ML19354C401
| ML19354C401 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/09/1980 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CINCINNATI GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8012290457 | |
| Download: ML19354C401 (8) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 12/9/80 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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CIriCINNATI GAS AND ELECTRIC
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Docket No. 50-358 COMPANY, et al.
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o (Wm. H. Zimmer Nuclear Power
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Cig Counsel for Applicants y
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5 1747 Pennsylvania Avenue, N.W.
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20006 NRC STAFF SECOND INTERROGATORIES TO APPLICANTS The NRC Staff hereby requires the Applicants, the Cincinnati Gas and Electric Company, Columbus and Southern Ohio Electric Company and The Dayton Power and Light Company, pursuant to 10 C.F.R. E 2.740(b), to answer separately and fully, in writing, and under oath or affirmation, the following interro-gatories o1 or before January 15, 1981.
These interrogatories all pertain to a document titled:
PELIMINARY EVACUATION TIME STUDY OF THE PLUME EXPOSURE EMERGENCY PLANNING ZONE AROUND THE WM. H. ZIMMER NUCLEAR POWER STATION UNIT 1 Prepared for The Cincinnati Gas & Electric Company Columbus and Southern Ohio Electric Company The Dayton Power and Light Company August 1980 3
by 2
Stone & Webster Engineering Corporation New York, New York The aforesaid described document is hereinafter referred to as S & W Study, copy attached.
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i 1.
Identify by interrogatory number the names, addresses, place of employment and position therein, of all persons who answered, or contributed to each such answer, excluding clerical personnel.
2.
Set forth a statement of professional qualifications for each person identified in answer to Interrogatory 1.
3.
Identify by name, address, place of employment and position therein, of 1
all persons who contributed to the S & W Study, excluding clerical personnel.
4.
Provide a statement of professional qualifications for each person identified in' answer to Interrogatory 3.
5.
Identify specifically and in detail the contribution to the S & W Study made by each person identified in answer to Interrogatory 3.
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6.
Identify in terms of hours, the time spent on the S & W Study by each person identified in answer to Interrogatory 3, specifying where these hours j
were spent, i.e., in New York City, in travel, in Kentucky, etc.
i 7.
Identify all State and local government agencies contacted in making the S & W Study, setting-forth the names of the persons contacted, the dates of i
the contact, and who, on behalf of the licensees, made such contact.
8.
Sumarize the subjects discussed and the conclusions reached.in all f
meetings with State and local government agencies while preparing the S & W Study.
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. 9.
Specify in detail the criteria and parameters which define a "Best estimate" as that term is used on S & W Study page 1-1, line 21.,
Set forth all assump-tions and judgments used indefining that term.
10.
Identify all studies and set forth all methodologies and calculations employed which resulted in the conclusion that the evacuation time of general population in Zone I for adverse weather would be 10% longer than the best estimation evacuation time.
11.
Identify, zone by zone, in detail all physical and demographic differences among the zones which caused the adverse weather general population evacuation i
to vary from a 10% increase in Zone I for adverse weather as opposed to best estimate, to a-34% increase in Zones I, III, VII for adverse weather as opposed to best estimate, and identify the specific contribution of each identified 3
difference to the increase in evacuation time among all of the adverse weather l
general.c;.alation evacuation time estimates in Figure 3-1.
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- 12. Define and quantify "Particulary severe winter weather conditions or
' severe flooding" as those terms are used on lines 39 and 40, page 1-2 S&W Study and quantitatively identify the differences between the terms quoted above and " adverse weather" as used in Figure 3-1.
- 13. Set forth the criteria and parameters which define " adverse weather" as those terms are used in Figure 3-1 S & W Study.
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. 14.
Identify by route number and number of persons the routes and. population referred to in lines 41 and 42 on page 1-2 S & W Study.
- 15. Describe the methodology, calculations and analysis which are the basis of the S&W Study statement that "a number of alternative evacuation routes are generally available and_a part of the affected population may already have been evacuated" (S & W Study, page 1-2, lines 39-43).
- 16. Zone by zone - identify all physical and demographic features which cause adverse weather evacuation times to be 5'to 25% higher without a prompt notification. system while 10 to 35% higher (S & W Study, pp._1.2 and 3.1) with a prompt notification. Your answer should account for the differences in the increased evacuation time.
1 17.
Identify in detail the parameters of adverse weather assumed by'the-State and local planners listed in the S & W Study (bottom of p. 3-1) and 3
contrast them with the parameters assumed in the S & W Study (S & W Study,
- p. 3-2, lines 9 and 10).
- 18. -The S & W Study assumed adverse weather would reduce road capacity and speeds by 50% (S & W Study, p. 3-2, line 11) yet evacuation time was increased 10 to 35% (S & W Study, p. 3-1, line 20). Explain the rationale for your conclusion.-
- 19. Have the Applicants or any one on their behalf prior to August 1980 empirically verified that adverse weather would reduce road speeds'and capacity 1
- by 50% (S & W Study p. 3-2).
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- 20. Do the_ Applicants know of any empirical verification of the 50% reduction in road speed and capacity assumed to occur in adverse weather?
21.
If the response to Interrogatories 19 and/or 20 is affirmative, fully l
set forth that empirical verification in detail.
- 22. Have the. Applicants or any one on their behalf empirically verified that evacuation times would increase 10 to 35% in adverse weather (S & W Study, p.
3-1).
- 23. Do the Applicants know of ?ny empirical verificatica of the asserted 10 to 35% increase in evacuation time during adverse weather (S & W Study, p.
3-1).
- 24. 'If the response to Interrogatories 22 and 23 is affirmative, fully set forth, zone by zone, that empirical verification in detail.
- 25. Footnote 3 to Table 5-1, page 5-11, S & W Study, indicates that evacuation route average capacity in vehicles per hour was derived from l
reference 3 and reference 5.
Explain how the capacities in Table 5-1 l
were so derived; cite by page and line number the use made of reference 3 and reference 5; include your methodology; include your calculations; include your assumptions; and describe your field work.
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- 26. Provide a description, including all assumptions, calculations and field work, in detail of how the S & W Study concluded that CR743 and CR756
.have an average capacity of 1,000 vehicles per hour under emergency I
evacuation circumstances.. This interrogatory relates to the S & W Study conclusion set forth on Table 5-1, page 5-10, of the S & W Study.
Respectfully submitted, 4
Y Charles A. Barth Counsel for NRC-Staff Dated at Bethesda, Maryland 4
this 9th day of December, 1980.
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PRILIMINARY EVACUATION TIME S~CY i
OF THE PLUME r :POSURE EMEROENCY PLANNING ZO!E AROU?C.r.:
WM. H.4 ZIMMER NUCLEAR POWER STATION i
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