ML19322E640

First Set of Interrogatories Directed to Nrc.Supplements Sc Sholly 800117 Interrogatories Re Restart Proceeding. Includes Questions Re Quantity of Radiation,Adequacy of Emergency Plan & Ingestion Exposure.Certificate of Svc Encl

ML19322E640
Person / Time
Site:	Three Mile Island
Issue date:	03/13/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8004020044
Download: ML19322E640 (7)

Text

• UNITED STATES CF AMERICA NUCLEAR REGULATCRY CCSD1155ICN BEFrRE THE ATCMIC M FETY AND LICENSI.';G Br APD In the Matter of )

MEIRCPCLITAN EDISCN CCMPANY Doc t 9 sat (Three Mile Island, Unit 1) )

INTERVENCR STEVEN C. SHCLLY FIRST SET OF FCLLCW-CN INTERRrGATORIES TO NRC STAFF Intervenor Steven C. Sholly flied on 1/17/80 a set of interrogatories and document requests with NRC Staff.

On 3/7/80, a partial response (dated 2/29/80) was received.

Pursuant to the Board's Fourth Special Prehearing Conference Order, Intervenor Sholly poses the following " follow-on" discovery requests to the NRC Staff:

Follow-on Interroaatory to Resoonse to Question 1-4 This interrogatory requested an estimate of the amount of radioactivity released to the environment as a result of the failure of containment isolation to occur when there was a high -level of contamination in the reactor sump line. The Staff implies that the interrogatory implies that a large quantity of radiation was released as a result of this set of circumstances , and states , "Most of the radioactivity released resulted from letdown line leakage in the auxiliary building and was not a result of failure of containment isolation . . . The interrogatory makes soo4esoo+4.c;.,

no reference whatsoever to releases due to makeup-letdown system actLvLty during the accLdent. The interrogatory very clearly asks for an estimate of the radtoactivity which was released due solely to late contatnment isolation.

Again, the Lnterrogatory is posed: Has Ltaf f estimated the quantLty of radiation released to the environment as a direct fatlure of the Unit 2 containment to isolate and orevent onmolne of the reactor buildine sumo to the auxtilary butidtre? If so, provide this data.

Follow-on InterrnFatorv ln Resoonse to Question 5-1 In response to Question 1-4, Staff states 14 curles of I-131 were released during the entire accident. Yet in the response to Question 5-1, staff cites the maximum release rate for Lodines on March 30th as being "about 20 CL/sec".

a. Is the 20 CL/see figure correct?

b. If so, how does Staff reconcile this with the total estimated I-131 release figure given in response to Question 1-47

c. What was the isotope makeup of the 20 CL/sec release rate?

Follow-on Interroaatory in Resoonse to Ouestion 8-1 This question asked the Staf f whether Lt felt that Ltcensee's ,

1 Emergency Plan can be fully evaluated wLthout reviewing the Emergency Plan Implementing Procedures. Staff answered.

" Prior to restart as part of the long-term program the Staff will review the Emergency Plan Implementing Procedures."

ThLs does not answer the question. Intervenor Sholly requests that Staff answer the original question and explain Les answer. Also. Staff's response prompts the following interrogatory:

a. Why does Staff consider the Emergency Plan Implementing Procedures to be a "long-term" ttem? Specifically address the issue of whether the Emergency Plan can be expected to protect the public health and safety if the Emergency Plan Implementing Procedures are inadequate.

Follow-on Interrogatory in Resoonse to Question 8-2 This interrogatory asked Staff if the Emergency Plan submitted by the Licensee contains sufflctent information about the Ingestion Exposure EPZ. Staff responded, "The ingestion exposure EPZ is part of the long-term program and outside the scope of the Commission's Order."

Contention 8, subparts "N" and "U" deal with the ingestion exposure EPZ and by their nature challenge thn necessity and sufficiency of the Commission's Crder. Staff shot sd have raised objections to these subparts of Contention 8 when it was submitted, not now. These subparts have been accepted by the Board and are therefore ripe for discovery.

The Staff's response does not address the original ,

i question. Intervenor Sholly requests that Staf f respond to the original interrogatory. That interrogatory did not I

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• request that the Staff discuss whether the Engestion EPZ was covered by the Commission's Crder as a short or long term Ltem, but rather requested an assessment from the Staff as to the sufficiency of Licensee's discussion of the Engestion EPZ in the Emergency Plan.

Follow-on Interrogat ory in Resnonse to Question 8-4 The interrogatory requested Staff to assess whether Licensee had sufficiently justtf ted the chotee of a 10-mile circular EPZ for Plume Exposure in Ltcensee's Emergency Plan. Staff responded, "The Licensee has selected a plume exposure EPZ that meets the objectives of NUREG-0396 and the Commission's Polley Statemenc of October 18, 1979." Intervenor Sholly fLnds this answer vague in that Staff was requested to explatn the answer. The following interrogatory is therefore posed

a. Has Licensee, as per NUREG-0396, taken adequate note of local condtttons such as demography, land use, transportation routes , and local jurtsdictLonal boundartes in the selection of a 10-mile circulate EPZ for plume exposure?

Spectf tcally address in your answer the fact that this proposed EPZ passes through the city of Harrisburg, and the fact that TMI has the 4th largest population within 10 miles of all Itcensed reactors in the U.S.

Respectfully submitted, .

r ^

ghllsu . ~.  :). *-

DATED: 13 M sach 1980 5teven C. Sholly t

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% 24 I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket No. 50-289 METROPOLITAN EDISON COMPANY ) (Restart)

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of Intervenor Steven C. Sholly First Set of Follow-On Interrogatories to NRC Staff, dated March 13, 1980, which was hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania, on March 14, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, thio 17th day of March, 1980.

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/ohn F. Wilson Dated: March 17, 1980 aQ e .

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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)

SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street  ;

Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing 'hairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Ne lear Regulatory Commission Attorney for Newberry Township Washington, D.C. 20555 T.M.I. Steering Committee 2320 North Second Street John A. Levin, Esquire Harcisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Commission Widoff Reager Selkowitz 6 Adler P.O. Box 3265 P.O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105

• Person on whose behalf service is being made. Only Certificate of Service is enclosed.

Ellyn Weiss, Esquire Robert Q. Pollard Sheldon, Harmon & Weiss Chesapeake Energy Alliance Suite 506 609 Montpelier Street 1725 Eye Street, N.W. Baltimore, Maryland 21218 i

Washington, D.C. 20006 Chauncey Kepford Steven C. Sholly

• Judith H. Johnsrud 304 South Market Street Environmental Coalition on Nuclear Power Mechanicsburg, Pennsylvania 17055 433 Orlando Avenue State College, Pennsylvania 16801 Holly S. Keck Legislation Chairman Marvin 1. Lewis Anti-Nuclear Group Representing 6504 Bradford Terrace York Philadelphia, Pennsylvania 19149 245 West Philadelphia Street York, Pennsylvania 17404 Marjorie M. Acaodt R.D. 5 Karen Sheldon, Esquire Coatesville, Pennsylvania 19320 Sheldon, Harmon & Weiss Suite 506 George P. Trowbridge, Esquire 1725 Eye Street, N.W. Shaw, Pittman, Potts & Trowbridge Washington, D.C. 20006 1800 M Street, N.W.

Washington, D.C. 20036

• Person on whose behalf service is being made. Only Certificate of Service is enclosed.

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