ML20062G785
| ML20062G785 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/11/1982 |
| From: | Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | SUNFLOWER ALLIANCE |
| References | |
| NUDOCS 8208130165 | |
| Download: ML20062G785 (27) | |
Text
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c ncgETe RC iDplgP UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMFANY, et al.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
APPLICANTS' ANSWER TO SUNFLOWER ALLIANCE, INC.
ET AL. SECOND SET OF INTERROGATORIES TO APPLICANTS Applicants for their answers to Sunflower Alliance, Inc.
et al.
(" Sunflower") Second Set of Interrogatories to l
Applicants, dated April 30, 1982, state as follows:
Applicants hereby respond to the interrogatories directed to Issue #1.
As agreed between counsel for Applicants and counsel for Sunflower, Applicants will respond later to the interrogatories directed to Issue #6.
Applicants' counsel conferred by telephone with Mr. Daniel D.
,lt, Sunflower's counsel, on August 9, 1982, with regard to Applicants' objections.
Applicants' Counsel explained to Mr.
Wilt that Applicants would object to certain of the 820813d115 8208AI '
PDR ADOCK 05000440 0
PDR C)
-interrogatories on the basis of relevancy for the reasons given in Applicants' answers to Sunflower's First Set of Interrogatories to Applicants, as further explicated in
" Applicants' Substantive A'nswer To ' Sunflower Alliance, Inc. et al. Motion To Applicant To Compel Discovery'" (July 23, 1982).
No agreement between Applicants' counsel and Mr. Wilt was reached as to the scope of Issue #1.
RESPONSES 43.
Produce any and all documents, corresporidence,.or memor-anda between CEI and the NRC, FEMA, local or state governments or any other entity relating to the use of thyroid blocking agents by CEI eniployees, emergency workers, or the general public.
Response
The only such document Applicants have is the State of Ohio Nuclear Power Plant Emergency Response Plan (December, 1980).
The county emergency response plans still being developed also will contain information relating to the use of thyroid blocking agents.
44.
Demonstrate and discuss how emergency response facilities meet each and every criterion listed in NUREG-0814; answer all questions therein.
(Emergency response facilities include the control room, Technical Support Center, Operational Support Center and Emergency Operations Facility.)
e F
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
The functions of the PNPP emergency response facilities are unrelated to the off-site emergency evacuation plans, and, therefore, are not within the scope of the Issue.
See
" Applicants Answers to Sunflower Alliance, Inc. First Ro'und Discovery Requests," filed February 5, 1982 (hereinafter
" Applicants' First Round Answers"), Responses to Interroga-tories #13 and #36; " Applicants' Substantive Answer To
' Sunflower Alliance, Inc. et al. Motion To Applicant To Compel Discovery,'" at 5-7, 16 (July 23, 1982) (hereinafter
" Applicants' Substantive Answer").
45.
Where will the Emergency Operations Facility be located (on-site or off-site)?
If on-site, explain why, since NUREG-0696 at p.
16 clearly states that the EOF is to be an off-site support center.
l,
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See Response to Interrogatory
- 44, supra.
46.
Describe and give the exact location of the alternate i
(backup) EOF, the Concord Service Center (FSAR, Appendix 13A, Sec. 7.1.3).
t. -.
i
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See Pesponse to Interrogatory
- 44.
47.
For both the main and backup EOFs, describe any normal, non-emergency activities occurring there.
Do these activities enhance or detract from emergency preparedness?
Are unauthori-zed persons excluded from the EOF during normal conditions?
Define the term " unauthorized person."
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See Response to Interrogatory
- 44.
48.
Answer the following questions for the High efficiency particulate air filters which have been or will be installed in the Radiation Emergency Area of Lake County Memorial Hospital, East:
To what level will the HEPA filters reduce particu-late levels?
Is the HVAC system controlled to permit isolation of the intake?
4 At what level of airborne activity is isolation perfo rmed?
How is the level determined?
Where are the sensors located?
Where is this level monitored?
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See 10 C.F.
R.
6 2.740(b)(1);
" Applicants' First Round Answers," Response to Interrogatory
- 16; " Applicants Substantive Answer," at 5-7.
4 I
49.
According to Sec. 5.5.6.1 of Appendix 13A of FSAR, "the decontamination room drains (at the hospital) are collected in a holding tank for subsequent disposal at PNPP." Describe how the. material in the holding tank will be transported to PNPP.
What safeguards will be taken to ensure safe transport of this material?
Response
The Interrogatory is not directed at eff-site emergency evacuation plans.
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 92.740(b)(1); " Applicants' Substantive Answer," at 5-7.
50.
Will any special provisions or consideration be made for those evacuees who have pets, e.g.,
special mass care centers, kennel facilities, pet food supplies, etc.?
Will people be allowed to take pets with them?
If not, what are people to de with the animals?
Response
Provisions for evacuees with pets will be addressed in the Standard Operating Procedures for reception centers.
Those procedures are being developed.
51.
What provisions will be made for the notification of deaf people within the 10-mile EPZ in the event of a radiation emergency?
Has any study been made as to how many deaf people are in the area?
Response
Provisions for notification of deaf persons within the plume exposure pathway EPZ will be addressed in the county emergency response plans and in the Standard Operating Procedures for the appropriate county agencies.
Those._
procedures are being developed.
Applicants are unaware of any study of the number of deaf persons in the area, though appropriate. rosters will be prepared and maintained by local fire departments.
See " Responses to Interrogatories Filed by Sunflower Allowance Pursuant to Previous Order of the Atomic Safety and Licensing Board and 10 C.F.R. 2.70 b," prepared by Lake County Commissioners and Lake County Disaster Services Agency (Second Set), Response #5.
52.
What provisions will be made for the notification of people who do not speak English within the 10-mile EPZ in the event of a radiation emergency?
Has any study been made on the number of non-English speaking people in the area _(e.g.,
Hispanics in the Geneva area, Finnish and Hungarian people in the Fairport area)?
Response
Notification of non-English speaking persons within the plume exposure pathway EPZ will be addressed in the county emergency response plans and the Standard Operating Procedures for the appropriate county agencies.
The county plans and the Standard Operating Procedures are being developed.
Applicants are unaware of any study of the number of non-English speaking
~
persons in the area.
53.
How will people on boats within the 10-mile EPZ, on Lake Erie, be notified to evacuate.
l
Response
Appropriate notification will be provided by the United States Coast Guard.
See Letter of Agreement between the United
States Coast Guard and John J. Waldron, dated September 23, 1974, in Appendix B to Appendix 13A of the FSAR.
There also are sirens located along the Lake Erie shoreline-that may alert boats near the shoreline.
54.
What provisions will be made~for the evacuation of non-institutionalized handicapped people or people dependent upon life-support systems?
Response
Evacuation of non-institutionalized handicapped persons or persons dependent on life-support systeme will be addressed in the county emergency response plans.
Those plans are being developed.
55.
Is there any priority system for evacuation?
E.g.,
who will be evacuated first, school children, pre-school children, pregnant women, or the elderly / infirm?
Response
Evacuation priorities will be addressed in the county emergency response plans.
Those plans are being developed.
56.
NCRP Report No. 55 at pp. 16-17 indicates that engineered safeguards at reactors may reduce the release of radioiodine during a nuclear acc.ident.
For each safeguard listed therein (and below), describe the system, if any, that will be in place at PNPP, explain how the system works to reduce iodine release, and indicate how efficient said system is at reducing radicio-dine levels.
(1) various methods for condensing the radioiodine-bearing steam that would be released to the reactor building.
I (2) enclosing the reactor in a sealed contai,nment structure.
(3) recirculating the contained atmosphere through absorbents and filters that remove radiciodines. l
(4) operation of sprays containing chemicals capable of absording the radiciodines and reducing their concentration in the atmosphere of the contain-ment building.
Response
The engineered reactor saf.aguards are not related to off-site emergency evacuation plans.
The Interrogatory thus is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 92.740(b)(1); " Applicants Substantive Answer," at 5-7.
57.
Explain how the plume exposure pathway EPZ depicted in Figure II-2 of Appendix D of Appendix 13A of FSAR was derived.
Explain precisely how each and every one of the following factors was considered in the determination of the extent of the plume exposure EPZ:
demography, including permanent and seasonal residents and transients; meterology;_ topography; land use characteristics; access routes; local jurisdictional bouldaries (sic]; release time and energy characteristics; release height; radionuclide content of release, including release fractions; plume dispersion, including plume rise; deposition velocity; dose-effects; sheltering and shielding; radiation treatment; breathing rates; time of year of release.
Response
PRC Voorhees is preparing a revised time estimate study.
The methodology and factors that were used in developing the plume exposure pathway EPZ will be explained in detail in the revised time estimate study.
58.
Describe in detail the methods and standards by which the-evacuation time estimates contained in Tables V-4 and V-5 in Appendix D of Appendix 13A of FSAR were determined.
Response
The revised time estimate study of PRC Voorhees will r
include a section explaining in detail the methodology that was used to derive the time estimates contained in Tables V-4 and V-5.
59.
What consequences (including early fatalities, delayed fatalities, early injuries, delayed injuries, developmental and genetic birth defects, and land and water contamination) would be associated with each of the evacuation time estimates listed in the FSAR?
Response
The type of consequences listed in the Interrogatory are a function of a number of factors other than just evacuation time.
It, therefore, is not possible to identify particular consequences only from specific evacuation time estimates.
60.
What range of estimates would be acceptable to the applicant?
State specifically the highest evacuation time estimate which would be acceptable to the Staff [ sic) for each evacuation sub-area drawn in the FSAR, and describe the conaequences (as categorized above) which would be associated with each such evacuation time.
Response
As explained in Applicants' Response to Interrogatory #59, supra, there are a number of factors other than just evacuation time that determine the consequences of a nuclear accident.
It, therefore, is not possible simply to state an " acceptable" range of evacuation time estimates.
i 61.
Has the applicant (or anyone on their behalf or to their knowledge) conducted any generic or site-specific consequence analysis for (or having relevance to) releases from PNFP equivalent to the BWR-1 to BWR-4 releases defined in WASH-1400?
If so, set forth in detail the methodology, assumptions, and results of any such study, including calculations of early
-g-l
fatalities, delayed fatalities, early injuries, delayed
. injuries, developmental or genetic birth defects, and land and water contamination.
If not, by whom was the decision made that such a study was unnecessary and what were the reasons for that decision?
What process was followed in reaching that decision?
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
The Issue is concerned with off-site emergency evacuation plans.
It is not concerned with the radiological consequences of nuclear accidents.
See " Applicants' Substantive Answer," at 5-7.
62.
Has the Applicant (or anyone on their behalf or to their knowledge) conducted any generic or site-specific accident consequence analysis for accidents with containment failure modes wuch [ sic] that the radioactive releases exceed those set forth in the design basis accident assessment described in Chapter 15 of the PNPP FSAR?
If so, answer Interrogatory #61, specific to any such study.
Response
Applicants object to the Interrogatory as irrelevant and beyond the scope of Issue #1.
See Response to Interrogatory
- 61, supra.
63.
In the Applicant's opinion, is it possible to evacuate safely the total permanent, seasonal, and transient populations within each of the following areas at any time of the day or any time of year?
Describe in detail any assumptions made and indicate how your response would differ if that assumption were changed.
Disclose any assumptions made with respect to an acceptable level of risk to the evacuating population.
(a)
The area designated at the plume exposure pathway EPZ for PNPP in the FSAR..
(b)
The area which the Applicant believes should constitute the plume exposure EPZ for PNPP.
(c)
The circular zone surrounding PNPP having a 20-T.ile radius.
(d)
The Mentor Headlands area.
(e)
The entire City of Mentor.
Response
Applicants believe that, with one exception, if an evacuation of the plume exposure pathway EPZ should ever be necessary, the evacuation can be achieved in an orderly and prompt manner.
The exception is weather conditions so adverse that roads within the plume exposure pathway EPZ essentially are impassable.,Under such extreme adverse weather conditions, other protective actions would be taken, Areas outside of the plume exposure pathway EPZ are irrelevant and beyond the scope of Issue #1.
See Response to Interrogatory #64, infra.
Applicants' belief is based on the evacuation time estimate study and information identified and summarized in the PNPP Emergency Plan and attached appendices.
See Appendix 13A of the FSAR.
64.
In the Applicant's opinion, would there ever be a need to order protective actions in any area outside of the plume i
l exposure pathway EPZ proposed by the Applicant in the FSAR?
If l
so, describe the circumstances therein, the areas so affected, and the nature of any such protective actions.
l
Response
t
~
Issue #1 is not concsrned with areas outside of the plume exposure pathway EPZ.
Applicants object to the Interrogatory as irrelevant and beyond the scope of the Issue.
See 10 C.F.R.
l t.-
o i
$2.740(b)(1); " Applicants' First Round Answers," Besponses-to Interrogatories #12, #18, and #34; " Applicants' Substantive Answer," at 5-7.
65.
Has any consideration been made of the possibility of the voluntary and spontaneous evacuation of persons within the plume exposure pathway EPZ in the event of an accident at PNPP and how this might affect the ordered evacuation?
If so, describe in detail any such study.
Response
The revised time estimate study of PRC Voorhees will consider the voluntary and spontaneous evacuation of persons in the plume exposure pathway EPZ.
66.
Has any consideration been made of the possibility of the voluntary and spontaneous evacuation of persons outside of the plume exposure pathway EPZ in the event of an accident at PNPP and how this might affect the ordered evacuation, especially the support organizations and facilities outside the EPZ?
If so, describe in detail any such study.
~
Response
The revised time estimate study of PRC Voorhees will consider the possibility of voluntary and spontaneous evac-uation of persons outside of the plume exposure pathway EPZ.
67.
In the Applicant's opinion, are there adequate facilities
'available to shelter simultaneously the total permanent and peak seasonal and transient populations in each of the following areas?
(a)
The area designated by the Applicant in the FSAR as the plume exposure pathway EPZ.
(b)
The area which the Applicant believes should comprise the plume exposure pathway EPZ.
(c)
The circular zone surrounding FNPP having a 20-mile radius.
j
With respect to each of these areas, describe the types of shelter available, indicate the numbers of each type of shelter available and the shielding factors associated with each type,.
describe the nature and location of the shelter to be used by transient populations, and disclose any assumptions made as to an acceptable level of risk to the public.
I
Response
The county emergency evacuation plans will address the sheltering of evacuees.
The plans are being developed.
Applicants have not inventoried the shelter facilities, and~
thus are unable to answer the Interrogatory.
68.
Describe in detail any design modifications which could be made to PNPP, Units 1 and 2 to reduce the early and/or delayed fatalities and/or health effects associated with accidents.
Specify the type of accident (s), the consequences of which each such modification would reduce, and estimate, for each modifi-cation, the extent of reduction for each of the following effects:
early fatalities, delayed fatalities, early injuries, delayed injuries, and developmental or genetic birth defects.
Response
The Interrogatory is not directed at off-site emergency evacuation plans, and, therefore,-is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 52.740(b)(1); " Applicants' Substantive Answer," at 5-7.
69.
In the Applicant's opinion, what constitutes an acceptable level of risk to the public surrounding PNPP in the event of an accident?
Specifically, what is the uppermost number of each of the following health effects which is acceptable:
early fatalities, delayed fatalities, early injuries, delayed injuries, and developmental or genetic birth defects?
If your answer varies depending on the type of accident which occurs, provide answers with respect to releases at PNPP equivalent to the BWR-1 to BWR-4 releases defined in WASH 1400.
Response
Applicants object to the Interrogatory as irrelevant end beyond the scope of Issue #1.
Neither the radiological consequences of nuclear accidents, nor Applicants' opinion of what "an acceptable level of risk to the public" would be, is relevant to off-site emergency evacuation plans.
See Response to Interrogatory #61, supra.
70.
In the Applicant's opinion what constitutes an appropriate and safe distance from PNPP for the location of reception / mass care centers for evacuees?
Describe any other criteria for the location of reception / mass care centers.
Response
Applicants believe that reception / mass care centers meeting the criteria of NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Rev.
1, 1980), Part II, Section J.10.h, at page 63, are located at an appropriate and safe distance from PNPP.
Other criteria that l
may be considered in locating such centers include the charac-teristics of the facility (in particular, purking, internal space, and available shower facilities), access to evacuation routes, and flexibility for expansion to nearby supplementary facilities.
71.
In the Applicant's opinion, if an accident occurs on a weekday during working hours what percentage of the permanent t
population within the plume exposure pathway EPZ proposed by the Applicant will be working at locations outside the EPZ, i
leaving other family members at home without automobiles?
Also, what p'ercentage of the automobiles said to be available in the Applicant's Evacuation' Study are operable? L m
f s
Response
Applicants do not have information on what percentage of-the permanent population living within the plume exposure pathway EPZ will be working outside of that EPZ during weekday working hours, leaving other family members at home without automobiles.
The revised time estimate study of PRC Voorhees will identif? the number of operable vehicles within the plume exposure pathway EPZ.
72.
Why has the Applicant not submitted separate evacuation time estimates for evacuating special facilities, as required by NUREG-0654, Appendix 47
Response
The revised time estimate study of PRC Voorhees will include time estimates for evacuating special facilities.
73.
NUREG-0654, Appendix 4 provides that (at p.
4-2), in preparing evacuation time estimates, "The number of permanent residents shall be estimated using the U.S.
Census data or other reliable data, adjusted as necessary, for growth."
(Emphasis added)
In the Applicant's opinion, what is the appropriate target date for adjusting population figures for growth:
the expected date of initial criticality, or the expected date for the termination of plant operations?
Why have unadjusted population data been used to prepare evacuation i
time estimates?
Provide evacuation time estimates using properly adjusted populations.
Response
The revised time estimate study of PRC Voorhees will be based on 1980 census data ext,rapolated to 1984 estimates on the basis of documented population trends.
. I
-74.
The Applicant's FSAR,_ Appendix 13A, Section 4.2 states
~that the Ohio DSA has adopted the EPA manual of protective action guidelines, EPA-520/1-75-001, and that recommendations to the State and local government will be based on these PAGs.
(a)
Is the Applicant. aware that this includes the administration of radioprotective drugs, such as potassium iodide?
(b)
If sc, describe in detail any and all provisions for the purchase, storage, stockpiling, distri-bution (including public education on proper use of the drug), and effectiveness / side effects monitoring of such drugs.
(c)
In the Applicant's opinion, would'the adminis-tration of radioprotective drugs to individuals off-site cver'be necessary or desirable in the event of an accident at PNPP?
If not, why not?
If so, to what radial distance from the site could dissemination of the drugs be necessary?
What is the maximum quantity of potassium iodide or other radioprotective drug that could be needed?
What repositories in the vicinity of the PNPP site currently stock such drugs and what quantities are maintained?
Response
(a)
Applicants are aware that the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, September 1975 (EPA-520/1-75-001), recommends the administration of stable iodine such as potassium iodide to emercancy wprkers under certain circumstances.
See Manusl, 51.6.3.5, at 1.41-1.42, and $5.5, Table 5.1, at 5.31.
(b)
The State of Ohio Department of Health is responsible for the purchase, storage, stockpiling and distributio.n of radioprotective drugs to emergency evacuation workers.
See State of Ohio Nuclear Power Emergency Response Plan (December 1980),Section II, Part I, Figure 2.
(c)
Administration of radioprotective drugs to off-site emergency workers may be desirable under certain circumstances.
The radial distance of dissemination will depend on the projected dose rates associated with a particular emergency.
The appropriate determination will have to be made by the State of Ohio Department.of Health.
See responce to part (b) above.
The maximum quantity of radioprotective drugs that could be needed is dependent on the number of off-site emergency workers provided for in the county emergency response plans.
Those plans are being developed.
The State of Ohio Department of Health will determine the location of the repositories and the amounts to be stockpiled in each repository.
See response to part (b) above.
Applicants do not have that information.
75.
Will emergencies of various classifications be declared whenever the Emergency Action Levels indicate that such declarations are in order?
Or does the Shift Supervisor / Emergency Duty Officer have-the discretion not to declare an emergency even though it is indicated by the applicable EAL?
What other criteria will be used by the Shift Supenvisor/EDO to classify or declare an emergency?
Response
The interrogatory is not directed at off-site emergency evacuation plans, end, therefore, is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R.
$2.740(b)(1); " Applicants' Substantive Answer," at 5-7.
76.
Explain precisely how each of the following possibilities was accounted for in the preparation of evacuation time estimates for PNPP:
(a)
Vehicles breaking down or running out of fuel during the evacuation.
(b)
Abandoned vehicles.
(c)
Vehicles having insufficient fuel at the commencement of the evacuation, to the knowledge of their owners.
(d)
Disregard of traffic control devices.
(e)
Evacuees using inbould traffic lanes for outbould [ sic] travel.
(f)
Blocking-of cross-streets at intersections.
Response
The revised time estimate study of PRC Voorhees will consider items (a) through (e).
Item (f) was accounted for in Appendix D of Appendix 13A of the PNPP FSAR.
A description of the methodology explaining how it was accounted for will be included in the revised time estimate study of PRC Voorhees.
77.
Estimate the number of each of the following types of vehicles' which will be needed to implement evacuations in each of the evacuation sub-areas outlined in Appendix D of Appendix 13A of the PNPP FSAR and the number of trips to and from those sub-areas which will be taken by each such vehicle:
Buses; ambulances; tow trucks; traffic control vehicles; and vehicles
.for use in notifying the public and/or conr:irming evacuation.
Explain the bases for your estimates in detail, disclosing any assumptions made.
j
Response
The number of such vehicles which will be available for l
use in evacuating the plume exposure pathway EPZ will be identified in the appropriate county agency Standard Operating Procedures.
Those procedures are being developed.
78.
Do the evacuation time estimates contained in Appendix D of Appendix 13A of the PNPP FSAR include any of the following times?
Indicate, for each' estimate listed in the'FSAR, how l
much of that time ca'n be attributed to each of the following:
l j l I
1 i
(a) notification time.
(b) preparation time.
(c) confirmation time.
I.e.,
are the evacuation time estimates only travel times?
Response
Notification and preparation times are included in the evacuation time estimates in Appendix D of Appendix 13A of the PNPP FSAR.
See Figure V-2, Tables V-1, V-2 and.V-3, and pages 30, 31 and 34.
Confirmation time estimates were not specified in the FSAR, but will be included in the revised time estimate study of PRC Voorhees.
79.
Upon what factual basis is the assumption that notifica-tion and preparation times are staggered dependent?
What would be the effect on the evacuation time estimates of not staggering either the notification or preparation times?
Response
The assumption that some persons will have started to prepare to evacuate while others still are receiving notifica-tion is based on-the fact that different people face different conditions.
Thus, for example, different persons are located within different parts of the plume exposure pathway EPZ and I
may receive notification from different sources.
Different persons also face different preparation conditions; for example, some may 6 ecd to evacuate large families while others may need to evacuate only themselves.
Notification and l
-preparation times, therefore, will not be identical for all 1
persons within the plume exposure pathway EPZ.
l l
l
If, instead of this staggered method, static mean evac-uation time estimates were used, final evacuation time would be reduced because the impact on overall evacuation time of those persons on the high end of the evacuation time distribution would be diminished.
80.
Have any emergency planning measures been' designed to mitigate the consequences of hypothetical releases to the liquid pathway as a result of a core melt accident at PNPP?
Are such measures necessary?
Describe any and all results of a release to the liquid pathway, and describe any design features-incorporated in PNPP which would mitigate the consequences of or prevent such a release.
Response
The off-site emergency evacuation plans are designed to mitigate the consequences of any nuclear accident.
To the extent that the Interrogatory is directed at PNPP design features or on-site response to a core melt accident, the Interrogatory is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 52.740(b)(1); " Applicants' Substantive Answer, "
at 5-7.
81.
Interrogatory deleted.
82.
List every visit made by or for Alan M. Voorhees and Assoc. to the PNPP site or tne surrounding area.
Specify for each visit the individuals who participated and their titles and affiliations, the exact locations visited (including the names of all roadways traversed for purposes of evaluating the transportation network in the Perry vicinity), the length of the visit, the itinerary or agenda, and all findings and conclusions which resulted therefrom (including any inventories which were developed as to available roadways, road capacities,.
shelter facilities, or the like).
Indicate how this informa-tion was incorporated into the Evacuation Study, Appendix D of Appendix 13A of the FSAR.
4
Response
Applicants still are in the process of compiling this information, and will respond within the near future.
83.
According to SEC. 6.5.2 of Appendix 13A of the FSAR, a supply of a suitable thyroid blocking agent will be available for use by CEI employees.
However, no such agent is listed in Appendix C.
" List of Emergency Equipm>3nt and Supplies."
Explain this apparent discrepancy.
Response
The Interrogatory is not directed at potassium iodide distribution to households within ten miles of the plan', and, t
therefore, is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 92.740(b)(1); " Applicants' Substantive Answer,"'at 5-7; Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 N.R.C.'175, 186 (1981).
84.
What provisions have been made to ensure the cooperation of the public during a radiation emergency?
Specifically, what authority do state and local governments have to force people to evacuate from their homes, to prevent spontaneous evacuation outside the EPZ (and possible [ sic] in the area of the reception / mass care centers), to compel the assistance of volunteers in the evacuation, and to control panic and subse-quent uncooperative behavior in evacuees?
Response
Applicants have not researched the legal authority for the specified actions.
Applicants are unaware.of any plans "to force people to evacuate from their homes," or "to compel the assistance of volunteers."
As for measures to control panic and uncooperative behavior, local and State law enforceme'nt
officials presumably will continue to have the authority to enforce laws regulating public conduct and prohibiting the commission of crimes.
The county emergency response plans still being developed will have statemente identifying the basis of authority for planning and execution of the plans.
See Lake County Responses (Second Set) (cited at Interrogatory
- 51, supra), Response #26.
85.
Would local police officers / departments ever be called on-site to aid PNPP security during any security threat at the plant?
If so, have any letters of agreement been signed with local police departments?
Describe any security threat scenarios that would result in radiation exposure to off-site police personnel called on-site.
Have local police departments received any training or equipment for situations involving radiation exposure?
Response
The Interrogatory is not directed at off-site emergency evacuation plans, and, therefore, is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 52.740(b)(.1); " Applicants' Substantive Answer," at 5-7.
86.
Has the Applicant (or anyone on behalf of or to the knowledge of the Applicant) conducted any' studies on protective acti ns other than-evacuation for the general public?
Specifically, are there any estimates or ana~ lyses of the time required to effectuate sheltering or thyroid prophylaxis?
'(Also for Counties?)
Response
Applicants have not conducted any studies on protective action other than evacuation, or have had any such studies conducted on their behalf.
Applicants are aware.that a number
e of such studies have been conducted by others.
Applicants are unaware of " time estimates" to effectuate protective actions other than evacuation.
87.
Concerning the evacuation of schools:
- (a)
What provisions will be made for the evacuation of nursery schools, pre-schools,. day care centers, and other such facilities, both public and private?
(b)
What provisions will be made for the evacuation of private schools within the plume exposure pathway EPZ?
Include in your answer the notification procedures for these schools and the availability of transportation, especially for those schools which do not have buses or other transportation programs.
(c)
For both private and public schools, what provisions wil1 be made for the evacuation (possible selective evacuation) of.those schools outside the plume exposure pathway EPZ but whose students may reside within the EPZ?
(d)
How will bus drivers be notified in the event of an emergency?
Many of these people work part-time and therefore may not be abailable
[ sic) by phone during non-working hours.
(d)
Discuss the suitability of schools for sheltering students for long periods of time.
Inclu'de sheltering factors for the buildings and the availability of sufficient food, medical supplies, blankets, etc.
Response
Evacuation of schools will be addressed in the county emergency response plans.
The plans are being developed.
It is not anticipated that schools outside of the plume exposure pathway EPZ will be evacuated.
The use, if any, of schools as shelter facilities will be addressed in the county emergency
. response plans.
See Response to Interrogatory #67.
88.
Describe in detail any independent monitoring for radia-tion around the PNPP site.
(Independent monitoring here means monitoring by a governmental or private entity that is not an agent of the Applicant.)
Include the types of monitors to be used, both mobile and stationary and detection / manufacturer type, manner and frequency of reading / analysis, availability of instantaneous data, type of data link with the responsible agency, name and affiliation of responsible agency, type of meteorological monitors / data input, of any, means of calculat-ing projected doses, and the source of funding of the responsi-ble agency.
Response
'The Interrogatory is not directed at off-site emergency evacuation plans, and, therefore, is irrelevant and beyond the scope of Issue #1.
See 10 C.F.R. 52.740(b)(1); " Applicants' First Round Answers," Response to Interrogatory #24;.
" Applicants' Substantive Answer," at 5-7, 14.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE e
By: /
/
Jay E.
- Silberg, P.C.
Robert L.
Willmore Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
August 11, 1982
)
)
s.s.
DISTRICT OF COLUMBIA )
AFFIDAVIT Rebecca B. Coffey, being duly sworn according to law, deposes and says that she is Associate Environmentalist, Licensing and Permits Section The Cleveland Electric Illuminating Company, and that the facts set forth in the foregoing Applicants' Answer to Sunflower Alliance Inc., et al. Second Set of Interrogatories
- 43 through #88, dated April 30, 1982, are true and correct to the best of her knowledge, information and belief.
l hwW'CH1
- 01) y bO(
Subscribed and sworn before me this 10th day o'f August, 1982.
M
[f.
. 4 ft--
Notary Public My cemesien Entr., u=d 31,1985 l
l l
i.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer To Sunflower Alliance, Inc. et al. Second Set Of Interrog-atories To Applicants," were served by deposit in the U.S. Mail, First Class, postage prepaid, this lith day of August, 1982, to all those on the attached Service List.
,[hk
Robert L.
Willmore Dated:
August 11, 1982 l
e
@@KTE@ MM;M@RcV7;51M;DggcM s e w NUCLEAR REGULATORY COMMISSION i
Before the Atomic Safety and Licensing Bo_ard I
In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440
' ILLUMINATING COMPANY, et al. )
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2
)
SERVICE LIST Peter B.
Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclaar Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry R.
Kline Docketing and Service Section Atomic Safety and Licensing Board Office'of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
~
Washington, D.C.
20555 Washington, D.C.
20555 Mr. Frederick J.
Shon Stepha.n H. Lewis, Esquire Atomic Safety and Licens.ing Board Office of the Executive-U.S. Nuclear Regulatory Commission Legal Director Wahsington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appeal Board U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire
. Atomic, Safety and Licensing P.
O. Box 08159 Appeal Board Cleveland, Ohio 44108 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Donald T.
E::one, Esquire Assistant Prosecuting Attorney Gary J.
Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Appeal' Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John G.
Cardinal, Esquire Prosecuting Attorney
'tomic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604
^