ML20092J756
| ML20092J756 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/21/1984 |
| From: | LIMERICK ECOLOGY ACTION, INC. |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20092J760 | List: |
| References | |
| OL, NUDOCS 8406270106 | |
| Download: ML20092J756 (15) | |
Text
Ls.
RELATED COTtr,ISPOND24CC CCSETEC UERC UNITED STATES OF AMERICA N 2 25 R202 NUCLEAR P.EGULATORY COMMISSION CG; 77 4 ;,,
Before the Atomic Safety and Licensing Board
-8 In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 6'
(Limerick Generating Station,
)
Units 1 and 2)
)
LIMERICK ECOLOGY ACTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION.0F DOCUMENTS TO'THE PHILADELPHIA ELECTRIC COMPANY ON LEA'S ADMITTED "0FF-SITE" EMERGENCY PLANNING CONTENTIONS Pursuant to th( Rules of Practice of 'the Nuclear Regulatory Commission ("NRC"), 10 C.R.F.h-2.740 (b),' and the Orders of the Atomic Safety-and Licensing Board in this7 pror.edding,' Limerick: Ecology Action:hereby propounds.the following.' interrogatories to the Philadelphia ~ Electric.
Company ~(PECO), to be^ answered fully-in writing, under oath,.
in accordance with the definitions and instructions set forth below. Additionally, pursuant.to 10 C.F.R. [ 2.741 Limerick Ecology Action requests that'PECO-produce copissnof those documents designated by it in-its respective answers below.
' Definitions and Instructions 1.
For each interrogatory, please state the full
.name,- work address, and title or position of each person providing information for the answer to the interrogatory.
K O 000 6
1 1
j 2.
The following definitions shall apply:
- a. "PEC0" shall refer to the Philadelnhia Electric Company, or any official, officer, member, employee, or consultant thereof, including Energy-Consultants, Inc.
i b.
" Document" shall mean any written, printed, typed or other graphic matter of any kind or 3
- nature, computer tapes or other electronically l
stored or generated material, and all mechanical j
r and electronic sound recordings or transcripts i
thereof, in the possession, custody, or control of PECO, or its officials, employees, or consultants;
^
it shall also mean.all copies or drafts _of documents-by whatsoever means made.
l c.
"Date" shall mean the exact day, month and year, if ascertainable, or, if not ascertainable, l
the best approximation (including-the event's relationsaip to other events in the relevant context of the interrogatory).
d.
"NRC" or " Commission" shall mean either the
- j Atomic Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regu-latory staff and adjudicatory boards, as indicated r
by the context of the interrogatory.
e.
"Specify",
when referring to a proceeding t
before the Nuclear Regulatory Commission, means i
that the answer shall set forth the proceeding, applicant, docket number, relevant date, and any l
t l
_ i other descriptive information appropriate to the request.
f.
"Specify" or " identify", when referring to an individual, corporation, or other entity, means i
that the answer shall set forth the name, present or last known work address, and, if a corporation or. other entity, its principal place of business or, if an individual, his or her title or titles and employer.
Once an individual corporation or
?
other entity has been thus identified in answer to an interrogatory,- it shall be sufficient thereaf-
~
ter when identifying.that individual, co'rporation or. Other entity to state inerely his, her or its L
name. -
3.
These -interrogatories,: request all knowledge and
~
l information -in '," FECO's possession mand /or knowledge and information in the possession of, PECO officials, officers, agents, representatives, consultants, and unless privileged, I
attorneys.
4.-
In each instance in -which an interrogatory re-quests a statement of _FECO's assertion, contention, view or opinion, the answer shall also contain a full discussion of the factual basis for the assertion or opinion.
Interrogatories 1.
State whether,PECO intends to present any expert witnesses on the subject matter at issue in the contentions and issues sponsored by Limerick Ecology Action e
.t admitted by the Atomic Iafety and Licensing Board in this April 20, 1984 on the issues of "off-site" emergency planning for the Plume-Excosure EPZ for Limerick.
If so, identify each expert witness and state (a) his professional qualifications; (b) the contention and subject matter on which the expert is expected to testify; (c) the substance
[
of the facts and opinicas to which the expert is expected to testify; (d) the grounds for each opinion.
Identify by court, agency or other body, each proceeding in which such individual rendered testimony on this subject.
2.
State whether PECO intends to present any l
factual witnesses on the subject matters at issue in LEA's admitted contentions.
If so, identify each such factual witness and further state (a) his professional qualifications; (b) li the contention and subject matter on which the witness is t
expected to testify; (c) the substance of the facts to which I
the witness is expected to testify.
Identify by court,
- agency, or other
- body, each proceeding in which such individual rendered testimony on this subject (s).
3.
Identify by title, author, publisher and date of issuance or publication, all documents that. PECO relics upon as a basis for contentions or th'at PECO inte.nds to use (by way of reference or evidentiary proffer) in present-ing i,ts direct case in cross-examining other witnesses on off-site emercency olanning contentions, and all documents which PECO intends to refer in conducting cross-examination of
F other witnesses who may testify in connection with any such contention.
4.
To the extent that your answer to any interroga-tory is based upon one or more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely;- (c) explain how the information provides a basis for 4
your answer.
5.
To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe the nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (b) identify the per.
son (s) or entity (ies) who performed-the study, calculation, research-or analysis; (c) describe in detail the'information a
which was the subject of the study, calculation,".research or " -
analysis;.(d) describe the results of such study,.calcu-lation,- research or analysis; (e) explain how such study, calculation', research or analysis provides a basis for your answer.
6.
To the extent that ayour answer is based upon conversations, consultations or correspondence or other communications with one or more individuals or entities,-
please identify each such individual or entity; (b) state the educational and professional background of each such individual, including occupation and !nstitutional.af fil-iations; (c) describe the nature of each communication,
-6 including time and context, and describe the information 4
received from each such individual or entity; (e) explain how such information provides a basis for your answer.
7.
To the extent that PECO possesses information or documents expressing facts or opinions which are relevant t'o the specific interrogatories below, but which do not support Annlicant's Position or which have not otherwise been fully provided in the answers thereto, please provide such information and documents.
UITH REC ARD TO LE A--ll:
8.
Supply any and all information currently available reb
___, ___ garding the arrangemento made for provisions of buses to evacuate school children in private and public schools in Chester and Montgomery Counties within the L'inerick Plume EPZ.
?
a list of the bus companies wilfing to make 9.
Provi,de buses available for evacuation of Chester and Montgomery County public and private schools in the event of a radiological emergency at Limerick'.
10.
Have formal Letters of Agreement been completed for all bus companies expected to provide buses for use in Chester and a list of the agreements still Montgomery Counties? If not, provide to be completed. If yes, provide a copy of all completed Letters of Agreement.
11.
Indicate the number of buses available from each company (by company) that can be expected to be available in the event of a radiological emergency at Limerick.
i i
~~ -
~
12.
For each bus company expected to provide buses, please
+
provide any information available to PECO or Energy Consultants, Inc., or any info they have knowledge thereof, regarding the length of time necessary to dispatch buses from the time it has been t
determined that they are needed until they reach the school to which they will be assigned.
13.
Who is responsible for c6ntacting the bus companies during a radiological emergency at Limerick?
l
.FOR THE.FOLLOWING, PROVIDE ANY INFORMATION AVAILABLE TO PECO, ENERGY CONSULTANTS, IN C. ~, OR WHICH EITHER PRESENTLY HAS ANY KNOWLEDGE THEREOF-14.
How will each bus company be contacted in the event of a radiological emergency at Limerick? Be specific.
- 15. How will esch': individual *. bus:. driver be contacted during any period of time covering a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period? Be specific.
16.
Are each-of the buses that will be used. equipped with T.
2-way radio eq'uipment? If PECO cr ECI has-knowledge of-details-about the kind of equipment involved, please provide any informae
~ ion either have knowledge thereof.
t 17.
Are buses pre-assigned to specific schools? If not,-
i how and when will th6se assignments be made in the event of a l
radiological emergency?tHow will this information be communicated?
By wh6m? If assignments have been made, provide all details available.
l 18..
WITH REGARD TO CONTENTION LEA-15, PLEASE PROVIDE ANSWERS TO THE FOLLOWING QUESTIONS ABOVE AS THEY WOULD PERTAIN TO " BUS-DRIVERS":
8, 10,.11, 17, and 9.
(For number 9, in the event that buses are--
l available but there'are insufficient _ bus drivers, provide any in-L t
formation available about the source of other personnel or persons L
that would be used to drive buses.in the event of a radiological l
emergency.)
19.
Does PECO or ECI have any knowledge of whether companies l
~
e-,--,
e,-
n.
,. -,... -, - +
- have surveyed their drivers to determine the number that would participate during a radiological emergency? If yes, which companies have done so, when was the survey done, and what were the results?
If no, what is the basis for the assumption that a sufficient number of bus drivers will be available?
- 20. llave all bus drivers expected to participate received
" training" for a radiological emergency?
21.
Please describe the " training" received. When, where, e
and by whom have the training sessions been conducted? Provide the dates of training sessions and the number of participants, identi-fying the bus company involved.
- 22. If any of the arrangements for buses are being made by anyone other than FECO or ECI, please provide the basis for the company's position that unmet needs have been or will be s at is fied.
Answer the same, question with regard to arrangements for bus drivers.
23.
Provide copies of all correspondence related to the involvement of bus drivers and buses in emergency response planning for a radiological emergency at 1.imerick. Provide any information available that outlines the responsibilities of the bus company or their drivers during a radiological emergency at Limerick. If none exists, please explain how this information has been discussed and agreed upon by the bus companies and their drivers. If someone other than PECO or ECI has made these arrangements (such as a County Office of Emergency Preparedness), please provide all infor-mation that will be relied upon by PECO to demonstrate that there are sufficient buses and drivers available to carry out the local, county and school district emergency response plans.
I* PECO is going to refer to any correspondence previously sent to LEA in this procee-
_.__.__r,
9 ding, please provide the date, author, and recipient of the letter /
information, to avoid any possible confusion, unless copies are going to be included in PECO's response to this and other Discovery requests.
24.
Provide a summary of any " verbal understa'ndings" that PECO has knowledge of, or will rely upon to prcvide assurance that individual bus drivers will respond when contacted in the event of a radiological emergency. Provide copies of any letters, contracts or written agreements to support PECC's position.
25.
Have bus drivers, school staff, and other emergency workers been informed of the " risks" associated with remaining in or entering the EPZ during radiological emergencies requiring
~
sheltering or evacuation as a protective measure? If not, why not?
If yes, what information has been provided to theu? How and when was this information presented?
26.
Have a'ny promises, inducements, incentives in writing (or otherwise) been made to bus companies or individual drivers or
" volunteers" of any kind to obtain their services or upon which a committment was made to provide such services or participation.
(An example of this would be the of fering of PECO to provide eqnipment necessary for the municipal EOC's.)
If so, please specify. If not, please state whether PECO anticipates providing any communications equipment for any of the bus companies, their drivers, or any public or private schools. Please provide any written agreements or summaries of any verbal agreements which encompass these understandings.
27.
Do any such agreements for bns services with individuals or companies contain penalty clauses for failure to comply? Do any such agreements contain incentive clauses for willingness to comply?
Does PCCO have any knowledge of whether or not such agreement pro-
10 -
L visions are;part of. general employment contracts for bus drivers?
- 28. Does PECO have any knowledge of whether or not school L
staff is expected to remain on duty during a radiological emergency due to1 contractual agreement? If yes, please provide any information that F
will be used by-PECO to support its position that there are sufficient i
school staff available and willing to remain with students during a l
I
-radiological emergency. Provide specific information available for each school. involved.
- 29. What information is available to PECO to indicate the i
amount of. response time involved before buses can be expected to arrive at their designated schools during a radiological emergency?
'Please indicate all information that will be relied upon by PECO, or that,the company presently has knowledge of.
~
- 30. Have bus companies been-informed of any potential legal liability for inadequate' response of its drivers during an emergency?
How does a bus company guaranter the n"ailability of drivers during a radiological emergency? Docs PECO have any knowledge of verbal, contractual, or written agreement.s between drivers and bus companies?
- 31. Do bus companies have committments to provide services for
[
more than 1 school district, municipality or other facility du' ring an emergency? If so,-please provide a licting of all committments i
that PECO (or ECI) has knowledge of.
rl'
- 32. Have bus drivers and their companies been informed about the need for them to remain at host schools to subsequently provide transportation to mass care centers? Is this matter discussed in writ-
+
ten or verbal agreements?
Please provide any info that PECO is aware of.
- 33. Does PECO (or ECI) have any knowledge of bus drivers or companies unwilling or unable to provide bus drivers for transportation from host schools to mass care centers? If yes, what arrangements L
have or will be made to provide transportation from host schools to
= - - - -, -. -
8 11 -
6 mass care centers?
f WITH REGARD TO LEA-13:
?
34.
What provisions have been made to provide transportation for pre-school and day care children out of the EPZ? Provide any 1
information that will be relied upon by PECO to provide assurance that these transportation needs have been identified and will be met.
(This refers to children within the EPZ at the time of an emergency) 35.
If local municipalities are making these arrangements, pro-vide all information that PECO has knowledge of regarding these arrangements. Have letters of agreement been developed to insure that adequate transportation will be available? Provide copies of any l
written agreements or summaries of any verbal agreement 6 or understand-ings. (The same appiles to any ar'rangements to be made by-the county or.
state agencies involved.)
- 36. What priority, if any,-has been given to the transportation needs of pre-school / day care children among the " pool" of transportatici I
needy people, which includes the ciderly, handicapped, or those i
otherwise without transportation means to evacuate?
- 37. Will buses or private emergency vehicles be used to evacuate the pre-school children? Have they been numbered and identified?
- 38. How many buses or emergency vehicles will be used to evacuate prelschool/ day care children? Have agreements been reached with bus drivers or "~olunteer" drivers to evacuate these children? If yes, please v
provide a copy of any such. agreements or understandings.'If not, when are these arrangements anticipated to be completed? If they are not contemplated, please explain why.
- 39. Are pre-school / day care staff expected to remain with children i
until parents arrive? If yes, what is this assumption based on. If no, what arr6ngements have been made to supervise, transport and care I
for these children during a radiological emergency?
40.
What effect will the use of volunteers have on the transportation of' pre-sch'ool-and day care children? Will parents be asked to approve release of their children to the care of unidentified, unnamed people in the event of a radiological emergency? What special training, if any, will such volunteers
. receive in dealing with pre-school evacuees?
. 4,1.
How will parents be notified of their child's whereabouts?
Will parents be allowed to enter the EPZ to pick up their children during a radiological emeinency?'Will parents otherwise be permitted to pick up their children at school before they are evacuated out of.the EPZ? Has this factor been considered in traffic congestion studies (especially for the larger day care centers)? For example, has the'effect on road access been considered? Will additional traffic control points be necessary? Has the additionni stress on existing traffic control points been considered?
14 2.
Will pre-schoolers be evacuated as efficiently and effec-tively as other school district pupils? What is the status of develo-ping emergency response plans for day care and pre-school children in Chester, Montgomery and Berks Counties? Please provide any informa-tion that PECO or ECI has knowledge of, or that will be relied upon n
in this proceeding..
43.
What consideration has been given to the capability of day-care and pre-school buildings in the. event that sheltering is the protective measure that is recommended? How will the adequacy of thes,e buildings be determined?
- 44. What measures will be or have been taken to insure that such centers (day care & pre-school) have adequate radio /TV/ phone i
communications for receiving information to d'etermine appropriate i
f response during a radiological emergency?
L
o UNITED STATES OP AMERICA NUCLEAR REGULATORY COMf11SS10N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 50-353 (Limerick Generating Station, Units 1 and 2)
NOTICE OF APPEARANCE Notice is hereby given that'Maureen Mulligan has been authorized by the Board of Directors of Limerick Ecology Action to enter an appearance in the above-captioned ma,tter. I will be
~
representing Limerick Ccology Action, with re ga rd to "off-site" emergency planning issues in this proceeding.
In accordance with 10 C.F.R. 32.713(a), the following information is provided:
Name: Maureen Mulligan
Title:
Vice President, Limerick Ecology Action i
Address: Maureen $ulligan Limerick Ecology Action
(*) for Federal Express use:
P.O.
Box 761 1
762 Queen Street Pottstown, Pa. 19464 Pottstown, Pa. 19464 Phone: (215) 458-5683 or (215) 326-9122 Name of Party: Limerick Ecology Action Please note: This information was previously provided verbally to I
- all parties actively involved in "off-site" emergency planning issues.
This Notice of Appearance is being distributed to the entire service list for this proceeding.
fdL4lubn 1:lthbfi a RAUREEN MULLIGAN Vice President L SWORN AND UBSCRIBED TO ME I'HIS 4 76 DAY OF If///
1984 e
Afff Afufh (Notary Public)
FRANKLIN MANN 3rd Notary Public Pottstown Boro. Montgomery Co. Pa.
My Commrsson Erpires February 4,1999
/
00: ?re-dt. ~
'84
,N AU N2 02 CERTITICATE OF SERVICE I
. r.~
I hereby certify that the following information was serhdhA.[:w' S.
upon the fol, lowing parties by first class mail, postage pre [aT[,4 with hand delivery, on June 21 1984, to those on the service list beside whose name appears an asterick
(*)*
LEA Findings of Fact and Concidsions of Law on LEA I-42;
- LEA Findings-of Fact and Conclusions of Law on On-site Emergency. Planning Contentions; (mailed under separate cover)
_ LEA's First Set of Interrogatories on Off-site Emergency Planning" !
(0) Lawrence Brenner, Chairman (2)
(*) Ann P. Hodgdon, Esq.
l Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, DC 20555 l
- Washington, DC 20555 t
(*) Benjamin Vogler, Esq.
(*) Dr. Richard F. Cole Office of the Executive Legal Di~ rector i
Administrative Judge U.Se Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission l
Washington, DC 20555
(*) Troy B. Conner, Jr., Esq.
Conner and Wetterhahn Dr. Peter A. Morris 1747 Pennsylvania Ave'., NW i
(o) Administrative Judge
- Washington, DC 20006 U.S. Nuclear Regulatory
- Commission
(*) Philadelphia Electric Company Wnshington, DC 20555 Attn:
Edward G.
Bauer, Jr.
VP and General Counsel
{
Docketing and Service Section 2301 Market St.
Office of the Secretary Phila., PA 19101
}
U.S. Nuclear Regulatory l
Commission Thomas Gerusky, Director N0shington, DC 20555 Bureau of Radiation Protection, DER l
5th fl, Fulton Bank Bldg.
Atomic Safety and Third and Locust Sts.
I
-Licensing Board Panel Harrisburg, PA 17120 l
U.S. Nuclear Regulatory Commission Spence W.. Perry, Esq.
Washington, DC 20555 Associate General Counsel l
FEMA l
Atomic Safety and Room 840 i
Licensing Appeal Panel 500 C St., SW U.S. Nuclear Regulatory Washington, DC 20472 Commission W2shington, DC 20555 Zori Ferkin, Esq.
Governor's Energy Council P.O. Box 8010 1625 Front St.
Ilarrisburg, PA 17105 e
L_._
Jay M.
Gutierrez, Esq.
Robert Sugarman, Esq.
U.S. Nuclear Regulatory Commission Sugarman and Denworth Region 1 Suite 510 631 Park Ave.
King of Prussia, PA 19406 North American Building 121 S. Broad St.
Phila., PA 19107 D.irector, PEMA Basement, Transportation David Wersan, Esq.
and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate 1425 Strawberry Square Angus Love, Esq./ Meg,g1 Cgid) liarrisburg, PA 17120 10 7 East Main St Norristown, PA 19401 Gregory C.
Minor Robert Anthony MilB Technical Associates 103 Vernon Lane 1723 Hamilton Ave.
Moylan, PA 19065 San Jose, CA. 95125 Martha W. Bunh, Esq.
Kathryn S.
Lewis, Esq.
Timothy Campbell Solicitor's. Office Chester. County Dept.
City of Philadelphia f
mergency enices Municipal Services Building 14 East Biddle Street Phila., PA 19107 West C h e s t e.r. Pa. 19380 Steven Hershey, Esq.
community Legal Services 5219 Chestnut'St.
Phila., PA 19139 Marvin I.
Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.
Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.
Ardmore, PA 19003 June 21, 1984 Ad1A1W f
MAUREEN MULLIdAN, A V.
PRESIDENT