ML20053B920

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Responds to Interrogatories.Certificate of Svc Encl.Related Correspondence
ML20053B920
Person / Time
Site: Indian Point  Entergy icon.png
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:
ROCKLAND CITIZENS FOR SAFE ENERGY
Shared Package
ML20053B913 List:
References
NUDOCS 8206010344
Download: ML20053B920 (41)


Text

RELATED CODDESPONDENCpt i

j' is o

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 CONSOLIDATED EDISON COMPANY OF NEW YORK, Docket Nos.

INC. (Indian Point, Unit No. 2) 50-247 SP POWER AUTHORITY OF THE STATE OF NEW YORK 50-286 SP (Indian Point, Unit No. 3)

May 24, 1982

- - - - - - - - - - - - - - - - - - - - - -x LICENSEES' RESPONSES TO INTERROGATORIES OF ROCKLAND CITIZENS FOR SAFE ENERGY f

ATTORNEYS FILING THIS DOCUMENT:

Brent L.

Brandenburg Charles Morgan, Jr.

CONSOLIDATED EDISON COMPANY MORGAN ASSOCIATES, CHARTERED OF N EW YORK, INC.

1899 L Street, N.W.

4 Irving Place Washington, D.C.

20036 l

l New York, New York 10003 (202) 466-7000 l

(212) 460-4600 l

l l

r

'82000 io3qq

TABLE OF CONTENTS O

Page PRELIMINARY STATEMENT 1

RESPONSES TO INTERROGATORIES 4

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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 Rockland Citizens for Safe Energy."

The following are general comments or objections applicable to interrogatories of Rockland Citizens for Safe Energy ("RCSE").

A.

Emergency Planning Responsibilities The RCSE interrogatories in many instances reflect a fundamental misapprehension as to the various responsibil-ities for radiological emergency planning both generically and at Indian Point in particular.

Although the Commission ultimately maintains licensing jurisdiction over nuclear power plants, the licensees' responsibility for and jurisdic-tion 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 emergency planning (see N.Y.

Executive Law, Art. 2-B).

Radiological emergency response plans and procedures ("RERP's" or " plans") for the four counties 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 obtained from the governmental authorities responsible for off-site emergency response.

Nevertheless, much of the information sought may be found in the off-site 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 This approach is analogous to the general principle of re-sponding to interrogatories, which permits reference to docu-ments as an answer where the answer may be derived or ascer-tained from such 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 derived or ascer-tained 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 afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries.

A specifica-tion shall be in suf ficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from l

which the answer may be ascertained.

l

continue to note, however, that the off-site authorities are the more appropriate sources for this type of information.

B.

Document Production In a number of instances RCSE has served inter-rogatories which are, in effect, requests for production of documents.

We note that while 10 CFR S 2.740b requires responses to interrogatories within 14 days, 10 CFR S 2.741 allows 30 days for responses to document requests.*

Accord-ingly, 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 RCSE has requested may also be encompassed by other intervenors' document requests, it may be in the interest of all parties to coordinate such requests.

i 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. i l

RESPONSES TO INTERROGATORIES 1.

INTERROGATORY:

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.

RESPONSE

a)

With regard to the portion of Contention 3.1 for which RCSE is listed as a contributing intervenor, see licensees' response to UCS/NYPIRG Interrogatory 6.

b)

With regard to Contention 3.3, the licensees' position is that the present estimates of evacuation times, based on NUREG-0654 and studies by CONSAD Research Corporation and by Parsons Brinckerhoff Quade & Douglas, Inc. are reli-able; are based upon proven assumptions; utilize verified methodologies; and conform to the actual plans.

c)

With regard to Contention 3.4, the licensees' position is that they will, in accordance with their license obligations, notify the proper authorities of conditions which might lead to an emergency promptly and accurately enough to assure effective response, in accordance with Commission require-ments.

d)

With regard to that portion of Contention 4.2 as to which RCSE is listed as a contributing intervenor, the licensees' position is that adequate sheltering capability exists for residents of the plume EPZ.. - -

[

e)

With regard to Contention 4.7, the licensees' position is reflected in their response to WESPAC Interrogatory 10 and Parents' Interrogatory 11.

2.

INTERROGATORY:

With respect to each of RCSE's contentions, please (a) identify each person whom the party expects to call as an expert witness concerning the contention; (b) state the subject matter on which the expert witness is expected 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.

RESPONSE

See responses to UCS/NYPIRG Interrogatories 1 and 2.

3.

INTERROGATORY:

Please identify all other persons whom the parti expects to call as witnesses concerning the issues raised by the RCSE 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.

RESPONSE

See responses to UCS/NYPIRG Interrogatories 1 and 2.

4.

INTERROGATORY:

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

RESPONSE

Licensees' response is annexed hereto as Exhibit A.

5.

INTERROGATORY:

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

RESPONSE

i The licensees object to this interrogatory on the grounds that it is premature.

The licensees cannot take a position with respect to this interrogatory until RCSE witnesses have been identified, discovery has been completed, and testimony has been pre-filed.

6.

INTERROGATORY:

What equipment, manpower and training shortfalls does Rockland County have with respect to 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 neeoad 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 complying with the evaluation criteria of NUREG-0654 Sec. II F and II G with respect to Rockland County.

RESPONSE

l See responses to UCS/NYPIRG Interrogatories 4-6, and pp.

1-3, above, regarding responsibilities for off-site radiological emergency planning.

Although the licensees are not responsible for assessing off-site planning, we note that the Federal En.ergency Management Agency (" FEMA") will issue an assessment of the Rockland County plans following its report on the March 3, 1982 Indian Point exercise.

7.

INTERROGATORY:

With respect to contention 3.3, please provide a listing of all evacuation plan estimate 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 pertaining to these studies, and updates of the studies, including the date of all such documents and updates.

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

e

RESPONSE

The following studies have been prepared by Parsons Brinckerhoff Quade & Douglas, Inc.:

1.

" Evacuation Time Estimates for Areas Near the Site of the Indian Point Power Plants,"

January 31, 1980.

2.

Draft " Methodology to Estimate Roadway Travel Times during Evacuation," January 1981.

3.

Radiological Emergency Response Plan and Pro-cedures, Revision 1 (August 1981); Appendices A, G,H, and K and Attachment 1 to each agency procedure for the following counties:

West-chester, Putnam, Rockland and Orange.

4.

Draft " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone," November 1981.

5.

Draft " Guidelines for Updating the Evacuation Portions of the Indian Point Radiological Emergency Response Plan and Procedures,"

April 1982.

See p.

3, above, concerning responses to document requests.

Licensees note that any studies done by CONSAD Research Ccrporation were commissioned by FEMA or others.

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8.

INTERROGATORY:

Please identify which version, if any, of the Rockland County Radiological Emergency Response Plan was relied l

upon in each of the studies or updates.

Please identify what l

studies were made of traffic patterns immediately outside of the 10 mile EPZ and of their effects upon traffic egress from

,the 10 mile EPZ.

Please identify the " level of service" assump-tions used in computing the evacuation time estimates in any known studies and the reasoning for selection of those levels of service in Rockland County.

RESPONSE

The Rockland County Radiological Emergency Response Plan and Procedures, Revision 1 (August 1981) was used in the preparation of the following studies:

Draft " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone," November 1981.

Draft " Guidelines for Updating the Evacua-tion of the Indian Point Radiological Emergency Response Plan and Procedures,"

April 1982 No detailed studies of traffic patterns immediately outside the plume EPZ were made.

However, there are provisions in the Rockland County RERP for the expediting of traffic flow beyond the plume EPZ.

The level of service assumptions incorporated in the evacuation travel time estimates are contained in the draf t document " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone" in Section III Al (Evacuation Capacity Analysis) and Appendix E l

(Methodology to Calculate Evacuation Capacities).

9.

INTERROGATORY:

Please identify all bottlenecks revealed by any evacuation time estimate studies done for Rockland.

State l

any time estimates that have been computed regarding traffic l

flow that does not progress in the optimal manner according to the plan.

RESPONSE

i Locations of potential maximum delays for evacuees revealed by the evacuation time estimate studies done for l

~

Rockland are indicated in Section IV 1 (Critical Locations) of the draft document " Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone."

The RERP does not assume that all traffic will flow in an optimal manner.

Evacuation travel time estimates were calculated for varying conditions, as described in Tables A-4 through A-7 in Appendix A of the Rockland County RERP.

10.

INTERROGATORY:

Please state the date and time of any and all events which would be classified as unusual events, site alerts, site emergencies or general emergencies 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 pertain-ing to the NRC investigation of the October 1980 fan cooler leak accident.

RESPONSE

Since the classification system referred to above went into effect there have been no such events at Indian Point 2.

With regard to the 1980 fan cooler leak incident at Indian Point 2, all documents related to the NRC's investiga-tion should be available for inspection and copying at the NRC's Public Document Rooms.

With regard to Unit 3, the following is a list of unusual events reported to the NRC since the new classifica-tion system went into effect:

EMERGENCY PLAN ACTIVATION 1982 1981 3-24-82 NUE*

l-24-81 NUE minor release (Techspecs)

Bomb threat Declared: 2358 Declared : 1914 offsite Notification: 2359 Offsite Notification: 1936 3-10-82 NUE 2-25-81 NUE microseismic event Bomb threat Declared: 1027 Decla red:

2352 Offsite Notification: 1039 Offsite Notification: 0014 3-14-82 NUE 5-18-81 NUE microseismic event microseismic event Declared: 1440 Declared: 1025 Offsite Notification: 1445 Offsite Notification: 1025 1980 6-20-81 NUE Bomb threat 9-4-80 NUE Declared : 0220 microseismic event Offsite Notification: 0237 Declared: 1140 Offsite Notification: 1246 6-21-81 NUE microseismic event 10-16-80 NUE Declared: 1520 microseismic event Offsite Notification: No Recorded Declared: 1700 Time Offsite Notification: 1715 7-22-81 NUE 12-13-80 NUE Bomb threat microseismic event Declared : 0220 Declared: 1137 Offsite Notification: 0237 Offsite Notification: 1200 1-20-81 NUE Bomb threat Declared: 1647 Offsite Notification: 1710 10-21-81 NUE microseismic event Declared: 1424 Offsite Notification:

No Recorded Time

  • Notification of unusual event. _ __

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11.

INTERROCATORY:

Please identify any studies on sheltering capability within the EPZ in Rockland County.

Please identify any standards known for sheltering factors in radiological emergencies.

It is requested that the NRC Staff provide any documents and testimony related to sheltering and air turnover rates in buildings.

RESPONSE

Several studies of sheltering capability and effectiveness have been performed that are applicable to the area in question although they were not specifically performed for that purpose.

Most such studies are generic in nature inasmuch as they evaluate various types of structures with respect to their shielding effectiveness and then may be applied as needed to any part of the country.

The results of surveys of structures on a state-by-state basis, the average shielding factors to be used and the technical justification for their use are presented in the following reports prepared by Sandia Laboratories:

(1)

Aldrich, D.C. and D.M.

Ericson, Jr., Public Protection Strategies in the Event of a Nuclear Reactor Accident:

Multi-compartment Ventilation Model for Shelters, SAND 77-1555, January, 1981 (2)

Aldrich, D.C.
Ericson, D.M.,

and Johnson, J.D.,

Public Protection Strategies for Potential Nuclear Reactor Accidents:

Sheltering Concepts with Existing Public and Private Structures, SAND 77-1725, February, 1978 -

There are no standards, as such, for sheltering factors in radiological emergencies.

There is, however, a standard methodology to be used in evaluating structures, basements and natural shields (e.g. terrain, curbs) for their protective effectiveness.

This standard technology, much of which is independent of the absolute magnitude of the source term, is applicable to any radiological emergency and is contained in the following documents as well as many others:

(1)

OCD PM-100-1, Office of Civil Defense,

" Design and Review of Structures for Protection from Fallout Gamma Radiation,"

(February, 1967).

(2)

OCD TR-20 Vol.1, Office of Civil Defense,

" Shelter Design and Analysis,"

(January, 1970).

Application of this technology to various types of structures and experimental verification of the methodology are reported in numerous documents prepared for the office of Civil Defense.

In addition, a study was prepared regarding shielding and ventilation calculations for the Rockland County Fire Training Center.

12.

INTERROGATORY:

What proportion of the population within the Rockland County EPZ is known to be deaf, blind, too young to understand instructions in the Emergency Planning brochures or unable to apeak English?

What special provisions have been taken to inform these populations of an emergency?

l

RESPONSE

See response to UCS/NYPIRG Interrogatory 25.

l RESPONSE TO INTERROGATORY 4(a):

Annexed hereto are bibliographies of articles, books or scholarly works published or presented by Dr. Russell R.

Dynes and Dr. Sidney Lecker.

To the licensees' knowledge, Bruce E.

Podwal has not published or presented such items.

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,.n e,

Russell E. Dyi.es Publications:

Books:

1964 Social Problens:

Dissensus and Deviation in an Industrial Society.

New York: Oxford University Press.

594 pp.

(Co-a u tho r).

1969 Deviance:

Studies in the Process of Stigmatization and Societal Reaction.

New York:

Oxford University Press.

(Co-author).

1970 Organized Behavior in Disaster.

Lexington:

D. C. Heath.

236 pp.

(Republished 1976).

1975 Social Movenents, Violence and Chance:

The May Move-ent in Curacao.

Columbus:

The Ohio State University Press.

(Co-author).

1975 Deviance:

Definition, Management and Treatment.

New York:

Oxford University Press.

(Co-author).

1982 Sociology in Apolied Settines, (tentative title)

(Howard Freeman, Russell R. Dynes, Peter Rossi, William Foote Whyte, eds.)

Chaeters, Mono:raphs, and Reports:

1.

1951 Homes for the Homeless in Tennessee.

Knoxville:

The University of Tennessee.

Publication of the Bureau of Sociological Research, The University of Tennessee Record Extension Series, Volume 27, No. 4, 67 pp.

(with William E. Cole).

2.

1954 "The Urban Class System" and "The Urban Religions."

Pp. 115-141 and 191-209 in Uilliam E. Cole (ed.), Dynamic Urban Sociolonv.

Harrisburg:

Stackpole Press.

3.

1955 Mobile Industrial k'orkers and the Church:

A Study of People en the Move in Chic's Atomic Area.

Sational Council of Churches, Division of Home Missions.

31 pp.

4.

1956 Consecuences of Population Mobility for School and Community Chance.

Columbus:

School-Community Development Study, The Ohio State University.

132 pp.

5.

1957 Social Factors Related to Adactability of Air Force Pilot Trcinees.

Columbus:

Research Four.dation, The Ohio State University.

176 pp. (with Alf red Clarke and John Cuber).

6.

1959 "The Relation of Community Characteristics to cdligious Organization and 3ehavior."

Pp. 253-263 in 'brvin Sussman (ed.), Corrunite Structure and Analysis.

Ne:. York:

Thomas Y. Crowell Co.

L.

Publications (continued) :

_ Chapters, Monographs, and Reports (continued):

7.

1960 "The Inner City Church."

Pp. 15-18 in John Lane Milliams (ed.), Our '41ssion to the City.

Report of Methodist Inner City Conference.

8.

1964 "Some Preliminary Observations in Organizational Responses in the Emergency Period after the Niigata, Japan Earthquake of June 16, 1964."

Research Report #11, Disaster Research Center, 49 pp. (with J. E. Haas and E. L. Quarantelli),

(Republished in entirety in Japanese by Japanese Government).

9.

1964 "Some Preliminary Observations of the Response of Community Organizations Involved in the Emergency Period of the Alaskan Earthquake." Working Paper F2, Disaster Research Center, 28 pp. (with J. E. Haas and E. L. Quarantelli).

10.

1966 Observations on Social Change.

Sirs-el-layyan, UAR:

Arab States Center for Education for Community Development.

44 pp. (in English and Arabic).

11.

1967 Acceptance of Change. Part I.

Sirs-el-layyan, UAR:

Arab States Center for Education for Ccmmunity Developrent.

29 pp. (with Louis K. Meleika).

12.

1968 The Functienine of Established Organizations in Cernunity Disasters.

Report Series No.

1.

Columbus :

Disaster Research Center.

52 pp. (with George Warheit).

13.

1968 " Operational Problems of Organizations in Disasters."

Pp. 151-176 in 1967 E.ergency Ooerations Symposium.

Santa Monica:

System Developrent Corporation.

14.

1969 Community Priorities in the Anchorage, Alaska Earthquake1 1961 Monograph Series No. 4 Columbus :

Disaster Research Center.

173 pp. (with Daniel Yutzy, nr.jor author, and Willian Anderson).

15.

1969 The Functioning of Expandine Orcanizations in Cc== unity Disasters.

Report Series No. 2.

Columbus:

Disaster Research Center.

82 pp.

16.

1969 Organized Behavior in Disaster:

Analysis and Conceptualiza-tion.

Columbus:

Disaster Research Center.

254 pp.

(Republished 1970.

Lexington:

D. C. Heath).

17.

1970 "Different Types of Organizations in Disaster Response and Their Operatienal Prob 1 cms."

In Robert Brictson (ed.),

Energence Operntions.

Les Angeles:

Tinnen-;rown.

(uith E. L. Quarantelli).

Publications (cont:

Chapters, "onographs, and Reports (continued):

18.

1970 Disruotion on the Canpuses of Ohio College and Universities, Spring. 1970.

Report prepared for the Ohio Council of Churches and Ohio Board United Ministries in Higher Education.

119 pp. (with E. L. Quarantelli).

(Several sections of this have been reprinted elsewhere.)

19.

1971

" Community Conflict:

An Explanation of Its Absence in Natural Disaster."

Pp. 220-204 in Clagett C. Smith (ed.),

Ccnflict Resolution:

Contributions of the Behavioral Sciences.

Notre Date:

University of Notre Dame Press.

(with E. L. Quarantelli).

20.

1971 Environrent Crises.

Columbus:

Water Resources Center, The Jan.

Ohio State University.

91 pp. (with Dennis Wenger).

21.

1971 A Model of Corrunity Problem Solving and Selected Enoirical Dec.

Applications.

Coluabus:

Water Resources Center, The Ohio State University.

153 pp. (with Dennis Wenger).

22.

1972

" Cross Cultural Perspective on Disaster."

Pp. 235-257 in Proceedings of the Japan-United States Disaster Ecscarch Seminar:

Orcanizational ced Co munity cspenses to Disaster.

Columbus:

Disaster Research Center.

23, 1972 A Persoective on Disaster Plannin2.

Report Series No. 11.

Columbus:

Disaster Research Center.

94 pp. (with E. L.

Quarantelli and Gary Kreps).

24 1972 " Police Department Planning for Civil Disturbances:

Orr,ani-zational Factors involved in Changes."

Pp. 76-88 in F. Adler and G. O. W. Mueller (eds.), Politics. Crime and the International Scene:

in Inter-A erican Focus.

Hato Rey, PR: North South Press.

(uith M. Brooks and E. L.

Quarantelli).

25.

1972 Police Perspectives and Behavior in a Cancus Disturbance.

'by Colunbus:

Disaster Research Center.

166 pp. (with E. L.

Quarantelli and James L. Ross).

26.

1974

" Organizations as Victins in Arerican Mass Racial Disturbances:

A Reexamination."

Pp. 121-142 in E. C. Vivano and Israel Drapkin (eds.), Victinoloev.

Volume 4.

Lexington:

D. C.

Heath.

(with E. L. Quarantelli).

27.

1974 " Police Perspectives and Behavior in a Carpus Disturhance."

In Donal MacNamara and ':are Riedel (eds.), Police:

Persrectives.

Problens and_Prospectiv: 1.

'M Yerh:

Praeger.

(win.

E. L. Quarantelli and James L. Ross).

1 1

.n Publications (continued):

Chapters, Monographs, and Reports (continued):

28.

1974 The Role of Local Civil Defense in Disaster Planning.

Report Series No. 16.

Columbus:

Disaster Research Center.

105 pp. (with E. L. Quarantelli).

29.

1975 The Delivery of Mental Health Services in the Xenia Tornado.

Columbus:

Disaster Research Center.

280 pp. (with E. L.

Quarantelli and others).

30.

1975 " Rapport sur les activities du Disaster Research Center."

Pp. 23-44 in Les Ccmoortements Associes Aux Catastrophes.

(Table Ronde du Centre National de la Recherche Scientifique)

Paris:

Institut International du Feu. (in French and English) (with E. L. Quarante111).

31, 1976 " Emergency Disaster Plans for Vocational Schools."

Pp. 151-161 in Developing the Leadership Potential of Urban Vocational Education Administrators.

1976 National Leadership Seminar for Administrators of Vocational Education in April.

(with E. L. Quarantelli).

32.

1976 "The Family and Community Context of Individual P.eactions to Disaster."

Pp. 231-245 in H. J. Parad, H. L. P. Resnick, and Liboie Parad (eds.), Emercency and Disaster Manatenent.

Bowic:

Charles Press Publishers.

(with E. L. Quarantelli).

33.

1976 Organizational Communications and Decision Makinz in Crises.

May Columbus:

Disaster Research Center.

58 pp. (with E. L.

Quarantelli).

34.

1977 " Crises and Disaster Research." In Annual Review of Sociology.

Volume 3.

Palo Alto:

Annual Reviews Inc.

(with E. L.

Quarantelli).

35.

1978 "Interorganizational Relations in Communities Under Stress."

l Pp. 50-64 in E. L. Quarantelli (ed.), Disasters:

Theory and Research.

London:

Sage Studies in Sociology.

36.

1979

" Helping Behavior in Large Scale Disasters." In Jacqueline MacCauley and David Horton Smith (eds.), Handbcok of Informal Participation.

San Francisco:

Jossey-Bass.

(with E. L.

Quarantelli).

37.

" Disasters and Emergency Medical Services."

In Proceedings of First International Svrposium on Emergency Medical Services.

Forthcoming.

J

Publications (continued)

Chapters, Monographs, and Reports (continued):

38.

1979, Report of the Emergency Preparedness and Restonse Task Force, Staff Report to the President's Commission on the Accident at Three Mile Island, Washington, U.S. Covernment Printing

Office, 168 pp.

39.

1981 "The Contributions of the Social Sciences to the Evaluation of Emergency Preparedness and Response" in D. Sills, C. Wolff and E. Shelanski, (eds.) The Accidant at Three Mile Island:

The Human Dimension, Boulder, Westview Press 40.

1981 " Biography of a Colleague" in R. Huff and I. Barak-Glantz (eds.)

The Mad, The Bad and The Dif ferent, Lexington, Lexington Bocks (with Alfred Clarke).

41, 1982 "Models of Emergency Planning:

Contributions From the Social Sciences" in Proceedings of the Third International Conference:

Social and Economic Effects of Earthquakes and Planning to Mitigate Their Ef fects.

(forthcoming) 42.

1982 " Perspectives on Applied Educational Programs" in Freeman et al, Sociolony in Applied Settines, (with Irwin Deutscher) l l

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Publications (continued):

Articles:

1.

1954 " Preference for Male and Female Children:

Traditional or Affectional." !brriaga and Family Living 16::128-130 (:by).

(with Simon Dinitz and Alf red Clark).

2.

1954 "Toward the Sociology of Religion." Sociology and Social Research 38:227-232.

3.

1955 " Church-Sect Typology and Socio-Economic Status." American Sociological Review 20:555-560.

4.

1956 " Levels of Occupational Aspiration and Selected Aspiration and Selected Aspects of Family Affection." American Socioloaical Review 21:212-215.

5.

1956 " Sectarianism, Ruralality and Migration." Rural Sociology 21:25-28 (March).

6.

1957 "The Consequences of Sectarianism for Social Participation."

Social Forces 5:331-334.

7.

1957 " Correlates of Marital and Sex Roles."

The Graduate School Record, The Ohio State University 2:9-10 (December).

(with Alfred Clarke and Simon Dinitz).

8.

1959 " Levels of Aspiration and Family Affection:

Religious Preference as a Variable." The Ohio Journal of Sciences 59:103.(March).

(with Alfred Clarke and Simon Dinitz).

9.

1963 " Student, Faculty and the Nature of the University."

Faculty Forum, Volume 25, May.

10.

1965 "The Religious Interpretation of Disaster." Topic 10:34-48 (Fall).

(Washington, PA:

Washington and Jeffersen College)

(with Daniel Yutzy).

11.

1965 "Three Ladies of Sirs-el-layyan." Vieupoints (Washington:

Friends of the Middle East), Volume 5, No. 9 (November).

12.

1966 " Natural Disaster as a Social Science Field." National-Review of the Social Sciences 3:85-94.

(also sunnary in Arabic).

~

13.

1966 " Theoretical Problems in Disaster Research." Bulletin of Business Research 41: 7-9 (September).

14.

1967 " Administrative, Methodological and Theoretical Problems of Disaster Research."

Indian Sociolo"ical "ulletin 4.4:

215-227 (Jul)).

(With E. L. Quarantelli and J. E. Haas).

Publications (continued):

Articles (continued):

15.

1967 " Impact of Disaster on Community Life."

EMO National Digest 7:10-13 (April).

16.

1967 " Societal and Community Problems in Disaster." EMO National Digest 7:16-18 (October).

17.

1968 "The Church in Higher Education." Leader 10:1-6 (April).

18.

1968 " Collective Stress and Its Relation to Water Resource Planning." Proceedine of Ucrkshop on Socioloeical Aspects of Water Resources Research, Utah State University.

19.

1968 " Group Behavior Under Stress:

A Required Convergence of Organizational and Collective Behavior Perspectives."

Socioloev and Social Research 52:416-429.

(with E. L.

Quarantelli).

20.

1968 " Looting in Civil Disorders:

An Index of Social Change."

The American Behavioral Scientist, Vol ume 2, March.

(with E. L. Quarantelli).

21.

1968 " Looting in Civil Disturbances and Disasters." Trans-Action 5 :9-14 (:'ay).

(with E. L. Quarantelli).

22.

1968 " Redefinitions of Property Nores in Community Energencies."

International Journal of Lecal Research 3: 100-112 (December).

(with E. L. Quarantelli).

23.

1968 "A Sociologist Looks at Water Resources Research."

Proceedings of the Uater Resources Collocuium.

Institute for Research on Land and Water Resources, ?ennsylvania State University.

24.

1969 "Dissensus and Consensus in Community Erergencies:

Patterns of Looting and Property Norrs."

IL Pclitico, Revista di Science Politiche 34:276-291.

(with E. L. Quarantelli)

(includes an Italian surrary).

25.

1969 " Organizations in Disaster." EMO National Dicest 9:12-13 l

( April-!by).

(with George Warheit).

26.

1969 " Looting Patterns in Community Disasters and Disturbances."

Proceedings of the Third National Svmposium on Law Enforce-cent and Technologv.

Chicago:

IIT Research Institute.

pp. 323-327 (uith E. L. Quarantelli).

27.

1970 " Editors' Introduction." American Behavinrni Scientist 13:325-330.

(with E. L. Quarantelli).

2S.

1970 " Organization as Victim in Mass Civil Disturbances."

Issues _

in Crininn'ory 5 : 191-19 3 (Sur. ar). ( -ith E. L. Quarantelli).

I J

Publications (continued) :

Articles (continued):

29.

1970 " Organizational Involvement and Changes in Community Structure in Disaster." American Behavioral Scientist 13:4.70-439.

30.

1970 " Property Norms and Looting:

Their Patterns in Community Crises." Phylon 31:168-182 (Summer).

(with E. L.

Quarantelli).

31.

1971 " Factors in Community Perception of Water Resources Problems."

Water Resources Bulletin 7:644-651.

(with Dennis Wenger).

32.

1972 "The Principle of Least Interest, Dating Behavior and Family Integration Settings." Journal of Marriace and Family 34:269-272.

(with K. Eslinger and Alfred C. Clarke).

33.

1972 "When Disaster Strikes (It Isn't Much Like What You've Heard About)." Psycholoev Today 5:66-70 (February).

(with E. L. Quarantelli).

34.

1973 " Editors' Introduction." American Behavioral Scientist 16:305-311.

(with E. L. Quarante111).

35.

1973 "On Institutionalization of Sociology in the United States."

Sociolocical Focus 6:1-xxvi (S ummer).

36.

1973 " Organizational and Political Transformaticn of a Social Movement:

A Study of the 30th of May Movement in Curacao."

Social Forces 51:330-341.

(with William Anderson).

37, 1973 " Postscripts to a Presidential Address." Footnntes 1:8 (November).

38.

1974 "Counterrioters in Urban Disturbances:

Opponents or Supporters of the Status-Quo?" Society 11:50-55 (March-April).

39.

1974 " Police Perspectives and Behavio: in a Canpus Disturbance."

Journal of Police Science ant *.ainistration 2:344-351.

(with E. L. Quarantelli and James L. Ross).

40.

1974 " Sociology as a Religious Movement:

Thoughts on its Institutionalization in the United States."

The Aretican Sociologist 9:167-176 (November).

41.

1974 "The Sociology of Religion of Charles Glock:

Review Essay."

Journal of Scientific Study of Relicion 12:466-469.

42.

1975 "Iae Comparative Study of Disastar:

A Social Organizational Approach."

'iass Enercencies 1:21-31.

I 4

_ _ =.

t Publications (continued):

Articles (con tinued) :

43.

1976 " Civil Disturbances and Social Change:

A Comparative Analysis of the United States and Curacao." Urban Affairs Quarterly, September.

(with William Anderson).

44.

1976 " Community Conflict:

Its Presence and Absence in Natural Disaster Situations." Mass Emercencies 1:139-152.

(with E. L. Quarantelli).

45.

1976 "The Impact of Devotionalism and Attendance on Ordinary and Emergency Helping Behavior." Journal of Scientific Study of Relicion 15:47-59 (March).

(with Lynn Nelson).

46.

1977 "A Background Note on the Preliminary Findings and Impressions j

of the DRC Studies." Mass Emergencies 2:147-150.

i 47.

1978 " Organizational Adaptation to Crises." Disasters, Volume 3, No. 1, March.

London:

International Disaster Institute.

(with Benigno Aguirre).

J 48.

1978

" Participation of Sociologists in the Fulbright Program",

I FOOTNOTES, Novedber 1

49.

1980 " Sociology in China:

Its Restoration and Future Role", FOOTNOTES, October 50.

1981 "The View From Inside", The American Sociologist, 16: 97-101, May l

l s

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Publications (continued):

Reprints of Articles:

1957 No. 3 in J. Milton Yinger.

Religion, Society and the Individual.

New York:

Macmillan.

1962 No. 4 in John F. Cuber and Peggy Harroff.

Readings in Sociolonv.

New York:

Appleton Century.

And in Bartlett H. Strudley.

Society and Self:

A Reader in Social Psycholocy.

New York:

Free Press.

1963 No. 9 in Grappling With Ideas.

Menominie:

Stout State College.

1966 No. 14 in Roles des Acences Familiales Dans Les Disasters.

Ottawa:

Ministre de la Sante-nationale et du Bein-etre.

1967 No. 3 in Dwight Dean and Donald Valdes.

Experiments in Sociology.

New York:

Appleton Century.

And in liarvin Shaw and Jack Wright.

Scales for the Measurement of Attitudes.

New York:

McGraw-Hill.

1968 No. 4 in Robert Rankin and Ritchie Lowery.

Sociology:

A Science of Society.

New York:

Charles Scribners Sons.

1968 No. 20 in New Society (August 8th).

And in Don Dowen and Louis Mascotti.

Riots and Rebellion.

Severly Hills:

Sage. And in Survival, Volume 4, No. 6 (December).

1968 No. 21 in Current (August).

1969 No. 3 in John Robinson and Phillip Shaver.

Measures of Social Psychological Attitudes.

Ann Arbor:

Institute of Social Research.

1969 No. 20 in Sinon Dinitz, et. al.

Deviance.

New York:

Oxford University Press.

1969 No. 21 in Rodney Allen and Charles Adair.

Violence and Riots in Urban Arerica.

Columbus:

Charles Jones.

1969 No. 17 in Faculty Forum (March).

And in The Christian (April).

1970 No. 21 in James Short, Jr.

Modern Crininals.

Chicago: Aldine.

And in Bobbs Merrill Reprint Studies in Black History, BC 72.

1971 No. 20 in Nils Bateman and David Petersen (eds.).

Targets for Change:

Perspectives on an Active Sociology. Waltham:

Xerox.

1971 No. 21 in H. Taylor Buckner.

Deviance:

Realitv and Chan;e,.

New York:

Random House.

1971 No. 30 in James Geschwender.

The Black Revolt.

New York:

Prentice-Hall.

1972 No. 4 in Robert Rankin and Ritchie Lowry.

Sociolo v:

Social Science and 9cefal Ceaccrn.

New York:

Charles Scribners Sonn.

(also in paperback).

Publicaefons (continued):

Reprints of Articles (continued):

1972 No. 20 in A. Birenbaum and E. Sagarin.

Social Problems:

Private Troubles and Public Issues.

New York:

Scribners.

1972 No. 21 in James Conyers and Morris Medley.

Sociolocy in the Seventies.

New York: Wiley.

And in Ralph Turner and Lewis Killian.

Collective Behavior.

New York:

Prentice-Hall.

1972 No. 33 in Readers Digest (July).

1973 No. 28 in Walter Reckless.

The Crime Problem.

New York:

Appleton Century.

1973 No. 33 in New Society (January 4th).

1973 No. 31 in Impact of Water Resources Development.

New York:

Environment Information Center.

1973 No. 32 in Wenen, A Random House Annual, 1972.

New York:

Random House.

1973 Pp. 4-10 of Social Problems in Clifford Bryan.

Social Chance, Conflict and Education:

A Foundations Text and Reader.

Columbus:

Charles "errill.

1973 No. 21 in James Short, Jr. (ed.),

Law and Order:

Modern Cririnals.

Transaction (2nd ed.).

1973 No. 21 in Peter Rossi (ed.), Ghetto Riots.

Transaction (2nd ed.).

1974 No. 20 in Stuart Palmer (ed.), New Perspectives on Deviance.

Chicago:

Aldine.

1974 No. 28 in Enilio Vivano and Israel Drapkin (eds.), Victiro'o;y.

j Lexington:

D. C. Heath.

l 1975 No. 30 in Simon Dinitz, et. al.

Deviance:

Definition,.Manaccrent, Treatment.

New York:

Oxford L'niversity Press.

1975 No. 37 in Volume in honor of...

1975 No. 33 published as "Wenn Die Katastrophe Kommt:

Wie Sich Dann l

Wirklich Verhalten, Psycholoev Heute, June 1979 No. 21 in Robert L. Ellis and Marcia J. Lipetz, Essential Sociolocv, I

Glenview, Illinois, Scott Forcsr.an and Co.

1982 No. 40 in Eduard Tir: aklan, The Phenorenan of Socioloy;., New York, Irvington Publishers l

Editing:

Editor, The Ohio Valley Sociologist, 1958-63.

Editor, Newsletter, Ohio Council of Family Relations, 1960-64 Editor, Speci.,1 Issue, "On the Sociology of Religion," Sociolocical Focus, Volume 2, No.

1, 1963.

(also Editor's Introduction, pp. 1-2).

Editor, Consultant on social problems concepts, Dictionary of >!odern Sociology, Littlefield, Adams and Co., 1969, Thomas F. Hoult, ed.

Co-Editor, Special Issue, " Organizational and Group Responses to Community Disaster," American Behavioral Scientist, Volume 13, No. 3 (January-February), 1970.

Co-Editor, Special Issue, " Dynamics of Organizational Involvement and Change in Civil Disturbances," American Behavioral Scientist, Volume 16, No. 3 (January-February), 1973.

Associate Editor, Review of Relicious Research, 1968-77.

Co-Editor, Disaster Research Center Series.

Reviewer for a number of journals raning f rom Journal of Scientific Study of Religion to Science.

Editor, ASA Footnotes, 1977-l l

i l

l s

I l

PUBLICATIONS OF DR. SIDNEY LECKER SCIENTIFIC PUBLICATIONS:

LECKER, S.,

et al.,

"Brief Intervention:

A Pilot Walk-In Clinic in Suburban Churches."

i The Canadian Psychiatric Association Journal, Vol. 16, 1971.

LECKER, S.,

Coping with Drug Abuse, A Community Social Action Approach.

Canada's Mental Health -

Supplement No. 64 March-April, 1970.

LECKER, S.,

Coping with Drug Abuse, An Indigenous Multi-disciplinary Clinic for Youth.

Canada's Mental Health -

Supplement No. 64 March-April, 1970.

LECKER, S., Adolescence - A Cultural Dilemma.

McGill Journal of Education.

Vol.

V, No. 1-Spring 1970.

LECKER, S., Changes in Youth Culture, The Doctor's Role. Guest Editorial, International Journal of Surgery, Sept. 1971, Vol. 56, No.

3.

LECKER, S.,

Innovative Services for Youth, Tape, Behavioral Science Tape Library, 1972.

LECKER, S.,

Family Factors, Interpersonal Competence and Drug Addiction.

The Addiction Therapist, Vol.

1, No. 2 - Spring ~1975.

LECKER, S., et al., New Approaches to Adolescent Psychotherapy, A Therapeutic System Approach.

The Pediatric Clinics of North America, 20: 883, November 1973.

1 L

SCIENTIFIC PUBLICATIONS: (continued)

LECKER, S.,

Family Therapies.

Treatment Methods of Mental Disorders.

(Chapter) A Handbook, Edited by Benjamin Wolman, published by Van Norstrand Reinhold 1976.

LECKER, S.,

and BOYNTON, G.,

Psychological Effects of Abortion (Chapter)

Psychological Aspects of Obstrectrics and Gynecology.

Published by Medical Economics Company ME Book Division, Editor Benjamin Wolman.

BOYNTON, G.

and LECKER, S.,

Psychological Aspects of Miscarriage and Stillbirth.

Psychological Aspects of Obstrectrics and Gynecology.

Published by Medical Economic Company ME Book Division, Editor Benjamin Wolman.

i

LECKER, S., The Natural Way to Stress Control, (Book),

Grosset & Dunlap, 1978.

LECKER, S., The Money Personality, (Book)

Simon and Schuster, March 1979.

LECKER, S., Who Are You, (Book) Simon and Schuster, May, 1980.
LECKER, S., Family Ties, (Book) Wyden Books, December, 1980.

PAPERS:

1964 - Quebec Society of Criminology -

" Criminal Acting-Out as Part of a Depressive State."

(Multiple co-authors - junior author).

1965 - Fifth International Criminological Congress -

"The Role of Guilt and Shame in the Genesis of Criminal Behavior."

1975 - Paper, 31st International Congress on Alcoholism and Drug Dependence, Bangkok, Thailand, February, 1975

" Family Factors, Interpersonal Competence and Drug Addiction."

. =.-

t i

i PAPERS:

(continued) l 1975 - Paper, National Drug Abuse Conference, New Orleans, Louisiana, April, 1975:

" Therapeutic Community:

A Generation Later."

1976 - Therapeutic Communities of America, Washington, j

D.C.

" Sexual Problems in the T C "

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RESPONSE TO INTERROGATORY 4(b):

The following are proceedings in which witnesses identified by licensees have previously testified:

Bruce E. Podwal:

In re Power Authority of the State of New York (Arthur Kill Station - Application of the Power Authority of the State of New York for Certificate of Environmental Compatability and Public Need to Construct a 700 MW fossil-fueled electric generating unit at Staten Island, New York),

before the Board on Electric Generation, Siting and the Environment, Case No. 80,004.

Power Authority of the State of New York, (Greene County Nuclear Power Plant), betore the Atomic Safety and Licens-ing Board, Docket No. 50-549.

Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1), before the Atomic Safety and Licensing Board, Docket No. 50-289-SP.

New York State Public Service Comission Hearings on Interstate Route 787 (Albany, New York)

New York State Department of Environmental Conservation Hearings (Construction of Crossgates Mall) (Guilderland, New York).

Dr. Russell R.

Dynes:

Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1), before the Atomic Safety and Licensing Board, Docket No. 50-289-SP.

Dr. Sidney Lecker:

Dr. Lecker has not previously testified on emer-gency planning or radiological matters.

He has testified on matters not herein relevant in family law and criminal proceedings, but only on behalf of his patients.

Licensees object to further identification of such proceedings on the grounds that it is beyond the scope of the Commission's Questions and disclosure would be against public policy.

l

As to Answers:

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.

i 9 J-h { } fl;.

')

'.js~L f.<

By

^u~/m /

Richara P.

Remshaw gry' Project Manager - Indian Point Hearings POWER AUTHORITY OF THE STATE OF NEW YORK By

'M Heru6hel Spe'ctef Project Manager - Indian Point Hearings As to Objections:

CONSOLIDATED EDISON COMPANY OF NEW YORK INC.

By

, h-

.l IJA I,

~'

Brent L.

Brandenburg g-)

Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK s

s MORGAN ASSOCIATES,' CHARTERED

'~}S xe,s'

'N

-/$.

3 I

3 u es m

By Joseph J.'- Levin' Jr.

,q'g l

SHEA & GOULD By av'

. P_.ve 2

l David H.

Pikus 1

Attorneys for Power Authority of the State of New York e

y r e

VERIFICATION STATE OF NEW YORK

)

o 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.

l ll 'jh

/

V

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j\\ / u

%:' /

/\\t11-l~.

' RICHARD P.

REMSHAW Sworn,to before me this 24thJ ay of.May, 1982.,

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dO u Q.)

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Notary PuMic THOMAS LOVE Matary Public State of New Yoft No. 312409638 Qualified in New York CCbnty Commission Expires March R,1381 l

l

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 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.

lin f

HERSCHEL / SPECTER S, worn to before me this 24th day of May, 1982.

Am

~

Notary Publi~c D/o"O 11. 9 Mi!^,,

N tar / F bhr,3!.:.; ei.n.i V:.t I b. 2; -:7?'.:Je Outf cf ?n Nv: Y:.:t (c. c:j Con.r.n:!n E@!m f.:L:5 0,: L '.':

Respectfully submitted, m

i 4

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s ie _ ',

( JL. ( f_

, _ '..,,. z

) 'j Brent L.

Brandenburg

,,;;7 /

Charles Morgan, Jr.

q' {;-

'1/

Joseph J. Levin, Jr.

Paul Colarulli 1899 L Street, N.W.

CONSOLIDATED EDISON COMPANY 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 i

POWER AUTHORITY OF THE STATE OF NEW YORK l

Licensee of Indian Point Unit 3 1

10 Columbus Circle New York, New York 10019 Dated:

May 24, 1982 e

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

)

In the Matter of

)

Docket !;os.

)

CONSOLIDATED EDISON COMPANY OF NEW YORK, )

50-247 SP INC. (Indian Point, Unit No. 2)

)

50-28 6 SP POWER AUTHORITY OF THE STATE OF NEW YORK )

(Indian Point, Unit No. 3)

)

May 24,198 2

)

CERTIFICATE OF SERVICE I hereby certify that copies of LICENSEES' RESPONSES TO INTERROGATORIES OF ROCKLAND CITIZENS FOR SAFE ENERGY in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 24th day of May, 198 2.

Docketing and Service Branch Ellyn R. Weiss, Esq.

Office of the Secretary William S.

Jordan, III, Esq.

U.

S.

Nuclear Regulatory Harmon & Weiss Commission 1725 I Street, N.W.,

Suite 506 Washing ton,

D.C.

20555 Washington, D.C.

20006 Louis J. Car ter, E sq., 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. Par is 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 Washing ton, D.C.

20555 Washington, D.C.

20555 Jeffrey M.

Blum, Esq.

Charles J. Maikish, Esq.

New York University Law Litigation Division School The Port Authority of 423 Vanderbilt Hall New York and New Jersey 40 Washington Square South One World Trade Center New York, N.Y.

10012 New York, N.Y.

10048 Marc L.

Parr is, E sq.

E zr a I. Bialik, E sq.

Eric Thorson, Esq.

Steve Leipsiz, Esq.

County Attorney Enviromental Protection Bureau County of Rockland New York State Attorney 11 New liemstead Road General's Office New City, N.Y.

10956 Two World Trade Center New York, N.Y.

10047 Geof frey Cobb Ryan Alfred B.

Del Bello Conservation Committee Westchester County Executive Chairman, Direc tor Westchester County New York City Audubon Society 148 Martine Avenue 71 West 23rd Street, Suite 18 28 White Plains, N.Y.

10601 New York, N.Y.

10010 i

Greater New York Council on Energy c/o Dean R. Corren, Director New York University 26 Stuyvesant Street New York, N.Y.

10003 l

\\

f 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 Conservation Friends of the Earth, Inc.

Association 208 West 13th Street 443 Buena Vista Road New York, N.Y.

10011 New City, N.Y.

10956 9.

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

! I~.

~.3- (., j, David H.

Pikus

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