ML20054H601
| ML20054H601 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/15/1982 |
| From: | Jeffrey Reed REED, J.G. |
| To: | MISSOURI, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8206240250 | |
| Download: ML20054H601 (10) | |
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..g 1 O ll 6 \ T z-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICFRSING BOARD I
In the Matter of )
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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1) )
JOHN REED'S INTERh0GATORIES AND REQUESTS KR PRODUCTION OF DOCUFENTS (SET NO.1)
TO THE MISSOURI PUBLIC SERVICE COMMISSION AND THE STATE OF MISSOURI .
Pursuant to 10 CFR, Section 2,740b and 2 741, Mr. Reed requests that the Missouri Public Service Commission and the State of Missouri (hereafter referred to as "the State of Missouri") answer separately and fully in writing, trid under oath or affinnation, each of the following ,
interrogatories, and produce and permit inspecticri and copying of the original or best copy of all documents identified in the response to interrogatories below. Interrogatory responses are due no later than 14 days after service of said interrogatories.
Mr. Reed requests that the name and address of the person or persons who provide infomation used in answering each interrogatory be identified, and that the source of information be disclosed.where an answer is based in whole or in part on information other than the personal knowledge of et-the person or persons answering.
l These interrogatories are intended to be continuing in nature, and the answere should be pronpt3y supplemented or amended as appropriate, should the Stute of Misnouri or any individual acting on their behalf obtain any new or differing information responsive to these interrogatories.
8206240250 820615 n PDR ADOCK 05000483 s
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Where identificaticn of a document is requested, briefly describe the document (e.g., book, letter, memorandum, transcript, report, hand written notes, test data) and provide th following inforn.ation as applicable: document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or, persons having possession of the document. Also, state the portien or portions of the document (section(s), chapter (s),
4 or page(s)).upon which you rely.
For the purposes of these interrogatories, the term " documents" shall mean all records of every type in the possession, control or custody of the State of Missouri, including, but not limited to memor,anda, reports, surveys, correspondence, charts, te.bulations, books, photographs, mnpa, bulletins, phamplete, minutes, notes, transcripts, voice recordings, and all other writings, to include copies of documents even though the originals, thereof, are not in the possession, custody, or control of the State of Missouri.
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For the further purposes of these interrogatories, a document shall l
be deemed to be within the control of the State of Missouri if they have ownership, possession or custody of the document or copy thereof, or the State of Missouri has the right to secure said document or copy thereof l
from any person or public or private entity having physical possession thereof.
STATE!ENT OF PUitPOSE These interrogatories relate to e:r.ergency plenning contentions and are submitted for the purpose of discovering information and evidence for uso in public hearings in the above captioned matter.
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INTEEROGMORIES
- 1. Pmduce any and all documents, correspondence, or memoranda between the State of Missouri and Union Electric Company, the NRC, FEMA, local govemments (counties and incorporated cities, towns or villages) in the State of Miceouri or my other entity relating to radiological
. emergency, plans, planning, response requirements, financial or funding arrangements or agreements, respiratory and thyroid protection, or a
discussions involving matters which have any bearing upon the above a subjects.
2 Produce copies of all lesson plans which will be used by the State of Missouri to instruct courses in procedures to be used in peacetime nuclear incidents: and accidents. Include all Federal guidance which supports such instruction and validates the techniques and procedures are taught in such lesson plans.
- 3. Request the names of all State of Missouri employees in the Radiaticn Health Division and any other agencies which have a role in the monitoring of personriel, . environs, livestock, foods in fields and gardens, or any other field survey required in Union Electric, State of Missouri, and local governmental radiological emergency response plans (RERPs) and standard operating procedures (SOPS), who have received training in which the lesson plans identified in 2, above, were used. Indicate any other formal training the employees so identified may have received from other sources which will affirm their qualifications to perform the duties identified, above.
- 4. Request a list of protective equipment be provided of all respiratory devices, protective clothing, TLDs (thermolucent dosimeters), film badges, etc. that is available in State of Missouri inventorios that
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the above named individuals will use in the performance of their assigned duties during a peacetime nuclear accident. Indicate any shortage of clothing or equipment that could possibly prevent an individual from functioning as required in a radiological environment.
- 5. Pmvide a breakdown of which of the pereonnel identified above will be assigned to duties in the 10 mile EPZ and which will be assigned to the 50 mile EPZ. Include an estimate of the probable time each
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man will take to perfom his duties in each area. .
- 6. In the opinion of the State of Missouri, do a sufficient number of qualified radiological monitors and protective equipment exist in i State of Missouri inventories to perfom all of the functions in the 10 mile EPZ and the 50 mile EPZ on a simultaneous basis? If so, l explain in detail tho' reasons for such reply. If not, why not, and l
what action or actions are being t.aken to resolve this matter.
- 7. Provide a list of instructors who will teach classes in peacetime radiological survey and monitoring., Indicate the formal education of each instructor, special educational courses attended which qualify such instructors to teach, past experience with radiation fields, include any other documentation relevent to their professional qualifications to include copies of publications authored or co-authored by the instructors identified above.
8 Request the name or names and professional certification of State of Missouri planners who prepared the State of Missouri Radiological Emergency Response Plans. For each name given, provide the title, organisational affiliation, list highest grade attained in formally recognized public or private schools and colleges and any degrees attained thereby, any special education received in planning techniques 1
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and the name and accreditation of the school at which such special training was received.
- 9. In the Interim Nuclear Accident Plan 1980, of the State of Missouri, copy 022, page B3, 0.2. Exposure to Radiciodines in a Plume, it states that:
"- - The principle inhalation dose will be from the iodines and particulate material in the plume. Due to the ability of the thyroid t8 concentrate iodine, the thyroid dose resulting from inhalation of radioiodines may be several times greater than the corresponding whole body extemal gamma dose that would be received."
In table 4-IV-B continured, on page B4, for lifesaving there is no upper limit given for thyroid dose:
"**No specific upper limit is given for thyroid dose since in lifesaving activities, complete thyroid loss might be an acceptable sacrifice if a life can be saved. However, this should not be necessary if respirators and/or thyroid protection for rescue personnel are available as a result of adequate planning."
In C.3. Exposure to Particulate Material in a Plume it states:
" - - protective actions (Prophylaxis iodine excepted) chosen on the basis of assuming that the iodine exposure pathway is critical will be sufficient to provide protection for radioactive l particulate material."
Specifically identify the person who prepared the above table and text, indicating applicable Federal documentation which supports the statements quoted, or other documentation which is so supportive. If documentation other than Federal documentation is used, indicate the author of each document, his professional affiliation, formal educational achievements which affiru the author's qualifications in nuclear medicine or radiological health physics. In the opinion of the State of Missouri, are the above quotations representative of actual facts and conditions as relate to exposures of iodines and particulates in a radioactive plume? If the answer is in the affirmative, explain in detail exactly how such relation is created. If t,he answer is in e _
the negative, explain why such statements were incorporated into this document.
- 10. In the State of Missouri Nuclear Accident Plan, Preliminary Issue, dated 4/30/82, page B3, C.2. Exposure to Radioiodines in a Plume, the identical quotation indicated in 9, above, is recorded. On page B4, table 4-IV-L continued, no upper limit is indicated for projected thyroid doses ,
"**No upper limit is given for thyroid dose since in lifesaving activities, complete thyroid loss might be an acceptable sacrifice if a life can be saved."
No consideration is given for respirators and/or thyroid protection at was done in the earlier intrim plan. Sub-paragraph C.3. reads exactly as did the interim plan and paragraph D. readst .
"Following a nuclear incident involving a release to the atmosphere, the most urgent actions in terms of response time will M those
_necessary to protect the population from inhalation g radioactive materials in the plume - - ." (en:phasis added)
In the opinion of the State of Missouri, if the information cited above is accurate and representative of actual facts and conditions as relate to exposures of iodines and particulates in a radioactive plume, be specific in explaining why the use of respirators and/or thyroid protection as a result of adequate planning was deleted. Provide a copy of Federal Food and Drug Administration or Environmental Protection l
Agency guidance which is supportive of this stand and give the name, title, organizational affiliation, address, telephone number of each person responsible for the change in table 4-IV-B. In addition, provide a copy of th'eir statement of professional qualifications, their highest grade att,ained in a duly accredited school or college, degrees eamed and a copy of each publication edited, authored or co-authored by each such individual which is related to radiological medicine,
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health physics, nuclear reacotr accidents or nuclear attack.
- 11. Provide the names, titles, organizational affiliations, addresses, and telephone numbers of each and every State of Missouri planner who contributed to or edited any portion of the State of Missouri Interim Nuclear Accident Plan 1980 and the State of Missouri Nuclear Accident Plan, Preliminary Issue, dated 4/30/82. In addition, provide a copy of their statement of professional qualifications, their highest grade attained in a duly accredited school or college, degrees eamed, if any, and a copy of each publication edited, authored or co-authored by each such individual which is related to radiological medicine, health physics, nuclear reactor accidents or nuclear attack.
12 NURm 0553, page 11-93, clearly states that radiological emergency response plans have legal status. Specify in detail what insurance or other funding the State of Missouri has available to protect against legal suite for inadequate planning or liability claim resulting from injury or property damage during or following a radiological accident at the Callaway Plant No.1. What liability exists for planners or other individuals who assist in the preparation of plans? What kind of protection is afforded to such planners and individuals? Describe l
- how the State of Missouri views the need for realistic radiological emergency response capabilities in support of cornercial nuclear power plants. Describe what steps have been taken to meet other than the mininum standards of planning and response required by the NRC in
- 10 CFR, Part 50, Section 50.47b; NUREG 0654 FEMA-REP-1, Rev.1; NUREG l
l 0396 EPA 520/1-78-016 or guidance in EPA-520/1-75-001.
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13 At Soddy-Daisy, Tennessee, potassium iodide (KI) wric inuued to 7,000 residents near the Sequoysh Nuclear Power Plsnt by the Tennessen Valley Authority. ':he Food and Drug Administrr. lion (FDA) has ruled that KI is safe and offective as a thyroid blockirid 36ent which prevents thyroid uptr.ke of radiolodin m. '.hn hPA rnanual of pratective action guidelines, EPA-520/1-75-001, includes the use of radioprotective drugs, such as KI. The FEEh has withdrawn any prior
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objection to use of KI and Union Electric will lucue KI to its ernergency workers at tho' Ca]laway Plant No.1 for thyroid protection.
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In light of the cited Federal guidance supporting use and the issuance and proposed issuance of KI, in addition to the sheltering requirements of State and local RERPs, explain in detail why the State of Missouri has decided not to provide K1 for emorgency workers or the general public. If the justification is for medical reasons, provide copies of FDA, EPA, FEMA, or NRC documents which contradict and superscede the Federal guidance cited above. Give the names, titles, addresses, professional affiliations, highest grade completed in duly acredited schools or colledes, degrees eamed, if any, a copy of their statement of professional qualificaticus and a copy of each publication edited, authored, or co-authored by each such individual which is related to
, radiological medicine, health physics, nuclear reector accidents, or 1
nuclear attack.
- 14. In the " draft EDS announcernent", page C21, of the State of Missouri l'
Nuclear Accident Plan, Preliminary Ic. sue, 4/30/82; it states that a quick, offective respiratory protective device can be made by folding l 3 mn's handkerchief to eight layers and placing it over the nose and l
l mouth. Such device is recommended for small children, also. Provide
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copies of Federal documents, citing specific sections, paragraphs, or sentances which support the effectiveness of such respiratory protection as is described above. Additionally, indicate the page(s) and section in 10 CFR, Part 20 or NRC Regulatory Guide 8.15 which establishes such filtration as provided by the handkerchief device meets acceptable standards for adults and children. If such dccumentation cannot be provided, explain in detail why and who made the 9
recomandation as included in the State of Missouri HERP, and give the name(s), title (s), addresses, professional affiliation (s), highest grade successfully completed in duly acredited schools or colleges, degrees camed, if any, a copy of their statement of professional qualifications and a copy of each publication edited, authored, or co-authored by each such individual which is related to radiological medicine, health physics, nuclear reactor accidents, or nuclear attack.
End of Interrogatories l
les ectfully submitted, j
Dated this 15th day John G. Reed i
of June 1982, at Citizen of the United States Kingdom City, NO. of Anerica RFD #1 Kingdom City, Missouri 65262 tel: (314) 642-2769 l
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O UNITED STATES OF id'hftICA NUCLEAR REGULATCRY C0! MIS 310N BEFORE THE ATOMIC SAFETY AliD LICENSING BOARD
, , In the Matter of )
)
UNION ELECTRIC C0!?ANY ) Docket Nou STN 50-48)
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(Callaway Pltsnt, Unit 1) )
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CERTIFICATE OF StatVICE I hereby certi+?y th% copic.* of the for.gol:.g 'Jchn Ree J's Interrogatories
, and Requesto for Production of Doct;':.entn (W ';o. 3 )" were served t hi s Sth Day of June 1982 by ' deposit in the U.S. Mai], first class postage prepaid, upon the following:
- Janes P. Gleanon, Esquire ' Mr. Glenn O. Bright Chairman, Atomic Safety and Atomic Safety and Licensing Board Licensing Board Panel 513 Gilinoure Drivc U.S. !!uclear Regul -ory Corranisalon Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jorry H. KJ ine N.*' Docketine and Service Section Atomh: Seiret,y and Licenning Offico of t.he W eretory l Doard Panet U.S. fhicJ ear llegulatory Conanlosion U.S. NucJ ear Regulat,ory Conenission Washingten, D.C. 20555 Washington, D.C. 20555 Roy P. Lesr.y. J r. , Esquire j
Kenanth M. Chael;os, hnqui re Orric. or t.h Execut.ivo 1.cgn1 Direct.or i Chuckes anri Hoare U.S. f;uelear liegulaf.ory Conunincion
, 314 N. Drostiway Washington, D.C. 20555 l St. Loulo, Mo. 63102 l
- A. Scott Caucar l
Thomas A. Baxter, Escuire ansistant, General Counnel Shaw, Pittnnn. Potts & Trowbridge MO. Public Service Conmission 1800 M. Street, N.W. P.O. Box 360 Washington, D.C. 20036 Jefferson City, MO. 65102 Ato:nic Safety an't Licensj ng ' Robert Wright.
Appeal Board Cal) way Cour;ty Co.et , Courthouse U.S. Nuclear Regulatory Censnission e'ul ton, !C mri 65251 Washington, D.C. 20555 e i T.? e d, ., 4. / ' ~
, ' John if, heed ' )
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