ML20063A197
| ML20063A197 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/18/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8208240231 | |
| Download: ML20063A197 (8) | |
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E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Ogg ]j BEFORE THE ATOMIC SAFETY AND LICENSING BOARG) $0 20 min },,f In the Matter of . . fdh.' - APPLICATION OF TEXAS UTILITIES g D o ck' e t N o s . ~ 5 0'"4'4 5 . ,.t and 50-446 GENERATING COMPANY, ET AL. FOR g AN OPERATING LICENSE FOR , g '
' 4; COMANCHE PEAK STEAM ELECTRIC -
I ~ STATION UNITS #1 AND #2 "~..- (CPSES) , p J 9.f CASE'S ANSWERS TO APPLICANTS' [ FOURTH SET OF INTERR0GATORIES TO CASE '[ AND REQUESTS TO PRODUCE, -- FILED AUGUST 4, 1982 ; Pursuant to 10 CFR 2.740b and 2.741(d) as modified by the Board's 8/6/82 -, -! [j} Scheduling Order, CASE (Citizens Association for Sound Energ$r), Intervenor ,. y herein, hereby files this, its Answers to Applicants' Fourth Set of Interroga- { J
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tories to CASE and Requests to Produce, Filed August 4,1982. Contention 22. Applicants have failed to comply with 10 CFR Part 50, Appendix E, regarding emergency planning, for the following reasons: ,
-] 7. .,
- a. The FSAR does not identify state or regional authorities responsible for emergency planning or who have special qualifications for dealing with emergencies.
1-4. Yes. 2-4. Federal agencies are not identified with sufficient specificity 'to be meaningful. Additionally, the Department of Agriculture is not identified. The Red Cross is not identified. Additionally, the following should be
, identified: personnel responsible for transmission of emergency information, '
responsible for food and water supplies, medical support personnel, security ., , personnel, and other support personnel . Further, CASE is concerned now, as .we have always been, with the use ' of" paper people" -- people who may exist only on paper and have no real, live bodies to 90 with them. Additionally, it is not sufficient to identify people without indicating that they have been properly trained and are capable of carrying out their functions; there is nothing to assure that the people indicated are going to be properly trained. There is also no documentation that the number of people available will be sufficient to take care of radiological emergencies. e amo nu 23 )
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_2 3 1 3-4. Self-explanatory. U [ 4-4. The rule of reason. NUREG-0654, Rev. 1. . r. i 5-4. No. p r 6-4. N/A. } 7-4. N/A. .
- ,4 8-4. Yes.
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- a. States that the County Judge is in charge of the Emergency Organization e and directs the operations of the agencies which make up the individual 4 Hood and Somervell County Emergency ~0rganizations. There is no lette'r ].
of agreement from either of the judges; there's no indication that these individuals have been-either informed of their duties or trained .d to do them. -k
- b. The two letters of agreement from the Sheriff's Departments, which are l.
basically identical in content, state that they will: 1. " Authenticate t the notification of an emergency by calling back the agency which made the initial notification." This would seem to be questionable, unless j{ the person calling the Sheriff's Departments will be calling no one else -( in the meantime. We would assume that they would be busy calling several ] individuals and/or organizations. It is also not clear how many people ;5 are available on a round-the-clock basis with each Sheriff's Department, Qj how easy it would be to get in touch with the appropriate people at the Department, how quickly the Department could be mobilized, etc. See "a comment in 2-4 preceding regarding " paper people". 1
- c. The letter of agreement with the Granbury Volunteer Fire Department is j being "re-negotiated and will be added to the plan when it becomes 1c available." Therefore, it is non-existent at the present time.
The Somervell County Fire Department letter of agreement also contains .! the s'tatement that "The Somervell County dispatcher may verify the authen- : ticity of the request by calling the CPSES Control Room." Them is l nothing to indicate that they wouhl get anything but a busy signal l
- if they did. Them is also nothing to indicate that regarding any :
telephone comunicati~ons there are any dedicated telephone lines. The letter limits the assistance to be given to extinguishing fires j at CPSES and on adjacent CPSES property. 4 The local fire-fighting support consists of approximately 50 volunteers, i with one truck, in approximately 30 minutes. There is no indication of i. how many volunteers could realistically be expected to show up. [' There are no specifics about training the fire-fighting support personnel.
- d. There is no mention how the ambulances will coordinate with the hospitals or the plant site, how any emergency on-the-spot treatment will be ;
administered (if any), how the ambulance drivers and attendants will distinguish what is a radiological injury and what protection they : will have from radiological contamination. It is not clear how the ambulance attendants will be trained or by whom. They will also call g and get a busy signal from the CPSES Control Room. , -
- e. Who is going to determine who has been exposed to radiation and who hasn' t? Hood can only handle 5 injured persons simultaneously (not -
specified to be radiological injuries); no indication that Hood Cty. . has had any training to treat radiological injuries; does not say ; 1
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r . .. 8-4.(continued): how many personnel, if any will be trained, and how they will be trained; says that a physicianshall be included on staff (appears to be entirely speculative at this time); nothing about capabilities to handle a large-scale accident; refers to back-up medical services from the Radiation Management Corporation and their affiliated hospital at the University of Pennsylvania (no provisions for transportation, how much time it will take to get any assistance either on-site or at Univ of Pa.). States TUGC0 will provide technical assistance, radiological monitoring equip-ment and personnel monitoring devices necessary to evaluate the radio-logocal condition of the patient (no indication of.who in TUGC0 can do this); etc. No letter of agreement with Marks Gen. Hospital.
- f. Letter of agreement is completely generic; nothing specific about CPSES.
No specifics: of procedures, time elements, does not identify any people who will act as liason between CPSES and/or hospital personnel, ~ does not identify any personnel or procedures to determine at which point RMC will be called on if needed, no indication RMC has done any site-specific evaluation of CPSES or surrounding amas or facilities, never state that an expert will come to site or surrounding area if needed, no provisions about how long it will take them to get down to site, how much notice they will need, how they will get down there, what their capabilities are in terms of how many individuals they can take care of, whether or not the patients will be physically able to ' be transported to Pa. and at whose expense. g,l Does not indicate how SCPI will effect the evacuation of Squaw Creek Park, how they will account for all park visitors, there is not one single person or title named, there is no indication of how many people are available at any given time at SCP, no written procedures have been developed for anything yet, no brochures and emergency information is available yet nor is it clear how the information will be made available and who will pay for it.
- h. Doesn't say how they are going to coordinate anything with anybody else. '
No indication of how it will be accomplished, no procedures, e.tc. , _.
- 1. No specificity as to how any of this will be accomplished.
J. No specificity as to how any of this will be accomplished or specifically by whom. Also no letter of agFeEnent with them (if required???).-
- k. It states that "The NRC, because of its familiarity with CPSES operations and reactor specific' terminology. ..etc." If this refers to Mr. Taylor, the Fy Resident Inspector (whom we assume is the most familiar with CPSES operations), it is not clear whether he will be available due to other pressing duties such as moving his family from the top of the CPSES dome.
No letter of agreement (if required????).
- 1. Letter of agreement does not agree with what is stated in 1.3.3.3.
Letter states "Unless the DOE or a DOE contractor is responsible for the activity, ionizing radiation source, or radioactive material involved in
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, an incident, DOE radiological assistance will be limited to advice and .
emergency action essential for the control of the immediate hazards to health and safety" after which they transfer responsibility to others. 9-4.. See answer to 8-4 above. . 10-4. NUREG-0654; the rule of reason. 11-4. See 10-4 above. [. . . . .. m. -. ;,m. .Mwda&. . . __ ] " ?PMP*NMW
-4 12-4. Yes.
13-4. See answer to 2-4 preceding. 14-4. NUREG-0654. The rule of reason. 15-4. See 21-4 following. 16-4. N/A. 1 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. 17-4. Yes. 18-4. See answe r to 8-4.a . , b. , c . , d . , e . , f. , g. ; h. , f . , J . , k. , 1. 19-4. Yes. , - 20-4. See 2-4 and 8-4.c and FEMA and NRC. 21-4. That contained in the FEDERAL REGISTER, 12/23/80, pages 84910 through 84917, Federal Emergency Management, Agency National Radiological Emergency Preparedness / Response Plan for Commercial Nuclear Power Plant Accidents . (Master Plan); the 8/19/80 FEDERAL REGISTER, pages 55402 through 55416, Nuclear Regulatory Commission, Emergency Planning: Final Regulations. 22-4. See 21-4 preceding. ' ' d 23-4. Yes. 24-4., See 21-4 preceding. , , , _. 25-4. See information can'tained in FR references in 21-4 preceding.
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. 26-4. See 25-4 preceding.
27-4 See second paragraph of 2-4 preceding. Also, there are not enough
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specifi'cs in the plan. 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. 28-4. Yes. 29-4. See 8-4.d., e. , f. preceding. 30-4., See 29-4 above. t 31-4. See 14-4 preceding. I 32-4. <Yes. Hospitals in Frr_ Worth and other near-by areas should also be r contacted and arrangtof ats made for refugees from CPSES, in addition .
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_ g_ a 32-4.(continued):
' 'l to arrangements being made to clothe, feed, and house and otherwise comfort and care for individuals who are suffering from psychological problems and stress. ' ~
33-4. See 32-4 above. -
-1 34-4. See 32-4 above. 'it 35-4. See 14-4 preceding. 'I 36-4. Yes. .]
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- 4. See 32-4 preceding.
-f,t 38-4. See 32-4 preceding. '
4 - c.. 39-4. See 14-4 preceding. 4 . 40-4. Yes. ' 41-4. See 8-4.d., e., and f. - '
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. 42-4. See 41-4 above. - .p
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43-4. See 41-4 above. r .'
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44-4. See 14-4 pre:eding. i g : j 45-4. Yes. 46-4. See 21-4. .. . . Contention 22. e. There is no provision for medical facilities in the innediate .- - vicinity of the site, which includes GlbliTose. 47-4. Yes. 4 48-4. See 8-4.'d., e., and f. See 8-4.d., e.., and f. N 49-4. , [$ 50-4. See 8-4.d., e., and f. - Sd
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51-4. See 14-4 above. . . -# of' 52-4. Yes. . b
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53-4. See 8-4.e. I "j 54-4. Yes. J:.i 55-4. See 8-4.f. 3 s. , N,. n.-o-~--.-, - am m ev-e, .- .. aar . - =- m e ~r - e-w- * - - - - * ~ -~ * **
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a.. 55-4. See 8-4.f. . 56-4. See 14-4 preceding. 'o 57-4. See 21-4 preceding. Yes. - .
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58-4. See 21-4 preceding. ,
. 59-4. No. . ,;>4.
el a.= 60-4. N/A. ,
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61-4. We believe Applicants have all the documents we have referenced; however . ,/ if you don't,please advise and we'will make them available for copying W. and inspection. - _ , ;c.
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Respectfully sub. m itted, -
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CCASE (Citizens 1426 S. Polk Dallas, Texas 75224 Association f.k for 214/946-9446 .
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OFFtCha[t.,8CH[ DOCK SERVICE ' ' '?f'di e . d7 .S'p.*,y-'
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Juanita Ellis, being duly sworn, deposes and says: . . :Jy,($.
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That she is President of CASE (Citizens Association for Sound Energy), i'i,
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- epidMj CASE's Answers to Applicants' Fourth Set of Interrogatories to CASE.. .- ' 'L i.'J.':'Md[
i and Requests to Produce, filed August 4,1982 ' -
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and that the same is true of her own knowledge and belief. v Ndk.. .w
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' SWORN TO and Subscribed . !.!,?>#.
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before me on this 18th day .. :.y a l of August ,1982.
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- j. ;The original of this page is being mailed under separate cover, First Class Mail, '
l'.:y.l{ ! tothe Secretary, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, ' ? !' l Attention: Chief, Docketing and Service Section, on this 18th day of August ! f I l 1982. 1 '. * ( t e ,;_. .c ).,c:
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UNITED STATES OF AMERICA UstlRC ./- .? NUCLEAR REGUi.ATORY COMMISGTOM ~ ~ %a.L 3
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARtl2 ASO 70 P2:320.: ply.f
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In the Matter of I 0FFICE CF SEstW'- a 5 rN. ? i i.t . I 00CKETING
- & SERV;CL ' & O APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445'R A NCH Q *$
CENERATING COMPANY, ET AL. FOR AN I and 50-446 . .,9#hhk OPERATING LICENSE FOR COMANCHE I . l PEAK STEAM ELECTRIC STATION I
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' UNITS #1 AND N2 (CPSES) ! .
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.5- 5 CERTIFICATE OF SERVICE i />U$"i:[. . v y' ray signature below, I hereby certify that true and correct copies of ,[Q'j!
CASE's Answers to Applicants' _ Fourth Set of Interroaatories to CASE and REaposts ' !:,~ 4.. j to Produce, filed August 4.1982 . 18th day of Auaust , 1982,..by,Q@9
- have been sent to the names listed below this ' - Express Mail where indicated by
- and First Class Mail elsewhere. S' d.g.
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- Administrative Judge Marshall E. Miller David J. Preister, Esq. ,
m - U . ' 'S . Nuclear Regulatory Commission Asnistant Attorney Geh ral 'Y '-
- Atomic Safety and Licensing Board Panel T:nvironmental Protection Division 'D W=hington, D. C. 20555 P. O. Box 12548, Capitol Station *
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Austin, TX 78711 .y .g '-
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CDr. Kenneth A.'McCollom, Dean Ms. Lucinda Minton :Wl ' Division of Engineering, Architecture, Panel law Clerk 'N and Technology Oklchoma State University Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission
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J- ? ?? J Stillwater, oklahoma 74074 Washington,.D. C. 20555 ~ ~
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- Dr. Richard Cole, Member Atomic Safety and Licensing ' ' P 'ef , -
! Atomic Safety and Licensing Board 'D % ard Panel b i
-U . S. Nuclear Regulatory Commission
- U. S. Nuclear Regulatory Commission i d f';. f WIhington, D. C.- 20555 Washington, D. C. 20555 .e y l
. ,. M.3.p, C Nicholas S. Reynolds, Esq. Atomic Safety and Licensing i d' Debevoise & Liberman Appeal Panel f.@.
1200 - 17th St., N. W. U. S. Nuclear Regulatory Commission - ,-{, . Wa:hington, D. C. 20036 w.ss hi ng ton , D. C. 20555 y"1g}g l 0 Marjorie Ulman Rothschild, Esq. Docketing and Service Section ,.'hy@h 5."
'tkM Office of Executive legal Director Office of the Secretary U. S. Nuclear Regulatory Commissien U. S. Nuclear Regulatory Commission ..$,I Wa;hington,- D. C. 20555 Washington, D. C. 20555 M.i[T2 .
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