ML20054H588
| ML20054H588 | |
| 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: | PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20054H582 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206240235 | |
| Download: ML20054H588 (18) | |
Text
.9 O
,,y.,,
lm.m CORRESPONDEf4Gk i1 '^
i 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 (Indian Point, Unit No. 3)
June 16, 1982
- - - - - - - - - - - - - - - - - - - -x LICENSEES' RESPONSE TO UCS/NYPIRG 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, N.Y.
10003 (202) 466-7000 (212) 460-4600 l
i l
l B206240235 820616-gDRADOCK 05000247 PDR
~.
a 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 "UCS/NYPIRG Supple-mentary Interrogatories to Con Edison and PASNY."
In many instances, UCS/NYPIRG has served interroga-tories which are, in effect, requests for production of docu-ments.
The documents requested in Interrogatories 15.S, 19.S, and 20.S were already provided to UCS/NYPIRG at the licensees' document production on June 1, 1982.
In addition, licensees do not have knowledge of any documents requested in Interrogatories 12.S, 16.S, and 18.S.
Licensees are prepared to produce the remaining documents requested in UCS/NYPIRG's Supplementary Interrogatories at the offices of Shea & Gould, attorneys for licensee Power Authority, at a mutually agreeable date.
RESPONSES TO INTERROGATORIES 1.S.
INTERROGATORY:
Referring to Fig. 22-25 of the November Dr:ft Report provided to UCS/NYPIRG in informal discovery (" Parsons Brincker-hoff Quade and Douglas, Inc., Draft Methodology to Calculate Evacuation Travel Time Estimates for the Indian Point Emergency Planning Zone, November 1981"), please provide the rates of evacuation (percentage of evacuees vs. time) for other scen-arios, sectors or ERPA's calculated but not included in the November Draft Report.
RESPONSE
The requested information is set forth in documents presently in licensees' possession.
See p.
2, above, concern-ing responses to document requests.
2.S.
INTERROGATORY:
The Parsons Brinckerhof f Draf t Reports provide the number of P.C.E.'s evacuated as a function of the scenario of a winter, weekday evening.
Please provide the number of P.C.E.'s evacuated as a function of scenario, and of course, zone for other times, especially during a daytime, school in session, scenario.
Please provide the assumptions on which the calcula-tions are based, especially the assumptions about the availa-bility of buses and how many buses are expected to make multiple trips.
RESPONSE
The requested information is set forth in documents presently in licensees' possession.
See p. 2, above, concern-ing responses to document requests.
3.S.
INTERROGATORY:
Are there changes in terminal times as a function of scenario?
RESPONSE
No.
4.S.
INTERROGATORY:
Referring to Appendix D, please provide the physical characteristics of the rest, the northern half, of the network.
RESPONSE
The referenced appendix appears in the draft January 1981 document.
This document was prepared only for the purpose of comparing evacuation travel times derived by static and dynamic traffic assignment methodologies.
For the purposes of the comparison, the entire evacuation network was not used.
Rather, a test network consisting of evacuation routes located in the more heavily populated portions of the plume exposure pathway emergency planning zone (" plume EPZ")
(i.e., Westchester and Rockland Counties) was used for comparative purposes.
For i
this reason, the information "for the rest of the network" requested in questions 4.S through 9.S cannot be provided because "the rest of the network" was not analyzed in the test.
l 1 -.
5.S.
INTERROGATORY:
Referring to Appendix E, please provide a schematic of the rest of the network, that part not indicated in the Appendix.
RESPONSE
See response to Interrogatory 4.S, above.
6.S.
INTERROGATORY:
Referring to Appendix F, please provide traffic signals for the rest of the network.
RESPONSE
See response to Interrogatory 4.S, above.
7.S.
INTERROGATORY:
Referring to Appendix H, please provide the traffic zone trip data, (including terminal times, P.C.E.
rates) for the rest of the network.
RESPONSE
See response to Interrogatory 4.S, above.
E.S.
INTERROGATORY:
Please provide the zonal Evacuation Routes for the rest of the network not indicated in Appendix L. l
RESPONSE
See response to Interrogatory 4.S, above.
9.S.
INTERROGATORY:
9.S.
Please provide equivalent of Appendix M to January 1981 Draft Report (" Parsons Brinckerhoff Quade and Douglas, Inc. January, 1981), for the rest of the network.
RESPONSE
See response to Interrogatory 4.S, above.
10.S.
INTERROGATORY:
Please provide the names of and biographical data for behavioral and/or social scientists who participated in preparation of the Parsons Brinckerhoff reports and draft reports relating to the Indian Point nuclear power plants.
RESPONSE
The names and biographical data of the principal Parsons Brinckerhoff participants are set forth in licensees' response to UCS/NYPIRG Interrogatory 1.
ll.S.
INTERROGATORY:
Please provide all meteorological information about Indian Point, including but not limited to precipitation fre-quency, wind persistence, dominant wind trajectories, wind speed and direction data, wind rose data, snowfall data (including amounts, frequency and duration), and other data considered in
_c_
the preparation of the Parsons Brinckerhoff evacuation time estimate reports and draft reports.
RESPONSE
No meteorological data specific to Indian Point was considered in the preparation of the Parsons Brinckerhoff evacuation time estimate reports and draft reports.
Heather conditions, to the extent that they would affect evacuation time estimates, were anticipated in the " adverse weather" scenarios, which were approved by the New York State Department of Transportation.
12.S.
INTERROGATORY:
Please provide all documents evaluating the accuracy of radiation dose projections systems and/or radionuclide con-centration predictions systems, including but not limited to MIDAS and ARAC.
RESPONSE
See p. 2, above, concerning responses to document requests.
13.S.
INTERROGATORY:
Please provide all documents in your possession or available to you or to Parsons Brinckerhoff discussing the use of sheltering as a protective response for radiological emergencies. - _ _ _ _ _ _ _ - _ _
RESPONSE
See p. 2, above, concerning responses to document requests.
14.S.
INTERROGATORY:
Please provide all documents in your possession or available to you or to Parsons Brinckerhoff discussing the extent to which performance in an actual radiological emer-gency can be predicted based upon emergency drills and exer-Cises.
RESPONSE
See p.
2, above, concerning responses to document requests.
15.S.
INTERROGATORY:
Please provide all sensitivity and/or parametric studies performed on evacuation time estimate raethodologies or computer programs and correspondence related to such studies.
I
RESPONSE
See p.
2, above, concerning responses to document requests.
16.S.
INTERROGATORY:
Please provide all documents in your possession or available to you or to Parsons Brinckerhoff discussing the impact of meteorological factors on evacuation tiraes and evacuation time estimates.
_a_
RESPONSE
l See p.
2, above, concerning responses to document requests.
17.S.
INTERROGATORY:
Please provide all documents in your possession or available to you or to Parsons Brinckerhoff discussing the impact of topography on diffusion of plumes during nuclear accidents.
RESPONSE
l See p.
2, above, concerr.ing responses to document l
requests.
18.S.
INTERROGATORY:
Please provide all documents in your possession or available to you or to Parsons Brinckerhoff discussing any form of limitation on evacuation times, whether a maximum or minimum limitation.
RESPONSE
See p.
2, above, concerning responses to document requests.
19.S.
INTERROGATORY:
Please provide all documents in your possession or in the possession of Parsons Brinckerhoff, or available to you or to Parsons Brinckerhoff, discussing the establishment of - - ___ _ __________-______-___ __-_ -___-
the Plume Exposure Pathway EPZ and Ingestion Exposure Pathway EPZ at Indian Point.
RESPONSE
See p.
2, above, concerning responses to document requests.
20.S.
INTERROGATORY:
Please make available for inspection and copying all documents listed in Con Edison's List of Documents Related to the March 3, 1982 Emergency Planning Exercise dated May 10, 1982 and in the Power Authority's Filing Pursuant to the March 10, and April 8 Orders dated May 10, 1981.
RESPONSE
See p.
2, above, concerning responses to document requests.
i i-I l
1 _ -
l As to Answers:
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
By
/
A Richard P.
~
Project Manager - Indian Point Hearings POWER AUTHORITY OF THE STATE OF NEW YORK By J
Am Iferschel Spectg W
Project Manager - Indian Point Hearings As to Objections:
CONSOLIDATED EDISON COMPANY OF NEW YORK INC.
By
[.
Br+nt L'. Brandenburg /
Assistant General Counsel POWER AUTHORITY OF TIE STATE OF NEW YORK MORGAN ASSOCIATES, CHARTERED By W
JcMeplU. tdsin, Jr.
g SHEA & GOULD By _
m David H.
Pikus Attorneys for Power Authority of the State of New York l
VERIFICATION STATE OF NEW YORK
)) ss.:
COUNTY OF NEW YORK )
RICHARD P. REFSHAW, 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.
f, e
i
/W
' RICHARD P.
REMSGAW Sworn to before me this 16th day of June, 1982.
%/
Notary Public tmn wna Iktsry Pu;11, Seis of tJew York No. 03 4515033 Quo'.fied in E,sen Coun>f Certif.cs's %d in tidv York Cov
- Commleda Laplies Msch 30,19.
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.
b s Mc$n_
tru HERSCHEL 8PECTER Sworn to before me this 16th day of June, 1982.
& #dh Notary Publii:
DMr.DU.P?tM Netry h 2: e G :
- c; ' Y; '
t?. 31 <tr' :
Queu.ed m No -, *.*/. C.. 'dy Cowr!:sica EW o R '" 22* I AU
Respectfully submitted, Jed M M a_ 04
(
4 Brent L. Brandent u~rg Charles Morgan, J7.)
/
Joseph J. Levin, U.
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 4 Irving Place Thomas R. Frey New York, New York 10003 General Counsel (212) 460-4600 Charles M. Pratt 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
~
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 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 )
(Indian Point, Unit No. 3)
)
June 16, 1982
)
CERTIFICATE OF SERVICE I hereby certify that copies of LICENSEES' RESPONSE TO UCS/NYPIRG SUPPLEMENTARY INTERROGATORIES and LICENSEES' RESPONSE TO WEST BRANCH CONSERVATION ASSOCIATION'S SUPPLEMENTARY INTERROGATORIES in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 16th day of June, 1982.
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 Washington, D. C.
20555 Washington, 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 9 Murray Street Philadelphia, Pennsylvania 19151 New York, N.Y.
10007
1 a
Dr. Oscar H. Paris John Gilroy, Westchester Administrative Judge Coordinator Atomic Safety and Licensing Indian Point Project U.S. Nuclear Regulatory New York Public Iaterest 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 IIall 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 Ezra I.
Bialik, Esq.
Joan Miles Steve Leipsiz, Esq.
Indian Point Coordinator Enviromental Protection Bureau New York City Audubon Society New York State Attorney 71 West 23rd Street, Suite 1828 General's Office New York, N.Y.
10010 Two World Trade Center New York, N.Y.
10047 Greater New York Council on Alfred B.
Del Bello Energy Westchester County Executive c/o Dean R.
- Corren, Westchester County Director 148 Martine Avenue New York University Uhite Plains, N.Y.
10601 26 Stuyvesant Street New York, N.Y.
10003 - -
)
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 Assemb!?
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 Paul Chessin, Esq.
Parents Concerned About Laurens R. Schwartz, Esq.
Indian Point Margaret Oppel, Esq.
P.O. Box 125 Botein, Hays, Sklar & Herzberg Croton-on-Hudson, N.Y.
10520 200 Park Avenue 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 c
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.
Ruthanne G. Miller, Esq.
P.O.
Box 384 Atomic Safety and Licensing Village Station Board Panel New York, New York 10014 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 David H.
Pikus