ML19305C850

Commonwealth of PA Response to Second Set of Interrogatories.Includes Info Re Federal,State & Local Emergency Response Plans.Certificate of Svc Encl

ML19305C850
Person / Time
Site:	Three Mile Island
Issue date:	03/17/1980
From:	Carter K PENNSYLVANIA, COMMONWEALTH OF
To:	ANTI-NUCLEAR GROUP REPRESENTING YORK
References
NUDOCS 8004100539
Download: ML19305C850 (33)

Text

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UNrIED STKIES OF MERICA NUCEAR REUIATORY (II4ESSION BEFORE 'IHE ATCMIC SAFETY AfD LICaEI!U E0ARD In the Matter of ) "

) - N MEIROPOLITAN EDISON 0}!PANY, ) Docket No. 50-289

) (Restart) 4 t

(*Ihree Mile Island Nuclear ) DOCKETED /

Station, Unit No.1) ) II USNRc "

2 MAR 211980 > b

' 00tDNWEALTH'S RESPONSE TO INIERROGATORIES (SECOND SET) 0F AIERY DYgg __

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15. (2(a)). Do "NRC gn'idalines" include anything other than WREGS 75/111 and 0654? If yes, please identify.

RESPONSE

Previous NRC guido14 nan have been incorporated into the new NUREG-0654, as indicated in the Foreword to that docunent, which states, "This docurent sucersedes previous guidance and criteria published by FD% and NRC."

16. (4). Has the Ccanonwealth conducted an indecendent assessment of -

the adequacy of the 10-mile EPZ apart froct htREG 03967 If yes, attach associated documentation.

RESP 0 TEE tb.

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17. (5). Idattify each individual "resxxise option," " protective action," and 'anergency response" tilat the Ome.alth considers to be "avniinble" to it In the event of a nuclear accident.

REPONSE

'Ihc response options are identi.fied as alert, sheltar, evacuation and administering potassiun iodide. '

Ihe protective actions or emerge .cy t

responses avniinhle are shelter, evacuation and the administration of potassiun iodide.

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a. For each such " response" identify the mfM== " lead time" that the Com mnwealth considers to be " adequate" for the inplanentation thereof.

RESP 0 TEE Minimum adequate lead tire is,a very ambiguous term and not conducive to a specific period of time bense the degree of completeness of the effort and the degree of risk changes with lead time available in any particular situation. 'Ihe object is to use the time available to the best possible advantage, understanding the less time available, the core

" risks" that may have to be taken.

b. What does the Comomealth mean by " variables in the situation?

Identify precisely how each such " variable" c:ay influence the times set forth in response to question #17(a).

RESPOtEE ,

Variables have to do with such things as weather, time of day, day of the week; all of which impart degrees of influence.

18. (6(a)). Identify the NRC official who ecumunicated the " advisory" which rw. dai the extensicn of energency response capability to 20-miles from 'IMI.

RESP 0 TEE Harold Denton is the NRC official who gave the Comonwealth the

" advisory."

a. What reason did NRC give the Connemealth, either at the time of the accident or subsequently, for such r%.adation?

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RESPONSE

'Ihe reason given the Cocmomealth was NRC's judgment at the time. l l

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b. When and under he ciretrastances (by whczn and for what reason (s))

was this r e ... a tion withdrawn?

RESPONSE

The reconecndation has not been officially withdrawn; however, the guidance in NURH;-0654 effectively supersedes the EC " advisory."

19. (8(b)). Identify the FDAA official who made this agreement.

RESPONSE

Mr. Robert Adamcik was the FDAA official. -

a. Was this agreement limited in duration to the TMI accident?

Is it in effect at the present time?

RESPONSE

The agreement was specifically limited to the 1MI accident -- and has not been specifically abrogated,

b. Where are these ambulances stored when not in use in response to a nuclear accident?

RESPONSE

1he anbulances are stored at various Federal agency activities.

20. (9). When and by what NRC official was the mi:ri::um "30-hour warning time" advisory ccumunicated to the Camonwealth?

RESPONSE

2 e "30-hour warning time" advisory was cocrunicated to the Connonwealth by Harold Denton early in the week of April 1,1979.

a. Does the Couronwealth believe that at the time it was issued such an advisory had a reasonable basis in either logic or fact?

RESPONSE ,

lhe advisory appeared to have a reasonable basis in logic and fact.

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. b. What is the basis for the Cccuenwealth's belief in the reasonableness of the use of a 5-hour time frame as a basis for ernergency planning in light of the information in Table 2 of NUREG 0396?

RESP 0tGE The information in Table 2 of NUREG-0396 is an acadenic evaluation and provides for a broad range of possibilities, time-wise. The specific situation at 'IMI following the March 28 incident provided a basis for certain judgments by techWally qualified personnel concerning initiation and duration of any tapu.qpowed radiological releases. Suchjudgments are not within the purview of PDfA, but nust be uM14W in inplementing the cost opywpitiate response actions.

c. Attach copies of all NRC-to-Cocmonwealth and Connonwealth-to-County u-mications which discuss nuclear accident warning times. .

RESTONSE IUREG-0654 is the ucst recent NRC-to Cocmxrmalth cccnunication discussing nuclear accident warning Hus. This document is being used in refining county plans associated with 1MI. There are no written Cocnonwealth-to-County camunications on the subject of warning times,

d. (9(a)). In the course of assisting York County in the preparation of its plan or of reviewing it did the Omnonwealth ever inquire into the basis for the quoted conclusion? If yes, what information was elicited by such inquiry? What judgpent did the Ocxmonwealth make on the effect of this conclusion on the plan's adequacy?

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RESPONSE

I The Cocuanwealth did not inquire into the basis for the quoted 1

conclusion. No judspent was made on the effect of the conclusica or the l

plan's adequacy.  !

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21. (10). Explain the reason (s) for the difference between York County's wavy dependerx:e on spontaneous evacuation in its plan and Dauphin County's decision'to seek mass care space sufficient to house the entire population of the 20-mile risk zone.

RESPO!EE Each of the counties concerned with preparing response plans for IMI made runerous independent decisions concerning plan developnent and unss care arrangenents.

a. To what extent is the reliance in the York County plan on the self-evacuation of over half of the 20-mile at risk population a consequence of the unavailability of sufficient mass care capacity within the county cornbined with a desire to avoid the logistical and financini difficulties of an interstate evacuation into Maryland?

RESPONSE

The Coctraealth does not have this information.

b. What is the Cocmonwealth's source (s) of information regarding the cited "recent Canadian evacuation" and the "other disaster experiences?"

RESPONSE

The Cormonwealth's source of information regarding tN "recent Canadian evacuation" is a respcnsible FDfA official, plus news reports

_ and various other corrmentaries. The Pennsylvania Emergency Management Agency is responsible for implementing appropriate response actions concerning both man-made and natural disasters. Staff members of PD%

have participated in such actions over che years. Additionally, various studies, seminars, and professional pealications addressing such matters have been utilized by PD% staff persmnel in egmting their experience base.

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c. Does the c -al h agree t or divee with the judgment of the FDR rey, Evacuation Planning in the M Accident, that York County a use of infomal polling of local officials and businesses as a guide to evacuation behavior was " questionable in its precision and riskf to use"? (p. 91) Explain.  ;

RESPOtEE POR has not made an over-all jndermt on the adequacy of FDR's report; however, the infomal polling of local officinh by York County authorities provided useful information for both York County and state officials at the time of the incident. he the infomation was not precisely accurate, can be attributed to the urgency of the developing situation around 'IMI.

d. (10(a)). Does the Conconwealth agree or disagree with the FDR report's figure of 31,000 for York County's total mass care capacity? Explain any disagreement. *

RESPONSE

PDR has made no over-all- judgment on the adequacy of the FDR report, and ha.s no opinion on the accuracy of the quoted figure.

e. Specify the section in the York County plan which provides for

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use of " additional mass care facilities in adjacent counties."

RESPONSE

Planning for unss care facilities in adjacent counties was and is an on-going project for various counties within the Camonwalth.

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In the course of assis' ting in the preparation of the York County plan or of a review thereof has any Conmonwealth official confimed the agreements of Frederick, Harford, Baltimore, and Carroll counties in Maryland to furnish overflow mass care )

space to York County? If not, what eviderce is there,the '

such agreerents exist?

RESPONSE

PDW was prepared to assist the counties in obtaining additional e ' '

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mass care facilities if required. 'Ihat this matter is not addressed in the York County plan is not a matter of concern, since oral advisories of the situation w re provided directly to the county by PEMA. FadA is working with eyywyciate Maryland authorities concerning joint matters of concern at 'IMI and Peach Bottom. Written and oral agreements between the states concern a variety of matters, and are part of the ongoing coordination efforts between the states -- to include mass care arrangements in Maryland counties.

22. (12). Does the Cannonwealth agree or disagree with the following evaluation of the warning capacility of sirens from IUREG 0553,

p. II-64:

Major disadvantages include: 1) the difficthty of hearing in residences during the winter because of sound-absorption and well-insulated houses and during the s.tmner in homes sealed up and air-conditioned. . .

Explain any disagreement.

BESPONSE

'Ihe Comnonwealth agrees with the quoted evaluation from IUREG-0553.

a. (12(b)). At the present is there a notification systan in place in the 'IMI EPZ capable of satisfying the " design objectives" of Appendix 3 of NUREG 06547 RESPO EE No.

b. Does the Carmonwealth have the means, fi.dl or otherwise, for putting such a system in place?

RESP 0 TEE No.

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c. Describe in detail any efforts currently underway to satisfy the notification requir ments of NUREG-0654.

RESPOtSE The untter is being addressed by the nuclear fixed facility manage:ent in accordance with the provisions of BUREG-0654 which states on page 39: "It shall be the operators responsibility to insure'that such means exist, regardless of who implements this requiremait."

d. (12(c)). How many Old Order Amish reside within 15 miles of TMI. 20 mi.les?

RESPONSE

Unknown. This infomation may be obtained from the Mennonite ,

Disaster Relief Association.

e. Has the Connonwealth made a determination as to whether tba presence of such concentrations of Old Order Amish constitutes a danographic characteristic warranting departure from a unifomly circular 10-mile EPZ for TMI? If yes, specify in detail the bases for such a determination. If no, does the Cecnonwealth intend to rake such a determination?

RESPONSE

The Cocmonwealth has dete.rmined that notification procedures for Old Order Amish is a special problem which nust be addressed in the on-going study mentioned in paragraph 22 c.

(f) What is the time required for the selection of an appropriate protective action after notification by tba utility of a nuclear energency? How was this time estimate derived?

RESP 0 TEE The time required for protective action selecticn shortens with t

more severe accidents. Evacuation for core melt acrWrits would be l

recamunded in less than 15 minutes. That decision time of -less- thansl5 . :.-. -

minutes also applies to events with dose projection in the range of the EPA-PAG's.

less severe accidents would require t: ore time, as long as hours, for decision making. These H m s apply only to the technical decision ti:re requirenent.

23. (13) Did the Ccumanwealth decline to quantify the criteria in factor #2 of its response because 1) such quantified criteria do not exist, 2) the Comonwealth does not believe quantification of emergency response criteria is necessary, or 3) scme other reason?

RESPONSE

We did not quantify " time required for relocation" because the -

Agency did not have the final value of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for 10-mile evacuation at the time of the response.

a.

What does the Ccemonwealth mean by the phrase '% ell underway prior to expected plume arrival"? 257, of the population evacuated? S07.7 757.?

RESPONSE

"Well under way" in this context means that the population to be evacuated has begun to nove.

b.

Assuning average travel conditions, a 4 miles per hour plume travel speed, and the notification and travel times stated in response to interrogatory #16, state the unst probably emergency response choice for each hourly increase in warning time frcm 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to one day.

RESPONSE

For the accidents expected to lead to containment failure due to core melt, evacuation would probably be indicated to 10 mLles all araurd regardless of windspeed and warning time.

For puff relcase having associated dose projections in the range of PAC's and lead times less than about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, shelter to-10 miles would = w =:

I probably be r+3-. aded. With lead times over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, evacuation to -

10 miles would probably be recomended.

For continuous releases expected to have dose projections in the PAG range, evacuation to 10 miles would probably be reccxImended.

'Ihese strategies are offered as exar:ples only and would not necessarily be selected in a real crisis.

24 (14). To what extent does the perception of an " expected but not yet realized hazard" capable of triggering a precautionary -

evacuation depend great upon the assessment of such nuclear powerplant status parac:eters as tenperature and pressure?

RESPONSE

The perception of an " expected but not yet realized hazard" depends basically on the understanding that the core is uncovered and that there is every reason to expect containment failure since means are not available to cover the core before the loss of a coolable gecmetry. For lesser accidents the phrase means events are underway but the associated discharge has not yet begun. The perception depends exclusively on in-plant i

instrumentation of mam kinds, and the interpretation of data from those instruments by individt ,1s intimately familiar with the facility, namely its staff.

b. Does the Commonwea. *.h ossess the expertise required for making such assessa y s? If yes, state name(s) and agency affiliation.

RESPONSE ,

Yes, William P. Dornsife, Ibclear Engineer, DER, Bureau of Radiation Protection.

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c. What action would the Ccmnonwealth have taken at 8AM on March

' 28 if it had known or been infomed that saturation conditions in the reactor had caused core uncovery and substantial fuel cladd hg damage? At 2PM on March 28?

RESPONSE

Had we known the core was uncovered, we would have had to have been so advised by the licensee, who would have had to have knam that the core was uncovered. Had they known, the licensee would have restarted the high pressure injection systan.

d. In light of the findings of the NRC/'IMI Special Irquiry Group that 'IMI personnel " failed to properly diagnose basic plant information that was known to them" (Vol. 2, pt. 3, p. 64) and provided infomation to off-site authorities that was "often colored by individual interpretations of plant status" (pt. 3, p.126) "when the mere provision of instrument randings would likely have been nere definitive and could have led to an earlier realization of the true plant status" (pt. 3, p.153),

What is the opinion of the Caumrx: wealth as to the necessity or -

desirability of instrunentation providing remote readouts directly to the Cannonwealth of effluent concentrations and essential plant parameters?

RESPONSE

Telemetered source term infomation directed to the Ccxmonwealth would be interesting, though not necessary or desirable. Heavy dependence on the system output could cause the analyst to ignore the fact that atmospheric effluents were escaping by way of an urrnonitored pathway, for instance. They would also cause the analyst to ignore the fact that a fulminating sequence is underway but, since the monitor displays an i.- condition, the verbal information and advice could be ignored.

Telerretered plant status infomation muld be much nore worti:while.

This proposition would, however, require the maintenance of a stable of nuclear engineers, for round the clock duty to service as many as 10 reactors. 'Ihe assigned NE would need to have intimate knowledge of tha assigned plant, cor:mensurate with that of the shift supervisor. Each position requires 5 people (NE's) behind it for full coverage.

25. (16(a)). AIERY repeats its request for specification of egress routes, road capacities, and anticipated traffic volumes.

RESP 0 TEE Attached is a copy of the PER transportation map developed following the March 'IMI incident.

a. What is the "1970 census tract population"?

RESPONSE

'Ihe 1970 census tract population is official U.'S. Goverreent data based on the 1970 census.

b. How does the increase in population over the ensuing ten years affect the time estimates given in response to interrogatory No. 16?

RESPONSE ~

For the purpose of time estimations given in response to interrogatory No.16, there is no appreciable adjustment based on changes in pcpulation.

c. (16(b)). Specify the sections fo the Ccumanwealth and/or County plans which provide for the stationing of '%reckers and -

other devices" along evacuation egress routes.

RESP 0tGE Arrangements by PD% and PennMr -- along with county programs --

provide for wreckers and other devises at critical points on evacuation routes.

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. 26. (17). What does the Camxamalth understand the term " scenario" to mean in the context of the quoted section from the final report of the Kemeny Cr-hsion? ,

RESP 0 TEE

" Scenario" means the conditions which define an incident to be ene of the four incident levels (unusual event, alert, site emergency and general mergency).

b. Identify specifically sections of either Ca m xwealth or County emergency response plans where any such scenarios may be found.

RESP 0 TEE Appendix 8, Septenber 1979, Annex E, paragraph II, identifies Incident Classification which will be changed in accordance with the nea guidance in NURDG-0610.

27. What deterndnations, if any, has the Comonwealth made as to the existence in the environs surrounding M of conditions such as deuography, topography, land characteristics, access routes, and local jurisdictional boundaries that warrant departure from a circular EPZ defined uniformly by a 10-mile radius from the plant?

If none, does the Comxsealth intend to address this question?

RESPOBSE The Comnonwealth is planning to retain a 20-mile evacuation capability around IMI--because this option has been requested by elected officials of affected counties. Adjustments to the 20-mile radius are being re- '

analyzed, though there are no present adjustments to the 10-mile radius.

a. Does the Contenwealth agree or disagree with the following conclusion reached by the NRC/M Special "mquiry Group (Vol.

1, p. 133): .

Therefore, at the very least, significant centers of population beyond 10 miles from the plant rust.be considered in the-planning as well.

O Explain the reasons for any disagr m wnt. If there is agreement, explain with reference to specific sections of Commonwealth or County plans how this conclusion has been incorporated into emergency planning around DfI.

RESP 0tE Significant centers of populatica beyond 10-miles of the plant have been considered in the planning process, in that any nunicipality which is partially within the 10-mile radius is treated as if it were entirely within that radius for purposes of emergency response. PS % has not made a judgment on the adequacy of the NRCTIMI Special Inquiry Group report and neither agrees nor disagrees with the conclusion.

28.

Identify the PWA official (s) who assisted York County in extending its emergency response capability to 20 miles during the DfI accident.

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RESPONSE

Mr. Robert Stimrel assisted York County in its emergency response planning.

a. Did such offiMnla concur in the routing provisions of the York County plan which, according to the FEMA report (p.100) would have resulted in the case of a 20-mile evacuation in "a major traffic problan" and in " people from one part of the county moving toward the hazard before moving away from it"?

RESPONSE

Yes.

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29. What is the Cocmonwealth's position with regard to the need for  ;

prior arrangenents for special deliveries of gasoline to service '

stations along evacuation routes?  ;

RESPONSE

Ccmmatuealth believes that special arrangerents for delivery of l gasoline to service stations along evacuation routes are appropriate r

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c. If such arrangements presently exist provide details with .

reference to specific : notions of Camomealth or Cbunty plans which make provision taerefor.

RESP 0 TEE Arrangai:ents are being forralized with the Govenor's Energy Council, i PennD0r and Departrent of Military Affairs for this matter.

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30. Identify the steps, if any, the Cocacmealth has taken to resolve each of. the eight "reccernendations" listed at pp.14 and 15 of the "After Action Poport" of the Pennsylvania National Guard, . dated June 7, 1979.

RESPONSE

REE M'E m TION: That units and individuals located within five miles radius of a nuclear incident not be considered as part of the initial forces available for the energency.

ACTION TAKEN: Provisions are now in effect which exempt personnel t,ho reside and units located within the five mi.le radius of a fixed

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nuclear facility frcra being called as part of the initial force during an energency. These provisions will be incorporated formally in the updating of the Pennsylvania National Ouard - Emergency Operational Plan scheduled for July 1980.

RECONENDATION: That a study is nw to determine map requirements for all logical eventualities. Map sets should be obtained and distributed in limited quantities for planning purpose with a stock maintained at this headquarters.

ACTION TAKEN: 'Ihe study has been cocpleted and maps are currently being procured by the Department of Military Affairs. Distribution of maps will be made to those PAARNG organizations tasked with responding to energencies at the various fixed nuclear facilities within the State. In addition, the Pennsylvania Emergency Managenent Agency has advised that the Pennsylvania Department of Transportation is currently developing maps, depicting evacuation routes and other information concerning evacuation of the population within a 20 mile radius of the various fixed nuclear facilities within the State. These maps will be issued to the Pennsylvania l National Guard for planning and operational purposes.

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RE00t e M TION: That tG arneries not be considered for use as mass care centers when such use would interfere with the mission of comitted tG units.

ACTION TAKEN: The Departnent of Military Affairs has adopted tba followmg policy regarding the use of National Guard aamies during domestic a::ergencies within the State. " National Guard amories normally will be used for the purposes of housing ard feeding National Guard troops ordered to State Active Duty and/or for tPa establishnent of cumsrd and control headquarters within the vicinity of the emergency area of operations." This Department has advised the Pennsylvania Emergency Managaaent Agency of this policy.

RE004 E M TION: Ihat radiation detection equipment such as Dosimeter INDA-93 CD4-138 (Iow Range) be obtain ' _hrough PEA in sufficient, quantities to provide adequate coverage to cocmitted troops.

ACITON TAKEN: The Department of Military Affairs has been advised that personnel dosimetry egnfyt will be provided thtional Guard personnel by the Bureau of Rndintion Protection in accordance with PAD Protection Appendix to Annex E, PA Disaster Operation Plan. Supplerental Dosimetry equipment will be provided from National Guard Federal Assets.

RE00teiDATION: That sufficient protective clothing and equipment be obtained to provide adequate protection to designated members of deconenmination teams in the PtE.

ACITON TAKEN: Inquiries regarding the availability of special protective clothing and equipwnt have been made to the National Guard l

Bureau and the Nuclear Regulatory Cn=4 =sion. Both agencies do not recaTmend special anti-contamination clothing for National Guard. Protective clothing which protects an.individuaLfrcxn penetrating radiation has not.- a u- -

l been developed as yet. Military clothing will prevent particles of rarHnactive material from contacting the skin. 'Ihe protective clothing and equipment designated for 'D!I, i.e. fatigue uniform, field jacket, pancho, helmet liner, carbat boots, gloves, wind resistant trousers ard M17 protective mask provided a higher degree of protection than required for the situation.

RE&tt!ENDATION: ht the feasibility of preparing DD Form 1141, _

Record of Occupational Exposure to ionizing radiation for individuals assigned duties in the area of operations be studied.

ACTION TAKEN: Feasibility study has been conducted. DD Form 1141 will be used as prescribed by Arnrf Regulation 40-14. Personnel monitoring data will be cocplied by the Bureau of Bndintion Protection and provided the worker and responsible agency.

REO@tENDATION: ht in order to supplecent overcrowded camercial comunication facilities, military canunications nets be placed in service inmediately, to assist in alert and coumand and control of units.

ACIION TAKEN: Connunications plans have been developed which include the positioning of high frequency single sidebard radios at each cmmand control headquarters cmmitted to an emergency situation. Planning is underway to establish voice radio links between State, area and county emergency managenent operations centers and National Guard Emergercy Operations Centers at State, task force and batenHnn levels. 'Ibese radio links will be utilized to supplement and/or replace existing cocmercial telephone systems should they becane overcrowded or inoperative.

It has been determined that militar/ camunications nets would be impractical for alerting personnel. 'Iherefore it is planned to utilize local radio and television stations to unke public anncuncements should- ' - -

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the primary means, television ndtification, prove ineffective.

RECONENDATION: Bat the Ibclear-Biological-Chanical (NBC) Defense Course being conducted by the FAARtG in August-Septanber 1979 be continued in future fiscal years to insure that NBC qualifications are maintained in ali units.

ACTION TAKEN: Program is being continued. De course for fiscal year 1980 was initiated on 23-24 February with subsequent classes being held on 22-23 March and 26-27 April. B ere are currently 137 students enrolled in the course.

31. Has the " guidance for the agricultural commity in dealing with energency nuclear accidents" called for in Section IX (A) (4) (g) of Annex E of the Conmonwealth DOP been " developed"? If so, where is it to be found? Identify the methods of comnication of such

" guidance" that,1) have been effectively inplemented, 2) have been developed but not inplemented, and 3) ranain to be developed.

RESP 0 TEE B e guidance has been developed.

Le guidance is included in the Agriculture Plan, an appendix of Annex E to the "Connonwealth of Pennsylvania Disaster Operation Plan" (copy attached).

1. Method of comuunication is that the guidance is in the form of fact sheets for inplanentation by local, State and Federal officials and the media.

2. We guidance developed has been inplemented as outlired above.

3. We understand that the " Disaster Hardbook for Extension Agents" is being reviewed by the Pennsylvania State University Cooperative Extension Service and that Extension Service television educational releases may be used. We cannot vouch for or provide target daces for ten Extension Service review.

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32. In light of the provision of the Pennsylvania Emegency ement Services Code (35 Pa. C.S. 57101 et seg.) (EMSC) stating t

" direction of disaster emergency management services is the responsibility of the lowest level of gover: rent affected" (EEC 57504(a)), is it the Cimumalth's position that effective errergency response capability for 'IMI depends upon the existence of local govemnental emergency response organizations and plans which satisfy the standards therefor in the BEC? Discuss any respects as to which the Conrunwealth does not subscribe to this position.

RESPONSE

The Ocmnonwealth subscribes to the position outlined in tbc DEC Section 7504 (a)-(b). Effective energency response is further dependent upon an effective county organization and plans for emergency management and response.

33. For each local goverrrnental unit (township, borough, city, etc.)

within a 10-mile radius of M provide the following information:

a. Whether or not a " local energency management organization" (ENSC 57501 (a)) which satisfies the Cacurmealth's criteria therefor persently exists.

(1) Specify in detail the standards and criteria the Ccanonwealth ecploys in evaluating the adequacy of local emergency management organizations.

RESPONSE

The Comtenwealth has no criteria or standards for evaluating the adequacy of local energency management organizations.

b. The identity of the " local coordinator" (DEC 57502 (a)).

RESPONSE

l Attached is a list of local coordinators for the five risk counties.

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c. The qualifications of each " local coordinator" (ENSC 57502 (d)). '

(1) Specify in detail the Connionwealth's standards and i criteria for local. coordinator. qualifications.,.u m m -

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RESP 0 TEE 1

The Ccxmmaalth has no such standards or criteria, nor does it maint,fn lists of coordinator qualifications.

d. Whether the local coordinator has completed in-service training in accordance with DSC 57502 (e)).

RESP 0 TEE Public law 1332 prescribes that the individual counties are responsible for the training of local coordinators, and for the maintenance of the training records for said individuals. 'Iherefore, ANGRY cust look to the --

various county organi = tions in order to ascertain the training status of local coordinators. The Ccumonwealth does not traintain such records.

(1) Describe in detail the Comaonwealth's career development program.

RESP 00GE The Ccxmonwealth's " career development program" has four (4) phases as described below.

1. Phase I - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (one week) in length. Transportation, food and lodging expenses paid by the Ccrmonwealth using federal funds. One course held per fiscal year (October 22-26, 1979, in Iawistown for current fiscal year).

Subject:

'%e Job of the Coordinator".

2. Phase II - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (one week) in length. Transportation, food and lodging expenses paid by the Carmonwealth using federal funds. One course held per fiscal year (March 31 - April 4, 1980, in Clearfield for current fiscal year).

Subject:

"The Work Envi e.t of the Coordinator".

3. Phase III - 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> (two weeks) in length. Fifty percent of the food and transportation expenses paid by the federal government; 507. to be e*

paid either by the student or by the cunicipality he represents. lodging is provided by the federal goverrnent free of charge. All o'f these courses are currently being offered at the m % Staff College in Battle Creek, Michigan.

Subject:

" h Personal Effectiveness of the Coordinator".

4. Phase IV - 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> (two weeks) in length. Fifty percent of the food and transportation expenses paid by the federal goverrnent; 507. to be paid either by the student or by the rmnicipality he represents. .

Iodging is provided by the federal goverrnent free of charge. All of these courses are currently being offered at the m% Staff College in Battle Creek, Michigan.

Subject:

" Civil Preparedness in National Security".

c. Whether or not a " disaster emergency management plan" (DEC 57503 (1)) which satisfies the C m ealth's criteria therefor presently exists.

(1) Describe in detail the Ccxmasealth's standards and criteria for the adequacy of local disaster emergency management plans.

RESPONSE

The Ccxmonwealth has no enforceable standards or criteria governing the adequacy of local plans, and does not have the information requested.

f. Whether or not an " emergency operations center" (ESC 57503 (2))

which satisfies the Ccxmonwealth's standards and criteria therefor presently exists.

(1) State the location of each such local "EOC".

(2) Describe in detail the Ccrmonwealth's standards and criteria for assessing the adequacy of local EOC's.

RESPONSE

h Cctmenwealth does not have this information ard has no enforceable i standards or criteria governing the adequacy of local EOC's.  !

i I

l

g. Whether or not " organizational and indivMm1 training programs" (DEC $7503(3)) which satisfy the Ocamonwealth's criteria therefor presently exist.

RESP 0tGE The Comonwealth presently has individual and organizational training programs available in accordance with P.L. 1332. A schedule of these courses is published each fiscal year.

(1) Describe in detail the Ccumonwealth's st.andards and criteria for assessing the adequacy of local training programs.

RESPONSE

The Comonwealth detemines the adequacy of local training programs from annual reports only if the local organization is a party to the Personnel and Administrative (P. and A.) Program. In all. situations, however, the county organizations are responsible for making such a dera mfrution.

h. Whether sufficient efforts have been undertaken to procure "all locally available manpower, materials, supplies, eqtdrrnant, facilities and services necessary for... emergency... response..."

(D SC 57503 (4)).

RESPOJGE The Ccomonwealth does not have this information.

34. For each of the five "at risk" counties describe the catmunications systen presently in effect between the county emergency operations center and local EOC's.

RESPONSE

The Comonwealth does not have this information. l l

a. Describe the extent to which any such system is not operable (i.e. , local contact not available) on a 24-hour basis.

RESPONSE

The Comonwealth does not have this information.

e b.. What is the Comonwealth's position as to the adequacy of these ~

systes?

RESPONSE

The Camxmealth has no position as to the adequacy of these syste::s at the present time.

35. Provide copies of any " unmet needs" listing furnished to the Conmorrealth by any "at risk" county since the 1MI accident pursuant to Annex E SIX(B)(1)(x).

RESP 0 TEE A review of unmet needs of both counties and municipalities affected by 1MI is presently in process. No such listing currently exists.

36. The NRC/'IMI Special Inquiry Group concluded that:

Only an offsite, real-time-detector syst s could have provided

~ the confirmation of offsite exposure rates at a relatively inaccessible location such as Goldsboro within the 10-15 minutes that the Board considered (Vol. 2, pt. 2, p.173).

It further recamended that "real-time online radiation monitoring l equipment should be installed around all nuclear powerplants" (pt. 2, )

p. 95). Does the Coam m ealth agr a or dianeree with this

~

reccurmendation? Explain fully the reasons for any dieorement.

1 "Real time on line radiation monitors" is assuned to mean ganra l

sensitive rate meters which ccxmunicate electronically with sane onsite terminal where the data is recorded and evaluated.

l Although the systs has merit, it should not be enbraced as a sine qua non for the following reasons:

1. 'Ihe systs will detect and record ganma exposure rate at the location of each detector only.

2. The system will not detect and record ai h. radiciodines at the location of.eachudetector..=Rnd4nindinea may.iuall ha- rha -ea=

critical set of radioisotopes.

~

3 %e plune may skillfully avoid all the detectors.

4 De treatment of false positives and false negatives cust be well developed and understood.

5. Exposure rate output frcm these devices will not, per se, assist in making the whole body dose projection inherent in applying whole body Protective Action Oddaa, since it is an after-the-fact parameter rather than a projection which is generated.

L e system has some advantages. Measurenents from these devices can serve the ccxnbined roles of verification / contradiction of the analysis perception of offsite ganma exposure rate consequences, as well as that of input to after-the-fact estimations of population ganma dose.

37. Do the high schools with pick-up routes for areas within 10 miles of

'IMI in York County cwn their own bus fleets or do they enploy bus fleets owned by outside contractors?

RESPONSE

Be Connenwealth does not have this information.

a. Identify each such outside contractor.

RESPONSE

The Couronwealth does not have this information.

b. What assurance is there from each contractor that its fleet with drivers will be available to fulfill the requirements of Annex VII of the York Comty Plan?

RESPONSE

Be Ccumenwealth does not have this information.

, J. . .

38. What method does PD% enploy to notify its off-duty officials of a nuclear emergency?

RESP 0tBE PINA erpluys ccrmercial telephone to notify officials. This activity is acccmplished by the duty person at the, direction of senior officials upon their notification or directly by personal contact during duty hours.

a. Should similne methods be adopted by county and local governmental units?

RESP 00EE _ . . .

Ibt necessarily. As long as the method" selected is reactive and has a 24-hour capability, the method need not be similar to that of the Commotwealth. -

39. What is the time required for the ratoval of seats frun the 30 buses Annex IV of the York County plan indicates will be used to evacuate nursing home wheelchair patients?

RESP 006E _

The Ccanonwealth does not have this information.

Respectfully subctitted, 4tw D*

KARIN W. CARN.K Assistant Attorney General l Attorney for .

Comucnwealth of Pennsylvania l l

i March 17, 1980 l

l l

1 1

RELATED CORRESPONDI!NCR WITED STATES OF AMERICA NUCIEAR REGUL\ TORY CC5MISSIQi BEFORE THE A104IC SAFETY AND LICaiSING BOARD In the Patter of )

)

METFOPOLITAN EDISQ1 CWPANY, ) ' N

) Ibcket tb. 50-289 4 t (Three Mile Island thclear. ) (Restart) oo m Station, Unit No.1) '

) [Il USNRC 3

AFFIDAVIT OF ORAN K. HENDERSON  : M 211980 > r

@ Officeof theSeselsf S Camuruealth of Pennsylvania ) Dodet44alnks County of Dauphin

)

)

SS g 8% e g 4 ORAN K. IEIDERSCN, being duly swom according to law, deposes and says that he is Director of the Pennsylvania Emergency Management Agency; that the infouration contained in Cacm:miealth's response to Interrogatories (Second Set) of ANCRY nuTbered 15, 16, 17, 18, 19, 20, 21, 22(a-e), 25, 26, 27, 28, 29, 32, 33, 34, 35, 37, 38, 39 is true and correct to the best of his kncwledge, infouration and belief.

CRAN K. HEh1ERSON Director Pennsylvania Etmrgency Management Agency Swom to and subscribed before me this day of March,1980.

EUIARY PUBLIC

~~ n M M OF Nm "ESPONDfWce - -

NUCLEAR REGUIRORY 03HISSION BEFORE ' die A'IINIC SAFEIY AND LICENSING BOARD In the Matter of )

)

ME30POLITAN EDISON 004PANY, ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) ) c 11%

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DCc1ETED f, AFFIDAVIT OF MARGARET A. REILLY ll- UWEC .

~: MAR 211980 > fl (IMOMEALTH OF PENNSYLVANIA )

) SS Ofcgcl, [ /[l

000NIY OF DAUPHIN )

co ,' &

Y i-MARGARET A. REILLY, being duly sworn according to law, deposes and.

says that she is Chief of the Emriwo- en1 Radiation Division, Bureau of Radineim Protection, Department of Envi2ws>ral Resources; and that the information contained in Connonwealth's Response to Interrogatories of ANGRY numbered 22(f), 23, 24 and 36 is true and correct to the best  ;

i of her knowledge, information and belief. ,

l l

l Shuu:T. A. RuJ@Y f Chief, Emritetwaaltal Rndiar4m Division Bureau of Radiation Protection l

Sworn to and subscribed I before me this /7d. day of March,1980.

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M7EARY PUBLIC w M. Case. Notarr PuMc g, c.,, a ti:wn t'n 2. ns3 hag. PA Dauphia County 1

REMTED COfutESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULA10RY CaHISSION BEEDRE THE ATOMIC SAFETY AND LICCSING BOARD In the Fhtter of )

) A TI91j FETROPOLITAN EDISON CCMPANY, ) D

) Docket Ib. 50-289 d' (Three Mile Island tbclear ) (Restart) DM Station, Unit tb.1) ) 'y. ""# 1

~~ MAR 21980 P 3 AFFIDAVIT OF ROBERT C. FURRER #

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Ccxmonwealth of Pennsylvania ) ,

C##a $^ gge, ,

) SS V

County of Dauphin. )

ROBERT C. FURRER, being duly sworn according to law, deposes and

, says that he is Ebnagement Analyst, Bureau of Administrative Services, Pennsylvania Department of Agriculture; and that the information contained in Commwealth's response to Interrogatories of ANGRY (Second Set) nmbered 31 is true and correct to the best of his knowledge, information and belief.

b8~f" b h wa ROBERT C. FURRER Management Analyst Bureau of Administrative Services Pennsylvania Department of Agriculture Sworn to and subscr beforemethis/@f. daybed of March 1980.

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, ,IUu\RY PUBLIC g, . ,. s. ; .',?' /{^

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' 4 DOCKETED UNITED STATES OF NERICA ustEC g g' ,

NUCLEAR REGUIATORY CatESSION ._

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BEFDRE 11E A10MIC SAFETY AND LICENSINGCesdtt3%wa' BOARDk

\ ed.:ticG N, #

In the Matter of )

, a

)

MI:T, ROPOLITAN EDISON COMPANY, ) Docket No. 50-289

. ) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) ) anuTED conRESM AFFIDAVIT OF MMOR GEtERAL RICHARD M. SOUIT Comaxrmalth of Pennsylvania )

) SS County of Dauphin )

MMOR GEIERAL RIGHARD M. S07IT, being duly sworn according to law, deposes and says that he is Adjutant General, Pennsylvania Department of Military Affairs; and that the information contained in Cmmonwealth's response to Interrogatory tb. 30 is true and correct to the best of his knowledge, information and belief.

F

~

I M.p - E A-MMOR GENERAL RICHARD M. SCOIT Adjutant General Pennsylvania Department of Milj.tary Affairs Sworn to and subscr* bed before me this </ day o -

, 1980."

//

M l IDfARY PUBLIC MJ -

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UNITED STATES OF AMERICA

!UCIEAR REGUIATORY Cat 4ISSIQ1 BEFORE THE A104IC SAFEIY AND LICH1 SING BOARD In the thtter of )

) RELiTED CORRESPONDENCB MET. ROPOLITAtt EDISCt1 COMPANY, )

) Docket tb. 50-289 (Three Mile Island tbclear ) (Restart)

Station, Unit tb.1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the comonwealth of Pennsylvania's Response to Interrogatories of ANGRY (Second Set) were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 18th day of March, 1980, and that a copy of said document was served upon Ms. Holly S. Keck by deposit in the United States mail, postage prepaid, on March 17, 1980.

R  ?. O a.: , ', ) I?. C :lh3s KARIN W. CAR'1ER -

Assistant Attorney General Dated: March 18, 1980 4 occKEED usNBC -

1.4AR 2 119 M

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INITED SDUES OF A) ERICA MJCEAR REGUIAIORY C3tESSION E BERRE 'DE Alt 24IC SAFE 1Y AND LICENSING BOARD .

In the Matter of )

)

MEIROPOLITAN EDISON C0fANY, )

) Docket Ib. 50-289 (Three Mile Island Nuclear ) (Restart)

Station, Unit No.1) )

SERVICE LIST  ;

George F. Trowbridge, Esquire Theodore A. Adler, Esquire -

Shaw, Pittman, Potts & Trcubridge Widoff, Reager, Selkowitz & Adler 1800 M Street, N.W. -

P. O. Box 1547 Washington, D.C. 20006 Harrisburg, Pennsylvania 17105 Ms. Marjorie M. Amnode Ivan W. Smith, Esquire R.D. #5 Gaimart -

Coatesville, Pennsylvania 19320 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory C W asion Ms. Holly S. Keck, Iag. Gaimari E shington, D.C. 20555 - -

~'

Anti Nuclear Group Representing York (ANGRY) Dr. W lter H. Jordan 245 W. Philadelphia Street Atomic Safety and Licensing Board Panel York, Pennsylvania 17404 881 West Outer Drive Oak Ridge, Tennessee 37830 Coalition for Nuclear Power Dr. Linda W. Little Plant Postponement Atomic Safety and Licensing Board Panel 2610 Grendon Drive 5000 Hermitage Drive Wilndngton, Delaware 19808 Raleigh, North Carolina 27612 Mr. Robert Q. Pollard Docketing and Service Section 609 Montpelier Street Office of the Secretary Balitznore, Maryland 21218 U.S. Nuclear Regulatory M asion Wahington, D.C. 20555 Walter W. Cohen, Esquire Consumer Advocate Ellyn R. Wiss Department of Justice Sheldon,16m, Roisman & Wiss Strawberry Square, 14th Floor 1725 I Street, N.W.

Harrisburg, Pennsylvania 17127 Suite 506 Wahington, D.C. 20006 Dr. Chatzcey Kepford Judith H. Johnsrud Karin P. Sheldon, Esq. (PANE)

Enviw&ral Coalition on Nuclear Sheldon, Harnon, Roisman & Weiss Power 1725 I Street, N.W., Suite 506 433 Orlando Avenue W shington, D.C. 20006 i State College, Pennsylvania 16801 James A. Tourtellotte, Esquire

.=.2-< Mr. Steven C. Sholly = = -. == = . . Office. of_the: E-4vehgal 2. - -

304 South Market Street Director Mechanicsburg, Pennsylvania 17055 U.S. Nuclear Regulatory Cer=4csion Eshington, D.C. 20555

John A. Isvin, Esquire Jordan D. Cunningham, Esquire Assistant Counsel Attorney for thewberry Township Pennsylvania Public Utility T.M.I. Steering Conmittee e=niasion 2320 North Second Street P.O. Box 3265 Harrisburg, Pennsylvania 17110 Harrisburg, Pennsylvania 17120 Marvin I. Lewis Robert L. Youpp, Esquire 6504 Bradford Terrace Assistant Solicitor Philadelphia, Pennsylvania 19149 County of Dauphin P.O. Box P Jane Iae 407 North Front Street R.D. 3, Box 3521 Harrisburg, PA 17108 Etters, Pennsylvania 17319 John E. Mirmich N4=m, Dauphin County Board of -

C W asioners Dauphin County Courthouse Front and Market Streets Harrisburg, Pennsylvania 17101 l

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