ML20042B748
| ML20042B748 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/23/1982 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8203250612 | |
| Download: ML20042B748 (14) | |
Text
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v3 Merch 23, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 7 BOAR $ '33 U
In the Matter of
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)
TEXAS UTILITIES GENERATING
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Docket Nos. 50-445 and COMPANY, et al.
)
50-446
~~~
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating Licenses)
~
APPLICANTS' FOURTH SET OF INTERROGATORIES TO CASE AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. SS 2.740b and 2.741, Texas Utilities Generating Co., et al.
(" Applicants") hereby serve Applicants' Fourth Set of Interrogatories and Requests to Produce upon i
Citizens Association for Sound Energy
(" CASE").
Each interroga-tory shall be answered fully in writing, under oath or affirma-tion, and include all pertinent information known to CASE, its officers, directors or members as well as any pertinent informa-tion known to its employees, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control or CASE, its officers, directors or members as well as its employees, advisors or counsel.
In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceeding each MD answer or response.
Also,ypleaseeldentify the person providing
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each answer or response.
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These interrogatories and requests shall be continuing in n ature.
Thus, any time CASE obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, CASE should supplement its previous response to the appropriate interrogatory or request to produce.
CASE should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony.
The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained, whether prepared by CASE or by another person. We request that at a date or dates to be agreed upon, CASE make available for inspectic7 and copying, all documents subject to the requests set forth below.
These interrogatories are based on those. aspects of Contention 22 which do not rely upon the existence of State and local emergency plans for resolution.
Upon submittal of those plans, Applicants will submit additional interrogatories based l
on the remaining portions of Contention 22.
Applicants believe those plans will be submitted in the near future.
Thus, sub-mission of the instant discovery requests at thi.s time will lighten the discovery load anticipated with respect to those plans.
. These interrogatories seek specification of CASE's position on information which is set forth in the Comanche' Peak Emergency Plan, as revised October 26, 1981.
This revision was made after Applicants' previous interrogatories to CASE on Contention 22 were filed.
Thus, Applicants have.not yet conducted discovery against CASE based on the revised Plan.
CASE has received a copy'of the Plan as Amendment 28 to the
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Comanche Peak FSAR.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contention 22.
Applicants have failed to comply with 10 C.F.R. Part 50, Appendix E, regarding emergency planning, for the following reasons:
a.
The FSAR does not identify state or regional authorities responsible for emergency planning or who have special qualifications for dealing with emergencies.
This portion of Contention 22 contends that the Comanche Peak Emergency Plan does not identify state or regional authorities responsible for emergency planning.
Applicants have identified in their Emergency Plan organizations which will support any response to an emergency at the Comanche Peak site.
See Emergency Plan S 4.3.
Accordingly, please provide responses to the following questions.
s
. 1-4.1/ oes CASE contend that Applicants' identification of the D
federal, State and local authorities with responsibilities for emergency planning and for responding in the event of a radiological emergency (Section 4.3 of the Comanche Peak Emergency Plan) is inadequate, incomplete, erroneous or otherwise not in compliance with applicable regulations?
2-4.
If the response to Interrogatory 1-4 is in the affirmative, specify any additional " authorities" which CASE contends should be identified.
3-4.
For each authority listed in the response to Interrogatory 2-4, specify the role which CASE contends the authority should play in the event of a radiological emergency.
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4-4.
What are.the bases for your responses to Interrogatories l-4 through 3-4?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
5-4.
Does CASE contend that any of the organizations identified in the Emergency Plan should not be included therein?
6-4.
If the response to Interrogatory 5-4 is in the affirmative, please identify those organizations and set forth the reasons CASE contends each should not be included in the Comanche Peak Emergency Plan.
7-4.
What are the bases for your response to Interrogatory 6-4?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
8-4.
Does Case contend that Applicants have not adequately described the role of each of the support organizations
-identified in Section 4.3 of the Comanche Peak Emergency Plan?
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-1/
Applicants have identified these Interrogatories as the Fourth Set to CASE by the hyphen 4 following each number.
Please respond for each of the following:
Hood and Somervell County bmergency Organizations a.
b.
Hood and Somervell County Sherriff's Departments c.
.Somervell County and Granbury Fire Departments d.
Somervell County and Hood General Hospital Ambulance Services e.
Hood General and Marks English Hospitals f.
Radiation Managenent Corporation g.
Squaw Creek Park, Inc.
h.
Texas Department of Health i.
Texas Department of Public Safety j.
FEMA k.
NRC 1.
DOE 9-4.
If the response to Interrogatory 8-4 is in the affirmative with respect to any of the listed organizations, please describe specifically what required information CASE contends has not been included for each of those organizations.
10-4.
For each of the organizations listed in Interrogatory 8-4 for which CASE contends additional information must be provided, please specify the particular regulatory requirement on which CASE relies for its position.
11-4.
Please set forth the bases in addition to the information provided in response to Interrogatory 10-4 for CASE's responses to Interrogatories 8-4 and 9-4.
Identify any documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
12-4.
Are there any state, local or federal authorities which CASE contends have "special qualifications for dealing with emergencies" which must be but have not been identified in the Comanche Peak Emergency Plan?
13-4.
If the response to Interrogatory 12-4 is in the affirmative, please identify each of those organizations and describe the "special qualifications" which CASE contends they have.
14-4.
Please set forth the bases for your responses to Interrogatories 12-4 and 13-4.
Identify all documents, testinony or oral statements by any person and legal requirements on which CASE relies in support of its position.
. 15-4.
Does CASE contend that there are any other NRC requirements besides 10 C.F.R. Part 50, Appendix E, Sections IV.A.7 and IV.A.8, and NUREG-0654 2/ Section II, Part A.l.a that are applicable to Contention 22.a?
16-4.
If the response to Interrogatory 15-4 is in the affirmative, please specify each NRC requirement which CASE contends is applicable to Contention 22.a.
Contenzion 22.
b.
No agreements have been reached with local and state officials and agencies for the e'arly warning and evacuation of the public, including the identification of the principal officials by titles and agencies.
This aspect of Contention 22 concerns the agreements made between the Applicants and local and state officials and agencies for participation in emergency plan implementation and the identification of the principal officials involved.
Applicants believe that the information set forth in Section 4.3 and Appendix H of their Emergency Plan responds to this concern.
In this regard, please answer the following questions.
17-4.
Does CASE contend that the agreements included in Appendix H of the Applicants' Emergency Plan are not satisfactory?
18-4.
If the response to Interrogatory 17-4 is in the affirmative, please specify your concerns with respect to each agreement.
19-4.
Does CASE contend that Applicants must reach agreement with any other state and local officials or agencies to satisfy its concerns in Contention 22.b?
-2/
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654, Rev. 1 (November 1980).
. 20-4.
If the response to Interrogatory 19-4 is in the affirmative, please identify each agency and official with which CASE contends Applicants must but have not signed an agreement.
21-4.
For each agency and official identified in your response to Interrogatory 20-4, specify the role which you contend such agency or official is to play in responding to radiological emergencies at Comanche Peak.
22-4.
What are the bases for your responses to Interrogatories 17-4 through 21-4?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
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23-4.
Does CASE contend that NRC requirements other than 10 C.F.R. Part 50, Appendix E,Section IV.D.l. and NUREG-0654, Sections II. A.l.d and A. 3 are applicable to the concerns expressed in Contention 22.b?
24-4.
If the response to Interrogatory 23-4 is in the affirmative, please specify each requirement CASE contends is applicable to Contention 22.b.
25-4.
For each of the agreements which CASE contends must be reached with the officials and agencies identified in the response to Interrogatory 20-4, please specify exactly what information CASE contends must be included in those agreements.
26-4.
For each item which CASE contends in its response,to Interrogatory 25-4 must be included in the agreements with officials and agencies, please specify the specific regulatory requirement which CASE contends requires that such information be included in the agreements.
27-4.
Does CASE contend that Applicants have not adequately identified the principal State and local officials responsible for responding in the event of a radiological emergency at Comanche Peak?
If so, please specify CASE's l
concerns and identify any of ficials CASE contends should be but have not been identified.
. C7ntention 22.
c.
There is no description of the arrangements for services of physicians and other medical personnel qualified to handle radiation emergencies and arrangements for the transportation of injured or contaminated individuals beyond the site boundary.
Contention 22.c has two parts.
First, CASE asks for a description of arrangements for medical services for radiation emergencies.
Second, Contention 22.c says that there is no description of arrangements for the transportation of injured or contaminated individuals beyond the site boundary.
Applicants describe the arrangement for medical and ambulance service for injured and contaminated individuals in Sections 4.3.1.3, 4.3.1.4 and 6. 6. 4 of their Emergency Plan.
In addition, Applicants have obtained letters of agreement with Hood General Hospital and the Radiation Management Corporation for medical services for contaminated individuals.
Accordingly, please respond to the following Interrogatories.
28-4.
Does CASE contend that Applicants' description of ambulance and medical support services in Sections 4.3.1.3, 4.3.1.4 and 6.6.4 of the Emergency Plan is inadequate?
29-4.
If the response to Interrogatory 28-4 is in the af firmative, please specify each area of the descriptions which CASE contends is inadequate.
30-4.
For each of the areas identified in the response to Interrogatory 29-4, spe,cify the specific information which CASE contends that Applicants must but have not included in those descriptions.
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. 31-4.
What are your bases for your responses to Interrogatories 28-4 through 30-4?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
32-4.
Does CASE contend that any other organization must be included within the scope of the medical support classi-fication for radiological emergencies at Comanche Peak?
33-4.
If the response to Interrogatory 32-4 is in the affirmative, please identify each such organization.
34-4.
For each organization identified in the response to Interrogatory 33-4, please describe the exact role which CASE contends such organization should play in responding to a radiological emergency at Comanche Peak.
35-4.
For each response to Interrogatories 32-4 through 34-4, please set forth the bases for CASE's position.
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
36-4.
Does CASE contend that Applicants must arrange for additional services of physicians and other medical personnel beyond those arrangements which are described in the Emergency Plan?
37-4.
If the response to Interrogatory 36-4 is in the affirmative, please identify every service which CASE contends must be provided and the additional medical personnel which CASE contends must be provided.
38-4.
For each of the services and medical personnel identified in the response to Interrogatory 37-4, please describe the precise role which CASE contends such services and personnel will play in responding to radiological emergencies at Comanche Peak.
39-4.
Please specify the basis for each of your responses to Interrogatories 36-4 through 38-4.
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
40-4.
Does CASE contend that the description in the Emergency Plan of arrangements for the transportation of injured or contaminated individuals beyond the site boundary is inadequate?
. 41-4.
If the response to Interrogatory 40-4 is in the affirmative, please specify the particular inadequacies with which CASE is concerned.
42-4.
Fo$ each of the concerns which CASE indentifies in its response to Interrogatory 41-4, please describe the arrangements which CASE contends must be made to satisfy NRC regulations.
43-4.
For each of the arrangements described in the response to Interrogatory 42-4, describe the specific function which CASE contends each arrangement is intended to fulfill.
44-4.
What are the bases for your responses to, Interrogatories 36-4 through 34-4?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
45-4.
Does CASE contend that there are any other NRC requirements applicable to Contention 22.c besides 10 C.F.R.
S 50.47 (b)
(12), Part 50, Appendix E, Sections IV.E.6 and 7, and NUREG-0654, Sections II.L.1 and II.L.47 46-4.
If the response to Interrogatory 45-4 is in the affirmative, 1
please specify each additional requirement which CASE contends is applicable to the concerns expressed in Contention 22.c.
Contention 22.
e.
There is no provision for medical facilities in the immediate vicinity of the site, which includes Glen Rose.
The concerns raised in Contention 22.e involve provisions for medical facilities in the area of the Comanche Peak site.
Applicants have described in the Comanche Peak Emergency Plan the medical facilities which are available for use in the event of an emergency at Comanche Peak.
The Plan provides for treatment of injuries involving radioactive contamination at the Hood General Hospital, with back-up support by. Radiation Management Corporation, as discussed in Sections 4.3.1.4 and 6.6.4, and
e
. evidenced by the letters of agreement included in Appendix H.
Marks English Hospital in Glen Rose will be used for treatment of injuries not involving radioactive contamination.
Thus, no letter of agreement with that hospital is necessary or required.
The description of this service is set forth in Section 4.3.1.4 of the Emergency Plan.
In this context, please respond to the following Interrogatories.
47-4.
Does CASE contend that the provisions for medical facilities described in the Comanche Peak Emergency Plan are inadequate?
48-4.
If the response to Interrogatory 47-4 is in the affirmative, please identify the specific provisions which CASE contends are inadequate.
49-4.
For each of the provisions identified in the response to Interrogatory 48-4, please describe the spec'ific concerns which CASE has.
50-4.
Please set forth the additional provisions which CASE contends are required to be made for medical facilities.
51-4.
What are your bases for your responses to Interrogatories 47-4 through 50-4?
Identify all documents, testimony or oral statements by any person and legal requirements" on which you rely in support of your position.
52-4.
Does CASE contend that Hood General Hospital is unable to adequately care for individuals contaminated by radioactive materials?
53-4.
If the response to Interrogatory 52-4 is in the affirmative, please specify the particular services which CASE contends that hospital is not able to provide.
54-4.
Does CASE contend that the services of Radiation Management Corporation are inadequate to assure proper care for contaminated individuals?
55-4.
If the response to Interrogatory 5'4-4 is in the affirmative, please specify and describe the particular services which CASE contends Radiation Management Corporation is unable to provide.
O 56-4.
What are your bases for your responses to Interrogatories 52-4 through 55-4 ?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
57-4.
Does CASE contend that any legal requirements other than 10 C.F.R.
S 50. 47 (b) (12) and Part 50, Appendix E,Section IV.E.7, and NUREG-0654,Section II.L.1 are applicable to Contention 22.e?
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58-4.
If the response to Interrogatory 57-4 is in the affirmative, please specify each requirement which CASE contends is applicable to the concerns expressed in Contention 22.e.
59-4.
Do you intend to call any witness in the~ upcoming hearing with respect to Contention 22?
If so, please identify the witness, including a summary of his or her profes.
sional and educational background.
Also, set forth any other information bearing on that person's qualifications to testify with respect to Contention 22.
60-4.
If you plan to call any witness during the upcoming hearing with respect to Contention 22, please specify the nature and scope of his or her testimony.
Please list or identify any documents which that witness intends to rely on in giving their testimony.
Alco please state whether that witness has conducted any research or made any studies which such witness intends to rely upon.
Please provide copies of such testimony.
Also, please provide for inspection and copying any documents relied on in such testimony.
l 61-4.
Please produce for inspection and copying all documents j
identified by CASE in the above Interrog tories.
Sincer 1,
(
s Nichol S '.I Reynolds l
hL V CJk William A.
Horin
~
DEBEVOISE & LIBERMAN l
1200 17th Street, N.W.
t Washington, D.C.
20036 (202) 857-9817 l
Counsel for Applicants March 23, 1982
a a
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, -
)
50-446 et al.
)
(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' Fourth Set of Interrogatories To CASE and Requests to Produce", in the above-captioned matter were served upon the following persons by overnight delivery (*)
or by deposit in the' United States mail, first class postage prepaid this 23d day of March, 3982,:
Marshall E.
Miller, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Kenneth A. McCollom Marjorie Ulman Rothschild, Esq.
Dean, Division of Engineering Office of the Executive Architecture and Technology Legal Director Oklahoma State University U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission 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 Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory J.
Marshall Gilmore, Esq.
Commission 1060 W.
Pipeline Road Washington, D.C.
20555 Hurst, Texas 76053
O
. Mr. Richard Fouke Mr. Chase R.
Stephens 1669-B Carter Drive Docketing & Service Branch Arlington, Texas 76010 U.S. Nuclear Regulatory Commission
- Mrs. Juanita Ellis Washington, D.C.
20005 President, CASE 1426 South Polk Street Dallas, Texas 75224
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William A. Horin cc:
Homer C. Schmidt Spencer C.
Relyea, Esq.
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