ML19260D803

Interrogatories Directed to State of PA Re State Disaster Operations Plan,Pa Emergency Mgt Agency & Lancaster,York, Cumberland,Dauphin & Lebanon Counties Emergency Response Plans

ML19260D803
Person / Time
Site:	Three Mile Island
Issue date:	01/19/1980
From:	Bowers J ANTI-NUCLEAR GROUP REPRESENTING YORK
To:	PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML19260D804	List: ML19260D803 ML19260D810 ML19260D818
References
RTR-NUREG-0396, RTR-NUREG-0560, RTR-NUREG-0600, RTR-NUREG-396, RTR-NUREG-560, RTR-NUREG-600, RTR-WASH-1400 NUDOCS 8002120400
Download: ML19260D803 (4)

Text

' -

. /- ,. ,

m.,7c0RRes=mm

// cocKETED g UNITED STATES OF AMERICA US@G NUCLEAR REGULATORY COMMISSION M j$2 3 MN Office 0W.S g g ting &SmDS BETORE THE ATOMIC SAFETY AND LICENSING BOARD B nch 8

% y e

In the Matter of )

) Docket No. 50-289 METROPOLITAN EDISON COMPANY ) . (Restart)

)

(Three Mile Island ,

Nuclear Station, Unit One) )

)

INTERROCATORIES OF INTERVENOR ANGRY

~

T0 COMMONWEALTH OF PENNSYLVANIA )}hk }k7 Intervenor Anti-Nuclear Group Representing York (ANGRY) hereby piapeunds pursuant to 10 C.F.R. g2.740h' . the following interrggatories to the Commonwealth of Pennsylvania.

These interrogatories are deemed to be continuing, and shall be supplemented pursuant to 10 C.F.R. 2.740(e) .

1. State whether or not Annex E of the Pennsylvania Disaster Operations Plan (DOP) has been submitted to the Nuclear Regulatory Commission for the purpose of receiving the latter's " concurrence" therein.

a. If not, when is such submission contemplated to occur?

b. If it has, was Appendix 8 thereof,' the Bureau of Radiation Protection (BORP)

Plan for Nuclear Power Generating Incidents, also submitted at the same

• time and for the same purpose?

'o, If it has, were the EmergencyResponse Plans of Lancaster, York, Cumberland, Dauphin, and Lebanon Counties also submitted ac the same time and for the same purpose?

d. On what date did these submissions occur?

e. Has such concurrence been granted or denied with respect to any of the aforement tiened plans? Attach copies of all correspondence, memoranda or other docu=entation received or issued by the Commonwealth relating to compliance or non-compliance of any of the afore=entioned plans with NRC concurrence standards and criteri.

2 According to DOP Section IX(A)(2)(c) the Pennsylvania Emergency Management Agency (PEMA) ha.s the responsibility to " review and ' approve county RERP" (Radiological Emergency Response Plans),

a. Specify in detail the standards and criteria that EEMA employs in such review and approval procedure, b, Has such approval been granted or denied with respect to the "EERP"of Dauph-Attach ifi, York, Lancaster, Cumberland, or Lebanon Countics? If so, when?

copics of all correspondence, memoranda or other docu=entation r.cceived or issued by the Cocmonwealth relating to compliance or non-compliance of

.. h 800 2120 'fCO

a

,r, any of the aforementioned plans with PEMA approval standards and criteria,

3. DOP Section VIII(G) states that the Governor " retains directional authority" over decidion-making in the ' event of an "e=ergency nuclear encident." Yet the Governor is totally abstmt f acm the notification sequence set forth in DOP Appendix 3. Does Appenaix 3 accurately reflect the role of the Governor in nuclear emergency decision-making? If not, please describe his place in the Appendix 3 notification sequence as precisely as possible.

4 What aget he factual and analytical bas 6s for the " assumption" that "the 10-m11e evacuation distance includes an adequate safety margin which precludes the need for evacuation of institutions, facilities, or people beyond the'.10-m11e radius"? (DOP gIV(F))

5 Nhat are the factual and analytical bases for the ' assumption" that

" adequate lead time will be available to implemenc the provisions of this plan"? (DOP gIV(E))

'a. ht is the minimum " lead time" that the , Commonwealth considers to be

" adequate" for DOP implementation?

b. How was the answer to interrogatory #5(A) derived?

1954 148 6 Identify the emergency response capability of the 5 " risk counties" in terms of radial distance from the TMI site at the time of the March 28, 1979, accident. ,

~

a. To what distance were such counties instructed to extend such capability in the period during and i= mediately following the accident?

b. What was the basis for the distance defining such d:ttended capabi&ity that was chosen?

c. R111 counties which have developed emergency response capabilities to a distance which exceeds that specified in DOP gIV(F) be required to main-tain such capability?

d. ht is the reason for the answer to interrogatory 16(_cl?

7. Does the Commonwealth have plans to obtain, stockpile, and develop distribution:-

methods f6r a tE/roid blocking agent such as potassium iodide?

a. If yes, by what date will these steps be completedi

b. If no,' give reason.

c. Is the availability of such a thyroid blocking agent in sufficient quint 1 ties necessary to effective emergency eesponse capability?

d, he is the reason for the answer to interrogatory #7(c)?

8 The York County RERP states at p. IV-2 that 50 - 2 passenger ambulances will be supplied by " State C.D." to assist in evacuation of nursing homes,

a. Identify the Commonwealth agency that agreed t'o provide such service and attach a copy of letter, if any, confirming such agreement,

b. h t arrangements are in effect for providing drivers for such vehicles in the case of a nuclear accident?

• I i

9. The York County RERP reflects at p. VII-1 the selection of two time frames, five and twenty-four hours in duration, upon which to base its emergency planning. Identify the assumptions and bases underlying the selection of these two time frames.

' .S . a. ht is the basis for the conclusion that "we do not believe that the five-hour plan could be accomplished if schools were in session."

b. We contingency plan (s) exist far use in the event of a nuclear accident that occurs while schools are 1~ 2ssion?

10 h t '** the factual and analytical _ bases..Iunderlyingtheassumptionthat "the majority of people within. the evacuation area vill elect to stay with friends and relatives within or outside York County"? (York Co. RERP, p. 2)

a. h t would be the impact upon the plan's effectiveness if either more or fewer people behaved as stated in this assumption?

11. h t is tha time required for the evacuation of each of the seven " hospitals located within a 10 mile raaius of TMI" as listed in Table 3 of the Licensee's Emergency Plan. Explain fully the reasons for the time given in each case.

12 ht is the basis for belief in the effectiveness of the principal method of warning employed by the County RERP's, Civil Defense sirens?

a. ht measures have been taken to insure that persons who are so warned have the kno'iledge necessary to enable them to receive further instructions?

b. h e is the time required for such notification procedures to be completed?

c. Describe the special procedures, if any, that have been adopted for the notification of Old Order Amish, h e is the time required fcr such special procedures to be carried out? ,

13. Explain how the decision will be made whether to order sheltering or evacuation during an atmospheric release of radioactive materials. Factors such as

" time to release" or " time required for relocation" should be quantified, if Possible, 14 h t does the Commonwealth understand the terms " precautionary" niid " selective" cyacuation,Wetpactively, to mean? h t factors, quantified if possible, would lead to the choice of each as an appropriate protective action?

15. State whether or not an Atmospheric Release Advisory Capability SystM (ARAC) was placed in operation at Three Mile Island.during the accident,

a. h made the decision to install this system and what was the basis for such decision?

b. he are the advantages of ARAC over conventional methods of' dose assessment and projection? ,

c. ht is the opinion of the Commonwealth as to how the absence of thq information-analysis capability provided by ARAC affects the Licensee's ability to provide prompt and accurate dose assessment infoPation to off-site authorities?

16 How much time would be necessary to evacuate all persons within a 10-mile radius of 'ntI. Include the estimated time for notification, for preparation, and for actual transit time.

1954 149

s  %.

a. Identify all assumptions used in arriving at such estimates, such as road capacitics and traffic volume over given egress routes,

b. How woul' such estimates be affected by each of the following conditions:

(L) Incienent weather. (3) Traffic accidents.

(2) Rush-hour traffic congestion'.

17 What action has the Commonwealth taken, if any, to comply with the following 0

recommendatinn of the Presiddnt's Commission 0 the Accident at Three Mile Islandt Planning should involve the identification of several different kinds of accidents with different possible radiation consequences..For each scenario, there should be clearly identified criteria for the appropriate responses at various distances... response plans should be keyed to various possible scenarios. . . (pp. 76, 77) .

18 Identify all documents and studies relied upon by the Commonwealth in answering the foregoing interrogatories.

, Respectfully submitted,'

Anti-Nuclear Group Representing York By: ~Johd Bowers 245 W. Philadelphia St.

York, PA 17404 DATE: January 19, 1980 ,

~  !

s.

m O

1954 150

_