ML20073P210
| ML20073P210 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/22/1983 |
| From: | Scherr S National Resources Defense Council, Sierra Club |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8304250068 | |
| Download: ML20073P210 (24) | |
Text
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- - p UWC UNITED STATES OF AMERICA N EP N Ul N NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.
Dr. Cade t H. Hand, Jr .
)
In the Matter of )
)
UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
. TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
)
)
~ RESPONSE OF INTERVENORS TO NRC STAFF FIRST SET OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUESTS FOR ADMISSIONS TO NATURAL RESOURCES DEFENSE COUNCIL, INC . AND THE SIERRA CLUB CONCERNING CONTENTION 9 (EMERGENCY PREPAREDNESS)
DATED APRIL 8, 1983 Pursuant to 10 CFR $$ 2.742 ard { 2.740b, and in accordance with the Board's Construction Permit Scheduling Order of March 29, 1983, Intervenors, Natural Re sources Def ense Council, I nc .
and the Sierra Club, hereby respond to NRC Staf f First Set of Construction Permit Interrogatories and Requests f or Admissions to Natural Resources Def ense Council, Inc. and the Sierra Club Concerning Contention 9 (Emergency Preparedness ), dated April 8, 1983.
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General Responses (a) The direct answer to each interrogatory is provided
- below.
(b),(c) Documents, if any, will be identified in the direct answer below.
(d) Thomas B. Cochran is the primary NRDC employee who provided the answers to these interrogataories. His qualifications have been provided to all parties at the LWA-1 Hearings.
(e) None.
(f) Experts have not been identified at this time.
Interrogatory 9-1 Define, " seriousness," arrl " potential scope," as those j terms are used in Contenticn 9(a).
Response
9-1 Intervenors have withdrawn Contention 9(a) and therefore no response is required.
Interrogatory l
l 9-2(a) Define, " radiological-consequences," as that term is usal in Contention 9(a).
(b) List all " radiological consequences," which NRDC believes must be considered by Applicants and/or Staff with regard l to energency pregaredness.
Response
9-2 Intervenors have withdrawn Contention 9(a) and theref ore no response is required.
Interrogatory 9-3(a ) Define, "energency situations within arri outside the site Wery," as that yttrase is used in Contention 9(a).
(b) List all emergency situations diich NRDC contends must be ccnsidered by Applicants and/or Staff with regard to energency pregaredness.
Response
9-3 Interven9rs have withdrawn Contention 9(a) and therefore no response is required.
Interrogatory 9-4(a) Define, " capabilities for dose projection," as that phrase is used in Ccntention 9(a). Does the term refer to ccuputer codes, modeling, or physical hardware?
(b) List all "cagabilities for dose projection" that NRDC contends Applicants must anplay to satisfy NRC regulations arti guidelines.
- (c) What models and assumptions does NRDC contend should be used in the dese grojections referred to in Ccntention 9(a)?
(d) Identify the organ doses that NRDC contend should be calculated as part of the dose projecticns referral to in Contention 9(a).
(e) List all locations (e.g., EPZ, ex:lusion area boundary) where NRDC contends that doses must be calculated by Applicants.
Response
9-4 Intervenors have withdrawn Contention 9(a) and therefore no response is required.
f Interrogatory 9-5(a) Define, "real-time," as that term is used in Contention j 9(a), by stating the range of time delays acx:eptable for
l meteorological information to be utilized by Applicants in their dose grojections.
(b) List all " meteorological information" which NRDC contends must be considered by Applicants in deriving their dose projecticms.
Response
9-5 Intervenors have withdrawn Contention 9(a) and therefore no response is required.
Interrogatory M (a) Define, " radiological monitoring teams," as that term is ussi in Centention 9(a).
(b) List the mp=hilities diich NRC contends the
" radiological mcnitoring teams" must possess in order to adequately resporu to radiological incidents at CRBR.
Response
9-6 Intervenors have withdrawn Contention 9(a) and therefore no response is required.
Interrogatory 9-7 What Comission regulations and/or Staff regulatory
[ guidance does NRDC corttend require the capabilities discusssi in l Contention 9(a)? Cite to specific sections and stbsections of the
! IEC regulations and guidance materials.
l l Response l
9-7 Intervenors have withdrawn Contention 9(a) and therefore no response is required.
i l Interrogatory l
l 9-8(a) Define, " local emergency resInnse needs and capabilities", as that term is ussi in Contention 9(b).
(b) Define, " local," by listing the areas around the CRBR site which N10c contends are " local".
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(c) List the " emergency response needs and capabilities" rsferred to in Contention 9(b). Provide the factual basis for each item which NRDC contends is a "need". Provide the regulatory basis for eadt item which NRDC contends should be a "cagability" .
Response
9-8 Intervenors have withdrawn Contention 9(b) and l therefore no response is required .
Interrogatory 9-9 ' Specifically describe how Applicants and Staff have failed to " properly account" fm local energency respertse needs ard capabilities in desigrating the EPZs for CRBR.
Response
9-9 Intervenors have withdrawn Contention 9(b) and
- theref ore no response 'is required.
Interrogatory 9-10 Describe the methoiology ard criteria that NRDC conterds the Applicants and/or Staff should utilize in designating the plune exposure pathway ard ingestion pathway EPZ's for CRBR. " Provide the basis for NRDC's answer, by specifically citirq regulations, regulatory guidance materials, periodical articles, or books.
Response
9-10 Intervenors have withdrawn Content.i n 9(b) and therefore no response is requi red .
Interrogatory 9-11 Describe the boMaries of the plune exposure pathway ard ingestion pathway EPZs for CRBR which NRDC contends are more approgriate than the Applicants' ard/or Staff's. If NRDC does not have proposed EPZs for CRBR, does it interd to develop alternate
. EPZs for CRBR? Set forth the date by which these alternate EPZs will be developed.
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Response
9-11 -Intervenors have withdrawn Contention 9(b) ~ and therefore no response is required.
Interrogatory 9-12 Describe with particularity the methodologies and criteria whi& NRDC cattends the Applicants and/or Staff must utilise in order to sufficiently analyze evacuation time for the CIBR locality. Provide the basis for NRDC's answer, by
, specifically citing NRC regulaticris, regulatory guidance materials, periodical articles, or books.
Response
9-12 Intervenors have withdrawn Contention 9(b) and therefore no response is required.
Interrogatory 9-13(a) Does NRDC ocntend that there are methodologies and criteria which must be utilized to designate sectcrs within the EP7A for CRBR?
(b) If the answer to (a) is yes, describe with specificity, and provide the basis for NRDC's answer, by citing NIC regulations, regulatoray guidarce materials, periodical articles, or books.
Response
9-13(a) Intervenors have withdrawn Contention 9(b) and
, . therefore no response is required.
Interrogatory 9-14(a) Define, " major imparliments," as that term is used in Contention 9(c).
(b) ' Set forth the criteria, parameters, or other factors which NRDC contends should be utilized to distinguish " major" iWiments from' impediments whi& are minor, or less serious.
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Response
9-14(a) See Answer to Interrogatory 27 of Applicants'
-Eighth Set of Interrogatories to Intervenors, filed April 14, 1983.
(b) Intervenors have identified no such criteria at this time .
Interrogatory 9-15(a) Define, " transient populaticn", ard " pes.r -
population", as those terms are used in Centention '4(c).
(b) Set forth the criteria, prameters, dta, or other factcrs that NRDC centerwis should be utilized in determining whether an irdividual should be categorizai as part of the "transiet" or "permanet" populations.
Response
9-15(a) Intervenors define these terms as used in 10 CFR 50
, Appendix E.
i (b) rntervenors have identified no such criteria at this t ime .
I Interrogatory 9-16(a) Define, "gotective actions," as that term is used in Ccntenticn 9(c).
l (b) List all potective actions which NRDC ocnterds must
! be ccnsidered by Applicants and/or Staff with regard to energency preparedness.
Response
l 9-16(a) Intervenors define these terms as used in 10 CFR 50
. Appendix E.
(b) Intervenors have identified no such criteria at l this t ime .
I
Interrogatory 9-17 Define, "capatibility of proposed emergency plans," as
~
that term is used in Cententicn 9(d).
Response
9-17 . Intervenors have withdrawn Contention 9(d) and
- theref ore no response is required.
Interrogatory 9-18 List and describe with particularlity the " facility desip features", which NRDC asserts must be considered to ensure the capatibility of proposed CRBR emergency plans.
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Response
1 9-18 Intervenors have withdrawn Contention 9(d) and
, theraf ore no response is - required .
l Interrogatory.
9-19 Describe with particularity the methodology and criteria which NRDC centends should be utilized by Applicants and/or Staff tc ensure the compatibility of proposed CER anergency plans. In your answer, describe how facility desim features, site layout, ard site location mast be considered. Provide the basis for NRDC's answer, by specifically citing sc regulaticns, regulatcry guidarr:e materials, periodicals, or books.
Response
9-19 Intervenors have withdrawn Contention 9(d) and theref ore no response is required.
Interrogatory 9-20 Define, "authorizaticm", " notification", ard "instructicn procedures fcr evacuaticn," as those terms are ussi in Centention 9(e).
i
Response
9-20 Intervenors have withdrawn Contention 9(e)' and ,
=
i theraf ore no response is required. [
Interrogatory l I
9-21 Ibes the term, "grotective actions," as used in l Ccntenticm 9(e), have the same meaning as in Cmtenticm 9(c)? If ;
not, set forth the definition of " protective actions" as used in L Ccntenticn 9(e).
Response
Intervenors have withdrawn Contention 9(e) and therefore no j response is requi red . l v
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Interrogatory [
9-22 'Ihere is no Interrogatory 9-22.
l Interrogatory 9-23 List the Cm types Mch 15tDC centends the Applicants' ,
emergency plans must take into acrount.
Response
9-23 All CDA types must be taken into account in !
Applicants' emergency plans. f
?
I Interrogatory 9-24(a) List ard describe with partia11arity the protective, t evacuation, and monitoring measures which NRDC centends must be j taken into account by the Applicants. Provide the basis fm 16tDC's t
answer, referring to specific Inc regulations, regulatory guidarce ;
materials, pericdicals, ard books. ;
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(b) Provide the specific basis for BRDC's contenticn that I "special measures" are neessary to cope with a CDA, as ccamparsi to other radiological ircidents dtich CIBR may experience. ,
Response t 9-24 See Response to Interrogatory 31 of Applicants' Eighth !
l e
Set of Interrogatories to Intervenors filed April 14, 1983. j i
Interrogatory i I
9-25 What em=niasien regulaticms ard/or Staff regulatory .l guidan:e does NRDC assert require special ccnsideration of CDA's, j as opposal to other radiological incidents which CRBR may j experience? j Response f 9-25 See Response to Interrogatory 31 of Applicants' Eighth f s
Set of Interrogatories to Intervenors filed April 14, 1983. !
l Interrogatory 9-26 Provide the basis for NREC's assertion that occurrerce of !
CDA's at CIBR will necessitate " decreased respcnse time," as (
compared to the response time available following other i radiological incide1ts which CRBR may experiarce. (
Response
9-26 Intervenors draw this conclusion from the analysis provided in Appendix A of the SER.
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( Interrogatory !
i !
l 9-27 Define "special protective action levels," as that term )
is usal in Ccntention 9(f). j 1
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i i 9-27 Intervenors define this term as used in 10 CFR 50 Appendix E. l h
Interrogatory i I
9.-28 List ard describe with partio11arity the "special protective actions levels" . ach NRII: ccntends would be apptogriate for CRBR. If MtDC has not yet developed special protective acticn levels which it feels are appropriate for CRBR, does it interd to i
do so in the future? If so, provide the date that you expect to complete development of such acticn levels. ;
Response
9-28 See Response to Interrogatory 31 of Applicants' Eighth l Set of Interrogatories to Intervenors filed April 14, 1983. l Intervenors may develop PAGs. f i
1 Interrogatory [
9-29 Define "adecpate assurarce", as that term is used in '
Cententicn 9(g). .
r
Response
4 9-29 Contention 9(g) is a summary statement which tracks the language in the first f ull paragraph of 10 CFR 50 Appendix i l
E.II. The substantive issues raised are covered in Contention !
I' subparts 9(c) and (f).
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Interrogatory 9-30 Define "Iroposed emergency plans", as the term is used in !
Ccntenticn (g). !
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Response
9-30 Contention 9(g) is a summary statement which tracks the language in the first f ull paragraph of 10 CFR 50 Appendix E.II. The substantive issues raised are covered in Contention subparts 9(c) and (f ) .
Interrogatory 9-31(a) State with particularity each item of Applicants' emergency plans which NRDC castends fails to provide adegate assurarre that 10 C.F.R. 5 50.47(b) will be met.
(b) Fm each item identified in NRDC's answer to Interrogatory 9-31(a), identify the plaming stardards of 10 C.F.R. 50.47(b) that NR[X: contends the iten does not satisfy. ,
Response
9-31 Contention 9(g) is a summary statement which tracks the language in the first f ull paragraph of 10 CFR 50 Appendix E.II. The substantive issues raised are covered in Contention subparts 9(c) and (f).
Interrogatory 9-32 'Ihere is no Interrogatory 9-32.
Interrogatcry 9-33 List all relevant setiens ard s@ sections of the CER Safety Evaluation Repzt ("SER") whids NRDC cattends inadequately discusses emergency pparedness.
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Response
9-33 Intervenors have not yet completed their analysis of the SER, but will provide answars to these interrogatories when their analysis is complete.
Interrogatory 9-34 Per each secticn ani stbsecticn listel in NRDC's answer to Interrogatcry 9-33, state with particularity the reascns wly the Staffs discussion in these secticms an1 stbse:tions are ir* = te . Set forth the subject matters which NREC believes are inadequately disc 2ssel, or should be discussai in these sections an1 subsecticns.
Response
9-34 Intervenors have not yet completed their analysis of the SER, but will provide answers to these interrogatories when their analysis is complete.
ADMISSIONS A&rtission 9-1 The PSAR, Section 13.3, Energercy Plarning, contains a prelimimry decripticn of the following items:
a) Baergency response facilities - Technical Stpport .
Caster, operaticns Stppert ceter armi a cetralized Emergency Operations Facility - that will be utilized in stpport of an energency respasse at CRBRP. ,
b) 'Ihe emergercy organizaticn on shift ard the augmented emergency organisticn.
c) An energency classificaticm adseme that conforms to NUREG-0654.
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i d) The method by dtich Emergency Actias Imvels are used as t thresholds for determining the emergency classificatias.
! e) '1he means for providing protective measures for persons assite ani offsite.
l f) '1he capability of the Muscle Shoals Emergency Centrol
! Center for determining the actual a potential offsite j environmental conditions through its as====mt acticms.
] g) '1he coordination with offaite groups accanplished to j'
date, ard the arrangements that will be made with State and local aganizations.
i h) '1he althcrity ard respansibilities of the State of 2
Tennessee T!!NL as regards to planning fm evacuation f arrangements, traffic control ard steport from other State
- .,e e es.
Response
l i
! 9-1 a) Intervenors admit this statement, but do not admit I
! to the adequacy of the description.
i l b) Intervenors admit this statement, but do not admit
}
j to the adequacy of the description.
t j c) Intervenors can neither admit nor deny this t
l statement since we have not made the comparison with NUREG-0654 i
i at this time.
j d) Intervenors admit this statement, but do not admit 1
- to the adequacy of this description.
I j e) Intervenors admit this statement, but do not, admit l to the adequacy of this description.
j f) Intervenors admit this statement, but do not admit l
l to the adequacy of this description.
4 g) Intervenors admit this statement, but do not admit
- to the adequacy of this description.
h) Intervenors can neither admit nor deny this i statement since we are not f amiliar with the actual authority and l
} responsibilities of the State of Tennessee TER.
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! Admissicn 9-2 In Section 13.3 of the Prelimimry Safety Aralysis Report
("PER") for CER, the Applicants ccusait to the followings a) We TSC win meet the guidance criteria of. NUEG-0696 ard the requiranasts of 10 cfR 50, Appeniix E.
b) he site energency organizations will axpoent the shift operaticms crew in accordarce with NUEG-0654, Table B-1.
c) Providing an outline of the energercy duties ard respcmsibilities of the various plant supervisors in the final plan.
d) Initial dose projecticms ard notificaticms to offsite authorities can be accmplished within 15 udrutes.
e) TVA win rocczunend protective actions to the State ani local agencies ard win assist these agencies as necessary to implement protective acticms.
f) That specific e vcedures will be developed to ensure that accidssts are properly evaluated, rapid notificaticn made ard assessment and protective acticns performed.
g) Se Tennessee Radiological Baergency Plan will be included in the final plan as Appardix F.
Se prelisirary descripticms ard erunnitments concerning energercy Ireparedness in the CElf PSAR Section 13.3, ard set forth in Admissions 9-1 ard 9-2, provide adegaats assurarce that facilities, egaipment, gracedures, ensite energency ceganizaticm ard offsite s@ port groups will be available to respond to ard mitigate the consegaences of emergercy corditions at CERP, with the excepticn that provision for real-time meteorology ard dose projecticna must be clarified in the final plan.
Response
9-2 a) Intervenors deny this statement. Applicants' commitment is less inclusive.
i b) Intervenors admit this statement.
c) Intervenors admit this statement if final plan and ,
CRBRP-REP are synonymous. j d) Intervenors can neither admit nor deny this
)
l sta tement , since we cannot find any reference to such a
- commitment.
e) Intervenors admit this statement.
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i f) Intervenors can neither admit nor deny this j statement, since we cannot find any reference to such a j
- commitment.
9 l g) Intervenors admit this statement.
i I Unnumbered paragraph on p.12 - Intervenors can j neither admit nor deny this statement since it calls for a legal i
! conclusion .
Achissicn 9-3 'Ihe PSAP, Secticn 13.3, Emergency Plaming, specifies an EPZ of 10 miles with regard to protective measures for the ptblic,
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an1 an EPZ of 50 miles with regard to the ingesticn pathway.
l Response j
1 1
9-3 Intervenors admit this statement, t
Achissicn l
i 1 9-4 The PSAR, Section 13.3 contains a list of local civil, fire, law enforcement ard medical agencies /crganizaticms within the
. 5-county area that will mrticipate I in the firal plans for CRBRP.
l Response 4
l 9-4 Intervenors admit this statement if the staf f is 1
referring to Table 13.3-1.
Ashissicn
%5 The PSAR, Section 13.3 r=mits to incorporating the plan for the State of Tennessee ard the plan for that portion of the
} State of North Carolira within the 50-eile EPZ into Apperdix F of j the final plan.
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i Response ,
l l 9-5 Intervenors can neither admit nor deny this statement !
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{ as we cannot identify such a commitment. ;
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- Adnissicn l
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} M 'Ihe PSAR, Secticn 13.3 identifies TDR as the prircipal i offsite agency having the authority ard respcnsibility for j emergency plaming for the area arourd CRBN.
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! Response 9-6 Intervenors neither admit nor deny this statement, although we have no basis for believing otherwise.
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Admissicn l 9-7 Absent any Federal reg 2irements ard guidarce regarding the
! designation of size ard shape of EPZs for INFBR sites, the use of i current LMt guidame for establishing WZs for CRBR is a reasonable i conservative approad to the problem.
l Response i
j 9-7 Intervenors deny this statement which to our knowledge 1
has not been demonstrated anywhere.
1 l.
I Adnission i
9-8 The PSAR, Apperdix 13.3A contains a prelimirary descripticn of the following:
, a) An estimated time fcr evacuation of the 2-mile, 5-mile l ard 10-mile sectors of the area within 10 miles of the plant.
i b) The eva:uaticn time estimates that were obtained from j the Traf fic Management Division of the Tennessee DOP.
- c) 'Ihe transient ard resident populationin 16 directional sectcrs within 10 miles of the plant.
d) 'Ihe populaticn informaticn using current (1980) census
! &ta and projectal figures for the year 2020.
i e) The primary means fbe evacuation of the population; ard the possible use of buses for the Edgewoc3 S&ool. .
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! f) Se State ani local agencies that would be involved in the stpport of an evaoaation of the population.
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Response
2
! 9-8 Intervenors admit this statement, without admitting the accuracy or adequacy of such descriptions.
i I
Admissicm i M 2e PSAR, Appendix 13.3A ev=mits to the following:
a) Se time requirsi to ern all residents and transient perons in any evacuaticm sector will ocnform to the l requirunents of 10 CPR 50, Appeniix E.
b) We means of transportation for the population, including any problem associated with the eva::uation of Edgeuxxl School will be specifically addressai in the final Pl an.
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Response
1 9-9 a) Intervenors can neither admit nor deny this statement since it calls for a legal conclusion.
b) Intervenors admit this statement without admitting the adequacy of this discussion.
, Adnissicn 9-10 Se atove preliminary descripticms an! <rumitments
. concernirs emergenr.y propursiness in the CRBIP PER Section 13.3 ani set forth in Admissicms 9-8 ani M provide adeqttate assurance r
that the final plan will ocmtain evacuation time estimates that meet the reqLlirements of current Federal regulaticms, i
Response
9-10" Intervenors can neither admit nor deny this statement since it calls f or a legal conclusion.
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j A&issicn I
. 9-11 The PSAR, Secticn 13.3 Emergency Plaming, contains a
{ prelisimry description of the following:
l a) The emergency response facilities, eglignent,
- peccedures and persemel that would be utilizei in the respcnse
! to an energercy at CRBRP.
b) Other 'IVA plans ard emergency instructions (e.g., Spill Prevention Control arti Countermeasure Plan) that will be
- ocuplimented by the firal emergency plan.
l c) '1he ccntents of the apperdices to the final plan which j will describe the methods 'IVA will use to detect ard evaluate j the severity of an emergency situation, retify and activate j emergency ceganizaticns, evaluate potential offsite j ecmsequences, recommend protective actions ard mitigate the j ocnsegaences of the accident. !
! d) Protective measures to be employed (n-site and offsite. l e) A radiological analysis of the facility design j l; features, ard site layout ard locaticn with respect to i consideration of surrcurdings.
} f) The plume EPZ ard ingestion EPZ, ircluding the counties i and States involve 1.
g) The local, State ard Federal orpnizaticms that will be l participating in the final plan.
)
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4 Response 9-11 Intervenors admit this statement without admitting the l adequacy of these descriptions.
1 1 Adnission l 9-12 Section 2 of the PSAR grovides a descripticn of site
! characteristics (layout and location). ;
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j Response .
i
! 9-12 Intervenors admit this statement. l l
Akissicn i
l 9.-13 Secticns 4 thru 12 of the PSAR grovide a description of i the facility desip features.
i j Response
} 9-13 Intervenors admit this statement.
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i Adnissim 4
9-14 Section 13.3 of the PSAR mits to the following:
a) We plans fcr local and Stata agencies will be incorprated as Appendix F to the final plan.
b) Se plan will utilize the liaistns already established in developing the Browns Ferry, Segacyah, Watts Bar ard Bellefcnte Radiological Energency Plans with the States of Alahma and Tennessee.
c) '1VA will maintain liaison with the Tennessee Emergency Management Agency, particularly with respect to the availability of emergency services.
d) TVA will provide all necessary radiological training for local offsite apport grotps.
e) The emergency classificaticn system will be compatible with the system used by the State and local emergency organizaticms.
j
Response
9-14 Intervenors admit this statement.
Adnissicn 9-15 The above preliminary descripticns and rmmitments concerning energency preparedness in the CRBRP PSMt ard set forth in Achissicns 9-11 through 9-14 provide adeglate assurance that the final emergency plans (on-site ard offsite) will be compatible with facility desicys features and site layout and locaticn.
Response
9-15 Intervenors can neither admit nor deny this statement I
since it calls for a legal conclusion.
1 Admission 1 9-16 The PSAR, Secticn 13.3, Bnergency Plaming, contains a i
preliminary descripticn of the following:
a) Se indivi&aal ansite (ard desicpee) in charge of all activities.
b) We methods for notifying the site energency organizaticn and offsite agencies.
c) Se time recpired for rotificaticm of offsite agencies ard grning of the ptblic.
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d) The protective measures ard implementaticn methcds ;
employed fcr ansite perscns. ;
e) The responsibilities of State and local governments for the decision to implement protective measures for the public. l l
f
Response
1 9-16 Intervenors admit this statement without admitting the i
adequacy of such descriptions. )
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i Adaission 9-17 'Ihe PSAR, Section 13.3 commits to the following l a) Tm will raccamend protective acticns to Stata ard ;
] local agencies ard will assist these agerx:les in implananting l i potective actiais for the p211c. j b) '1VA will Irovide a prompt notification system for State I ard local cpverraents to alert the p@lic within a lO-mile area .
arourd the plant that grotective actions may be reg 2 ired.
c) 'Ihe initial dose projecticn and rotification of offsite i authcrities can be accomplished within 15 minutes.
d) 'Ihe time to mrn all residents ard transients in any i evacuation sector (within 10 miles of the plant) will ecnform !
to the regulrunets of 10 CFR 50, Apperdix E. [
Response l 9-17 a ) and b) Intervenors admit this statement without ;
i admitting the adequacy of such descriptions.
c) See Response to Request for Admis sion 9-2 (d ) .
- d) See Response to Request for Admission 9-9(a). ,
i t Adnissicm !
9.-18 TVA carrently utilizes a czabination of fined sirens, i sobile sires ard tone alert radios for the prompt rotification !
system for the 1Mle EPZ for Broms Ferry ard Segacyah Nuclear i
! Plants.
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- Response 9-18 Intervenors lack the requisite information to either admit or deny this sta tement.
i A&nission . l l
9-19 'Ihe preliminary descriptions ard ev==itments concoming l emergency preparadress in the CIBRP P!RR Section 13.3, as set forth in A&nissicms 9-16 ani 9-17, in part provide adeqttate assurance that the final plans will meet the requiremets of current Federal I regulations with regard to yrocedures by diich protective actions I i will be carried out, including authorizaticm, rotification, ard instruction grocedures for evacuations.
Response
[ 9-19 Intervenors can neither admit nor deny this statement since it calls for a legal conclusion.
Admission 9-20 '!he PSAll, Sction 13.3 (!!lmergency Plan) contains a descripticm of the radiological analysis of CRBRP performed using the Site Saitability Source Term (! ESP).
Response
9-20 Intervenors admit there is such an analysis, however, believe this analysis is in error. See our LWA-1 testimony.
l l Admissien I
9-21 Current Federal regulaticris related to preliminary l emergency plans do rot require special asargency measures, l ircluding ircreased protective, evacuation and monitoring measures, re&ced respcmse time ard special protective action levels.
Response
9-21 Intervenors can neither admit nor deny this statement si nce it calls for a legal conclusion.
_ _ _ _ _ _ _ _ =_=- _ = = . = . - _w=-..-: - . . - . - . . - , - . . . - - - _ . - - - . - .
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} 9-22 Se prelimirary plan ircludes a descripticn of the
- Geraral Emergency clasaification - events are in progress or have j occurred Wicit involve actual or imminent attastantial core failure j with potential fcr loss of ccntairment integrity.
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! Response l 9-22 Intervenors admit this statement without admitting the adequacy of the description.
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! A&issicn
) 9-23 We preliminary plan ircludes the methcx1 by *ich Emergency Action Levels (e.g., specific measured values or
- observable conditicms) will be usal as thresholds for determining
} the emergency classificaticns.
) Response i
I 9-23 Intervenors admit this statement without admitting the j
1 adequacy of the description.
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1 a A&ission 1
l 9-24 We prelimirary plan commits to providing firal plans i Whicit irclude proce&tres that provide the capability to cope with a j spectrim of accidents ranging from those of little consequence to i major core melt.
Response
]
9-24 Intervenors admit this statement without admitting the i
adequacy of the description.
I A&issicm
- 9-25 We PSAR, Secticm 13.3, Emergercy Plarning, centains a 1 prelimirary descripticm of the following
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{ a) A provisicn for final plans that will meet the j acceptarne criteria of NUIEG-0654.
i b) Gals arti objectives that are to be ensured by the j establishnest of a final plan (rote: see Secticm 13.3.1 of the i PSAR).
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c) Iecal, State ani Federal agercies that will be participating in the CIBle final plan.
d) Facilities, equipment, Irocedures, ard a site energency crganization that will be ussi to identify, respord to, assess j ani mitigate the consegmences of an accident at CRBIP.
1 i Response i
l 9-25 a)-b) Intervenors can neither admit nor deny this 1
statement since it calls f or a legal conclusion.
l l c) Intervenors admit this statement.
1 j d) Intervenors admit this statement without admitting 1
the adequacy of the items identified.
j Admissicn 9-26 'Ihe preliminary description ocncerning energency
- preparedness in CBBR PER Secticm 13.3, as set fcrth in Admission j 9-25, in part provides adeq2 ate assurarce that the proposai j emergency plans will meet the requiren.ents of 10 C.F.R. 50.47(b)
- Response ,
i j Intervenors can neither admit nor deny this statement since i
it calls for a legal conclusion.
i Respect 1 submitted, J
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$ UBa l' ra A. Finamore S Jacob Scherr atural Resources Defense j Council, Inc.
{ 1725 I Street, NW, #600
] Washington, D.C. 20006 j (202) 223-8210 i Dated: April 22, 1983
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