ML19309D350
| ML19309D350 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/17/1980 |
| From: | Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Sholly S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19309D344 | List: |
| References | |
| NUDOCS 8004100285 | |
| Download: ML19309D350 (13) | |
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March 17, 1980 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 INTERROGATORIES (SECOND SET) FROM STEVEN C. SHOLLY INTERROGATORY NO.08-013 From among the persons who contributed to the Licensee's Emergency Plan, either by writing the plan or by providing supporting analy-ses 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 traffic 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.
RESPONSE-
[ With respect to the areas listed in items (a), (b), (c) and (d) of this interrogatory, Licensee has relied upon the expertise-and guidance of State and local emergency management. agencies. In the area of meteorology, Licensee has relied upon the. firm of M004106 1 bW
Pickard, Lowe and Garrick, Inc., 1200 18th Street, N.W., Suite 612, Washington, D.C., as well as Tom Walsh, a Meteorologist em-ployed by GPU. The background information requested with respect to Pickard, Lowe & Garrick and Mr. Walsh will be placed in Li-censee's Discovery Reading Room.
INTERROGATORY NO.08-014
- According to NUREG-0396 at page 18, major radiation releases frem nuclear power plants can begin within as little as 30 minutes after the start of the initiating event. Specify how this fact is recon-ciled with the assumptions in county emergency plans on which Li-censee 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 actions to be implemented on a timely basis within the Plume Exposure EPZ. Discuss each county plan separately in responding to this interrogatory.
RESPONSE
4 Licensee's Emergency Plan contains provisions for prompt recognition of accidents and prompt notification of state and local officials. The redefined accident classification system i requires pro'mpt notification of abnormal situations and the potential for releases. The classification hierarchy is de-signed to be anticipatory for all events which might impact public health or safety in order to provide maximum lead time to state and local officials. These considerations are applicable to all county plans.
INTERROGATORY NO.08-015 Provide a map of suitable scale which delineates clearly the geo-graphic extent of the Licensee's proposed Ingestion Exposure EPZ.
x This map must show all counties which fall within this EPA [ sic]
as well as the locations of towns and cities within the EPZ as proposed by Licensee.
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RESPONSE
Figure 6 of Licensee's Emergency Plan provides guidance on the extent of the ingestion exposure EPZ. Licenseg is in the process of preparing a map of large: scale as part of its emer-gency planning activities and will place a copy of the map in Licensee's Discovery Reading Room when it is completed.
INTERROGATORY NO.08-016 Provide copies of the most recent letters of agreement and und'er-standing 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 t show evidence of contact between Licensee and the government agen-cies with regards to the Ingestion Exposure EPZ. Where neither a letter of agreement or understanding nor documents which show evi-dence of such contact exist (s), explain why and provide a schedule-for making such contacts and obtaining letters of agreement and understanding with regard to emergency planning within the Inges-tion Exposure EPZ.
RESPONSE
The protective measures to be taken in the ingestion pathway EPZ are the responsibility of state governments and not of the counties. Therefore, letters of agreement between Licensee and the counties would not be expected to cover such measures. Li-censee's current letters of agreement with state agencies are in-cluded in Appendix C to the Emergency Plan.
INTERROGATORY NO.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 par-ticular site is dependent on the characteristics of that site.
In this light, provide the factual basis for the proposed cir-s cular EPZ's for both Plume and Ingestion Exposure Pathways, speci-
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fying 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.
RESPONSE
In accordance with NRC guidance, Licensee has committed to EPZ's of 10 and 50 miles. The responsibility for defining the precise boundaries of these EPZ's is that of the state and local governments, and Licensee has relied on their judgment in this area.
INTERROGATORY NO.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 documenta-tion which confirms that Licensee has in fact contacted each such milk processing plant and that letters of agreement and under-standing 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 emergency response planning.
RESPONSE
Licensee has not contacted milk processing plants and has not executed any letters of agreement with such facilities. The responsibility for contacting milk processing plants and assuring that appropriate protective measures can be taken if necessary, resides with the Commonwealth of Pennsylvania.
i INTERROGATORY NO.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 use-ful in emergency planning. Identify each statement in Licensee's Emergency Plan which takes into account any accident beyond the design basis of TMI-1. Specify how Licensee's Emergency Plan takes into account accidents beyond '.Le design basis for TMI-1, I particularly with reference to assurnptions utilized in determining the time availabla for identification of an accident, assessment i
s of the sericuenass of the accident, notification of off-site authorities, implementation of protective actions, and confirmation f of the completion of the protective actions.-
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RESPONSE
See Licensee's response to Sholly Ir.cerrogatory (First Set)
No.08-006.
INTERROGATORY NO.08-020 NUREG-0396 at page I-6 states that Class 9 accidents cover a full spectrum of releases of radioactivity which range from those acci-dents which are on the same order as the DBA-LOCA type of release to those accidents which release significant fractions of the available radioactive materials in the reactor to the atmosphere.
The lower range of the spectrum of Class 9 accidents is described to include accidents in which a core " melt-through" of the con-tainment 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 Li-consee's Emergency Plan and the Emergency Plan Implementing Docu-ment. Where such documents do not exist, discuss with specificity how Licensee's Emergency Plan has taken into account these acci-dents.
RESPONSE
See Licensee's response to Sholly Interrogatory (First Set)
No.08-006.
INTERROGATORY NO.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 [ sic] safety systems."
If Licensee believes this to be [a] true statement, then Licensee is requested to explain 1.ow a Class 9 accident occurred at Unit 2 of the TMI Nuclear Staticn. 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 re-sponse of both systems and people," (Emergency _ Plan, Amendment 6, November 1979, pages 2-5 and 2-6), how the fact that. engineered safety systems cannot be relied upon to miti' gate 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.
RESPONSE
Licensee believes its statement in the Emergency Plan to be i
accurate. Prior to termination of the engineered safety systems, those systems functioned properly and did mitigate the consequences of the Unit 2 accident. The lessons learned from the TMI-2 acci-4 dent have suggested changes in equipment, procedures and training so that safety equipment is not prematurely terminated. These
. changes are described in Licensee's Restart Report.
INTERROGATORY NO.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 rapid evaluation of plant conditions against emergency action levels so as to, promptly recognize and declare emergencies (within 10 minutes of event) . "
i In the light of the fact that over 2-1/2 hours elapsed between the start of the Unit 2 accident and the declaration of a Site Emer-gency, 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. Dis-cuss also the training given to reactor operators and shift super-visors which assures that this 10-minute emergency declaration commitment will be met.
RESPONSE
NUREG-0610 requires that numerous and diverse indications of potential accident conditions be considered by plant operators.
The Emergency Plan includes a description of these indicators
, (see SS 4.4.1 & 4.6.2). In addition, procedures are being de-veloped that will incorporate these emergency action level criteria.
Licensee has adopted the emergency action level criteria in NUREG-0610 to ensure timely assessment of accident conditions ~.
Reactor operators and shift supervisors will be trained pursuant to the accelerated operator retraining program in the new emer-gency plan including emergency action levels and the criteria for assessing accidents and declaring the various otates of emergen-cies (see Restart Report at S 4.4.8.1).
t INTERROGATORY NO.08-023 At page 2-7 of the Restart Report (Amendment 6, November 1979),
it is stated that the State Plans and the TMI Emergency Plan were developed in close coordination. Provide documentation which' veri-fies that this is true. Provide names of State personnel and representatives who worked with Licensee in developing and coor-dinating the State Plans and the TMI Emergency Plan.
RESPONSE
I Key state personnel involved in the writing of the state plan and TMI emergency plan include: Oran Henderson; Craig Williamson; Dick Lamison; Jim Lothrop; Carl Kuehn; Charles A.
Crowe; Charles Blaisdell; and Bill Karl. Minutes of meetings with state personnel will be placed in Licensee's Discovery Read-ing Room.
INTERROGATORY NO.08-024 Specify any and all assumptions upon which the TMI Emergency Plan is based. Discuss each such assumption and explain why it is ap-propriate and what it's (sic] basis is in fact.
RESPONSE
Licensee has objected to this interrogatory.
-INTERROGATORY NO.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 response: .
- a. Recognition of condition which fulfills one of e
the emergency event classes;
- b. Assessment of the seriousness of this condition;
- c. Initiation and completion of all required notifi-cations;
- d. . Implementation of necessary emergency response;
- e. Confirmation that emergency response (protective action) has been completed.
RESPONSE
Every emergency response is likely to be unique. Plant con-ditions will vary and Licensee's assessment of these conditions also will vary. It is thus not possible to formulate meaningful time estimates for each step requested in this interrogatory.
Prompt recognition and initiation of notifications (within 10 minutes) is a chief goal of the Emergency Plan and Licensee believes that the provisions of the Emergency Plan are adequate to achieve this goal. If further assessment of plant conditions indicates' a need, the emergency event will be reclassified to a j higher or lower level than made during the initial assessment.
INTERROGATORY NO.08-026 Provide a description of the means to be used by Licensee to notify the general public, including transients, of an emergency condition at the TMI site. Include documents which depict the existence of agreements with local media, Civil Defense, educational, and other groups which will be depended upon to provide the emergency noti-fications.
RESPONSE
See Licensee's responses .to Sholly Interrogatory (First Set)
Nos.08-007, 08-008 and 08-009.
a INTERROGATORY NO.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 moni-toring_and increased security), describe the nature and scope of
the support services to be provided and the qualifications of each organization to provide such services.
RESPONSE
, . Licensee is in the process of collecting qualifications data for contractors who may be called upon to provide support services during an emergency at the TMI site. This information 4
will be placed in Licensee's Discovery Reading Room as it becomes available. Letters of Agreement which already exist for the majority of contractors are included in Appendix C of Licensee's [
I INTERROGATORY NO.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, including the expertise of available personnel, the time frame within which their assistance would be available, and other re- .
l sources which each body would be expected to provide in the event of an emergency.
RESPONSE
Licensee depends on PEMA for implementation of protective actions. Details on the response capabilities of PEMA are in the Pennsylvania Disaster Operations Plan Annex E; details on the response capabilities of the affected counties are in the appropri-ate County Emergency Plans.
l INTERROGATORY NO.08-029 l
. 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.
RESPONSE -
l The radiation exposure guidelines followed by Licensee are those. set forth in 10 C.F.R. Parts.20, 50, and 100 of the Commis-
! sion's Regulations. These regulations are implemented when off-site assistance personnel arrive onsite at a control point by assigning health physics personnel to be with oncoming individuals or groups.
INTERROGATORY NO.08-030 Provide documentation which shows that all outside agencies which are depended upon by Licensee for medical and firefighting ser-vices are aware of the guidelines addressed in Interrogatory 08-029 and that these organizations are cognizant of these guide-lines and understand their implications with regard to providing the required services.
RESPONSE
Radiation exposure guidelines for offsite support groups who may be called on to provide onsite services are addressed in an-nual training sessions conducted by Licensee. These training ses-sions are described in Chapter 8 of Licensee's Energency Plan.
INTERROGATORY NO.08-031 Provide documentation which shows that hospital and medical per-
- sonnel who are relied upon by Licensee to provide emergency ser-vices are qualified to accom[mlodate radiological emergencies, especially injured persons who may also be radioactively. con-taminated.
RESPONSE
Radiation Management Corporation and Hershey Medical Center are the organizations relied upon by Licensee to provide these services. Their resources are committed to Licensee by, and de-scribed in, the Letters of Agreement.
INTERROGATORY NO.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 acceptable criteria for the implementation of these types of assistance.
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RESPONSE
Other than the existing Letters of Agreement, Licensee does not possess documents specifying the assistance to be rendered or the criteria for implementation. The program to update the Letters of Agreement (see Licensee's response to Sholly Interroga-tory (First Set) No.08-009) will provide additional information
! in this area.
INTERROGATORY NO.08-033 Detail each responsibility of the Shift Supervisor under condi-tions of a Site Emergency and a General Emergency. Describe, for each Shift Supervisor, any and all training received which qualifies them to make judgments regarding protective actions (i.e., health physics training, medical degree with specializa-tion in radiation protection, etc.).
RESPONSE
During Site and General Emergencies and in the course of events that led to their declaration, the shift supervisor is re-quired to take the following actions:
(1) Classify the event; (2) Ensure safe operation of the plant by implementa-4 tion of emergency procedures; (3) Ensure that immediate notification requirements are met; (4) Dispatch Radiological Monitoring Teams; and
,( 5) Assess plant conditions and respond.
In order to fulfill these tasks, shift supervisors receive periodic training (see Restart Report Question 40, Supp. I, Part I and Ques-tio,n 25, Supp. I, Part II). This training includes information about the EPA developed Protective Action Guides which form the basis of the state and local protective measures. .
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4 INTERROGATORY NO.16-005 .
t 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 nonproprietary in nature and can be released publicly without violating NRC regulaticus. ;
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RESPONSE
Licensee's documents which are nonproprietary and which re-late to security at TMI Unit 1 and Unit 2 are as follows:
(a) Memorandum on Unit 2 Contractor / Vendor Photo-Identification Re-badging; promulgation of .
schedule and general instructions pertaining to, dated November 13, 1979.
f (b) Memorandum on Site Protection Personnel, dated l
December 5, 1979. .
(c) Memorandum on TMI Physical Security, dated December 10, 1979.
(d) Training outline.
These documents are being placed in Licensee's Discovery Reading Room.
i INTERROGATORY NO.16-006 Will Licensee maintain separate security forces for Unit 1 and Unit 2? If so, how will this separation be assured? If not, why not?
RESPONSE
Licensee maintains separate security forces for TMI Units 1 and 2. This separation is achieved through the use of physical s_, barriers that divide the TMI Station so that both TMI Units 1 and 2 have separate owner-controlled areas, protected areas and vital areas.
4 A separate and distinct badging system is in place for each unit which identifies through the use of color-coded photo identi-fication badges those security personnel authorized access to the 4
respective units. This physical and employee separation isolates r l Unit 1 and Unit 2 from each other.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: [ 7 i
l Rober 5. Zahlet i
Dated: March 17, 1980 t
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