ML20049H879

Second Set of Interrogatories Directed to Lake County Commissioners & Lake County Disaster Svc Agency.Proof of Svc Encl.Related Correspondence

ML20049H879
Person / Time
Site:	Perry
Issue date:	02/24/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	LAKE COUNTY, OH
References
NUDOCS 8203040401
Download: ML20049H879 (8)

Text

@

MI D

nEtnED COHnEsrcNnmen 198~W I/.A81

'\9-A UNITED STATES OF AMER $e ,~%,

~

NUCLEAR REGULATORY Okit SSibi7

~/

\ ,\ C, fi,N!,N.

i.w a )'

N ,

.h cw NM For the matter of:

, DocdetNo's: 50-4d J ' j 50-441 The Cleveland Electric illuminating C , et 'l a i j

(Perry. Nuclear Power Plant, Uni ts 1 and 2) s .

y, N

Sunflower Alliance, l_nc.._et al. Second Set of interrocatories to Lake County Con:-i ssioners and Lake Coun_tv _Di sas te r Service _Acen_cy (he re_i na f te r ca l led Countv) .

These interrogatories (Second Set) are filed by Sunflower Alliance Inc. et al, pursuant to the previous orders of the Atomic Safety and Licensing Board and pursuant to 10 CFR 2.740 6. These interrogatories are di rected to the County and pertain to one or more of the seven issues that have been admitted to date in this proceeding.

It is required that each interrogatory be answered separately and fully in writing unde r oath or a f fi rma tion, wi tnin 14 days after service. These interrogatories shall be continuing in nature and the answers must be imediately supplemented or amended, as appropriate, should the county offer any new or di f fering information responsive to the Interrogatories.

For purposes of these Interrogatories the term "decuments" means all records of every type in the possession, control or custody of the County or of the County's attorney (s),

including, but not limited to, memoranda, correspondence, reports , surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, end cll othc r writings recordings or video tapes of any kind. " Documents" shall also mean copies of documents even though the originais thereof are not in the possession, custody, or control of the County.

For purposes of these interrogatories, a document shall be deemed to be within the

' control' of the County or Countys' attorney (s) if tyey have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession the reof.

When identification of a document is requested, briefly describe the document, i.e.

le tte r, nemorandun, book , panphlet , etc., and state the following in h emation as applicable to the particular document: name, title, number, author, date of publication and publisher, addresses, date written or approved, and the name and address of the person (s) having possession of the document.

S 1(

8203040401 820224 PDR ADOCK 05000440 PDR

i Statement of

Purpose:

These in:errogatories relate to the Emergency Planning contention and are designed to discover .nformation and evidence for the hearing.

1 Produce any and all documents, correspondence, or memoranda between CEI and the NRC, FEMA, local or s' tate governments or any other entity relating to the use

of thyroid blocking agents by CEI employees, energency workers, or the general puclic.

T

2. Answer the following questions for the high efficiency particulate air filters which have been or will be installed in the Radiation Emergenef are: of Lake County Memorial Hospital, East:

E To what level will the HEPA filters reduce particulate levels?

is the HVAC system controlled to permi t isolation of the intake?

At what level or airborne activity is isolation performed?

How is the level determined?

i i Where are the sensors located?

Where is this level monitored?

3. According to Sec. 5.5.6.1 of Appendix 13A of FSAR, "the decontamination room drains (at the hospital) a 4 collected in a holding tank for subsequent disposal at PNPP." Describe how the material in the holding tank will be transported to PNPP. What safeguards will be taken to ensure the safe trarsport of this material?

4 Will any special provisions or consideration be made for those evacuees who have pets, e.g. , special mass care centers, kennel f acilities, pet feod supplies, etc.?

Will people be allowed to take pets with them? If not, what are people to do

! with the animals?

5. What provisions will be made for the notification of deaf people within the 10-i- mile EPZ in the event of a radiation emergency?- Has any study been made as to how many deaf people. are in the area?

6. What provisions will be made for the notification of people who do not speak English within the 10-mile EPZ in the event of a radiation emergency? Has any study been made on the number of non-English speaking people in the area (e.g.,

Hispanics in the Geneva area, Finnish and Hungarian people in the Fairport area)?

7. How will people on boats within the 10-mile EPZ, on Lake Erie, be notified to evacuate.?

8. What pro' visions will be made for the evacuation of non-institutionalized hand!-

capped people or people dependent upon life-support systems?

I 9. Is there any priority system for evacuation? E.g., who will be evacuated first, school children, pre-school children, pregnant women, or the elderly / infirm?

10. Explain how the plume exposure pathw'ay EPZ depected in. Figure 2 of Appendix D of Appendix 13A of FSAR was derived. Explain precisely how'each and every one of the following factors was considered in the determination of the extent of the

~

plume exposure EPZ: demograpny, including-permanent and seasonal residents and

. transiends; meterology; topography; land use. characteristics; access routes; 2

local jurisdictional boundaries; release time and 3nergy characteristics; release height; radionuclide content of release, including release f ractions; plume disperslun, including plume rise; deposition velocity; dose-ef fects; chel te.-ing and shielding; radiation treatment; brecthing rates; time of year of release.

11 Does County agree with this EPZ area?

12. In the County's polnion, is it possible to evacuate safely the total permar.ent, seasonal, and transient populations within each of the following areas at any time of day or any time of year? Describe in detail any assumptions made ard Indicate how your response would dif fer if that assumption were changed. Disclose any assumptions made with respect to an acceptable level of risk to the evacuating population.

(a) The area designated as the plume exposure pathway EPZ for PNPP in the FSAR.

(b) The area which the County believes should constitute the plume exposure EPZ for PHPP.

(c) The circular zone corrounding PNPP having a 20-mile radius.

(d) The Mentor Headlands area.

(e) The entire City of Mentor.

13. In the County's opinion, would there ever be a need to order protective actions in any area outside of the plume exposure pathway EPZ proposed by the Applicant in the FSAR7 If so, describe the circumstances therein, the areas so affected, and the nature of any such protective actions.

14 Has any consideration been made of the possibility of the Voluntary and spontaneous evacuation of persons within the plume exposure pathway EPZ in the event of an accident at PNPP and how this might effect the ordered evacuation? If so, describe in detail any such study.

15. Has any consideration been made of the possibility of the voluntary and spontaneous

~

evacuation of persons outside of the plume exposure pathway EPZ in the event of an accident at PNPP and how this might affect the ordered evacuation, especially the support organizations and facilities outside the EPZ7 If so, describe in detail any such study.

16. In the County's opinion, are there adequate facilities available to shelter simultaneously the total permament and peak seasonal and transient populations in each of the following areas?

(a) The area designated by the Applicant in the FSAR as the plume exposure pathway EPZ.

(b) The area which the County . believes should comprise the plume exposure pathway EPZ.

(c) The circular zone surrounding PNPP having a 20-mile radius.

. With respect to each of these areas, describe the types of shelter available, Indicate the numbers of each type of shelter available and the shleiding factors  :

associated with each type, describe the nature and location of the shelter to be i i

used by transient populations, and disclose any assumptions made as to an acceptable level of risk to the public.

3

17. In the County's opinion, what constitutes an accep;aale level of risk to the public surrounding FNPP in the event of an accicen:? Specifically, what is the uppermost number of each of the following healtn e#fects which is acceptable:

early fatalities, delayed fatalities, early injuries, delayed injuries, and developmental or genetic birth defects? If your a swer varies depending on the type of accident which occurs, provide answers wit- respect to releases at PHPP equivalent to the BWR-1 to BWR-4 releases defined 'n WASH-1400.

18 In the County's opinion, what constitutes an appre:riate and safe distance f rom PNPP for the location of reception / mass care cente s for evacuees? Describe any other criteria for the location of reception / mass care centers.

19. In the County's opinion, if an accident occurs on a weekday during working hours, wSat percentage of the permanent population within the plume exposure pathway EPZ proposed by the Applicant will be working at locations outside the EPZ, leaving other family members at home without automobiles? Also, what percentage of the automobiles said to be available in the Applicant's Evacuation Study are operable?

20 NUREG-0654, Appendix 4 provides that (at p. 4-2), in preparing evacuation time estimates, "The number of permament residents shall be estimated using the U.S.

Census data or other reliable data, adjusted as _necessary, for__crowth." (Emphasis added) in the County's opinion, what is the apprc:uiete target date for adjusting population figures for growth: The expected date Of initial criticality, or the expected date for the termination of plant operatiens? Why have unadjusted population data been used to prepare evacuation ti e estimates? Provide evacuation time estimates using properly adjusted populations.

21 The Applicant's FSAR, Appendix 13A, Section 4.2 states that the Ohio DSA has adopted the EPA manual of protective action guidelines, EPA-520/1-75-001, and that recommendations to the State and local govern ent will be based on these PAGs.

(a) is the County aware that this includes the ac-inistration of radioprotective drugs, such as potassium iodide?

(b) If so, describe in detail any and all provisions for the purchase, storage, stockpiling, distribution (including public ecucation on proper use of the drug), and ef fectiveness/ side effects moni toring of such drugs.

(c) In the County's opinion, whould the admini stration of radioprotective drugs to individuals off-site ever be necessary or cesirable in the event of an accident at PNPP? I f not, why not? If so, to what radial distance from the site could dissemination of the drugs be necessary? What is the maximum quantity of potassium lodide or other radiopretective drug that could be needed? What repositories in the vicini ty of the PNPP site currently stock such drugs and what quantities are maintained?

22 Explain precisely how each of the following possibilities was accounted for in the preparation of evacuation time estimates for PNPP:

(a) Vehicles breaking down or funning out'of fuel during the evacuation.

(b) Abandoned vehicles.

(c) Vehicles having insufficient fuel at the commencement of the evacuation, to the knowledge of their owners.

, (d) Disregard of traffic control devices.

4

1 (e) evacuees using inbould traffic lanes for outbound travel.

(f) blocking of cross-streets at intersections.

23. Estimate the neber of each of the following types of vehicles which will be needed to implement evacuations in each of the evacuation sub-areas outlined in Appendix 0 of Appendix 13A of the PNPP FSI,R and the number of trips to and f rom those sub-areas which will be taken by each such vehicle: buses; ambulances; tow trucks; traffic control vehicles; anc vehicles for use in notifying the public and/or confirming evacuation. Explain the bases for your estimates in detail, disclosing any assumptions made.

24 Have any emergency planning measures been designed to mitigate the consequences of hypothetical releases to the lizuid pathway as a result of a core melt accident at PNPP? Are such measures necessary? Describe any and all results of a release to the lizuid pathway, and describe any design features incorporated in PNpP which would mitigate the consequences of or prevent such a release.

25. List every visit made by or for Alan M. Voorhees and Assoc. to the PNPP site or the surrounding area. Specify for each visit the individuals who participated and their titles and affiliations, the exact locations visited (including the names of all roadways traversed for purposes of evaluating the transportation network in the Perry vicinity), the length of the visit, the itinerary or agenda, and all findings and conclusions which resulted therefrom (including any inventories which were developed as to available roadways, road capacities, shelter facilities, or the like). Indicate how this information was incorporated into the Evacuation Study, Appendix 0 or Appendix 13A of the FSAR.

26 What provisions have been made to ensure the cooperation of the public during a radiation emergency? Specifically, what authority do state and local governments hwe to force people to evacuate from their homes, to prevent spontaneous evacuation outside the EPZ (and possibly in the area of the reception / mass care centers), to conpel the assistance of volunteers in the evacuation, and to control panic and subsequent uncooperative behavior in evacuees?

27. In the County's opinion, might a nuclear emergency occurring at PNPP ever require the imposition of martial law? If so, what areas around the site might be so affected and for how long?

28 NUREG-0654 at p. 13 states that "The range of times between the onset of accident conditions and the start of a major release is of the order of one-half hour to several hours." Section 5.2.4 of Appendix 13A of the PNPP FSAR states that the Emergency Duty Officer, who must be able to respond within 60 minutes, is responsible for recommending protective actions for the general public. In the County's opinion, in the event of a major release occurring within i hour, does

! this arrangement provide suf ficient time for alerting the public and implementing the appropriate protective actions, including evacuation, such that no member of the general public would receive radiation doses in excess of the limits prescribed l by 10 CFR Sec. 20.105?

29. What is the basis of legal authority (reculations, legislation at Federal, State, or local level) governing the cooperation of state, local, or private emergency response organizations with utilities operating nuclear power plants? Would local police officers /depstments ever be called on-site to aid PNPP security during _ any securi ty threat at' the plant? if so, have any letters of agreement been

! signed with local police departmmts? Describe any security threat scenarios that would result in radiation exposure to of f-site police personnel called on-si te.

Have local police departments received any training or equipment for situations involving radiation exposure? -

c 5

^

30 Has the Applicant (or anyone _ on behalf of or to the knowledge of the Applicant) concucted any studies on protective actions other than evacuation for the general public? Specifically, are there any estimates or analyses of the time required to effecuate sheltering or thyroid proghylaxis? (also for Counties?)

31. Concerning the evacuation of schools:

(a) What provisions will be made for the evacuation of nursery schools, pre-schools, day care centers, and other such facilities, both public and private?

(b) What provisions will be made for the evacuation of private schools within the plume exposure pathway EPZ? Include in your answer the notification procedures for these schools and the availability of transportation, especially for those schools which do not have buses or other transportation programs.

(c) For both private and public schools, what provisions will be made for the evacuation (possible selective evacuation) of those schools outside the plume exposure pathway EPZ but whose students may reside within the EPZ?

(d) How will bus drivers be notified in the event of an emergency? Many of these people work part-time and therefore may not be available by phone during non-working hours.

(e) Discuss the suitability of schools for sheltering students for long periods of time, include sheltering factors for the buildings and the availability of sufficient food, medical supplies, blankets, etc.

32 Describe in detail any independent monitoring for radiation around the PNPP site.

(Independent monitoring here means monitoring by a governmental or private entity that is not an agent of the Applicant.) include the types of monitors to be used, both mobile and stationary and detection / manufacturer type, manner and frequency of reading / analysis, availability of instantaneous data, type of data link with the responsible agency, name and affiliation of responsible agency, type of meteorological monitors / data input, of any, means of calculating projected doses, and the source of funding of the responsible agency.

)

i i F e n Me

• 6

. <- \

Respectfully submitted

/

[ [

1el D. Vilt fttorney for Sunflower Alliance Inc.

7301 Chippewa Road Brecksville, Ohio 44141 (216) 526-2350 Proof of Service i A copy of these Second Set of Interrogatories to Lake County has been sent to everyone on the attached Service List on this OD day of February, le32,

~

J wAI k ,

D niel D. Wilt

+

Attorney for Sunflower. Alliance Inc.

i 1

T I

9

, 3 SERVICE LIST Peter B. Bloch, Chairman Dr. Jerry R. Klein Atomic Safety & Licensing Board Atomic Safe;y & Licensing Board

iuclear Regulatory Commission Nuclear Regulatory Commission Washington, D.C. 20555 -

War.hington, D.C. 20555 l

Frederick J. Shon Jay Silberg, Esq.

Atomic Safety & Licensing Board 1800 M Street N.W.

l Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Donald T. Ezzone, Esq. Daniel J. Herron, Esq.

Assistant Prosecuting Attorney Assistant Prosecuting Attorney 105 Main Street Ashtabula County Courthouse * '

Painesville, Ohio 44077 Jefferson, Ohio 44047 Tod J. Kenney Jeff Alexander 228 Scouth College St. Apt. A 920 Wilmington Ave.

Bowling Green, Ohio 43402 Dayton, Ohio 45420 ,

Terry Lodge, Esq. Robert Alexander

• 915 Spitzer Bldg. 2030 Portsmouth St. Apt. 2 Toledo, Ohio 43604 Houston, Texas 77098 Atomic Safety & Licensing Appeal Board Docketing & Service Section l Nuclear Regulatory C6mmission Office of the Secretary l Washington, D.C. 20555 Nuclear Regulatory Commission l Washington, D.C. 20555 i

Charles Barth, Esq. t Nuclear Regulatory Commission Washington, D.C. 20555 q lc>i ; ik p  % 1

$?$~5?

[g_ l\

f MARj Y 1982% y' ti 9 ES.'%% 'i r5k'& k ,  ;

=

4 l Cu @

+

4

__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _