ML19309D659

Followon Interrogatory Directed to State of PA Re Restart Proceeding.Requests Identification of All Repts,Studies & Documentation Relied Upon in State of PA Response to Interrogary 23(b).Certificate of Svc Encl

ML19309D659
Person / Time
Site:	Three Mile Island
Issue date:	03/27/1980
From:	Bowers J ANTI-NUCLEAR GROUP REPRESENTING YORK
To:	PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 8004110095
Download: ML19309D659 (3)

Text

' e - ANGRY 3/27/80 UNITED STATES OF AMERICA g 8/

NUCLEAR REGULATORY COMMISSION USNRC -

3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I > [

Office of the Secretary

• In the Matter of ) 00thetitig & Sonice Y t;b Branc

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 y 6 (THree Mile Island Nuclear (Restart) O

)

Station, Unit One) )

)

ANTI-NUCLEAR GROUP REPRESENTING YORK FOLLOW-ON INTERROGATORY TO COMMONWEALTH OF PENNSYLVANIA Fursuant to authorization by the Board in its Fourth Special Prehearing Conference Ordar, p. 23, interve".or AntiNuclear Group Representing York hereby propounds follow-on interrogatories to the Commonwealth of Pennsylvania in regard to its response to ANGRY interrogatory #23(b).

40. Identify all reports, studies, or other documentation relied upon by the Comonwealth in providing this response.

a. Specify the radiological release characteristics, particularly the source-release duration time, assumed in the first paragraph of the Commonwealth's response to interrogatory #23(b).

b. Specify any differences in the radiological release characteristics assumed in the first and third paragraphs, respectively, of the Commonwealth's response.

c. Under the conditions postulated would the Commonwealth make the emergency reapafige recommendation set forth in paragraph 3 regardless of wind speed and warning time?

d. Were the emergency response recommendations set forth in paragraphs 1 and 3 of the Commonwealth's response based upon comparative dose reductions factor calcule.-

tions for the alternative emergency response options of evacuation and shelteriftng respectively? If yes, please attach copies of documentation in which such calcula=

tions are set forth. If no, explain in detail the baces for the Cocmonwealth's total rejection of sheltering as an appropriate &mergency response under the postulated conditione.

e. Does the Commonwealth employ a system or procedure for emergency response selectios equal or similar to that described in pages 35-51 of the document referenced at footnote #1(3) os page 55 of NUREG 06547 If yes please describe the system so employed by the Commonwealth in detail. If no, does the Commonwealth have any intention to adopt such a system or procedure?

f. Does the Commonwealth perceive any inconsistency between the emergency response recommendations it has set forth in paragraphs 1 and 3 of its response and the following language from page 1 of NUREG 0610:

The immediate action for this class (general emergency) is sheltering (staying inside) rather than evacuation until an assessment can be made that 1) an evacuation is. indicated and 2) an evacuation, if indicated, 9004110 N

can be completed prior to significant release and transport of l radioactive material to the affected areas.

Explain in detail the bases for the Commonwealth's belief that under the postulated conditions its recommendation would afford greater protection to public health and safety than that quoted from NUREG 0610.

Respectfully submitted, At.ti-Nuclear p Representing York i

By: W Bowers i

I.

0 3

UNITED STATES OF AMERICA

?ICLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY A!D LICENSING BOARD In the matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

)

(Three Mile Island Nuclear Station, )

Unit No. 1 )

i CEDTIFICATE OF SEPVICE I hereby certify that I have this 27th day of March, 1980, served copies of the foregoing Follow +on Interrogatories to the ~

Commonwealth of Pennsylvania  ;

, on each of the following persons by deposit in the United St ates mail, post age prepaid.

Ivan W. Smi th, Esq. Docketing and Service Section Atomic Saf ety and Licensing Board Of fice of the Sec retary U.S. IMclear Regulatory Commission U.S. Nuclear Regul atory Commission Washington, D.C. 20555 Washingt on, D.C. 20555 Dr. Walter H. Jord an James A. Tou rt el lot te, Esq. I 881 W. Outer Drive Office of Executive Legal Direct or ;

Oak Ridge, Tennessee 37830 U.S. Nuclear Regul atory Commission Washington, D.C. 20555 l

i Dr. Linda W. Little George F. Trowbridge, Esq.

5000 Hermitage Drive Shaw, Pittman, Potts & Trowbridge R ale igh, North C arolina 27612 1800 M Street, N.W.

Washingt on, D .C. @)))9 Karin W. Carter, Esq.

, Assist ant Attorney General 505 Executive House P.O. Box 2357 H arrisbu rg, Pennsylvania 17120 4 \

Holly S. Keck D at ed: March 27, 1980 I

i