ML20054M179

Reply to Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20054M179
Person / Time
Site:	Indian Point
Issue date:	06/30/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
ISSUANCES-SP, NUDOCS 8207120064
Download: ML20054M179 (8)

Text

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i DELATED CORRE9}"JNDS7'CF

. UNITED STATES OF AMERICA D NUCLEAR REGULATORY COMMISSION f g ATOMIC 5AFETY AND LICENSING BOARD [  ;

E Administrative Judges; JUL 0 G82 $' 4 2g jtn C.  :

Louis 3. Carter, Chairman 0$ce O't ge#r -

Dr. Oscar H. Paris 0 DWd$s C <

?

In the Matter of Frederick 3. Shon CONSOLIDATED EDISON COMPANY OF NEW YORK 4 [/

(Indian Point, Unit 2) Docket Nos. 50-247-SP 50-236-SP i POWER #""*

(IndianAUTHORITY Point, Unit 3)OF THE STATE OF NEW YORK

• WEST BRANCH CONSERVATION ASSOCIATION'S REPLY TO INTER-ROGATORIES OF LICENSEES Enclosed is reply to some of the 182 interrogatories posed by the Licensees without specifying which is di-rected to WBCA. We have replied to those for which we are responsible in the phase of above captioned case

.g_. involving Questions THREE and FOUR, as lead intervenors.

EG We have also responded to any directed to WBCA specifi-cally and to those we are doubtful about but are willin'g to reply since it may be that we are the only intervenors using those bases. We have gone beyond the call of duty in the latter regard because the references in the Board's Order of April 23 refer _ to contentions by number albeit not to the entire contention, as can be deduced by reading ..

the questions framed by the Board. Licensees have stepped' far beyond the Board's questions.

Those questions not shown by number in what follows are purposely omitted by WBCA as not germane.

We refer to witness by name and number in the compen-dium submitted by the Intervenors on June 7 J'

for West Branch Conservation Association k' 443 Buena Vista Road New City, N.Y.

914/634-2327 b

by UZipporah

1. S. F1eisher Secretary 8207120064 820630

{DRADOCK05000 g

_QUESTION 9 I the Plan are in Appendix A, page . A-31 paragraph B. TheFor h a

' numbers them. of vehicles are insufficient for those needing The supply of drivers of vehicles is not assured.

dix A, The defects in travel times described in Appen-pages Brinkerhoff (PB) A-3,4 and 5, II, are illustrated by Parsons  ;

charts Figures 26 and 27 in what is now, j Exhibit UCS #1, showing critical bottleneck links for }

" School In Session" and " Nighttime Scenario". '

shows routes 306 and Little Tor Road as equal Neither to or worse than other major routes for bottlenecks.  ;

bottlenecks sufficient to override the travel time esti-Both maps show mates.

This is a defect due to PB.

OUESTION 10 I is not a consideration.There is no response to this in the Plan. Triage equal basis is WBCA's contention.The safety of all people on an -

QUESTION 17  ;

tervenor. This question does not apply to WBCA as Lead In -

k ASLB added 3.2 after the April 14 conference. Noting the absence ,, 5 ggg Utilities We hope to have a witness from Orange and Rockland -

pared setting of a subpoena a time. on June 25 for a judge's signature and i Pres. of WBCA spoke to Mr. Tom Griffin, Pres.On June 25 Mr. Walter Fle o f ORU.

~

June 29 Mr. Frank Fischer, On spoke to Mrs. Fleisher, Sec. of WBCA.a Vice-Pres. of OR; called and testimony and a witness. We again requested be filed late through no fault of WBCA.If these are forthcoming they will Q

_UESTIONS 27 and 29 g.

Blattstein #59, See testimony of Gladys Burger #63, Barbara John Moore #51. M f:

nesses but they don't seem to be known.We asked for more details from d Q

_UESTION 28 h Ed

~

sa fib About 125 cards were returned from the brochure the 10 mile EPZ.out of a total population of disabled of dbout 16,000 in ,

is d_a

2

.'.Y::.

=5

4 kms

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It is not clear how a person standing at a bus stop would know if the bus had been by or was yet to come.

, :S.. Notification by radio that a bus had completed its route I "E' would depend on hearing the route number correctly and on i knowing it. Additionally, one would have to decide where to i wait if no portable radio was available. Confusion could l be bad enough for the able but exceedingly disturbing to the disabled.

For the above two reasons the brochure has not been read and understood and does not satisfy the require-ments of 50 CFR 50.47 (b) (10).

See reply to Questions 27 and 29 above.

QUESTION 30 (a) Spanish (b) Don't know OUESTION 33 50 CFR 50.47 (b) is deficient as it applies to Rockland County under (1) "each principal response organi-zation has staff to respond and to augment its ihitial re-sponse on a continuous basis." Not so for Rockland County.

Same for (b)(5)

(b)(6) 75% of emergency personnel cannot be reached during the day. Witnesses Schnakenberg 27, Bower 443.

(b)(7) not done (b)(9) Rockland County Health Department asks for 12 monitoring kits but was only promised 3 by NYState REPG on May 28, 1982 - see testimony of Rockland County witness James McGuire.

(b)(10) Not in Rockland County (b)(11) see testimony 41 and 42 (b)(12)

King and Galdone (b)(14) " major portions". There has been no drill of buses and individual automobiles.

(b)(15) is not (b)(16) is not QUESTION 34 See reply to 33 above. ,

OUESTION 35 see (b)(9) in reply to 33 above OUESTION 54 see reply 33 (b)(14) above i: -

iC QUESTION 55 There haven't been any in regard to roads.

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QUESTION 58 ,See 33(b)(14) and 55 above. '

1 j

QUESTION 68 There is no way of knowing how many buses will be available. See testimony of Rockland County witnesses Lebovsky and Bull.

QUESTION 69 See testimony witness Rochard Bower 43.

QUESTION 70 See maps of bottlenecks, Exhibit UCS-1 QUESTION 75 l kn effective drill would be one of the buses and autos to see how they would move on the roads without panic.

WBCA contends that the road network and movement over it is the Achilles heel of the Plan. Until it is tested, nothing will be known. that comes near it in importance.

QUESTION 85 WBCA knew the views in 1980 and 1981 of witnesses Seeger 26, Holland 29, Scurti 25, Schnakenberg 27, Tomkins 47 and Rockland County witness James Kralik.

1 CUESTION 86 See answer to 17 above.

CUESTION 96 Answer to 85 above. The road system in Rockland County is unusual in that North-Sou:th ridges discourage East-West traffic and conditions are exacerbated due to the density of population.

CUESTION 98 See reply to 85 above CUESTION 107 Not a subject for Questions 3 and 4.

CUESTION 108 WBCA understood the PB model was developed for handling road system loading and was not designed for radio-logical emergencies. There has been no real live radio-logical accident to follow. The simulation is questionable.

QUESTION 109 Public reports of the Palisades Interstate Park Commission, later confirmed by data from Chief James W.

Donnelly, Chief of the Park Police, on February 3. (This ct .

should have been an attachment to Robert Johnson's testi- -"

=eny 17, he will prepare it for submission July 6.-) .

The summer peak instant capacity is 59,800 people in Bear Mountain and Harriman State parks, plus ,

(n. 1,700 at Hi-Tor, 9,800 at Rockland Lake and 800 at Stony VEF Point Battlefield. If one allows 3 persons to a car it would equal 50,000 cars. Additionally there could be up to 2,500 people brought to the park by the dayliner.

QUESTION 110 See testimony of Myles Lavelle 24, Chief

. Scurti 25, Stanley Brooker 151, Kenneth Ingenito 22.

QUESTION 111 See RERP Plan Appendix A-53,54 & 55. Testi-mony of Holland 29 and Seeger 26 and Jan. 11 WBCA bases for Question 1.

QUESTION 121 Not enough East-West roads in Rockland.

North-South is all that's left.

QUESTION 127 What is the definition of " Indian Point area"?

If it is the ten mile EPZ then Caspar Hill Road is an ex-ample of topographic impossibility; as well as the infamous two right turns on Route 202 going south off 9W in West Haverstraw and Wayne Avenue in Stony Point. See brochures

1. 8 and #9 routes to evacuate and also see WBCA January 11 contentions pages 6 and 7.

.=_ )

QUESTION 145 PB data supplied by Licensees shows no account for traffic entering major routes from the side streets and it does show bottlenecks which were not offered in the RERP Rev. 1 as called for in NUREG 0654-FEMA Rep 1 - Rev 1 page 4-9 regarding the area map.

QUESTION 158 l

Because there are no feasible off site procedures Rockland County rejected the Plan. Primary is our inability to discover in the Plan, or by interrogatory of the Licen- ,

sees to PB, how many volunteers total that would be needed for an emergency and how many might be available, for such as directing traffic, drive buses and supply ambulance teams.

Emergency personnel in Rockland County have felt ill equipped and have no faith in the Plan made by PB. They do not work to enforce it. See testimony of Bower 43, Rev.

Fred Johnson 32 and those listed in the replies above.

QUESTION 160 See bottleneck maps of PB Figures 26 and 27 in d@h Exhibit UCS #1. All major evacuation routes excepting the Palisades Interstate Parkway would need widening and straight-ening to move traffic to the PB evacdation time standards. It is not feasible because no one has the money to pay for road

i redesign. i l

41.  !

character that still remaina.The residents of Rockland County covet the rural 99?

road " improvements". They have voted down many ness William Chase and Fred Seeger 26.See testimony of Rockland County wit-straightening roads a reality,Because the Planit isoffers impossible to un-only an make leveling an reality.

.County.

made but it is eminently unrealistic to redesign RocklandOn p homes on the curves of roads alone would be beyond the cost to which any agency would be willing to subscribe. [L Q

.UESTION 161 I:

v See reply to 85, 96, 108, 110, 121. and 160 (a) =l antiquated roads are routes 202,as306, listed pages A-53-56, Little Tor, 45,in9RERP Appendix W, Middletown/ A, and Main Street in New City.Caspar Hill Road, Wayne Avenue, Kings Highwa '"

~~

QUESTION 162

~

TU Wein,51.Gladys Burger 63, Barbara Blattstein 59 and JohnSee tes

~

Bi Moore "

too be may little equipment alone at home. to warn the deaf and the blind whoThere are All within the 10 mile EPZ. ;_

OUESTION 163 r71 See reply to 162 above, a OUESTION 165 h evacuation. All persons should have equal opportunity for Wi not believe in Notriage.

lives should be sacr ificed. NBCA does @

Certainly in weighing hm-oa life ==

versus the supply of electricity there should be no .tuch thoughts. ti f

condition is not for us to judge. Human life in its best or least advantaged ((i Le ME is also reflected in the number of handicapped,The including density of@Ip the Helen Hayes Rehabilitation Center, E5 by the Association for Retarded Children,the school conducted EE County Health County CenterComplex For the Physically Handicappedthe Rockland @2 the Rockland many persons at home., the many nursing homes, and the EE3 EE.8

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C5 EE 55

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._ x_ ,. l OUESTION 166'See Blattstein 59, Burger 63 and Rockland

,y.g County witnesses. Ruth Northrup and Wein. ,

OUESTION 168, Lack of sufficient buses.

QUESTION 172 See7 reply to 166 ,

i

. QUESTION 173 See isply to 166. ,

OUESTION 178 See reply to 166 OUESTION 180 See WBCA list sub:nitted June 22 and testimony book.

QUESTION 181 WBCA is Lead Intervenor on 3.9 and 4.4 QUESTION 182 (e) see reply to 181 above.

AFFIDAVIT I, Zipporah.S. Fleisher, Secretary of West Branch Conservation Association, being duly sworn, do hereby affirm that the attached answers to Interrogatories of the Licensees in above captioned case, are true and correct to the best of my knowl3dge.

? 12h ri E r Mipporah S. Fleisher Sworn before me this 30th day of June /f/A NothyPubl[c .

DOLORES CAMPIONE

( Notary Pubhc, State of New YoAt No.4527041 i 4

Quahfied in Rockland Cour i

Term Espues Marcn 30,1 e .

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION G

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ATOMIC SAFETY AND LICENSING 80ARD Before Administ rative Judges:

Louis J. Carter, Chairman Frederick J. Shon

. In the Matter or Dr. Oscar H. Paris

)

CONSOLIDATED EDISON COMPANY OF )

NEW YORK, INC. (Indian Point, )

Unit No. 2) ) Docket Nos. 50-247-SP

) 50-286-SP POWER AUTHORITY OF THE STATE OF )

NEW YORK, (Indian Point, June 30,1982

)

Unit No. 3) i CERTIFICATE OF SERVICE This is to certify that I have this 30th day of June placed in the U. S. Mails first class a copy of the REPLY TO INTER-ROGATORIES OF LICENSEES to each of the parties listed below.

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443 Buena Vista Road, New City, N 7. 10956 W4,rth '. ,'

914/634-2327 *> d F$g

k. _ by Zipporah 5. I'le J.s her Secretary

-_ _ _ _ . - - .