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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
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l A
UNITED STATES OF AMERICA NUCLEARREGULATORYCOMMISSIO3E(k50 Bl: FORE THE ATOMIC SAFETY AND LICENSING BOARD
'82 EC 30 A11:44 In the Matter of ,
fr CONSOLIDATED EDISON COMPANY OF NEW YORK D cket Nos. 50-247-SP (Indian Point Unit 2) 50-286-SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK 24 December 1982 (Indian Point Unit 3) 4 UCS/NYPIRG SUPPLEMENTAL RESPONSE TO 8 LICENSEES' FIRST SET OF INTERROGATORIES UNDER COMMISSION QUESTION ONE Introduction On June 16, 1982, conholidated Edison Company of New York, Inc., and the Power Authority of the State of New York ("the n.
Licensees") filed " LICENSEES' FIRST SET OF INTERROGATORIES AND DOCUMENT REQUESTS UNDER COMMISSION QUESTION 1 TO UNION OF CONCERNED SCIENTISTS /NEW YORK PUBLIC INTEREST RESEARCH GROUP, a
INC., FRIENDS OF THE EARTH, INC., NEW YORK CITY AUDUBON SOCIETY, AND PARENTS CONCERNED ABOUT INDIAN POINT". UCS/NYPIRG responded to this filing on July 23, 1982. Pursuant to discussions between counsel for the Licensees and counsel for UCS/NYPIRG, it was agreed that answers to the following interrogatories from Licensees' first set on Commission Question one would be supplemented to
! the extent possible: 2, 4, 5, 9, 10, 22, 28, 41, 43, 47, 48, 49, 50, 53, 55, 56, 71, 72, 75, and 78. Supplemental responses are b
8301030175 821224 - I gDRADOCK05000 g
9 provided below. A signed and notarized affidavit will be supplied as soon as possible; an unsigned copy is affixed in order that the Licensees may know the identity of the preparer.
Supplemental Response to #2 Licensees are already in receipt from the NRC Staff of copies of the Sandia National Laboratories' " draft" review of IPPSS, Qated August 25, 1982; in addition, Licensees participated in a meeting with the NRC Staff and representatives from Sandia to discuss the " draft" review.
UCS/NYPIRG witness Robert Weatherwax is reviewing the IPPSS study; he has not completed this review, nor has any written evaluation been geherated as of this date. UCS. Technical Research Associate Steven Sholly has reviewed portions of the IPPSS; no written documents document this review, other than marginal notes. The following specific criticisms of the
,; IPPSS have been identified in this review:
(a) The study appears to ignore pressurized thermal shock as an initiating event leading to core melt; (b) The accident consequences model (CRACIT) appears to have failed to consider the impact of external j events on the alert and notification system (i . e . ,
l sirens and route alerting) and on emergency communications; it would seem probable that any external event such as an earthquake or hurricane with sufficient severity as to initiate a core melt accident would also severely disrupt offsite communications and travel routes, thus presenting considerable difficulties in effectuating any protective actions; as a general indicator, the Reactor Safety Study concluded that an ineffective l
9 I
evacuation would nearly double the number of early fatalities in the most severe accident conditions evaluated in that report; (c) The extensive use of Bayesian probabilistic methodology represents an area of uncertainty which has not yet been fully evaluated; (d) The consequences evaluated do not include property damage, genetic effects, nor societal consequences such as job losses, loss of resources (such as water supplies or facilities such as West Point);
thus, the full societal impact of core melt accidents with releases to radioactivity to the environment are not evaluated in the IPPSS and, therefore,
- e. risk is not fully evaluated; (e) The IPPSS assumes no acts of malevolence (sabotagel v' as accident initiators, thus introducing what may be a substantial uncertainty in the estimates'of risk; Indian Point may be a more visible and attractive target for sabotage due to the proximity of the' plant to New York City and the media located there, as well as the stories appearing in the press over the last several years regarding problems with the security forcg; (f) The human errors evaluation in the IPPSS appears to ignore acts of commission in response to core melt accidents; in addition, " latent" errors such as those caused by incorrect or inadequate or unclear emergency procedures are also apparently ignored; (g) The prediction of failure pressure for the containments
- , apparently ignores por sible design, fabrication, or installation flaws, any of which singly or in combination >
could result in a structural weakness which might be j sufficient to result in containment failure at a much lower pressure than postulated in IPPSS; in addition, the IPPSS appears to ignore failures of containment penetration seals as a failure mode; (h) The consequences model accepts the LD-50/60 dose of 510 Rads given in the CRAC model for CRACIT; it is l
probably more realistic to use the " lower bound" level of 340 Rads from WASH-1400's dose-response l
curves given the lack of preparation of the medical l
community to deal with large numbers of radiation
- exposure victims and the problems inherent in i.
readily identifying who has been sufficiently exposed as to benefit from " supportive treatment" which is l
L,.
implicit in the LD-50/60 dose of 510 Rads; and (g) The IPPSS fails to include CCDF curves which makes it difficult to compare the risks with those posed by other reactor-site combinations.
Supplemental Response to f4 UCS/NYPIRG star.ds by its previous response which referred Licensees to the response to Interrogatory #3. We also note, however, that uses of PRA methodology might include determination of risk #reduction (.in a relative sense) of various mitigation features, ranking of safety problems by their relative severity (taking due note of uncertainties), and in comparisons of specific features from plant to plant to ascertain differences in performance.
a g Supplemental Response to #5 As with our prior response, we have generated no such criticisms in the form of written documents. UCS/NYPIRG has y been awaiting the completion of this report (i . e . , the issuance of Volume 21 We now understand from UCS/NYPIRG's deposition of NRC Staff witness James Meyer that Volume 2 may not be completed in time for the Indian Point special investigation.
UCS has filed a Freedom of Information Act request related to Volume 2 of NUREG-0850 and will inform Licensees of any documents produced by the NRC in response to this request.
A principal criticism of Volume 1 of NUREG-0850 is the NRC Staff's apparent plan to propose a system of " heat pipes" as a passive means of removing heat from containment as part of N
N a three-part accident mitigation package which also includes a flooded cavity concept for core retention and igniters for hydrogen gas control. Based on preliminary information about this system, it would appear that the heat pipe concept would involve the necessity for one and probably multiple fresh containment pene-trations in order to implement the concept. Such new penetrations will change the structural nature of the containment, and might do more'-harm than good. Further, there would appear to be some degree of problem with qualifying the heat pipes for the seismic e
events that IPPSS found to dominate risk for the Indian Point reactors, We continue to believe that filtered vented containments or compartment venting systems offer a greater degree of reliability in this regard. b.,
O Supplemental) Response to #9 Licensees have already been provided with this information on December 17, 1982, in the notification of witnesses on Commission Question One.
l Supplemental Response to #10 If this Interrogatory is limited to Commission Question One, there are no additional persons to list in response.
l l
l l
Supplemental Response to #22 The analysis referenced in the original response has not
! been performed. Iti may be that it will not be performed due to k
1
s the tight schedule under which the proceeding is now operating.
UCS/NYPIRG is unaware of any other such evaluation, however, compliance with the Regulatory Guide or an equivalent system would be necessary '.c a showing that the instrumentation provided to operators is sufficient to ensure an adequate response to accidents.
Supplemental Response to #47 "Ch/NYPIRG has performed no such evaluations. As noted y previously, such evaluations have been performed by the NRC Staff using the CRAC code, and an evaluation based on a larger reactor (1120 MWe) has been performed by Sandia National Laboratories using the CRAC2 model Omicrofiche available in NRC's Public Document Room for both studies). The methods and assumptions are detailed in user's guides for the two codes which are available in the NRC's Public Document Room or from UCS, Washington, D.C., office. In addition, evaluation a methods for evaluating the impacts of accidents on job loss and on specific economic subclasses (i.e., various manufacturing and agricultural activities) are detailed in NUREG/CR-2591, available from the NRC's Public Document Room. From discussions with the authors and the NRC technical monitor for the contract, we understand that an evaluation specific to Indian Point has not been performed. Also, considerations related to societal economic and other impacts which are not evaluated in the CRAC or CRAC2 codes are detailed in J.M. Griesmeyerm T.E. McKone, and h
F W.L. Baldewicz, " Management of Potential Resource Losses Due to Nuclear Power Plant Accidents", August 1982, available from Dr. Thomas E. McKone, Advisory Committee on Reactor Safeguards, 1717 H Street, Washington, D.C. 20555. This report notes at page 5 that a potential resource loss for. Indian Point in the event of an "SSTl" release would be the Croton Reservoir, with a capacity of 65.3 billion' gallons of fresh water, which the report notes "provides mucy of the New York City water supply".
Supplemental Response to #48 The NRC's CRAC code evaluation for' Indian Point, which is available in the NRC's Public Document Room in microfiche form, and the Sandia evaluation using CRAC2, sbnilarly available, b
demonstrate the basis for thI's allegation adequately. These evaluations project early fata'lities alone of up to 20,000 or more from especially severe accidents. The problems faced by the medical community would be more severe, however, since more persons than those identified above would require
" supportive treatment" in order to survive, and, in addition, there are no presently available means for rapidly and accurately assessing who among many tens of thousands of persons suffering from radiation-related illnesses have received sufficient exposure to require more than " minimal treatment". This problem will be aggravated by the fact that there are no means by which to assure that all potentially exposed victims proceed to reception centers for monitoring, and
s the fact that persons will be responding to medical facilities for treatment which are not adequately prepared to handle con-tamination or large numbers of exposed persons.
Supplemental Response to #49
- a. Those specified in the CRAC and CRAC2 consequence assessment codes and their respective code descriptions, including Appendix VI of WASH-1400. See, also, J.M. Griesmeyer, et. al., referenced in Supplemental Response to 147.
s.
- b. See Appendix VI of WASH-1400 and J.M. Griesmeyer, et. al.,
referenced in Supplemental Response to #47.
- c. Based on NRC Staff CRAC code results of the number of persons receiving whole-boqy doses of 200 Rems or more, the number could range into the hundreds of thousands for Indian Point.
- d. This number will be a subset of that given in "c" above.
Not all irradiated persons will necessarily be contaminated.
- e. Already answered--see Appendix VI to WASH-1400, w
Supplemental Response to #50 The documents are available in the NRC's Public Document
- Room, except for J.M. Griesmcyer, et. al., which is available l
as noted in Supplemental Response to 547.
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Supplemental Response to #53 This allegation is also based in part on the limited liquid pathway analysis presented in NUREG-0850, Vol. 1. The detailed I
r version of this analysis has not been provided to UCS/NYPIRG and is to the best of our knowledge not yet published.
Supplemental Response to #55 As noted elsewhere in this response, the methodology exists to perform such studies, but so such studies have been carried out for Indian. Point. Some of these values Li.e., b and cl may be estimated from the CRAC and CRAC2 results for Indian Point referenced above. Others (e, f, g, and h1 are discussed in R J.M. .Griesmeter, et. al., in a generic sense and to a limited extent specific to Indian Point. Regarding item d, see NUREG/CR 2723, a draft Sandia report which details calculations of health-related costs; UCS/NYPIRG does not necessarily endorse this methodology, but merely brings it to the Licensees' attention as a possible means of performing such calculations.
Supplemental Response to #56 N Licensees should refer to the source documents for this information (code descriptions for CRAC and CRAC2, WASH-1400 Appendix VI, J.M. Griesmeyer, et. al., draft NUREG/CR-2723, and NUREG/CR-2591).
Supplemental Response to #71 In addition, a principal problem with comparisons of nuclear energy and non-nuclear energy risks are the uncertainties in the risk estimates. See, DOE-EV-0109, P.W. House, et. al.,
" Comparing Energy Technology Alternatives from an Environmental g
l Perspective", U.S. Department of Energy, February 1981 Supplemental Response to #72 Listed in Supplemental Response to #71. See, also, William W. Lowrance, On Acceptable Risk.
Supplemental Response to #75 In gddition, unless identical: methods, data bases (where applicablel, and assumptions are used for both studies for a
which a comparison is attempted, the comparison is very sensitive to these factors. These differences can completely dominate the comparison if significant. For example, the IREP reports contain a speckfic caution not to compare the results with WASH-1400 due to' the use of different methodologies P
and data base (NUREG/CR-2515, SAND 81-7229/1, A. A. Garcia, et. al., " Crystal River-3 Safety Study, Volume I - Main Report",
Science Applications, Inc., for the U.S. Nuclear Regulatory Commission, December 1981, page I-i)_.
o Supplemental Response to #78 In short, the answer is no. Both IPPSS and WASH-1400 fail to address initiating conditions other than full power and normal conditions. Neither study addresses all of the Unresolved Safety Issues. Neither study adequately accounts for actual operational experience with accidents in other facilities. Neither study adequately accounts for human errors, especially latent
_11 errors and errors of commission. Neither study considered sabotage adequately. Neither study adequately addressed design, fabrication, or installation errors. The accuracy of such studies in an absolute sense is open to serious question and large uncertainties. Other risk studies have not been reviewed in sufficient detail to permit a response, nor are other risk studies necessarily relevant to the risk posed by Indian Point.
Supplemental Response to #28 Upon reflection, UCS/NYPIRG has nothing to add to the earlier response.
b Supplemental Response to #41' Additional information regarding probabilities of PWR-2 releases can now be found in NUREG/CR-2239, which includes a " generic" estimate of the probability for an SST1 release, which includes PWR-2.
Supplemental Response to #43 i
! Contamination is defined as the excess amount of radioactivity
{
present above background levels for the area.
DATED: 24 December 1982 RESPECTFULLY SUBMITTED, cm s. L /g C4f EMMY (/1. Blum, Esq./
Counsel for UCS I
i,
l l
l l
VERIFICATION DISTRICT OF COLUMBIA ) :S.:
l I, STEVEN C. SHOLLY, being duly sworn, depose and say:
That I am Technical Research Associate for the Union of Concerned Scientists; that I am authorized to make this verification on behalf of UCS/NYPIRG; and that the foregoing answers to Interrogatories were prepared under my direction and supervision and are true and correct to the best of my knowledge, information, and belief.
L.
Steven C. Sholly 'N Sworn to before me this b day of December 1982 Notary Public My Coramissbn optres OctoM 31.1086
.