ML20010H198

Answers to NRC Third Set of Interrogatories & Request for Documents Re Contention 9.Certificate of Svc Encl.Related Correspondence

ML20010H198
Person / Time
Site:	Comanche Peak
Issue date:	09/10/1981
From:	Brink B CITIZENS FOR FAIR UTILITY REGULATION
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8109240124
Download: ML20010H198 (3)

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102.1T4D COR.TCPO.NDE.NCE S-P g 17 GN * "it UNITED STATES OF AMERICA

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. EUCLEAR REGULATORY COMMISSION P BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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i the Matter of T'XAS UTILITIES GENERATING COMPANY, ET AL.

Docket Nos. 50-445 '

Comanche Peak Steam Electric 7 50c446 Station, Units 1 and 2 g' g fg CFUR 'S RESPONSE TO NRC STAFF 'S THIRD

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SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS

%. ' ,w kg  %,4 gq CFUR rogatoriesfiles this and its answers Request to ERC Staff's Third Set of Inter-for Documents.

ANSWERS TO INTERROGATORIIS ON CONTENTION O 9-18. CFUR contends ; hat the staff's DES (parts 5.el and 5.82) fails to adequately resolve the issues raised by CFUR in Contention 9 9-19 Section 5.8.1 of the DES a 1egedly establiches that the combination of continuous (anplanned) and periodic (planned) releases will not exceed the requirements set forth in Part 20 and/or Part 50 of 10 CFR. However, therds no dis-cussion and no attempt to indicate how the Applicant will cenply with 10 CFR 20.1 (c) which states (paraphrased):

In accordance with the requirements of the Federal Radiation Countil the Applicant should, in addition to complying with the requirements set forth in this part, make every reasonable .

effort to maintain radiation exposures as low as is reasonably achievable.

In addition, section 5.e.2 of the DES allegedly establisnez a relationship betwnn health impacts of unplanned releases and probabilities. It is reasonable to assume that periodic Teleases of accumulated radioactivity (not released during 503 accident) will occur in a planned manner follov;ing many accidents. There is still no discussion of nor any inMca- /

tion of how Applicant will comply with 10 CFR Part 20.1 (c) as previously described.

The applicant has come control in the release of gaseous radioactive effluents in that they can choose the nost favorable meterological conditions to make these releasen T8109240124 810910

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CFUR's response, page 2 in order to mirdmize the total person-rem exposure which would result as a conscquence of the release.

As stated in 10CFR Part 50 Appendix I, the total person-rem expo-sure must rely on calculational procedures based upon models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. Account shall be taken of the cumulative effec t of all sources in the pathway. Furthermore, the interium measure of $1000 per total man-rem and $1000 per man-thyrad-rem implies that the linear hypothesis is to be used for the purpose af making these calculations. .

4-20. Other than attornies-in fact, CTUR has relied on no oiber persons.

21. These questions are duplicates of Staff interrogatories G -1, G -2 and G -3 CFUR 's original answer, " Unknown at this time" remains the same. CFL3 is under obligation to ans-wer these interrogatories -J will do so when the infor-mation the Staff is seeking can be supplied. Supplements will be in response to G-1, G-2 and G-3, not 9-21.

9-22. These questions are duplicates of Staff interrogatories ,

G -4, G -5 , and G -6 . CFUR 's original answer, "Unkncwn at this time," remains the same. CFUR is under obligation to answer these interrogatories and will do so when the infor-

- mation the Staff is seeking can be supplied. Supplements will be in response to G-4, G-5 and G-6, not 9-22.

CERTIFICATE I declare (cr certify, verify or state) under penalty of perjury that the preceding answers to NRC Staffs' interrogatories are day true and correct to the best of my knowledge on this /6 ML of September, 1981 ,

_J Betty Brink CFUR 7600 Anglin Drive

- Fort Worth, Texas 76119

CERTIFICATE OF SERVICE I certify that a copy of the foregoing documents have been forwarded ,

to all parties of record this /BW6 day of September,1981, by de-posit in the United States mail.

Adninistrative Judge Marshall E. Miller Mrs. Juanita Ellis U.S. Nuclear Regulatory Comission President, CASE Atomic Safety and Licensing Board Panel 1426 South PCk Street Washington, D. C. 20555 Dallas, IX 75224 Dr. Forrest J. Renick, Menber Atenic Safety and licensing Board 305 E. Hanilton Avenue State College, PA 1680)

Dr. Richard Cole , Me .be. David J. Prcister, Esq.

Atomic Safety and Licensing Board Assistant St'Omey General U. S. Nuclear Regulatorf Cc=ission Environnental Prctection Divisien Washington, D. C. 20555 P. O. Bcx .125LS, Capitol Station Austin, TX 75711 Marjorie U1 nan Rothschild, Esq.

Office of Executive legal Director .- Jeffrey L. Hart, daq.

U. S. Nuclear Regulatory Comissi.on 4021 Prescott Avenue Washington, D.C. 20555 Dallas, TX 75219 -

Nicholas S. Reynolds, Esq. Arch C. McCc11 I:I, Esq.

Debevoise & Libeman 701 Ccmerce S reet

- 1200 17th Street, N.W. Suite 3CL Washington, D.C. 20036 Dallas, TX 752c2 Docketing and Service Section Atomic Safety and Licensing Board Panel Office of the Secretary U. S. Nuclear Regulatory Ccmission .

U.S. Nuclear Regulatory Comission Washington, D. C. 20555 Washington, D. C. 20555 Atonic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Cc :.ission

, Washington, D.C. 20555

/

, . Betty - ink CFUR 7600 Anglin Drive F ort '*:crth , Tc:..w 7511c 0

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