ML20010C580

Interrogatories Directed to NRC Re Emergency Planning & TMI-2 Related Issues.Related Correspondence

ML20010C580
Person / Time
Site:	05000471
Issue date:	08/14/1981
From:	Cleeton A, Cleeton M CLEETON, INTERVENORS
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20010C581	List: ML20010C580 ML20010C585
References
NUDOCS 8108200213
Download: ML20010C580 (5)

Text

.< .

- fik .

nt.fcL t.

~ -

lQ UNITED STATES OF AME'RICA $ ""~ C  !

NUCLEAR REGULATORY COMMISSION- Q ,

.l ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'In the Matter of )

)

BOSTON EDISON COMPANY, et al. -

) Docket No. 50-471

)

(Pilgrim

• Nuclear Generating Station, ) p Unit 2) )

,Q"qM{$ ' -

6D INTERVENOR CLEETONS' INTERROGATOR _IES g\@\f _

TO NUCLEAR REGULATORY COMMISSION STAF 4 #c'c RELATIVE TO EMERGENCY PLANNING.D b 3'1 -

AND TMI-2 RELATED ISSUES \ # Y f

Pursuant to 10 C. F. R. Section 2. 720 (h) (2) (ii), the Intervenor Cleetons requests that the attached Interrogatories be answered fully, in writing, and under oath by NRC personnel (hereinafter, " Staff") with the knowledge of the facts and designated by the Executive Director for Opera-tions. ,

Please answer each question in six parts as follows:

-A. Provide the direct answer to the question.

B. Identify each document, and the particular parts thereof, which in any way serves as a basis for the answer.

C. Identify all documents known to the Staff which per-tain to the subject matter questioned h.it which do not l serve as bases for the Staff's answer, including doc-uments which provide or support an answer different from that provided by the_ Staff. Dgo3 3

/ /

0108200213 810814 DR ADOCK 05000 7

• 2. l l

D. Set forth the name, affiliation and title of each individual  !

who participated in any way in the preparation of the Staff's answer, whether or not said individual is an official or em-ployee of the NRC. -

E. Set forth the name and title of any Staff member who did not participate in the preparation of the Staff's answer and who has, or may have, more direct personal knowledge of the subject matter of the question that the individual (s) identi-fled in Section D.

F. Identify the person (s), if any. 90m the Staff intends to have testify on the subject matter que.::tioned and state their qualifications.

For purposes of these requests, the term " document (s)" refers to the original and copy (but not both if identical in every respect) of any

. printed, written, recorded, transcribed, punched, taped, filmed, photo-graphed or graphic matter, whether sent or received or neither, whether a draft or otherwise, however produced or reproduced, and both sides thereof, including but not limited to, any memorandum, correspondence, letter, affidavit, court paper, transcript, diary, report, study, telegram, table, telex message, record, chart, paper, work paper, graph, index, book notebook, pamphlet, periodical, tape, data sheet, data processing card, note, notation, minute desk calendar, appointment book, sound re-cording, computer print-out or microfilm.

INTERROGATORIES

1. What was the state of emergency preparedness in the Harrisburg area .

and in the Commonwealth of Pennsylvania on March 28,1979? Please ex-plain fully and in detail.

i .

t .. _.

3

,- ' 3,

2. Had Metropolitan Edison and the Commonwealth of Pennsylvania conducted any tests of emergency preparedness? Had they checked supplies, hospital readiness, traffic control plans and security troop emplacement for the pro--

tection of citizens and their property around the TMI complex? Please des-cribe fully and give all bases for your ' answer.

3. In the opinion of Staff is the state of emergency preparedness in the im-mediate and extended area around the proposed Pilgrim II less adequate, equal to, or better than that around TMI-2 on March 28,1979? Please de-tail all differences and similarities.

~

4. To Staff's knowledge have any of the emergency planners spent more than a few hours inspecting specific problem areas described in the studies for evacuation at Pilgrim II ? Please give full details of time spent, methods used, and qualifications of planners.

5. If a thorough study has not been done, why has a matter so crucial to the health and safety of the public been ignored?

6. We were told by Mr. Froelich, of the Environmental Protection Division of the NRC, that the NRC had an evacuation plan for Cape Cod. What is the evacuation plan? Please describe in detail.

7. If the NRC has no plan for evacuating Cape Cod, does the Federal Emer-gency Management Agency have such a plan? Please describe fully.

. 8. If there are no plans for evacuating Cape Cod, what are the reasons that a matter so essential to the health and safety preparedness of the public been neglected? Please list all reasons.

l i

- ' 4. i

r. 9. Does Staff know whether any study of the voluntary, partial (pregnant

j. women and small children), and general evac'uation,which took place after the accident at TMI-2,have been done? Please give full results of such a i study. >

10. If a study of these evacuations has not been done, why has this excellent

opportunity to learn more about the health and safety needs, and the behavior,. ,

of the public in an actual emergency been overlooked? Please explain fully.

. 11.- What study has been conducted by the NRC, or by any agency or person (s) commissioned by the NRC, or by any other person (s), concerning the biological effects of ionizing radiation upon the general population in the immediate and i extended areas surrounding TMI-2? What are the detailed findings, to date, of this study? What future health problems are projected?

12. If the study referred to in 11 has not been done, when is such a study

planned? Why has a study so vital to the health and safety of the public been a

)

delayed? Please give a full explanation.

4

13. Has the NRC, or any person (s) or organization, conducted a study of I persons in the immediate and extended area around TMI-2, who are at spe-l cial risk, like Mrs. Cleeton? (See attached letter) This would include persons with respiratory illness, extended irradiation through medical and dental x-rays, radiation therapy, and/or a family history of cancer. If so, what are the findings? Please give full details.

14. If such a study has nec been done, why has/ matter which would neces-i sarily involve the health and safety of a substantial percentage of the public t

.been disregarded? Please explain fully.

. .- - . . - - - , - _ _ . . . - . . . . , , ,, _ . . .,,_m,, .. ; .=n:.- ,. -n

-' 5 4

15. Has a study been done of the psychological and economic effects of the-accident at TMI-27 How many people have had to sell their homes at a loss, in order to leave the area? Hok* many people have had to consult psycholo-gists or psychiatrists due to their concerns about the hedth and safety of themselves and their fanilies? Please list all findings of such a study.

16. H such a study has not been done, can Staff explain why a matter deeply  :

involving the health and safety of the public, as well as their economic wel-fare, has been omitted from consideration?

17. In previous hearings an opportunity for limited appearance statements from local citizens was deferred until the hearings on emergency planning.

In Staff's opinion, at what times and locations are those limited appearance statements likely to be authorized?

Respectfully submitted, (a't .

,%/a w m a Alan R. Cleeton Intervenors, Marion W. Cleeton Pro Se 22 Mackintosh Road Franklin, MA 02038 (617) 528-2610  ;

i 6

_