ML19305D060

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Response to Newberry Township TMI Steering Committee 800215 First Set of Interrogatories Re Restart Proceeding.Includes Info Re Selection of Witnesses & Licensee Studies Re Emergency Plan.Gf Trowbridge 800331 Forwarding Ltr Encl
ML19305D060
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 03/31/1980
From: Trowbridge G, Zahler R
METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
NEWBERRY TOWNSHIP, YORK HAVEN, PA
Shared Package
ML19305D049 List:
References
NUDOCS 8004140017
Download: ML19305D060 (11)
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Text

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O Lic 3/31/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island. Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSE TO THE FIRST SET OF INTERROGATORIES FROM NEWBERRY TOWNSHIP TMI STEERING COMMITTEE (DATED FEBRUARY 15, 1980)

INTERROGATORY NO. 1 State the name, address, position and occupation, place of em-  !

ployment and subject matter of testimony of all witnesses who ,

will be called by Met Ed in this proceeding to testify on any j aspect of Met Ed's Emergency Plan for the Three Mile Island i Nuclear Station, j

RESPONSE

Met Ed has as yet made no selection of witnesses who will testify as to Licensee's Emergency Plan.

INTERROGATORY NO. 2 t

For each person named in response to Interrogatory No. 1 above i who will testify to matters of opinion based upon ascerted [ sic] !

expertise and some recognized discipline, profession or occupa-tion, state all educational institutions attended after second-ary school, all undergraduate and graduate degrees granted, areas of concentration, titles of thes[e]s, professional articles and books authored or co-authored; caption, docket number, date, place and subject matter summary of any prior testimony in any state or federal judicial or administrative proceeding, as well as the name of the party for whom appearing. Moreover, state the subject matter on which the witness is expected to testify; and state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion.

0 0 0 414 OC ~1

RESPONSE ,

since witnesses have not yet been selected, it is not pos-sible at this time to respond to this interrogatory. However, background and qualifications of any experts who may be offered by Licensee as witnesses will be included in prepared testimony filed with all participants in advance of the hearing session at which such witnesses may appear.

INTERROGATORY NO. 3 State the name, address, position and occupation, place of em-ployment of each individual who participated in the drafting of the Emergency Plan for the Three Mile Island Nuclear Station.

RESPONSE  :

(a) George Giangi, Emergency Planning Coordinator, Metropolitan Edison Company, Post Office Box 480, Middletown, Pennsylvania 15057. Addi-tionally, many Met Ed employees had specific input on particular areas of expertise at var- ,

ious times.

(b) Alexis Tsaggaris, former Emergency Planning Coordinator for Met Ed. Currently a Con-sultant with Schneider Consulting Engineers, t 98 Vanadium Road, Bridgville, Pa. 15017 (c) John D. Bigbee, former Acting Emergency Planning Coordinator John J. Allman, Jr. Engineer Samuel Baggett, Sr. Engineer l

Bruce M. Center, Sr. Engineer Larry Grunnet, Engineer Ray J. Hallmark, Sr. Engineer Laurie Lindgren, Associate Engineer

Dennis P. McCloskey, Engineer Clemon L. Shoemake, Sr. Engineer Energy Incorporated, Post Office Box 736, Idaho i

Falls, Idaho 83401. -

INTERROGATORY NO. 4 Did any of the individuals who participated in the drafting of the Emergency Plan meet with any County officials to elicit opinions from them with regard to the Emergency Plan?

RESPONSE

Licensee participates in the Radiological Emergency Response Planning (RERP) Team for TMI. The purpose of the RERP Team is to coordinate Licensee, state, and county plans. Members include individuals from numerous state agencies and county representa-tives.

INTERROGATORY NO. 5 If so, state: ,

(a) the names of the individuals who met with the County officials; (b) the names of the County officials who were con-tacted by the individuals referred to in sub-paragraph (a) above; (c) the dates on which these meetings took place; (d) the reason for the meetings with the County officials.

RESPONSE

(a) The Emergency Planning Coordinator was Licensee's representative on the RERP Team.

(b) Minutes of the RERP meetings that are available will be placed in Licensee's Discovery Reading Room. These notes provide the information sought in (b) , (c) , and (d).

(c) See response to 5 (b) .

(d) See response to 5(b).

i INTERROGATORY NO. 6 Did any of the individuals involved in the drafting of the Emer-gency Plan meet with any State or Federal officials?

RESPONSE

Some of Licensee's meetings with state and federal personnel are included in the responses to Interrogatories 4 and 5. In addition, many planning meetings were held between PEMA and Li-censee's Emergency Planning Coordinator and other facility repre-sentatives. Meetings with federal agencies involved the NRC and FEMA.  ;

INTERROGATORY NO. 7 If so, state: i (a) the individual who met with the Federal or State agencies; (b) the date on which the Federal or State agen- ,

cies were contacted;  ;

(c) the substance of the discussions that took i place between the individual and the State or g

Federal a'ency; (d) the reason why the Federal or State agency was contacted; (e) the name of the person who was contacted at the Federal or State agency.

RESPONSE

l (a) At a minimum, Licensee's representative was the Emergency Planning Coordinator.

(b) State and federal agencies were contacted l

l frequently on a routine basis. Licensee does not have a record of all such contacts.

(c) Routine contacts were made to coordinate the (d) planning process, reach agreement on emergency planning concepts, and clarify new guidance from the NRC Staff.

(e) Primary contacts at the state level were:

Oran K. Henderson, PEMA Craig Williamson, PEMA Jim Lothrop, PEMA  ;

Charles Crowe, PEMA Primary contact at the federal level was Jack Roe, NRC.

r INTERROGATORY NO. 8 State whether you have evei conducted any studies with regard to l the Emergency Plan concerning traffic flow in the event an evacuation was ordered in the event of an emergency.

RESPONSE l Licensea has relied on information supplied by PEMA as the .

lead state agency for emergency planning. The RERP Team, of which Licensee is a part, was provided with traffic flow data supplied by the Pennsylvania Department of Transportation (Pa. DOT).

l INTERROGATORY NO. 9 ,

If so, state:

(a) the date on which the study was conducted; t

(b) the person who conducted the study;  ;

(c) The findings of the study; (d) whether the study was reduced to writing. If so, attached (sic] a copy of this report to i your answers to these interrogatories. j

RESPONSE

Licensee does not possess the information requested.

INTERROGATORY NO. 10 Are you making any adjustments to the Emergency Plan in light of the recent Rogovin Report to the Nuclear Regulatory Commis-sion, which recommended at [ sic] ten-mile radius for evacuation of citizenry in the event of an emergency condition existing?

RESPONSE

Licensee is currently reviewing the Rogovin Report recom-mendations for possible input to the Emergency Plan.

INTERROGATORY NO. 11 If so, please state the amendments or adjustments made to the Emergency Plan.

RESPONSE

Licensee's review is not yet complete.

INTERROGATORY NO. 12 As regards volunteer firemen and policemen, and local police departments, besides the letters of agreement attached to the Emergency Plan, what guarantees do you have that such personnel will submit themselves to your service in the event of an emergency?

RESPONSE

Licensee relies on the professionalism of the personnel in these agencies to provide the agreed-to services.

INTERROGATORY NO. 13 In the event that voluntary personnel did not respond to your requests for aid in times of an emergency, please state how you would respond to the situation.

RESPONSE

Licensee's response would depend on the specific situation at hand. Generally, Licensee believes there is sufficient re-dundancy and overlap in support organizations to provide assur-ance of appropriate response.

INTERROGATORY NO. 14 Specifically state the premises and grounds on which you answer the preceding interrogatory. If there are studies available, please indicate the existence of those studies and attach a copy of the studies that you have in your possession to your answers to these interrogatories.

RESPONSE l See responses to Interrogatories 12 and 13.

INTERROGATORY NO. 15 What provisions have been made for the training of National Guard personnel that you rely upon being in place in the event of an emergency condition?

RESPONSE

, Licensee is not responsible for training National Guard personnel and they are not required onsite.

INTERROGATORY NO. 16 State whether, with regard to the National Guard personnel, any protective gear has been purchased to protect National Guardsmen in the event of an emergency.

RESPONSE

Licensee has not purchased any protective gear for National Guardsmen.

INTERROGATORY NO. 17 Did you forward to County Civil Defense offices that surround the Three Mile Island Nuclear Station copies of the revised Emergency Plan?

RESPONSE

i Yes.

INTERROGATORY NO. 18 If so, state:

j (a) the dates on which you forwarded the revised Emergency Plan to the County Civil Defense offices;

r.

(b) state the offices which you forwarded a copy of the Emergency Plan to; (c) state whether any local Civil Defense office has offered comments, either oral or written, to the Emergency Plan; (d) state whether these comments were ever reduced to writing, and if so, attach a copy of all such writings that you have in your possession to your answers to these interrogatories.

RESPONSE

(a) March 14, 1980 and November 1979.

(b) Cumberland, Dauphin, Lancaster, Lebanon, and York County Emergency Management Agencies.

(c) See responses to Interrogatories 4 and 5.

(d) No.

INTERROGATORY NO. 19 What provisions have you made for in the Emergency Plan for the evacuation of farm animals?

RESPONSE

Responsibility for farm animals lies with the Commonwealth of Pennsylvania.

INTERROGATORY NO. 20 -

Did you ever have any studies undertaken to determine the exact number of hours it would take to evacuate all of the citizenry from a ten-mile radius from the Three Mile Island Nuclear Sta-tion in the even[t] of an emergency condition?-

RESPONSE

Licensee has not undertaken such studies. Licensee has relied on the Commonwealth of Pennsylvania for evacuation'in-formation, t

INTERROGATORY NO. 21 If so, please attach a copy of all reports relating to this matter that you have in your possession to your answers to these interrogatories.

RESPONSE

Evacuation time information was obtained for submittal to the NRC. This information was transmitted to the attention of Brian K. Grimes by letter dated February 4, 1980 from J. G.

Herbein. A copy of this transmittal will be placed in Licensee's Discovery Reading Room.

1 INTERROGATORY NO. 22 ,

Did you ever attempt to verify facts or assumptions made in the County plans which were attached and made part of your Emergency Plan?

RESPONSE

The county plans submitted were what was available at the time. A program has been established through PEMA to coordinate the five county plans wit.. state and Licensee plans and to upgrade the county and state plans to meet requirements which are being developed by the NRC and FEMA. This is being done through RERP. !

A part of the RERP Team review is to ensure that assumptions used are consistent and acceptable. When required, sources of facts are verified by RERP Team members.

INTERROGATORY NO. 23 If so, please state:

(a) the names of the individuals who made the veri-fications; (b) whether any of the facts or assumptions made in the County plans were found to be erroneous;

6 (c) set forth those facts and assumptions found to be erroneous in the County plan in specific detail.

RESPONSE

See responses to Interrogatories 4 and 5.

INTERROGATORY NO. 24 Did you ever attempt to coordinate the five county plans which are incorporated by reference to the Emergency Plan? If so, please state what attempts were made to coordinate the various plans.

RESPONSE

See responses to Interrogatories 4, 5, and 22.

INTERROGATORY NO. 25 Did you ever attempt to coordinate the onsite emergency plan with those of the five surrounding counties which are incorpor-ated by reference into the Emergency Plan?

RESPONSE

See responses to Interrogatories 4, 5, and 22.

INTERROGATORY NO. 26 If so, state what attempts were made to coordinate onsite emer-gency plans with those of the five counties.

RESPONSE

See responses to Interrogatories 4, 5, and 22.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: A %A j "t3pfbrgtVF.' Trokbridge [

Robert E. Zahler Dated: March 31, 1980

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. , A.M .,,E ,N . C . March 31, 1980 Jordan D. Cunningham, Esq.

Attorney for Newberry Township T.M.I. Steering Committee 2320 North Second Street Harrisburg, Pennsylvania 17110 Re: Three Mile Island Unit 1 Docket No. 50-289 (Restart)

Dear Mr. Cunningham:

I enclose Licensee's responses to Newberry Township's first set of interrogatories, dated February 15, 1980. Copies of signed affidavits for these responses are not enclosed, but will be forwarded soon.

Sin ely yo rs, eor F. Tr ph/

bridge Enclosure cc: Service List

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