ML20055A268
| ML20055A268 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/15/1982 |
| From: | Perlis R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Jeffrey Reed REED, J.G. |
| References | |
| ISSUANCES-OL, NUDOCS 8207160046 | |
| Download: ML20055A268 (70) | |
Text
4 o 07/15/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
UNION ELECTRIC COMPANY Docket No. STN 50-483 OL
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(Callaway Plant, Unit 1) )
NRC STAFF INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOHN G. REED INTRODUCTION AND INSTRUCTIONS ,
The NRC Staff hereby requests that John G. Reed, pursuant to 10 C.F.R. 56 2.740, 2.740b, and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories, and produce and permit inspection and copying of any and all documents identified in the responses to the interrogatories below. As per the Board Order of June 9, 1982, responses must be filed by August 16, 1982.
In addition to the interrogatories listed below, the Staff request, responses to the following interrogatory (hereinafter referred to as
" Staff Question 1") for each contention or subcontention:
- a. Upon what person or persons do you rely to substantiate in whole or in part your views on this assertion?
- b. Provide the addresses and education and professional qualification's of any persons named in your response to 1(h)a. above,
- c. Identify which of the above persons or any other person you may call as witnesses on this assertion.
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- d. Provide summaries of the views, positions or proposed testimony on this assertion of all persons named in response to subparts (a) and (c) immediately above that you intend to present during this proceeding.
- c. State the specific bases and references to any documents which ,
the persons named in response to this interrogatory rely to substantiate their views regarding this assertion.
- f. List all documentary or other material that you may use during this proceeding to support this assertion or refer to during this proceeding to support this assertion or refer to during your examination of witnesses. The list should be by author, title, date of publication (if applicable), publisher (if applicable). In addition to listing such .
documents, provide a copy of all documents that are not NRC documents or documents provided to the NRC in this proceeding. Such documents need only be listed. If uncertainty exists as to whether a document was provided to the NRC, provide that document.
Reed Contention No. 1
" Applicant has not made sufficient arrangements with local governments nor local agencies and organizations to meet the requirements of 10 C.F.R., Part 50, Section 50.47(b)."
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The following interrogatories relate by letter to the subsections of section 4 of the discussion under Reed's Contention No. 1.
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A. See 50.47(b)(1). Primary responsibilities for i
emergency response by local organizations within l
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the EPZ have not been assigned, nor have the emergency responsibilities of the various supporting organizations been specifically established and each principal response organization lacks staff to respond and augment an initial response on a continuous basis.
(1). Local plans do not include letters of agreement with each local agency or organization indicating an acceptance of a response roll in the proposed RERP or 50P (Standard Operating Procedure). The assignment of a responsibility without its acceptance by the agency or organization concerned is not a valid assignment of such responsibility. ,
Interrogatory A(1)(a)
Provide the basis for your assertion that the primary responsibility for emergency response by local organizations within the EPZ have not .
been assigned.
Interrogatory A(1)(b)
List the local agencies and organizations for which local plans do 1
not include letters of agreement indicating an acceptance of a response roll in the proposed RERP or S0P.
Interrogatory A(1)(c) ,
Provide the basis for requiring a letter of agreement from each of the agencies and organizations listed in the answer to Interrogatory A(1)(b).
Interrogatory A(1)(d)
Provide the information for this interrogatory requested by Staff
- Question 1.
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- 2. No acceptance of specific responsibilities, established in the proposed RERPs and SOPS, is indicated in said documents. Assignment of a specific task to an individual must be accompanied by an acceptance of such responsibility by said individual or no assignemnt exists.
Interrogatory A(2)(a)
List each individual for which you contend an agreement to accept specific responsibilities, established in the proposed RERP's and SOP's, must be listed in the above mentioned documents.
Interrogatory A(2)(b)
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Provide the basis for requiring that this acceptance be obtained
, from each individual listed in the answer to question A(2)(a) in order l for there to exsit a valid assignment of each function.
Interrogatory A(2)(c)
Provide the information for this interrogatory ' requested by Staff Question 1. ,
- 3. Not all local organizations have staff to initiate and maintain a response on a continual basis.
Personnel staffing is inadequate in many departments and agencies or organizations under normal conditions.
Interrogatory A(3)(a) ,
List each local organization that you contend 'does not have the staffing necessary to initiate and maintain a response on a continual basis.
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B. See 50.47(b)(P)'.' fpterfaces amo,ng" onsit,e .
response activities' and all offdte support and j ., - e.
response activitie's are not spec'if fed. -
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,y (1). No interface axists betw?en ondte and . -
all local gosenaents due to inadeqi.' ate f- '
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communications facilities and/or fomal a, gree:wnts. >
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InterrogatoryB(1)(a) j !' -
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.,j a., e f State the basis, technical and legal, 'for jour assert $nn that the '
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Interrogatory B(1_)(b) i
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Describe in ' detail the steps that you contend should be-taken to . ':1). J &
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correct any inadequacies in the communications network j Providethil', "' ,e
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,o Interrogatory B(1) c)
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List the specific agencies and support groups that you contend that ,
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the Applicant mus,t enter into formal agreement with to assure that these v
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groups will ,stwlf *onsite support in the event of 6n ,encrgency. Provide ,
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y Do you allego any other inadequacies in the interfaces among onsite response activities and offsite support and" response activities? ,If so,
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list: (i) these addi,tional inadequacies; (ii) your j;as'ig fce asserting these deficiencie's; (iii) the steps that you contfend 60 ld be taken to 1f Is/
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q correct these deficiencies; and (iv) the basis for these corrective measures, i
! , Interrogatory B(1)(e)
! ,/ Provide the information for this interrogatory requested by Staff p - l j.s _-'
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t'. Arrangements for requesting and effectively
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(1). All local assistance has not been
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their cooperation and participation in emergency p) response activities. Local response forces lack
,4, .c . communications equipment, radio-protective T1 ' equipment, training, support equipment and funding
. . to respond effectively.
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ll ikterrogatoryC(1)(a)
Do you contend that every source of local assistance must be
- identified in the Applicant's emergency plans? If so, provide the basis twy
! for your assertion.
Interrogatory C(1)(b)
List each emergency response organization or group that you contend j the Applicant must identify as having arranged for their cooperation and
- , , emergency response activities. Provide the basic for your answer.
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Interrogatory C(1)(c)
Describe what you contend the Applicant must do to assure and demonstrate that these groups will indeed cooperate in emergency response activities. Provide the basis for your answer.
Interrogatory C(1)(d)
List: (i) each local response force that you contend lacks the ability to respond effectively; (ii) what you contend each group lacks in the way of funding, equipment, and funding; (iii) the party that should be required to supply each of these needs; (iv) and the basis for your answer. .
Interrogatory C(1)(e)
Provide the information for this interrogatory requested by Staff Question 1.
(2). Formal interface with local governmental agents at Applicant's E0F does not mitigate the need for dedicated communications facilities for such agents use in contacting his local E0C. No such communications equipment has been identified or installed.
Interrogatory C(2)(a)
State the basis for requiring dedicated communications facilities for the use of local government agents in contacting their local E0C's from the Applicant's E0F.
Interrogatory C(2)(b)
Discuss why formal interface with local government agents at the Applicant's EOF does not mitigate the alleged need for dedicated communications facilities. Provide the basis for your answer.
Interrogatory C(2)(c)
Describe in detail the communications network that you contend must be installed in order to provide dedicated communications between the Applicant's E0F and the local E0C for local government agents. Provide the technical and regulatory bases for your answer.
Interrogatory C(2)(d)
Provide the information for this interrogatory requested by Staff Question 1.
D. See 50.47(b)(4). A standard emergency classification system has been established, but no emergency action level scheme is included.
l l Interrogatory D(a)
State your basis for asserting that no emergency action level scheme has been established in the emergency classification system.
Interrogatory D(b)
State: (i) the steps that you contend must be taken to establish emergency action levels; (ii) what you contend these levels should be; and (iii) the basis for your answer.
Interrogatory D(c)
Provide the information for this interrogatory requested by Staff Question 1.
(1). Only emergency notification of personnel is included in the SOPS and the SOPS do not include specific actions to be taken.
Interrogatory D(1)(a)
Provide the regulatory basis for requiring the SOP's to include the specific actions that are to be taken by emergency personnel upon notification of an accident. Interrogatory D(1)(b) ,
List: (i) each personnel category whose specific actions in the event of an emergency you contend must be included in the S0P; (ii) what you contend these actions must be; and (iii) the basis for your answer.
Interrogatory D(1)(c)
Provide the information for this interrogatory requested by Staff Question 1.
(2). The proposed local plans do not include duties to be performed by personnel when alerted 4 (notified) or duty stations to which they report to perform said duties.
e 0 Interrogatory D(2)(a)
Provide the regulatory basis for requiring the local emergency plans to include the duties to be performed by personnel and the duty stations to which they report to perform these duties when alerted of an accident.
Interrogatory D(2)(b)
List: (i) each personnel category for which you contend that the local emergency plans should include the duties to be performed and the duty stations at which this performance must take place; (ii) the precise duties that each personnel category must perform; (iii) where this performance must take place; and (iv) the basis for your answer. .
Interrogatory D(2)(c)
Provide the information for this interrogatory requested by Staff Question 1.
E. See50.47(b)(5). Procedures have been established for notification, by the licensee, of State and local response organizations (local sheriffs' offices and the Missouri E.M. A. via the Missouri Highway Patrol), but no provision exists for notification of emergency personnel by all organizations who may respond or be needed to respond.
(1). County administrative judges may never be reached if they are away from their phones at home. The function of an administrative judge is considered "part time" and some Courts sit one day a week.
. o Interrogatory E(1)(a)
Describe the function performed by the County administrative judges in the local emergency response. Include the time period in which you contend they must be notified to effectively perform this function.
Interrogatory E(1)(b)
List each administrative judge that has an emergency response function and provide the days that each one actually sits in court.
Interrogatory E(1)(c)
Describe in detail the procedures that you feel must be put in place -
to ensure that these judges can be reached when needed. In particular, list any other jobs that these officials hold or other places that they can be reached when not in court.
Interrogatory E(1)(d)
Provide the information for this interrogatory requested by Staff Question 1.
(2). Sheriff's deputies, some fire personnel, police officers, and other emergency response workers, to include school bus drivers lack communications equipment if they are away from their home phones. Bus drivers, especially, need communications equipment when they are enroute to and from schools with students. In such cases, i without specific notice of required actions to be l taken, children's health and safety is at risk.
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Interrogatory E(2)(a)
Identify all categories of emergency response workers for which you contend the currently proposed notification procedure is inadequate.
Provide the basis for your answer.
Interrogatory E(2)(b)
Do you contend that each individual in each category must be notified immediately after the declaration of an emergency in order for there to be an effective emergency response? If not, how many in each group must be initially notified for there to be an effective response.
Interrogatory E(2)(c)
Do you contend that the current notification plan will not notify the minimum number of workers needed to have an effective initial response to the emergency? If so, state the steps that you contend must be taken to ensure an adequate initial notification and response.
Interrogatory E(2)(d)
Provide the basis for your answers to Interrogatories 2(b) and 2(c).
l Interrogatory E(2)(e) l If you contend that all members of each category of emergency workers must actually be notified upon the declaration of an emergency, provide the basis for this assertion.
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Interrogatory E(2)(f)
For each category of emergency workers listed in the answer to Interrogatory E(2)(a), list the steps that you contend are necessary to provide for the correct level of communications. Include a list of the equipment that allegedly must be provided to each group and state the party that must supply this equipment.
Interrogatory E(2)(g)
Provide the basis for your answer to Interrogatory E(2)(f).
Interrogatory E(2)(h) ,
In particular, explain how the lack of enroute communications capability with school bus drivers during normal operations endangers the health and safety of the students. List the specific schools and bus routes that would be put in danger in an emergency situation due to this lack of enroute comunications.
Interrogatory E(2)(i)
Provide the basis for the answer to Interrogatory E(2)(h).
Interrogatory E(2)(j)
Provide the information for this interrogatory requested by Staff Question 1.
F. See50.47(b)(6). Provisions for prompt l communications between principal response organizations and emergency response personnel do not exist.
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(1). Inadequate communications facilities exist at all local governmental levels to communicate effectively between all E0Cs and emergency personnel in the field.
Interrogatory F(1)(a)
List: (1) the emergency personnel in the field that you contend that all E0C's must have the ability to communicate with; (ii) the steps that must be takt_n to establish this level of communication; and (iii) the basis for your answer.
Interrogatory F(1)(b)
Describe in detail: (i) the communication network that you contend must be established in order to provide for adequate communication between all E0Cs; (ii) why the present communication plan does not meet this standard; and (iii) the basis for your answer.
Interrogatory F(1)(c)
Provide the information for this interrogatory requested by Staff Question 1.
(a). Reliance on the Sheriff's radio net for the transmission of emergency traffic relating to a radiological emergency as well as the normal law enforcement traffic it carries constitutes an overload to the system and interferes with the primary mission for which the net was intended.
Interrogatory F(1)(a)(1)
Provide the basis, technical and otherwise, for your assertion that the Sheriff's radio network will be overloaded if used for the transmission of emergency messages related to a radiological emergency.
Interrogatory F(1)(a)(2)
Describe what alternative system you would require in place of the Sheriff's radio network for the transmission of messages related to a radiological emergency. Provide the basis for requiring the described system.
Interrogatory F(1)(a)(3)
Do you contend that the ordinary traffic over the Sheriff's radio network cannot be preempted for the transmission of messages dealing with a radiological emergency? If so, provide the basis for your contention.
Interrogatory F(1)(a)(4)
If not, state whether the Sheriff's radio network will be overloaded by the preemptive radiological emergency messages alone. Provide the basis for your answer.
Interrogatory F(1)(a)(5)
Provide the information for this interrogatory requested by Staff Question 1.
(2). No communications networks or equipment for such nets exist for field use between operating
units or for contact between field units and command headquarters.
Interrogatory F(2)(a)
Define the terms " operating units," " field units," and " command headquarters" as used by you in section F.2.
Interrogatory F(2)(b)
Provide the basis for requiring that communication networks between these units and command headquarters be in place.
Interrogatory F(2)(c)
Provide the information for this interrogatory requested by Staff Question 1.
(a). Reliance on existing law enforcement or fire response nets is inadequate due to the short range of such existing equipment, dead spots in area coverage, and a potential for net overload as indicated above.
Interrogatory F(2)(a)(1)
Provide the reasons and bases for and supporting the above assertion.
Interrogatory F(2)(a)(2)
Discuss the alleged short range, dead spots, and potential for overload in the existing fire response and law enforcement networks. In
particular, explain (i) why these problems render the communications system inadequate; (ii) the steps that must be taken to correct these problems; (iii) the party that should be responsible for taking each corrective measure; and (iv) the basis for your answer.
Interrogatory F(2)(a)(3)
Describe the test by which you contend this communications network must be tested and the basis for your answer.
Interrogatory F(2)(a)(4)
In addition to the problems with the communications network listed .
in Interrogatory F(2)(a)(2), list in detail: (i) any other shortcomings in meeting the standard listed in Interrogatory F(2)(a)(3); (ii) the steps that must be taken to correct any problem; and (iii) the basis for your answer.
Interrogatory F(2)(a)(5)
Provide the information for this interrogatory requested by Staff Question 1.
G. See 50.47(b)(7). Formal informational links do not exist between Applicant and all local governments impacted by the 10 mile EPZ. No letters of agreement have been signed by media personnel to perform public informational duties with or without fees for such services.
Interrogatory G(a)
List all the local governments impacted by the 10 mile EPZ that you contend do not have formal informational links with the Applicant.
Provide the basis for your answer.
Interrogatory G(b)
List and describe: (i) the basis for requiring such informational links; (ii) the standard by which the adequacy of such links must be measured; (iii) the steps that must be taken to bring the links with each of the local governments listed in Interrogatory G(a) up to this standard; and (iv) the bases for your answers. Interrogatory G(c) ,
Provide any reasons that you have for believing that media personnel will not perform public informational services.
Interrogatory G(d)
Provide the basis for requiring that letters of agreement to perform public informational duties be acquired from media personnel.
Interrogatory G(e)
Define the term "public informational duties" as used by you in section g to the discussion of Reed's Contention 1.
Interrogatory G(f)
Provide the information for this interrogatory requested by Staff Question 1.
H. See50.47(b)(8). Adequate emergency facilities and equipment to support emergency response are not provided nor maintained at the local level of government.
(1). Local governments do not have Emergency Operating Centers (E0Cs), nor the equipment for the creation of such facility.
Interrogatory H(1)(a)
List the equipment that you contend each local government needs in order to create emergency operating centers. State the basis for requiring the equipment that you list. Interrogatory H(1)(b)
Are the local governments in the process of obtaining this equipment or do they intend to acquire the equipment to develop these facilities?
Interrogatory H(1)(c)
Who do you contend should be responsible for providing the necessary equipment? Provide the basis for your answer.
Interrogatory H(1)(d)
Provide the information for this interrogatory requested by Staff Question 1.
(2). Emergency response personnel do not have radiation protection equipment, communications t
equipment, nor'is such available to them for use at the outset of a radiological accident at the power plant.
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Interrogatory H(2)(a)
Identify each category of personnel that you contend does not have adequate protection and communications equipment and specify the exact equipment that you contend must be made available for each category.
Provide the basis for your answer.
Interrogatory H(2)(b)
Are there stockpiles of radiation protection and communications available in Missouri that could be sent to the Callaway site in the event of an emergency? If so, describe the content and location of these stockpiles and state how long it would take to transport this equipment ,
to the local emergency workers.
Interrogatory H(2)(c)
If stockpiles do not exist, describe the exact type and quantity of equipment that you contend is needed.
Interrogatory H(2)(d)
State what party you contend should be responsible for supplying each type of equipment listed in the answer to Interrogatory H(2)(c).
Provide the basis for your answer.
Interrogatory H(2)(e)
List: (i) any other objections that you have to the adequacy of emergency facilities and equipment maintained by the local governments;
(ii) the steps that should be taken to correct any shortcomings; and (iii) the basis for your answer.
Interrogatory H(2)(f)
Provide the information for this interrogatory requested by Staff Question 1.
I. See50.47(b)(9). Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequances of a radiological emergency condition are not in use or available at State or local government levels.
(1). No ability exists to detect or measure -
alpha emissions or presence of radio-iodines at State or local levels of government.
Interrogatory I(1)(a)
Provide the basis for requiring State and local governments to maintain the ability to monitor alpha emissions and radio-iodines.
Interrogatory I(1)(b)
Describe the equipment and procedures that you contend the State and local governments must procure in order to maintain the ability to monitor alpha emissions and the presence of radio-iodines. Provide the basis for your answer.
Interrogatory I(1)(c)
Provide the information for this interrogatory requested by Staff Question 1.
(2). No protective equipment is available to fire-fighters, law enforcement officers or other emergency workers who may man roadblocks or monitor evacuees leaving a contaminated or suspected contaminated area.
Interrogatory 1(2)(a) l Provide the basis for requiring that emergency workers, manning roadblocks or monitoring evacuees from a suspected contaminated area, be i
provided with protective equipment.
Interrogatory I(2)(b)
Specify the protective equipment that you contend should be supplied ,
to emergency workers. Provide the basis for your answer.
Interrogatory I(2)(e)
Provide the information for this interrogatory requested by Staff Question 1.
(3). No pre-sited decontamination centers are identified or established for evacuees or emergency workers who may become contaminated as a result of a radiological accident at the plant.
I Interrogatory I(3)(a)
Provide the basis for requiring that pre-sited decontamination centers be identified and established.
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Interrogatory 1(3)(b)
State the equipment and facilities that must be provided to establish these centers. Provide the basis for your answer.
Interrogatory I(3)(c)
Upon what party do you contend that the responsibility for establishing these centers rests? Provide the basis for your answer.
Interrogatory I(3)(d) (
Where do you contend that these centers should be located? Provide the basis for your answer. .
Interrogatory I(3)(e)
Provide the information for this interrogatory requested by Staff Question 1.
(4). No facilities exist in the State of Missouri (except at the plant site) for evaluation of personnel exposures to radiation or their biological uptake of radio-nuclides.
Interrogatory I(4)(a)
Provide the basis for requiring that facilities for the evaluation of personnel exposures to radiation or their biological uptake of l
radionuclides, in addition to those maintained at the plant site, be in place.
Interrogatory I(4)(b)
State what equipment and facilities are needed to provide evaluation of radiological personnel exposures. Provide the basis for your answer.
Interrogatory I(4)(c)
State where the facilities and equipment should be located and who should have the responsibility for creating, maintaining, and operating them. Provide the basis for your answer.
Interrogatory I(4)(d)
Provide the information for this interrogetory requested by Staff .
Question 1.
(5). Proposed use of Applicant's onsite facilities for evaluation of evacuee and emergency workers radiological exposure and/or biological uptake of radio-nuclides is impractical in an evacuation situation wherein personnel are being directed away from the plant for safety reasons, also, Applicant has not authorized the on-site facilities for such use by either State or local governments. (see State REPR, pg F1.1)
Interrogatory I(5)(a)
Explain in detail why the use of the Applicant's onsite facilities for the evaluation of radiological exposure and biological uptake of
- radionuclides is impractical. Provide the basis for your answer.
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Interrogatory I(5)(b)
Could the Applicant's facilities to monitor for the evaluation of radiological exposures be moved offsite or used in some other manner that does not endanger the emergency workers and evacuees when evacuation of the area around the site is necessary?
Interrogatory I(5)(c)
If so, explain the method that could be used.
Interrogatory I(5)(d)
Do you have any reason to believe that the Applicant will not use ,
these facilities to evaluate the radiological exposure of evacuees and emergency workers? If so, describe what they are.
Interrogatory I(5)(e)
Provide the basis for requiring the Applicant to officially authorize such a use by the State and local governments in order to be assured that this evaluation will be done.
Interrogatory I(5)(f) f State: (i) any other objections that you have to the systems, methods, and equipment in place to assess and monitor the consequences of a radiological accident; (ii) the corrective steps that you contend must take place; and (iii) the basis for your answer.
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Interrogatory I(5)(g)
Provide the information for this interrogatory requested by Staff Question 1.
J. See 50.47(b)(10). A range of protective actions have not been developed for the plume exposure pathway EPZ for emergency workers or the public which protect against radiation (direct or ingested), nor are such in place. Protective actions for the ingestion exposure pathway EPZ appropriate to the locale have not been developed.
(1). Evacuation is established in the State RERP as preferable to use of pottassium [ sic]
iodide (KI) as protection against inhalation /
ingestion of radio-iodines; however, evacuation is considered secondary to in-place shelter as a -
protective measure. (see M0. RERP, pg B5 and Bil).
Interrogatory J(1)(a)
Do you contend that potassium iodide must be distributed whenever sheltering is done in preference to evacuation in order to render sheltering safe? If so, provide the basis for your answer.
Interrogatory J(1)(b)
If not, state in explicit terms your objection to the order of protective actions in the State's REPR.
Interrogatory J(1)(c)
If you do not contend that potassium iodide is always necessary to render sheltering safe, describe the situations where you contend that it is necessary and is not necessary. Provide the basis for your answer.
Interrogatory J(1)(d)
Provide the information for this interrogatory requested by Staff Question 1.
(2). State of Missouri recommends use of folded man's handkerchief over the nose for respiratory protection (see M0. RERP, pg C21).
This is not in accordance with provisions of 10 C.F.R., part 20 or NRC Regulatory Guide 8.15 for respiratory protection devices.
Interrogatory J(2)(a)
State the exact provisions of 10 C.F.R. Part 20 and Regulatory Guide 8.15 that you contend the recommended use of a folded man's handkerchief for respiratory protection violates.
Interrogatory J(2)(b)
State what protective measures that you contend the State of Missouri should recommend for respiratory protection. Provide the regulatory and technical bases for your answer.
Interrogatory J(2)(c)
Provide the information for this interrogatory requested by Staff Question 1.
l (3). Use of KI for emergency workers and the general population residing within the plume j exposure pathway EPZ to protect the thyroid from the destructive effects of radio-iodines has been deemed by the U.S. Food and Drug Administration to be both safe and effective. The Commission has no l
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objection to such use and the Tennessee Valley i Authority (TVA) has issued KI for general use at Soddy / Daisy, Tennessee. This constitutes Federal guidance in this matter, also see EPA-520/1-75-001.
1 Interrogatory J(3)(a)
Do you contend that distribution of KI to emergency workers and the general population in the plume exposure pathway EPZ is required? If so, state the basis for your assertion.
Interrogatory J(3)(b)
Do you contend that there are no other effective means of protecting workers and the population from the effects of radio-iodine? If so, provide the basis for this assertion.
Interrogatory J(3)(c)
If not, describe the other protective measures that you would deem as adequate. Provide the basis for your answer.
Interrogatory J(3)(d)
Provide the information for this interrogatory requested by Staff Question 1.
(4). No pre-located decontamination facilities are established or identified for evacuees and/or emergency workers. Portable units are not immediately available for use by contaminated individuals.
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Interrogatory J(4)(a)
State the basis for your assertion that portable decontamination units are not immediately available for use by contaminated individuals.
Interrogatory J(4)(b)
In particular, state how many portable decontamination units are available in the State and how long it would take to provide them to persons contaminated due to an accident at the Callaway site. Provide the basis for your answer.
Interrogatory J(4)(c) ,
State how many portable units you contend are needed and what party you contend has the responsibility to provide them. Provide the basis for your answer.
Interrogatory J(4)(d)
Provide the same or similar information for this Interrogatory J(4) as requested in Interrogatory 1(3)(a)-(d) to the extent that the information differs as related to the range of protective actions
- required in the plume exposure EPZ.
Interrogatory J(4)(e)
State: (i) any other objections that you have to the range of protective actions developed for the plume exposure pathway EPZ for emergency workers and the public; (ii) the corrective measures that you contend must be taken; and (iii) the basis for your answers. In
particular, discuss any protective actions for the ingestion exposure pathway EPZ, peculiar to the locale, that you contend should be developed.
Interrogatory J(4)(f)
Provide the information for this interrogatory requested by Staff Question 1.
K. See50.47(b)(11). Means for controlling radiological exposures of emergency workers at the local level of government have not been established.
(1). No protective equipment is available for each emergency worker, nor is there an adequate detection and measurement capability at State or local levels of government for alpha emissions or radio-iodines. (see State RERP, pg DS, DS.1, A2B.2)
Interrogatory K(1)(a)
State: (i) the equipment that you contend must be provided for each emergency worker; (ii) the number of workers that it must be provided for; (iii) the party that must supply it; and (iv) the basis for your answer.
Interrogatory K(1)(b)
Do the State and local governments have to provide monitoring of alpha emissions or radio-iodines or may the Applicant supply this monitoring? Provide the basis for your answer.
r
Interrogatory K(1)(c)
Does the Applicant now have the capability to supply this monitoring for the State and localities? If not, state the steps and equipment necessary to provide this capability. ' T Interrogatory K(1)(d)
If you contend that the Applicant cannot supply this monitoring capability for the State and localities, provide the steps and equipment needed to ensure their capability to provide this monitoring.
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Interrogatory K(1)(e) .
List: (i) any other objections that you have to the local government's ability to control the radiological exposures of emergency workers; (ii) the corrective steps that should be taken; and (iii) the basis for your answer. ;
Interrogatory K(1)(f)
Provide the information for this interrogatory requested by Staff l Question 1.
l
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l L. See50.47(b)(2). Arrangements have not been ' <
i made for medical services for contaminated, injured ~
individuals (emergency workers and residents living j within the plume exposure pathway EPZ).
(1). No agreements exist with local ambulance districts to transpnrt such victimes (patients). '
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4 Interrogatory L(1)(a) ,
J Provide any reasons or basis for asserting that local ambulance districts will not transport radiological victims.
Interrogatory L(1)(b)
- State what you contend must be done in order to edequately demonstrate that the local ambulance districts will transport.
radiological victims. Provide the basis for your answer.
- Interrogatory L(1)(c) j What percentage of the.Tocal districts do you contend must agree in -
j order to provide adequate transportatir injured parties? Provide the basis for your answer. ,
Interrogatory L(1)(d)
Provide the information for this interrogatory requested by Staff Question 1.
l (2). No agreements with ambulance districts outside the local area to provide transport for radiologic' ally contaminated, injured individuals are in , existence.
Interrogatory L(2)(a)
Provide any reasons or basis for asserting that ambulance districts outside the-local area will not transport radiologically contaminated, s
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injured persons. In articular, idintif$ any <dbtricts that you contend j ,/ . .. t '
will not tr'ansport stich patien.ts. /,I j'
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1, I Interrogatory L'2): )
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State what,yof, contend must be done in order to adequately-demonstrate thad thea *atu?ance districts outside the local area will transport radiological yictims. Provide the "basis for your answer. "
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- Interrogatory L(2)(c) ,
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What percentage' of these districts do you conMnd must agrep in L 3
order to provide adequate transportation for
- injured persons? Provide '
7 the basis for your answer. ., s , , 1 r-1 ', .
Interrogatory L(2)(d) ' '
Do you contend that the cooperation of these ambulance districts is necessary to provide adequate transportation 'to' injured, contaminated t
persons? If so, provide the basis for your.arswer. ,
P Interrogatory L(1)(e)
Provide the information for this interrogatory requested by Staff Question 1.
, (3). No capability exists in the State of l Missouri (outside Applicant's facility onsite) to fully measure radiological exposure or biological l uptake of radio-nuclides. (see M0. RERP, pg F1.1) l I
l l
4 l Interrogatory L(3)(a)
State the basis for your assertion that no facility in the State of Missourf has the capability to fully measure radiological exposure or biological uptakes of radionuclides.
j Interrogatory L(3)(b) .
I
- List and describe the capability of every medical unit in Missouri l j with facilities to evaluate radiological exposure.
Interrogatory L(3)(c)
~
',. List any facilities outside the State with the capacity to evluate -
, , radiological exposure and biological uptake that could be used for the j
treatment of persons contaminated due to an accident at the Callaway 3
site.
1 s Interrogttory L(3)(d)
Upon what party would you place the burden of developing the capability of local medical facilities to evaluate the radiological exposure and biological uptake of contamination victims? State the basis for your answer.
Interrogatory L(3)(e)
Provide the information for this interrogatory requested in Staff Question 1.
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(4). No agreement exists with Applicant to use its onsite facility for biological evaluations of radiological exposure or uptake and such use would be impractical during an accident requiring facility evacuation.
Interrogatory L(4)(a)
Provide any reasons or basis that you have for asserting that the Applicant will not allow the use of its onsite facilities for the evaluation of the radiological exposure or biological uptake of emergency workers or the public.
Interrogatory L(4)(b) .
Provide the basis for requiring a formal agreement with the Applicant for the use of these facilities.
Interrogatory L(4)(c)
Explain why these facilities could not be removed from the Callaway site or used in some other way that would not result in danger to the public or emergency workers, in the event of an accident.
Interrogatory L(4)(d)
Provide the information for this interrogatory requested in Staff Question 1.
M. See50.47(b)(13). No general plans for recovery or reentry are developed at the local level of government.
---,-,-r - - - - . - , . . -
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(1). A simple statement of reentry controls and authorization does not constitute a plan. No implementin procedures)ginstructions(detailed,stepbystep exist for recovery / reentry or general area decontamination in State or local plans.
Interrogatory M(1)(a)
Provide the factual or regulatory basis for the assertion that step by step plans for recovery / reentry are required.
Interrogatory M(2)(a)
Provide the information for this interrogatory requested by Staff Question 1. -
N. See 50.47(b)(14). No local authority or organization has agreed to participte in either drills or exercises.
Interrogatory N(a)
Identify each local authority or organization that must participate l in either drills or exercises.
l Interrogatory N(b)
Provide the information for this interrogatory requested by Staff i
l Question 1.
O. See50.a7(b)(15). No program for radiological training exists outside of general guidance in the State of Missouri and Applicant's RERPs, nor have local emergency workers been trained in response procedures.
I I
Interrogatory 0(a)
Provide the factual or regulatory basis for the assertion that more than general guidance for radiological training programs is required in emergency plans.
Interrogatory 0(b)
Briefly describe the depth of the details for radiological training programs it is contended must be provided for in the emergency plans.
Interrogatory 0(c) .
Provide the information for this interrogatory requested by Staff Question 1.
P. See50.47(b)(16). Local planners do not exist at all local governmental levels, nor are responsibilities for local emergency plan development, review and distribution established.
No planners are trained at the local level of government, nor is a training program for such plannersinexistance[ sic].
Interrogatory P(a)
Provide the factual or regulatory basis for the assertions that
, (1) local planners are required at all local governmental levels; and (2) responsibilities for local emergency plan development, review and distribution must be established in training program for local planners.
L
Interrogatory P(b)
Identify each local government level at which it is contended planners must exist.
Interrogatory P(c)
For each entity identified in your response to Interrogatory P(b),
identify the number and types of planners it is contended are required.
Interrogatory P(d)
Describe the training program (in terms of depth of training) it is contended it is necessary to adequately train local planners. .
Interrogatory P(e)
Provide the information for this interrogatory requested by Staff Question 1.
REED'S CONTENTION N0. 2 Funding of local government to meet radiological safety response capability has not been adequately addressed by NRC, FEMA, or other Federal Agency.
Failure to resolve the problem of funding for emergency planning and response capability at the local level of government will result in a placing of responsibility for supporting commercial nuclear power plants upon governmental jurisdictions which do not have the financial ability to meet established NRC criteria for the protection of public health and safety. This is a contradiction of Conmission policy and intent (PS-31, 44 FR 61123,10/23/79). To defer action on this matter l
until after the Callaway Plant is in operation can adversely affect the health and safety of the public as regards any radiological incident due to the operation of this facility.
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Interrogatory 2(a)
Is it your contention that the radiological emergency response capability at local levels will be unable to meet NRC and FEMA requirements if funding is not provided to local governments and/or organizations? If your answer is yes, answer Interrogatories 2(b)-2(e).
Interrogatory 2[b),
Identify each local organization (local governmental body or any local agency) that requires funding.
Interrogatory 2(c) .
For each organization identified in your response to 1 Interrogatory 2(b), describe the response role it will play in a radiological emergency at the Callaway facility.
Interrogatory 2(d)
For each organization identified in your response to Interrog: tory 2(b), estimate the amount of funding required. Break down your estimate to reflect startup costs, annual costs, and special costs j that might be incurred in an actual emergency. Include in your estimate the purpose of the funds (e.g., training, equipment, salaries, etc.).
Interrogatory 2(e)
For each organization identified in your response to ,
Interrogatory 2(b), list the NRC/ FEMA requirements (with references to specific provisions of 10 C.F.R. Part 50, NUREG-0654, or whatever other
regulatory basis is alleged) that cannot be met by such organization if funding is not provided.
Interrogatory 2(f)
Provide the information for this interrogatory requested by Staff Question 1.
REED'S CONTENTION NO. 3 "There has not been an adequate definition of the
! allocation of responsibilities for offsite emergency plar.ning between state and local -
organizations, as provided in NUREG-0654."
The following interrogatories refer by number to the " Planning Inadequacies" alleged on pages 16-32 of " Final Particularization of Reed's Contentions 1, 2, and 3."
- 1. Not all local or private sector response agencies have been identified as required in criteria A,1.a.
Failure to include fire protection districts in all counties, ambulance companies, etc. will be verified by absence of such in plans and testimony of individuals in such agencies.
Interrogatory 1(a)
Identify each local and/or private sector response agency which has not been identified as required in Criterion A.1.a.
Interrogatory 1(b)
For each organization identified in your response to 1(a), provide the basis for your belief that these organizations are required to be
part of the overall response organization. In your response, include:
(i) the particular function each organization will perform in the overall response organization; (ii) the organization currently designated in the plans to perform such function; and (iii) the basis for your belief that the organization listed under (ii) will be unable to perform the function.
Interrogatory 1(c)
Provide the information for this interrogatory requested by Staff Question 1.
- 2. Concepts of operations and relations to the total effort is not specified as required in A,1.b. for each organization or suborganization. The failure of hospitals, ambulance districts, fire departments, but companies, trucking companies and.
law enforcement agencies to indicate how they will function will be verified by the absence of such specification in plans and by individual testimony as required.
Interrogatory 2(a)
Identify each organization or suborganization for which it is con-tended that the organization's (or suborganization's) concept of operations and relationship to the total effort is not specified.
Interrogatory 2(b)
For each organization or suborganization listed in your response to Interrogatory 2(a), state whether the organization is referenced in either the Applicant's, the State's, or any local plans. If the
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organization (or suborganization) is referenced in any of the above-mentioned plans, identify the reference and provide the basis for the allegation that the specification required by N'JREG-0654, II. A.1.b is not provided. If the organization (or suborganization) is not referenced in any of the above-mentioned plans, please provide the information relative to each such organization (or suborganization) requested in Interrogatory 1(b) of Contention 3.
Interrogatory 2(c)
Provide the information for this interrogatory requested by Staff Question 1.
- 3. No identification of the individual in charge has been included for each organization as required in A,1.c.
Interrogatory 3(a)
Identify each organization for which it is contended the individual in charge has not been identified.
Interrogatory 3(b)
Provide the information for this interrogatory requested by Staff Question 1.
, 4. Not all authorities for inclusion of incorporated cities, towns, or villages in county response activities are contained in local RMRPs as required in A,2.b. Absence of such agreements / contracts and official testimony will verify this item.
Interrogatory 4(a)
Identify each incorporated city, town, or village for which it is contended the authorities required in Evaluation Criterion A.2.b are not provided.
Interrogatory 4(b)
If any city, town, or village listed in your response to Interrogatory 4(a) is not referenced in local REPR's, state: (i) the basis for your belief that each such city, town, or village is required to be included in the RERP's; (ii) describe the function (s) to be per-formed by the city, town, or village; (iii) identify the entity currently ,
designated in the RERP's to perform such function (s); and give the basis for your belief that the entity currently designated to perform such function (s) is incapable of doing so.
Interrogatory 4(c)
State the basis for the belief that " agreements / contracts" have anything to do with Evaluation Criteria A.2.b.
Interrogatory 4(d)
Provide the information for this interrogatory requested by Staff Question 1.
1
- 5. Not all State / local governmental agencies and other support organizations have written agreements in-dicating acceptance of emergency measures to be provided, mutually acceptable criteria or arrange-
ments for exchange of information as required in A,2.&3.
Interrogatory 5(a)
Identify the prospective parties (state / local governmental agencies and other support organizations) to the written agreements which it is contended are required by Evaluatton Criteria A.2 and A.3.
Interrogatory 5(b)
For each party identified in your response to Interrogatory 5(a),
state whether the party is currently included in either the Applicant's, State's, or any local plan. For each party not included in any plan, (i) provide the basis for the belief that the party is required to be included in the plan (s); (ii) describe the function (s) to be performed by the agency or organization; (iii) identify the entity currently designated to perform such function (s); and (iv) provide the basis for the belief that the entity identified in response to-(iii) is incapable of performing the function in question.
Interrogatory 5(c)
Provide the information for this interrogatory requested by Staff Questien 1.
- 6. Not all principal organizations have 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operational capability for protracted periods as required by A,4. Volunteer organizations cannot provide individuals on any but short term operations.
Interrogatory 6(a)
Identify all the principal organizations which it is contended lack the capability to operate continuously (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) for protracted periods.
Interrogatory 6(b)
For each organization listed in your response to Interrogatory 6(a),
describe the function (s) to be performed by the organization and provide the basis for the belief that the organization is a " principal organization" to be included in Criterion A.4.
Interrogatory 6(c)
Identify those organizations listed in your response to Interrogatories 6(a) and 6(b) that are " volunteer organizations."
Interrogatory 6(d)
For each organization listed in your response to Interrogatory 6(c),
provide the basis for the belief that individuals can not be provided on any but short term operations.
Interrogato"y 6(e)
Provide the information for this interrogatory requested by Staff Question 1.
- 7. RERPs fail to identify facilities, organizations and individuals who can be relied upon for emergency assistance as required by C,4. Absence
of letters of agreement with facilities, organizations and individuals (bus drivers, truck drivers, monitor personnel, etc.) and testimony of such individuals shall support this item if needed.
Interrogatory 7(a)
Identify the facilities, organizations, and individuals that it is contended must be (and are not) identified in the RERP's.
Interrogatory 7(b)
For each facility, organization, or individual included in your response to Interrogatory 7(a), describe (i) the basis for the belief that they must be identified in the RERP's; (ii) the function of the facility, organization, or individual would perform in an emergency; (iii) the entity currently designated to perfonn such function; and (iv) the basis for the belief that the entity identified in response to (iii) is incapable of performing such function.
Interrogatory 7(c)
Provide the information for this interrogaoty requested by Staff Question 1.
- 8. No procedures are in place to provide for emergency actions as required in D,4. No RERP/ SOP outlines specific actions to be taken if emergency actions are recommended by the Applicant.
Interrogatory 8(a)
Is it contended that procedures and specific actions are lacking for every State and local organization, or only for certain specific organizations?
i Interrogatory 8(b)
If the response to 8(a) is that procedures and actions are lacking for only certain organizations, identify ea-5 such organization. For all such organizations refe-enced in the State and local plans, describe (with references to the plans themselves) the emergency actions and procedures to ba taken by such organizations as provided in the plans and provide the basis for the belier that such provisions are inadequate.
Interrogatory 8(c)
If the response to 8(a) is that all organizations lack procedures for energency actions, describe (with references to the plans themselves) -
the actions and procedures to be taken by the Counties of Callaway and Osage as provided in the plans and provide the basis for the belief that such provisions are inadequate. If your answer would substantially differ if organizations other than Callaway and Osage Counties were addressed, identify such organizations and explain why your answer would substantially differ.
Interrogatory 8(d)
Provide the information for this interrogatory requested by Staff Question 1.
- 9. No organization (including sub-organizations) has a procedure for alerting / notifying / mobilization at the local levels of government as required by E,2.
Week-ends, non-duty hours, etc. are not provided for in local RERPs.
Interrogatory 9(a)
Identify each organization you contend must develop the notification procedures called for in Criterion E.2.
Interrogatory 9(b)
Provide the basis (including reference to the various plans) for the assertion that no organization has notification procedures. If it is contended that written procedures are inadequate in any way, identify the alleged inadequacies and supply your basis therefor.
Interrogatory 9(c) .
Provide the basis (including reference to the various plans) for the assertion that weekend and nonduty hours are not provided for.
Interrogatory 9(d)
Provide the information for this interrogatory requested by Staff Question 1.
- 10. No written messages contain instructions with regard to specific actions to be taken by occupants of affected areas as regards effective respiratory protection and thyroid protection as required in E,7. for short term or protracted shelter or evacuation. Absence of such information in RERPs and SOPS will verify this item.
Interrogatory 10(a)
Define what you mean by " effective respiratory protection" and
" thyroid protection".
Interrogatory 10(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 11. No communications facilities exist for sustained communications between local E0Cs and emergency response field teams, or between members of such field teams at separate sites, to include support services that may be required as specified in F,1.d.
Interrogatory 11(a)
Identify the local E0C's and emergency response field teams which you content require communication facilities as specified in Criterion F.1.d.
Interrogatory 11(b)
For each organization identified in your response to Interrogatory 11(a), describe the communication facilities you contend are required by Criterion F.1.d.
Interrogatory 11(c)
Provide the information for this interrogatory requested by Staff Question 1.
- 12. No provisions are included in local RERPs for alerting / activating emergency personnel in each response organization as required in F.1.e.
Interrogatory 12(a)
Identify the response organizations for which you contend provisions for alerting / activating emergency personnel as required in Criterion F.1.e. are lacking in local RERPs.
l
, Interrogatory 12(b) i Provide the information for this interrogatory requested by Staff Question 1.
- 13. No coordinated communications for fixed and mobile medical support exists in all local governments as required in F,2. .
Interrogatory 13(a)
Identify each local government for which it is contended no coordinated communications exist as required in Criterion F.2.
Interrogatory 13(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 14. No E0F exists at all local governments as required in H,3.
Interrogatory 14(a)
! Identify each local government for which it is contended that r.o E0F exirts as required in Criterion H.3.
l
Interrogatory 14(b)
Provide the information for this interrogatory requested in Staff Question 1.
- 15. No local radiological monitor equipment capable of detecting or measuring iodines or alpha particles exists in the vicinity of the nuclear facility as called for in H,7.
Interrogatory 15(a)
Provide the basis for the assertions that Criterion H.7 requires
" local radiological monitor equipment."
Interrogatory 15(b)
If it is contended that offsite radiological monitoring equipment as provided for in the various emergency plans is inadequate for the detection or measurement of iodine or alpha particles, supply the basis for such a contention. Include in your response the equipment you contend is necessary for adequate detection and measuring.
Interrogatory 15(c)
Provide the information for this interrogatory requested in Staff Question 1.
- 16. No reserve equipment is pro /ided as required in H,10.
Interrogatory 16(a)
Provide the basis for the assertion that no reserve equipment is provided.
_ . _ _a
Interrogatory 16(b)
Identify the type and extent of reserve equipment you contend is required by Criterion H.10.
Interrogatory 16(c)
Provide the information for this interrogatory requested by Staff Quartion 1.
- 17. No protective, communications, radiological monitoring equipment and emergency supplies is appendixed to local RERP. as required in H,11.
Interrogatory 17(a) ,
Provide the information for this interrogatory requested by Staff Question 1.
- 18. No central point for receipt and analysis of all field monitor data and sample media exists at local government levels as required in H,12.
Interrogatory 18(a)
Identify the local government levels that you contend are required by Criterion H.12 to establish central points for receipt and analysis of all field monitor data.
Interrogatory 18(b)
If the plans currently call for the receipt at local government levels of only certain field monitor data, identify the additional data you contend the local governments must receive and provide your basis therefor.
- _ _a
Interrogatory 18(c)
Provide the information for this interrogatory requested by Staff Question 1.
1 i
- 19. No local resources or capability for local field j monitoring within the PEP exists as specified in
- I,7.
! Interrogatory 19(a)
Supply the bais for the assertion that Criterion I.7 requires local field monitoring capability.
Interrogatory 19(b)
Identify the extent of the local field monitoring capability ,
j (including the entities performing the monitoring and the range of monitoring) you contend is required by Criterion I.7 and provide an estimate of the resources (including manpower, training, and equipment) l that would be needed to implement this capability.
Interrogatory 19(c) i If it is contended that the field monitoring program identified in the plans will not provide sufficient data, describe the inadequacies in the program.
Interrogatory 19(d)
Provide the information for this interrogatory requested by Staff
- Question 1.
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- 20. No State or local capability exists to provide methods, equipment, and expertise to make rapid assessments of radiological hazards, including activation, notification means, field team composition, transport, communication, monitor equipment and estimated deployment times as required in I,8.
Interrogatory 20(a)
Supply the basis for the assertion that Criterion I.8 requires State or local capability to make rapid assessments of radiological hazards.
Interrogatory 20(b)
Identify each entity you contend is required to possess the capability to make rapid assessments of radiological hazards. .
1 Interrogatory 20(c)
Identify the extent of the capability you contend is required for each entity identified in your response to Interrogatory 20(b). Include in your response an estimate of the manpower, training, and equipment i
that would be needed for each entity.
i Interrogatory 20(d)
Provide the information for this interrogatory requested by Staff i
Question 1.
- 21. TheStateofMissourihasnoca2fbility to measure radioiodine levels as low as 10 uCi/cc under field conditions as required in I,9. See State RERP, page A2B.2 (time lost implementing IRAP violates item I,8. standard for " rapid assessment".
Interrogatory 21(a)
Provide the basis for the assertion that the State of Missouri lacks the capability to measure radioiodine levels as low as 10-7 uCi/cc under field conditions.
Ir.terrcoatory 21(b)
Define what is meant by the assertion " time lost implementing IRAP violates item I.8 standard for rapid assessment," and provide your basis for the assertion.
Interrogatory 21(c)
Provide the information for this interrogatory requested by Staff ,
Question 1.
- 22. No separate procedures are published (none referenced in State RERP) by the State of Missouri to meet the requirements of I,10.
Interrogatory 22(a)
Provide the information for this interrogatory requested by Staff Question 1.
i
- 23. No provisions are included in State or local RERPs to comply with the criteria requirements of J,2.
Interrogatory 23(a)
Describe the type of provisions you contend are required to be included in State or local RERP's to comply with the criteria l requirements of J.2.
l
Interrogatory 23(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 24. No license action is noted in State or local RERPs to indicate how or where an individual arriving on site during an emergency will receive protective clothing, respiratory / thyroid protection as required by J,6.a.b.c.
Interrogatory 24(a)
Do you contend that the provisions in the Applicant's plan to satisfy the requirements of Criterion J.6 are inadequate? If so, identify each alleged inadequacy and state what corrective measures -
should be taken.
Interrogatory 24(b)
Provide the basis for the assertion that State and local RERPs are required by Criterion J.6 to " note" licensee action? In your response, describe the extent of the provisions you believe each plan is required to have to conform with Criterion J.6.
Interrogatory 24(c)
Provide the information for this interrogatory requested by Staff Question 1.
l l 25. No formal means (mechanisms) ate indicated for prompt, direct recommendation of protective actions to all local governments as required in J,7. No command communication net exists in RERPs.
l l
Interrogatory 25(a)
,j Identify each State and/or local authority you contend is required j to be notified pursuant to Criterion J.7.
Interrogatory 25(b) -
For each authority identified in your response to Interrogatory 25(a), detail the alleged inadequacies in the notification mechanism and supply your basis therefor.
Interrogatory 25(c) ,
Define what is meant by "No command communication net exists in RERP's."
Interrogatory 25(d)
Provide the ii. formation for this interrogatory requested by Staff question 1.
i
- 26. No capability exists at any local level of government to implement protective measures
- regarding human and animal foods as required in l J,9. No specific actions are defined ir the State l RERP.
i Interrogatory 26(a)
Provide the basis for the assertion that no capability exists at any local level of government to implement the protective measures called for by Criterion J.9.
i c
e , --- . -- , - - , ,- ~ - - - --- .,
Interrogatory 26(b)
Identify each local governmental entity you contend is required to possess the capabilities called for by Criterion J.9.
Interrogatory 26(c)
For each entity identified in your response to Interrogatory 26(b),
describe the extent of the capability, including manpower, training, and equipment, you contend is required by Criterion J.9.
Interrogatory 26(d)
Describe in more detail the alleged inadequacies in the State RERP ,
as regards Criterion J.9.
Interrogatory 26(e)
Provide the information for this interrogatory requested by Staff Ouestion 1.
- 27. State and local RERPs do not indicate preselected radiation sample or monitor points, relocation centers or shelter areas as required in J,10.a.
Interrogatory 27(a)
Do you contend that there are any inadequacies in Applicant's plan regarding the indication of " preselected radiation sample or monitor points, relocation centers or shelter areas" as called for by Criterion J.10.a? If your answer is yes, describe each alleged inadequacy and i explain how it could be cured.
1
i Interrogatory 27(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 28. Local RERPs do not include protection for persons of impaired mobility as required in J,10.d. ~
Interrogatory 28(a)
Provide the information for this interrogatory requested by Staff Question 1.
- 29. No provisions exist in RERPs to implement J,e. & f.
(KI for emergency workers and civil populace) as required. See M0. RERP, pg. B11. s Interrogatory 29(a)
[ 4 Is it your contention that Criteria J.10.e and J.10.f require that Potassium Iodide or any other radioprotective drug be made available in certain circumstances? If your answer is yes, describe the circumstances in which you contend such drugs are required.
/
Interrogatory 29(b)
Provide the information for this interrogatory requested by Staff --
Question 1. i
- 30. ho local RERPs contain methods for identification I
of potential impediments or contain contengency ,
measures as required in J,k.
Interrogatory 30(a)
What " methods for identification" do you contend are required for potential impediments?
s
a s -
Interrogatory 30(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 31. No time estimates are contained in State / local RERPs , per~ J ,1&m.
Interrogatory 31(a)
Provide the information for this interrogatory reguested'by Staff Question 1. _ s
- 32. State RERP does not set out methods of protection of public from ingestion of rad-contaminated foods, or criteria for deciding whether dairy animals shall be put on stored feed, detection of ,
, contamination, estimating dose consequences of uncontrolled ingestion or imposing protective measures, etc. per J,11.
! Interrogatory 32(a)
' Provide the information for this interrogatory requested by Staff Question.1.
- 33. No means of registration / monitoring of evacuees at all host areas at local governmental levels for the
'first 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, per J,12.~ is included in State or local RERPs. Additionally, no means of control of traffic from evacuation areas to host ,
areas is identified in said RERPs.
Interrogatory 33(a)
Provide the information for this interrogatory requested by Staff Question 1.
f 4 34 No capability exists at State or local government to' meet the requirements of K,3.a.b., nor is such l included in said RERPs.
i (
Interrogatory 34(a)
Describe the extent of the capability at State and local government levels, including manpower, training, and equipment, you contend is necessary to meet the requirements of Criterion K.3.a and K.3.b.
Interrogatory 34(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 35. No local organization has established a decision chain for authorizing radiological exposures in excess of EPA PAGs per K,4. .
Interrogatory 35(a)
Provide the factual basis for this assertion.
Interrogatory 35(b)
Provide the information for this interrogatory requested by Staf.f Question 1.
- 36. No State or local action levels have been estimated for the determination of a need for decontamination as required in K,5.a. nor do provisions to comply with K,5.b. exist in plans.
Interrogatory 36(a)
Provide the factual basis for this assertion.
, . 1 I l l
Interrogatory 36(b)
Provide the information for this interrogatory requested by Staff Question 1.
1 37. No arrangements for local and backup hospital and medical service with a capability to evaluate and measure radiological exposure and biological uptake or that persons providing such services are prepared to handle contaminated persons as required in L,1.
Interrogatory 37(a)
Provide +he factual basis for this assertion.
. Interrogatory 37(b)
Provide the information for this interrogatory requested by Staff
- Question 1.
i 1
- 38. Not all local governments or State has arranged for transport of victims of radiological accidents to nedical support facilities as required in L,4.
Interrogatory 38(a)
Identify each entity that has not arranged for transport of victims as required in Criterion L.4.
- Interrogatory 38(b)
Provide the information for this interrogatory requested by Staff i
Question 1.
- 39. No State or local RERPs indicate plans and procedures for reentry and recovery exist (except 3 for simple statements that such is under the control of the Presiding Judge) or are the means
indicated by which the allowing of relaxation of protective measures is permitted as specifd?d in M,1.
Interrogatory 39(a)
Provide the factual basis for the assertion that the plans do not adequately provide for reentry and recovery. Include in your response the types of additional information you contend are required.
Interrogatory 39(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 40. The State RERP does not include the means of .
informing the members of response organizations that recovery is to be initiated or at what radiation levels recovery response is possible/
practical as required in M,3.
Interrogatory 40(a)
Do you also contend that there are any inadequacies in Applicant's plan's compliance with Criterion M.37 If the answer is yes, describe the alleged inadequacies.
Interrogatory 40(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 41. Neither State or local RERPs provide methods of estimating total population exposures to radiation /
nuclides as required in M,4.
Interrogatory 41(a)
Provide the basis for the assertion that local RERPs are required by Criterion M.4 to provide methods of estimating total population exposures.
Interrogatory 41(b)
Provide the information for this interrogatory requested by Staff Question 1.
- 42. No agreements by local response organizations to participate in exercises or drills is included in local RERPs as provided for in N,; N,1.b.; ,
N,2.a.c.d.
Interrogatory 42(a)
Identify the basis for the requirement that agreements by local response organizations be included in local RERPs.
Interrogatory 42(b)
Identify all the local response organization agreements it is contended are required.
Interrogatory 42(c)
Provide the information for this interrogatory requested by Staff Question 1.
- 43. No local RERP has a description of how exercises /
drills will be carried out as required in N,3.
l Interrogatory 43(a)
Provide the information for this interrogatory requested by Staff Question 1.
- 44. No local RERP identifies an official observer by name or title as specified in N,4 Interrogatory 44(a)
Provide the basis for the assertion that local RERP's are required to identify on official observer by name or title.
Interrogatory 44(b)
~
Provide the information for this interrogatory requested by Staff Question 1.
- 45. No local means for evaluation of observer /
participant comments exist in RERPs as required in N,5.
Interrogatory 45(a)
Provide the information for this interrogatory requested by Staff Question 1.
- 46. No radiological emergency response is proposed for local personnel in all political entities as specified in 0,; 0,1.a.b.; 0,4 & 5. Current plans call for no radiation monitor equipment in local hands.
Interrogatory 46(a)
Identify each political entiry for which it is contended that no raidological emergency response is proposed as specified in Criterion 0.
Interrogatory 46(b)
Is it contended that local entities must operate radiation '
monitoring equipment? If your answer is yes, provide the factual basis therefor. Include in your response the specific entities you contend must operate the equipment.
Interrogatory 46(c)
Provide the information for this interrogatory requested by Staff Question 1.
- 47. No local RERP provides for compliance with planning -
criteria as required in P.; P.1., 6., 7., & 10.
Interrogatory 47(a)
Provide the information for this interrogatory requested by Staff Question 1.
- 48. No capability for local remote interrogation of meteorological data and effluent transport and diffusion estimates exist at county E0Cs or at the State E0C as outlined on page 2-4, Appendix 2.
Interro,gatory 48(a)
Is it contended that not all systems producing meteorological data and effluent transport and diffusion estimates have the capability of-being remotely interrogated? If your answer is yes, identify each system lacking such capability.
Interrogatory 48(b)
Is it contended that each E0C (State and county) must have the capability of remotely interrogating the systems referred to in Interrogatory 48(a)? If your answer is yes, provide the factual basis therefor.
Interrogatory 48(c)
Provide the information for this interrogatory requested by Staff Question 1.
49-50 NO INTERR0GATORIES Respectfully submitted,
... _!' w?
U~
Robert G. Perlis Counsel for NRC Staff Dated at Bethesda, Maryland this 15th day of July,1982.
UNITEn STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
UNION ELECTRIC COMPANY Docket No. STN 50-483 OL (Callaway Plant, Unit 1) )
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter. In accordance with 5 2.713, 10 C.F.R. Part 2, the following information is provided:
Name - Richard J. Goddard Address - Offi..e of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Telephone Number - Area Code 301-492-7417 Admissions - Supreme Court for the State of Illinois Name of Party - NRC Staff U.S. Nuclear Regulatory Comission Washington, D.C. 20555
/ s U JRichar . Godj ard Co el for NRC Staff Dated at Bethesda, Maryland this 15th day of July, 1982.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
UNION ELECTRIC COMPANY Docket No. STN 50-483 OL (Calleway Plant, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO JOHN G. REE9" and " NOTICE OF APPEARANCE" of Richard J. Goddard in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of July, 1982:
James P. Gleason, Esq., Chairman Administrative Judge Barbara Shull Atomic Safety and Licensing Board Lenore Loeb 513 Gilmoure Drive League of Women Voters of Missouri Silver Spring, MD 20901 2138 Woodson Road St. Louis, M0 63114 fir. Glenn 0. Bright
- Administrative Judge Atomic Safety and Licensing Board Marjorie Reilly U.S. Nuclear Regulatory Commission Energy Chairman of the League of Washington, DC 20555 Women Voters of Univ. City, MO 7065 Pershing Avenue Dr. Jerry R. Kline* University City, M0 63130 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Gerald Charnoff, Esq.
Washington, DC 20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge Mr. John G. Reed 1800 M Street, N.W.
Rt. 1 Washington, DC 20036 Kingdom City, M0 65262 Dan I. Bolef A. Scott Cauger, Esq. President, Board of Directors l Assistant General Counsel for the Coalition for the Environment, Missouri Public Service Commission St. Louis Region i P.O. Box 360 6267 Delmar Boulevard
- Jeffe son City, MO 65101 University City, MO 63130 l
i i
l
- ,c Donald Bollinger, Member Rose Levering, Member Missourians for Safe Energy Crawdad Alliance 6267 Delmar Boulevard 7370a Dale Avenue University City, W0 63130 St. Louis, M0 63117 Mr. Fred Luekey Kenneth M. Chackes Presiding Judge, Montgomery County Chackes and Hoare Rural Route Attorney for Joint Intervenors Rhineland, MO 65069 314 N. Broadway St. Louis, Missouri 63102 Mayor Howard Steffen Chamois, MO 65024 Professor William H. Miller Mr. Earl Brown Missouri Kansas Section, School District Superintendent American Nuclear Society P.O. Box 9 Department of Nuclear Engineering Kingdom City, MO 65262 1026 Engineering Building .
University of Missouri Mr. Samuel J. Birk Columbia, M0 65211 R.R. #1, Box 243 Morrison, MO 65061 Mr. Harold Lottman Presiding Judge, Dasconade County Robert G. Wright Rt. 1 Associate Judge, Eastern District Owensville, MO 65066 County Court, Callaway County, Missouri Eric A. Eisen, Esq.
Route #1 Birch, Horton, Bittner and Monroe Fulton, M0 65251 Suite 1100 1140 Connecticut Avenue, N.W.
Atomic Safety and Licensing Washington, DC 20036 Board Panel
- U.S. Nuclear Regulatory Commission Docketing and Service Section*
Washington, DC 20555 Office of the Secretary U.S. Nuclear Regulatory Coninission Atomic Safety ard Licensing Washington, DC 20555 Appeal Board
- U.S. Nuclear Regulatory Commission Washington, DC 20555 __ _
c& _ J , , LA Rijhard J oydard Counsel or NRC Staff