ML20028B298

Replies to 820718 Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20028B298
Person / Time
Site:	Indian Point
Issue date:	11/24/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20028B297	List: ML20028B296 ML20028B298
References
ISSUANCES-SP, NUDOCS 8211300263
Download: ML20028B298 (6)

Text

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' U-UNITED STATES OF AMERICA ' '5IU

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NUCUE.AR REGULATORY COMMISSION ATOMIC SAFITY AND UCENSING BCAAD '82 fi0V29 A10:10 Administrative Judges: .

as w. . .

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James Gleason d /.C

- Dr. Oscar Paris l'.. Chairman -

In the Mattar of Frederick 3. Shon CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 30-247-SP Undlan Point, Unit 2) 30-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK November 24, 1982 Undian Po. int, Unit 3) . .

WEST BRANCH CONSERVATION ASSOCIATION'S REPLIES TO LICENSEES' INTERROGATORIES DATED JULY 18, 1982' The Licensing Board's Order of November 15 was received by WBCA at 4 P.M. on Friday the 19th. We did not prepara our replies because we did not know what contentions we would respond to until we received the Order. We are en-deavoring to submit this and other papers as soon there-after as is possible. We do not own a copying machine and are at the mercy of the local services.

No. 24 For the present, pending study of the IPPSS, the 21 plant damage states listed in Table 5.2-1 (Review and Evalu-ation of the Zion Probabilistic Safety Study, dated March 5, 1982 by Sandia National Laboratories. Copies of this Study are in the possession of the Licensees per the distribution for West Branch Conservation Association 443 Buena Vista Road -

New City, N.Y. b b,.d> < b 914/634-2327 'g(ZipporahS. Fleisher .

Secretary

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8211300'263' B21124 ~

PDR ADOCK 05000247 O PDR

list accompanying the Study,) will serve as a base.

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The probabilities given by Sandia in Table 5.2-1, for the present, can serve as an upper bound. We stopped all work when so directed by the Board by telegram of July

29. Now we are given no time to resume work but rather an impossible deadline in hand date for the day we received the notice. We will study the IPPSS and the peer review to further refine our position.

No. 25a The " cooling system" referred to by the ASLB in contention 2.2a) is the containment building f an coolers with the related piping, pumps, ductwork and other compo-i nents that make .an operable system.

No. 25b, e and d and 26 These questions apply to contention 2.2d) which has been recoved from case.by Order of November 15.

No. 27 - moot by Order of November 15 removing 2.2c).

No. 28 - As presently written 2.2b) is not our contention, and 2.2c) has been removed from the case.

No. 29 - moot by Order of November 15 removing 2.2c).

No. 30 We have made no independent study. We expect the study being conducted by Con-Ed, per letter to NRC l

by John D. O'Toole dated January 27, 1981 will provide information on this subject.

No. 31 - moot by removal of 2.2d). -

No. 32

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There are only two locations where brackish water is used inside containment, Indian Point and Oyster Creek.

No. 33 There is no reason to believe that the joints in the system will not corrode. If there have been any studies or modifications we have not heard of them. Since all in-terrogatories on these questions are now barred,only where piping has been replaced gives us our contention.

No.34, 35 and 36 - moot by removal of 2.2b0 c0 and dO.

No. 37 and 38 The New York State Public Service Commission, in opinion 82-2'*of January 21, 1982, on page 85, bottom para-

! graph stated that' Coned" incurred $33.7 million of excessive fuel adjustment clause charges. . .due to a lack of reasonable care in its operation of the Indian Point No. 2 nuclear generating plant." Also, fines have been levied by the NRC.

i No. 39 PSC Opinion 81-4 of March 12, 1981, page 33 under

" Timing of Decommissioning" lists the year 2006 for I.P. #2, as "the year Indian Point 2 will be dismantled." We have no information about I.P. #3 but it is safe to assume a fear or two later is projected.

No. 40 and 41, moot (2.2b)

No. 42 and 43 - moot (2.2c)

}{o. 44 throuch No. 51 - moot by removal of 2.2d .

No. G2

a. Walter L. Fleisher, 443 Buena Vista Road, New City, N.Y. 10956, Vice-President, West Branch Conser-vation Association.

b. Resund was sent with application to inspect i station #3, June 11,1982, to all parties'. Resund will also accompany Mr. Fleisher's testimony. If you cannot locate your copy we will send you another on request.

c. Mr. Fleisher will testify on contention 2.2a.

d. Mr. Fleisher will relate his experiences with the use of brackish water from the Hudson River.

e. Attached is an addendum to the resumd sent previously which answers this interrogatory.

No. 53 N'o other persons.

No. 54 through 59 - not WBCA contentions.

j CERTIFICATION STATE OF NEW YORK ) 8* **

COUNTY OF ROCKLAND) t I, Walter Fleisher being duly sworn, depose and say:

! That I am Vice-President of the West' Branch Conserva-tion Association, Inc., and that I am authorized to make this certification on behalf of the corporation; and that the fore-going answers to the interrogatories of the Licensees of July 18, 1982, were prepared under my direction and supervision and are true and correct to the best of m knovrledge and belief.

$ _2 w Sworn before me this 24th day of November, 1982. JAcos J. re uMG-Mot 3:HG NOTARY FUBUC, State of New York .

, No. 44 6138730 i Qualified in Rockicnd Co ety

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N isl'on N s)Ic~rc.Yo. $h q Hotary Public _4

WALTER L. FLEISHER ADDENDUM TO PROFESSIONAL RESUME 1982 PROVIDING ENVIRONMENTAL AND CIVIL ACTIVITIES Rockland County Environmental Management Council Member of Study group for the creation of an EMC.for Rockland County. . , ,

Member and Vice Chair person 1973-1977 Representative from EMC and Chairman of Rockland County Water Rources Study Co'amLittee.

Reappointed for 2 year terms in 1979 and 1981.

Have served on many special committees of the Rockland County Legislature and currently a member of a Special Committee to review Spring Valley Water Company's rate structure.

West Branch Conservation Association 1971 to present a member of the Board of Directors and Vice President involved in activities leading to the County's acquisition of Butter Milk Falls Park, the Perry Property and South Mountain Park.

Major contributor in Clarkstown's acquisition of the Davenport Preserve.

Appeared for the WBCA as an active intervenior and/or witness before the Public Service Commission in Orange and Rockland Utilitie rate taken in 1975, 1977, 1979 and 1981; Spring Valley Water Company in 1975, 1977, 1979 and 1981; and the Electric Utilities long range planning under Section 149b in 1974, 1975,'1976, 1977, 1978 and 1979.

Active in zoning, sewer planning, drainage prob.iams and related matters too numerous to list.

Also a member of the Rockland County Conservation Association, R0ckland County Historical Society, Scenic Hudson and Congressman Be.tjamin Gilman's environmental advisory committee.

" " " ^

UNITED STATES OF AMERICA c.3 NUC:. EAR REGULATORY COMMISSION $,h[._.!

ATOMIC SAFETY AND LICENSING 80ARD 8efore Administrative Judges: .~09

. James Gleason, Chairman

• J Frederick J. Shon i In the Matter of De. Oscar H. Paris E 2.';s. .. : .:. c

) idCh CONSOLIDATED EDISON COMPANY OF )

NEW YORK, INC. (Indian Point, )

Unit No. 2) ) Docket Nos. 50-247-SP ,

) 50-286-SP POWER AUTHORITY.0F THE STATE OF ) Nov. 24, 1982 NEW YORX, (Indian Point, ) - - ~ - ' " -

Unit No. 3) )

CERTIFICATE OF SERVICE

- I-have- this-day-placed - in--the-f-irst-class-mai-1s a-- copy- to each---

of the parties listed below WEST BRANCH CONSERVATION ASSN.'S REPLY TO LICENSEES INTERROGATORIES ON QUESTION 2, REQUEST FOR PERMISSION FOR LATE REPLY and REQUEST FOR RECONSIDERATION OF 2.2(d) AND REJECTION OF 2.2(b).

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