ML19347B434
| ML19347B434 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 10/09/1980 |
| From: | Moon C Office of Nuclear Reactor Regulation |
| To: | Schuessler W AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8010150072 | |
| Download: ML19347B434 (11) | |
Text
9 10/09/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOUSTON LIGHTING & POWER COMPANY
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Docket No. 50-466
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(Allens Creek Nuclear Generating
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Station, Unit 1)
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NRC STAFF'S RESPONSES TO WM. J. SCHUESSLER'S FIRST SET OF INTERROGATORIES The NRC Staff responds as follows to the first set of interrogatories pro-pounded by Wm. J. Schuessler to the Staff in the captioned proceeding:
1.
Assuming accidents like those used in WASH 740 should occur
'at ACNGS, with winds blowing from (a) Northwest, (b) West and (c) Southwest, please answer the following questions as they would relate specifically to:
1 Area within 10-mile radius 2
Area within 50-mile radius
- 3) Tomball
- 4) Houston
- 5) Harris County
- 6) Sugarland
- 7) Stafford 8)
Richmond 9)
Rosenberg
- 10) Angleton
Response
The NRC Staff has not performed the analysis postulated in the interrogatory.
Hence, any responses provided to subparts of Interrogatory No.1 will not reflect the results of such an analysis.
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1.a.
How many short-term deaths would probably occur?
Response
The NRC Staff has made no estimates of the short-term deaths that might occur if accidents like those in WASH 740 should occur at ACNGS.
I l.b.
How many serious injuries would probably occur?
What medical facilities and personnel will be avail-i able for care and treatment of injured? What special training is planned or anticipated for such personnel?
What specialized equipment and supplies will be available for treatment of injuries expected from such an accident? Identify individuals and agencies responsible for care and treatment of injured. Descr'be their qualifications and training.
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Response
The NRC. Staff has made no estimates of how many serious injuries would probably occur.
i 1.c. 'How many people would probably require evacuation or shelter? What arrangements have been made, or are planned, to provide for their needs, such as transportation, safe food and water, sanitary facilities and medical care? Icentify individuals and agencies responsible for care and treatment of injured. Describe their qualifications and training.
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Response
The NRC Staff has made no estimates of how many people would probably require j'
evacuation or shelter. The Commission's regulations require emergency planning 1
i for such actions out to a radius of approximately ten miles. The Applicant's l
estimates of populations by sector within ten miles are provided in the i
Preliminary Safety Analysis Report (PSAR Table 2.1-3).
1.d.
What arrangements have been made, or are planned for removal and handling of dead, including possibly radioactive bodies? What burial or funeral arrange-ments are planned, with wishes of families in mind?
Identify individuals and agencies responsible for l
dealing with these problems. Describe policies they i
will work under.
Response
Such arrangements are not planned by the NRC.
l.e.
What would be the amount of property damage estimated at projected 1980, 1985, 1990, and year 2000 prices?
Response.
No estimates of property damage resulting from postulated WASH 740 accidents at the ACNGS have been made by the NRC Staff.
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1.f.
What methods are planned for alerting public to emergency?
What are estimates of time required? What are estimates of effectiveness of efforts? What individuals and agencies are responsible for carrying out this task?
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Response
j The Applicant has not yet provided this information for NRC Staff review.
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l.g.
What methods are planned for directing. informing, and otherwise communicating with the public? How effective are these efforts expected to be?
Identify individuals and agencies who will' be responsible for this task.
From what point (s) will they operate, and from what e
sources will they receive infomation to be given the public?
Response
The Applicant has not yet provided this information for NRC Staff review.
l.h.
Please identify individuals or agencies who will be responsible for detemining if and when evacuation is necessary. On what criteria will such decisions be based? What infomation, from what source will be used?
Response
The Applicant has not yet provided this infomation for NRC Staff review.
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'l.i.
Should evacuation be deemed necessary:
(1) Describe the (.ypes of vehicles considered, their availability, reliability and capacities.
What problems have been anticipated in this regard and how will they be resolved?
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(2) What mode of transportation will be available for evacuation of elderly and handicapped living in residences, schools, hospitals, jails and prisons, rest and convalescent homes, homes for aged, and other such centers? What studies have been done to asses [ sic] the magnitude of this problem? Please produce data.
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(3) Describe plans and arrangements made, or to be made, for providing for evacuees. Where will they go? What shelter will be provided? Will they be removed to other urban areas, or are tent-city [ sic],
type facilities to be provided? If the later what arrangements have been made for sites and equipment? If the former, name urban areas, l
facilities and persons or agencies with whom ar-rangements have, or will be made?
(4) What estimates have been made as to minimums and maximums of necessary length of evacuation period?
(5) What estimates have been made as to timely safe return to evacuated areas?
(6)
Identify planned evacuation routes. What studies
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have been made to determine suitability and adequacy of these routes? Are they, and will they be, accessible? Are they to be made one-way routes?
If so, will they prevent or hamper counter flow of emergency traffic? Are they free of possible flooding. in stonn conditions? Considering worst likely weather and traffic conditions, what is estimated to be time required for evacuation of given population groups? Provide estimated carrying capacities of proposed evacuation routes under a variety of possible conditions, including but not limited to, direction, time, weather, etc.
(7) -Identify individuals and agencies responsible for the planning, directing, and _otherwise implementing evacuation plans. Please produce copies of arrange-ments and agreements made with.them.
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Response
The Applicant has not yet provided this infomation for NRC Staff review.
s 2.
Do emergency. evacuation and safety problems and con-siderations at ACNGS differ from those at the South
[
Texas nuclear facility? If so, explain how. How i
does safety and emergency evacuation planning differ for these two projects. Provide data.
Response
The Applicant has not yet provided the informatic.n required for the NRC Staff to review the ACNGS emergency planning necessary for a decision on i
issuant? of a construction permit. No comparison with similar infomation for the South Texas Project is contemplated or required by NRC regulations.
3.
Section of PSAR dealing with demographics has been sub-stantially emmended [ sic]. Please produce copies of original PSAR pages which have been replaced in this section, including pages 2.1.3 through 2.1-9 and 2.1-24 through 2.1-29.
Are similar ammendments [ sic],
based on current new data, planned?
Response
Not applicable to NRC Staff. See Applicant's Response to Intervenor Schuessler's First Set of Interrogatories and Requests for Production of
. Documents to Houston Lighting and Power Company, dated September 24, 1980.
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y 4.
Please furnish copies of all data, documents, communi-cations and preliminary or final drafts which ara part of, or relate to preparation of your up-coming second final supplement to the Final Environmental Statement.
l-
Response
The ' draft of the second supplement to the Final Environmental Statement is scheduled to be published in October 1980.
It will not contain any information
- pertaining to emergency planning.
1 5.
Have any population density and population distribution studies been made by you, or are such studies planned, which are based on preliminary data from the 1980 U.S.
Census which may confirm or dispute PSAR estimates and j
projections based on 1970 U.S. Census?
If so, please produce all resulting data and findings, J
Response
None have been made and none are planned. The results of the NRC Staff's latest review of population estimates and projections of population as reported in the PSAR by the Applicant are-included in Supplement No. 2 to the Safety Evaluation Report, NUREG-0570, March,1979. The Applicant is responsible for reporting any new information that would significantly change the bases for projections in the PSAR.
6.- Identify all sites ~which were considered for this project before Allens Creek was was [ sic] selected.
Produce copies of all data, documents and communications related to comparative judgements [ sic] in regard to safety and emergency planning, which were made for the site selection.
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Response
s.
Not applicable to NRC Staff.
7.
How cid Allens Creek compare with other sites considered, in regard to safety and emergency plar.ning? Please pro-duce all data resulting from such studies.
Response
The Staff knows of no such comparisons.
- 8. ' Identity by name and title all individuals who were involved in the process of selecting this site.
Produce copies of all communications, studies, notes, transcripts, documents which bear directly, or indirectly, on the making of this decision.
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Response
l-l Not applicable to the NRC Staff.
9.
Identify all expert witnesses you plan to present in these procedings [ sic].
t l
Response
NRC Staff witnesses for this contention have not yet been identified.
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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
)
l Station, Unit 1)
)
AFFIDAVIT OF CALVIN W. MOON i
I I hereby depose and say under oath that the foregoing NRC Staff responses to interrogatories propounded by Wm. J. Schuessler were prepared by me or under my supervision.
I certify that the answers given are true and correct to i
the best of my knowledge, infonnation and belief.
I
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~ Calvin W. Moon Subscribed and sworn to before me this 9th day of October,1980.
W2r lu I4 plt '
Netary PJ/blic
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My.Comission Expires:
July 1, 1982 i
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UNITED STATES OF A*4 ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
HOU5 TON LIGHTING & POWER C0!!PANY Docket No. 50-466 (Allens Creek Nuclear Generating
)
g Station, Unit 1)
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CERTIFICATE OF SERVICE F
I hereby certify that copies of "NRC STAFF'S RESPONSES TO WM. J. SCHUESSLER'S FIRST SET OF INTERR0GATORIES" in the above-captioned proceeding have been I
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 9th day of October,1980:
Sheldon J. Wolfe, Esq., Chairman
- Susan Plettman, Esq.
Atomic Safety and Licensing Board P".n01 David Preister, Esq.
U.S. Nuclear Regulatory Commission Texas Attorney General's Office Washington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box 350A Watkinsville, Georgia 30677 Hon. Jerry Sliva, Mayor City of Wallis, Texas -77485 Mr. Gustave A. Linenberger
- Atomic Safety and Licensing Board Panel Hon. John R. Mikeska i
U.S. Nuclear Regulatory Commission Austin County Judge Washington, DC 20555 P.O. Box 310 Bellville, Texas 77418
-t Mr. John F. Doherty 4327 Alconbury Street Houston, Texas 77021 J. Gregory Copeland, Esq.
Baker & Botts One Shell Plaza Houston, Texas 77002 Mr. F. H. Potthoff, III Jack Newman,-Esq..
Houston, Texas 77080 1814 Pine Village Lowenstein, Reis, Newman & Axelrad 1025 Connecticut. Avenue, N.W.
Washington, DC 20037 D. Marrack 420 Mulberry Lane Carro Hinderstein Bellaire, Texas 77401 8739 Link Terrace Houston, Texas -77025 p..
o Texas Public Interest Margaret Bishop Research Group, Inc.
J. fiorgan Bishop c/o James Scott, Jr., Esq.
11418 Oak Spring 13935 Ivymount Houston, Texas 77043 Sugarland, Texas 77478 Brenda A. McCorkle 6140 Darnell Houston, Texas 770/4 l
Mr. Wayne Rentfro P.O. Box 1335 Rosenberg, Texas 77471 Stephen A. Doggett, Esq.
Pollan, Nicholson & Doggett f
Rosemary N. Lemmer P.O. Box 592 11423 Dak Spring Rosenberg, Texas 77471 Houston, Texas 77043 Bryan L. Baker
,1923 Hawthorne Houston, Texas 77098 Robin Griffith Leotis Johnston 1034 Sally Ann 1407 Scenic Ridge Rosenberg, Texas 77471 Houston, Texas 77043 Elinore P. Cummings Atomic Safety and Licensing
- 926 Horace Mann Appeal Board Rosenberg, Texas 77471 U.S. Nuclear Regulatory Conmission Washington, DC 20555 Atomic Safety and Licensing
- Board Panel U.S. Nuclear Regulatory Commission Mr. William Perrenod Washington, DC 20555 4070 Merrick Houston, TX 77025 Docketing and Service Section
- Office of the Secretary Carolina Conn U.S. Nuclear Regulatory Comission 1414 Scenic Ridge Washington, DC 20555 Houston, Texas 77043 Mr. William J. Schuessler U.S. Nuclear Regulatory Commission 5810 Darnell Region IV Houston, Texas 77074 Office of Inspection and Enforcement 611 Ryan Plaza Drive The Honorable Ron Waters Suite 1000 State Representative, District 79 Arlington, Texas 76011 3620 Washington Avenue, No. 362 Houston, TX 77007-l 4tW ob Ric.bard L.'B%ck
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Cou'nsel for NRC Staff