ML20092P769

Second Set of Interrogatories & Request for Production of Documents to State of PA Emergency Mgt Agency on Admitted Offsite Emergency Planning Contentions.Related Correspondence

ML20092P769
Person / Time
Site:	Limerick
Issue date:	07/03/1984
From:	LIMERICK ECOLOGY ACTION, INC.
To:	PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 8407090355
Download: ML20092P769 (4)

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BEFORE THE ATOMIC SAFETY AND LICENSING 30ARD

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E R; ?D' In the Matter of Docket Nos. 50-352 P3ILADE'LPf!IA ELECTRIC COMPANY 50-353 (Limerick Generating Station, Units 1 and 2)

LIFERICK ECOL 0rv ACTION'S 2nd. SET OF INTERR0c.AT0*iIES AND REnUEST F07 PRODUCTION OF DOCU"ENTS TO T;iE PENNSYL'!ANIA E"E'l"ENCY MANAGEMENT AGENCY ON LEA'S AD'1ITTED "iFF '.;ITE" E"ERGENCY PLANNIN', CONTENTIONS Pursuant to the Rules of Practice of tne Nuclear Regulatory Commission (N.R.C. ),10 C.F.R. 2.740 (b), and the Orders o# the Atomic Safety and Licensing Board in this proceeding, Limerick Ecology Action hereby propounds e

the following interrogatories to the Pennsrivania Emercency Manage ent' Agency,

("PE"A"),-i;o be answered fully in writing, under oath, in accorcance with the definitions and instructions set forth oeiow. ndditionally, pursuant to 10 C.F.R. 5 2.741, Limerick Ecology Action requests that PE:'.A procace copies of thos.e s

documents designated by it in its respective answers below.

Definitions and Instructions a

1.

For each interrogatory, please state the full name, work address, and t

title or position of each person providing information for the answer to tne 4

interrogatory.

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2.

The following definitions shall apoly:

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a. "PEMA" shall refer to the Pennsylvania Emergency 'ianascaent Acency, or any official, c,fficer, rember, employee, or consultant thereof and snail include I

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any other related agencies of tne C~nonwealth, upon r;nich ?E"A will rely, particularly the Pa. Sureau of Radiation Protection in the Fa. Jept. of Environmental Resources, and the Governor's Enercy Council representative participating in this proceeding on oenaif of PC1A.

b. " Document" shall mean any written, printed, typec or other graphic matte of any kind or nature, computer tapes or other electronically stored or generated material, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of PE::A

, or wnich PE4A has knowledge thereof, and intends to rely upon in tnis proceeding "Date" shall mean tne exact day, ronth and year if ascertainacie, or if c.

not ascertainable, the best approxination ; including the event's relationshi to other events in the relevant context of the interrogatory)

A d.

"NRC" or " Commission" shall mean either the Atomic Energy Comissio Nuclear Regulatory Comission, as appropriate, including its regulatory s L

L and adjudicatory boards, as indicated by the ccntext of tne interrogatory E

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"Specify", when referring to a proceeding before the Nuclear Regulat e.

E Comission, means that the answer shall set fortn the pecceeding i

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, cpplicant, f

docket number, relevant date, and any otMr descriptive infomation ap h

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• o the req'u'est.

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f. "Specify" or

" identify", when referring to an individual, corporation t

, or other entity, means that the answer snail set forth the name, present or last g

!ij known work address, and if a corporation or other entity, its principal pq e

of business, or if an individual, his or her titie or tities and erpioyer.

D unce an individual corporation or other entity has been thus identified in an answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation or other entity to state merely his E:,

, her or its name, kh 3.

These interrogatories request all knowledge and information in PE! A's

.2 possession and/or knowledge and infomation 4

in the possession of PEMA officials, m)

[M officers, agents, representatives, consultants, and unless privileged, a M8 sil b$

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In each instance in which an interrogatory recuests a statement of pef 1A's assertion, contention, view or opinion, the answer shall also contain a full discussion of the factual basis for the assertion or opinion.,

INTERROGATORIES i

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1. Provide a copy of all information relating to the Penn-DOT t

2 traffic analysis done for the Limerick Plume EPZ (cited by PEMA as t.

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the. source for traffic flow estimates indicated on Limerick Plume i

EP2 maps). Provide all information that was used to determine the s

h vehicle number and time estimates shown on these maps. (fhtual d) 2.

Provide a map of the Limerick Plume EPZ that reflects any, changes made after the'EP2 was slightly extended in Feb. 1984. Please fj3 discuss how these changes were determined.

E Provide all information relating to traffic flow and congestion

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3.

in IS If the following areas.below. Please indicate what analysis has been made

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to consider these impacts during a radiological emergency.

E3 5 51 (a) Valley Forge National. Park and King of Prussia area 5

(unless provided EE in answers to First Set of Interrogatories)

(b) Marsh Creek State Park and flopewell Village area (c) Route 100 South from Pottstown to Exton Mall

4. lias PEMA conducted any surveys or studies to determine the effect that

$3 the Plume EPZ may have on traffic b

spontaneous evacuation outside

==W congestion backing up into the EP2? lias this impact on evacuation times h

been considered?

If yes, please provide any details available. If not, 15 explain why this has not been considered by PEMA

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5. lias PEMA completed its review of PECO's May 1984 Evacuation Time 6 stimate Study? Please provide any comments that

'it PEMA has made about as this study, including all correspondence. exchanged during the develon-

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ETEi mont of the study.

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WITH REGARD TO LEA-22:

6.

Does PEMA have any information available +o determine the number of farmers who would be eligible to be designated as emergency workers in the event of a radiological emergency at Limerick? Provide a status report on the progress made in training farmers who reside within i

the EPZ.

7 Does PEMA have any information relating to possible accident scenarios which could result in radiation releases that might prevent f

farmers from being designated as h.

emergency workers *, or any other E

E circumstances that might limit farmer access to the EPZ?

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8.

Does PEMA intend to present any witnesses on LEA-22? If yes, ES please provide information about the subject matter to be covered in 9_,

E any such testimony, and any information about witness credentials E

currently known by PEMA.

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9. Provide a detailed explanation of the x:

training being offered to b

farmers within the EPZ. When and where have these sessions been h

$$n Who has conducted them? How many farmers have participated? Specifically 5 E@

explain what farmers are being told about the ' risks' of exposure to

~EP td radiation if they chose to remain in the EPZ during a radiological emergency [

What role has PEMA played in determining the content of training sessions?

EE in Have PEMA representatives attended these training sessions? How is the EE

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effectiveness of such training evaluated?

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10. In the event of a radiological emergency, where is a farmer supposed

=gg to obtain dosimetry and KI supplies? What arrangements have been made for ggy ES decontamination of farmers ?:.What about pets and livestock?

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