ML19296D174

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Second Set of Interrogatories Directed to Met Ed.Requests Info Re Licensee Emergency Plan,Proposed Ingestion Exposure Emergency Planning Zone & Class 9 Accidents.Certificate of Svc Encl
ML19296D174
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/31/1980
From: Sholly S
AFFILIATION NOT ASSIGNED
To:
METROPOLITAN EDISON CO.
Shared Package
ML19296D173 List:
References
NUDOCS 8002290440
Download: ML19296D174 (16)
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/a' BEFORE THE ATOMIC SAFFTY AND LICENSING BOARD -

In the Matter of )

)

METROPOLITAN EDISON COMPANY )

Docket No. 50-289

)

(Restart)

(Three Mi.le Island, Unit 1) )

INTERVENOR STEVEN C. SHOLLY SECOND SET OF INTERROGATORIES TO LICENSEE WITH DOCUMENT REQUESTS Steven C. Sholly, Intervenor, hereby files the followi.ng interrogatories and document requests with Li.censee pursuant to 10 FR 2.740 and 10 CFR 2.741. Interrogatories are to be answered fully, in writing, and under oath by any officers or employees of the Licensee who have personal knowledge thereof. The answer to each interrogatory should contai.n the name(s) and identificati.on of the person (s) supplying the answer.

Interrogatories and document requests are arranged according to the Contenti.on numbers as accepted by the Board.

Contention numbers appear f'rst, followed by the interrogatory or document request number withi.n the particular contenti.on.

For example,13-001 refers to the fi.rst i.nterrogatory or document request for Contenti.on #13.

Interrogatories and document requests are considered to be continuing and are to be supplemented as required by applicable parts of 10 CFR 2.

8002290

08-013--From among the persons who contributed to the Licensee's Emergency Plan, either by writing the plan or by providing supporting analyses or input, identify by name, title, position, and organization, those persons with expertise in the following areas:

(a) Demography (b) Land use planning and analysis (c) Analysis of transportation capabilities ,

including traffic volume analysis and the impact of adverse weather conditions on traf fic flow (d) Evacuation planning (e) Meteorology, especially diffusion characteristics For each person so identified, list degrees and where they were received, publications relevant to the area of expertise, and memberships in professional societies and certifications related to the area of expertise.

08-014--According to NUREG-0396 at page 18, major radiation releases from nuclear power plants can begin within as little as 30 minutes after the start of the initiating event. Specify how this fact is reconciled with the assumptions in county emergency plans on which Licensee relies to provide necessary protection of public health and safety in terms of the lead times which are required

by each such plan in order for protective actic to be implemented on a timely basis within the Plume Exposure EPZ. Dsicuss each county plan separately in responding to this interrogatory.

08-015--Provide a map of suitable scale which delineates clearly the Seographic extent of the Licensee's proposed Ingestion Exposure EPZ. This map must show all countics which fall within this EPA as well as the locations of towns and cities within the EPZ as proposed by Licensee.

08-016--Provide copies of the most recent letters of agreement and understanding with all county and state governments which fall within the proposed Ingestion Exposure EPZ.

For each instance where no such letter exists, explain the reason and provide documents which show evidence of contact between Licensee and the government agencies with regards to the Ingestion Exposure EPZ. Where neitbar a letter of agreement or understanding or documents which show evidence of such contact exist, explain why and provide a schedule for making such contacts and obtaining letters of agreement and understanding with regard to emergency planning within the Ingestion Exposure EPZ.

08-017--NUREG-0396 at page 16 states that although the radius for an EPZ implies a circular area , the actual shape of an EPZ for a particular site is dependent on the characteristics of that site. In this light, provide the factual basis for the proposed circular EPZ's for both Plume and Ingestion Exposure Pathways ,

specifying how local conditions of demography, land use, access routes, topography, and local jurisdictional boundaries combine to result in circular EPZ's for Plume and Ingestion Exposure of 10 and 50 miles radius respectively. Provide documents which support the size and shape of the proposed EPZ's.

08-018--NUREG-0396 at page 17 states that all milk processing plants within the Ingestion Exposure EPZ should be included in emergency response plans regardless of their location. Provide documentation which confirms that Licensee has in fact contacted each such milk processing plant and that letters of agreement and understanding have been executed with each such milk processing plant. For each such milk processing plant, provide the address, name of the facility, and the name and title of the person at each such facility who has been contacted regarding emergenc-response planning.

08-019--NUREG-0396 at page I-4 concludes that discussion of a spectrum of accidents in Classes 1 through 8 is too limited in scope to be useful in emergency planning.

Identify each statement in Licensee's Emergency Plan wPich takes into account any accident beyond the design basis of TMI-1. Specify how Licensee's Emergency Plan takes into account accidents beyond the design basis for TMI-1, particularly with reference to assumptions utilized in determining the time available for identification of an accident, assessment of the seriousness of the accident, notification of off-site authorities, implementation of protective actions, and confirmation of the completion of the protect! ve actions.

08-020--NUREG-0396 at page I-6 states cnac Class 9 accidents cover a full spectrum of releases of radioactivit y which ranSe from those accidents which are on the same order as the DBA-LCCA type of release to those accidents which release significant fractions of the available radio-active materials in the reactor to the atmosphere. The lower ranco of the spectrum of Class 9 accidents is described to include accidents in which a core " melt-through" of the containment would occur. Given the fact that NUREG-0396 at page I-4 states that discussion of a spectrum of accidents in Classes 1 through 8 is too

limited in scope to be useful in emergency planning, produce documents which show how Class 9 accidents and their releases of radioactivity, including the core " melt-through" , have been taken into consideration in the preparation of the Licensee's Emergency Plan and the Emergency Plan Implementing Document. h'here such documents do not exist , discuss with specificity how Licensee's Emergency Plan has taken into account these accidents.

08-021--On page 2 6 of the Emergency Plan (Amendment 6, November 1979), it is stated:

"The engineering design of the TMI Nuclear Station ensures that the consequences of major malfunctions will be mitigated by the engineering safety systems."

If Licensee believes this to be s true statement ,

then Licensee is requested to explain how a Class 9 accident occurred at Unit 2 of the TMI Nuclear Station. If Licensee no longer believes this statement, indicate so and explain, in the light of the fact that, " Total emergency preparedness requires plans for the emergency response of both systems and people," (Emergency Plan, Amendment 6, November 1979, pages 2-5 and 2-6), how t ne fact that engineered safety systems cannot be relied upon to mitigate the consequences of major equipment

malfunctions impacts on the Emergency Plan and its ability to provide for the protection of the public health and safety in the event of an accident at the TMI Nuclear Station.

08-022--At page 4-2 of Licensee's Emergency Plan (amendment 6, November 1979) it is stated:

"The classification system is designed to permit raptd evaluation of plant conditions against emergency actLon levels so as to romptly recogntze and declare emergencies p(within 10 mi nutes of event) ."

In the light of the fact that over 2 hours elapsed between the start of the Unit 2 accident and the declaration of a Site Emergency, discuss with specificity how plant operating procedures and the Emergency Plan have been modified to ensure that emergencies will be declared within 10 minutes of the initiating event. Discuss also the training given to reactor operators and shift supervisors which assures that this 10-minute emergency declaratton commLtment will be met.

08-023--At page 2-7 of the Restart Report (Amendment 6, November 1979), it is stated that the State Plans and the TM1 Emergency Plan were developed in close coordtration.

Provide documentatLon which vertfies that this is true.

Provide names of State personnel and representatives who worked with Licensee in developing and coordinating

the State Plans and the TMI Emergency Plan.

08-024--Specify any and all assumptions upon which the TMI Emergency Plan is based. Discuss each such assumption and explatn why Lt is appropriate and what it's basis is in fact.

08-025--Provide time estimates, including upper and lower bounds, of the time required to perform each of the following major steps in an emergency responses

a. Recognttton of conditton which fulfills one of the emergency event classes;
b. Assessment of the seriousness of this condition
c. Initiation and completion of all required nottftcations
d. Implementation of necessary emergency response
e. Confirmation that emergency response (protective action) has been completed.

08-026--Provide a description of the means to be used by Licensee to notify the general public, including transients, of an emergency condttton at the TMI site. Include documents which depict the extstence of agreements with local media, Civil Defense, educational, and other groups which will be depended upon to provide the emergency notifications.

08-027--For each and every contractor who may be called upon to provide support services during an emergency at the TMI site (such services would include, but not be limited to, supplemental radiation monitoring and increased security), describe the nature and scope of the support services to be provided and the quali fications of each organization to provide such services.

08-028--For each and every government body on which Licensee's Emergency Plan depends for implementation of protective actions, provide details of the specific response capabilities of each such body, tacluding the expertise of available personnel, the time frame within which their assistance would be available, and other resources which each body would be expected to provide in the event of an emergency.

08-029--Provide documents which show what radiation exposure guidelines will be followed by medical, firefighting, and decontamination services personnel and how these guidelines will be implemented in the event of an emergency.

08-030--Provide documentation which shows that all outside agencies which are depended upon by Licensee for medical and firefighting services are aware of the guidelines addressed in Interrogatory 08-029 and that

these organizations are cognizant of these guidelines and understand their implications with regard to providing the required services.

08-031--Provide documentation which shows that hospital and medical personnel who are relied upon by Licensee to provide emergency services are qualified to accomodate radiological emergencies, especially injured persons who may also be radioactively contaminated.

08-032--For each agency or organization with which Licensee has a letter of agreement and understanding, provide documents which specify what assistance is to be rendered and list mutually acceptabic criteria for the implementation of these types of assistance.

08-033--Detail each responsibility of the Shift Supervisor under conditions of a Site nergency and a General Emergency. Describe, for each Shif t Supervisor, any and all training received which qualifies them to make judgments regarding protective actions (i.e.,

health physics training, medical degree with specialization in radiation protection, etc.).

16-001--Identify those portions of Licensee's Security Plan ,

which discuss how security forces will maintain positive control over access to Type I and Type II vital areas under conditions of Site Emergency and General Emergency.

16-002--Identify those portions of Licensee's Security Plan which discuss any and all special precautions which are being taken or will be taken at Unit 2 due to its increased vulnerability to sabotage as discussed in Pre- and Post-Accident Sacurity Status at Three Mile Island By Donald G. Rose, Los Alamos Scientific Laboratory, and Three Mile Island Saborare Analysis By Eddie R. Claiborne, Richard L. Cubitt , Roy A. Haarman, and John L. Rand, Los Alamos Scientific Laboratory, both of which are in the National Archives with documents authroed by the Kemeny Commission.

16-003--Identify those portions of Licensee's Security Plan which discuss how applicants for security force positions as guards or watchmen are investigated to determine their mental and physical fitness for such positions. Included in this Interrogatory are those investigations performed to determine the accuracy of statements made on job applications. This Interrogatory includes both employees of Licensee as well as security forces provided ay outside contractors, including Gregg Security.

16-004--Identify those portions of Licensee's Security Plan which discuss the specific qualifi. cations whi.ch guards and watchmen must meet, including those candidates for supervisory positions.

16-005--Identify any and all documents or portions of documents in any way related to security at Unit 1 or Unit 2 at TMI, or both, which are non-proprietary in nature and can be released publicly without violating NRC regulations.

16-006--Will Licensee maintain separate security forces for Unit 1 and Unit 2? If os, how will this separation be assured?

If not, why not?

Respectfully submitted, lv$ A:A? .N

  • Steven C. 7 Sholly d(r/

304 South Market eet Mechanicsburg, PA 17055 h--717 - 76 6 - 18 5 7 w--717-566-3237 3238 DATED: 5 February 1980

UNITED STATES OF AMERICA NUCLEAR PIGUL ATORY CO'@lISSION BEFORE THE ATOMIC SAFETY AND LTCENSING BOA RD In the Matter of )

Doc t 9 MEIROPOLITAN EDISON COMPANY es a (Three Mi.le Island, Uni.t 1) ) ,

CEP,TIFICATE OF SERVICE I hereby certi.fy that a single copy of INTERVENOR STEVEN C. SHOLLY SECOND SET OF IhTERROGATORIES TO LICENSEE WITH DOCUMENT REQUESTS was served upon the Licensee by hand deli.very to the Three Mile Island Observation Center, addressed to the attenti.on of Mr. John Wi.lson, on this 5th day of February 1980, for servi.ce to the other parties of thi.s proceedi.ng under the provisi.ons of Li.censee for such servi.co.

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ON) . 1 -P Steven C. Sholly p DATED: 5 February 1980

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[c NUCLEAR REGULATORY C0FSfISSION fj' 5EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor Steven C. Sholly Responses to Licensee's First Set of Interrogatories dated January 31, 1980 and Intervenor Steven C. Sholly Second Set of Interrogatories to Licensee with Document Requests dated February 5,1980, which were hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania, on February 5, 1980 were served upon those persons on the attached Service List by deposit in the United States nail, postage paid, this 6th day of February, 1980.

John F. Wilson

/

Dated: February 6, 1980

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

)

METROPOLITAN EDISON COMPAm' ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1)

SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsy' ania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan ' Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Guter Drive 407 North Front Street Oak Ridge, Tennessee 37330 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Comnission Attorney for icwberry Township Washington, D.C. 20555 T.M.I. Steering Committee 2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Conaission Widoff Reager Selkowit: & Adler P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105

  • Person on whose behalf service is being made. Only Certificate of Service is enclosed.

Ellyn Weiss, Esquire Robert Q. Pollard Sheldon, Harmon & Weiss Chesapeake Energy Alliance Suite 506 609 Montpelier Street 1725 Eye Street, N.W. Baltimore, Maryland 21218 Washington, D.C. 20006 Chauncey Kepford Steven C. Sholly

State College, Pennsylvania 16801 Holly S. Keck Legislation Chairman Marvin I. Lewis Anti-Nuclear Group Representing 6504 Bradford Terrace York Philadelphia, Pennsylvania 19149 245 West Philadelphia Street York, Pennsylvania 17404 lbrjorie M. Aamodt R.D. 5 Karen Sheldon, Esquire Coatesville, Pennsylvania 19320 Sheldon, Harmon & Weiss Suite 506 George F. Trowbridge, Esquire 1725 Eye Street, N.W. Shaw, Pittnan, Potts & Trowbridge Washington, D.C. 20006 1800 M Street, N.W.

, Washington, D.C. 20036

  • Person on whose behalf service is being made. Only Certificate of Service is enclosed.
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