ML19345F402

Requests Postponement to Answering NRC & Applicant Interrogatories Until Receipt of Info Requested in 810209 Ltr to N Reynolds.Info Incomplete from Applicants 801008 Emergency Plan.W/Certificate of Svc.Related Correspondence

ML19345F402
Person / Time
Site:	Comanche Peak
Issue date:	02/09/1981
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19345F403	List: ML19345F402 ML19345F408
References
NUDOCS 8102170417
Download: ML19345F402 (5)

Text

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RELATED CORKSS?O.mCE g iI 4 g

2/9/

UNITED S MTES OF AMERICA 2 EES f -?.

NUCLEAT REGUIATORY COMMISSION k cftl A2 5 3 BEFORE IEE r..OGC SAFETY AND LICENSINI BOARD k f: '

In the Matter of l 0 l Docket Nos. 50-45 APPLICATION OF TEIAS 17fILITIES l and 50-M6 GENERATING COMPANY, ET AL. FOR AN l OPERATING LICENSE FOR CCNANCHE l '

PEAK STEAM ELECTRIC STATION [

UNITS.#1 AND #2 (CPSES) l-CASE'S MOTION FOR POSTPONEMENT OF RESPONSES TO INTERROGATORIES REGARDING CONTENTION 22 FENDING RECEIPT OF CERTAIN INFCRV.ATION FRCM APPLICANTS ,

COMES NOR CASE (Citizens Association for Sound Energy), hereinafter referred to as CASE, Intervenor herein, and files this, its Motion for Postpone-ment of Responses to Interrogatories Regarding Contention 22 Pending Receipt of Certain Infor=ation frcm Applicants.

CASE's Contention 22 (part f of which is shared with ACORN) states:

CONTENTION 22: Applicants have failed to ecmply 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 special qualifications for dealing with emergencies.

b. No agreements have been reached with local and state officials and agencies for.the early warning and evacuation cf the public, including the identi-w .. fication of the principal officials by tit 16,s and agencies.

l c. There is no description of the arrangements for services of phyoicians and other medical personnel qualified to bar.dle radiation emergencies and arrangements for the transportation of injured or contaminated individuals beyond the site boundary.

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.

e. There is no provision for medical facilities in the immediate vicinity f.

of the site, which includes Glen Rose; and There is no provision for emergency planning for Glen Rose or the M

Dallas /Ft. Worth metroplex. -

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CASE has just completed its prelimicary answer to Applicants' S econd Set of Interrogatories and we are working on cur response to sthe NRC Staff' First Set of Interrogatories at this time.

However, we find that the information supplied to us in our copy of the Applicants' October 8

, 1980 Emergency Plan was incomplete and effectively crecludes ou responding to interrogatories fully and accurately. .

k'e therefore L <- that CASE be g' ranted a postponement fr om answering further interrogatories by the Applicants and the NRC 7taff (aft 1

er our preliminary response to the NRC St'aff's First Set of Interrogatories, which is to be filed February 17 -- see attached letter to Marjorie Rothschild) until we have received the information requested in CASE's February 9 let'er tooNich l as Reynolds, which was not provided in CASE's ecpy of Applicants' Emergency Pl an; specifically the following Appendices:

K. Emergency Plan Procedures

1. I Emergency Con =unication and Notification i

2. .

Assessment of Emergency Acti.on Le'vels 3.

Emergency organization an' d racility Activation 4.

Use of the Accident Assessment Kit 5.

Station Evacuation

6. Site Evacuation 7.

Radiological Monitoring of Evacuees ,

8.

Personnel Decontamination 9.

Personnel Accountability

10.

• Surveillance of Emergency Xits t 2-

1

11. Transporting of Contaminated Victims *

12. First Aid 1 I

13. Control of Site Access I

i 14 Personnel Dosimetry for Emergency Conditions

15. Emergency Radiological Survey  !

16. Re entry and Recovery ~

17.

Review, Update and Control of the Emergency Plan

18. I t - Annual Exercise Procedure

19. Drill. Procedures 1

20. Issuance of Thyroid Blocking Agents M.

Appendix 3 to Annex L - Texas Radiological Emergency Response Plan for Fixed Nuclear Facilities .

N. Somervell and llood Counties Emergency Operations Plans P

Q. EPZ Evacuation Tipe Estimates CASE's ability to respond adequately to interrogatories depends upon the i

response which we receive to our attached letter to Mr. Reynolds. Therefore,

- g i t l if we have not received the requested information by March 9, we will so advise the Chairman and request that this pleading be considered a Motion to Compel e

Applicants to supply the rOglested information at that time, shoul<1 it become i

necessary.

(We are attempting to cut down paperwork for all parties by this j r

procedure.)

WHEREFORE, PREMISES CONSIDERED, CASE moves that the Board grant our notions as stated herein.

i Respectfully submitted, l

lh26 S. Polk, Dallas, TX 75224 21h/9k6-94h6

>> c _ _ M bA >

p's.) Juanita Ellis, President l

214/941-1211, usually Tues. & Fri. 'mE (Citizens Association for Sound Enerev) i l __ _ _- .

1

' UNITED STATES OF AMERICA <

NUCLEAR REGULATORY COMMISSION ' '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of , , l' I

APPLICATION OF TEXAS UTILITIES J Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN I OPERATING LICENSE FOR COMANCHE and 50-4.46 1

PEAK STEAM ELECTRIC STATION 1 UNITS #1 AND #2 (CPSES) 1 CERTIFICATE OF SERVICE By my signature below, I certify that a true and correef, copy of CA5'E's MOTION FOR POSTPONEMENT OF RESPONSES TO INTERROGATORIES REGARDING CONTENTION 22 Pending Receipt of Certain Information from Applicantsihas been sent this 9th day of February,1981, to the following by First Class Mai1*:

'I

• vith Certificate of Mailing receipt -

5

+ Valentine B. Deale, Esq., Chaiman David J. Preister, Esq.

Atomic Safety and Licensing Board Assistant Attorney General .

1001 Connecticut Avenue, N. W. Environmental Protection Division Washington, D. C.

20036 P. O. Box 12548, Capitol Station Austin, Texas 78711 Dr. Forrest J. Remick, Memb.er Atomic Safety and Licensing Board Mr. Richard Fouke 305 E. Hamilton Avenue 1668-B Carter Drive State College ~, PA 16801 Arlington, TX 76010 Dr. Richard Cole, Member Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

• Nicholas S. Repolds, Esq. Atomic Safety and Licensing Debevoise & Liberman . 1 Appeal Panel 1200 - 17th St. , N. W. U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555

• Marjcria Rothschild Docketing and Service Section i Counsel for NRC Staff Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 Washington, D. C. 20555 .

Mr. Geoffrey M. Gay Arch D. McColl, III, Esq.

West Texas Legal Services 701 Commerce Street, Suite 302 100 Main Street (Lav,yers Bldg.) Dallas, u Fort Worth, TX 76102 75202 l

Jeffery L. Hart, Esq.

l 14021 Prescott Avenue - W4M- O>

m e8 u 75219 f.rs.) Juanita Ellis, President TASE (CITIZENS ASSOCIATION FOR SOUND ENERGY) 1

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C A S E ==

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(CITIZENS ASSN. FOR SOUND ENERGY)

February 9, 1981 Mr. Nicholas S. Reynolds, Esq.

Debevoise & Liber =an 1200 - 17th St., N. W.

Vcshington, D. C. 20036 i

Subject:

Docket Nos. So hh5 and 50 kh6 ,

Texas Utilities Generating Co., et. al.

Application for Operating License for Comanche Peak Nuclear Plant Applicants' October 8,1980 Emergency Plan In preparing our response to the NRC Staff's First Set of Interrogatories and our update to the Applicants' Second Set of Interrogatories, we find that the infor=ation contained in the copy which we received of subject Emergency Plan was inco=plete.

The following Appendices state: "This information is not provided in this copy.

It vill be provided in all controlled Emergency Plan manuals." (Emphasis added.)

K, E=ergency Plan ProceO res M, Appendix 3 to Annex L -- Texas Radiological Emergency Response Plan for Fixed Nuclear Facilities N, Sccervell and Hood Counties Emergency Operations' Plan Q, EPZ Evacuation Time Estimates It is impossible for CASE to accurately evaluate whether or not -Applicants have taken care of our concerns regarding Contention 22 without having this infor=ation. It =ay well be that Applicants have taken steps to take care of all or scme of the concerns which ve have regardingthis contention; however, ve simply cannot assess this without this vital information.

Pleace supply us with copies of the requested inforination.

Sincerely, C? 'E (CITIZENS ASSOCIATION FOR SOUND ENERGY)

[rs.)& a Ellis, Juanita OAD President

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