ML20003B520

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Answers to Applicant 810112 Second Set of Interrogatories & Requests to Produce.Contention 22 Re Emergency Planning & Contention 25 Re Applicant Financial Qualifications Are Addressed.Certificate of Svc Encl.Related Correspondence
ML20003B520
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/06/1981
From: Ellis J
Citizens Association for Sound Energy
To:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8102120327
Download: ML20003B520 (9)
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Text

'" W M CORRESPORDE.N:2 g D h 2/6/81 b k;.  %

V UNITED STATES OF A)GRICA ,

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BEFORE THE ATO(IC SAFETY AND LICENSIF, BOARD g ,'.

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In the Matter of l N j ; g M/

{ Docket Nos. 50 hA5 APPLICATION OF TEXAS ITJILITIES OENERATING COMPANY, ET AL. FOR AN

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l and 50 k46 e s OPERATING LICEESk FOR C34ANCHE 4 -

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PEAK STEAM ELECTRIC STATION l ([ [ m-'e'Q,\,

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OF INTERROGATORIES AND REQUESTS TO PRODUCE

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CCMES N0'4 CASE (Citi:: ens Association for Scund Energy), hereinafter referred to as CASE, Intervenor herein, and files this, its Answers to Applicants' Secend Set of Interrogatories and Requests to Produce,1 dated January 12, 1981, and received by CASE cn January 17, 1961.

ANS'4ERS

. CONTENTION 2: Applicants have failed to ec= ply with 10 CFR Part 50, Appendix E, regarding emergency planning, for the following reasons:

1 a.

The FSAR does not identify & tate or regional authorities responsible for emergency planning or who have special qualifications for dealing vita emergencies.

b. i No a6reements have been reached with local and state officials and agencies i for the early warning and evacuation of the public, including the identi- I fication of the principal officials oy titles and agencies.

On January 26, 1961, in telerhene ccnversations vita Mr. '41111a= Horin and Mr. Valentine Deale, it was agreed that Applicants have no objection to an extention of time of filing tnis respcase till February 6 (instead of January 31,1931), and CASE was granted such extension.

This extension was necessary due to illness of CASE's primary representative.

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c. There is no description of the arrangements for services of pnysicians and other =edical personnel qualifiec to handla radiation emergencies and arrangements for tne transportatica of injured or contaminated individuals bey .d the site boundary,
d. There are no a'aquate plans for testing by periodic drills of emergency plans and provisions for participation in the drills by persons whose assistance may be needed, otner nan employees of the Applicants.
e. There is no provision for medical facilities in the tamediate vicinity of the site, voich includes Glen Rose; and
f. There is no provision for emergency planning for Glen Rose or the Dallas /Ft. Worth metroplex. *

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,1-2. The present wording of Contention 22 is CASE's evn wording; see 5/7/79 Supplement to Petition for Leave to Intervene and Contentions by CASE (hereinafter referred to as CASE's 5/7/79 Contentions), pages 40, kl and h2.

2-2. 10 CFR Appendix ^ E to Part 50; NUREG-065L, FEMA-REP-1, Rev.1, whien CASE is in tce process of reviewing, along with related documents; and CASE's 5/7/79 Contentions, pages 40, L1, and 42, and CAE 's /10/50 Position on Contentions, pages 43 and Lk.

1~2: N0' L-2. No.

5-2. None. We vill probably have future meetings with ACORN regaraing 22.f.

since ve are now consolidated on this portion of this contention.

6-2. None.

7-2. Yes. Unknown at this time.

l

%2. Probably. Unknown at this time.

9-2. Probably. Unknown at this time.

10-2. Unknown at this time.

l 11-2. Yes. However, we have not yet reviewed the most recent revisions and are unable to state at this time vnat oearing tney may nave on this contention, l if any. With regard to the Applicants' Emergency Plan, we nave some questions regarding certain aspects of it and vill oe asking scce interrogatories regard-I ing it in the near future when ve have completed our review and analysis. Thus, ve are not at this time in a position to fully respond to this question and its sub-parts; we vill update our response later.

a. See Answer to 11-2 aoove.

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11-2 (continued): .

b. See answer to 11-2.
c. See answer to 11-2.

12-2. Those specified in NRC final regidntions (NUREG-0654 and related documents and other regulations which are in tne process of being developed at the present time). =e will be supplementing this answer later. See also answer to 11-2.

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13-2. See answer to 12-2.  !

14-2. See answer to 12-2.

15-2. See answer to 12-2. .

16-2. See answer to 12-2.

17-2. See answer to 12-2.

18-2. See answer to 12-2.

19-2. See answer to 12-2.

20-2. 10 CFR Appendix E to Part 50, NUREG-065h and related de:usents and other regu-lations which are in the process of being develcrea st the present time.

21-2. See answer to 12-2.

22-2. See answer to 12-2.

23-2. See answer to 12-2.

24-2. See ansv- to 12-2.

l 25-2. See answer to 20-2.

26-2. See answer to 12-2.

27-2. See answer to 12-2.

28-2. See answer to 12-2.

2o-2. See answer to 12-2.

30-2. See answer to 12-2.

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31-2. See answer to 12-2.

E See answer to 20-2.

M See answer to 12-2.

34-2. See answer to 12-2.

35-2. See answer to 20-2.

36-2. See answer to 12-2.

37 See answer to 12-2.

[

F-38-2. See answer to 12-2. -

M See answer to 20-2'.

ko-2. See answer to 12-2.

41-2. See answer to 12-2.

k2-2. See answer to 20-2.

h?-2. See answer to 12-2.

j kk-2. See answer to 12-2.

45-2. See answer to 12-2.

ko-2. See answer to 12-2.

1 ,-

! h7-2. See answer to 20-2.

LS-2. See answer to 12-2.

i 49-2. See ansver to 12-2 and 20-2.

50-2. See answer to 20-2.

51-2. See ansver -to 12-2.

52-2. See answer to 12-2.

53-2. See answer to 12-2.

i 1

i 5k-2. See answer to 12-2.

- k-I l

55-2. See ansver to 12-2. e 56-2. See answer to 20-2.

57-2. See answer to 12-2.

58-2. See answer to 12-2.

54-2. Yes.

60-2.

For some areas of the Dallas /Ft. Worth metroplex, yes; perh4ps for some others.

61-2. Yes. See answer to 12-2.

62-2. See answer to 20-2.

63-2. See answer to 12-2.

6h-2. See answer to 12-2.

65-2. See answer to 12-2.

66-2. See answer to 12-2.

67-2. See answer to 12-2.

68-2. See answer to 12-2.

69-2. See answer to 12-2.

70-2. See answer to 12-2.

71-2. See answer to 12-2.

12-2. See answer to 12-2.

[

73-2. See answer to 12-2.  !

7h-2. See answer to 12-2.

75-2. See answer to 20-2.

76-2. See answer to 12-2. We have not yet analyzed tne precise areas.

77-2. See answer to 12-2 and 60-2. We have not yet analyzed the precise areas.

78-2.

See answer to 76-2 and 77-2. We have not yet analyzed the precise differences.

79-2. See answer to 20-2.

60-2. Not necessarily. See answers to 00-2 and 77-2.

51-2. N.A.

d2-2. See answer to 12-2.

83-2. See answer to 12-2.

Sh-2. See answer to 12-2.

  • i.

85-2. See answer to 12 2.

86-2. See answer to 20-2.

37-2. See answer to 12-2.

85-2. See answer to 20-2.

69-2. See answer to 12-2.

90-2. N.A. at this tine.

91-2. See answer to 20-2.

02-2. We have not thcroughly analyzed how the Applicants have fallen snort in their revised E=er5ency Plans; see answer to 12-2.

93-2. See answer to 20-2.

NOTE regarding Interrogatories en Emergency Planning:

At this point in time, we have not analyzed how the Applicants revised Emergency Plan may affect this contention; further, we are now in the process of analyzing NUREG-0654, Rev.1 and related documents. We are not trying to evade answering these interrogatories; hevever, we see no point in answering them based on out-dated and possibly nov erroneous information. We rally intend to update our responses to these interrogatories.

I' Contention 25 .

The requirements of the Atomic Energy Act, as maendec,10 CFR 50 57(a)(L) and 10 CFR So, Appendix C, have not eeen =et in tnat the Applicant is not financially qualified to operate tne proposed facility.

9L-2. The wording of tais contention is very straigntforwar: as stated above; we mean very simply that Applicants have not =et the require:ents of the referenced regulations and laws.

Without meeting those requirements, an operating license cannot be issued.

95-2. k In addition to that set forth in CASE's 5/7/79 Contentions (pages h3  ;

through 47, Old Contention 16) and CASE's h/10/c0 Contentions (pages k5 and

'6, old Contention 16), there have now been further rate hearings for the Texas i Utilities ccmpanies.

According to these eccpanies' sworn testtzony, the tnree 3 operatin6 co=panies of Texas Utilities are in constant jeopardy of havin6 their h Lond ratings lowered and starting down the road to financial disaster. Also, CASE is currently locking into the financial integrity of the other Applicants  :

in tne hearings; we vill supplement our answer as pertinent infonsation is developed.

96-2. No.

97-2. No.

90.2. None.

99.2. None.

100-2. Yes. Unknown at this time. We vill supplement our answer as appropriate.

101-2. Pro'cably. Unknown at this time.

102-2. Probably. Unknown at tnis ti=e.

103-2. Unknown at this time.

l 10L-2. Yes, to the extent incicated in answer 95-2.  !.

105-2. Not applicable (N.A.).  !

106-2.

See answer to 95-2. We expect to nave more inforzatica in response to interrogatories and req,uests for inspection of documents.

107-2.

None tnat we have seen so far would so indicate; bovever, we haven't seen all of them yet.

106-2. N.A.

l 100-2. See answer to 106-2.

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110-2.

Since there is disagreement as to tne start-up time of Comanche Peak we cannot supply this information at this time. ,

estimates as the basis of temporary estimates in the meanti=e.We vill accept the Ap 111-2.

Unknown at thisetc.

future interrogatories, time, pendin6 receipt of information we obtain from See answer to 106-2.

112-2. N.A. at this time.

113-2. N.A. at this time.

11h-2.

N . A . at this t ime .

115-2. N. A . at this time .

116-2. See answer to 106-2.

the Atomic Energy Act as amended, and 10 CFR 50, Appendix C.0f cours 117-2.

That required by the Atomic Energy Act and 10 CFR 50, Appendix C, which accurately demonstrates tne Applicants' true financial integrity.

, 116-2. See answer ta 117-2.

119-2.

I We have not yet reviewed the latest information supplied thoroughly , so ve are at this time unable to accurately answer this. We vill supplement our response to this interrogatory.

i 120-2. N.A. at this time.

1 21 - 2 . Yes.

122-2. See answer to 95-P, and 13 9-2.

123-2. Unknown; we have not made this analysis at this time.

Respectfully submitted,

, . > ~

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(Mrs.) Juanita Ellis, President

CASE (Citizens Association for Sound Energy)

! 1h26 S. Polk Dallas, TX 7522h 21h/9k6-9hh6 21L/9kl-1211, work, usually Tuesdays .

and Fridays '

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND L. CENSING BOARD In the Matter of I .

I APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENEPATING COMPANY, ET AL, FOR AN 1 and 50-446 OPERATING LICENSE FOR COMANCHE I PEAK STEAM ELECTRIC STATION I UNITS #1 AND #2-(CPSES) 1 CERTIFICATE OF SERVICE By =y signature belev, I hereby certify that a true and correct copy' of CASE'S ANSWERS TO APPLICANTS' SECOND SET OF INTERROGATORIES AND REQ,UESTS TO PRODUCE vere sent to the following names, by First Class Maili this 6th day of February, 1981:

  • vith Certifieste of Mailing receipt  ;

+ Valentine B. Deale, Esq. , Chairman 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, Member 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. Reynolds, Esq. Atomic Safdty and Licensing Debevoise & Liberman Ap peal ' Panel 1200 - 17th St., N. W. U.'S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555

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l Marj orie Rothschild Docketing and Service Section Counsel for NRC Staff Office of the Secretary

, U. S. Nuclear Regulatory Commitsion U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 Washington, D. C. 20555 Mr. Geoffrey M. Gay Arch C. McColl, III, Esq.

West Texas Legal Services 7o1 c'cannerce Street, Suite 302 100 Main Street (Lawyers Bldg.) M as, H 75202 Fort Worth, TX 76102 , ~ . . . .

Jeffery L. Hart, Esq.. #

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kO21 Prescott Avenue N' N.. ;n-s -(Mrs.) Juanita Ellis, President Dallas, n 75219 g p Cy' CASE (CITIZENS ASSOCIATION FOR

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