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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
' 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 -
) /Y/2
.;: . - r u. :-jj ;; .
) '
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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