ML20055B130

Interrogatories & Requests for Production of Documents. Certificate of Svc Encl

ML20055B130
Person / Time
Site:	Callaway
Issue date:	07/13/1982
From:	Jeffrey Reed REED, J.G.
To:	UNION ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8207200389
Download: ML20055B130 (7)

Text

p ,

wi. .. ,c .

{

il  : <>

j, UNITED STATES OF AMr.RICA t HUCLEAR REGULATORY COD:ISSICH ,

BEFORE THE A70!!IC SAFETY AND LICENSING BOARD

%a m[SEO In the Mat.ter of )

) e r; j  ; .n-UNICN ELECTRIC CO!PANY ) Docket No. STN 50 83 DP

)

(Callaway Plant, Unit 1) " ~

) t .

IG.u ,3 c. . -

c.3J.t r!

JCHN REED 8S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FOR APPLICANT, U.E.

Pursuant to 10 CFR, Sections 2 740 and 2.741, Mr. Reed requests that the Applicant answer separately and fully in writing, and under oath or affinr.stion, each of the following interrogatories and produce and pemit inspection and copying of the original or best copy of all documents identified in the response to interrogatories below. Interrogatory responses are due not later than 16 August 1982.

Mr. Reed requests that the name and address of the person or persons who provide information used in answering each question be identified, and that the source of information be disclosed where en answer is based in whole or in part on infccmstion other then the personal knowledge of the person or persons answering.

These interrogatories are intended to be continuing in nature, and the '

answers should be cromptly supplen.ent.ed or amended as appropriate, should the ApnHeant or any indiviaual acting on their behalf obtain new or differing information responsive to these interrogatories.

dhere identification of a document is requested, briefly describe the doeuremt (e.g. book, letter, a.cmorand'2m, transcript, report, hand written notus, test data, etc.) and provide the following information as applys:

8207200389 3 PDR ADOCK 0 ppg ,

b 03

d.,cu;ent na: o, title, nurr.ber, m thor, date cf publication r.r i publishcr, addros.,ee, J--.to 4ritten sr npproved, and the nue und address of the person or persons having ponneasion of the document. Also, state the portion or portions of the document (section(s), chcpter(s) or page(s)) upon which you rely.

For the purposes of these interrogatories, the term " documents" shall raean all records of every type in the possession, control or custody of the Applicant, the Applicant's attorney (s), or any governmental entity with which the Applicant has entered into forrml or informal agreemont or contract, including, but not linited to remorcnda, reports, surveys, correspondenco, charts, tabulations, books, photographs, maps bulletins, phan.plets, minutes, notes, transcripts, voice recordin6s, and all other writings, to include copies of docunents even though the originals, thereof, are not, in the poscoscion, custody or control of the Applicant, Union Electric Comptny of St. Louis, Missouri.

For the further purposes of those interregntories, a document shall be

, deemed to be within the control of the Applicant, its attorney (s) if they have ownership, possession or custody of the document or copy thereof, or such docut.cnt is in the ownership, passossion or cust.oay covernr. ental entity with which the Applicant has joined in or propocos to join in an emergency radio-logical preparedness pr.rtnership or join

• operations / funding agreement, or

[ sid d App 31 cant has the right to necure said document or copy thereof from any person or public or privato entity having physien1 possesaion thereof.

l l S LY W :T T PilhPC M i

l ihese intorrw,ctories relate to en.ergency planning contentions and are submitted for the purpose of diacovering inforation snd evidence for use in 1

pubH c henrings in the above ext'.oned matter.

INTERFOCnTORIES

1. Provido a copy of all comunicati ons between Union Electric Company and the State of Missouri, 'its Departments, Agencies, Directors or employees as relates to radiolog' scal emergency response planning onsite, offsite, and/or financial considerations related thereto.

2 Provide the opinions of the Applicant's Board of Directors, emergency planning coordinators, agents, representatives, or any person hired by said Applicant involved in emergency planning issues, as regard the actual need for onsite and offsite radiological emergency response preparedness, the cost effectiveness of such preparedness and their assessment of an actual need to upgrade emergency response capabilities at the State and local levels of government. Specifically, provide the opinions and past documentation to support such views fort Mr. Charles Daugherty of Union Electric Company, Mr. Donald F. Schnell of Union Electric Company Mr. Donald Capone of Union Electric Compcny Mr. Robert Schukai of Union Electric Company Mr. Milton Stiller of Union Electric Company

3. Provide copies of all written communications between these, above named, individuals as regard emergency planning issues; include a copy of the letter from Mr. Stiller to Mr. Robert Schukai, dated 28 April 1982, titled " Emergency Planning Issues witt John Reed", and other such documents by Mr. Stiller, to include written responses to such documents.

4. Provide a copy of all agreements between Applicant and Callaway County and or the City of Fulton, Missouri involving radiological emergency planning, responec activities, financial agreements or contracts concerning any and all aspects of the provision of equipnent, personnel, or funding relating to radio-logical emergency plans or response (to include ambulance agreements, offers

4-and letters relating to the same, as well as hospital agreements which have been approved by the hospital board, offers and letters relating to these r:atters) .

5. Demonstrate that the plume exposure pathway EPZ for the Callaway Plant, Unit 1, has been established with appropriate consideration of local emergency response capabilities as affected by demography, topography, land use or characteristics, and jurisdictional boundaries; also, identify, by name and occupation, who established the boundaries and what local officials approved such limits.

6. NUREG-0654, Rev.1 indicates that the duration of a release from a plant accident could range from 30 minutes to several days (see page 13). Explain in detail how plant operators can detemine the time length of a radiological release and how this determination affects the choice of reconmending offsite protective actions for the public.

7. Demenstrate that neans exist and are available to the Applicant to corrrunicate with all offsite emergency response authorities and that such means are sufficient to assure pmmpt, full-time comrnnications under all anticipated conditions, including but not limited to such considerations as lightning, icing, damaging winds, vandalism, sabotage, and pcwer failure.

8. Offsite emergency response is to be predicated upon dose predictions which will be provided to govemmental authorities by Applicant's onsite personnel. Fully identify the dose projection system which will be used by the Applicant to provide this information including estimates of the accuracy of such a system.

~

9. Provide copies of the following documents which are referenced in NUREG

! 0654, FEMA-REP-1, Rev.1, as sources of guidance and additional information.

a. EPA-520/1-75-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Sept. '75 (see page 6, NUREG 0654)

b. Respiratory Protective Devices Manual, American Industrial Hygiene Association,1963, pages 123 thru 126 (see page 46, NUREG 0654)

10. Indicate how the NUS Corporation of Rockville, the Corporation hired by the Applicant to prepare local governmental emergency response plans, intends to protect the public and emergency workers from ingestion of radio-iodines and other radio-nuclides. Specifically, what respiratory and thyroid protection will be provided for the emergency workers and general public in the event of a nuclear release during a plant accident.

11. Indicate how much respiratory protection is provided by a handkerchief folded into eight layers and held snuggly over the mouth and nose, or a towel folded into three layam and held in the same manner as con: pared to no device used at all. Give an estimate of the time length of such protection if a person using such device is outside, exposed to a passing plume. How does such protection compare to the filter systems approved and recorrmended by the NRC and EPA 7 How long can a handkerchief or towel, folded and used as indicated above, be used during moderate exercise before the build-up of carbon-dioxide within the human system causes discomfort or bcdily damage by reduction of oxygen to the brain and other cells? How does this carbon-dioxide build-up affect infants and small children as compared to adults?

12. Does the handkerchief / towel respiratory device meet the standards of l

l 10 CFR, Part 20, NRC Regulatory Guide 8.15 and/or EPA-520/1-75-00l?

i End Interrogatories Respectfully subndtted, Dated this 13th day John G. Reed of July 1982, at Citizen of the United States Kingdom City, Missouri of America RFD #1 Kingdom City, Missouri 65262

) tel (314) 642-2769 1

i i

i i

1 I

UNITED STATiG OF AikRICA NUCLEAR REGULATORY COMMISSION PEFTE THE ATOMIC SAFETY AND LICEt!MUC BOARD in the }ttter of )

)

UNIOi ELECTRIC ColfANY ' ) Docket No. STN 50-483

)

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that the document attached hereto was served this 14th day of July ,1982 by deposit in the U.S. mail, first class' postage prepaid upon the followings, r

James P. Gleason, Esquire '

Mr. Glenn O. Bright Chairman, Atonio Safety. and Atomic Safety and Licensing Board Licensing Board Panel 4 Panel

$13 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 . Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comadssion . Washington, D.C. 20555 Washington, D.C. 20555

, Roy P. Lessy, Jr., Esquire Kenneth M. Chackes, Esquire Office of the Executive Legal Director Chackes and Hoare U.S. Nuclear Regulatory Commission 314 N. Broadway Washington, D.C. 20555 St. Louis, M. 63162 A. Scott Cauger, Esquire

'Ihomas A. Baxter, Esquire Assistant General Counsol Shaw, Pittman, Potts & Trowbridge H0. Public Service Conmission 1900 M. Street, N.W. P.O. Box 360 Washington, D.C. 20036 Jefferson City, M. 65102 Atornic Safety and Licensing Robert Wright, Judge Eastom Dir:t.

Appeal Board Callaway County Court U.S. Muclear Regulatory Corrrission County Court.heuse Washington, D.C. 20555 Fulton, Missouri 65251 fohn G. Heed Git 3 zen er t.he United States of America