ML19309A706

First Set of Interrogatories & Document Requests.Includes Questions Re Communications Links Between State Agencies & Licensee & State & Licensee Emergency Event Classification Scheme.Certificate of Svc Encl

ML19309A706
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML19309A704	List: ML19309A703 ML19309A706 ML19309A708 ML19309A709
References
NUDOCS 8004010040
Download: ML19309A706 (7)

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S- USNT UNITED STATES OF AMERICA FEB 2 71980 P 3 NUCLEAR REGULATORY COMMISSION 9' ottice et the secreten gng & Senice .

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '/

cv to In the Matter of METROPOLITAN EDISON COMPANY Doc No 0-289 (Three Mlle Island, Unit 1)

INIERVENOR STEVEN C. SHOLLY FIRST SEI 0F INTERROGATORIES AND DOCUMENI REQUESTS TO THE COMMONWEALTH OF PENNSYLVANIA Steven C. Sholly, Intervenor, hereby files the following interrogatories and document requests with the Commonwealth of Pennsylvania pursuant to 10 CFR 2.740 and 2.741. Interrog-atories are to be answered fully, in writing, and under oath by any officers of the Commonwealth who have personal knowledge of the facts sought by the interrogatories. The answer to each interrogatory is to contain the names and identifications of the person (s) supplying the answer.. All documents relied upon in supplying the answers to the interrogatories are to be referenced according to title, author (s), source of the document, and page numbers utilized in supplying the answers.  !

l These interrogatories and document requests are deemed to l be continuing and are to be supplemented as required by NRC regulations. Interrogatories and document requests are arranged according to the Contention numbers and sequential number of j the interrogatory or document request (i.e.,13-005 would refer to interrogatory or document request #5 for Contention #13).

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08-001--Describe the communications links between agencies of the Commonwealth and the Licensee's control room for TMI-1. In the description, describe the extent to which backup, redundant links exist, and, if none exist, the conditions under which the communications link could fall to work properly.

08-002--What is the Commonwealth's position regarding the sufficiency of Licensee's Emergency Planning Zones (EPZ's) for Plume and Ingestion Exposure Pathways?

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 were developed. Provide documentation which would either support or refute this claim, including in such documents letters, transcripts of meetings, and other memoranda which deal with development of emergency plans and coordination between the Common-I wealth's plan and Licensee's plan.

08-004--Provide a copy of the most recent letter of understanding l

with Licensee regarding Commonwealth assistance during emergencies at TMI-1.

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08-005--To what extent does the Commonwealth have the capability to independer tly assess the magnitude and composition of radioactive releases from TMI-I in the event of an accident? How long might it take for the Commonwealth's monitoring capabilities to be placed in service (provide upper and lower bound estimates k sed on best possible response and a worst case response, i.e. , a middle-of-the-night incident during a snowstorm or heavy rain)?

l 08-006--Provide documentation which evidences Licensee contact with the Commonwealth regarding the 50-mile EPZ for i Ingestion Exposure and the necessary emergency plans for coping with a release which would require implementation of protective actions within the Ingestion EPZ.

i 08-007--In response to ANGRY Interrogatory to the Commonwealth

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1. 16, Col. Henderson lists assumptions utilized in determining evacuation time requirements. The assumption of " prior mobilization and stationing of emergency I

forces from Stato and county" appears to be indefensively optimistic and does not reflect the reality of the situation.

In the event of another accident at TMI 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,

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• 1 4 j there are numerous accident sequences which would not permit prior mobilization of emergency forces and their stationing at appropriate locations. Thirdly, i

many of these persons have families of their own which 1 they would naturally consider to be their first responsibility in the event of an accident serious l enough to require a general evacuation. In view of these points, to what extent are the evacuation time estimates provided in answer to ANGRY interrogatory

1. 16 sensitive to the assumption of prior mobilization and stationing of emergency forces from the State and counties? If it is assumed that no prior mobilization and stationing, or only partial mobilization and stationing is possible prior to the evacuation order going out, how much longer could the evacuation require?

08-008--Licensee's emergency event classification scheme and the scheme used by the Commonwealth 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 maximum. protection to public health l and safety when there is'such a clear opportunity for for human error in interpreting events and classifying them?

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08-009--In 1974, then Governor Milton Shapp apointed a Fact-Finding Committee to investigate health effects allegations about radioactive releases from the Shippingport Nuclear Power Station. That Fact-Finding Committee (hereinafter referred to as GFFC, Governor's Fact-Finding Committee) made numerous recommendations regarding radiation monitoring. Among these recommendations were: ,

a. That the Commonwealth immediately begin an independent comprehensive environmental radiation monitoring program in the vicinity of all nuclear reactors in the Commonwealth, and that the results from such a program should be freely available to the pubilc.

b. That a certified Health Physicist be located at each plant to review environmental radiation monitoring program results.

Five years later during the TMI-2 accident, it was clear that these recommendations had not been followed through. What steps are the various Commonwealth agencies taking to ensure that the many recommendations made as a result of the TMI-2 accident are followed 1

through to their completion? What steps is the Commonwealth l taking to monitor Licensee followthrough on commitments made in the wake of the Unit 2 accident?

Respectfully submitted, DATED: 25 February 1980 g <g Steven C. Sholly , .

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

Dock No -289 METROPOLITAN EDISON COMPANY (Three Mlle Island, Unit 1)

CERIIFICATE OF SERVICE I hereby certify that single copies of INIERVENOR STEVEN C.

SHOLLY FIRST SEI 0F ~1NIERROGATORIES AND DOCUMENT REQUESTS TO THE COMMONWEALTH OF PENNSYLVANIA were served upon the atta :hed service ilst by deposit in the United States Mall, postage prepaid, on the 25th of February 1980.

rf F Stdven C. Sholly ' '

Ivan W. Smith, Esq. Docketing and Service Section Chairman, Atomic Safety and Office of the Secretary Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 John A. Levin, Esq.  ;

Dr. Walter H. Jordan Assistant Counsel Atomic Safety and Licensing Pennsylvania Public ,

Board Panel Utility Commission l 881 West Outer Drive P.O. Box 3265 1 Oak Ridge, TN 37830 Harrisburg, PA 17120 )

1 Dr. Linda W. Little Karin W. Carter, Esq.

Atomic Safety and Licensing Assistant Attorney General l Board Panel Commonwealth of Pennsylvania 1 5000 Hermitage Drive 505 Executive House Raleigh, NC 27612 P.O. Box 2357 Harrisburg, PA 17120 James A. Tourte11otte, Esq.

Office of the Executive

Legal Director (OELD)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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1 John E. Minnich Holly S. Keck Chairman Legislation Chairman Dauphin County Board of ANGRY Commissioners 245 West Philadelphia Street  ;

Dauphin County Courthouse York, PA 17404 1 Front and Market Streets  !

Harrisburg, PA 17101 Robert Q. Pollard l Chesapeake Energy Alliance l Walter W. Cohen, Esq. 609 Montpelier street  !

Consumer Advocate Baltimore, MD 21218 Department of Justice 14th Floor, Strawberry Square Chauncey Kepford Harrisburg, PA 17110 Environmental CoalltLon on i

Nuclear Power Jordan D. Cunningham, Esq. 433 Orlando Avenue Attorney for Newberry State College, PA 16801 Township TMI Steering Committee Marvin I. Lewis 2320 North Second Street 6504 Bradford Terrace Harrisburg, PA 17110 Philadelphia, PA 19149 Theodore A. Adler, Esq. Marjorie M. Aamodt Attorney for TMIA R.D. # 5 Widoff, Reager, Selkowitz, Coatesville, PA 19320 and Adler P.O. Box 1547 George F. Trowbridge, Esq.

Harrisburg, PA 17105 Attorney for LLeensee Shaw, Pittman, Potts, &

Ellyn Weiss, Es Trowbridge Sheldon Harmon,q.& Weiss 1800 M Street, hv Attorney for UCS Washington, D.C. 20036 Suite 506 1725 I Street, hv Washington, D.C. 20006 Karen Sheldon, Esq.

Sheldon, Harmon & Weiss Attorney for PANE SuLte 506 1725 I Street, hv Washington, D.C. 20006 1

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