ML19341A090
| ML19341A090 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/19/1981 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8101220073 | |
| Download: ML19341A090 (27) | |
Text
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b VillTED STATES OF A'1 ERICA s44'.?j IS l 9
flVCLEAR REGULATORY C0ftt11SS!0fl Zg i
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BEFORE THE AT0'11C SAFETY AtlD LICErlSING B
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In the !btter of
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TEXAS UTILITIES GE!1ERATING C0!!PA!1Y,
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50-446
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(Conanche Peak Stean Electric
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Station, Units 1 and 2)
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NRC STAFF'S FIRST SET OF INTERR0GATORIES T0, AtlD REQUEST FOR THE PRODUCT 10tl 0F DOCU'1E.'!TS FR0:1, If1TERVErl0R CASE The 'Nclear 'tegulatory Connission (ilRC) Staff hereby requests that Intervenor CASE, pursuant to 10 CFR % 2.740(b) and in accordance with the Atonic Safety and Licensing Board's (hereafter "The Board") " Order Subsequent To The Prehearing Conference of April 30, 1980", dated June 16, 1989, and
'tenorandun and Order of December 31,1980,1/ answer separately and fully, in 1/ The Board's l'enorandun and Order of December 31, 1980 contains the Board's rulings on 1) consolidation of the intervenors,
- 2) appoint-nents of lead intervenors and 3) niscellaneous notions and other natters.
The Board consolidated the intervenors for certain conten-tions, with CASE being aopointed lead intervenor for consolidated contentions 22 and 24 and, as the sole sponsor of individual conten-tion 25, for that contention as well. The Board provided that the lead party-intervenor for a particular contention is lead for all purposes, which would include discovery. Accordingly, the Staff has directed interrogatories for consolidated contentions 22 and 24 to CASE only, as lead intervenor for those contentions.
It is the Staff's expectation that in responding to these interrogatories, CASE will consult with the consolidated intervenors.
CASE's responses should be the joint responses of the Intervenors consolidated for these contentions and should reflect the views and positions of all of the consolidated intervenors.
B101220 g g f
writing under oath or affimation, the following interrogatories within fourteen (14) days after service hereof.E For each response to the interrogatories set forth below, identify the person or persons who prepared or substantially contributed to the prepa-ration of the response.
The NRC Staff further requests that Intervenor CASE, pursuant to 10 CFR
@ 2.741, provide copies of, or make available for Staff inspection and copying, the documents designated by Intervenor in resDonse to certain of the accompanying interrogatories within thirty (30) days af ter service hereo.
I.
GENERALINTERR0GATORIEd/
G-1.
State whether or not you intend to call any person or persons as witnesses in this proceeding in support of (a) Contention 22 (c) Co,ntention 25 (b) Contention 24 The Staff has attempted to avoid duplication of Applicants' interrog-atories to CASE and has not included interrogatories which, in its view, seek precisely the same infomation which CASE has provided in response to Applicants' interrogatories to CASE.
3/ Interrogatories in this section should be answered with respect to each contention. The contentions referred to are those contentions raised by Intervenor as modified, renumbered and admitted by the Licensing Board in its 1) Order Subsequent to The Prehearing Conference of April 30, 1980, dated June 16, 1980 and 2) Rulings on Objections to Board's Order of June 16, 1980 and on Miscellaneous Motions, dated October 31, 1980.
In the Board's October 31, 1980 order, the Board deleted Con-tention 11 and construed Contention 5 to cover the Inspection and Enforcement Report subjects which Intervenor ACORN specifically identified at Appendix A of its offer of proof served August 29, 1980.
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and provide the names, addresses, educational backgrounds and professional qualifications of those persons you intend to call.
G-2.
Indicate which of those persons identified in response to Inter-rogatory G-1 will appear voluntarily and which persons you intend to subpoena.
G-3.
Provide surmaries of the views, positions, or proposed testimony on (a) Contention 22 (c) Contention 25 (b) Contention 24 of all persons named in response to Interrogatory G-1 that you intend to present during this proceeding.
G-4 Identify by author, title, date of publication and publisher, all books, documents and papers that you intend to employ or rely upon in pre-senting your direct case on (a) Contention 22 (c) Contention 25 (b) Contention 24 and provide copies of, or make available for Staff inspection and copying, those items.
G-5.
If the representations made in (a) Contention 22 (c) Contention 25 (b) Contention 24
are based in whole or in part on any documents prepared by the Applicants or NRC Staff which you contend are deficient, identify the documents and specify the particular portions thereof you regard as deficient and explain why they are deficient.
G-6.
Identify by author, title, date of publication and publisher all books, documents or papers that you intend to. emply or rely upon in conduct-ing your cross-examination of prospective NRC Staff witnesses testifying in connection with (a) Contention 22 (d) Board Ouestions 1, 2 and 3 as set forth in the Order (b) Contention 24 Subsequent To The Prehearing Conference, dated June 16, (c) Contention 25 1980.
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II.
INTERROGATORIES RELATED TO SPECIFIC CONTENTIONS Contention 22 Statement of Contention i
Applicants have failed to comply with 10 CFR Part 50, Appendix E, regarding emergency planning, for the following reasons:
a.
The FSAR does not identify state or regional authorities responsible for emergency planning or who have rpecial pualifications for dealing with energencies.
(CASE 12(a))5 Interrogatories in this section should be answered with respect to each contention. The contentions referred to are those contentions raised by Intervenor as modified, renumbered and admitted by the Licensing Board in its 1) Order Subsequent to The Prehearing Conference of April 30, 1980, dated June 16, 1980, supra, and 2) Rulings on Objections to Board's Order of June 16, 1980 and on Miscellaneous Motions, dated October 31,1980, supra.
El The numbers in parentheses indicate the contentions in Intervenor's filings from which the admitted contention is derived.
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b.
No agreements have been reached with local and state officials and agencies for the early warning and evacuation of the public, including the identification of the principal officials by titles and agencies.
(CASE 12(b))
c.
There is no description of the arrangements for services of physicians and other medical personnel quali-fied to handle radiation energencies and arrangements for the transportation of injured or contaminated individuals beyond the site boundary.
(CASE 12(c))
d.
There are no adequate plans for testing by periodic drills of emergency plans and provisions for participation in the drills by persons whose assistance may be needed, other than employees of the Applicants.
(CASE 12(d))
e.
There is no provision for medical facilities in the immediate vicinity of the site, which includes Glen Rose.
(CASE 12(e))
f.
There is no provision for emergency planning for Glen Rose or the Dallas /Ft. Worth metroplex.
(CASE 12(f) and ACORN 24)
C22-1. Define " emergency planning" as that term is used in Conten-tion 22 and specifically as the term is used with regard to parts (a), (d) and (f).
J C22-2.
As to Contention 22(a), Applicants' Emergency Plan (as revised in Amendment 12 to Applicants' FSAR, October 8, '.980), Section 4.3.2 " State Agencies" identifies State and regional authorities responsible for emer-gency planning or who have special qualifications for dealing with emer-gencies.
(a) Do you believe that Applicants' Emergency Plan (as revised) complies with 10 C/R Part 50, Appendix E regarding identification of State and regional authorities responsible for emergency planning or who have special qualifications for dealing with emergencies?
(b)
In view of the revisions to Applicants' Emergency Plan described in C22-2 above, are you willing to withdraw part (a) of Conten-tion 22, in which you allege that the Applicants have failed to comply with 10 CFR Part 50, Appendix E, regardino emergency planning, because the "FSAR does not identify state or regional authorities responsibis for emergency planning or who have special qualifications for dealing with emergencies"?
(c)
If you are not willing to withdraw Contention 22(a), answer
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the following questions:
(i) State specifically what is meant by the terr
" regional" as it is used in the contention. What geographical area corresponds to the region for which you believe the author-ities responsible for emergency planning should be identified?
Please specify the area and provide the distance from the Comanche peak site.
(ii) Describe the deficiencies in Applicants' emergency plan with respect to identification of State and regional authori-ties, provide the basis for your view that the plan is deficient in that respect and specify the additional identification of State and regional authorities that yott believe to be necessary.
(d) State specifically the requirements (including the particular sections of 10 CFR Part 50, Appendix E), which randate that Applicants' FSAR
" identify State or regional authorities responsible for energency planning or who have special qualifications for dealing with emergencies".
C22-3.
As to Contention 22(b), Applicants' Emergency Plan (as revised in Amendment 12 to Applicants' FSAR, October 8,1980), Section 4.3.1.,
" Local Agencies," Saction 4.3.2., " State Agencies" and Section 9.0, Appendix H contains agreements reached with State and local officials for the early warning of the public, including the identification of the principal officials by titles and agencies.
(a) Do you believe that Applicants' Emergency Plan (as revised) complies with 10 CFR Part 50, Appendix E regarding agreements with local and state officials and agencies for the early warning and evacuation of the public, including the identification of the principal officials by titles and agencies?
(b)
In view of the revisions to Applicants' Emergency Plan described in C22-3 above, are you willing to withdraw part (b) of Contention 22, in which you allege that Applicants have failed to comply with 10 CFR Part 50, Appendix E, because no agreenents have been reached with local and state officials and agencies for the early warning and evacuation of the public, including the identification of the principal officials by titles and agencies?
(c)
If you are not willing to withdraw Contention 22(b), answer the follcwing questions.
(i) Define what is meant by " local officials" and
" local agencies", as those terms are used in the contention.
(ii) State specifically what is meant by the tem
" local" as it is used in the contention.
What geographical area corresponds to the area which you consider to be " local"?
Please specify the area and provide the distance from the Comanche Peak site.
(iii) Specify what is meant by the tem "early warning."
(iv) Define what is meant by "public".
What geogra-phical area corresponds to the area in which you contend there must be agreements for "the early warning and evacuation of the public"? Please specify the area and provide the distance from the Comanche Peak site and provide the basis for your assertion in this regard.
(v) Describe the deficiencies in Applicants' Emer-gency Plan with respect
" agreements reached with local and 1
state officials and agencies for the early warning and evacu-ation of the public, including the identification of the principal of ficials by titles and agencies".
(vi) Provide the basis for your view that the plan is deficient in this regard.
Specify in what respects the plan is deficient regarding " agreements reached with local and state officials and agencies for the early warning and evacuation of the public including the identification of the principal offi-cials by titles and agencies".
(vii) Set forth with specificity the requirerents (including the particular sections of 10 CFR part 50, Appendix E) which mandate that Applicants must reach agreements with " local and state officials and agencies for the early warning and evacuation of the public, including the identification of the principal officials by titles and agencies".
C22-4 As to Contention 22(c), Applicants' Emergency Plan (as revised in Amendment 12 to Applicants' FSAR, October 8,1980), Section 4.3.1.4,
" Medical Support"; Section 6.6.4, " Medical Treatment" and Section 9.0,
Appendix H describe arrangements for the services of physicians and other medical personnel qualified to handle radiation emergencies.
Sections 4.3.1.3 " Ambulance Service", 4.3.1.4 " Medical Support" and 6.6.3 " Medical Transportation" and Section 9.0., Appendix H describe arrangements for the
' ansportation of injured or contaminated individuals beyond the site boundary.
(b) Do you believe that Applicants' Emergency Plan (as revised) complies with 10 CFR Part 50, Appendix E reoarding the " description of arrangements for the services of physicians and other medical personnel qualified to handle radiation emergencies and arrangements for the transportation of injured or contaminated individuals beyond the site bounda ry" ?
(b)
In view of the revisions to Applicants' Emergenc Plan described in C22-4 above, are y;u willing to withdraw part (c) of Con-tention 22, in which you allege that Applicants have failed to comply with 10 CFR Part 50, Appendix E, in that "there is no description in the FSAD of the arrangements for services of physicians and other medical personnel qualified to handle radiation emergencies and arrangmeents for the transportation of injured or contaminated individuals beyond the site bounda ry"?
(c)
If you are not willing to withdraw Contention 22(c), answer the following questions.
(i) State specifically what is meant by the term "other medical personnel qualified to handle radiation emer-gencies"? What types of " medical personnel" does the terr I
encompass, other than nurses? Describe specifically the types of emergencies which you consider to be " radiation emergencies".
(ii) Describe the deficiencies in Applicants' Ener-gency Plan regarding the " description of the arrangements for services of physicians and other nedical personnel qualified to handle radiation energencies and arrangenents for the transpor-tation of injured or contaminated individuals beyond the sith boundary"; provide the basis for your view that the plan is deficient in this regard and state what description you would consider to be adequate in this regard.
(iii)
State specifically the requirenents (including the particular sections of 10 CFR Part 50, Appendix E) which nandate that Aoplicants' FSAR and/or Energency Plan contain a
" des:ription of the arrangements for services of physicians or other nedical personnel qualified to handle radiation energencies and arrangenents for the transportation of injured or contaninated individuals beyond thi. t te boundary".
i C22-5.
As to Contention 22(d), Applicants' Energency Plan (as revised in Anendment 12 to Applicants' FSAR, October 8,19EJ), Section 8.2.2.
" Exercises" and Section 8.2.3 " Drills" and Section 9.0, Appendix H contain
" plans for testing by periodic drills of energency plans and provisions for participation in the drills by persons whose assistance may be needed, other than employees of the _ Applicants."
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(a) no you believe that Applicants' Energency Plan (as revised) complies with 10 CFR Part 50, Appendix E regarding " plans for testing by periodic drills of enernency plans and provisions for participation in the drills by persons whose assistance nay be needed, other than enployees of the Aoplicants"?
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(b)
In view of the revisions to Applicants' Emergency plan described in C22-5 above, are you willing to withdraw part (d) of Contention 22, in which you allege that Applicants have failed to comply with 10 CFR Part 50, Appendix E, regarding emergency planning because there are no " adequate plans for testing by periodic drills of emergency plans and provisions for participation in the drills by persons whose assistance may be needed, other than employees of the Applicants"?
(c)
If you are not willing to with?aw Contention 22(d), answer the following questions.
(i) State specifically. hat is meant by the phrase
" adequate plans" and the basis for your position as to what plans would be considered to be " adequate".
(ii) Define specifically what is meant by the phrase
" periodic drills", including how often such " drills" should be conducted in oroer to be considered " periodic".
(iii) Define what is meant by " persons whose assistance may be needed" including details as to what persons would be included in such definition.
(iv) What is the specific role which you contend Applicants should have with respect to developing "adeouate plans for testing by periodic drills of emergency plans and provisions for persons whose assistance may be needed"?
(v) What particular role do you contend Applicants should have with respect to the implementation and carrying out of plans for testing emergency plans by periodic drills?
(vi) What role do you contend State, local and regional officials should have with respect to 4 ;veloping adequate plans for testing emergency plans by periodic drills?
(vii) What role do you contend State, local and regional officials should have with respect to the implementation and carrying out of plans for testing emergency plans by periodic drills?
(viii) What role do you coatend the NRC should have in developing adequate plans for testing emergency plans by periodic drills?
(ix) What role do you contend the NRC should have with respect to the implementation and carrying out of adequate plans for testing emergency plans by periodic drills?
(x) What role do you contend the Federal Emergency Management Agency (" FEMA") must have with respect to developing adequate plans for testing of emergency plans by periodic drills?
(xi) What role do you contend FEMA should have with respect to the implementation and carrying out of adequate plans for testing of emergency plans by periodic drills?
(xii)
Precisely how do you contend Applicants should demonstrate that " adequate plans for testing by periodic drills of emergency plans" have been formulated?
(xiii) Precisely how do you contend the NRC Staff should demonstrate that " adequate plans for testing by periodic drills of emergency plans" have been developed and implemented?
(xiv) lihat are your bases for your responses to Interrogatories (iv) through (xiii)?
.(xv)
Describe the deficiencies in Applicants' Ener-gency Plan with respect to " plans for testing by periodic drills of energency plans and provisions for participation in the drills by persons whose assistance nay be needed, other than
-enployees of the Applicants"; provide the basis for your view that the plan is deficient in this regard and specify what
" plans for testing by periodic drills of emergency plans and provisions for participation by persons whose assistance nay be needed" you would consider to be adequate and provide the basis for your position in this regard.
?
(xvi)
State specifically the requirements (including particular sections of 10 CFR Part 50, Appendix E), which nandate
.I that Applicants' FSAR and/or Energency Plan contain " plans for testing by periodic drills of energency plans and provisions for particioation in the drills by persons whose assistance nay be needed, other than employees of the Applicants".
C22-6.
As to Contention 22(e), Applicants' Energency Plan (as revised in Amendment 12 to Applicants' FSAR, October 8,1980), Section 4.3.1.4,
" Medical Support", Section 6.6.4, " Medical Treatnent" and Section 9.0, Appendix H contain. infornation regarding " provision for nedical facilities in the innediate vicinity of the site, which includes Glen Rose".
(a) Do you believe that Applicants' Energency Plan (as revised) conplies with 10 CFR Part 50, Appendix E, regarding " provisions for nedical facilities in the innediate vicinity, which includes Glen Rose"?
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(b) In view of the revisions to Applicants' Emergency Plan described in C22-6 above, are you willing to withdraw part (e) of Contention 22, in which you allege that Applicants have failed to comply with 10 CFR Part 50, Appendix E, regarding emergency planning because "there is no provision for medical facilities in the immediate vicinity of the site, which includes Glen Rose"?
(c)
If you are not willing to withdraw Contention 22(e), answer the following cuestions.
(i) What kind of " medical facilities" do you contend must be provided for the "immediate vicinity of the site"?
State the basis for your position in this regard.
(ii) What particular role do you contend Applicants should have with respect to " provision for medical faciliites in the immediate vicinity of the site"? What is the basis for your position in this regard?
(iii) Precisely how do you contend Applicants should demonstrate that there is " provision for medical facilities in the imrrediate vicinity of the site"? State the basis for your position in this regard.
(iv) What role do you contend state and local officials should have with respect to " provision for medical faciliites in the immediate vicinity of the site"? What is the basis for your position in this regard?
(v) What role do you contend the NRC Staff should have with respect to " provision for medical facilities in the immediate vicinity of the site"? What is the basis for your position in this regard?
(vi) Precisely how do you contend the NRC Staff should demonstrate that there is " provision for medical facilities in the immediate vicinity of the site"? State the basis for your position in this regard.
(vii) What role do you contend the Federal Emergency Management Agency (" FEMA") should have with respect to " pro-vision for medical facilities in the immediate vicinity of the site"? What is the basis for your position in this regard?
(viii) What is the geographical area which corresponds to the "immediate vicinity of the site, which includes Glen Rose"? Specify that area and provide the distance of the area from the Cs ianche Peak site. What is the basis for your position in this regard?
(ix) Describe the deficiencies in Applicants' Emer-gency Plan with respect to " provision for medical facilities in the immediate vicinity of the site"; provide the basis for your view that "there is no provision for medical facilities in the immediate vicinity of the site, and specify what " provision for medical facilities in the immediate vicinity of the site" 2331 would consider to be adequate and state the basis for your position in this regard.
(x) State specificall; the requirements (including particular sections of 10 CFR part 50, Appendix E) which you contend mandate that the Applicants' FSAR and/or Emergency Plan contain " provision for medical facilities in the immediate vicinity of the site".
C22-7.
As to Contention 22(f), Applicants' Emergency Plan (as revised in Amendment 12 to the FSAR, October 8,1980), contains " provisions for emergency planning for Glen Rose or the Dallas /Ft. Worth metroplex".
(a) Do you believe that Applicants' Emergency Plan (as revised) complies with 10 CFR Part 50, Appendix E regarding " provisions for emergency planning fo: Glen Rose and the Dallas /Ft. Worth metroplex"?
(b)
In view of the revisions to Applicants' Emergency Plan described in C22-7 above, are you willing to withdraw part (f) of Contention 22, in which you allege that "there is no provision for emergency planning for Glen Rose or the Dallas /Ft. Worth metroplex"?
(c)
If you are unwilling to withdraw Contention 22(f), answer the following questions.
(i) What type of emergency planning do you contend must be provided for Gian Rose?
(ii) What kind of emergency planning do you contend must be provided for the Dallas / Fort Worth metroplex?
(iii) Do you contend that emergency plans for Glen Rose must include evacuation procedures?
(iv) Do you contend that the emergency plans for Dallas / Fort Worth must include evacuation procedures?
(v) Do you contend that emergency measures should vary with respect to the type of event which triggers their actuation?
If so, please identify the events which you contend should trigger actuation of emergency measures and specify the particular emergency actions which you contend must be taken for each event identified in your response.
(vi) What are your bases for your responses to !nter-rogatories (1) through (v)?
(vii) What 1s tne specific role which you contend Applicants should have with respect to developing emergency plans for Glen Rose and the Dallas / Fort Worth metroplex?
(viii) What particular role do you contend Applicants should have with respect to the actuation of emergency plans?
(ix) What role do you contend Applicants should have o
with respect to carrying out the emergency plan measures?
(x) What role do you contend State, regional and local officials should have with respect to developing emergency plans for Glen Rose and the Dallas / Fort Worth metroplex?
(xi) What role do you contend State, regional and local officials should have with respect to the actuation of emergency plans?
(xii) What role do you contend State, regional and local officials should have with respect to carrying out the rmergency plan measures?
(xiii) What role do you contend the NRC Staff should have in emergency planning for Glen Rose and the Dallas / Fort Worth metroplex?
(xiv) What role do you contend the NRC Staff should have with respect to the actuatien of emergency plans?
(xv) What role do you contend the NRC Staff should have with respect to carrying out emergency plan measures?
(xvi) What role do you contend the Federal Emergency Management Agency (" FEMA") should have with respect to emergency planning for the Glen Rose and the Dallas / Fort Worth metroplex?
(xvii) What role do you contend FEMA sho~uld have with respect to the actuation of emergency plans?
(xviii) What role do you contend FEMA should ha.re witn respect to carrying out emergency plan measures?
(xix) What are your bases for your responses to Interrogatories (vii) through (xviii)?
(xx)
Precisely what is the geographical area which corresponds to the area you are concerned with when you speak of
" emergency planning for Glen Rose"? Please specify that area including the distance of the area from the Comanche Peak site.
(xxi) What is the geographical area which corresponds to the " Dallas / Fort Worth metroplex", for which you contend there should be emergency planning? Please specify that area and provide the distance of the area from the Comanche Peak site.
(xxii) Should the emergency plans for these two creas differ in any way?
If so, please specify.
(xxiii) What are your bases for your responses to Interrogatories (xx) through (xxii)?
(xxiv) Do you contend that emergency planning rust be provided for the entire " Dallas / Fort Worth metroplex" as identified in your response to Interrogatory (xxi)?
. (xxv)
If your response to Interrogatory (xxiv) is in the affirmative, please set forth with specificity the requirements (including particular sections of 10 CFR Part 50, Appendix E) which you contend mandate that emergency planning be provided for the entire area which you have identified as "the Dallas / Fort Vorth metroplex" in your response to Interrogatory (xxi).
(xxvi) What are the dangers which you contend might cause the need to take emergency action in the Glen Rose area?
(xxvii) What are the dangers which you contend night require emergency action to be taken in the Forth Worth area?
(xxviii) What are the dangers which you contend might require emergency reasures to be taken in the Dallas area?
(xxix) With respect to each cf your responses to Interrogatories (xxvi) through (xxviii), please specify precisely the initiating event, the sequence of events, and the exposure pathway for radiological dangers.
(xxx) For eacn of your answers to Interrogatories (xxiv) through (xxix) please set forth the assumptions, analyses, conclusions and any documents relied on for your answers.
(xxxi) With respect to your answer to Interrogatories (xxvi) through (xxviii), please identify the specific emergency planning measures you contend should be provided for the dangers which you contend could exist.
(xxxii) What is your basis for your response to Interrogatory (xxxi)?
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i (xxxiii)
Do you contend that any particular connuni-cation capability nust'be provided as part of the energency planning with which you are concerned in Contention 22(f)?
(xxxiv)
If your response to Interrogatory (xxxii.i) is in the affin1ative, please specify the precise capabilities and functions of the connunications systen which you contend nust be provided.
(xxxv) ilhat is your basis for your response to Inter-rogatory (xxxiv)?
(xxxvi) Precisely how do you contend the Applicants should denonstrate that adequate energency planning as required for Glen Rose and the Dallas / Fort !1 orth netroplex has been prepared? State the basis for your position in this regard.
(xxxvii)
Precisely how do you contend the f1RC Staff
- hould demonstrate that adequate energency planning for Glen lose and the Dallas / Fort Worth netroplex has been prepared?
State the basis for your position in this regard.
Contention 24 Statenent of Contention A favorable cost / benefit balance cannot be nade becausa A3plicant has failed to adequately consider:
a.
The costs of safely deconnissioning the facility after its useful life.
b.
The costs in terns of health, as well as the economic costs of a possible accident in the on-site storage of spent fuel.
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c.
The fuel costs and supply.
d.
The costs of waste storage.
C24-1.
State specifically what is meant by the term " favorable" as it is used in the contention.
C24-2.
State your understanding of the term " cost / benefit balance".
C24-3.
State specifically what is meant by the phrase " adequately consider" as it is used in the contention.
i C24-4 With respect to Contention 24(a):
(a) State what is meant by the phrase " safely deca"missioning" as it is used in the contention.
(b) State specifically what is meant by the tenn " facility" as it is used in the contention.
(c) State specifically what is meant by the term "useful life" as it is used in the contention.
What period of time corresponds to the "useful life" of the " facility"?
(d) What particular mode of decommissioning do you contend must be evaluated in the Comanche Peak cost / benefit analysis? State the basis for your position in this regard.
(e) What is the dollar cost of decommissioning which you contend should be considered in the cost / benefit analysis? State how you arrived at this cost figure.
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(f) Describe the type of consideration by Applicants of the costs of " safely decommissioning the facility after its useful life" which you believe would be adequate and state the basis for your response.
C24-5. With respect to Contention 24(b):
(a) Where do you contend that such accidents could happen?
Please specify as to the precise location within the Comanche Peak facility.
(b) What is the specific sequence of events which you postulate would lead to the type of accident you contend might happen with regard to the onsite storage of spent fuel?
(c) Do you contend that the accidents with which you are concerned would occur during the movement of spent fuel? If so, please specify.
(d) Do you contend that the accidents with which you are concerned would occur during the storage of spent fuel? If so, please specify.
(e) Do you contend that such accidents would occur at any particular time after the discharge of spent fuel from the reactor core?
If so, please speci fy.
(f) Do you contend that such accidents would be caused by mechanical failure?
If so, please specify.
(g) Do you contend that such accidents would occur because of material failure? If so, please specify.
(h) Do you contend that such accidents would occur because of human error? If so, please specify.
(i) What is the probability of occurrence of the accidents which you contend must be considered?
f (j)
For Interrogatories C24-5(a) through C24-5(1), please set forth the basis for your response and set forth with particularity the analysis which you have perfomed with respect to those interrogatories.
l Also, please provide for inspection and copying any documents on which you rely for your response to Interrogatories C24-5(a) through C24-5(i).
(k) What are the consequences of the accidents with regard to the onsite storage of spent fuel which you contend must be considered?
(1) Do you contend that any consequences with respect to such accidents are other than radiological in nature?
If so, please specify.
(n) What is the total activity released to the environment by the accidents which you contend should be considered? Specify in Curies.
(n) lihat are the radioactive doses which you contend would be caused by such accidents? Please specify in tems of naxinun exposure to an individual (specify in rems) and total exposure to the population (specify in man-rens).
(o) What is the population which you contend would receive the doses identified in your response to Interrogatory C24-5(n)?
(p) lihat is the decay time prior to the accident for each radio-active nuclide which you contend would be released in the environnent in the accident which you postulate should be considered?
(q)
With respect to Interrogatories C24-5(k) througn C24-5(p),
please specify the basis for your responses.
( r) Please identify any analyses, including the assumptions and conclusions thereof, with respect to your response to Interrogatories C24-5(k) through C24-5(p),
Please provide any copies of those analyses for inspection and copying.
Contention 25 Statement of Contention The requireInents of the Atomic Energy Act, as amended,10 CFR 50.57;:)(4) and 10 CFR 50, Appendix C have not been met in that the Applicant is not financially qualified to operate the proposed facility.
C25-1.
State specifically those requirements of the Atomic Energy Act which you contend have not been met because of what you contend to be Appli-cants' lack of financial qualifications to operate the proposed facility.
C25-2.
State specifically the requirements in 10 CFR Part 50, Appen-dix C which you contend have not been met because of what you contend to be Applicants' lack of financial qualifications to operate the proposed facility.
C25-3.
State specifically what is meant by the phrase " financially qualified" as it is used in the contention.
C25-4. What do you contend Applicants must do to demonstrate that they have met the requirements of the Atomic Energy Act, as amended, and 10 CFR Part 50, Appendix C with respect to their financial qualifications to operate the proposed facility?
C25-5.
What is the basis for your response to Interrogatory C25 4?
C25-6. What do you contend is necessary in order for the Commission to make the finding, pursuant to 10 CFR 6 50.57(a)(4), that the Applicants are
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financially qualified to engage in the activities authorized by an operating license? State the basis for your position in this regard, s
C25-7.
State specifically the basis for Contention 25.
Respectfully Submitted,
}$f 0% ~ ?5efa':-laAet i
flarjorie Ulman Rothschild Counsel for ilRC Staff Dated at Bethesda, !1aryland i
this 19th day of January,1931 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES GENERATING COMPANY, ET AL.
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Docket Nos. 50-445
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50-446 (Comanche Peak Steam Electric Station,
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Unit: 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERROGATORIES T0, AND REQUEST FOP. THE PRODUCTION OF DOCUMENTS FROM, INTERVENOR CASE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 19th day of January,1981:
Valentine B. Deale, Esq., Chaiman Mr. Geoffrey M. Gay Administrative Judge West Texas Legal Services Atomic Safety and Licensing Board 100 Main Street (Lawyers Bldg.)
1001 Connecticut Avenue, N.W.
Fort Worth, TX 76102 Washington, DC 20036 David J. Preister, Esq.
Forest J. Remick, Administrative Assistant Attorney General Judge Environmental Protection Division Atomic Safety and Licensing Board P.O. Box 12548, Capital Station 305 E. Hamilter. Avenue Austin, TX 78711 State College, PA 16801 Mr. Richard Fouke Richard Cole, Administrative Judge
- 1668-B Carter Drive Atomic Safety and Licensing Board Arlington, TX 76010 U.S. Nuclear Regulatory Commission Washington, DC 20555 Arch C. McColl III, Esq.
701 Commerce Street Nicholas S. Reynolds, Esq.
Suite 302 Debevoise & Liberman Dallas, TX 75202 120017th Street, N.W.
Washington, DC 20036 Jeffery L. Hart, Esq.
4021 Prescott Avenue Mrs. Juanita Ellis Dallas, TX 75219 President, CASE 1426 South Polk Street Dallas, TX 75224 l
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Atomic Safety and Licensing Board Docketing and Service Section (7)*
Panel
- Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Panel (5)*
l U.S. Nuclear Regulatory Commission Washington, DC 20555 i
i Ma.ye,w Mw h UNMk Marjofie Ulman Rothschild Counsel for NRC Staff t
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