ML20062J431

Informal Request for Addl Responses to First Set of Interrogatories & Requests for Production of Documents,In Lieu of Motion to Compel.Includes Second Set of Interrogatories Directed to Util.Related Correspondence

ML20062J431
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/20/1980
From:	Schuessler W AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-CP, NUDOCS 8010240570
Download: ML20062J431 (2)

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{ October 20, 1980 INTERVEiOR SCHUESSLER'S REPLY TO APPLICANT'S RESPCNSE TO FIRST SET OF INTERROGATCRIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS AND SECCND SET OF INTERRCGATORIES AND REQUESTS FOR PRODUCTICN OF DOCUMENTS TO HOUSTCN LIGHTING AND POWER COMPANY Consistant with comments made at the August 13, 1980 Pre-hearing Conference by Chairman Wolfe, which Intervenor understood to be an expression of a hope and desire tht parties to this proceeding will complete discovery informally and without need for motior.s to compel, Intervenor offers the following reply to Applicant's response to his first set of interrogatories:

Interro catory 1.-

Applicant's objections notwithstanding, Interrogatory 1, including subparts, is proper and Applicant has not been respon-sive. Use of the phrase " accidents like those used in WASH-740" is intended to indicate in a general way the kind of study or studies which would he appropriate. Its use is not intended to require accident assumptions identical to those used in WASH-740 studies. Because the question may have lead to misunderstanding, and since Applicant states that no analyses have been made, for any purpose, wnich utilize accident sequences contained in WASH-740, Intervenor will reword Interrogatory 1, in part, as follows:

1 Assuming occurrances at ACNGS of any accidents which could have a potential for significant off-site radio-lo (b ical releases}

West, and ( c with winds blowing Southwest, from (a) please answer theNorthwest, following questions as they would relate specifically to:

(Remainine nart of Interrocatory 1 unchanced)

If any studies have been done, or if Applicant possesses data and information from any source which is related to the subject matter of Interrogatory 1, please produce such data and infomation.

1.b.* Applicant is unresponsive. Response fails to provide

" sufficient informaticn" required by 10 CFR ? art 50, Appendix E, II. Please describe in greater detail the first aid and decontamination areas, number and training of personnel. Identify and describe possible or proposed sites for these facilities.

1.c.- Incufficient information (See Appendix E, II). Answer not responsive. Please describe local preliminary plans made. What discussicns have taken place, with whom, and what are results?

1.f.- Insufficient infomation (See Appendix E, II). Please provide more detailed description of alternatives being considered. Describe any tests which have been done on these alternatives--their histories and their effectiveness. Who will pay for warning systems? Have costs been estimated?

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THIS DOCUMENT CONTAINS /

8 010 240 5 ~/ D G POOR QUAUTY PAGES

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1.z.- Insufficient information (See Appendix E, II). Please provide more detailed information on preliminary arrange-ments with local authorities. How many mobile public .

address units would be needed? What would cost of oper-tion be and who would pay for it? Paid personnel? Full or part-time? Would these be used in low population density areas? Have estimates been made of effectiveness?

1 1.(1); (2); and (3): Insufficient information (See Appendix E II).

1.1.(4): Please produce copies of all documents comprising the preliminary evacuation analysis. Who prepared it?

Who will testify on it?

1.1.(7): In the process of reaching understanding and agreement with state and county officials, has Applicant been informed by state and counties if they plan to limit to 10 miles their areas of concern? (Reference is, of course, to 10 mile radius EP2.) Who will testify for state?

Who drafted the letters of understanding and agreement from county sheriffs' offices, of which copies were attached to response?

What steps have been taken, if any, to comply with the saggested emergency support facilities set out in NUREG-0694, "TMI-Related Requirements for New Operating Licenses," III.A.1.2 and III.D.3.3, page 20?

SECCND SET OF INTERROGATORIES AND RECUESTS FOR PRODUCTION OF DOCUMENTS TO HOUSTON LIGHTING AND POWER COMPANY 10 Please provide biographical sketches of expert witnesses Murri and Griffin. 'ahat are their particular areas of expert-ise, and what will their testimony cover?

11 Applicant has provided copies of letters of intent from the sheriffs of Austin, Pt. Eend, Waller, Colorado and Wharton counties, and representatives of Polly Ryon and M. D. Ander-son hospitals. Letters refer to discussions between themselves and representatives of HL&P. Please describe these discussions.

When and where did they take place? Who participated? What was discussed and agreed, and in what detail? Etc.

12. 10 CPR Part 50, Appendix E I. Introduction, states that each applicant for a construction permit is required by section 50.34(a) to include in the PSAR a discussion of preliminary plans for coping with emergencies, and sets minimum require-ments for these plans. Please produce copies of PSAR pages containing this disc ssion.

13. In consideration of possible emergencies at ACNGS, what was the " worst possible" accident evaluated?

14 What was learned and what changes in plans for ACNGS have resulted from HL&?'s participation in the meeting of March 19, 1980 conducted by NRC/ FEMA?

Respec fully submitted,

~@ m f-cc: Attached list. Wm. J. chuessler