ML20063B271
| ML20063B271 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/23/1982 |
| From: | Schukai R UNION ELECTRIC CO. |
| To: | REED, J.G. |
| References | |
| ISSUANCES-OL, NUDOCS 8208250318 | |
| Download: ML20063B271 (12) | |
Text
.
~*
o f' SYlRC A00 2 ' fjj :j 7 Cer-~r August 23, 1982 cc<;
^'
UNkTEDSTATESOFAMERICA 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) )
APPLICANT'S RESPONSES TO JOHN REED'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS INTERROGATORY NO. 1. Provide a copy of all communications between Union Electric Company and the State of Missouri, its Departments, Agencies, Directors or employee s as relates to' radiological emergency response planning onsite, offsite, and/or financial considerations related thereto.
INTERROGATORY NO. 4. Provide a copy of all agreements between Applicant and Callaway County and or the City of Fulton, Missouri involving radiological emergency planning, response activities, financial agreements or contracts con-cerning any and all aspects of the provision of equipment, personnel, or funding relating to radiological emergency plans or response (to include ambulance agreements, offers and letters relating to the same, as well as hospital agreements wh$ch have been approved by the hospital board, offers and letters relating to these matters).
ANSWER. Enclosed herewith are the documents requested in Interrogatories 1 and-4.
- 1 ghO O k u
D50 1
w V INTERROGATORY NO. 2. Provide the opinions of the Applicant's Board of Directors, emergency planning coordi-nators, 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 pre-paredness 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 suppor.t such views for:
Mr. Charles Daugherty of Union Electric Company, Mr. Donald F. Schnell of Union Electric Company Mr. Donald Capone of Union Electric Company Mr. Robert Schukai of Union Electric Company Mr. Milton Stiller of Union Electric Company.
OBJECTION: Applicant objects to Interrogatory 2. The opinions of Applicant's Board of Directors or other Union 4
Electric employees as to the actual need for onsite and offsite radiological emergency response preparedness are irrelevant to this proceeding, in view of the fact that NRC regulations require that the state of onsite and offsite emergency pre-paredness provides reasonable assurance that adequate protec-tive measures can and will be taken in the event of a radiolog-ical emergency. 10 C.F.R. $ 50.47(a)(1).
INTERROGATORY NO. 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 with John Reed," and other documents by Mr. Stiller, to include written responses to such documents.
OBJECTION: Applicant objects to the document production request contained in Interrogatory 3 which is stated as a follow-on interrogatory to Interrogatory 2, and is not relevant to the adequacy of offsite emergency planning at the Callaway Plant, which is the subject of Mr. Reed's proposed contentions.
INTERROGATORY NO. 5. Demonstrate that the plume exposure pathway EPZ for the Callaway Plant, Unit 1, has been estab-lished 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.
ANSWER. See Applicant's Responses to Specified Reed Interrogatories Served Dn The Callaway Court Administrative Judges and Emergency Management Coordinator, July 23, 1982, at 9-7,4. The proposed boundaries of the PEP EPZ were defined as a part of the offsite emergency planning effort performed by NUS Corporation. NUS Corporation coordinated and reviewed all work on this project; however, the proposed PEP EPZ boundaries were actually defined by PRC Voorhees under a subcontract to NUS Corporation. To Applicant's knowledge, no local authorities have approved the proposed PEP EPZ boundaries.
INTERROGATORY NO. 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 determine the time length of a radiological release and how this determination affects the choice of recommending offsite protective actions for the public.
ANSWER. The specific methodology used by plant operators to determine the time. length of a radiological release is dependent upon the circumstances of the particular accident.
In general, however, the duration of a release can be estimated by using the following parameters:
(1) Quantity of material that will be released (volume or mass).
_-. _- . =
(2) Physical parameters at the release location (e.g.,
pressure, temperature, size of release opening).
A computer model is available to estimate the potential airborn radioactive effluent releases. This model accounts for:
(1) Decay in the containment.
(2) Fraction core activity released inside the contain-ment.
(3) Effects of sprays and plateout of radionuclides.
(4) Leak rate from the containment.
(5) Filtration.
The model will be programmed to correspond to a set of postu-lated accidents such as a loss of coolant accident or a fuel handling accident.
l The duration of a radiological release (together with other parameters such as meteorology, wind speed and direction, and quantity of material released) determines recommendations of offsite protective actions. These recommendations may involve in-place sheltering or, if time permits and circum-stances warrant, evacuation. As an example, if a short duration release or " puff" occurred, in-place sheltering would probably be recommended.
INTERROGATORY NO. 7. Demonstrate that means exist and are available to the Applicant to communicate with all offsite emergency response authorities and that such means are suffi-cient to assure prompt, full-time communications under all anticipated conditions, including but not limited to such considerations as lightning, icing, damaging winds, sabotage, and power failure.
vandalism'{[
n o,
ANSWER. Applicant's means of communication with offsite emergency response authorities is set forth in Applicant's Radiological Emergency Response Plan and the proposed Callaway Offsite Emergency Response Plan. Direct radio communications, with an emergency power source, will exist between the control room and the Callaway C'ounty Sheriff through a secured fre-quency.on the permanent plant radio system. Commercial telephone is also available. The Callaway County Sheriff's dispatcher has responsibility to notify the sheriffs in other counties in the PEP EPZ.
An extension on the National Warning System and NAWAS will be installed in the Control Room. This will be used to warn the Missouri State Highway Patrol, Troop F, of any serious problems at the Plant. This system will be backed up by commercial telephone and through the Callaway County Sheriff's radio communications. NRC is notified through a dedicated telephone link.
INTERROGATORY NO. 8. Offsite emergency response is to be predicated upon dose predictions which will be provided to governmental 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.
ANSWER. Union Electric will utilize a computerized Radiological Release Information System (RRIS) at the Callaway Plant to provide relevant meteorological and radiological data to plant and offsite personnel before, during, and after a radioactive release, such that accurate and timely emergency )
decisions can be made in order to protect the public.
-s- !
9 The RRIS uses detailed site-specific mathematical disper-sion models to provide (1) real time estimates and predictions of atmospheric effluent transport and diffusion; and (2) calculations of radiological dose and dose rate to the public surrounding the plant, including whole body gamma dose, beta skin dose, and thyroid inhalation dose. The model works in a totally dedicated mode and is continually outputing data for use by the appropriate personnel on color CRT monitors or hard copy printers. In the EOF the output displays can also be printed on to transparencies for use with an overhead projec-tor.
INTERROGATORY NO. 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-OO1, 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)
ANSWER. Enclosed he;rewith is a copy of the 1975 EPA Manual of Protective Action Guides and Protective Actions for Nuclear Accidents. Applicant does not have a copy of the 1963 edition, pages 123 through.126, of the American Industrial Hygiene Association's Respiratory Protective Devices Manual.
4 INTERROGATORY NO. 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 respira-tory and thyroid protection will be provided for the emergency i
workers and general public in the event of a nuclear release during a plant accident.
I ANSWER. NUS Corporation was retained to prepare emergency plans, not to implement them. The emergency plans and standard operating procedures prepared by NUS Corporation for the local governments surrounding..the Callaway Plant describe the respiratory protection which will be provided for the offsite emergency workers. Respiratory and thyroid protection for the general public will be determined in accordance with the State of Missouri Nuclear Accident Plan. .
INTERROGATORY NO. 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 layers and held in the same manner as compared to no device 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 recommended by the NRC and EPA? 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 bodily 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?
ANSWER. The respiratory protection provided by a hand-kerchief or towel held snuggly over the mouth and nose can be estimated by evaluating their filtering efficiencies. The geometric mean efficiency for filtering aerosols of 1-5 micron particle size for handkerchiefs (8 thicknesses) is 88.9%; for a bath towel (2 thicknesses) it is 85.1% (NUREG/CR-2272, Table 1-2).
i 4
Respiratory protective devices should only be considered for short term action of 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and, therefore, should be used in conjunction with other protective actions such as seeking shelter or evacuations. (Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001).
Expedient respiratory, protective devices (such as a folded handkerchief or towel) could provide filtering efficien-cies greater than 90% in some instances. Industrial experience with half-mask respirators indicated that due to poor fitting or improper use, leakage around the skin / respirator seal might preclude achieving much better than about 95% efficiency. The expedient respiratory protective measures, therefore, approach the filtering efficiency of half-mask respirators.
The test procedures used to determine the filtering efficiencies of expedient respiratory measures included a measurement of the resistance to air flow through the device.
The test results indicated that a pressure drop of 20 mm of CL water through a respiratory device was about the upper limit for comfortable breathing. Since comfortable breathing precludes carbon dioxide build-up and/or reduction of oxygen, it is not considered a problem with expedient respiratory measures, if used as recommended.
Applicant is not aware of any data on the effect of-carbon-dioxide build-up on infants and small children as compared to adults.'
O INTERROGATORY NO. 12. Does the handkerchief / towel respiratory device meet the standards of 10 CFR, Part 20, NRC Regulatory Guide 8.15 and/or EPA-520/1-75-0017 ANSWER. 10 C.F.R. $ 20.103 and NRC Regulatory Guide 8.15 are applicable only to individuals in restricted areas. This does not apply to the general public. Union Electric employees who must be exposed to airborne radioactive contamination in restricted areas will be provided adequate protective devices.
The Manual of Protective Action Guides and Protective 4
Actions for Nuclear Incidents, EPA-520/1-75-001, referenced in this interrogatory, does not list any standards for respiratory devices.
l I
_9
e o
UNITED STATES OF AMERICA !
NUCLEAR REGULATORY COMMISSION i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
)
(Callaway Plant, Unit: 1-) ) ,
AFFIDAVIT OF ROBERT J. SCHUKAI City of Saint Louis)
Robert J. Schukai, being duly sworn according to law, deposes and says that he is General Manager-Engineering of Union Electric Company; that the answers contained in " Applicant's Responses to John Reed's Interrogatories and Requests for Production of Documents" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are the o f ficers , employees, agents and contractors of Union Electric Company.
Robe f J. S hukai Sworn to and subscribed before me this 20th day of August, 1982.
N Notary Putsic l' v f My commicsion expires M- ##- 85' .
BARBARA J. PFAFF NOTARY PUBLtC. STATE OF f.t:SSOURI MY CCYM!SSION EXPIRES APRIL 22,1925 ST. LOUIS COUNTY
o August 23, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
Before the Atomic Safety and Licensing Board In the Matter of )
)
UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the foregoing APPLICANT'S RESPONSES TO JOHN REED'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS and AFFIDAVIT OF ROBERT J. SCHUKAI were served by deposit in the United States mail, postage prepaid, addressed to each of those persons on the attacbed Service List, this 23rd day of August, 1982.
Oxl d b.
Deborah B. Bauser Counsel for Applicant
7 i
e ,/
t UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
l l In the Matter of )
i )
UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
)
(Callaway Plant, Uni,t 1) )
SERVICE LIST James P. Gleason, Esquire F= Esth M. Gackes, Esquire Chaivman Chackes and Hoare Atomic Safety and Licensing Board 314 N. Brna/u=y 513 Gilucure Drive St. Iouis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Reed Mr. Glenn O. Bright Boute 1 i Atcmic Safety and Licensing King &:m City, Missouri 65262 Doard Panel U.S. Nuclear Regulatory Cmmi=sion Mr. Howard Steffen l
Washington, D.C. 20555 Chanois, Missouri 65024 Dr. Jerry R. Klina Mr. Earold ILLLAm Atarric Safety and Licensing Route 1 Board Panel Owenwille, Missouri 65066 i
U.S. Nuclear Regulatory em miasion Washington, D.C. 20555 Mr. Earl Brown P.O. Box 146 Robert G. Perlis, Esquire Auxvasse, Missouri 65231 Office of the Executive Iegal Director U.S. Nuclear Regulatory rmm4=sion Mr. Fred Luekey Washington, D.C. 20555 Rural Ibute Phi =1=nd, Missouri 65069 Docketing and Service Section Office of the Secretary Mr. Ka= =1 J. Birk ,
U.S. Nuclear Regulatory rmmicsion P.O. Box 243
.i Washington, D.C. 20555 bbrrison, Missouri 65061 m . i
!* , Joseph E. Birk, Esquire Mr. Fcbert G. Wright "
Assistant to the Gene.ral Counsel Ibute 1 Union Electric Cccpany Pulten, Missouri 65251 P.O. Box 149 St. Iouis, Missouri 63166 Eric A. Eisen, Es @
Bi d., Ho.~.,.On, Bittner & benroe A. Scott cauger, Es @ 1140 Connecticut Avenue, N.W., #1100
-Assiset General Counsel Washingren, D.C. 20036 Missouri Public Service Carlssion P.O. Box 360 Jeffersen City, Missouri 65102 .
- l-
. . . _ -