ML20003C141

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Fourth Set of Interrogatories & Requests to Produce Directed to Applicant.Concerns Contention 25 on Financial Qualifications of Applicant & Contention 22 on Emergency Planning.Certificate of Svc Encl.Related Correspondence
ML20003C141
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/17/1981
From: Ellis J
Citizens Association for Sound Energy
To:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20003C137 List:
References
NUDOCS 8102260699
Download: ML20003C141 (12)
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Cu to BEFORE THE ATOEC SAFFFY AMD LICENSIK, BOARD In the Matter of l

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and 50-4h6 GEEERATIEG CCEEPANY, ET AL. FOR AN l

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UNITS fl AND #2 (CPSES)

J CASE'S FONRTH SET OF IFFERROCATORIES TO APPLICAFFS AED REQUESTS TO PRODUCE CQtBS NOW CASE (Citizens Association for Sound Energy), hereianfter referred g

to as, CASE, Intervenor herein, and files this, its Fourth Set of Interrogatories to Applicants and Requests to Produce.

Pursuant to 10 CFR 2.7kOb and 2 7k1, please answer the following interroga-tories in the manner set forth herewith. Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent informa-tion known to Applicants, their officers, directors or employees as' well as any 1

pertinent inforsation known to their advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control i

e of Applicants, their officers, directors or employees as well as their advisors or counsel. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory; do not ecishine answers. Please identify.the person providing each answer or response.

These interrogatories and requests to produce shall be continuing in naturt-Thus, any time Applicants obtain information which renders any previous response 8102260(07%

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incorrect or indicates that a response was incorrect when made, Applicaats should supplement their previous response to the appropriate interrogatory Cr request to produce. Applicants abould also supplement their responses as necessary with respect to identification of each person expected to be called ct the hearing as an expert witness, the subject matter of his or her testimony, tad the substance of that testimony. The term " documents" shall ine' ude any writings, drawings, graphs, charts, pho'tographs, reports, studies, and other data ccompilations frcum which information can be obtained. We request that at s

o date or dates to be agreed upon by mutual consent, Applicants make available for inspection and copying all documents which CASE has specifically requested or subject to the requests set forth below. All interrogatories which do not request docuents should be answered pursuant to 10 CFR 2 7h0b(b).

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CASE'S IFFERROGATORIES AMD REQUESTS TO PRODUCE Contention 25 The requirements of the Atcaic Energy Act, as amended,10 CFR 50 57(a)(4) and 10 CFR 50, Appendix C, have not been met in that the Applicant is not financially qualified to operate the proposed facility.

Do the Applicants believe that they have don) everything necessary and required 1.

to demonstrate that they have met the requirements of the Atcucic Energy Act, as amended,10 CFR 50 57(a)(4) and 10 CFR 50, Appendix C7 2.

If the anever to Question 1 above is yes, answer the following questions:

(a) What specific documents have Applicants provided to the NRC to cosply with these regulations? (Provide a listing by: date of document; date document was sent to the NRC; name and title of NRC representative to whcun document was sent; name, title, and ccupany affiliation of Applicants' representative who sent document; title of document; general content.of document in terms of what it purports to show with regard to this contention.)

(b) Provide all documents listed in (a) above for inspection'and copying.

(c) Are the. documents lis,ted in (a) above all the documentation which Appli.

cants have providaithe NRC to demonstrate that they have met the require.

ments referenced in Question 1 above?

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Answer the following question for each of the Applicants listed below:

Does the Applicant have the ability to pay its obligations on a timely basis, to pay a reasonable return to its investors, to borrow money at a reasonable rate, to maintain a good credit rating, and to maintain flexibility within its dealings in the financial community and 'in obtain-ing capital?

(a) Dallas Power & Light Company (DP&L)

(b) Texas Electric Service Company (TESCO)

(c) Texas Power & Light Ccupany (TP&L)

(d) Brazos Electric Power Cooperative, Inc. (BEPC)

(e) Texas Municipal Power Agency ('IMPA)

(f) TEX-LA Electric Cooperative of Texas, Inc. (TEX-LA) 4.

If the answer to any of the, above is no, explain specifically in what regard it is not so, for each Applicant to which this is applicable.

5 If the answer to any or all of (a through f) of Question 3 above is yes, for each Applicant listed, answer the following question: Has the Applicant supplied documentation (as set forth in your answer to 2(a) preceding) to prove your answer to question 3 preceding?

6.

If the sansv' ay part of question 5 above is no, explain specifically and in dett..

etly how the Applicant (s) in question have failed to provide such documentation.

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7 If the answer to any part of question 5 above is no, is it the Applicant (s) position that it is not necessary for said Applicant (s) to provide this documentation?

8.

If the answer to nny part of question 7 above'iis yes, explain exactly what the Applicants ba11 eve they are required to do to demonstrate that they are financially qualified to operate CPSES. Include in your answer specifically what you believe the requirements for each Applicant are, as well as what ycu believe the requirements are for the Applicants as a whole.

9 Have you prepared any report, study or other documents (as defined on page 2 of this pleading) with respect to this contention?

10. If the answer to question 9 above is yes, identify each sr.ch document (if not identified in your answer to question 2(a) preceding) by subject and.

author, including the author's professional and educational background.

11. If the answer to question 9 preceding is yes, provide for copying and inspection each such report, study or document referenced in your answer to question 10 above.
  • i COFFINTION 22:

Applicants have failed to emply with 10 CFR Part 50, Appen&Lx E, regarding emergency planning, for the following. reasonst.

1 The FSAR does not identify state or regional authorities responsible a.

for energency planning or who have special qualifications for dealing with emergencies.

b.

No agreements have been reached with local and state officials and agencies for.the early warning and evacuation of the public, including the identi-fication of the principal officials by titles and agencies.

There is no description of the arrangements for services'o'r physicians c.

and other medical personnel qualified to haindle radiation emergencies and arrangements for the t2 ansportation of injured or contaminated individuals beyond the site boundary.

d.

There are no adequate plans for testing by periodic drills of emergency plans and provisions for participation in the drills by persons.whose assistance an'ay be needed, other than employees of the Applicants.

There is no provision for medical facilities in the immediate vicinity e.

of the site, which includes Glen Rose; and f.

There is no provision for emergency planning for Glen Rose or the Dauas/Ft. Worth metroplex.

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12. State in your own words tne meaning of " emergency planning."
13. Is it the Applicants' position tha your Emergency Plan (as revised) fulfills all the requirements of 10 CFR Part 50, Appendix E7 1h. Specifically, is it the Ap].licants' position that your Emergency Plan (as revised October 8,1980) includes everything necessary to meet every criteria referenced in this conte 62 ion?
15. On page 16 of your Emergency Plan, Sect' ion h.2.4, Corporate Support, "The Texas Utilities corporate offices offer additional support for the Emergency Plan," would seem to indicate that Texas Utilities Conpany vill provide the additional support referenced. Please state with specificity exactly what j

part DP&L, TP&L, TE3CO, TUGCO, TUFCO, TUSI, or other Texas Utilities personnel vill have in providing this additional support.

16. On pages 17 and 18 of your Emergency Plan, under Section 4 31.1, Sheriff's Department, it is stated " Agreements have been reached with the Smervell County and Hood County Sheriff's Departments to support the CPSES Emergency Plan with a commitment of officers and vehicles to assist in evacuation efforts, traffic control, and security assistance.

"The Sheriff's office vill be used as the primary County hergency Operations Center (EOC) in their respective counties."

In Appendix H, page H-2 and H-3, the letters frm the Somerven County and Hood County Sheriffs' Departments only indicate that they vill " participate 4

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in the implementation of the Dnergency Plan... coordinate our activities with other law enforcement agencies and emergency personnel in trainin6 alerts and 7ther training requirements as needed" and " participate in the implementation of the CPSES Emergency Plan...ve vill coordinate our activities with other law enforcement agencies with Comanche Peak Station' personnel and we vill participate in trainin6 exercises as required," respectively.

Regarding the above, answer the following questions:

(a) Have the Sheriffs' Departments of each of the counties been apprised of the new infor:sation and requirements contained in NUREG-o654, Rev.1, November 1930, and other pertinent NRC/ FEMA documents which have been issued since they signed the letters of agreement in May 5,1977, and May 17,1977, respectively1 Answer for Sanervell and Hood Counties:

(1) Somervell County' Sheriff's Department (2)HoodCountySheriff'sDepartment (b) If the answer to (a) above is yes, what is there in the statements contained in their respective letters of agreement to indicate that they will do what Applicants' claim they will do in your Emergency Plan 4

on pages 17 and 18, as referenced in question 16 above?

(c) If the answer to (a) above is yes, where is the documentation that they have been apprised of such new information and that they agree to do what is stated by Applicants that they will do in your Emergency Plan on pages 17 and 18, as reference in question 16 above?

17. On page 18, Emergency Plan (EP), under Section k.313, Ambulance Service, it is stated " Written agreements with the Somervell County Ambulance Service and the Granbury Ambulance Service describe,their support in providing back-up assistance to the CPSES Emergency Vehicle to transport victims for medical assistsace."

(a) Is the Sonervell County A:nbulance Service one and the same as the Glen l

Rose /Semervell County Volunteer Fire, Rescue, and Ambulance Service?

(b) If the answer to (a) above is no, where is the documentation of the statement made on page 18 of the EP7 l

(c) If the answer to (a) above is yes, has the City of Glen Rose been apprised of the new information and requirements contained in NUREG.

l 0654, Rey,1, November 1980, and_ other pertinent NRC/FINA documents which have been issued since the letter fran the City of Glen Rose contained in Appendix H vas signed on January 30, 19797-(d) Is the Granbury Ambulance Service one and the same as Hood General Hospital Ambulance Service?

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(e) If the answer to (d) above is no, where is the documentation of the state-i ment made on page 18 of the EPT (f) If the answer to (d) above is yes, has the Hood General Hospital Ambulance Service been apprised of the new inferination and requirements contained in NUREG-0654, Rev.1, November 1980, and other pertinent NRC/FDIA docu-ments which have been issued since the letter in Appendix H, from B. C.

Hm=Hton, Administrator of Hood General Hospital in Granbury, was signed on May 12,19777 (g) If the answers to (a) and/or(d) precedin6 is no, provide copies of the documentation referenced in (b) and (e) preceding.

(h) If the answers to (c) and (f) are yes, where is the documentation that the City of Glen Rose and the Hood General Hospital Ambulance Service have been apprised o/ t'he information referenced in (c) and (f), that they fully understand the part their respective organizations are expected to fulfill in the event of an emergency situation at' CPSES, ad that they I

agree to fulfill such requirements?

l (1) Provide copies of letters of agreement with the City of Glen Rose and the Hood General Hospital Ambulance Service which contain the informa-tionreferencesin(h) preceding.

18. On page 18, EP, 4 31.4, Medical Support, it is stated " Accident victime j

at CPSES who require medical attention are transported to either the Hood General Hospital in Granbury, Texas, or the Marks English Hospital in Glen Rose, Texas...An agreement has been made with Hood General Hospital to receive accident victims from CPSES who could be contaminated with radin=

active material."

i On page 64, EP, 6.6.4, MEDICAL TREA7NENT,1 it is stated "...two local hospitals are available for accepting accident victims from CPSES... Hood General Hospital will serve as the lockl support hospital for contaminated l

victims, providing gross decontamination, life saving activities, and patient stabilization."

Regarding the preceding, answer the following questions:

(a) Where is the letter of agreement from Marks English' Hospital in Glen Rose to document these statements?

(b)Provideacopyoftheletterofagreementreferencedin(a)above.

(c) Has Hood General Hospital been apprised of the new information and requirements contained in NUREG-065k, Rev.1, November 1980, and other pertinent NRC/ FEMA documents which have been issued since the Administra-tor signed the letter of agreement on May 12, 1977, in which it was stated "This letter is to advise you that the Hood General Hospital Ambulance Service vill. participate in the implementation of the Energency Plan 6-

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for the Comanche Peak Steam Electric Station. We vill respond to emergency calls at the station and we vill participate in training exer-cises as required."? (Emphasis added.)

(d) Are Applicants relying in whole or in part on the May 12,1977, letter frca Hood General Hospital in Granbury, referenced in (c) preceding, as documentation of the statements made on pages 18 and. 64 of the EP7 (e) Are Applicants relying in whole or in part on the letter marked " Received Nov. 2,1977, R. J. Gary" which states "This letter is to inform you that the Hood General Hospital vill support the emergency planning efforts for the Comanche Peak Steam El.ectric Station...We vill receive-and ad-minister to all accident victims, including those individuals that could be contaminated with radioactive material er suffer from radiation over-exposure. We vill provide these emergency services and participate in cooperative training sessions and emergency drills as necessary to satisfy the Emergency Plan requirements."'...as documentation of the statements made on pages 18 and 6k.of the EP7 (f) If the answer to (e) abcVe is yes, answer the following questions:

(1) Why was this letter undated?

(2) Why was this letter not written on, Hood General Hospital letterhead,

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as was the May 12, 1977, letter?

(3) Who signed the letter 7 (The signature on CASE's copy was not legible.)

(4) What is the position of authority with Hood General Hospital of the person who signed the letter?

(5) Does the person who signed the letter have the authority to speak on behalf of the Hospital and to enter into an agreement which vill be binding on future Hospital Administrators and employees?

(6) tihy vaan't the name and title or the person who signed the letter l

typewritten below the sitnature, as it was on the May 12,15rr7, letter?

(7) Why vasn't the letter typed on the same typewriter as the May 12, 1977, letter?

(8) Why didn't the Administrator of Hood General Hospital provide a dated, properly typed, letter on Hospital letterhead stationary?

(9) Considering the above (1) through (8), do Applicants consider this letter to be documentation?

(g) If the answer to (c) preceding is yes, where is the documentation that the Hood General Hospital has been apprised of the information referenced in (c) and pages 18 and 64 of the EP, that they fully understand the part the Hospital is expected to fulfill in the event of an emergency situation at CPSES, that they are qualified, to handle such emergency situations, and that they agree to fulfill such requirements?

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m-(h). Provide a copy of the letter of agreement with Hood General Hospital which contains the information referenced in (g) preceding.

19. In the letter of agreement with Radiation Management Corporation, in Appendix H, Section 9 0 of the EP, it is stated: "With regard to Comanche Peak, the IMAP (Emergency Medical Assistance Program) contains the following provisions:
1. Semi-anmm1 review of plant and hospital procedures, equipment and supplies; one of these audits vill be in conjunetion with (6.) below.. 6. Annual train-ing for the plant, ambulance and hospital personnel who may be directly or indirectly involved in the execution of the radiation medical emergency pro-gram; 7. Preparation of an ' accident' scenario for use as a training aid in a radiation medical emergency drill; 8. Coordination of a radiation medical emergency drill based on the scenaiio; umpired, video-taped and critiqued by RMC; 9. Submission of two Drill Evaluation Reports; one relating to the l

observations made at the station, and another relating to observations made at the hospital; and 10. 'Pa'rticipation in an annual one-day seminar in Philadelphia on the management of radiation accidents for physicians. Each-plant site may send one person, and each utility ccanpany may send one person."

Regarding the above, provide the following infonnation:

(a) Has Radiation Management Corporation been apprised of the new informa-tion and requirements contained in NURm-o654, Rev.1, November 1980,

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and other pertinent NRC/ FEMA documents which have been issued since RMC's letter of agreement dated 16 December 19777

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(b) If the answer to (a) above is yes, where is the documentation that RMC has been apprised of the information referenced in (a) above, that they fully understand the infonnation, that they fully understand the part they and the personnel they will be training regarding.CPSES are expected to fulfill in the event of,an emergency situation at CPSES, that they have incorporated ths information referenced in (a) above into their training program, and that they agree to fulfill such re-quirements now and in the future?

(c) Provide a copy of the letter of agreement with RMC which contains the information referen ed in (b) above.

(d) Regarding item 1 in RMC's letter of agreement:

j (1). Has any semi-annual review of plant and hospital procedures, equip-ment and supplies been done yet?

(2) If the answer to (1) above is yes, provide a listing -of all such reviews and/or audits showing the following; dr.te of review or audit; general summary of scope of review or audii;; results of review or audit.

s (3) Provide for review and copying all reviews and/or audits referenced in your answer to (2) above.

(4) Are the reviews and/or audits listed in your answer to (2) preceding each and every such review and/or audit which has been done to date?

(e) Regarding item 6 in RMC's letter of agreenent:

(1) Has any of the annual training referenced been done yet?

(2) If the answer to (1) above is yes, provide a list of ab such annual training which has been done showing the following: dates of each training program or activi'ty; general summary of scope of training or activity; organizations, governmental agencies or entities, hospitals, ambulance, plant, and other participanta which parti-cipated 1,n each t' raining program or activity; results of training program or activity.

(3) Provide for review and copying all documents (as defined on page 2 of this pleading) referenced or relating to your ansver to (2) above.

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(k) Are the training programs or activities listed in your answer to (2) preceding each and every such training program or activity which has been done to date?

(f) Regarding item 7 in BMC's letter of agreement:

(1) Has the " accident" scenario for use as a training aid in a radiation medical emergency drill been developed yet?

(2) If the answer to (1) above is y,es, snpply the basic details of such scenario.

(3) Provide for review and copying a copy of the scenario and all documents (as defined on page 2 of this pleading) referenced or relating to your answer to (2) above.

(g) Regerding item 8 in BMC's letter of agreement:

(1) Has the radiation medical emergency drill based on the scenario referenced in item 7 of RMC's letter of agreement been developed yet?

(2) If the answer to (1) above is yes, supply the basic details of such drill.

(3) Provide for review and copying a copy of the drill procedures and all documents (as defined on page 2 of this pleading) referenced or relating to your answer to (2) above.

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o (4) Has the referenced drill been conducted yet?

(5) If the answer to (A) above is yes, supply the basic details of such drill, or each such drill if more than one has been conducted, including the following: dates of each drill; general summary of scope of drill and general procedures covered; organizations, govern-mental agencies or entities, hospitals, ambulance, plant, and other participants which participated in each drill; results of drill (s).

(6) Specify which of the drills referenced in (5) above ver,e video-taped.

i (7) Specify which of the drills referenced in (5) above were critiqued by RMC.

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(8) Provide for review and copying a copy of each video-tape referenced in your answer td (6) above.

(9) Provide for review and copying a copy of each critique by RMC referenced inyouranswerto(6)above.

(10) If a transcript is available of any or all of the video,-tapes referenced in your answer to (6) above, provide copies of each such transcript for review and copying.

(b) Regarding item 9 in RMC's letter of agreement:

(1) Has RMC submitted any Drill Evaluation Reports relating to the t

observations made at the station?

(2) If the answer to (1) above is yes, provide for, review and copying i

a copy of each such Reports.

(3) If the anaver to (1) above is yes, supply the basie. details of l

each such Report, including the following: dates of each Report; l

general sununary of content of each Report.

(i) Regarding item 10 in RMC's letter of agreement:

l (1) Has any annual one-day seminar in Philadelphia on the management of radiation accidents for physicians been held yet?

l (2) If the answer to (1) above is yes, supply the baeic details of e' ch a

l such seminar, including the following: dates of each seminar; general l

sunmaary of scope of seminar and goals of seminar; organizations, i

governmental agencies or entities, hospitals, ambulance, plant, and other participants which participated in each seminar; results of l

each seminar

s (3) Provide for review and copyin6 all band-out materials, planning guides, training materials, and all other documents (as defined on page 2 of this pleading) used in each seminar and/or referenced in your answer to (2) above.

Respectfully submitted,

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c(Mrs.) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)

Ik26 S. Polk Dallas, Texas 75224 21k/9k6-94k6 21k/9hl-12n, work,part-time,usually Tuesdays and Fridays 2/17/81 9

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  • i, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
  • _BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 1-I APPLICATION OF TEXAS UTILITIES 1

Docket Nos. 50-445 GENERATING COMPANY, ET AL, FOR AN 1 and 50-4,46 OPERATING LICENSE FOR COMANCHE I

PEAK STEAM ELECTRIC STATION 1

UNITS #1 AND #2 (CPSES)

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CERTIFICATE OF SERVICE By my signature belov, I hereby certify that a true and correct ecpy of CASE'S FOURTH SET OF INTERROGATORIES TO APPLICANTS AND REQUESTS TO nt0 DUCE has been sent this 17th day of February,1981,'to the following by First Class Mail:

  • = with Certificate of Mailing Receipt
  • Valentine B. Deale, Nsq., Chainnan David J. Preister, Esq.

Atomic Safety and Licensing Board Assistant' Attorney General 1001 Connecticut Avenue, N. W.

Environmental Protection Division-Washington, D. C.

20036 P. O. Box 12548, Capitol Station Austin, Texas 78711

  • Dr. Forrest J. Remick, Member

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Atomic Safety and Licensing Board Mr. Richard Fouke

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'305 E. Hamilton Avenue 1668-B Carter Drive State College, PA 16801 Arlington, TX 76010 Dr. Richard Cole, Member Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Washington, D. C.,

20555

+ Nicholas S. Reynolds, Esq.

At$micSafetyandLicensing l

Debevoise & Liberman Appeal Panel l

1200 - 17th St., N. W.

U. S. Nuclear Regulatory Commission Washington, D. C.

20036 Washington, D. C.

20555

  • Marjorie Rothschild l

Counsel for NRC Staff Docketing and Service Section U. S. Nuclear Regulatory Commission Office of the Secretary i

U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Washington, D. C 20555 9

Mr. Geoffrey M. Gay Arch D. McColl, III, Esq.

West Texas Legal Services 100 Main Street (Lawyers Bldg.)

701 Cannerce Street, Suite 302 Fort Worth, TX 76102 Dallas, n 75202 Jeffery L. Hart, Esq.

h021 Prescott Avenue

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l Dallas, n 75219 s.) Juanita Ellis, President ASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)

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