ML20032D963
| ML20032D963 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/23/1981 |
| From: | Gilmore J CITIZENS FOR FAIR UTILITY REGULATION |
| To: | |
| References | |
| NUDOCS 8111190379 | |
| Download: ML20032D963 (3) | |
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00t.KETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EN 2 56 OFFICE OF SECRETARX UEFORE TiiE ATOMIC SAFETY AND LICENSING BOAD00KEllHG & SERylCt.
BRANCH In the Matter of
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TENAS UTILITIES GENERA. !G
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Docket Nos. 50-445 COMPANY. et al.
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50-446
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(Comanche Peak Steam Electric
)
( Application for Station, Units 1 and 2
)
Operating Licensep\\g k**
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[NOV13htl CFUR'S ANSWERS TO APPLICANT'S FOURTH SET OF INTERROGATORIES AND REQUESTS TO PRODUC1 e s. %
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Pursuant to 10. C.F.R. Section 2.740(b), Citizens for Fair Utility',/w Regulation: "CFUR" herely submit their answers to " Applicant's" Fourth-S of Interrogatories and Request.to Produce dated October 2,1981.
ANSWERS 1-4 Yes. Yes.
The methodology, information, data and analyses in the Final Environment;d St atement, "FES", for Comanche Peak, for purposes of Contention 9.ackJresses only average conditions based upon random releases of radioactive gases yet Applicant has the capacity to control its releases so as to minimize the exposure of the general public to such radioactive material.
Therefore CFUR's specific objection to such information is that it is not sufficient to comply with 10 CFR Part. 20.l(c).
2-4 At the time CFUR responded to Applicant's Interrogatory 93-3 CFUR understood that Applicant's position was that there would be no planned releases from Comanche Peak. Applicant has since taken the position that there will be anywhere from twelve to eighty planned releases per year on m average in its letter of 9/25/81 f rom llomer C. Schmidt. Identi ficatior of sources of such leakages or creditable compromice are therefore moot at this time in that Contention 9 deals with the manner in which those releases should be made, not where they are coming from.
3-4 As stated in answer to 2 - 4 hereof Applicant admits that it will make planned releases of radioactive materials. Contention 9 as defined earlier by CFUR s*
8111190379 811023 h#
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s relates to how those relca,e3 are conducted. The Applicant is required to know what radioactive elements are capable of being released in gaseous form and t he.,ource of its release.
4-4 CFUR expects the Applicant to comply with all NRC regulations concerning containable transients and /or accidents.
5-4 Table 5.7 of the FES indicates average atmospheric disbusions factors arid deposition values for maximum sight boundary and receptor Iccations near CPSES. CFUR contends that the Applicant is obligated to minimize cumulative person-rem exposure by choosing optimum meterological conditions which affect the particular subject area. In choosing such optimur' metero-logical conclitions the methodology should include the factor that the Applicant can pur aosefully time such planned releases.
6-4 CFUR Contention 9 is con :erned with cumulative person-rem exposure rather than maximum individual dose commitments.
7-4 Applicants have control over timing of releases so as to take into consideration the direction of the wind and other meterological factors. T he refore, for instance, use of mean directional wind calculations is improper methodology.
8-4 That geographical region which corresponds to and contains ninety-five percent (9;",) of the total body perdon-rem and person thyroid-rem exposuren from radioactive material releases at Comanche Peak.
Respectfully submitted,
/jp J. MARSHi mL GILMORE CFUR 1060 W. Pipeline Road Hurst. TX 76053.
~WCSDr.NCE te1' M k OxKETED USN3C UNITi:D STATES OF AMERICA l
N UCLI.AR iiEG ULATORY COMMISSION l
in DCT P2:56 BEFORE Ti!L ATOMIC SAFETY AND LICENSING COARD OFFICE OF SECRETA?.c DOOKETING & SERVitt-
.in t he Matter of
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BRANCH
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TEX AS UTILITIES GENER ATING
)
Docket Nos. 50-445 COMPANY et al.
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50-446
)
(Comanche Peak Ste.im Elect rit
)
Station, Units 1 and 2
)
( Application for
)
Operating Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing instrument in the above captioned matter were served upon the following persons by deposit in the United States mail, first class posyge prepaid this l$ day of(1-db 1981.
Chairman, Atomic Safety &
., a rs h all z... Miller, L.sq.
Chairman, a, tomic b. fet y and Licensing n, ppeal Panel a
U. S. h.uclear Regulatory Commission Licensin"" noard l',.as hin g ton, D. C. 20...333 U.
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5 uclear Reguiatory C.ommission
'/lashin gton. D.C. 205 55 Dav.d J. Preister. : sq.
i Dr. K.ennet.n A. McC,ullom Assistant Attorney General Environmental Protection D.ivision Dean, Division of En cineerine,.
architecture &.I'echnolo.;y P.O. Box 1234S Capitol Station x ustin, T.\\.
ll soi Oklahoma State University Stillwater. Oklahoma 74074 J..,d a rs h a,d Gilmore,1.sq.
Dr. R. hard Cole, Member 1060 l'i. Pipeline ic H urs t,
N.,.60 3 3 i
atomic S. fety & Licensing Baird a
U.S. Nuclear Regulatot y Commirion Mrs. J uanita r.lb.s
..ashin gton, D. C. 20 30 Presiden t, C a, d t.
1426 South Polk Street C hai rman, n. iomic S.a fet y & Licensing Dallas,
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- oarn Pane!
U.S. Nuclear Regulatory Com ninion
.dr. C. nase R. Stephc:as
.c as hi n gto n D. C,.
,0 3 3 3 Docketing L Service Branch U.S. Nuc! car Regulatory Commission
,,a riorie L.im a n d.oi n.sc nild. E.da.
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.,0 3 3 3 U: tice of the i.xec utive Legal Director U.S. Nuclear Reg ulator y Comn.i s., ion t.
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F.ouke a.s u n g t o n. D. C..
fbn l o, o, 5-B Cart e r D r.
Arhngton, TN 76010 I
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