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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20069L1991983-04-22022 April 1983 Interrogatories & Document Request.Related Correspondence ML20069L2091983-04-22022 April 1983 Supplemental Interrogatories.Certificate of Svc Encl ML20071D2941983-03-0303 March 1983 Supplemental Response to 820621 Interrogatories on Contention 6.2,transmitting Form for Recording Continuous Type Releases.Certificate of Svc Encl ML20083Q3931983-02-22022 February 1983 Motion to Permit Entry on Licensee Controlled Land to Observe 830309 Emergency Planning Exercise from Control Rooms & near-site Emergency Operations Facility ML20065C2111983-02-22022 February 1983 Motion to Permit Entry Upon Land Controlled by Licensees & to Allow Observance of 830309 Emergency Planning Exercise from Both Units 2 & 3 Control Rooms & from near-site Emergency Operations Facility ML20028C8671983-01-0707 January 1983 Response to Licensee 821203 Ltr Requesting Supplemental Responses to Licensee First Set of Interrogatories. Certificate of Svc Encl ML20064C4481982-12-30030 December 1982 Suppl to Responses to First Set of Interrogatories & Document Requests on ASLB Questions 1,2 & 5 ML20070L5471982-12-24024 December 1982 Supplemental Response to First Set of Interrogatories Under Commission Question 1 ML20070L5491982-12-22022 December 1982 Response to First Set of Interrogatories & Document Requests Under Commission Question 6.Certificate of Svc Encl.Related Correspondence ML20070F7581982-12-17017 December 1982 Supplementation of Interrogatory Response,Naming Question 1 Witnesses.Certificate of Svc Encl ML20069Q5231982-12-0707 December 1982 Supplemental Response to Interrogatories on Commission Questions 1 & 2.Certificate of Svc Encl ML20069P7641982-12-0606 December 1982 Supplemental Response to First Set of Interrogatories & Document Requests on ASLB Questions 1,2 & 5 ML20067B1761982-12-0303 December 1982 Response to 820716 First Set of Interrogatories & Request for Documents Re Commission Questions 1 & 2 ML20067B2391982-12-0202 December 1982 Response to Interrogatories & Document Requests Re Commission Questions 2 & 5.Related Correspondence ML20028B2981982-11-24024 November 1982 Replies to 820718 Interrogatories.Certificate of Svc Encl. Related Correspondence ML20028B4011982-11-22022 November 1982 Supplemental Response to First Set of Interrogatories Re Questions 1 & 2.Certificate of Svc Encl ML20066J2611982-11-19019 November 1982 Responses to Interrogatories & Document Requests on Commission Question 2,Contention 2.2.Certificate of Svc Encl.Related Correspondence ML20066J0411982-11-19019 November 1982 Responses to First Set of Interrogatories & Document Requests on ASLB Questions 1,2 & 5.Certificate of Svc Encl ML20028A0491982-11-0303 November 1982 Response to 820526 Interrogatories & Document Requests Re Question 6.Interrogatories Received on 821015 ML20058G5211982-07-23023 July 1982 Response to Final Set of Interrogatories & Document Requests Re Commission Question 1.Certificate of Svc Encl.Related Correspondence ML20058D5921982-07-23023 July 1982 Response to First Set of Interrogatories Re Commission Question 1.Certificate of Svc Encl.Related Correspondence ML20058D5681982-07-21021 July 1982 Response to 8206221 Interrogatories,Objecting to Interrogatories 1-11 as Irrelevant,Beyond Scope of Permissible Discovery & Beyond Scope of Commission Question 6.Certificate of Svc Encl.Related Correspondence ML20058D5791982-07-20020 July 1982 Response to Second Round of Interrogatories Re Commission Questions 1,2 & 5.Certificate of Svc Encl ML20055B8621982-07-19019 July 1982 Interrogatory on Question 2,Contention 2.2.Certificate of Svc Encl ML20069C8621982-07-19019 July 1982 First Set of Interrogatories & Document Requests on Board Questions 1,2 & 5 ML20055A9981982-07-16016 July 1982 First Set of Interrogatories & Request for Documents Re Commission Questions 2 & 5.Certificate of Svc Encl ML20055A9901982-07-16016 July 1982 First Set of Interrogatories & Request for Documents Re Commission Question 1 ML20055A9961982-07-16016 July 1982 First Set of Interrogatories & Request for Documents Re Commission Questions 1 & 2 ML20063E4491982-07-0707 July 1982 Response to First Set of Interrogatories on Commission Question 6.Certificate of Svc Encl.Related Correspondence ML20054L5771982-07-0202 July 1982 Responses to First Set of Interrogatories on Question 6. Certificate of Svc Encl ML20054L7991982-07-0101 July 1982 Addl Response to Interrogatories Under Commission Questions 3 & 4 Per ASLB 820625 Order.Certificate of Svc Encl ML20054L5201982-07-0101 July 1982 Supplemental Response to Licensee 820503 Interrogatories. Certificate of Svc Encl.Related Correspondence ML20054M1791982-06-30030 June 1982 Reply to Interrogatories.Certificate of Svc Encl.Related Correspondence ML20054L5501982-06-30030 June 1982 Supplementary Responses to First Set of Interrogatories Re Questions 1 & 2.Certificate of Svc Encl.Related Correspondence ML20054J5871982-06-25025 June 1982 Responses to First Set of Interrogatories Re Questions 1 & 2.Certificate of Svc Encl.Related Correspondence ML20054J9301982-06-25025 June 1982 Final Response to Util Interrogatories.Certificate of Svc Encl.Related Correspondence ML20054H8941982-06-24024 June 1982 Second Set of Interrogatories Re Commission Questions 1,2 & 5.Certificate of Svc Encl ML20054H8901982-06-24024 June 1982 Second Set of Interrogatories Re Commission Questions 1,2 & 5 ML20054J1221982-06-22022 June 1982 Response to Ucs/Ny Pirg Requests for Admissions.Details Surrounding TMI-2 Accident Would Require Burdensome & Oppressive Research.Affidavits & Certificate of Svc Encl ML20054J1471982-06-21021 June 1982 Interrogatories on Contention 6.2.Related Correspondence ML20054H5411982-06-17017 June 1982 Responses to NRC Interrogatories & Document Requests. Certificate of Svc Encl.Related Correspondence ML20054H5301982-06-17017 June 1982 Responses to NRC Interrogatories & Requests for Documents. Certificate of Svc Encl.Related Correspondence ML20054H2601982-06-17017 June 1982 Reply to NRC 820526 Interrogatories ML20054H5661982-06-17017 June 1982 Responses to NRC Interrogatories & Document Requests. Certificate of Svc Encl ML20054H2631982-06-16016 June 1982 Reply to Licensee First Set of Interrogatories,Question 6. Certificate of Svc Encl ML20054F9801982-06-16016 June 1982 First Set of Interrogatories & Document Requests Re ASLB Contention 1.Certificate of Svc Encl.Related Correspondence ML20054H5811982-06-16016 June 1982 Response to West Branch Conservation Assoc Supplementary Interrogatories.Related Correspondence ML20054H5881982-06-16016 June 1982 Response to Ucs/Ny Pirg Supplementary Interrogatories. Certificate of Svc Encl.Related Correspondence ML20054H6081982-06-16016 June 1982 First Set of Interrogatories Re Commission Question 6 ML20054F6251982-06-14014 June 1982 Answers & Objections to Interrogatories & Document Requests. Certificate of Svc Encl 1983-04-22
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARJPN-99-029, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors ML20212E4181999-09-15015 September 1999 Petition Per 10CFR2.206 Requesting OL for Unit 2 Be Modified or Suspended to Prevent Restart Until Reasonable Assurance That Licensee in Substantial Compliance with Terms of OL & Has Proper Consideration for Public Health & Safety JPN-99-022, Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds1999-06-22022 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds ML20202J6321999-01-20020 January 1999 Transcript of 990120 Meeting in Peekskill,Ny Re Decommissioning.Pp 1-132.With Related Documentation ML20198E9721998-12-21021 December 1998 Order Prohibiting Involvement in NRC-Licensed Activities. Orders That Wh Clark Prohibited for 1 Yr from Engaging in NRC-Licensed Activities JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects ML20198L2731998-12-21021 December 1998 Comment Supporting NEI Re Proposed Rules 10CFR50, 52 & 72 Re Changes,Tests & Experiments JPN-98-050, Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal ML20155F4561998-08-26026 August 1998 Demand for Info Re False Info Allegedly Provided by Wh Clark to Two NRC Licensees.Nrc Considering Whether Individual Should Be Prohibited from Working in NRC-licensed Activities for Period of 5 Yrs ML20238F5271998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 IA-98-261, Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-461998-05-20020 May 1998 Partially Deleted Transcript of 980520 Enforcement Conference in King of Prussia,Pa Re J Stipek.Pp 1-46 ML20238F5241998-05-0606 May 1998 Transcript of 980506 Enforcement Conference Held in King of Prussia,Pa Re Con Edison,Indian Point.Pp 1-75 JPN-97-037, Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated1997-12-0101 December 1997 Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated ML20148M6471997-06-19019 June 1997 Comment Opposing Porposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems ML20133N0511997-01-0505 January 1997 Comment Opposing Proposed Rule 10CFR50, Draft Policy Statement on Resturcturing & Economic Deregulation of Electric Util Industry ML20149M4621996-12-0909 December 1996 Comment Opposing Proposed Rule 10CFR50 Re Draft Policy Statement on Restructuring & Economic Deregulation of Electric Utility Industry ML20077G3481994-12-0808 December 1994 Comment on Proposed Rule 10CFR2,51 & 54 Re Nuclear Power License Renewal ML20070P0561994-04-19019 April 1994 Comment Supporting Proposed Rule 10CFR50 Re NRC Draft Policy Statement on Use of Decommissioning Trust Funds Before Decommissioning Plan Approval ML20029C5771994-03-11011 March 1994 Comment on Proposed Rule 10CFR20 Re Draft Rule on Decommissioning.Informs That 15 Mrem/Yr Unreasonably Low Fraction of Icrp,Ncrp & Regulatory Public Dose Limit of 100 Mrem/Yr ML20059C3031993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Definition of Commercial Grade Item ML20045H8751993-07-19019 July 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule ML20045F2451993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria ML20044F5681993-05-20020 May 1993 Comment on Draft Commercial Grade Dedication Insp Procedure 38703,entitled Commercial Grade Procurement Insp. Endorses NUMARC Comments Dtd 930517 JPN-02-034, Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl1992-07-0606 July 1992 Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants1991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants JPN-91-005, Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended1991-01-28028 January 1991 Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended ML20066G4411991-01-23023 January 1991 Comments on Proposed Rule 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Substantive Typo in 901015 Filing on Behalf of Licensee Noted ML20058G6341990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty Program JPN-90-068, Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS1990-10-22022 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20065H7541990-10-15015 October 1990 Comment Re Proposed Rules 10CFR2,50 & 54 on Nuclear Power Plant License Renewal.Commission Assessment of Four Alternatives Should Be Expanded to Include Not Only Safety Considerations But Other Atomic Energy Act Objectives JPN-90-067, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC1990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR1990-07-0909 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR JPN-90-050, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary ML20012C6491990-03-0909 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against PTS Events. Any Utilization of NRC Proposed Application of Reg Guide 1.99, Rev 2,would Be Inappropriate W/O re-evaluation by NRC ML20005F6521989-12-13013 December 1989 Comment on Proposed Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Concurs w/industry-wide Position Presented by NUMARC & Offers Addl Comments ML20246P6061989-07-0707 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Significant & Independent Industry Efforts Already Underway to Address Issue ML20245K1941989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235V9011989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Supports NUMARC Position.Proposed Rule Will Hinder Important Initiatives to Improve Maint JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments ML20205L8521988-10-21021 October 1988 Comment Opposing Proposed Rule 10CFR20 Re Cleaning or Disposing of Nuclear Waste.Incineration of Radwaste Oil Should Not Be Allowed JPN-88-015, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site1988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site JPN-88-002, Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed1988-01-25025 January 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed JPN-87-062, Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex1987-12-31031 December 1987 Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex JPN-87-053, Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection1987-10-15015 October 1987 Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl ML20235Y9911987-07-20020 July 1987 Notice of Issuance of Director'S Decision Under 10CFR2.206 Re Emergency Planning for School Children in Vicinity of Indian Point.* Request to Suspend OLs Denied ML20151C5061987-02-18018 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20093H6421984-10-15015 October 1984 Comments on Staff Presentation at Commission 841002 Meeting. Commission Should Conclude Proceedings Due to Inescapable Conclusion That Facility Safe to Operate & Poses No Undue Risk to Public.Certificate of Svc Encl ML20098D2721984-09-26026 September 1984 Comments on Commission 840905 Meeting Re Facilities,Per Sj Chilk 840911 Memo.Licensee Agrees W/Staff That Further Mitigative Features or Plant Shutdown Unnecessary Due to Low Risk.Certificate of Svc Encl 1999-09-20
[Table view] |
Text
_ . - . _ _ . . _ _ . . __
-. ,, ,m r r n E u tim Cv,. -
UNITED STATES OF AMERICA
- .~o' CLEAR REGULAICRY CCMMISSICS 00CKETED USNRC 3efore the AICMIC SAFETY AND LICENSI::G RCgD .-Mc-2 ni:u
' " 7 07 pcu f?
.c- oh, n g - t In the Matter of
. Docket Numbers Consolidated Edison Company of 50 247-SP New York (Indian Point Unit 2) -
d~0L286-s?
5 Power Authority of the State of New York (Indidn Point Unit 3)
~
July 2.3,1982 PARENTS CCNCERhED A3 CUT INDIAN PLIKT RESPONSE to Licensees' First Set of Interrogatories and Document Requests Under Commission Question 1 to ... Parents ..
We have answered the following interrogatories to the best of our abilities based on our personal knowledge at the present of the issues addressed herein. -
(1) RESPONSE PARENTS does not know how the AS & LB defines " risk" and "high safety risk". PARENTS has a general understanding that risk means the sum of the probabilities of accident sequences that could result in a significant release
. of radiation. Since new accident sequences are constantly
'being discovered, the risk is difficult to assess accurately.
(2) RESPONSE (1) NUREG/CR-0400 " Lewis Committee Report" .
(2) Review of the Zion Probabilistic Safety Study, Sandia and Brookhaven Labs. .
(3) RESPONSE PARENTS has no information which can help us respond to this question.
(4) RESPONSE Not applicable.
(5) _ RESPONSE None.
8200030348 820723 PDR ADOCK 05000247 b
. Parents, July 23, 1982 (6) RESPONSE No degree of risk from nuclear power facilities is acceptable to PARENTS, because other safer technologies, including conservation technologies, exist to supply our energy needs. We believe that no benefit to society is acceptablewhich places the burden of intolerable risk on individuals.
(7) RESPONSE PARENTS knows of no such documents.
(8) RESPONSE There is no level of radiation to which the public may be exposed without harm. The effects of radiation are cumulative. Fetuses, children and the elderly are more susceptible to radiation effects than healthy adults.
(9). RESPONSE PARENTS is not prepared to answer at this time. We will supplement when this information is available.
(10) RESPONSE None.
(109) Specify the types of nuclear accidents or accident ..
scenarios which form the basis of Parents Contention I, and quantify the probability of occurrence of each accident.
RESPCNSE PARENTS plans to use the types of acciden'ts or accident scenarios described in the following documents:
(1) Potential Precursors to Severe Core Damage (tne study by the Cak Ridge National Laboratory)
(ii) Reactor Safety Study (Wash 1400)
(iii) Three Mile Island, A Recort to the Commissioners anc to tne Public (Rogovin Commis.-ion Report)
(iv) ReDort_of the Zion / Indian Pnint Study
( NUREG/ CR-1410)
(v) Technical Bases for Estimatics Fission Product Eenavlor Durine LWR Accidents (NUREG-0722)
(vi) Risk Assessment Review Grout Retort to the U.S. N.R.C. (Lewis Report, 1.~UREG/ C R-0400 )
(vii) Indian Point Probalistic safety Study
Paronts, July 13, 198
-3=
The scenarios involve reactor embrittlement, fire hazards, hydrogen burning, thermal shock, loss of pressure, overpressur-
. 1:ation, valve and pump failure, spray and fan cooler problems, control rod failure, aging equipment, and steam spike.
PARENTS has not idependently quantified the probability of the occurence of each accident. We therefore object to the interrogatory as being unduly burdensome.
(110) State the radiation dose absorption rate for children and for adults, and specify the protective measure which would accomodate such rate f.or children.
RESPONSE PARENTS plans to rely on the sources listed in ATTACHMENT #1, among others, in developing its testimony on radiation dose absorption rates. ,
No protective measure can completely accomodate any rate of radiation exposure by children, since radiation effects are cumulative over the entire life of the individual. However, the following measures, if all taken promptly, might mitigate ..
the most serious consequences: " reverse isolation..., sterilization of all objects in patient's room, use of... laminar-air-flow systems, large doses of antibiotics, and transfusions _of whole-blood packed cells or platelets." (Wash-1400, Appendix VI, F1, as quoted in written testimony of Dr. Jan Beyea, June 7, 1982, Table 1,~page 18.)
(111) State the difference in risk as applied to children and adults with regard to the following consequences of an accident at Indian Point: (a) prompt fatalities; (b) early fItalities; (b) early illnesses; (d) latent illnesses; (e) fatal cancers; (f) non-fatal cancers; (g) thyroid nodules; (h) genetic effects; and (i) genetic defects.
RESPONSE PARENTS has a general understanding that rapidly dividing cells are more susceptible to all the effects of ra-diation, including the effects listed in interrogatory (111).
Yetuses, whose cells are dividing most rapidly, are most sus-ceptible. The increase in dose absorption rates depends on the nature of radiation exposure and the body-part affected, and the difference between child and adult dose absorption rates may vary by a factor of two or a factor of 10.
Parante, July 23, 1982
-p Cur understandin6 is based on non-expertreports and use of the expert literature. For instance, in order to make the calcula-tions which form the basis of his testimony, Dr. Jan Seyea assumed "a 5 times higher dose for children than ad'ults for the same exposure."
PARENTS plans to rely on the following sources, among others, in developing its testimony on the difference between adult and child dose absorption rates:
(1) The Effects on Population of Exposure to Low Levels of Ionizing Radiation: Report of the Advisory Committee on the Biological Effects of Ionizing Radia-tions. 3EIR Report, 1972 and 1980.
(ii) Jablon, et.al: Cancer in Japanese Exposed as Children to Atomic Bombs. Lancet 1:927-932, 1971 (iii) Hempelmann: Neoplasms in Youthful Populations Following x-ray Traatment in Infancy. Environmental-Research 1: 338, 1967.
(iv) McMahon, 3: Prenatal x-ray Exposure and Malig-nancy. JAMA 183:721, 1963. ,
(v) Silverman and Hoffman: Thyroid Tumor Risk from Radiation During Childhood. Preventive Medicine 4: 100, 1975.
Thyroid (vi) Weiss, Rallison, London et al:
Nodularity in Southwestern Utah school children Ex-posed to Fallout Radiation. Am J Publ Health 61:241, 1971.
l (vii) Rallison, Dobyns, Keating, et al: Thgroid 1
Disease in Children: A Survey of Subjects Potentially Exposed to Fallout. Radiation. Am J Med 56:457, 1974.
(viii) Rallison, Dobyns, Keating, et al: Thyroid l
Nodularity in Children. JAMA 233: 1069, 1975.
(ix) Mays, C.W: Thyroid Irradiation in Utah
~
Infants Exposed to Iodine 131. Scientist and Citizen, i
l August, 1966.
(x) MacMahon, 3: Prenatal x-ray Er.posure and Childhood Cancer. J . Natl Cancer Inst 28: 1173, 1962.
(112) State the probability of the occurrence of an accident at Indian Point having each censequence described in Interrogatory No. 111.
1 l RESPONSE PARENTS objects to this interrogatory as burdensome and onoressive. Farents has not hired an expert to calculate prob-abilities.
l
Parents, July 13, 1982 (113) Provide all documents which contain and/or pertain to the calculation of the probabilities described in Interrogatory 4 lio 112.
RESPONSE Except for the documents listed in the answer to Interrogatory No. 109, PARENTS does not have custody and control of any such documents.
Respectfully s bmitted, Pat Posner PAREIiTS CONCER13D A3CU.T INDIAN PCINT I hereby certify that copies of this document have been mailed or delivered by hand (to those marked with *) to the following -
service list this day of July 23, 1982 Pat Posner
- ~ - - - -- --. .-... .~ . _ . .
. A TTMANGW7~ 9L Radiation: Unccfo At Apy Leval, H. Caldicott, cd:ptGd from Nuclear Madness _, 1978 (as appeared in The Progressive, 12/78, pp. 39-44.)
Low-Level Radiation: A High-Level Concern, C. Holden, Science, 4/13/79, (204, pp. 155-158.)
Low-Level Radiation: Just How Bad Is It?, J. Marx, Science, 4/1 /79, (204, pp. 160-164.)
Th3 Risks For Radiation Workers, J. Rotblat, Bulletin of the Atomic Scientists, 9/78, (34,7, pp. 41-46.) Edsall, Toxicity of Plutonium and Some Other Actinides, J.
Bulletin of the Atomic Scientists, 9/76, (32,7, pp. 27-37.)
Migrction of Radioactive Products Through Alimentary Chains, I.
Vasilenko, Journal of Hygiene, Epidemiology, Micro-biology and Immunology, 1977, (21,4, pp. 395-404.)
Plutonium in Drinking Water: Effects ofR.Chlorination Larsen and R.
on Its Maximum Permissable Concentration, Oldham, Science, 9/15/78, (201, pp. 1008-1009.)
Tcble of Types of Cancers Associated with Radiation in Various Populations, U. S. Interagency Task Force on Ionizing Radiation, 1979 Cancor and Low Level Ionizing Radiation, K. Morgan, Bulletin of the Atomic Scientists, 9/78, (34,7, pp. 30-41.)
Stewart, Advances in Low Dose Radiation Cancers in }bn, A. .
Cancer Research, 1971, (14, pp. 359-390.)
Mortclity from Leukemia Colton, and Cancer The in Shipyard Lancet, Nuclear 5/13/78 (pp.Workers, 1018-1020.)
T. Najarian and T.
The Plutonium Controversy, J. Gofman, Journal of the American Medical Association, 7/19/76 (236,3, pp. 284-286.)
Summary of Epidemiological Evaluation of Cancer Incidence Rates for the Period 1969-1971 in Areas of Csnsus Tracts with Measured Concentrations of Plutonium Soil Contamination Downwind from the Rocky Flats Plant, C. Johnson, 2/9/79 Childhood Leukemias Associated With and Gardner Fallout From New K. Udall, Nuclear Testing, England J. Lyon, M. Klauber, J.
Journal of Medicine, 2/22/79, (300,8, pp. 397-402.)
Radiation as the Cause of Lung Cancer AmongUranium Miners, 7/22/65, J. Wagoner et al., New Rngland Journal of Medicine, (273,4, pp. 181-188.)
l Radiation Dose Effects in Relation to Obstetric X-Rays and Kneale, The Lancet, I Childhood Cancers, A. Stewart and G.
6/6/70, (pp. 1185-1188.1 Down's Syndrome and Related Abnormalities in anKochupillai, Area of High Background Radiation in Coastal Kerala, N.Ramalingaswami, Nature, 7/1/76, I. Verma, M. Grewal, and V.
(262, pp. 60-61.)
Localisation of Plutonium in Mouse Testes, D. Green, G. Howells, E. Humphreys*and J. Vennart, Nature, 5/1/75, (255, p. 277.)
Plutonium and Other Actinide Elements In Gonadal Tissue of Man and Animals, C. Richmond and R. Thomas , Health Physics , 1975, (29, pp. 241-50.)
Cytogenic Investigation in a Brazilian Population Living in an Area of High Natural Radioactivity, M. Barcinski et cl.,
American Journal of Human Genetics, 1975, (27, pp. 802-806.)
Chromosomal Abegrations at Very Lcw Radiation Dose Rates, J. Savage, Nature, 2/15/79, (277, pp. 512-513.)
Radiation-Induced Chromosome Aberrations in Nuclear-Dockyard Workers, H. Evans,'K. Buckton, G. Hamilton and A. Carother, Nature, 2/15/79, (277, pp. 531-534.)
Tho Medical Consequences of Thermonuclear War, New England Journal of Medicinen 5/31/@20 (2 66 g22 g gp. 1126-1145.),
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