ML20058J683
| ML20058J683 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/09/1982 |
| From: | Horin W DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8208110162 | |
| Download: ML20058J683 (16) | |
Text
W
~
~
o REUTED COblBMINitvho 00CKETED August 57C1982 l
i' ffD 10 f*3 :11 1
...v U
b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 and COMPANY
)
50-446 (Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2,)
)
Operating Licenses)
APPLICANTS' SEVENTH SET OF INTERROGATORIES TO CASE AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R.
I$2.740b and 2.741, Texas Utilities Generating Co.,
et al.
(" Applicants") hereby serve Applicants' Seventh Set of Interrogatories and Requests to Produce upon Citizens Association for Sound Energy (" CASE").
Each interro-gatory shall be answered fully in writing, under oath or affirmation and include all pertinent information known to CASE, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control of CASE, its officers, directors or members as well as its employees, advisors or counsel.
In answering each interro-gatory and in responding to each request, please recite the r208110162 820809 PDR ADOCK 05000445 g
J interrogatory or request preceeding each answer or response.
Also, please identify the person providing each answer or response.
These interrogatories and requests shall be continuing in nature.
Thus, any time CASE obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, CASE should cupplement its previous response to the appropriate interrogatory or request to produce.
CASE should also supplement its responses as neces-sary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony.
The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data compi-i lations from which information can be obtained, whether prepared by CASE or by another person.
We request that at a date or dates to be agreed upon, CASE make available for l
inspection and copying, all documents subject to the requests t
set forth below.
l These interrogatories are based on those aspects of l
Contention 22 which relate, at least in part, to State and local emergency plans.
As stated in our August 4, 1982 letter to CASE, the Texas Radiological Emergency Response Plans, including applicable local plans, are available for review at
4 the FEMA, Region VI offices in Denton, Texas.
See 47 Fed.
4 Reg. 30669 (July 15, 1982).
Accordingly, these interroga-tories seek specification of CASE's position in Contention 22 on information which is set forth in the State and local I
emergency response plans.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contention 22.
Applicants have failed to comply with 10 C.F.R. Part 50, Appendix E, regarding emergency planning, for the following reasons:
a.
The FSAR does not identify state or regional authorities responsible for emergency planning or who have special qualifications for dealing with emergencies.
This portion of Contention 22 contends that the Comanche Peak Emergency Plan does not identify state or regional i
authorities responsible for emergency planning.
In addition to the information set forth in the Comanche Peak plan, which was the subject of Applicants' Fourth Set of Interrogatories, a description of the organization and responsibilities of authorities which will support any response to a radiological emergency at the Comanche Peak facility is set forth in Part One, Sections V.A and B of the State plan and Section VI of the Somervell and Hood County Plans.
In this context, please answer the following interrogatories.
a 1-7.1 Does CASE contend that the identification and descrip-tion of the State and local authorities with responsi-bilities for emergency planning and for responding in the event of a radiological emergency is inadequate, incomplete, erroneous or otherwise not in compliance with applicable regulations?
2-7.
If the response to Interrogatory 1-7 is in the affirmative, specify any additional " authorities" which CASE contends should be identified.
3-7.
For each authority listed in the response to Interrogatory 2-7, specify the role which CASE contends the authority should play in the event of a radiological emergency.
4-7.
What are the bases for your responses to Interrogatories 1-7 through 3-7?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
5-7.
Does CASE contend that any of the organizations identified in the State and County emergency plans should not be included therein?
6-7.
If the response to Interrogatory 5-7 is in the affirmative, please identify those organizations and set forth the reasons CASE contends each should not be included in those emergency plans.
7-7.
What are the bases for your response to Interrogatory l
6-7?
Identify all documents, testimony or oral l
statements by any person and legal requirements on which CASE relies in support of its position.
l l
8-7.
Does CASE contend that the functions of each of the l
organizations identified in Part One, Sections V.A and B l
of the State plan and Section VI of the Somerville and l
Hood County Plans are not appropriate for each organization?
9-7.
If the response to Interrogatory 8-7 is in the affir-mative, please describe specifically what functions CASE contends are not appropriate for those organizations.
1 Applicants have identified these Interrogatories as the Sever.th Set to CASE by the hyphen 7 following each number.
l l
4 10-7.
Please specify the particular regulatory requirement on which CASE relies for its position in its response to Interrogatory 9-7.
11-7.
Please set forth the bases in addition to the information provided in response to Interrogatory 10-7 i;
for CASE's responses to Interrogatories 8-7 and 9-7.
Identify any documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
12-7.
Are there any state, local or federal authorities which CASE contends have "special qualifications for dealing with emergencies" which must be, but have not been, identified in the State and County emergency plans?
13-7.
If the response to Interrogatory 12-7 is in the affirmative, please identify each of those organi-zations and describe the "special qualifications" which CASE contends they have.
14-7.
Please set forth the bases for your responses to Interrogatories 12-7 and 13-7.
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
Contention 22.
b.
No agreements have been reached with local and state officials and agencies for the early warning and evacuation of the public, including the identification of the principal officials by titles and agencies.
l This aspect of Contention 22 concerns the agreements made between the Applicants and local and state officials and agencies for participation in emergency plan implementation and the identification of the principal officials involved.
Identification and responsibilities of principal officials I
1 involved in the warning and notification of the public are set t
forth in Annex L,Section VII.A.4 of the State plan and Annex F,
Section V and Attachment G of the Hood and Somervell County Plans.
In this regard, please answer the following questions.
15-7.
Does CASE contend that the identification and description of responsib311 ties of the principal officials involved in the warning and notification of the public, as set forth in the State and County plans, is inadequate?
16-7.
If the response to Interrogatory 15-7 is in the affirmative, please specify each inadequacy with which you are concerned.
17-7.
Does CASE contend that any other state and local officials or agencies must be identified in the State and County plans to satisfy its concerns in Contention 22.b?
18-7.
If the response to Interrogatory 17-7 is in the affirm-ative, please identify each agency and official which CASE contends must be included in those plans.
19-7.
For each agency and official identified in your response to Interrogatory 18-7, specify the role which you contend such agency or official is to play in responding to radiological emergencies at Comanche Peak.
20-7.
What are the bases for your responses to Interrogatories 15-7 through 19-7?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
Contention 22.
c.
There is no description of the arrangements for services of physicians and other medical personnel qualified to handle radiation emergencies and arrangements for the transportation of injured or contaminated individuals beyond the site boundary.
Contention 22.c has two parts.
First, CASE asks for a description of arrangements for medical services for radiation emergencies.
Second, Contention 22.c says that there is no description of arrangments for the transportation of injured or contaminated individuals beyond the site boundary.
To the extent State organizations might be involved in providing such services in the event of an emergency, in addition to those for which Applicants have made arrangements, such information is set forth in Appendices 3, 11 and 12 to Annex L of the State Plan.
These appendices are available from the Texas Department of Health, at 1100 West 49th St., Austin, Texas, Accordingly, please respond to the following Interrogatories.
21-7.
Does CASE contend that arrangements for ambulance and medical support services described in Sections 1.3.1.3, 1.3.1.4 and 10.0 of the comanche Peak Emergency Plan, in conjuction with the arrangements described in l
Appendices 3, 11 and 12 of Annex L to the State plan, are inadequate?
I 22-7.
If the response to Interrogatory 21-7 is in the affirmative, please specify each area which CASE contends is inadequate.
I 23-7.
For each of the areas identified in the response to i
Interrogatory 22-7, specify the specific information which CASE. contends must be included in the plans.
24-7.
What are your bases for your responses to Interrogatories 21-7 through 23-77 Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
. 25-7.
Does CASE contend that any other organization not identified in State, County or site plans within the scope of the medical support classification for radiological emergencies at Comanche Peak must be identified?
26-7.
If the response to Interrogatory 25-7 is in the affirmative, please identify each such organization.
27-7.
For each organization identified in the response to Interrogatory 26-7, please describe the exact role which CASE contends each such organization should play in responding to a radiological emergency at Comanche Peak.
28-7.
For each response to Interrogatories 25-7 through 27-7, please set forth the bases for CASE's position.
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
29-7.
Does CASE contend that the State must arrange for additional services of physicians and other medical personnel beyond those arrangements which are described in Appendices 3, 11 and 12 to Annex L to the State Plan?
30-7.
If the response to Interrogatory 29-7 is in the a f firmative, please identify every additional medical service which CASE contends must be provided and the additional medical personnel which CASE contends must be provided.
31-7.
For each of the medical services and personnel identified in the response to Interrogatory 30-7, please describe the precise role which CASE contends such services and persmnnel will play in responding to radiological emergencics at Comanche Peak.
32-7.
Please specify the basis for each of your responses to Interrogatories 29-7 through 31-7.
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
Contention 22.
d.
There are no adequate plans for testing by periodic drills of emergency plans and provi-sions for participation in the drills by persons whose assistance may be needed, other than employees of the Applicant.
Section VIII.B of Appendix 7 to Annex L of the State plan identifies Tab 1 to Annex L, Appendix 7 as setting forth information relating to drills and exercises for fixed nuclear facility accident response plans.
Further information is included in the Comanche Peak plan in the appropriate letters of agreement (Appendix H) and Section 12.
In this context, please respond to the following interrogatories.
33-7.
Do you contend that the provisions for the testing by periodic drills of the emergency response plans, as described in Annex L, Appendix 7, Tab 1 to the State plan and in Section 12 and the letters of agreement in Appendix H to the Comanche Peak plan are inadequate?
34-7.
If your response to Interrogatory 33-7 is in the affirmative, please specify each inadequacy you contend exists in those plans.
35-7.
For each inadequacy described in your response to Interrogatory 34-7, please describe the information which you contend must be included in those plans.
36-7.
What are your bases for your responses to Interrogatories 33-7 through 35-77 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
37-7.
Do you contend that the provisions for participation by appropriate persons in periodic drills of the emergency response plans, as decribed in Annex L, Appendix 7, Tab 1 to the State plan and in Section 12 and the letters of agreement in Appendix H to the Comanche Peak plan are inadequate?
38-7.
If your response to Interrogatory 37-7 is in the affirmative, please specify each inadequacy which you contend exists in those plans.
39-7.
For each inadequacy described in your response to Interrogatory 38-7, please describe the information and l
provisions which you contend must be included in those plans.
40-7.
What are your bases for your responses to Interrogatories 37-7 through 39-7?
Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
41-7.
Does CASE contend that any legal requirements other than 10 C.F.R.
I 50.47(b)(14) and Part 50, Appendix E, Section F.,
and NUREG-0654,Section II.N. are applicable to Contention 22.d?
42-7.
If the response to Interrogatory 41-7 is in the affirmative, please specify each additional requirement CASE contends is applicable to the concerns expressed in Contention 22.d.
t Contention 22.
e.
There is no provision for medical facilities in the immediate viciinity of the site, which includes Glen Rose.
The concerns raised in Contention 22.e involve provisions for medical facilities in the area of the Comanche Peak site.
Applicants have described in the Comanche Peak Emergency Plan the medical facilities which are available for use in the event of an emergency at Comanche Peak.
In addition, responsibilities for identification of additional medical i
c.
m
facilities are assigned in accordance with Annex F,Section V.J of the Somervell and Hood County emergency plans.
In this context, please respond to the following Interrogatories.
43-7.
Does CASE contend that additional provisions for medical facilities must be made?
44-7.
If the response to Interrogatory 43-7 is in the affirmative, please identify the specific provisions which CASE contends must be made.
45-7.
For each of the provisions identified in the response to Interrogatory 44-7, please describe the specific concerns which CASE has.
46-7.
What are your bases for your responses to Interrogatories 43-7 through 45-7?
Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
47-7.
Does CASE contend that the assignment of responsibility in the Hood and Somervell County plans for medical services is inadequate to assure that proper medical services will be available?
48-7.
If the response to Interrogatory 47-7 is in the affirmative, please specify the particular services which CASE contends must be available but which will not be available in the event of an emergency.
49-7.
What are your bases for your responses to Interrogatories 43-7 through 48-7?
Identify all documents, testimony or oral statements by any person and legal requirements on which CASE relies in support of its position.
e Contention 22.
f.
There is no provision for emergency planning for Glen Rose or the Dallas /Ft. Worth metroplex.
Emergency plans for Glen Rose and Somervell County are set forth in the Somervell County & City of Glen Rose, Texas Emergency Operations Plan.
Dallas and Fort Worth are beyond the Emergency Planning Zone for which detailed plans must be prepared.
However, protective measures to be taken in the ingestion exposure pathway are described in Annexes C and L, and Appendices 2, 7 and 9 to Annex L of the State plan.
Copies of these documents may be obtained from the Texas Department of Health.
In this context, please answer the following Interrogatories.
50-7.
Do you contend that additional emergency planning must be made for the city of Glen Rose?
51-7.
If your response to Interrogatory 50-7 is in the affirmative, please specify the particular measures you contend must be included in the emergency plan for Glen Rose.
52-7.
For each of the measures identified in your response to Interrogatory 51-7, please specify the person or organization responsible for taking such measures, the conditions under which such measures would need to be taken and the purpose of such measures.
53-7.
What are your bases for your responses to Interrogatories 50-7 through 52-77 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
54-7.
Please define the geographical area to which you refer by the term " Dallas /Ft. Worth metroplex."
55-7.
Identify the legal requirements which you contend require emergency planning for the " Dallas /Ft. Worth metroplex."
56-7.
Describe the specific emergency planning measures which you contend must be taken for the " Dallas /Ft. Worth metroplex."
Identify the specific legal requirement which you contend requires such measures to be taken.
57-7.
Do you contend that any of the measures described in Annexes C and L and Appendices 2, 7 and 9 to Annex L of the State plan regarding measures to be taken in the ingestion exposure pathway are inadequate?
58-7.
If your response to Interrogatory 57-7 is in the affirmative, please specify each inadequacy which you contend exists.
59-7.
What are your bases for your responses to Interro-gatories 57-7 and 58-77 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.
General Interrogatories 60-7.
Do you intend to call any witness in the upcoming hearing with respect to Contention 227 If so, please identify the witness, including a summary of his or her professional and educational background.
Also, set forth any other information bearing on that person's qualifications to testify with respect to Contention 22.
61-7.
If you plan to call any witness during the upcoming hearing with respect to Contention 22, please specify the nature and scope of his or her testimony.
Please list or identify any documents which that witness intends to rely on in giving their testimony.
Also please state whether that witness has conducted any research or made any studies which such witness intends to rely upon.
Please provide copies of such testimony.
Also, please provide for inspection and copying any documents relied on in such testimony.
\\
d I.
62-7.
Please produce for inspection and copying all documents identified by CASE in its responses to the above Tnterrogatories.
Respectfully submitted, 1
N William A.
Horin '
DEBEVOISE & LIBERMAN 1200 Seventeenth St.,
N.W.
Washington, D.C.
20036 (202) 857-9800 counsel for Applicants August 9, 1982
9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i)
)
Docket Nos. 50-445 TEXAS UTILITIES GENERATING
)
50-446 COMPANY, ~~et al.
)
)
(Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' Seventh Set of Interrogatories to CASE and Requests to Produce,"
in the above-captioned matter were served upon the following persons by express delivery (*) or by deposit in the United States mail, first class postage prepaid this 9th day of August, 1982:
- Marshall E.
Miller, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel Licensing Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Lucinda Minton, Esq.
- Dr.
Kenneth A.
McCollom Atomic Safety & Licensing Dean, Division of Engineering Board Architecture and Technology U.S.
Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C.
20555
- Dr. Richard Cole, Member
- Marjorie Ulman Rothschild, Esq.
Atomic Safety and Licensing Office of the Executive Board Legal Director U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Chairman, Atomic Safety and Licensing Appeal Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
David J.
Preister, Esq.
Mr. Scott W.
Stucky Docketing & Service Branch Assistant Attorney General Environemtnal Protection U.S.
Nuclear Regulatory Division Commission P.O.
Box 125478 Washington, D.C.
20005 Capitol Station Austin, Texas 78711
- Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 i
L:::=
William A.
Horid cc:
Homer C.
Schmidt Spencer C.
Relyea, Esq.
O