ML20053E569

Answers & Objections to 820501 Interrogatories.Related Correspondence

ML20053E569
Person / Time
Site:	Indian Point
Issue date:	06/02/1982
From:	Feinberg J NEW YORK, STATE OF
To:	FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY
Shared Package
ML20053E570	List: ML20053E569 ML20053E574
References
ISSUANCES-SP, NUDOCS 8206090028
Download: ML20053E569 (12)

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' RELATED CORRESPONDR5try UNITED STATES OF AMERI @ . , .. y NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICEMSING BOARD -

12 J2;-7 N0:13 In the Matter of -

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CONSOLIDATED EDISON COMPANY ) IU -Mi!M i OF NEW YORK (Indian Point, Unit 2) Docket Nos. 50-247-SP

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

NEW YORK (Indian Point,- Unit 3 )

June 2,1982 ANSWERS AND OBJECTIONS TO INTERROGATORIES AND DOCUMENT REQUESTS PROPOUNDED BY FOE /AUDOBON TO THE

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STATE OF NEW YORK  ;

1 On,May 1, Friends of the Earth /New York City Audobon Society (FOE /AUDOBON) mailed interrogatories directed to the State of New York. The State of New York hereby responds with its answers to the in'cerrogatories and document requests propounded by FOE /AUDOBON.

It should be emphasized that the State of New York is not a party to this proceeding since it is participating as an interested state pursuant to 10 CFR S 2.715(c). Interrogatories such as those served upon the State of New York can be filed by parties on parties under S2.7406. The production of documents can only be requested by parties from parties'under' S2.141. The State is not a party and therefore is not bound to answer these discovery requests. However the State recognizes that it should, as part of the exercise of its emergency planning function 1Dk participate in this preceeding and cooperate with reasonable

! inquiries related to emergency planning. The State therefore I

responds below to FOE /AUDOBON's interrogatories and document 82060900aB B20602 PDR ADDCK 05000247 U PDR

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, , requests. By responding, the state does not relinquish any protection against discovery it.has as an " interested state'- in 3 1 i

this or other contexts, such as access to state facilities during emergency exercises. All answers were prepared by Donald Davidoff and an affirmation to that affect is attached.

Respectfully submitted, STANLEY KLIMBERG General Counsel NYS Energy Office

%Jn D. %aq b By JONATHAN D. FEINBERG -

Staff Counsel NYS Department of Public Service

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UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSOLIDATED EDISON COMPANY )

OF NEW YORK (Indian, Point, Unit 2)

) Docket Nos. 50-247-SP POWER F.UTHORITY OF THE STATE OF ) 50-286-SP NEW YORK (Indian Point, Unit 3 )

AFFIDAVIT OF CORRECTNESS OF INTERROGATORIES I, Donald B. Davidoff, Director of the New York State Radiological Emergency Preparedness Group, being duly sworn her,eby swear and affirm that the attached answers to the Interrogatories filed upon the State of New York by Friends of the Earth - Etw York City Audobon Society are true and correct to the best of Lry knowledge and belief.

A' "Sr Dondld /B. David 6ff Sworn to before me this 2nd day of June 1982

/[4 + w , kNAtf Notary Public MARION Z. ZRELAK metery Putu.c. State of New Yort Qualified in Altbony County c2 commtwen Emoires meerch ae. leas

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1. a) Identify by title, author and date of' production all studies, reports, investigations, and other documents produced, consulted or '

commissioned by you with regard to possible damage to or contamination of the following within a fifty mile radius as a result of a nuclear accident at Indian Point:

I. Agricultural soils II. Recreational lands and wildlife areas III. Water supplies, including but not limited to, streams, rivers, reservoirs and wetlands.

IV. Private and public buildings including but not limited to homes, schools, hospitals, places of worship, businesses and factories.

V. Means of transport including but not limited to roads, bridges, tunnels, cars, trucks, trains, railways, ships, ports, airplanes and airports.

VI. Utility systems and fuel supplies.

VII. Crops, livestock, packaged and processed foods.

VIII. Household and consumer goofs including but not limited to clothing, furnishings, appilances' and personal items.

IX. Wildlife b) For each item listed in responst to the request above, please attach a copy if available without charge, or if unavailable, state place and time at which said item may be inspected and copied.

a) The Radiological Emergency Preparedness Group (REPG) has not produced, consulted or commissioned any studies, reports, investigations or other documents pertaining to possible damage to or contamination of any of the 9 specified items in Question #1. The State of New York did produce some studies in the early 60's which are now outdated and were not relied upon in the development of the Plan.

b) No copies are available of the studies referenced above.

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.- 2. a) Identifybytitle,authorandbat~e of production all studies, reports, investigations or other documents known to you, discussing, proposing or furthe.': elaborating upon plans for monitoring the types /

levels and geograph ic extent of radioactive contamination of the materials li1At~ed in Interroga"cory 1(a) above.

. b) For each item listed in ret.onse to request 2(a) above, please attach a copy if available without charge, or if unavailable, state place

and time at which said item may be inspected and copied.

a) Plans for monitoring the types, levels and geographic extent of radioactive contamination of the materials listed in Question 1(a) are discussed in v.trious sections of the New York State Radiological Emergency 1reparedness Plan. More specifically, the State portion of the overall Plan contains two specific ref'erences (Part I,Section III, subsections 5 & 6; Fart III,Section I, Procedure G). The four separate County Plans which are component parts of the overall State Plan also contain references to this question. '(Volume I, Section III-G; Appendix J. Volume II, Sections 3 & 14. Please note that the Section 14' material for Putnam County is contained in Section 13) Development of a list of material bearing upon plans for monitoring of radioactive material would require an extensive search of the voluminous literature on radioactive contamination. No studies or other documents were specifically relied upon in developing the State Plan in regard to radiation monitoring.

b) The referenced Plan material is already in the possession of the Intervenors.

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l 3. a) Describe all medical and scientific procedurea considered or proposed by you or any consultants 'or experts with whom you have  ;

communicated or received information that would be used to treat '

humans who have been exposed to radioactivity or have ingested -

radioactive materials as a result of an accident at Indian Point.

b) Identify specifically the l'ocations, facilities and personnel that would be available for treatment identified in' response to 3(a) and indicate as accurately as possible the. capacity of such facilities.

c) If documents are cited in response to requests 3(a) or 3(b) above, please append a copy of the relevant pages if available without I charge, or provide a concise summary of the pertinent portions of said documents.

a) The New York State Radiological Emergency Preparedness Plan,

. both the State and County portions, contains procedures for the basic decontamination of humans who hr.ve been exposed to or who have ingested radioactive materials. (See the references stated in response to Question #2(a) above.) However, specific medical and scientific procedures to be employed by appropriate facilities are not a part of the Plan in that such procedures are beyond the scope of the emergency plan itself.

b) The following hospitals are capable of treating accident victims with radiation contamination.

Name No. of Beds (1)

Cornwall Hospital -- 120 Laurel Avenue Cornwall, NY 12518 New Rechelle Hospital Medical Center 336 16 Guion Place New Rochelle, NY 10802 Vassar Brothers Hospital 342 28 Reade Place Poughkeepsie, NY 12601 Good Samaritan Hospital of Suffern 296 Suffern, NY 10901 Phelps Memorial Hospital 253 North Tarrytown, NY 10591

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Westchester County Medical Center 380 .

Valhalla, NY 10595 United Hospital ,

332 406 Boston Post Road Port Chester, NY 10573 E.A. Horton Hospital 297 60 Prospect Avenue Middletown, NY 10940 ,

Arden Hill 123 Harriman Drive Goshen, NY 10924

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Information about the personnel available for decontamination should be obtained from the hospitals. -

(1) Number of Beds is total number of certified beds, not only for contaminated patients. The capability of a hospital to decontaminate persons at any one time should be obtained from the hospital.

c) Not applicable

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P 4. a) Describe all procedures that you or any experts with whom you have communicated have. considered or proposed with regard to the .

decontamination of each of the materials listed in Interrogatory 1(a) above.

b) Identify specifically the equipment that would be available and the personnel that would be responsible for carrying out procedures described in the response 4(a) above.

d) If documents are cited in response to requests 4 (a) or 4 (b) above, please append a copy.of the relevant pages if available without charge, or provide a concise summary of the pertinent portions of said documents.

a) The State has not developed specific decontamination procedures.

The need for decontamination and therefore the methods and degree of decontamination will vary greatly depending on the assumed level of contamination and the structures, items, and portions of the environment involved. For certain contaminated areas, it is presumed that disbursement

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and removal by natural environmental and decay processes will be sufficient.

b) Since there are no specific procedures for decontamination, the equipment and personnel used for decontamination cannot be identified.

c) Not applicable.

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5 a) Identify the location, size and nature of all sites considered or ornnosed by you or any experts with whom you have communicated for he use of storage or disposal of materials contaminated as a result of an accident at Indian Point.

b) Describe specifically any plans within your knowledge or under consideration by you or your consultants with regard to:

I. Transport of contaminat'ed materials to the sites.

II. Types of structures,that would be used for the containment of contaminated materials.

III. Care and maintenance of the sites.

c) If documents are cited in response to 5(a) or 5 (b) above, please append a copy of the relevant pages if available without charge, or provide a concise summary of the pertinent portions of

. said documents.

a) Contaminated materials will be disposed of or stored at only the facilities licensed by appropriate Federal and/or State agencies for this purpose. The State would obtain information about the appropriate sites from the NRC when necessary.

b) These three items are covered by applicable NRC, DOT or New York State DOT regulations. .

c) Not applicable.

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6. a) Describe all estimates within pur knowledge of the time that would be required to decontaminate radioactive objects and sites J sufficiently to resume normal use and access by human beings without

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b) If' estimates cited in response to request 6(a) above are based upon any studies, reports, investigations or other documents , please ,

append a copy of the relevant pages, or provide a concise summary of i the pertinent portions of said documents.

a) The State has no generic time estimates for the.

decontamination of radioactive objects and sites so as to permit the resumption of normal use of those sites under acceptable health and safety standards. The time required to reduce contamination to acceptable levels is site and incident specific. Health and safety criteria come first. It is the State's intention to take as much time as is needed before permitting the resumption of normal use after an accident which results in contamination. We question the value of even hazarding a guess about time estimates.

i b) None J

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7. a) Identify by title, author and date of production all studies, reports, investigations, and other documents produced, consulted or commissioned by you with regard to:

I. The difficulties of ' emergency evacuation posed by the existing network of roadways in Westchester and Rockland Counties.

II. The possibilities of mitigating these difficulties by expanding, improving or upgrading roadways.

b) For each item listed in response to request 7(a) above, please attach a copy if available without charge, or if unavailable, state place and time at which said item may be inspected and copied.

c) For each item listed in response to request 7(a) above, state specifically the page numbers where said dif ficulties and possibilities are discussed.

a) Evacuation time estimates were prepared by Parsons, Brinckerhoff, Quade & Douglas, Inc. The estimates took into account the existing roadway network. The referenced material was reviewed by evacuation experts from the New York State Department of Transportaion who ultimately concurred in the findings of the Parsons study, b) Not applicable.

c) Not applicable.

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8. a) Identify by name any witnesses you plan to have testify at the hearings with regard to any aspect of onsite or offsite emergency' planning procedures, or any other matter pertinent to Commission Questions 3 or 4. ,

b) Provide the following information with regard to the' witnesses identified in 8(a) above: ,

I. Address II. Occupational title '

III. Place of employment IV. Business address and telephone V. Times within your knowledge at which said witnesses will be available for deposition.

c) State briefly the matters about which each witness identified in request 8 (a) is expected to testify.

SCOPE OF ADDRESS & PHONE TITLE EXPERTISE TESTIMONY NAME ESP Tower Bldg, Director Emer. Planning- State Plan-Donald B. Davidoff Rm. 1750, Albany, Public Health Site Specifi (518) 473-3394 ESP Tower Bldg, Chief, Emer. Planning- Local Plans Lawrence B. Czech & Radiolo-Rm. 1750, Albany, Nuclear Radiological (518) 473-3393 Protection Health gical healt aspects If necessary, the State's witnesses are available for deposition in Albany, New York during normal working hours at mutually-agreeable times dictated by the press of other business.

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