ML20079L455

Response to First Round of Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14,15 & 18.Certificate of Svc Encl.Related Correspondence

ML20079L455
Person / Time
Site:	Catawba
Issue date:	01/17/1984
From:	Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP, PALMETTO ALLIANCE, RILEY, J.L.
To:	DUKE POWER CO.
References
NUDOCS 8401260132
Download: ML20079L455 (7)

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UNITED STATES OF AMEd vn NUCLEAR REGULATORY COMMISSION optien BEFORE THE ATOMIC SAFETY AND LICENSING B6%nD In the Matter of ) I9 Pl2:S;

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D DUKE POWER COMPANY, et al. ) Docke' EKom.950:-141 3

) 9943 50W14 (Cat,awba Nuclear Station ) ' *A Units 1 and 2) )

CESG'S AND PALMETTO ALLIANCE'S RESPONSE TO DUKE'S FIRST ROUND OF INTERROGATORIES AND REQUESTS TO PRODUCE RE EMERGENCY PLANNING CONTENTIONS 1, 3, 6, 7, 6, 9, 11, lh, 15, and 18 In response to Applicant's filing of December 22, 1983:

1. This response is prepared by Jesse Riley who is known to the parties.

2. At present Riley may testify in regard to all or part of contentions 1, 3, 9, and 11. I am not able to identify other witnesses for PA or CESG.

1. a. Adequacy of the DPC brocnure for EPZ residents.

b. Deficiencies in regard to radiological information, specificity of instructions in the framework of flexible plannind+

c. Known to Applicant.

3 a. Inadequacy of facilities for potential maximum number of evacuees.

b. Studies for evacuation in the event of nuclear war.

9 a. Problems in notification related to time of day or night, weather, availability and reliability of components in the plan, unforeseen responses.

b. Common knowledge of breakdowns in plans and procedures as ' evidenced by LER's and failures in military planning.

]l. a. Local meteorolore, denography, consequence estimates 8401260132 840117 PDR ADOCK 05000413 G PDR .- _ _. . , _ _

o in NUREG/CR-2239 and NRC CRAC study.

b. The combination of prevailing wind, stagnation, and demography is eztreme for Catawba. Population density and transit limitations make detailed planning essential.

b The low probabilities of serious accident occurrence are speculative.

3 1. a. Based on examination of the brochure and a common sense evaluation.

b, c , d, e, and f. NA 3 a. It would be burdensome and of little value to the Applicant to assemhbea list of all studies relating to the consequences of ground contamination by particulates in a serious accident which provide the basis for this contention. The FES starting at p. 5-25 and p. 5-28, pp. 5-30, 31, p.5-36 et seq. makes clear that for a variety of accidents different magnitudes of relocation would be required.

b. The AEC performed WASH-740; with the Dept. of Agricul-ture it made earth contamination studies. The OTA in its report on nuclear war discusses the problems -

of ground contamination and relocation. WASH-1400 considers the subject.

c. These documents are certainly known to the Applicant.

d. The volume of the appendices to WASH-1400 should make clear the impracticality of making a literal response to this request.

e, f. See response to c. foregoing.

9. a. The several emergency planning documents sent to the parties by the npplicant provide the basis for concerne

y expressed by Intervenors.

b, c. Known to Applicant.

d, e. Studies do not lend themselves to description in g parametric terms.

f. The studies provide a limited number of incompletely defined scenarios of insufficiently specified accidents.

The content of the planning documents is primarily organizational and administrative. Substantive matters appear to be relegsted to ad hoc solutions.

In regard to dealing with a major accident there is this alarming sentence, " Municipal and epunty governments are responsible for the safety and welfare of their constitusnts (although none were involved in the CP or OL proceedings] to the extent of .their capabilities and resources in time of a t

threat or disaster." York Plan, p. 4 (May,1963)

11. a. Applicant is familiar with the documents to be referred to: "Sandia Study", NUREG/CR-2239; S ER , NUREG-0954, p. 13-13; Evacuation Time Estimates, ,

FRC Voorhees (April 1983); ER Plans, etc., KUREG-0654'; f Comparative Climatic Data for the US Through 1962, h noaa; Inversion Studies, Job. No. 52575 and 16454; C. R. Mcsler, Low-Level Inversion Frequency in the Contiguous United States, Monthly Weather Review, i

p. 319-339 (September, 1961); FSAR as appropriate; South Carolina Air Quality--1982 Annual Report.

b. The sponsors of the reports, a. foregoing, have been .

identified. Largely the authors are not identified.

c. The dates of most of the studies are given in a.,

_g-foregoing. The inversion studies are for 1/72-12/76 and 1/64-12/73 respectively,

d. This request is burdensome in the extreme and of D dubious value given the identity of the documents.

e. The relevant results of these studies provide the basis for substantial portions of the affidavit of the undersigned filed in the subject proceeding Nov. 18, 1983

f. See affidavit of hov. 18, 1983, e. foregoing.

4 1. a. The brochure has been discussed with Robert Guild and Michael Lowe, both known to Applicant.

b. See a. foregoing.

c. No log was kept of the several conversations. The time would be shortly after receipt of the emergency plan documents. The minimization of radiological dangers and the possible functionality of the brochure were discussed.

d. NA.

e. NA.

1 a.

3 See 4.1.a. foregoing.

b. See 4 1.a. foregoing.

l c. The costs of long term relocation for a substantial number of evacuees and the problems of accomodating a large number of evacuees were discussed. Crisis relocation planning in a war emergency was famuliar to the participants.

l d. Each individual appeared to be equally knowledgable.

The conclusions were commonsense conclusions.

i e. NA.

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9. a, b. See 4 1.a. foregoing.

c. Commonsense considerations such as knowing that some sleeping people are not likely to hear sirens, 4 that. weather influences sound transmission, that there are circumstances in which people panic and do not act wisely in their corporate interest formed the basis of this contention.

d. NA.

e. NA.

11. a, b. See 4 1.a. foregoing

c. A similar contention had been made and accepted in the reopened McGuire OL proceeding. Applicability to Catawba was discussed, the more unfavorable meteorology mentioned.

d. NA.

l e. NA.

Re requests for documents: Intervenors have made no written records of their conversations, etc. As yet intervenors have held no conversations with prospective witnesses.

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/ L. ~3 Jesse L. Riley for CESG and Palmetto Alliance Affirmed this 17th day of January, 1984

UNITED STATES OF AMERICA Chh;[

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '84 Jtd 19 P12:51 In the Matter of

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) BRANCH DUKE POWER COMPANY, et al. ) Docket No. 50-413

) 50-414 (Catawba Nuclear Station )

Units 1 and 2) )

AFFIRMATION OF SERVICE I hereby affirm that copies of "CES3'S AND P1LMETTO ALLIANCE'S RESPONSE TO DUKE'S FIRST ROUND OF INTERROGATORIES AND REQUEST TO PRODUCE RE EMERGENCY PLANNING CONTENTIONS 1, 3, 6, 7, 9, 11, 14, 15, and 18" in the above captioned matter were served on the following by deposit in the United States mail this 17th day of January,1981;, with the exception of the copy to Ron Shearin which was hand-delivered on this date.

James L. Kelley, Chairman Richard P. Wilson, Esq.

Atomic Safety and Licensing Board Assistant Attorney General Panel State of South Carolina U. S. Nuclear Regulatory Commission P. O. Box 11549 Washington, D. C. 20555 Columbia, South Carolina 29211 Dr. Paul W. Purdom Robert Guild, Esq.

235 Columbia Drive Attorney-at-Law Decatur, Georgia 30030 P. O. Box 12097 Charleston, South Carolina 29412 l

l Dr. Richard F. Foster Palmetto Alsiance P. O. Box 4263 2135 1/2 Devine Street Sunriver, Oregon 97702 Columbia, South Carolina 29205

! Chairman Ron Shearin, Esq.,

l Atomic Safety and Licensing Duke Power Company l Board Panel l U. S. Nuclear Regulatory Commission P. O. Box 33189 Charlotte, N. C. 28242 l

Washington, D.C. 20555 l Chairman Henry A. Presler

! Atomic Safety and Licensing 945 Henley Place Appeal Board Charlotte, North Carolina 28207 l U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 l

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. George E. Johnson, Esq. Karen E. Long Office of the Executive Legal Assistant Attorney General Director N. C. Department of Justice U. S. Nuclear Regulatory Commission P. O. Box 629 Washington, D.C. 20555 Raleigh, North Carolina 27602 Scott Stucky Don R. Willard Docketing and Service Section Mecklenburg County U. S. Nuclear Regulatory Department of Environmental Commission Health Washington, D.C. 20555 1200 Blythe Boulevard Charlotte, North Carolina 28203 Michael J. McGarry, III, Esq.

Bishop, Liberman, et al 1200 Seventeenth Street, N.W.

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