ML20054H581

Response to West Branch Conservation Assoc Supplementary Interrogatories.Related Correspondence

ML20054H581
Person / Time
Site:	Indian Point
Issue date:	06/16/1982
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:	WEST BRANCH CONSERVATION ASSOCIATION
Shared Package
ML20054H582	List: ML20054H581 ML20054H588
References
ISSUANCES-SP, NUDOCS 8206240221
Download: ML20054H581 (10)

Text

,

RELATED COltimS10NDENCE

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UNITED STATES OF AMERICA Z  ; ~ Td NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H, Paris

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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 June 16, 1982 (Indian Point, Unit No. 3)  :

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x LICENSEES' RESPONSE TO WEST BRANCH CONSERVATION ASSOCIATION'S SUPPLEMENTARY INTERROGATORIES ATTORNEYS FILING THIS DOCUMENT:

Brent L. Brandenburg, Esq. Charles Morgan, Jr.

CONSOLIDATED EDISON COMPANY MORGAN ASSOCIATES, CHARTERED OF NEW YORK, INC. 1899 L Street, N.W.

4 Irving Place Washington, D.C. 20036 New York, New York 10003 (202) 466-7000 (212) 460-4600

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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 supplementary interroga-tories served by West Branch Conservation Association ("WBCA").

The WBCA interrogatories continue to reflect a funda-mental misapprehension as to the various responsibilities for radiological emergency planning both generically and at Indian Point in particular. As noted in licensees' response to UDCA's first set of interrogatories (at pp. 1-3), the State of New York maintains primary responsibility for offsite radiological cuer-gency 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 off-site emergency planning were again misdirected to the licensees. Nevertheless, we have again attempted to respond l

to the interrogatories concerning those plans, on the basis of the plans or other documents with which licensees are familiar. We continu to note, however, that the off-site P

authorities are the more appropriate sources for this type of information.

RESPONSES TO INTERROGATORIES:

X-1. INTERROGATORY:

Judge Carter in the Order of April 23 suggested that questions of use might be asked.

Licensee's response of May 18 to UCS/NYPIRG #88,

p. 77, shows a probability higher than anything in WASH-1400.

The Preliminary Report " Review and Evaluation of Zion Probab-ilistic Safety Study" by Sandia Lab. , letter of transmittal of March 5, 1982 to the NRC, in Section 5, page 5-1 shows a chart ofmanyvariouspossiggeaccidents. No meltdown accident has the probability of 10 or any number c1 se to it. A melt-5 down on that chart might be 4.2 X 10 and the totgl for the critique at the bottom of the columns is 1.3 X 10 . Please explain the methodology used to arrive at any higher figure and also for the one in Licensees reply 88.

RESPONSE

The accident scenario chosen for the Indian Point exercise consisted of highly unlikely selective failures of equipment and systems, as well as adverse meteorological conditions that changed at various time intervals.

l The purpose of this scenario was to test as many l aspects of the emergency plans as possible in a given time period. The methodology used in arriving at the prob-ability for this practice accident scenario is the same methodology which is described in Section O of the Indian Point Probabalistic Safety Study.

l e

X-2. INTERROGATORY:

Please advise how many of the 77 sites surveyed by the Yankelovich organization described by Licensees are in Rockland and details of the results of each siren, referred to in Licensees reply #91, p. 80, to UCS/NYPIRG.

RESPONSE

Of the 77 sites surveyed by the Yankelovich organiza-tion, 21 were located in Rockland County. Of these, 19 sirens were reported to have sounded, one was reported to have not sounded, and one was reported as having a weak signal. Three sites were in remote areas and were not checked. Subsequent to the exercise, all 24 Rockland County sites were inspected and retested. Three sites required repairs. All 24 sites are working and in an operational mode.

4.4-12. INTERROGATORY:

If a hospital has been advised to shelter its patients rather than move them, and a radioactive plume has passed over it, who will take over the clean-up, the monitoring and the responsibility of aiding the occupants of a State hospital?

RESPONSE

See Section III.H.4 of the Rockland County RERP, and Part I,Section IV of the New York State RERP.

r s 4.4-13. INTERROGATORY:

The removal of the sick and incapacitated in State hospitals by other than State personnel requires letters of agreement. Are there any such for Rockland Psychiatric Hospital and Helen Hayes Rehabilitation Hospital?

RESPONSE

Licensees understand that in order for a State hos-pital to receive accreditation, there must be an approved evacuation plan for all of the hospital's patients. These evacuation plans are required to address arrangements with supporting hospitals and, therefore, these arrangements would obviate the need for letters of agreement.

4.4-14. INTERROGATORY:

Critics of the RERP have stated that the RERP for a General Emergency as described in Appendix of NUREG-0654, has written into it a necessity to make triage type decisions as to who receives consideration for safety and in what order. Please comment on the ability of the Plan to assure the safety of all citizens of Rockland County with equal opportunities for their safety and protection.

RESPONSE

Licensees note that this interrogatory appears to fall outside the scope of Commission Questions 3 and 4.

Nevertheless, Licensees believe that the emergency plans provide reasonable assurance that appropriate measures can and will be taken to protect the citizens of Rockland County in the event of a radiological emergency.

e i

4.4-15. INTERROGATORY:

Considering the breakdowns in communications and the lack of suitable equipment in Rockland County as described in FEMA's evaluation draft of the March 3 drill, when do you expect remedies to those defects? Who will pay for them? How will the people unable to move themselves be assured their safety can be served in Rockland County?

RESPONSE

The State of New York has assumed responsibility for maintaining the off-site emergency plans, including respons-ibility for addressing alleged deficiencies in planning and response identified in exercises. Funds for radiological emergency planning are allocated pursuant to Article 2-B of the New York State Executive Law.

See licensees' response to WBCA Interrogatory 4.4-5 regarding persons needing special transportation arrangeraents.

4.4-16. INTERROGATORY:

In what time frame might the citizens of Rockland County expect to have in place the type of evacuation plan as envisaged in NUREG-0654 and 50CFR [ sic]?

RESPONSE

1 See licensees' response to UCS/NYPIRG Interrogatory 6.

3 As to Answers:

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.

6 By Richard P. Remshaw Project Manager - Indian Point Hearings POWER AUTHORITY OF THE STATE OF NEW YORK By ~~

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Herschel Specter Project Manager - ndian Point Hearings As to Objections:

CONSOLIDATED EDISON COMPANY OF NEW YORK INC.

By _, {} , kf)y 1/

Brenti L." Brandenbur'g Assistant General Cou 1 POWER AUTHORITY OF THE STATE OF NEW YORK MORGAN ASSOCIATES, CHARTERED By h _ _

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Q in, Jr.. '/"

SHEA & GOULD By _'

David H. F1Es Attorneys for Power Authority of the State of New York l

s VERIFICATION STATE OF MEW YORK )

SS.:

COUNTY OF NEW YORK )

RICHARD P. REMSHAW, being duly sworn, deposes and says:

That he is the Project Manager - Indian Point Hearings for Consolidated Edison Company of New York, Inc., licensee of Indian Point Nuclear Generating Station, Unit No. 2; that he is authorized to make this verification on behalf of said corporation; and that the foregoing answers to interrogatories were prepared under his direction and supervision and are true and correct to the best of his knowledge, information and belief.

t

' RICHARD P.

.) w REMSIMW Sworn to before me this 16th day of June, 1982.

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s 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.

& /)&bL l HERSCllEL' SPECTER l

Sworn to before me this t

16th day of June, 1982.

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Respectfully submitted, a h e i I.

Brent L. Brandenburg m e '

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CharlesMorgan,Jr.f.f)

Joseph J. Levin, Jr Paul Colarulli 1899 L Street, N.W.

CONSOLIDATED EDISON OMPANY Washington, D.C. 20036 OF NEW YORK, INC. (202) 466-7000 Licensee of Indian Point Unit 2 Thomas R. Frey 4 Irving Place General Counsel New York, New York 10003 Charles M. Pratt (212) 460-4600 Assistant General Counsel 10 Columbus Circle New York, New York 10019 (212) 397-6200 MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.

Washington, D.C. 20036 SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 Dated: June 16, 1982