ML20052D148

Wespac Interrogatories Directed to Metropolitan Transporation Authority.Related Correspondence

ML20052D148
Person / Time
Site:	Indian Point
Issue date:	05/03/1982
From:	Scheiner C WESTCHESTER PEOPLES ACTION COALITION, INC.
To:	METROPOLITAN TRANSPORTATION AUTHORITY NEW YORK
References
EP, ISSUANCES-SP, NUDOCS 8205060314
Download: ML20052D148 (3)

Text

BJMATED CORRESPONDENCF NN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION __ _.

,i ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: '82 g ;y 5 m u d'>

Louis J. Carter, Chairman Mr. Frederick J. Shon ,.. ~ ~ c, Dr. Oscar H. Paris Ti; }

In the Matter of  !

' Consolidated Edison Company of  ! Docket Numbers50-247SP New York (Indian Point Unit 2)  !50-286SP Power Authority of the State of  ! May 3, 1982 New York (Indian Point Unit 3)  !

N WESPAC'S INTERROGATORIES FOR j[/

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On April 23, 1982 the Atomic Safety and Licensing oard] issued a

. Memorandum and Order Formulating Contentions, Assigning Intervenors, and Setting a Schedule for the above-captioned proceeding. The Board ordered that formal discovery was to begin on April 26, and that all interroga-tories on " matters under Commission Questions 3 and 4" be filed by May 3, although " discovery on matters to be heard later than the week of June 22 shall continue." (Board 4/23 order at 22, footnote 5). WESPAC received this order un the evening of April 28, two working days before the filing deadline.

WESPAC hereby requests that the Metropolitan Transportation Authority answer each of the following interrogatories in accordance with the foregoing and in line with the Federal Rules of Civil Procedure as soon as possible, but in no event later than May 31, 1982.

1. List any transportation facilities (including railroads, automobile t)$O3 roads, highways, bridges, tunnels, or other parts of a road network) under the jurisdiction of the MTA that are wholly or partly wi. thin /6 Westchester or Putnam County. Where facilities are run by other agencies (such as Conrail) but are related to the MTA, include them.

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WESPAC INTERROGATORIES FOR METROPOLITAN TRANSPORTATION AUTHORITY PAGE 2

2. Indicate which, if any, of the items listed in (1) are within the currently-defined Emergency Planning Zone for Indian Point.

3. Indicate which, if any, of the items listed in (1) are involved in any of the evacuation routes for the Indian Point Radiological Emergency Plan.

4. Supply copies of any reports, telephone calls, memoranda, or other comunication between the Metropolitan Transportation Authority and PASNY, con Edison, the Four-County Nuclear Safety Committee, or the two consultants (Parsons, Brinkerhoff, Quade, & Douglas and EDS Nuclear) relative to the use of MTA facilities in the offsite emergency plan. Such reports should include at minimum the following:

(i) Any information requested as to road capacity, traffic control personnel, and other transportation network data, whether or not the MTA was able to supply it, and the MTA's response.

(iii) The requirements for MTA personnal to participate in emergency response.

(iv) Training of MTA personnel as to their roles in emergency response to an Indian Point accident.

6. Please list all closings or delays in the MTA facilities listed in (2) or (3) due to construction, breakdowns, labor actions, operator error, or adverse weather for the past five years. Include the cause, ef'ect, and duration of the disruption of service. Indicate what steps were taken to compensate. If the records are available, list all such closings since 1962, the year Indian Point Unit 1 began operation.

8. Is the Metropolitan Transportation Authority confident that the transportation facilities it is involved with would perform satisfac-torily in the event of an accident at Indian Point? If not, what improvement would the MTA like to see?

r V . ~* WESPAC INTERROGATORIES FOR METROPOLITAN TRANSPORTATION AUTHORITY PAGE 3  ;

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Respectfully Submitted, 1

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Charles A. Scheiner Co-Chairperson Westchester People's Action Coalition, Inc.

P.O. Box 488 White Plains, New York 10606 914/682-0488 May 3, 1982 ,

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