ML20054J930

Final Response to Util Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20054J930
Person / Time
Site:	Indian Point
Issue date:	06/25/1982
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 8206300215
Download: ML20054J930 (18)

Text

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NUCLEAR REGULATORY COMMISSION NY ..

In the Matter of )

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CONSOLIDATED EDIS0N CO. OF NEW YORK ) Docket Nos. 50-247-SP (Indian Point, Unit No.~2) ) 50-286-SP June 25, 1982 POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit No. 3) )

RCSE'S FINAL RESPONSE TO LICENSEE' S INTERROGATORIES For mare complete response, some materials are provided and pages from relevant documents included, as requested.

1 R_e . 10 CFR 50.47 (b)(6): see RCSE's Third Response to  !

Inte rrogato rie s , dated June 7, 1982 In addition, we attach  !

document received by RCSE on morning of June 22, in response to RCSE request at June 1 document production. (Attachment 1 In-volved is letter from N.Y. Telephone Company affirming prior statements regarding the potential overload on central offices in the event of a general evacuation--which would include evac-ua tion o f N.Y. Telephone personnel. )

l RE 10 CFR 50.47 (b)(7): See RCSE June 7 response.

l l #2 - 3: Don' t apply.

l #9e R_E Time frames and assurance of effective response:

NUREG-0654 I D 3: Time factors associated with releases ( Attach-I ment 2_. hereto) and NRC order RJ Duke Power Co. and Texas Utili-ties Generating Co. petition for stay of 15 minute notification

( Attachment 1) . Rationale for 15 minute notification and its need spelled out in p. 4 of aforementioned atta, chment.

1. 10 - 12: Don' t apply "P 8206300215 820625 ,

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RCSE final response to interrogato ries #13: See response to #1 and Attachment li also personal know-ledge of difficulties with 268- exchange in Rockland County under normal circumstances.

1. 14-16: Don' t know

1. 17: See answer #13 ,

1. 18: Any unplanned release of radioactivity or leak in .

systems such as occurred on March 24, 1982. Any minor events which, in the words of NUREG-0654, Appendix I, page 1-3 ". . .

could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized".

1. 19,24: See page 3, RCSE Third Response to Interrogatories.

1. 20-23: Can't answer

1. 25: Not enough in6rmation is provided for individuals who have no other source of information upon which to acts i.e.

~what they should actually do--nor can this be individualized j given the numbers of people for whom directions must be provided.

1. 26: It simply fails to do so: English only at this time.

1. 27a-d f: Wil1 deal only with non-English-speaking: Hispanic origin: about 5% of population of Rockland County (11,772 according to latest census report), about 6,000 of whom reside in northern part of county (testimpny of Luis del Pilar). Other origins: 3%. #27e: present plans have no provision for non-English-speaking people. #27g: no knowledge. #27h,i: Thorough public education program in target language, the same way other population should be notified: functioning sirens.

1. 28: We concur with answers provided by Parents to this question, especially with respect ot misleading information which is not necessarily true, e.g. page 6: "You will have

RCSE Final Response to Interrogatories ample time to leave". It is assumed that brochures were re-ceived, kept, read, understood by residents. Need for concern minimized. Then why need for evacuation planning?

1. 29,30: See answers to #27,28 rg non-English-speaking.

Cannot give exact information re other groups. Conmon sense.

dictates that if people are to be notified and informed, it  ;

must be done at their level. All other languages must be ,

identified.

1. 31,32: Much testimony relates to transients, both in park systems and elsewhere. Many people present in the EPZ at all times are either workers who live outside EPZ, visitors, or just passing through (see testimony of Lois Jessup). They may be brought by bus, car, dayline or other means: since there is no positive way of identifying large numbers of them, there is no way of assuring that they can receive adequate notification.

1. 33-38: Not RCSE contention.

1. 39-42: Large population of Rockland County and the county configuration (bound on east by Hudson River, north and west by mountains and south by densely populated New Jersey) make rapid evacuation im:e ssible. Most evacuation is only possible to the south. If a plume should travel over Rockland County, it would also travel over evacuation routes (see map Attachment 4 from RCRERP). No adequate protective action available for accidents occurring before evacuation could be effected.

~

1. 43-44: There is no sheltering capability at all for thous-ands of parks visitors, campers, hikers, etc. Air exchange rates in structures under average conditions (exclusive of air provided for ventilation) provide less than one hour's protection according to EPA Protective Action Evaluation (see RCSE's Third

RCSE Final Response to Interrogatories Response to Interrogatories), and theAmerican Society of Heating Air Conditioning and Refrigerating Engineers' 1981 Pundamentals Handbook, Chapter 22, page 22.8. See also Attach-ment j, Reactor Safety Study page.

1. 45-54: Not RCSE.

1. 55: Drills are planned, accidents are not. Drills involve limited numbers of pre-determined perscnnel, aware in advance that it is a drill. Drills do not involve the component of a true emergency / evacuation situation: masses of people unaware of what to do, frightened, unable to carry out what they per-ceive as adequate response to protect themselves, their families and their homes.

1. 56-58: Don't apply

1. 59-60: Show us that adequate revisions have been and are being made on a periodic basis (as required in 10 CFR 50.47).

Periodic does not mean once a year, in our estimation, but far more frequently.

! #61,62: " Idealized conditions" for adequate response by .any l

l emergency response organization would be the absence of Rockland County's 260,000 people, since these people, as well as multi-ples of that number living and moving just south of us (in New l

l Jersey) form the major stumbling block to timely evacuation. It is each person and family with individual needs, problems, etc.,

which make even the thought of timely evacuation ludicrous. It

is a farce, a tragi-comedy devoid of common sense. Testimony al-1 I

ready presented is but an iota of the evidence available.

1. 63-69: Not RCSE contentions.

1. 70: (1.) Common senses (2.) My husband has 20 years ex-perience in-towing business. We know.

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- RCSE Final Response to Interrogatories y

1. 71,72: Far too numerous to mention or can't identify at =

g if this time. 5 1.; :

1. 73: See response to #18, also RCSE Third Response re E. .

Fan Cooler Leak accident, October 1980. g g

1. 74: Cf. testimony of Rockland Sheriff Chief James Kraliks g also Rogovin and Kemeny Commission reports on Three Mile Island. 3 cf. Attachment 1 Rockland County exchange 268- already in- g a

tolerable. _

1. 75: Try to evacuate all of residents of Rockland County within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in fair weather and it will still leave doubt re more rapid time-frame occurrences.

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1. 76: Identify the needs, situations, capabilities and abili- Ej ties of Rockland County residents, especially those of the ten- i 1

mile zone and you have the answer.  :

1. 77,78: Fires, floods, etc. are tangible, visible, identi- fc fiable threats. Radioactivity is invisible, incapable of being j i

detected except with instrumentation. People know this. g i

Common sense re human nature. Testimony of FEMA

1. 79:

I witnesses McIntire, Husar and Keller, page 24, only bears this out: " Panic occurs only under special circumstances. . .within en-closed area and escape routes are closed off". This can very easily be Rockland County.  !

1. 80,81: Common sense, past life-experience.  !

Rogovin and Kemeny Commission Reports on TMI: common

1. 82:

sense.

1. 83: Not RCSE contention

1. 84: Time estimates and plan simply assume that all will and can follow plan. This is a totally unreasonable assumption.

1. 85: We .never said that Rockland cannot be evacuated in any

RCSE Final Ranponsa to Interrogatories safe times perhaps in 4-5 days, with tremendous hardship for elderly and infirm, it can be done.

1. 86-88: Not RCSE

1. 89: This would require most of testimony of this hearing j and an additional six mon *,hs of witnesses. My own example: I live on top of a steep hill on New Hempstead Road which has ,

several times become completely impassible with only i inch of snow. Sliding cars and collisions have _ stopped traffic on this main east-west artery for more than two hours on several occasions (police and sheriff can verify this). Frequent colli- l sions on this stretch of road have stopped traffic completely l

in fair weather. In addition, our evacuation route goes from New Hempstead into one of the most congested intersections of the county, Middletown Road and Route 59, Nanuet (currently under " halted" construction). Thousands of residents have this route.

1. 91: See previous answer related to this question.

1. 92: See answers to 43,44: why aren't related questions grouped together?

1. 93-99: Not RCSE.

1. 98: Assumptions in time estimates not related to reality.

1. 99,100: Buses need drivers and roads on which to travel.

Both might not be available.

1. 101-107: Not RCSE.

.#108: See answer.to #89

1. 109: Included in testimony already received.

1. 110: Not RCSE.

1. 111: Answer to 89 applies in general.

1. 112-117: Not RCSE.

1. 118: Not RCSE contention, but RSS, WASH-1400, USNRC, Oct.

RCSE Final Response to Interrogatories 1975, Appendix VI, page 11-6 applies (Attachment 5).

1. 119,120: Not RCSE.

1. 121: See attached map.

1. 122-128: Not RCSE.

~

1. 129: cf. previous answers: we question possibilities of sheltering as a protective action.

1. 130: Cannot be expected.

1. 131-135: Not RCSE.

1. 136: No such sheltering can be provided for all residents and transients (underground with air filtration systems, food, water, sanitary facilities, etc.)

1. 137: Already addressed; why repeat here?

1. 138: When available, sealed basements ar e better than other options for a short period of time; see answers #43,44

1. 139-151, 153: Not RCSE.

. #152: Sirens, most of which don't appear to function 1

adequately in Rockland County.

1. 154,155: See #43,44

1. 156: No protective action would be adequate in major releases.

1. 157: cf. references #43,44 (EPA document).

1. 158: already addressed.

1. 159: All listed in 4.2 plus closing the plant, only the last one" feasible".

1. 160-175: Not RCSE or are duplicative, already addressed.

1. 176-177: See responses of Parents, UCS/NYPIRG.

1. 178: Not RCSE.

1. 179: Cannot identify at this time, know many personally.

1. 180: Already done, both RCSE individually and with UCS/NfPIRG.

1. 181: See previous RCSE Response to Interrogatories as well

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RCSE Final Response to Interrogatories . $

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as this one.

1. 183: Numerous communications by phone and in person with g:

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Rockland County emergency response personnel. E w

Already identified by others. We concur. Major

1. 184:

deficiencies already addressed in #55 -

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.m.voto romStem or cow =ses Ms. Judith Kessler Rockland Citizens for Safe Energy 300 New Hempstead Road New City, New York 10956 Re: Indian Point Hearings

Dear Ms. Kessler:

Enclosed herewith are the documents which you requested us to reproduce following licensees' document production on June 1, 1982. In light of the small number of copies requested, licensees will not insist on payment of the 51d reproduction charge.

Very truly yours, David H. Pikus l

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Emergency Pr'eparedness Meeting Held on April 19th,1982 at Mt. 'Kisco, N.Y.

At'tendees: George Harenberg - NY Tel .- Chaiman Angelo Fasolino - NY Tel.

Mike Wachur - NY Tel. s J

John Puckhaber - NY Tel.

Mike Scalpi - Putnam County Phil Schmer - Orange County Brian Sullivan - P.A.S.N.Y. '

Terry Marganela - Westchester County l W.R. Silbereisen - NY Tel. Mktg Sales . .

Sandy Fried - Westchester County Marvin Silverman - NYS-R.E.P.G.

About one year ago, New York Telephone completed detailed ,

plans to define company operations in the event of an accident at the Buchanan nuclear power plant. Aware that the power companies', counties l and New York State now have, or are currently developing, radiological response plans to be used in such an emergency, New York Telephone _-

requested this meeting in an effort to identify inter-plan conflicts.

Highlights of the Telephone Company plan were reviewed and discussed. This plan includes identification of all company work centers in the emergency planning zone; preparation of each Central Office prior to evacuation; surveillance, comand and control from a remote location; evacuation routes; alternate work locations; removal of company vehicles and the transfer of calls for company service to unaffected locations.

l An Emergency Control Center (ECC) has been established for I each site and the local District Switching Operations Manager has been appointed an ECC activator. Alerting and reporting procedures have been defined. ECC Activators have been provided with telephone number lists for police, fire departments, hospitals, civil disaster preparedness units as well as for pre-selected technical employees who are to be available on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis in eight hour shifts daily.

Power company and county representatives pointed out that public instructions including evacuation routes, have been prepared. It was agreed that copies of such material will be fomarded to NY Tel so that any discrepancies that might exist can be resolved.

The Telephone Company stated that any public order to evacuate or to prepare for evacuation, would probably result in a traffic

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, I overload on central offices within the Emergency' planning Zone. Since the Bell System policy calls for evacuation of all employees, these central offices would remain unattended during the evacuation period. ,

If these offices are to handle the maximum load of which they are ,

capable while operating unattended, the Telephone Company requires advance notification.

Discussion revealed that the notification procedure of the d

A Telephone Company plan does not assure the required early warning.

new procedure will be developed jointly by the Telephone Company and the counties. (See Fig. 1) When completed, a copy of the notification procedure will be forwarded to each attendee.

County representatives expressed a need for copies of the documentation of the NY Tel plan. Such documentation is considered proprietary in nature. However, subsequent to the meeting, a formal request by Mr. Schmer of Orange County was sent to.NY Tel. . Steps -

request.ing corporate clearance have been instituted by NY,Tel.

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D. Planning Basis (continued)

a. the downwind range within which contamination will generally not exceed the Protective Action Guides is limited to about 50 miles from a power plant because of wind shif ts 'ouring the release and travel p'eriods;

b. there may be conversion of atmospheric iodine (i.e. ,

iodine suspended in the atmosphere for long time perious) to chemical forms which do not readily enter the ingestion pathway;

c. much of any particulate material in a radioactive plume would have been deposited on the ground within about 50 miles from the facility; and

d. the likelihood of exceeding ingestion pathway protective action guide levels at 50 miles is comparable to the likelihood of exceeding plume exposure pathway protective action guide levels at 10 miles.

3. Time Factors Associated with Releases The range of times be. tween the onset of. accident conditions and the start of a major release is of the order of one-half hour to several hours. The subsequent time period over which radioactive naterial may be expected to be released is of the order of one-half hour (short-term release) to a few days (continuous release).

Table 2 summarizes the guidance on the time of the release, which

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'b COMt11SSIONERS: d gm John F. Ahearne, Chairman UsNRC "

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Joseph 11. Hendrie DEC - 5193 > :-

'5 Peter A. Bradford 4 otra of the W Dociating & Serms

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PR-50 (44 FR 75167)

FINAL RULE ON EMERGENCY PLANNING )

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tiEMORANDUM AND ORDER (CLI-80-40)

On November 12, 1980, the Duke Power Company and the Texas Utilities l Generating Company (hereinafter " petitioners") moved the Commission for reconsideration and for a stay of the 15-minute notification capability requirement in the emergency planning rule. 10 CFR Part 50, App. E, 5 IV, D, 3 ; 45 Fed. Reo. 55402, 55412 (Aug.19,1980). The Commission has received an extensive analysis of the evidence presented in the motions from its tech-nical staff and believes that insufficient evidence is presented to justify immediate modification or stay of the 15-minute requirement. That analysis is enclosed and describes more fully the Commission's reasons for denial of the relief requested.

Petitioners object to the rule's requirement that a licensee must demon- '

strate that a public notification system exists which is designed "to have the capability to essentially complete the initial notification of the public within the plume exposure pathway [10-mile emergency planning zone] EPZ c

within about 15 minutes [of notice by the facility of a severe accident]."

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. t The Commission discussed the 15-minute notification capability require-ment in detail at open public meetings with the NRC staff and with representa-tives of the industry and affected governments in deciding what the require-ment should be.

On June 18, 1980, the Commission met with the staff and discussed at length

• the feasibility of a 15-minute notification time (as opposed to 30 minutes or some other longer time). Public Meeting, Staff Presentation of Final Rulemaking to the Nuclear Regulatory Commission, pages 17-42 (June 18,1980). The staff explained that it had concluded, after study and evaluation and an analysis of ,

the canments received, that a public notice system should be designed to provide the maximum degree of time within which to take protective actions. For example,'l the staff noted that in a very severe accident, when releases of radiation could occur within about 30 minutes time, immediate notice and action would be necessary. In addition, the staff described that an accident's potential for severe consequences might not be recognized until several hours into the acci-dent, leaving only a short time actually available to effect protective Where a system exists for prompt notice, governmental officials will /

actions.

have more options available for protective actions, including evacuation itself which may take from two to ten hours. June 18 Transcript, at 18-19. The dis-cussion also focused on whether the State and local governments could take appropriate protective actions during the 15 minutes that was initially allotted to their decisionmaking process. Id . , a t 31-32. The Commission decided at the 1

June 18,1980 meeting, after reviewing the rulemaking record to date, that (1) more flexibility was needed for the State and local government decisionmaking

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i AI'PENDIX VI

% f go IIEACTOIl SAFETY STUDY U.S. NUCLEAR ItEGULATORY CO.TDIISSION OCTOBEft 1975

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Y Ev:custions due to transportation accidents are used as the descriptive model for

• ecctor accidents since they often involve airborne releases of noxious gases and the

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/ in evccuationtimes and evacuation movements are comparable. Since there is a large variation speed, the use of one " representative" speed miaht not be appropriate.

• Tha log-normal distribution is therefore represented by three discrete evacuation ercsd3 o f 0, 1.2, and 7.0 mph, with probabilities of 30, 40, and 30s, respectively.

As chswn in Fig. VI 11-3, the 1.2- and 7.0-mph values are the probability midpoints

• of the associated intervals (the 1.2-mph value is the 50th percentile, and the 7.0-aph valu2 is the 85th percentile). Although the probability midpoint of the first inter-val 10 0.2 mph, zero mph (inef fective evacuation) is assigned. On the other hand, although the presence of a 5% nonparticipating minority is considered to be a real-istic phenomenon, it was not incorporated into the model because its effect did not s2tm tb justify an increase in the complexity of the consequence model. The net effset is thought to be conservative since a 301 probability of ineffective evacuation han higher consequences than a 1001 probability of 5% of the population remaining.

Future. work will study the effect of the nonparticipating minority.

With respect to the relation between ef fective speed and distance relation shown in Fig. VI J-5 of Appendix J, the 1.2- and 7-mph values correspond to evacuation distances of 5 cnd 35 miles, respectively. If the detailed distance relation were incorporated into the evacuation model, it might show the present, discreticized medel to be conserva-tive since the evacuation speed would increase with the distance traveled and the varicbility of speed for a given distance would be smaller than that in the present modal. The treatment of this distance relation is somewhat complex and will be deferred for future study.

None o~f the evacuations covered in the EPA report involved a major population center j (e.g., New York City). It is not to be expected that either the results of the statisti-cal analyses or the evacuation model would be applicable to such centers. However, this restriction does not invalidate the use of the model for reactor risk assessments.

Current and past siting practices by the U.S. Nuclear Regulatory Commission have precluded reactors being sited within 20 miles of a major metropolitan area. A review of the 68 sitas at which the first 100 commercial LWRs are located (Table VI 10-1) shows that the largsst city within 25 miles of a reactor site is Cincinnati, Ohio, with a population of 4 27,000. New York City, Boston, Philadelphia, Chicago, and Los Angeles are all bsyond 25 miles from a commercial power reactor. For the accident :enarios evaluated I

in this report, there is no presumption that the population in any of these major f cities could be moved in less than 1 week.

11.1.2 VENTI 1ATION Ons potential benefit from remaining indoors during the passage of the radioactive cloud would be reduction in the quantity of radionuclides inhaled. The important parameter in this respect is the ventilation or turnover rate of the air within the building, I which is a function of meterological conditions and the construction of the building.

l l Tne ventilation rate is af fected by the inside-outside temperature differential, wind l spsed and direction, quality of construction, and topographical setting. Building vrntilation is reasured by the fraction of building volume turned over per hour. A survey y of the literature of home ventilation rates found this to vary f rom 0.07 to 3.0 per hour (Handley and Barton, 1973). Although one would expect a considerable variation of this

[( parameter from one region of the country to a'nother, none was indicated by this survey.

This invariance is probably a reflection of the rather limited data and the use of standard construction materials and practices. With the building at ambient temoerature, thz ventilation rate should approach zero as the wind speea approaches zero. Megaw (1962) found that, for a wooden hut with tight-fitting windows and snug doors, there is a linear relationship between the mean wind steed, u, and the ventilation rate; that is, for speeos of up to 6 m/sec, n = 0.9u, where u is in meters per second and n is in reciprocal units of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. For a cloud of constant air concentration, which would giva a dosage external to the building of Vo, in a time at, the dc. sage inside a shelter, g, is given by (Slade, 1968)

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UNITED STATES OF AMERICA .p'~ g; 25 X0 ;52 NUCLEAR REGULATORY COMMISSION

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In the Matter of

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CONSOLIDATED EDISON CO. OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit No.'2) )' 50-286-SP

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POWER AUTHORITY OF THE STATE OF )

NEW YORK (Indian Point, Unit No. 3) June 25, 1982

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CERTIFICATE OF SERVICE This is to certify that I have served copies of RCSE'S FINAL RESPONSE TO LICENSEES' INTERROGATORIES to all present at the ASLB Hearing on the af ternoon of June 25, 1982. All parties not present will have copies served by deposit in the U.S. Mails on this day, June 25, 1982, first class, postage paid, i)$ l/ M2k-JpithKessler Loordinator, RCSE e