ML20070L549

Response to First Set of Interrogatories & Document Requests Under Commission Question 6.Certificate of Svc Encl.Related Correspondence

ML20070L549
Person / Time
Site:	Indian Point
Issue date:	12/22/1982
From:	Rodriquez P PARENTS CONCERNED ABOUT INDIAN POINT
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
ISSUANCES-SP, NUDOCS 8301030176
Download: ML20070L549 (6)

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UNITED STATES OF AMERICA NUCLEAR RE ULATORY COMMISSION CXKETO

,999 Y BEFORE THE nTOMIC SAFETY AND LICENSING BQARD ot EC 30 A11:39

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In the Matter of ~

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CONSOLIDATED EDIS0N COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2)

) 50-286 SP

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POWER AUTHORITY OF THE STATE OF NEW YORK )

(Indian Point Unit 3) ) December 22, 1982 PARENTS CONCERNED ABOUT INDIAN--PCINT RESPONSE TO LICENSEES' FIRST SET OF INTERROGATORIES AND DOCUMENT REQUEST UNDER COMMISSION QUESTION 6 INTERROGATOR,Y #12 Define what you mean by " physical environment.

RESPONSE

" Physical environment" meaLa the comb'inatioh 6'f extefnal or' .1 extrinsic conditions that affect the bodily or material growtli and development of organisms. _

~ IN,TERROGATORY #13 '

State the grounds for the statement that the workers in4 +

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plant are exposed to unacceptable levels of radiation.

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RESPONSE

Newspaper accounts of ac,tions and' statements by Indian' Point worker's and NRC enforcement actions. '.

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INTERROGATORY #14 Identify environments or conditions that ~~

are used as reference points for the assertion in~ Inteltogatory Number 13.

RESPONSE ,

Radioactive water in the storage- pool; ' contaminated rags, tools, and other solid waste; radioactive dust; violation of safety procedures during maintenance work; broken and otherwise faulty monitoring devices; a practice of minimizing information to workers on the effects of radia-tion; large numbers of repairs required on radioactive equipment; hand- ,

ling radioactive material without proper protective gea'r; pressure on r301030176 821222 DR ADOCK 05000

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workers tua reduce the amount of time spent on refueling ~ outages; inadequate maintenance of of employee health reco.rds; failure to continuously monitor workers' radiation exposure.

INTERROGATORY #15 Identify and provide all documents that report on the impa:t of a. nuclear plant on the physical environment of children.i

RESPONSE

Parents knows of no such documents. , In its Response to Licensees' First Set of Interrogatories and Document Requests Under Commission Question 11to . . . -Parents , served on July 23, 1982, Parents identified documents that report on the impact of radiation on children.

INTERROGATORY #16 With regard to the physical environment of adults and children, state how living near the Indian Point site compares with living near other industrial facili_ ties (e.g. , chemical plants, fiberglass f actories) . Identify t

the health effects associated with the routine operation of!

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all of the above facilities. Identify all those effects

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that you regard as acceptable.

RESPONSE --

Parents Objects to this interrogatory as irrelevant and_ burdensome.

- INTERROGATORY #17 -

ith regard to the physical environment of adults and children, identify and ptate how the health effects from living near the India,n Point site compare with he health effects of living near other power-generat-in,g cfa'ilities including, but not limited to, (a) coal-fired plants, (b) oil-fired plants, (c) hydroelectric; windmills, (e) solar systems, (f) cogeneration plants, and ptations. (d)

g) biomass conversion plants. Identify the health effects associated with the!

outine operation of all ,he t abov; facilities. Identify all those" effects

!that you regard as acceptable.

RESPONSE

Parents objects to this interrogatory as irrelevant and burdensome.

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INTERROGATORY #18 Compare the physical environment of childre'n li.ving in the vicinity of nuclear plants to that of children who do not live in the vicinity of a nuclear plant. Provide all documents which substantiate _your answer. ,

RESPONSE <

The physical-environE$nt of children living in the vicinity of nuclear plants contains more, radioactivity than the environment of children who do not. This answer is based on commun sense: Nuclear plants, in particular Indian Point, vent radioactive material daily, some of which is long-lixed radioisotopes which accumulate in the environment.

INTERROGATORY #19 -

State the grounds for the statement that "the workers are at risk of disease and genetic damage to"their offspring".

RESPONSE Provide all documents that substantiate your' answer. '

Workers at Indian Point are allowed to receive doses ten times higher than the maximum allowable exposure for members of the general public. Documents noted by Parents in the Response served by Parents.on July-23, 1982, report on diseases and genetic damage asso-ciated with exposure to radiation. Radiation effects are cumulative and there is no iafe threshold dose below which no effects are noticed.

r INTERROGA'IORY #20 -

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Define the age bracket that you associate with being considered a child.

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RESPONSE

A child is a person from birth to physical' maturity.

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INTERROGATORY #21 I,dentify the differences ^in health effects from the years of the construction permit grant or reviews. Identify studies which have been done on the subject of the-heelth effects of living near a nuclear plant. Identify such studies which have been done on the Indian Point site in particular. ,

RESPONSE

This interrogatory should be addresse,1 to the New York State

e A-Department of Health and the Departments of Health in each of the ~

four counties surrounding Indian Point and other. counties downwind of Indian Point. 'When Parents discovers any such studies, it will inform the licensees. Because of the minimal latency periods for solid tumors and leukemia, these health effects may be starting tc show up only now from the operation of Indian Point.

INTERROGATORY #121 Identify: _,

(a) each person whom you expect to call as a witness

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at the evidentiary hearings relating to Commission Question ,

6 (including, without limitation, each such person's full name, present address, present employment or other professional affiliation, aad qualifications) and annex a copy of said person's resume and list all his publications; (b) the subject matter and Board contention and -

underlying intervenor contention on which the witness is -

expected to testify; (c) the substance of the facts and opinions to which the witness is expected to testify and a summary of the

. grounds for each opinion;

f. (d) each document (including, without limitation,_each j treatise, book bulletin, accounting i.nterpretation, l

regulation, report, article, or other literature or writing) upon which the witness has based his' testimony, or -

will so rely at the hearing, or will otherwise refer to in support of his testimony; (e) any relationship between the witness and any

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intervenor or party herein; and (f) any proceeding in which the witness has previously ,

testified and the transcript pages of such testimony (you should annex the transcript pages,to your response). j

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RESPONSE

The response to this interrogatory will be served at a later date.

INTERROGATORY #122 Identify all communications, written or oral, with federal, state, county, or local government of-ficials, pon which u rely in responding to ay interrogatories.

RESPONSE _

None.

INTERROGATORY #123 Identify and provide all contracts and communications, written or oral, with consultants, contractors, employees or others upon whose testimony, written or oral, you rely

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RESPONSE in responding to any interrogatorids.

None. -

Respectfully submitted, a

CERTIFICATE OF SERVICE o a ents Conger d About Indian Point I hereby certify that copies of this document have been served- by hand to the New York offices of the l'icen see s ' attorneys and mailed to

, , the rest of the minimal service list -

on December 23, 1982.

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SERVICE LIST e

Spense W. Perry Office of Genc.rsl Cbunsel ,

. mm Atomic Safety and Li:ensing Board 500 C Street SW U.S. Nuclear Regulatory Ccannission Washington, D.C. 20472

• Washington, D.C. 20555 M3. Janice Moore Stewart M. Glass Office of Executive Atomic Safety and Licensing Appeal. fegional axnsel Icgal Director Board rm Nuclcar Regulatory Casn Watington, D.C. 20555 U.S. Nuclear Reg'?latory Cec: mission 26 ftdcral Plaza Fm 1349 Washington, D.C. 20555 N W York City 10278 Docketing and Service Section Steve Sholly Stanley B. Klimber6 Office of the Secreta *y #

G:naral Counsel U.S. Nuclear Regulatory Ccznmission 1346 (bnnecticut Ave tM i N:w York State Washington, D.C. 20555 Suite 1101 i Encr6y Office Washington, DC 20036

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2 Rsekefeller State Plaza J e s P. Glaa "

Jeffrey M. Blum, Esq.

M bany. NY 12223 New York University Law School Atomic Safety and Licensing Board 423 Vanderbilt Hall 513 Gilnore Drive 40 Washington Square Sou*.h D nald Davidoff Silver Spring, tti 20901 New York, NY 10012 Dir*ctor, REPG Empire State Plaza Dr. Oscar H. Paris Zipporah S. Fleisher l T; war Bldg Rm 1750 Administrative Judge West Branch Conservation Albany, NY 12237 Atomic Safety and Licensing Board Association U.S. Nuclear Regulatory Cc= mission 443 Suena Vista Road Washington, D.C. 20555 New City, W 10H 6 Nxw York City Council _.

c/o National Emersency Mr. Frederick J. Shen Judith Kahsler, Coordinator Civil Liberties Committee Administrative Judge 175 Pifth Ave, Suite 712 Rockland *.itizens for Safe Energv ~

Atomic Safety and Licensing Board N:w Drk City 10010 U.S. Nuclear Regulatory Commission 300 New hempstead Road AT*N: Criig Kaplan Washington, D.C. 20555 New City, NY 10956 Ruthanne Miller, Esq. 15 rent L. Brandenburg, Esq. Charles A. Scheiner, Assistant General Counsel vo-Chairperson Ltw clerk. AS & LB Consolidated Edison Company of WestcW ster Pebple's Action U.S. N.R.C. New York, Inc. Coalition, Inc.

Washington, D.C. 20555 4 Irving Place P.O. Box 488 New York,!q 10v03 White Plains, NY 10602 Charlos J. Maikish, Esq. .

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Litigetion Division Lorna Salzman The Port Authority of Paul F. Colarulli, Esq. Mid-Atlantic Representative Nzw York and New Jersey Joseph J. Levin, Jr., Esq. Friends of the Earth, Inc.

Ons-World Trade Center. Pamela S,, Horowitz, Esq. 208 West 13th Street N w York, NY 10048 Charles Morgan, Jr., Esq. New York, NY 10011 Morgan Associates, Chartered Ezra I. -Bia$.ik, Esq. 1899 L St#*et, N.W*

- Eric Thorsen, Esq. '

Stave Leipsis, Esq. Washington; D.C. 20036 , County Attorney, County of Environmental Protect 3cn Bureau -. Rockland ,

New York State Attorney Charles M. Pratt 11 New Hempstead Road

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Gantral's Office. Stephen L. Baum '

New City, NY 10956 8 Two World Trade Center .PASNY New York, NY 10047 10 Columbus Circle Geoffrey Cobb Ryan New York, NY 10019 Conservation Committee Alfred B. Del Bello . Chairman, Director Wastehtster Coun{y Executive New York City Audubon Society Westchsster County David H. Pikus, Esq. 71 West 23rd Street, Suite 1828 14 8 Martin Avenue Richard F. Czaja, Esq. gew York, NY 10310 Whito Plains, NY 10601 330 Madison Avenue New York, NY 10017 Greater New York Council on Andrsw S. Roffe, Esc- Energy Nsw York State Assembly Ellyn R. Weiss, Esq. c/o Dean R. Corren, Director Albany, NY 11248 William S. Jordan , III, Esq. New York University Harmon & Weiss 26 Stuyvesant Street Renes Swartz, Esq. 1725 I Street, N.W., Suite 506 New York, NY 10003 Botsin, Hays, Sklar & Herzberg Washington D.C. 20006 - ~ *

• Attorneys for Metropolitan Honorable Richard L. Brodsky Transporation Authority Joan Holt, Project Cirector Member of the County 1,egisla nre 200 Park Avenue Indian Point Project Westchester County Nsw York, NY 10166 New York Public Interest County Office Bailding Research Group White Plains, NY 10601 Honorable Ruth Messinger 9 Pt:rray Street Membar of the Council of the New York, NY 10007 Mayor City of New York Village of Buchanan.

District 64 Amanda Potterfield . 236 Tate Avenue City Hall Johnson aad George Buchanan, KY 10511 NIw York, NY 100,07 528 Iowa Avenue

Iowa Cisy, Iowa 522 40

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