ML20054F626

Third Response to Interrogatories Supplementing 820531 Response,Per ASLB 820604 Order.Certificate of Svc Encl. Related Correspondence

ML20054F626
Person / Time
Site:	Indian Point
Issue date:	06/07/1982
From:	Kessler J ROCKLAND CITIZENS FOR SAFE ENERGY
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
ISSUANCES-SP, NUDOCS 8206170167
Download: ML20054F626 (6)

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EE2TED CORRESPONDENER ~~ ~

UNITED STATE 5 0F AMERICA '

t'UCLEAR REGULATORY COMMISSIC'; ( .

EEFORE THE ATOMIC SAFETY AND LICE"SI';3 BOARD . . . . . . . . .

4

, Q< , M " -

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.l In the Matter of ) '22 L:: iC P2 29 l

) 4 CONSOLIDATED EDISON COMPANY OF NEW YORK ) DocketIfos.50-247 SP {a (Indian Point Unit 2) .- . 50~-286 _-

SP 9

POWER AUTHORITY OF THE STATE OF NEW YORK ) ' June 7, 1982  ?

(Indian Point Unit 3) )

RCSE'S THIRD RESPONSE TO LICENSEES' INTERPOGATORIES To compensate insofar as possible for our brief reply of L

May T_ ic Licensees' Interrogatories, and to conply with the y Board Crder o f June 4, we submit this additional response. 3 E

Preparation of witnesses' testimony add the inordinately short {

time in which to perform such tasks hat.:er our efforts to pro-vide a mere thorough response, but we shall do what we can at -

1 B

I this time.

(r HE 0:ntention 3,1 (with reference :o communications and  ?

info rma tion) : It is common knowledge that sirens' operation is inadecuate at this point in time. Tests and repairs are on-going, according to Lonald McGuire. Deputy Director of Emer-ger.cy Services for Rockland County. At this time, specific data on status of sirens cannot be provided since tests are being conducted every day, approximately. We will supply in-f b

formation as we obtain it. '

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3 b g gO Cn many occasions over the last year, meetings and phone 3 L NvE conversations with Chief James Kralik of the Rockland County SE'L 88 @ E Sheriff's Patrol have established that the communications system mg nOg  ;

s in Rockland County is greatly inadequate with regard to emer- u (v o

b M gency/ evacuation plans for Indian Fcin . Chief Kralik's tasti- 54 i; om E

.ony, avn'_able frc- hocklan:i Ocunt:. At-.rney Eric Thorsen and $$o

RCSE THIRD RESPONSE TO ' INTERROGATORIES .. \ "

due to ba filed on this date (June 7), provides necessary, l f

specificity in many areas, from the local phone system to the need for additional emergency channel frequencies. Again, common sense must prevail, since there may be nearly as many communications difficulties and inadequacies as there are in-dividuals with whom to be communicated.

RE Contention 3 1, (information available on periodic i basis. . . . ): Personal experience of residents of Rockland County, some of which will be available as testimony to be filed today, should be adequate. It is a fact that there is no periodic supply of information on notification and courses of action the public should follow in the event of an emergency at Indian Point. The only" official" i'nformation supplied has been through the brochure supplied by the Four County Nuclear Safety Committee. Its inad' quacies (especially with respect to non-English speaking populations) are addressed under Contention ,

4.7, to be addressed by RCSE witness Luis del Pilar, resident ]

of Haverstraw. No information on a periodic basis is appar-ently available through the local media (see testimony of RCSE k 8

witness Betty Ramey, owner, WRKL radio, Pomona). Prior arrange-ments with news media for dissemination of information are largely lacking with regard to completeness of nessages, etc.

(Cf, testimony of Betty Ramey). Messages are in English and do a

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not take into account the many non-English-speaking residents c

of.Rockland County. [

RE Contention 3 3 ( Evacuation time estimates. . .are un-  ;

re A raole . . . ) : We must assumethatUCS[NYPIRG'sresponseto this will also be our own to a large degree. We have not had

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the time to properly review those responses and can, at this :_

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RCSE THIRD RESPONSE TO INTERROGATORIES ,;

time, add that our own experience as residents cf a heavily '

s

/M populated area with little egress routes can only emphasize this point. Testimony of Rockland County Emergency Service heads will provide specificity as will examples provided in

. RCSE Supplement to Petition: Contentions (12-1-51, page 2).

RE Contention 3.4 (Licensees cannot be depended upon to notify authorities...promptly and accurately encugh to assure effective response): Two recent incidents (Fan Cooler leak accident of October 1981 and the radiation release of March 26, 1982, form the most current basis of this centention (see NRC Sequence of Events report, Indian Point 2 Water Leakage into Containment, signed by Theodore Rebelowski, Resident Inspector, no date, and findings for October 1983 accident, plus reports other than press accounts of events and sequences which are on file with the NRC) Regardless of the outcome of the March 1982 incident, Licensee Consolidated Edison had no way of knowing at the outset of leak that it would not esca-late. They did not notify Rockland County officials of the i leak until it was closed off approximately two hours later.

" . . .promptly and accurately enough to assure effective res-ponse" relies upon (1) Time Factors Associated with Releases, NUREG-0654: (2) Memorandum and Order (CLI-80-40) of NRC Comm-issioners, in response to Duke Power Company andTexas Utilit-ies Generating Company's petition for stay of the 15-minute notification capability (12-5-80 Such stay was denied on the basis that major releases could occur within as little time as 30 minutes from onset of accident conditions. In addition, an accident potential might not be recognized immediately, thus leaving too short a time for protective actions (3) Working Fapers of the 1964-65 Revision of Wash 7h0, The 3rockhaven J

1

M RCSE THIRD RESPONSE TO 'INTEi4ROGATORIES Report, for which no final' version was published (such papers l l available from NRC Public Document Room), wherein time avail-able for evasive action is discussed.

j What is also of serious question here is "what is_" prompt-ly and accurately enough"to assure effective response, even, ,

if effective response could be assured. In neither of the.two  !

incidents cited above were Rockland County officials notified at the outset, yet they have been notified of seeningly incon- ]

1 sequential occurences which had no bearing on radiation releases )

or potential accidents involving the reactor. It is the opin-ion of planning people, generally, as well as of the population j in general, from our experience,'that notification of serious f events may be delayed by efforts to he'ad-off or remedy a threat-ening situation or by non-recognition of seriousness of events Numerous conversations, dates  ;

and inability to control them.

unknown, have confirmed this, as have accident reports from i both Indian Point and elsewhere, notably Three Mile Island (Cf. Rogovin Report on Accident at Three Mile Island, Kemeny Commission Report on Accident at Three Mile Island). Other bases exist, but present time constraints limit us.

RE Contention 4.2 (adequacy of sheltering as a protective action): Our bases for this contention are (1) EPA 520/1-78-001 A. Protective Action Evaluation, Part I, Effects of Sheltering as a Protective Action against Nuclear Accidents'In-volving Gaseous Releases, and 3_, op. cit. Evacuation and Shel- -

tering as Protective Actions against Nuclear Accidents Involving Gaseous Releases: (2) previously cited Brookhaven Report update working papers, page 92-7 and elsewhere. Rockland County buildings fall within all categories refered to in the above reports and attenuation factorr/ air turnover rates dictate little

RCSE THIRD RESPONSE TO INTERROGATORIES "

j or no protective ac. tion available in the event of a major, re-l j 3

lease. ,

2 RE Contention 4.7 (brochure): a substantial number of non-English-speaking persons reside in Rockland County, many within less than 5 miles of Indian Point. Rockland County Planning Board figures are already being supplied by others' specifying exact numbers and related documents are available at that office. RCSE witness Luis del Pilar will outline spe-cific difficulties encountered by one such group. _

e This completes our replies to interrogatories at this time.

Other documents provide the basis for our work, such as the -

Reactor Safety Study, Wash 1400, especially Appendices V and VI, 2 as well as its 1978 evaluation, "The Lewis Report", Risk Assess- 3 ment Review Group Report to the U.S. Nuclear Regulatory Commission, NUREG/CR-0400. There is no end of material on which to base {

cur contentions, material of which Licensees are well aware, we are sure.

Regarding our witnesses: Linda Co will replace. Joyce I e

Lawrence of Rockland County Girl Scout Council, Inc., and will deal with large numbers of children in camping situations, etc.

Jane Capon and Phyllis Helbraun will deal with children and -

their care in nursery school. day-care situations. Betty Ramey3 owner of WRKL radio, Pomona, N.Y. , will deal with provision of information to the public and the need for prompt notification in the event of an emergency. Joseph Pirone, Sharon Pirone, ,

U and Norman Szmanski will not be presented by RCSE.

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UNITED STATES 0F AMERICA -;

P' ' LEAR PrGULATORY COMMISSION 4

BEFORE inE ATOMIC SAFETY AND LICENSING BOARD s .c g -

/

In the Matter of )

) ). l" P2 M CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2) ) , 50-2.86 SP

) c:di.<.3.h.-

POWER AUTHORITY OF THE STATE OF NEW YORY,)

(Indian Point Unit 3) )

June 7. 1982 N" f//

CERTIFICATE OF SERVICE I hereby certify that I have served copies of RCSE THIRD RESPONSE TO LICENSEE INTERROGATORIES on the following parties by deposit in first class mail, postage paid, on this 7th day of June,1982. Response to Licensees will be delivered by Consolidated courrier on the following morning by pre-arrangement with Indian Point courrier into New York City, lg and by an RCSE member to PASNY in New York City. g Dmanewg are Service erwu:n N cm. s. uam. na Latistuma De.u.en o,,,,,, 4, %, %

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