ML20111C602

Interrogatories to Bob Neiner Farms,Inc Re Contention 3 Concerning Plant Emergency Plans.Certificate of Svc Encl. Related Correspondence

ML20111C602
Person / Time
Site:	Braidwood
Issue date:	03/12/1985
From:	Copeland V COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	NEINER, B. (BOB NEINER FARMS, INC.)
Shared Package
ML20111C599	List: ML20111C594 ML20111C602
References
OL, NUDOCS 8503150475
Download: ML20111C602 (9)

Text

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3/12/85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC' SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Nuclear Power )

Station, Units 1 and 2) )

INTERROGATORIES TO INTERVENOR BOB NEINER FARMS, INC., ET AL. - SET II i Applicant, Commonwealth Edison Company, hereby serves upon Intervenor Bob Neiner Farms, Inc., et al. this second set of

! written interrogatories pursuant to 10 C.F.R. S 2.740b. Each interrogatory should be answered separately and fully in writing, under oath or affirmation, within 14 days after service.

NEINER FARMS CONTENTION 3 i 1. Identify the source (s) (documents and/or persons) of Intervenor's knowledge of the emergency plans for l

Braidwood Station.

2. Inasmuch as the emergency plans for the Braidwood l l

Station are not yet available, identify the emergency plans which Intervenor contends are inadequate. l 1

8503150475 850312 PDR 0 ADOCK 05000456 PDR

3. Define the nature and extent of a " radiological emer-gency" as contemplated by Intervenors in the preamble of Neiner Farms Contention 3.

. '4. ' Identify the document (s) which and/or the person (s) whose opinion provide the basis for the Intervenor's contention that the emergency plans for the Braidwood Station are inadequate.

5. State with particularity the bases for Intervenor's contention that the emergency plans are inadequate.

6. State with particularity the bases for Intervenor's contention that the emergency plans should include the six items specified in Neiner ' Farms Contention 3.

i subparagraphs "a" through "f".

7. Inasmuch as the emergency plans for the Braidwood Station are not available,' state the bases for Inter-venor's inference that the six items specified in l

Neiner Farms Contention 3 subparagraphs "a" through "f" l are not or will not be included in the emergency plans for Braidwood Station, i .

8. State whether the distribution of brochures which inform the public of radiological emergency procedures- 1 2 -

I would satisfy Intervenor's concerns expressed in Neiner Farm Contention 3, subparagraph "a". If not, define the program can'templated by Intervenors for informing and educating the public of radiological emergency procedures.

9. State with particularity the elements of the "public" contemplated by Intervenors in Neiner Farm Contention 3, subparagraph "a".

10. Define the nature and extent of a " radiological emer-gency" as contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "a".

11. Identify the " response [the public] should take" contemplated by the Intervenors in Neiner Farms Con-tention 3, subparagraph "a".

12. Identify the "means for obtaining instructions" contem-plated by Intervenors in Neiner Farms Contention 3, subparagraph "a".

13. State whether the use of sirens and television and radio announcements to notify residents and persons using recreational facilities within 10 miles of Braidwood Station of a radiological emergency would t

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1 satisfy Intervenor's concerns expressed in Neiner Farms i Contention' 3, subparagraph "b". If not, define the

" specific plan" contemplated by the Intervenors for such notification.

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14. Define the elements of notification as contemplated by Intervenors in Neiner Farms Contention 3, subparagraph nga, i

55. Identify the specific recreational facilities contem-plated by Intervenors in Neiner Farms Contention 3, 4

subparagraph "b".

16. State with particularity.the elements of the "public" contemplated by Intervenors in Neiner Farm Contention 1 3, subparagraph "b".

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17. Define the elements of an " assurance . - . . that insti-tutions can be evacuated or adequately protected in a radiological emergency".as contemplated by Intervenors "c".

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in Neiner Farms Contention 3, subparagraph

18. Identify the specific hospitals and nursing homes li contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "c".

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19. Identify wi 1 specificity all other - institutions, if 1

.' any, contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "c".

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20. Define the nature and extent of. a " radiological emer-4 gency" as contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "c".

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21. Define the nature and extent of a." nuclear emergency" l as conterhplated by Intervenors in Neiner Farms Conten-tion 3, subparagraph "d".

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22. State with particularity the amount and type of ra-

! diation exposure contemplated by Intervenors in Neiner l Farms Contention 3, subparagraph "d".

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23. State with particularity the types of injury contemplated by Intervenors resulting from a " nuclear accident" in Neiner Farms Contention 3, subparagraph "d".

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24. State with particularity the type (s) of medical treat-ment contemplated by Intervenors in Nelner Farms Contention 3, subparagraph "d".

25. Identify the bases (documents and/or persons) for-Intervenor's belief that as a result of.a radiological l

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accident members of the general public would be exposed to the levels of radiation indicated in answer to question 22.

26. Define the elements of an " assurance that these facil-ities are capable of handling the treatment" as contem-plated by the Intervenors in Neiner Farms Contention 3, subparagraph "d".

27. Define the nature and extent of "an accident" as contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "e".

28. Define the type and amount of radiation exposure contemplated by Intervenors in Neiner Farms Contention 3, subparagraph "e".

29. Define the nature and extent of " radiation casualties" as contemplated by Intervenors in Neiner Farms Conten-J tion 3, subparagraph "e".

j i 30. State with particularity the persons who . comprise

" operating personnel as contemplated by Intervenors 1 in Neiner Farms Contention 3, subparagraph "e".

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31. Define the elements of a " suitable plan" as contem-plated by Intervenors in Neiner Farms contention 3, subparagraph "e".

32. Identify the "public and private organizations" contem-plated by Intervenors in Neiner Farms Contention 3, subparagraph "f".

33. Identify by name, title or position, and address all persons Intervenor intends to present as witnesses to testify with regard to Neiner Farms Contention 3.

Submitted by:

LYd1 h One Of The Attorneys For Applicant COMMONWEALTH EDISON COMPANY Joseph Gallo, Esq.

Victor G. Copeland, Esq.

ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Suite 840 Washington, DC 20036 Rebecca J. Lauer, Esq.

ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 ~

Chicago, Illinois 60602 (312) 558-7500

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Nuclear Power Station )

Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of the Interrogatories To Intervenor Bob Neiner Farms, Inc., Et Al. - Set II and Interroga-tories To Intervenor Bridget Little Roram and Appleseed Alliance were served on the persons listed below by deposit in the United States mail, first-class postage prepaid, this 12th day of March, 1985.

Lawrence Brenner, Esq. Chairman C. Allen Bock, Esq.

1 Administrative Law Judge P.O. Box 342 Atomic Safety and Licensing Board Urbana, IL 61801 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. A. Dixon Callihan Atomic Safety and Administrative Law Judge Licensing Board Panel Union Carbide Corporation U.S. Nuclear Regulatory P.O. Box Y Commission Oak Ridge, TN 37820 Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and Administrative Law Judge Licensing Appeal Board Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Ms. Bridget Little Rorem 117 North Linden Street Essex, IL. 60935

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Myron Karman, Esquire Docketing and Service Section Elaine I. Chan, Esquire Office of the Secretary Office of General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Douglass W. Cassel, Jr., Esquire Lorraine Creek Timothy W. Wright, III, Esquire Route 1 ,

BPI '

Box 182 109 North

Dearborn Street Manteno,

Illinois 60950 Suite 1300 Chicago, Illinois 60602 Charles Jones, Director Illinois Emergency Services and Disaster Agency 110 East Adams Springfield, IL 62705 k '

Victor G. Copeland One of the Attorneys for Commonwealth Edison Company J

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