,- N.Y.
10956 New York, N.Y.
10048 l
l Joan Miles Ezra I.
Bialik, Esq.
l Indian Point Coordinator Steve Leipsiz, Esq.
New York City Audubon Society Enviromental Protection Bureau 71 West 23rd Street, Suite 1828 New York State Attorney New York, N.Y.
10010 General's Office Two World Trade Center New York. N.Y.
10047 i
Greater New York Council on Alfred B.
Del Bello l
Energy Westchester County Executive I
c/o Dean R.
10601 26 Stuyvesant Street New York, N.Y.
10003 i
{
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Andrew S.
Roffe, Esq.
Honorable Richard L. Brodsky New York State Assembly Member of the County Albany, N.Y.
12248 Legislature Westchester County County Office Building White Plains, N.Y.
10601 Renee Schwartz, Esq.
Pat Posner, Spokesperson Botein, Hays, Sklar & Herzberg Parents Concerned About Attorneys for Metropolitan Indian Point Transportation Authority P.
O. Box 125 200 Park Avenue Croton-on-Hudson, N.Y.
10520 New York, N.Y.
10166 Stanley B. Klimberg Charles A. Scheiner, Co-General Counsel Chairperson New York State Energy Office Westchester People's Action 2 Rockefeller State Plaza Coalition, Inc.
Albany, New York 12223 P.O. Box 488 White Plains, N.Y.
10602 Honorable Ruth Messinger Alan Latman, Esq.
Member of the Council of the 44 Sunset Drive City of New York Croton-on-Hudson, N.Y.
10520 District No. 4 City Hall New York, New York 10007 Richard M.
Hartzman, Esq.
Zipporah S. Fleisher Lorna Salzman West Branch Conse vation Friends of the Earth, Inc.
Association 208 West 13th Street 443 Buena Vista Road New York, N.Y.
10011 New City, N.Y.
10956 i
l 1
Mayor George V.
Begany Judith Kessler, Coordinator village of Buchanan Rockland Citizens for Safe 236 Tate Avenue Energy
- Buchanan, N.Y.
10511 300 New Hempstead Road New City, N.Y.
10956 Ms. Amanda Potterfield, Esq.
P.O. Box 384 Village Station New York, New York 10014 j'
l David H.
Pikus l
e __
.