ML19340C314

Response to W Schuessler Request for Addl Answers to First Set of Interrogatories.Applicant Is Not in Possession of Data Analyzing Hypothetical Significant Offsite Radiological Releases.Certificate of Svc Encl

ML19340C314
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/10/1980
From:	Copeland J, Raskin D BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Schuessler W AFFILIATION NOT ASSIGNED
References
NUDOCS 8011140493
Download: ML19340C314 (7)

Text

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- November 10, 1960 UNITED STATE 3 OF AMERICA NUCLEAR REGULATORY COMMISSION t

i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

I HOUSTON LIGHTING & POWER COMPANY) Docket No. 50-466

)

(Allens Creek Nuclear Generating)

Station, Unit No. I ?. )

! )

TdPLICANT'S RESPONSE TO SCHUESSLER'S i REQUEST FOR ADDITIONAL ANSWERS TO HIS FIRST SET OF INTERROGATORIES In response to your request for additional answers to your first set of interrogatories, Applicant provides the following information. Your requests are set out first, followed by Applicant's response to each.

Interrogatory 1:

1. Assuming occurrences at ACNGS of any accidents which could have a potential for significant off-site radiological releases, with winds blowing from (a) Northwest, (b) West, and (c) Southwest, please answer the following questions as they would relate specifically to:

(Remaining part of Interrogatory 1 unchanged)

If any studies have been done, or if Applicant possesses

! data and information from any source which is related to the

, subject matter of Interrogatory 1, please produce such data and information.

Response

Applicant would like to clarify that its earlier answer l to this interrogatory was not limited to precise accident

( sequences analyzed in WASH-740. Applicant has not performed any analyses of hypothetical accident sequences resulting in "significant off-site radiological releases" at the ACNGS.

Applicant is not in possession of any data or studies OE11ggM3

\f _ - _ .- - - - _ . -- . - - . -

t .

4 l analyzing hypothetical "significant off-site radiological releases" at the ACNGS. Applicant has never speculated as i

to the number of short-term deaths, serious injuries, number i

4 of probable evacuees or amounts of property damage that would i

result from such "significant' releases."

4 Interrogatory 1.b:

I Applicant is unresponsive.- Response fails to provide

" sufficient information" required by 10 CFR Part 50, Appendix E, II. Please describe in greater detail the first aid and decontamination areas, number and training of personnel. Identify and describe possible or proposed sites for these facilities.

Response

Applicant has responded to this interrogatory based on current. information. However, additional study is ongoing in conjunction with the preparation o# an amendment to Section 13.3 of Applicant's PSAR discussing preliminary plans

- for coping with emergencies. This amendment is being pre-

!, pared to comply with the Commission's recently revised emer-gency planning regulations and will be submitted to the NRC in the near future. More information on this subject might be available at that time. A copy of the amendment will be

~

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1 made available for inspection and copying.

l l Interrogatory 1.c.:

Insufficient information (see Appendix E, II). Answer

! not responsive. Please describe local preliminary plans i

made. What discussions have taken place, with whom, and what are results?

I Response:

f See amended response to Interrogatory 1.b.

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O Interrogatory 1.f.:

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Insufficient information (see Appendix E, II). Please provide more detailed description of alternatives being considered. Describe any tests which have been done on these alternatives--their histories and their effectiveness. Who will pay for warning systems? Have costs been estimated?

Response

See amended response to Interrogatory 1.b.

Interrogatory 1.g.:

Insufficient information (see Appendix E, II). Please provide more detailed information on preliminary arrangements with local authorities. How many mobile public-address units would be needed. What would cost of operation be and who would pay for it? Paid personnel? Full or part-time? Would these be used in low population density areas? Have esti-mates been ma d e of effectiveness?

Response

See amended response to Interrogatory 1.b.

Interrogatory 1.i. (1) ; (2); and (3) :

Insufficient information (see Appendix E, II).

Response

See response to new Interrogatory 1.i.(4) set forth below. This document comprises all of the information com-piled by Applicant pertaining to this subject.

Interrogatory 1.i.(4):_

. j

\

Please p;oduce copies of all documents comprising the I preliminary evacuation analysis. Who prepared it'. Who will i testify on it? j

Response

r Applicant's draft preliminary evacuation analysis is available for inspection and copying at the Applicant's Energy Develepment Complex, 12301 Kurland Drive, Houston.

1 Arrangements may be made to inspect this document during

. - - . _. .. .~. - . . __ .- ... - _ _ _ -

normal business hours by contacting Mr. J. Gregory Copeland.

1-at (713) 229-1301. This analysis was prepared by i t

Mr. William Griffin of HMM Associates, Waltham, Massachu-j setts.

1 Interrogatory 1.i.7.:

In the process of reaching understanding and agreement with state and county officials, has Applicant been informed

. by state and counties if they plan to limit to 10 miles their areas of concern? (Reference is, of course, to 10 mile radius EPZ). Who will testify for state?

I Who drafted the letters of understanding and agreement

! from county sheriffs' offices, of which copies were attached j to response?

What steps have been taken, if any, to comply with the 4

j

} suggested emergency support facilities set out in NUREG-0694,

"TMI-related Requirements for New Operating Licenses,"

j III.A.l.2 and III.D.3.3. page 20?

r

Response

I

, a) Ple.se refer to the letters from tne Texas y

Department of Health and the local County Sheriff's departments attached to Applicant's earlier response.

1

Applicant has no additional information at this time.

Applicant does not intend to call any witness from the 1

State of Texas.

b) Letters of agreement and understanding were drafted by Houston Lighting & Power Company at the request of the various Sheriffs. They were then presented to the Sheriffs for review and approval.

j c) As its title indicates, NUREG-0694 sets forth i l

, requirements for obtaining " Operating Licenses." Therefore, i

Applicant has not addressed it. The PSAR amendment 1

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l referened above, will include a discussion of emergency support facilities, however, in compliance with 10 CFR Part 50, Appendi) E.

Respectfully submitted, b

OF COUNSEL:

d8lek "

Jack R. Newman LOWENSTEIN, NEW:iAN , REIS, Robert H. Culp AXELRAD & TOLL David B. Raskin 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D.C. 20036 Wa.shington, D.C. 20036 BAKER & BOTTS J. Gregory Copeland 3000 One Shell Plaza C. Thomas Biddle, Jr.

Houston, Texas 77002 Darrell Hancock 3000 One Shell Plaza Houston, Texas 77002 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER CO:iPANY e

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