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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
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I ADMJA Q#M'D.NDENCH a
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UNITED STATES OF AMERICA COCXETED NUCLEAR REGULATORY COMMISSION USMC ATOMIC BeforeSAFETY AND LICENSING Administrative BOSp) Ifl 27 E3 :16 Judges:0 James P. Gleason, Chairman Dr. Oscar H. Paris Frederick J. Shon
x CONSOLIDATED EDISON COMPANY OF : Docket Nos. 50-247-SP NEW YORK, INC. (Indian Point, : Docket Nos. 50-286-SP Unit 2) :
POWER AUTHORITY OF THE STATE OF :
NEW YORK, (Indian Point, :
Unit 3) :
x April 22, 1983 LICENSEES' INTERROGATORIES TO THE FEDERAL EMERCENCY MANAGEMENT AGENCY ATTORNEYS FILING THIS DOCUMENT:
Charles Morgan, Jr. Brent L. Brandenburg MORGAN ASSOCIATES, CHARTERED CONSOLIDATED EDISON COMPANY 1899 L Street, N.W. OF NEW YORK, INC.
Washington, D.C. 20036 4 Irving Place (202)466-7000 New York, New York 10003 (212)460-4333 8304280087 830422
"" \
PDR ADOCK 05000247 0 PDR s
PRELIMINARY STATEMENT Pursuant to 10 CFR Part 2 and the Memorandum and Order (Formulating Contentions, Assigning Intervenors, and Setting Schedule) herein, dated April 23, 1982 (the " April 23, 1982 Order"), 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 (" Power Authority"),
-licensee.of Indian Point 3 Nuclear Power Plant (collectively the
" licensees"), request that the Federal Emergency Management Agency (" FEMA") answer on or before April 26, 1983, under oath and otherwise in accordance with 10 CFR Part 2 and the April 23, 1982 Order, the following interrogatories:
DEFINITIONS A. "or" shall mean and/or.
B. " Document" shall mean any kind of written or graphic matter, however produced or reproduced, of any kind or description, whether sent or received or neither, including originals, copies and drafts and both sides thereof, and including, but not limited to: papers, books, correspondence, telegrams, cables telex messages, memoranda, notes, notations, work papers, transcripts, minutes, reports and recordings of telephone or other conversations, or of interviews, or of conferences, or of other meetingr (including, but not limited to, meetings of boards of directors or committees thereof),
affidavits, statements, summaries, opinions, reports, studies, analyses, evaluations, contracts, agreements, journals, statistical records, desk calendars, appointment books, dia'ies, r
lists, tabulations, sound recordings, financial statements, computer printouts data processing input and output, microfilms, all other things similar to any of the foregoing however denominated by FEMA.
C. " Identify" or " state the identity," when referring to a' document shall shall mean to state:
- 1. The generic nature of the document (e.g.,
letter, memorandum, telegren, etc . ) ;
- 2. The date on which the document and each copy thereof was prepared;
- 3. The name of each author, addressor and addressee of the document;
- 4. The name of each past or present custodian of each copy of the document; and
- 5. A brief description of the contents of the document. (In lieu of such a description,'you may append to your answer a true and complete copy of the document.)
, D. " Identify," when referring to an oral communica-tion, shall mean:
- 1. To state the date of such communications;
- 2. To identify each person participating therein and each person who was present;
- 3. To state what was said by each participant in the course of such communication, or, if not known as recalled, the substance;
t
. 4. .To state whether there are any documents which set forth, summarize or refer to any portion of such oral communication; and
- 5. If such documents exist, _to identify each such document and each person having ctistody of the document.
1 E. ~" Identify" or " state the identity", when referring to a person, shall mean to state:
- 1. The person's full name;
- 2. The name of his employer;
- 3. His position with such employer;
- 4. His business address and telephone number; and
_5. His present or last known home address and telephone number.
F. " Identify," when referring to a claimed' deficiency, defect or inadequacy in emergency planning for Indian Point or the Indian Point emergency plan, shall mean to state specific-ally the nature of the claimed deficiency, defect -or inadequacy,
' including:
, 1. the aspect of planning, provision of the plan alleged to be deficient, defective or inadequate;
- 2. the grounds for your claim that the aspect of planning, plan or provision is deficient, defective or inadequate;
- 3. whether steps have been taken at any nuclear plant, or in any emergency plan other than Indian Point to correct such deficiency, and if so, the identity of the nuclear plant or emergency plan.
G. To " state the grounds" or to " identify the grounds" for an allegation, claim, or contention means to describe in 4
detail the reasoning-and facts and to provide all data and calculations, which you claim support the' allegation, claim, or contention, and to-identify all relevant documents, and
- communications, and individual informants and to state the precise nature and source of'your knowledge, information and-
~
belief that there is good ground to support such allegation, claim, or contention, and to specify any assumption on which the-allegation, claim or contention is based.
INTERROCATORIES
- 1. State whether FEMA has a plan or program, the purpose of which is to insure uniformity or consistency in the interpretation or application of the regulations in 10 CFR 550.47 and Appendix E to 10 CFR Part 50, or of NUREG-0654 planning standards,'between nuclear power plant sites and between FEMA Regions, and if so, describe and identify the plan or program. Identify all nuclear power sites to which this plan or program has been applied.
- 2. State whether FEMA has any manuals, guidebooks or standard review plans or procedures, other than NUREG-0654, which it employs in reviewing radiological emergency plans or in assessing the adequacy of such plans, and if.so, identify the documents and materials so employed.
- 3. In connection with FEMA's review and evaluation of radiological emergency plans, and in connection with FEMA's review of radiological emergency plan drills and exercises, state how a determination is made as to whether a particular shortcoming or deficiency is to be' characterized as "significant" or " minor," and identify all criteria employed in making such characterizations.
- 4. Identify each instance in which FEMA has encoun-tered a lack of cooperation or participation in radiological emergency planning activities on the part of one or more state county or local governmental units, and in each such instance:
(1) describe and identify the nature of the lack of cooperation or participation; (2) identify all compensating actions or measures taken or attempted-to ameliorate the significance of the' lack of cooperation or participation; (3) state whether FEMA evaluated or assessed the sufficiency of the compensating actions or measures, and if so describe and identify FEMA's evaluation or assessment; and (4) describe and identify the activities engaged in by FEMA to bring about the cooperation or participation of the governmental unit or units involved.
- 5. Identify each instance in which FEMA has determined that there were radiological emergency planning or preparedness deficiencies relating to arrangements for transportation of transit-dependent persons, and in each such instance: (1) describe and identify the nature of the deficiency; and (2) state whether the deficiency was found by FEMA to be significant or not, and describe the process by which such finding was made and the grounds therefor; and (3) identify all compensating actions or measures taken or attempted to ameliorate the significance of the deficiency.
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- 6. Identify each radiological emergency response plan of which FEMA is aware which requires or provides for contract-ual arrangements committing public or private transportation providers to transport transit-dependent persons in the event of a serious radiological accident.
- 7. In reviewing radiological emergency plans or in assessing the adequacy of such plans, state whether it is FEMA's policy to consider or assess the adequacy of planning with
~
respect to any particular serious radiological accident or class of accidents, and if so, describe the accident or class of accidents en' ployed, and state why such accident or class of accidents was selected.
- 8. Identify each instance in which FEMA has found that it could not assure that public health and safety could be protected in the vicinity of a nuclear power plant and in each such instance: (1) describe end identify the grounds for FEMA's inability;to provide such assurance; (2) describe the oasis, grounds and criteria which FEMA used in reaching such a conclusion; and (3) describe and identify the assumptions which FEMA made about the radiological accident or accidents for which protection could not be assured, including the warning time for such accident (s), the nature, timing and effectiveness of those protective responses which FEMA was able to find as feasible, and the quantity of radioactive materials released.
- 9. With respect to proposed 44 CFR Part 350, state why such proposed regulations have not been adopted, and
identify all comments.which FEMA has received regarding such
. proposed regulations subsequent to their publication in 47 Federal Register 36388 (August 19, 1982).
- 10. State whether FEMA Region II has received any instructions from the office of the FEMA Director or Associate Director regarding either the conduct of the Indian Point Special Proceeding or the evaluation of radiological emergency planning or preparedness in the vicinity of the Indian Point site, and if so, describe and identify such instructions.
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- 11. Identify and describe all correspondence between i
FEMA and-the Nuclear Regulatory Commission ("NRC") relating or-referring to: (1) the sufficiency of radiological emergency planning or preparedness at the Indian Point site; (2) those instances referred to in your answers to Interrogatory Nos. 4 and 5; (3) generic problems in evaluating off-site radiological emergency planning or preparedness; or (4) procedures or a
standards for characterizing emergency planning deficiencies as "significant" or " minor".
! 12. Identify and describe all correspondence between FEMA and state, county or local government elected officials relating to off-site radiological emergency planning or i
preparedness in the vicinity of the Indian Point site.
- 13. State whether it is FEMA's policy to encourage
- states to undertake compensatory actions or measures in instances where there is a lack of cooperation or participation in rudiological emergency planning on the part of county or local govenmental units, and describe the standards and criteria by~ which FEMA would. evaluate any.such compensatory actions or measures.
- 14. Identify and describe the standards and criteria which FEMA employs or would employ, for determining the suf ficiency of radiological emergency planning and preparedness to provide assurance that public health and safety would be protected,.with respect to conditions and circumstances which
.are not completely susceptible of verification by an exercise or drill.
- 15. -Identify and describe all criticisms and claims of
. inadequacy of which FEMA is aware relating to its radiological emergency planning and preparedness review and assessment activities.
- 16. State whether FEMA has provided, directly or through contractors, field training in the vicinity of nuclear power plants for persons who would be called upon to perform radiological emergency response activities in the event of a i
- serious accident at such plant site, and if so, identify each l
such site and describe the nature and extent of such field training.
[ 17. State separately (i) on an aggregate national r
basis, and (ii) for the Indian Point site, the amount of monies (or man-hours) which FEMA has devoted to: (1) radiological emergency preparedness training programs; (2) assessment and verification activities; (3) assessment and evaluation activities specifically'related to exercises;-and (4) other radiological emergency; preparedness functions including, without limitation, hearing support, and identify such other functions. ,
-- 18 . State whether FEMA has a plan or program, the purpose of which is to insure uniformity or consistency in the interpretation or application of the regulations in proposed 44 CFR Part 350 between nuclear power plant sites and between FEMA regions, and if so, describe and identify the' plan or program. Identify all nuclear power plant sites to which this plan or program has been applied.
- 19. Identify each radiological emergency response plan of which FEMA is aware which does not contain written or ,
other contractual commitments for emergency workers or response personnel identified in the plan-and in each instance: (1)-
identify FEMA's overall conclusion with respect to the adequacy of the plan; and (2) if the plan has been judged adequate, state why the absence of such written or other contractual commitments did not lead to a judgment of inadequacy.
- 20. Identify all FEMA procedures for appealing, challenging,~or otherwise contesting any finding, order, or other determination by a FEMA regional and/or national office.
DOCUMENT REQUEST Licensees request that FEMA produce for inspection and copying, pursuant.tua 10 CFR S2.741, each and every document identified in response to any interogatory set forth above.
It is requested that the aforesaid prode: tion be made on April 26, 1983 at a time and place to be agreed upon.
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Respectfully submitted,
.Y Brent L. Brandenburg
. 0),
Charles Morgan,[p . (jgg)
Paul F. Colarul M Joseph J. Levin, Jr.
CONSOLIDATED EDISON COIPANY MORGAN ASSOCIATES, CHARTERED OF NEW YORK, INC. 1899 L Street, N.W.
Licensee of Indian Point Washington, D.C. 20036 Unit 2 (202) 466-7000 4 Irving Place New York, New York 10003 Stephen L. Baum (212) 460-4600 General Counsel Charles M. Pratt Assistant Ceneral Counsel POWER AUTHORITY OF THE STATE OF NEW' YORK Licensee of Indian Point-Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D. Fischman Michael Curley Richard F. Czaja David H.Pikhs SHEA & COULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 Dated: April 22, 1983
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