ML19339C047
| ML19339C047 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 11/06/1980 |
| From: | Copeland J, Raskin D BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Schuessler W AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8011170244 | |
| Download: ML19339C047 (15) | |
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.:.-v==f9H UNITED STATES OF AMERICA 'y v's\
NUCLEAR REGULATORY COMMISSION N - D\ .
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~- .~ -t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.- ?,- --l
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HOUSTON LIGHTING & POWER COMPANY ) Docket No. 50-466 '
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APPLICANT'S RESPONSE TO SCHUESSLER'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Interrogatory 10:
Please provide biographical sketches of expert witnesses Murri and Griffin. What are their particular areas of expertise, and what will their testimony cover?
Response
Current resumes of Messrs. Murri and Griffin are attached.
The testimony of Messrs. Murri and Griffin has not yet been preparad. The testimony wil',1 cover Schuessler's contention on emergency planning.
Interrogatory 11:
Applicant has provided copies of letters of intent from the sheriffs of Austin, Ft. Bend, Waller, Colorado and Wharton counties, and representatives of Polly Ryon and M. D. Anderson hospitals. Letters refer to discussions between themselves and
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representatives of HL&P. Please describe these discussions. When and where-did they take place? Who participated? What was dicussed and agreed, and in what detail? Etc.
Response
Relevant discussions are described as follows:
- 1) Date. February 6, 1980 Place: Austin County Sheriff's Department;. Bellville, Texas pso3 5
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Participants:
R. .Lawhn - HL&P E.J. Compton - HL&P j
W.R. Griffin - HMM, Associates 3
' T.A. Maddox - Sheriff, Austin County The purpose of the meeting'was to discuss with the County Sheriff the requirement to . perform an analysis which estimates evacuation !
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times. Specil.- _tems discussed were:
- the scope of the analysis 1
- typical evacuation procedures in the area
] - past experience with emergencies
- factors that might affect evacuation
- the need to obtain comments from other Sheriffs on the analysis results.
- 2) Date: March 3, 1980 Place: Austin County Sheriff's Department, Bellville, Texas i
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P G.A. Marquardt - HL&P E.L. Murri - NUS T.A. Maddox - Sheriff, Austin County i J. Whitworth - Sheriff,.Waller County L. Hensley - Captain, Wharton County Sheriff's Department V. Steptoe - Sergeant, East Bernard Police
- Department T. Bock - Lieutenant, Fort Bend County Sheriff's Department
- i. Boyd - Lieutenant, Fort Bend County Sheriff's R.
i Department
! The. purpose of the meeting was to discuss the upgrading of preliminary emergency planning. Specific items discussed were:
- the major dif ferences between new NRC requirements and past require. ants ~
- the 10-mile'and 50-mile Emergency Planning Zone concept 1
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- areas.in the 10-mile EPZ-and'any special-characteristics r
that might help or hinder an emergency response effort
- the need for participation in drills, exercises acl training the communications and coordination between the five counties 1
- the_ emergency classification scheme and types of notification to be expected from the plant
- the need to identify principal local response agencies
- the need for_a letter documenting local response agencies
- the need for a letter documenting our discussion. Those present requested HL&P draft a letter for their review.
- what type of emergency planning effort will take place in future years, and the role of the State and Applicant
- the Three Mile. Island accident
- the evacuation time estimate analysis being performed
- 3) Date: March 21, 1980
! Place: Austin County Sheriff's Department, Bellville, Texas
Participants:
R. Lawhn - HL&P I E.J. Compton - HL&P W.R. Griffin - HMM, Associates T.A. Maddox - Sheriff, Austin County i
J. Whitworth - Sheriff, Waller County i G. Mueller - Sheriff, Colorado County J. Broussard - Deputy, Colorado-County Sheriff's
- Department -
L. Hensley - Captain, Wharton County Sheriff's Department The purpose of the meeting was to provide those present with
! preliminary estimates of evacuacion times, obtain comments on the results and assumptions used. The items discussed in the March 3, 4
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1980 meeting were reviewed for the benefit of those who had not been p1==ent at that meeting.
- 4) Date: May 7, 1980 Place: Austin County Sheriff's Department, Bellville, Texas
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P T.A. Maddox - Sheriff, Austin County The purpose of the teeting was to review draf t letters of under-standing / agreec.ent with the Austin County Sheriff.
- 5) Date: May 22, 1980 Place: Fort Bend County Sheriff's Department, Richmond, Texas
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P E. Hurta - Sheriff, Fort Bend County The purpose of the meeting was to review with Sheriff Hurta the
- i. ems discussed in the meetings of March 3 and 21, 1980 and review
- he draft letter of understanding / agreement. The preliminary results of the evacuation time estimate analysis relative to Fort Bend County were reviewed.
- 6) Date: May 30, 1990 Place: Waller County Sheriff's Department, Hempstead, Texas
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P J. Whitworth - Sheriff, Walier County The purpose of the meeting was to review the draft letter of agreement / understanding with Sheriff Whitworth
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P 4
G. Mueller - Sheriff, Colorado Counry The purpose of tr e eceting was to review the draft letter of r
agreement / understanding with Sheriff Mueller.
$ 8) Date: June 19,-1980 Place: Wharton County Sheriff's Department, El Campo, Texas
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P
'L. Hensley - Captain, Wharton County Sheriff's Departn.ent i
l The purpose of the meeting was to review the draft letter of agreement / understanding with Captain Hensley.
- 9) Date: July 7, 1980 Place: Polly-Ryon Hospital, Richmond, Texas
Participants:
R. Lawhn - HL&P E.J. Compton - HL&P H.E. Pinnell - Administrator, Polly-Ryon Hospital !
The purpose of the meeting was to verify that medical treatment l
facilities were still available at Polly-Ryon for the treatment of injuries, including those involving the presence of radioactive contamination, as a result of an accident at the ACNGS. HL&P 1
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requested an updated letter of agreement / understanding from Polly-Ryon Hospital.
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The Applicant is unable to clearly recall details relative to
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discussions with M.D. Anderson Hospital and Tumor Institute that took place in 1974. The purpose of discussions was to ascertain the services available for treatment of significant radioactive
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exposures and uptake of radioactive material.
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Interrogatory 12:
10'CFR Part 50, Appendix E, I. Introduction, states that each applicant for.a construction permit is required by section i
50.34(a) to include-in the PSAR a discussion of preliminary and sets minimum requirements l plans for. coping for~these plans.with emergencies,Please-produce copies of PSAR pages containing l this discussion.
i Response:
Chapter 13 of the Applicant's Preliminary Safety Analysis Report includes a discussion of preliminary plans for coping 1 with emergencies. A copy of the PSAR is maintained at the Houston Public Liorary. A copy will also be made available for your
, inspection and copying at the Applicant's Energy Development Center, 4
12301 Kurland Drive, Houston. Applicant is currently working with consultants to emend its PSAR on emergency planning to conform with the Commission's recently revised regulations governing this area. A copy of this revised discussion will be made available l
when it is completed and submitted to the NRC for regulatory I review.
1 i Interrocatory 13 :
In consideration of possible emergencies at ACNGS, what was the "wors t possible" accident evaluated?
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Response
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- No specific-accident scenario was evaluated in considering cossible emergencies a* the ACNGS. Applicant's emergency plans will be flexible enough to respond to a wide range of emergency
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situations.
it.;errogatory '14 :
What was learned and what changes in plans for.ACNGS have resulted from HL&P's participation in the meeting of March 19, i 1980 conducted by NRC/ FEMA?
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Resconse:
4 HL&P did not participate in. any FEMA /NRC meeting on March.19, 1980 and-is not aware.that any such meeting was
- conducted.
Respectfully submitted, l
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af f-s-OF CF . DEL: Jack R. Newman 4
Robert H. Culp LOWENSTEIN,-NEIGIAN, REIS' David B. Raskin MELMD & TOLL 1025 Connecticut Ave., N.W.
1025 Connecticut Ave., N.W. Washington, D.C. 20036 Washington, D.C. 20036 BARER & BOTTS J. Gregory Copeland C. Thomas Biddle, Jr.
3000 One Shell Plaza Darrell Hancock
! Houston, Texas 77002 3000 One Shell Plaza Houston, Texas 77002 ATTORNilS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY s
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- l STATE OF TEXAS 5 5
COUNTY OF HARRIS f BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally
. appeared Robert W. Lawhn, who upon his oath stated that he has answered Intarrogatory Nos.10,11 and 14 of Houston Lighting & Power Company's Respcnse to Schuessler's Second Set of Interrogatories and Requests for Production of Documents to Houston Lighting & Power Company in his capacity as Snoervising Engineer for Houston Lighting & Power Company, and all staten. ants contained therein are true and correct to the best of his knowledge and belief.
U. e dwT Robert W. Lawhn SUBSCRIBED AND SWCE:4 TO BEFORE ME by the said Robert W. Lawhn
. on this (cTA day of V14 w nelttb , 1980.
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- Notary Public in and for Harris County, Texas De*2C/1 $ 0* .'*<'
Netact P:A::c Ct.L .,t i.r;-
My Commesson Emphes ...O..'.7.'. ......
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ERNEST L, MURRI EDUCATION Idaho State University, B. S., Physics,1959 Vanderbilt University, M. S., Physics,1961 EXPERIENCE NUS CORPORATION,1977-Present
!ndependent Consultant, 1975-1977 Science Applications,Inc., 1974-1975 Consumers Power Company, 1971-1974 Phillips Petreleum, 1964-1971 Consumers Power Company,1961-) 364 NUS - Currently respons;ble for the supervision of the health physics applications group. Pro-vides direction and review of group projects. These include preparation and review of radiological emergency plans, preparation and review of emergency plan implementing procedure evalua-tions of operating health physics and chemistry programs, and training of client person, elin the fields of health physics and chemistry, Has performed in-depth reviews of health physics and chemistry programs at several operating nuclear facilities and audits of management and operational aspects of health physics programs.
Has prepared detailed emergency plans for utility and local response agencies as well as key implementing prccedures for emergency plans.
Acted as health physics support coordinator during the first 3 weeks of the Three Mile Island emergency recovery. During the next 2 months of the long-range recovery, served as onsite health physics technical advisor, independent Consultant - Reviewed, revised, and wrote procedures for health physics, opera-tions, maintenance, engineering, fuel management, procurement, and quality assurance for nuclear utilities. Conducted internal reviews and wrote reports and recommendations to assist utility management evaluate operational compliance witn applicable regulations, standards, procedures, and instructions in each of the above areas.
Science Applications. Inc. - Performed consulting services for nuclear utilities. Evaluated the effectiveness of respiratory protective devices for removal of radioiodine. Analyzed sources of
' ' ' occupational radiation exposures and recommended methods of exposure reduction. Made radioi-odine source-term evaluation studies at several nuclear power plants.
j Consumers Power Company - As Corporate Health Physicist for all Consumers Power nuclear plants, was responsible for health physics work involved with one single-unit boiling-water reactor in operation; one single-unit pressurized-water reactor during construction, startup, modification and operation; one two-unit plant during design. Provided expert testimony at public hearings.
Served as member of Safety Audit and Review Board and was responsible for evaluating specific occurrences and potential problems, and for drding management on technical aspects of nuclear-related activities.
O m Phillips Petroleum - Participated in applied research and development work which included developing analytical techniques for evaluation of loss-of-flow experiments; production ar'd analy-f m sis of very short-lived fission products; and production and analysis of accelerator- and cyclotron-S produced radionuclides. Orepared sources. took field measurements, and analyzed releases of i
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ERNEST L. MURRI Page Two large radioactive sources for the U.S. Atomic Energy Commission (AEC) Cloud Dose Study.
Assisted in the development of nondestructive methods to assay for plutonium, other transuranic radionuclio9s, and waste material from all phases of the nuclear fuel cycle. Acted as health physics consultant to several NRTS facilit.es.
Consumers Power Company - Was finalizing Master's thesis at the NRTS at the time of the SL-1 incident. Remained at NRTS for Consumers during the recovery and cleanup activities following the incident. Organized the health physics program for the Big Rock Point Plant.
Responsibilities included training station personnelin health physics; preparation of radiological emergency plan; and supervision of the health physics group during final construction, startup, and operation. Responsible for the health physics aspects of several major repair jobs, including the use of divers to make underwater repairs inside the irradiated reactor vessel.
. MEMBERSHIP Health Physics Society ,
PUBLICATIONS
" Gamma Rays Following the Decay of Pu-239"(thesis), Bu//. Am. Phys. Soc.,1961.
" Underwater Repair of Irradiated Reactor Vessel,." presented at the Health Physics Society meet-ing, Cincinnati, Ohio,1964. ,
" Decay of in-115m"(coauthor), Nuclear Physics,1967,
" Analysis of Short-Lived Fission Product Gamma-Ray Spectra Using Nal and Ge(Li) Detectors,"
presented at the Health rhysics Society meeting, Houston, Texas,1966.
"The Analysis of Grcss Fission Products Using Ge(Li) Spectrometers," presented at an American Nuclear Society meeting, San Diego, California,1967.
" Assaying of Boron in Nuclear Reactor Fuel Using Co-60 Tagging" (coauthor), presented at American Society of Nondestructive Testing, Cleveland, Ohio,1970.
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" Decay of Ba-141"(coauthor) Nuclear Physics,1968.
" Loft Sampling and Analysis"(coauthor), Phillips Petroleum 100 publication,1966.
"E:emental Determinations in Idaho Wildlife a nd Other Samples"(coauthor),Journalo/theIdaho Academy of Science,1971.
" Methods Utilized to Reduce Radioactive Liquid Discharge"(coauthor), presented at the Health Physics Society meeting, Las Vegas, Nevada,1972.
" Ventilation Systems as Air Cleaning Devices in Nuclear Power Plant-Experience at Palisades" (coauthor), presented at the AEC Air Cleaning Conference, San Francisco, California,1974.
"The Emergency Planning Quandary - A Consultant's View," presented at the Health Physics Society meeting, Seattle, Washington,1980. ,
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- WILLIAM R. GRIFFIN, Esq.
Education 2.0. Law, Suffolk University, 1978 M.S. Environmental Engineering. Northeastern University, 1974 '
B.S.
Civil, Engineering, Georgia Tech., 1970 Summary of Excerience Mr. Griffin has specialized in environmental regulation work since 1970. As a scientist, engineer, manager and attorney, he has been involved in alternative site studies, environmental impact studies, preparation of licensing documents, negotia-tions with state and federal regulatory agencies, preparation and presentation of expert testimony, and other activities associated with managing a major project through the regulatory process. The majority of his experience has involved energy projects, including electric power generation and transmicsion facilities, large industrial boilers and cogenerators, pipelines, offshore oil facilities, waste treatment and disposal facilities, and others. He has been involved in siting and licensing of fossil-fired and nuclear power plants for several electric utilities. He is national chairman of
.ceral Energy Bar Association Environment Ccmmittee.
Professional Exoerience 1979 - HMM Associates. Current projects include Present participation in environmental licensing for a
$250 million paper mill e_xpansion in Alabama, providing legal support in federal hearings for the Pilgrim 2 nuclear project, directing environmental and safety studies for nuclear power plant sites, involvement with hazardous waste regulations and air pollution law, and '
work on natural gas supply and pricing regulation.
1977-1979 Soston Edison Company. Federal Licensing Coordinator. Responsible for obtaining all federal licenses for the proposed Pilgrim 2 project. Responsibilities included development of project licensing strategy, managment of the preparation of licensing documents and expert testimony, acting as company spokesman in negotiations with federal agencies and project general contractor. Environmental and safety related licensing invcived the' Atomic Energy Act, Administrative Procedures Act, Clean Air Act, Clean Water Act, and state public utilities statutes. Also acted as company public spokesman with media and intervenor groups.
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WILLIAM R. GRIFFIN, Esq.
1975-1977 Anderson Nichols, Inc., Boston, MA Project Manager, Environmental Sciences Division.
Responsibilities included negotiations with federal agencies, management of the public meeting process, selection and management of subcontractors, and management of a staf f of engineers, scientists, and planners.
1972-1975 United Engineers and Constructors, Boston. As Project Coordinator, responsibilities included management of licensing and planning projects such as alternative site studies. As Project Licensing Engineer, responsibilities included managing the process for obtaining state permits for nuclear and fossil fueled electric power plants. As. Environmental Scientist, responsi-bilities included evaluation of the environ-mental impact of construction and operation of large industrial facilities.
1970-1972 Commissioned Officer in U.S. Public Health Ser-vice assigned to U.S. Environmental Protection Agency, Winchester, MA. As Environmental Engineer, responsibilities included research and development of methods and devices for environ-mental surveillance at nuclear facilities.
Professional Affiliations Certifications:
Member of the Bar, Massachusetts, since 1978 3
Registered to practice before the U.S. Office of Patent and Trademark, R.M. #P-29,926 EIT, Georgia, since 1970 Legal Organizations:
Federal Energy Bar As'aciation, National Chairman, Environment' Committee American Bar Association Massachusetts Bar Association Boston Bar Association Engineering and Scientific Organizations:
American Association for the Advancement of Science American Society of Civil Engineers Boston Society of Civil Engineers American Nuclear Society Oceanic Society New England Antiquities Research Association i
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p- s WILLIAM R. GRIFFIN, Esq.
Publications Editor: " Annual Report of the Environment Committee",
Federal Energy Bar Association, Energy Law Journal, 1980.
Author:
- Bodk review of A Comoilation of Qualification Considerations for Nuclear Generating Stations, 1978.
Author: " Mineral Resources Extraction from the Sea Floor: Leoal, Political, Social and Technological Problems", 1977.
Author: " Environmental Regulation: An International Perspective", 1977.
l Author: " Jacksonville Electric Authority Proposed Power Plant Sites: Review and Evaluation",
1975. ,
Editor: " Laws, Rules, Regulations and Procedures for Electric Power Plant and Transmission Siting in-New York", 1973-74 Author: " Conceptual Design of a 'ater Treatment System for a Brewery", 1973.
Author: " Observations of Airborne Tritium Waste Discharge from a Nuclear Fuel Reprocessing Plant", 1973.
Author: "A Sampler for Non-Aqueous Tritium", 1973.
i Contributor: "A Study of Severe Vehicular Accidents", 1970. .
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING & POWER COMPANY ) Docket No. 50-466,
)
(Allens Creek Nuclear Generating i Station, . Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of APPLICANT'S RESPONSE TO SCHUESSLER'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS were served on the following by deposit in the United States mail, postage prepaid, this 10th day of November, 1980:
Sheldon J. Wolfe, Esq., Chairman Susan Plettman, Esq.
Atomic Safety and Licensing David Preister, Esq.
Board Panel , ,
State Attorney General's Office U.S. Nuclear Regulatory Commission P.O. Box 12548 Washington, DC 20555 Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Watkinsville, Georgia 30677 Hon. Charles J. Dusek Mayor, City of Wallis Mr. Gustave A. Linenberger P. O. Box 312 Atomic Safety and Licensing Wallis, Texas 77485 Board Panel U.S. Nuclear Regulatory Commission Hon. Leroy H. Grebe Washington, DC 20555 County Judge, Austin County P. O. Box 99 Chase R. Stephens Bellville, Texas 77418 Docketing and Service Section Of fice of the Secretary of Atomic Safety and~ Licensing the Commission Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555 l
James M. Scott, Jr.
Richard Black, Esq. 13935 Ivy Mount U.S. Nuclear Regulatory Sugar Land, Texas 77478 Commission Washington, DC 20555 William Schuessler 5810 Darnell John F. Doherty Houston, Texas 77074 4327 Alconbury Street Houston, Texas 77021 Stephen A. Doggett, Esq.
P. O. Box 592 Rosenber.), Texas 77471 Att: Clarence Johnson Bryan L. Baker Executive Director 1923 Hawthorne Box 237 U.S. Houston, Texas 77098 University of Houston Houston, Texas 7704 J. Morgan Bishop Margaret Bishop Carro Hinderstein 11418 Oak Spring 609 Fannin Street Houston, Texas 77043 Suite 521 Houston, Texas 77002 W. Matthew Perrenod 4070 Merrick D. Marrack Houston, Texas 77024 420 Mulberry Lane Bellaire, Texas 77401 Brenda McCorkle -
6140 Darnell Houston, Texas 77074 F. H. Potthoff, III 7200 Shady Villa, #110 Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471
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