ML20003D204
| ML20003D204 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/09/1981 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8103190565 | |
| Download: ML20003D204 (9) | |
Text
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March 9, 1981 U Il,1.a UNITED STATES OF AMERICA DC0 5 00 i
NUCLEAR REGULATORY COMMISSION
- i. ~ x BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9
),gg g g g In the Matter of
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y EXAS UTILITIES GENERATING
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Docket Nos.50-44h'.
ANY, et al.
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50-446 ( y l
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[
e Peak Steam Electric
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(Application for 9
n, Units 1 and 2)
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Operating License) mag
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APPLICANTS' ANSWERS TO Sk%
CASE'S FOURTH SET OF INTERROGATORIES A
/
rsuant to 10 C.F.R.
$2.740(b), Texas Utilities Gener-ating Company, et al.
(" Applicants") hereby submit answers to " CASE's Fourth Set of Interrogatories to Applicants," dated February 17, 1981.
Applicants will respond to CASE's Requests to Produce included in its Fourth Set of Interrogatories pursuant to and on the schedule set forth in 10 C.F.R. $2.741(d).
ANSWERS TO CASE'S INTERROGATORIES Each answer is identified by the number of the corresponding interrogatory as set forth in CASE's Fourth Set of Interroga-tories.
1.
Appi.icants have provided the financial information, as l
required by 10 C.F.R.
f50.33(f) and 10 C.F.R. Part 50, 1
Appendix C, to enable the ~%mmission to make the findings required by 10 C..t.R.
$50.57(a)(4) regarding the Applicants' financial qualifications.
The NRC Staff may request additional information as part of their review of the Applicants' financial qualifica-tions.
See answer to Interrogatory 5, below.
2.
(a)
The financial information required by 10 C.F.R.
$50.33(f) and 10 C.F.R. Part 50, Appendix C was submitted to the NRC in the Comanche Peak Steam Electric Station Application for Operating License, April 21, 1978.
8108190 6 I
. (b)
Applicants will respond to this request for production of documents pursuant to and on the schedule provided in 10 C.F.R. $2.740(d).
(c)
The Applicants have provided and will provide as required annual financial reports.
3.
NRC regulations governing financial qualifications of an applicant for a power reactor operating license (10 C.F.R. 550.33(f) and 10 C.F.R. Part 50, Appendix C) require that the licensee possess or have reasonable assurance of obtaining the funds necessary to cover its share of the estimated costs of operation for each of the first five years of operation plus the estimated costs of permanently shutting down the facility and maintaining it in a safe condition.
Each of the participants in the Comanche Peak project has the financial qualifications to carry out, in accordance with these regulations, the activities for which the operating license for Comanche Peak is sought.
4.
Not applicable.
5.
Appropriate information has been submitted to NRC which demonstrates that DP&L, TESCO and TP&L all have reason-able assurance of obtaining the funds necessary to cover their share of the estimated costs of operation for each of the first five years of operation plus the estimated costs of permanently shutting down the facility and maintaining it in a safe condition.
As to BEPC, TMPA and Tex-La, Applicants also anticipate l
mmending the. operating license application to update financial information, particularly concerning TMPA and l
BEPC, and to provide financial information regarding l
Tex-La.
Applicants also anticipate responding to NRC l
Staff questions on financial matters.
The above information will be available when it is submitted to the NRC Staff.
6.
See response to Interrogatory 5.
7.
See response to Interrogatory 5.
8.
Not applicable.
i 9.
Only that listed in the response to Interrogatories 2(a) and 2(c).
. 10.
See response to Interrogatories 2(a) and 2(c).
11.
See response to Interrogatory 2(b).
12.
Applicants object to this interrogatory as irrelevant.
Contention 22 is not the Applicants' contention.
Applicants are not required to explain what Intervenors intend with respect to the language of Contention 22.
13.
Applicants believe the Comanche Peak Emergency Plan meets applicable requirements established pursuant to the provisions of and the schedule for compliance in 10 C.F.R.
$50.47 and Part 50, Appendix E.
14.
See response to Interrogatory 13.
15.
The Texas Utilities Corporate office will provide supplemental support for the CPSES Emergency Plan as required to comply with the requirements of 10 C.F.R. Part 50, Appendix E.
Specific details of this corpo-rate support will be described in the appropriate implementing procedures which will be submitted to the NRC at least 180 days prior to fuel load, as indicated in the February 12, 1981 letter from Nicholas S.
Reynolds to CASE.
16.
(a)(1) and (2)
No.
TUGCO is in regular contact with l
all the state and local planning authorities, agencies, and service i
organizations from which letters of l
agreement have been obtained, including the Hood and Somervell Counties Sheriffs' Departments, and is in the process of apprising them regarding the responsi-bilities of each in the Comanche Peak Emergency Plan.
Prior to operation of Comanche Peak, these individuals and organizations will be fully apprised of all appropriate regulations and criteria in effect at that time.
(b)
Not applicable.
l (c)
Not applicable.
l l
17.
(a)
Yes.
l (b)
Not applicable.
l l
I (c)
See response to Interrogatories 16 (a)(1) and (2).
(d)
Yes.
(e)
Not applicable.
(f)
See response to Interrogatories 16 (a)(1) and (2).
(g)
Not applicable.
(h)
Not applicable.
(i)
Not applicable.
18.
(a)
Contaminated injured individuals will not be trans-ported to the Marks-English Hospital in Glen Rose.
As stated in Paragraph 4.3.1.4 and Paragraph 6.6.4 of the Comanche Peak Emergency Plan, contaminated injured individuals will be transported only to Hood General Hospital in Granbury.
There is no need or requirement for making a prior agreement with Marks-English Hospital for treating any injuries that do not involve radioactive contamina-tion.
(b)
Not applicable.
(c)
See response to Interrogatories 16 (a)(1) and (2).
(d)
No.
(e)
Yes.
j (f)
(1)
We are not aware of the reasons for this.
t (2)
See response to f(l) above.
l (3)
Joe S. Langford.
(4)
Hood General Hospital Administrator.
(5)
Yes.
l (6)
See response to f(l) above.
l (7)
See response to f(1) above.
(8)
See response to f(1) above.
(9)
Yes.
(g)
Not applicable.
(h)
Not applicable.
l i
. 19.
(a)
Radiation Management Corporation is a consultant to Applicants for the furnishing of services involving the Emergency Medical Assistance Program for Comanche Peak.
As such, RMC is aware of the requirements in NUREG-0654, Rev. 1 (November 1980).
The Emergency Medical Assistance Program is being reviewed to assure its compatibility with all current NRC regulations and criteria.
(b)
None.
(c)
None.
(d)
(1)
No.
(2)
Not applicable.
(3)
Not applicable.
(4)
Not applicable.
(e)
(1)
No.
(2)
Not applicable.
(3)
Not applicable.
(4)
Not applicable.
(f)
(1)
No.
(2)
Not applicable.
(3)
Not applicable.
(g)
(1)
No.
(2)
Not applicable.
(3)
Not applicable.
(4)
No.
(5)
Not applicable.
l (6)
Not applicable.
l (7)
Not applicable.
i (8)
Not applicable.
l (9)
Not applicable.
l (10)
Not applicable.
l (h)
(1)
Not applicable, refer to response to l
Interrogatory 19 (g) (4).
(2)
Not applicable.
(3)
Not applicable.
I f
l (i)
(1)
No.
(2)
Not applicable.
(3)
Not applicable.
Respec ly submitted, f
Nicho] ys Reynolds
(
h am O.
William A.
Horin DEBEVOISE & LIBERMAN 1200 - 17th Street, N.W.
Washington, D.C.
20036 (202) 857-9817 Counsel for Applicants 1
i March 9, 1981 l
l
STATE OF TEXAS
)
)
COUNTY OF DALLAS
)
Homer C. Schmidt, being duly sworn, deposes and says:
That he is Manager, Nuclear Services, Texas Utilities Services, Inc., and knows the contents of the foregoing Applicants' Answers to CASE's Fourth Set of Interrogatories; that the same is true of his own knowledge except as to matters therein stated on infonnation and belief, and as to that, he believes them to be true.
f j
SWORN to and subscribed before me on this 5th day of March,1981.
t 1,
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s
. u m e.
Notary Public l
My Comission Expires: N-I 1
L i
i 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 COMPANY, et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating License)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Answers to CASE's Fourth Set of Interrogatories", in the above captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 9th day of March, 1981:
Valentine B. Deale, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W.
Commission Washington, D.C.
20036 Washington, D.C.
20555 Dr. Forrest J.
Remick, Member Marjorie Ulman Rothschild, Esq.
Atomic Safety and Licensing Office of the Executive Board Legal Director l
305 E.
Hamilton Avenue U.S. Nuclear Regulatory j
state College, Pennsylvania 16801 Commission l
Washington, D.C.
20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J.
Preister, Esq.
Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C.
20555 P.O.
Box 12548 Capitol S'ation t
l Chairman,. Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Mr. Richard L.
Fouke Commission CFUR Washington, D.C.
20555 1668B Carter Drive Arlington, Texas 76010 l
l
i
\\
- Arch C. McColl, III, Esq.
Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services Suite 302 100 Main Street (Lawyers Bldg.)
Dallaa, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq.
Mr. Chase R.
Stephens 4021 Prescott Avenue Docketing & Service Branch Dallas, Texas 75219 U.S.
Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C.
20555 President, CASE 1426 South Folk Street Dallas, Texas 75224
()
d.
~
William A.
Horin cc:
Homer C.
Schmidt Spencer C.
Relyea, Esq.
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