ML19320D785

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Responses to NRC Second Set of Interrogatories.Includes Info Re State Plan Review,Role of Local Agencies in Emergency Response Test Exercise & Absence of Offsite Monitoring Devices in Safety Evaluation
ML19320D785
Person / Time
Site: Crane Constellation icon.png
Issue date: 07/08/1980
From: Bradford G
ANTI-NUCLEAR GROUP REPRESENTING YORK
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19320D779 List:
References
NUDOCS 8007220209
Download: ML19320D785 (2)


Text

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ANGRY 7/8/80 (M% /

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COIGIISSION O

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>p BEFORE THE ATOMIC S AFETY AND LICENSING BOARD

,g1 In the Matter of J

METROPOLITAN EDISON Co.

Docket No. 50-289 ET AL.

ANTI-NUCLEAR GROUP REPRESENTING YORE'S RESPONSES TO THE NRC ST-AFF'S SECCND SET OF INTERROGATORIES 3

As the SER relates to Emergency Planning, ANGRY has a basic problem with it.

It does not discuss whether the Staff finds the Licensee"s and state and local Plans in compliance with the current Regulation, N. 0654 We note on page C3-2 that The Review by the Regional Advisory Committee is expected in the Summer of 1980.

We find the SER deficient because it fails to address IJ.0654 2-1.

We have no reason to either believe or disbelieve that the State Plans will be reviewed against N.75/111 from reading page C3-2 as directed.

N. 75/111 is not mentioned.

If by this cuestion the StaffmeansN.0654,notN.75/111,thenweNoreasonnottobelievethat the Regional Advisory Committee is reviewing the Plans as is stated.

2-2 We di not believe that all State and local " agencies" whose participation and cooperation is necessary for cetual Emergency Response will be part of the test exercise.

Please refer to ANGRY Revised Contention (6/30/80) for specifier tions.

The " existence of provi-sions"-referred to in the SER (p. C3-4) is vague and insufficient.

Gan the NRC recuire the Red Cross or the hospitals or any other

" support group" to participate in a test exercise?

We have not seen evidence to indicate that the Licensee has " coordinated" with many of the " support groups"' listed on paper in their plans. The SER does not mention all support groups, only just a very few. (C3-3) 80072203a7

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a 2-3 We find no mention in the SER of " permanent offsite monitoring devices which register all forms of ionizing radiation and which can be remotely read" (ANGRY Contention IIFal).

24 Please refer to ANGRY Revised Contentions (6/30/80).

Emergency Response is only effective if the local people and equipment needed are ready, willing and able to perform their parts.

No effort has been shown in the SER to assess the actual emergency preparedness as opposed to the rarer Plan.

Does the NRC allow the use of untested hardware, or unconnected 'cardware?

We believe the Staff's evaluation of the Emergency Plan is very seriously deficient because they have not extended their view beyond the " control room" parts of the machinery of the plan.

What, if anything, does the' control room" operate?

The SER does not address this question.

3-1 Yes.

See above.

Interrogatories 4 through 5 to follow separately.

~

July 8, 1980.

Respectfully submitted.

Gail P. Bradford,

//

/ legal coordinator fo"r AN6RY.

717/843-7705

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