ML19305D122
| ML19305D122 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1980 |
| From: | Carter K PENNSYLVANIA, COMMONWEALTH OF |
| To: | Sholly S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19305D120 | List: |
| References | |
| NUDOCS 8004140077 | |
| Download: ML19305D122 (8) | |
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NUCLEAR REGULATORY CalESSION Ulli 2 0 Q> b.
BEFORE 7EE A10 EC SAFEIY AND LICENSING BOARD g.g g g.g ]ji 9
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MEIROPOLITAN EDISON CQfANY,
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Docket No. 50-289
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(Restart)
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Station, Unit No.1)
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'lltDNWEAL'IH'S RESPONSE TO INIERROGA70 RIES OF STEVEN C. SHOLLY (FIRST SET)08-001 Describe the connmications links between agencies of the Connonwealth and the Licensee's control room for M-1.
In the description, describe the extent to stich backup, redundant linkc exist, and, if none exist, the conditions under stich
' lie coanunications link could fail to work properly.
RESPONSE
The primary comnunications link that exists between the Pennsylvania Emergency Managcment Agency (PEMA) and the control room for ihree Mile Island Unit One is coamercial telephane. The backup systen, which supplies redundancy, is the State National Warning System (NAWAS) circuit.
(Henderson, PEMA)08-002 What is the Connonwealth's position regarding the sufficiency of Licensee's Emergency Planning Zones (EPZ's) for Plume and Ingestion Exposure Pathiays?
RESPOIEE The Comnxiwealth has no conflict with the Licensee's definition of the EPZ's for Plume and Ingestion Pathways because the Licensee has accepted the ComTonwealth's positions on which nunicipalities, facilities or geographic borders are within the EPZ's.
(Henderson, PRfA) 8004140 D77
08-003 Licensee states in several places in the Emergency Plan (section 4, Restart Report) that there was close coordination between the State Emergency Plan and Licensee's Emergency Plan as these documents wre Provide documentation Wich m uld either suppo, developed.
rt or refute this claim, including in such documents letters, transcripts of meetings, and other mmoranda which deal with develorment of emergency plans and coordination between the Cmnwealth's plan and Licensee's plan.
RESPONSE
Attached are the following documents:
Mmo - PDR to Metropolitan Edison dated June 22, 1979, providing rewrite of Annex E on fixed nuclear facility incidents to be used as guidance in developing the M plan.
Meeting outline, agenda and attendee list of a working meeting between PER, Metropolitan Edison, Philadelphia Electric and Duqu'esne Light held on July 18, 1979 in the PE R conference room to review in detail the rlanning elments in the draft plans to be sure that there was a conglete understanding and workability of the plans.
Imtter - Henderson to Metropolitan Edison dated October 2,.1979 providing the draft Annex E dated September,1979, sich was prepared based upon the meeting in July and infonml exchanges such as telephone calls.08-004 Provide a copy of the most recent letter of understanding with Licensee regarding Cmunnwealth assistance during emergencies at M-1.
RESPONSE
The following letter of agreement between the Licensee and the Conunnwealth are attached.
- 1. ' Letter dated December 24, 1979, from Metropolitan ?!dison to PDR accepting facility responsibilities L Annex E.
Ietter dated January 3,1980, from Pa% to Vetropolitan Edison 2.
pledging full and active assistance in all mergency operations which might be necessitated by nuclear radiation incidents occuring in 'IMI.
To what extent does the Comonwealth have the capability 08-005 to independently assess the magnitude and composition of 3
radioactive releases from 'IMI-l in the event of an accident?
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How long might it take for the Comonwealth's nunitoring capabilities to be placed in service (provide upper and lower bound estimates on best possible response and a worst case response, i.e., a middle-of-the-night incident during a snowstorm or heavy rain)?
RESP 01EE Accident assessment' depends strongly on analysis of Licensee information regarding the nature of the accident and the status of consequence i
Our assessment may not necessarily agree with^ that mitigating features.
of the Licensee and in that sense is independent. 'Ihis assessment can be made in minutes. Severe accidents can be assessed faster than lower consequence accidents.
Field measurement capabilities, expected to be in place before July 1,1980, include Geiger-Muller survey meters, and air sampling and field analysis for airborne radiciodines. h one role of these measurements h
r is to support or refute the assessment tactic described above.
absence of measurements is unlikely to impede recomendation of protective actions for severe accidents.
Response times for the site in question range from a mininun of one hour to several hours.
(Reilly,BRP)08-006 Provide documentation which evidences Ilcensee contact with the Conmonwealth regarding the 50-mile EPZ for Ingestion Exposure and the necessary mergency plans for coping with a release which would require implementation of protective l
actions within the Ingestion EPZ.
RESPONSE
This agency does not n 'ntain records of such contacts with the Licensee.
(Reilly,BRP) r s03-007 In response to NGY interrogatories to the Connonwealth
- 16, Col. Henderson lists assumptions utilized in determining evacuation time requirements.
The assumption of " prior mobilization and stationing of emergency forces from State and county" appears to be indefensively optimistic and does not reflect the reality of the situation.
In the event of another accident at 'IMI requiring evacuation, numerous persons, including,
fire fighters, have stated that they would not stay, but would evacuate with the rest of the population.
In addition, there are numerous accident sequences which would not pernit prior '
mobilization of emergency forces and their stationing at appropriate locations. Thirdly, many of these persons have families of their own which they would naturally consider to be their first responsibility in the event of an accident serious enough to require a general evacuation.
In view of these points, to what extent are the evacuation time estimates provided in answer to MURY interrogatory #16 sensitive to the assumption of prior nobilization and stationing of emergency forces from the State and counties? If it is assumed that no prior nobilization and stationing, or only partial nobilization and stationing is possible prior to the evacuation order going out, how much longer could the evacuation require?
RESPONSE
i Evacuation plans--and asstcptions associated there.dth--n'ay be I
considered the initial information base, to which elected officials and their agents nust add specific details of the evolving emergrney sinution in order to make appropriate decisions and initiate adeque.f.e response actions.
The assumption of " prior nobilization and stationing of emergency forces from State and county" refers to novement time for evacuation of 1007. of 'the population under optimum conditions. Ovbiously, adverse weather, nore stringent time constraints, prior spontaneous evacuation of portions of the populace, dedication of public servants, and other considerations would have an impact on total evacuation time requirements.
In general, with less preparation time one can anticipate a less orderly and nere time consuming evacuation movanent.
(Henderson,PDR)08-008 Licensee's emergency event classification scheme and the scheme used by the Comanwealth are very dissimilar.
In view of recent events (i.e., the releases of radiation from Unit 2 and subsequent failure of timely notification by the Licensee),
how do these differences in event classification lend maxinun protection to public health and safety when there is such a clear opportunity for human error in interpreting events and classifying than?
RESPONSE
Licensee's emergency event classification scheme and the one,used by the Comanwealth are not that dissimilar (see agreement letter from Metropolitan Edison attached). Commrraealth generalized the initial notification to provide sin:plicity and speed to the initial notification.
h release from Unit 2, referred to, had nothing to do with classification.
NUREG-0610, dated September,1979, has since been adopted by both Licensee and Camenwealth for event classification.
(Henderson,PEbR)08-009 In 1974, then Governor Milton Shapp apointed a Fact-Finding Comnittee to investigate health effects allegations about radioactive releases from the Shippingport Ibclear Power Station.
ht Fact-Finding Comittee (hereinafter referred to as GFFC, Governor's Fact-Finding Comittee) made numerous recomendations regarding radiation monitoring. Anong these recomendations were:
ht the Comrotraealth inmediately begin an a.
independent comprehensive environmental radiation monitoring program in the vicinity of all nuclear reactors in the Comonwealth, and that the results fran such a program should be freely available to the public.
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h e a certified Health Physicist be located at each plant to review environmental radiation monitoring program results.
Five years later during the 'IMI-2 accident, it was clear that these recmmendations had not been followed through. he steps are the various Connonwealth agencies taking to ensure that the many reconmendations made as a result of the 'IMI-2 accident are followed through to their completion? What steps is the Coranonwealth taking to nonitor Licensee followthrough on conmitments made in the wake of the Unit 2 accident?
RESPONSE
Objection. Counsel for the Connonwealth and staff of the Bureau of Radiation Protection have examined this interrogatory at length and reluctantly have concluded that the Catmenwealth nust object to this interrogatory in its current vague and confusing form.
'Ihe first ground of our objection is that the two questions asked appear to bear no relationship to the previous statements, unless the preliminary statenents were intended to narrow the questions ~ to the subjects of nonitoring and cmployment of certified health physicists.
If that is the function of the preliminary statement, Mr. Sholly should so state. Otherwise, we do not know stat the questions were intended to meaa ss nodified by the preliminary statement.
Second, we do not know whose reconmendations to stat agencies on stat subjects and stat conmitments to what agencies on what subjects are the bases of the two questions. Recoranendations have been made by many entities and individuals, on many subjects, published and unpublished, official and unofficial since March 28, 1979. We do not object to answering properly framed questions about such matters (see, e.g.,
Connonwealth's response to ANGRY Interrogatory No. 30.) However, counsel for the Connonwealth needs enough infonnation to be able to refer the interrogatory to the appropriate state agency, if not the appropriate e
9 individual, for resp e e.
Unfortunately, Mr. Sho11y's interrogatory is not sufficiently precise to enable counsel to do that. However, the Connonwealth does believe that the interrogatory could be redrafted to be clear, conprehensible and answerable along the lines of ANGRY interrogatory No. 30. 'Ihe Comonwealth is ready to answer such an interrogatory, and to urge that the Board give Mr. Sholly an opportunity to submit such a redrafted interrogatory to the comonwealth as soon as Mr. Sholly is able to do so.
(This response, although styled an objection, should rot be construed as an acknowledgement of any legal duty of a non-party in an NRC proceeding to respond to interrogatories or object t'
to then.).
Respectfully submitted, U-i KARIN W. CARTER i
Assistant Attorney General Attorney for The Comvalth of Pennsylvania March 17, 1980 e i
E u nocomespexpgygy 1NITED STATES OF AMERICA NUCLEAR REGUIAIORY 00ttiISSION BEEDRE TIE ATOMIC SAFEIY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON 00fANY,
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Dociwt No. 50-289
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IMRGAFSr A. REILLY, being duly sworn according to law, deposes and says that she is Chief of the Er:Ironmental Radiation Division, Bureau of Radiation Protection, Departrent of Enviruuuuutal Resources; and that the infornution contained in Conurmalth's Response to Interrogatories of Steven C. Sholly (First Set) nt=bered 08-005 and 08-006 is true and correct to the best of her knowledge, inforuntion and belief.
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OEl.1 MARGARET A. $EILLY
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Chief, Enviw uacntal Radiation Division Bureau of Radiation Protection Sworn to and subscribed before me this // t/s day of March,1980.
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