ML20063D037
| ML20063D037 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/23/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20063D030 | List: |
| References | |
| NUDOCS 8208270456 | |
| Download: ML20063D037 (12) | |
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RELATED COT.ES?mENG 8/23/82 I
UNITED STATES OF AMERICA Dgly0 NUCLEAR REGULATORY COMMISSION P
BEFORE T H L A T OM I C S A F E T Y_ A N D L I C E N S I N G B O A R D '82 AS0 In the Matter of tFFICE OF SECRETL APPLICATION OF TEXAS UTILillES I
C0CEilNG & SEF I
Docket Nos.50-65M GENERATING COMPANY, ET AL. FOR AN OPERATING LICENSE FOR I
and 50-446 COMANCHE PEAK STEAM ELECTRIC I
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STATION UNITS #1 AND #2 I
(CPSES) l 2
CASE'S ANSWERS TO APPLICANTS' SEVENTH SET OF INTERROGATORIES TO CASE AND REQUESTS TO PRODUCE Pursuant to 10 CFR 2.740b and 2.741(d) as modified by the Board's 8/6/82 Scheduling Order, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Answers to Applicants' Seventh Set of Interroga-j 5
tories to CASE and Requests to Produce, Filed August 4,1982.
p Contention 22.
EMERGENCY PLT.:eNING Applicants have failed to comply wi th 10 CFR Part 50, Appendix E, regard-1I ing emergency planning, for the following reasons:
C The FSAR does not identify state or regional. authorities responsible a.
for emergency planning or who have special qualifications for dealing i
with emergencies.
1-7.
Yes.
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2-7.
(a) CASE is concerned n.ow, as we have always been, with the use of " paper people" -- people who may exist only on paper and have no real, live bodie.s to go with them.
Further, 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 i3 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.
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(b) Public Health Regions functional statement is "to be developed."
It is indicated that all Bumau of Radiation Cpntrol personnel will receive training.
It is indicated that individuals will receive initial and annual
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retraining applicable to their duties.
It is indicated that planners will or have attended FEMA' planning BNB U456 820823 PDR ADOCK 05000445 G
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d 2-7 (b) continued:
It is indicated that plans will be distributed.
-- FEMA review of Texas REP Plans (c) Fire Protection should be covered by the State, Texas Engineering Extension Service and Forest Service. Only a few capabilities in local pl an.
Reference is made to backup capability from University of Texas and Texas A&M, but does not give capabilities.
The only discussion of verification by the DPS will be in accordance with SOPS. SOPS not available for review.
Plans for training include State Personnel only.
-- Dept. of Health and Human Services Public Health Service Food and Drug Administration Review of Hood & Somervell Counties Plans (d) Annex C, Texas Department of Agriculture, not received.
Texas State Emergency Management Plan has written agreements between support organizations but does not include the use of USDA resources.
Maps for recording survey and monitoring data, key land use data l
(e.g., farming), food processing plants, and dairies, should start at the facility and cinlude all of the 50. mile ingestion pathway EPZ.
Up-to-date lists of the name and location of all facilities which regu-t l
larly process large amounts of food or agricultural products (originat-ing in the ingestion pathway EPZ, but located elsewhere) should also be maintained.
-- USDA, Food Safety and Inspection Service Review of State and County plans (e) Provisions for early distribution of personal dosimetry devices from local sources need to be developed so that local workers are covered during the estimated 4-hour deploynent time at the beginning of an
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emergency.
Procedures should be developed for emergency workers to report dosimeter readings frequently.
Additional procedures requiring notification when a worker's dose has reached a specified level shculd be in place.
A special set of instructions should be available for a member of the public who must go into an exclusion area. The exposure infonnation should be available before the individual is contaminated.
It is stated that the Texas Engineering Extension Service is responsible for training of fire fighting personnel, but not for training of police and security personnel.
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.. 'h 2-7 (e) continued:
.C Provisiorg for training of local support personnel am not found in N
the local plans.
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The cross reference for training of medical support personnel appears not to be responsive.
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Annex R is referenced in the cross reference for training of personnel responsbile for transmission of emergency information; Annex R is not available as part of the plan.
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The cross reference refers to documents that a're not available as part
?l of the basic radiological emergency response plan and is not responsive to the criteria.
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No listing by title of detailed procedures for step-by-step implementa-I.ed tion of the plan is included.
The sections of the plan to be implemented' M
by each procedure are not identified.
', ' 4 M.
Page 22, Sec. VIII and page 43, Sec. III.A and B. are referenced;
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however, none of those sections identify Federal and private sector
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]i f*f response organizations.
-l Sec. IV.D is cited in the cross reference for msources available to IR support Federal response. However, this section shows only the duties Diy M
of the response support group and no mention is made of available resources.
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' Annex F,Section V.M states that the Radiological Defense Officer will 16%
l provide assistance as requested to the Texas Department of Health if
'y resources are available. This does not address the requirements of W
NUREG 0654-H.7 that each organization, where appropriate, shall. provide qj for offsite radiological monitoring equipment in the vicinity of the H
nuclear facility. Same comments for H.10, H.11, and H.12.
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Section VII, Part B of the state plan describes the assignment of I
accident assessment responsibilities. The county should state what tj:
4 equipment, if any, is available to' measure whole body ganma exposures and airborne radiciodine concentrations.
A plan for transmitting these data, if any, to the E0F should be included.
Hood County Annex F,Section V.M. does not address I.7 which required
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that "Each organization shall describe the capability and resources i
for field monitoring wit.hin the plume exposure EPZ which are intrinsic
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parts of the concept of operations for the facility."
If the county 1
is not depended upon to supply radiological data to the state and to the utility for use in assessing the magnitude of the emergency, the plan should so state.
Same applies for I.8.
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'l 2-7 (e) continued:
E L
J.2 is not addressed. The utility is primarily responsible for this but cooperative arrangements for sheltering, decontamination, medical attention, etc. are needed.
a Attachment K to the Hood County plan for Emergency Husbandry Procedures addresses the problem of contamination of human and animal foods in j
an adequate manner.
Gamma ray and raiciodine exposures directly from the airborne plume are not adequately addressed.
The response indicated in the pmcedures for the Executive Group is one of ordering evacuation
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or sheltering when recommended by the state or by the utility.
If this is the case, the cross-reference for J.9 should include a refemnce to Section I - The Executive Group Procedures.
L Hood County Annex F,Section V M states that exposure control is the function of the Texas Department of Health but that the county RD0 will assist as requested if resources are available. Attachment G -
l Evacuation - Tab. 3 lists the contents of the list for roadblock per-i sonnel. Only a TLD is to be furnished.
NUREG 0654-K3 requires both self reading (e.g., pocket ion dosimeter) and pennanent record dosimeters (e.g.,TLD).
In addition, the self reading devices must have appropriate.
sensitivities to pennit meeting NUREG-0654, K4.
Each emergency worker should be provided a sensitive direct reading dosimeter (e.g., 0-200 i
m Rem) plus a higher range direct reading dosimeter (e.g., 0-20 Rem) plus a permanent record device (e.g., TLD or film badge).
Improvements are needed in the plan to insure the availability and proper distri-butions of appropriate dosimeters. Section VII-B-7 of Appendix 7 to Annex L of the state plan (contamination control) implies that all 3
workers entering a contaminated area will have dosimeters but the number available, the source of supply, etc., is not detailed.
Dose record forms need to be included in the plan and need to be e
distributed to emergency workers.
In addition, requirements need to be developed for frequent reading and timely reporting of doses to'the j
E0Cs by the emergency workers.
i The procedure for authorization of emergency workers to incur exposures in excess of PAGs needs to be clearly stated in the county plan. This should clearly name the official who is able to authorize this action.
The procedure should also clearly require that the decision take into account the exposure data from the preceding three paragraphs.
L Attachment H - Shelter; Monitoring and Precontamination Procedures of the Hood County plan does not specify action levels for decon-i tami nation.
The Tab 1, Chapter 1, Procedure 5, Part VI does specify i
action levels for initiating decontamination.
g Sections VIII.B.8 of Appendix 7 to Annex L of the state plan states that the Bureau of Radiation Protection will advise the local officials d
in decontamination actions, that are to be conducted in accordance with "NCRP Report No. 65."
No procedures for the disposal of wastes was found. No procedures were found in the Hood County plan for waste disposal., NCRP Report No. 65 should be made a part of the plan if it is the appropriate proceudre to be followed.
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-S-2-7 (e) continued:
Section III.R, Manual of Emergency Procedures, Annex 7 states that
" details and criteria for recovery and reentry "will be provided by the Texas Department of Health." However, there is no evidence in the plan that general plans and procedures have been developed.
The cross reference is marked N/A. The state plan, Sections XI.B and XI.D Annex 7 addresses only state plans and changes.
Provisions should be made for fonvarding local plans and changes to all responsi-ble emergency response personnel.
Supporting plans and their sources are not listed for the local plans.
The listing of supporting plans found in Tab.1, Introduction Sections III and IV, Annex 7, state plan pertains only to supporting plans for the state.
The cross reference indicates that provisions for updating telephone e
numbers are in the utility emergency response plan. They should also be included in the local plans.
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3 NOTE:
Paragraphs 6 on page 3 through the preceding paragraph above apply in similar fashion to both Hood County and Somervell County (the referenced sections in the two county plans may vary somewhat, but the basic infonnation is the same).
-- Argonne National Laboratory Evaluations of the Radiological Emergency Response Plans of the State of Texas and Hood and Somervell Counties (f) Annex C - Shelter Plan (not included).
Annex D - Radiological defense plan (not included).
Annex E - Crisis Relocation Plan (not included).
Cross Reference for C.l.a. indicates N/A. Base plan VI, A.l.d.
and VIII, indicates County Judges or Mayors may request State, Federal or military assistance through State Disaster Districts.
Can local government request Federal or military assistance directly? If so, it should be indicated and the proper procedures for doing so.
Cross reference for C.2.a. indicates this element N/A.
Plan should designate local official to serve as representative of local government at the E0F (may be there if he/she so chooses).
Local government relies heavily upon State assistance for technical capabili ties.
Local resources other than schools and local government not addressed.
Letters of agreement with school districts may be appropriate unless school resources have been comitted previously through legal instruments, in which case such instruments should be included.
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-6 2-7 ( f) (continued):
Unable to find maps of evacuation areas as such.
There is a general lack of precise evacuation procedures in the plans. Will instructions and procedures including areas to be evacuated be included in the public information packages? Unable to find maps of shelter or re-location areas.
Shelter facilities should be outside th*e 10 mile EPZ (Glen Rose Senior High is listed as shelter facility).
Where does the temporary clothing come from if individual's clothing is contaminated?
Local plans should indicate they will participate in appropriate training.
If mutual aid pacts or reciprocal agreements exist between governnent entities, like training will be made available to them.
Those organizations listed should indicate their intent to partici-pate in the necessary training to qualify them for response to an accident /
incident at CPSES.
Plan doesn't say that Emergency Management Director / Coordinator will be trained.
Plan will be reviewed each six months and revisad or updated annually.
While not mentioned specifically, mentions it is assumed this review and update process would consider any comments made as a result of exercise. Should make this specific and indicate who specifically will do such reviewing and updating based on comments received.
-- Evaluation of Hood /Somervell Co. REP Plans Organization - assume by John Benton (name written in in upper right-hand corner)
With regard to all the items listed in the preceding, there will people needed to do all the things which have not been done or which are not yet addressed.
The people (specifically) who will be doing those things should be included, along with an assessment of how many will be available, when they will be available, etc. Where applicable, letters of agreement should also be included with those people.
CASE has not fully evaluated die Texas and County Plans, since we just
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received them on August 7,1982, and this may not be all the items we will find with which we are concerned.
3-7.
See 2-7 preceding.
Other than what is specified there, we haven't made further evaluations at this time.
4-7.
See 2-7 preceding; NUREG-0654, Rev.1; the rule of reason.
5-7.
No.
6-7.
N/A 7-7.
N/A b
- 8-7.
We have not yet made this evaluation, since receiving the information on 8/7/82, other than as indicated in our 8/18/82 Answers to Fourth Set.
9-7.
N/A.
If appropriate, will supplement.
10-7. Same as 9-7 above.
11-7. Same as 9-7 above.
12-7. Yes.
13-7. See answer to 2-7 preceding.
14-7. Same as 4-7 preceding.
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.
15-7. Yes.
16-7. Same as answer 8-4 of CASE's 8/18/82 Answers to Fourth Set.
17-7. Yes.
18-7. See answer to 16-7 preceding.
19-7. See answer to 16-7 preceding.
20-7. Same as answer to 4-7 preceding.
As with the above, we are still reviewing the information which we recently received.
Contention 22.
There is no description of the arrangements for services of physicians c.
and other medical personnel qualified to handle radiation emergencies and arrangements for the transportation of injured or contaminated individuals beyond the site boundary.
21-7. Yes.
22-7. Same as 8-4.d., e., f. in CASE's 8/18/82 Answers to Fourth Set.
23-7. See 22-7 above.
24-7. See 4-7 preceding.
25-7. Yes. See answer 32-4 to CASE's 8/18/82 Answers to Fourth Set.
26-7. See 25-7 above.
27-7. See 25-7 above.
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l 28-7. See answer 4-7 preceding.
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I 29-7. Yes.
30-7. Same as answer 32-4 to CASE's answers to 4th Set.
31-7. See 30-7 preceding.
32-7. See 4-7 preceding.
Contention 22.
d.
There are no adequate plans for testing by periodic drills of emergency plans and provisions for participation in the drills by persons whose assistance may be needed, other than employees of the Applicant.
33-7. Yes.
34-7. Those outlined in the comments received from various State and Federal agencies on the emergency plan, copies of which we assume you have.
We have made no further evaluation at this time in this regard.
35-7. See answer 34-7.
36-7. See Answer 34-7. Also NUREG-0654, Rev.1; the rule of reason.
37-7. Yes.
38-7. See answer 34-7 preceding.
39-7. See answer 34-7 preceding.
40-7. See answer 36-7.
41-7. Yes. The following documents am also applicable to all of CASE's Emergency Planning contention:
FEDERAL REGISTER, 12/23/80, pages 84910 through 84917, Federal Emergency Management Agency National Radiological Emergency Preparedness / Response Plan for Connercial Nuclear Power Plant Accidents (Master Plan); the 8/19/80 FEDERAL REGISTER, pages 55402 through 55416, Nuclear Regulatory Conmission, Emergency Planning: Final Regulations.
42-7. See 41-7 above.
j Contention 22.
e.
There is no preivision for medical facilities in the immediate vicinity of the site, which includes Glen Rose.
43-7. Yes.
t 44-7. Same as Answer to 8-4.d., e., and f of our 8/18/82 4th Set Answers.
45-7. See 44-7 preceding.
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46-7. See answers to 4-7 and 41-7 preceding.
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47-7. Yes.
l 48-7. See answer to 34-7 preceding.
49-7; See 48-7 preceding and 4-7 and 41-7 preceding.
Contention 22.
e.
There is no provision for emergency planning for Glen Rose or the Dallas / Fort Worth metroplex.
50-7. Yes.
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51-7. See answer to 34-7 preceding.
P 52-7. See answer to 34-7 preceding.
f.
53-7. See answer to 49-7 preceding.
54-7. This question was asked and answered previously. See CASE's 8/18/81 CASE's Supplementary Answers: (1) To Applicants Regarding Contention 22, 5
etc., Answer to Applicants' Question 77-2 (page 36 on).
g 2
55-7, and 56-7.
These were also answered as indicated in 54-7 above (Applicants' Questions 87-2 and 86-2, respectively; page 40 on).
f 2
57-7. We have not yet made this analysis. We will supplement as appropriate.
y 58-7. N/A. See 57-7 above.
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59-7. See 58-7 above.
b General Interrogatories 7
60-7. We had thought we might in the past; however, we have been unable to make arrangements for anyone to testify in the time period presently scheduled.
q 61-7. See 60-7 preceding.
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62-7. There are no documents which we have which are not already in the possession of Applicants as far as we know.
If there are any mentioned which you don't have, please advise and we will make them available for copying and inspection.
Respectfully submitted, C
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(P}r's.) Juanita Ellis, President CASE (Citizens Association.for Sound Energy) j 1426 S. Polk Dallas, Texas 75224 214/946-9446
REL/.TED CO3REsPcN!)PNm y.
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DK TIED
.'D UNC UNITED STATES OF AMERICA -
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NUCLEAR REGULATORY COMMISSION.
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'82 ISO 25 Ali tr BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7F;CE OF SECRL'
"~'dEimG & SE';
0 In the Matter of I
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i.? U CH l
APPLICATION OF TEXAS UTILITIES I
Docket Nos. 50-445 y
GENERATING COMPANY, ET AL. FOR AN I
and 50-446 OPERATING LICENSE FOR COMANCHE I
PEAK STEAM ELECTRIC STATION I
UNITS #1 AND #2 (CPSES)
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Answers to Applicants' Seventh Set of Interrogatories to CASE and Requests have been sent to the names listed below this 23rd day of Auaust
, 1982, by:
Express Mail where indicated by
- and First Class Mail elsewhere.
- Hand-deli vered.
4 Ad:r.inistrative Judge Marshall E.
Miller David J.
Preister, Esq.
3 U.
S. Nuclear Regulatory Commission Asnistant Attorney Geh ral j
Atomic Safety and Licensing Board Panel T:nvironmental Protection Division Washington, D. C.
2o555 P. O.
Box 12548, Capitol Station Austin, TX 78711 W
3
- Dr. Kenneth A. ' McCollom, Dean Ms. Lucinda Minton, Panel Law Clerk
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Division of Engineering, Architecture,
U. S. Nuclear Regulatory Comission and Technology Atomic Safety & Licensing Board Panel Oklahoma State University Washington, D. C.
20555 6;
Stillwater, Oklahoma 74 o 74 l
Dr. Richard Cole, Member Atomic Safety and Licensing l
Atomic Safety and Licensing Board Board Panel I
U. S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Waahington, D. C.
20555 Washington, D. C.
20555
- Nicholas S.
Reynolds, Esq.
Atomic Safety and Licensing Debevoise & Liberman Appeal Panel
]*
1 1200 - 17th St., N. W.
U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20036 Washington, D.
C.
20555
- Marjorie Ulman Rothschild, Esq.
Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U.
S.
Nuclear Regulatory Commission W2.chington, D.
C.
20555 Washington, D. C.
2o555 1/A,~ E 6
f)f fs.) Juanita Ellis, President T.ASF (Citizens Association for Sound Energy) 2,i.1 4
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(
.'l 3a STATE OF TEXAS )
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!i Juanita Ellis, being duly svorn, deposes and says:
That she is President of CASE (Citizens Association for Sound Energy),
and kncvs the contents of the foregoing CASE's Answers to Applicants' Seventh Set of Interrogatories to CASE and Requests to Produce and that the same is true of her own knowledge and belief.
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/J1'anita Ellis a
SWORN TO and Subscribed before me on this 23rd day of August
,1982.
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Notary Public My Commission Expires:
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(SEAL)
The original of this page is being mailed under separate cover, First Class Mail, to the Secretary, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, t Attention: Chief, Docketing and Service Section, on this day of Augus 23rd 1982.
9-a
A,...a l STATE OF TEXAS )
Juanita Ellis, being duly sworn, deposes and says:
That she is President of CASE (Citizens Association for Sound Energy),
and knows the contents of the foregoing CASE's Answers to Applicants' Seventh Set of Interrogatories to CASE and Requests to Produce and that the same is true of her own knowledge and belief.
At Am W
%nitaEllis SWORN TO and Subscribed before me on this 23rd day of August
,1982.
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Notary Public My Commission Expires:
2-////</
(SEAL)
The original of this page is being mailed under separate cover, First Class Mail, tothe Secretary, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, Attention: Chief, Docketing and Service Section, on this day of August 23rd 1982.,
.