ML19330B439
| ML19330B439 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/23/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | METROPOLITAN EDISON CO. |
| References | |
| NUDOCS 8008040024 | |
| Download: ML19330B439 (11) | |
Text
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SHOLLY, 7/23/80
,, r, UNITED STAES OF AMERICA
.)Ub '> 31980 "tJCI. EAR REGULATORY COMilSSICN Befoh. the _ Atomic Safety and Licensing Board i.
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In the Matter or
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METROPOLITAN EDISON COMPANY, ET AL.
DocketNo.50-289 N
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4 (RESTART)
F (Three Mile I'sland Nuclear G
Station, Unit No.1)
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DISCOVERY REQUESTS TO LICENSEE JUL 2 81980 *
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ON REVISIGN 2 0F LICENSEE'S
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0,"ce c' t' t St~tyy EMERGENCY PLAN, PURSU.UT TO
" C'Tikrt e MEMORANDUM AND ORDER DATED
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p[ 7 15 July 1980 FROM ASLB Pursuant to the Memorandum and Order Resuming Schedule for Discovery and Contentions on Energency Planning, dated 15 July 1980, at page 2, the following discovery requests are directed to the '.icensee.
These discovery requests relate to Sholly Contention #8.
1.
Section 4.2.1.5 of the Emergency Plan (EP) has been changed.
The.EP dated November 1979 ( Amendment 10)' states:
" Metropolitan Edison Co=pany has, in defining the E=ergency Planning Zones (EP:') for Three Mile Island Nuclear Staticn, taken into consideration the information and data presented above as well as other i=portcnt f actors such as organizational-capabilities, availability of emergency f acilities and e:cipment, and the methods for i=plementing the TMI Emergency Pla,6.
THIS DOCUMENT CONTAINS Revision.2 of the EP provides:
POOR QUALITY PAGES "GPU Nuclear Corporation has, in defining the Emergency Flanning Zones (EP2) for Three Mile Island Nuclear 5tation, taken into consideration the information and data prc-z.ted above, guidance -
provided bv the Pennsvlvania Eter2ency Manntement Agencv, and other important' factors.
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- 'ith regards to the ".
. guidance provided by tbe Pennsylvania Ehergency S.
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Management Agency.
.", provide documentary recteds (including, but not I/
limited.to memoranda, notes, letters, reports, rec rds of telephone calls 800 gogo p V e
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and/or =ectings) which describe or discuss the referenced " guidance" from PEMA. Further, to the extent that such documentary ' records are in the possession of Licensee, provide docusentary records which contain analyses
, or evaluations of the PEMA' guidance, whether such analyses or evaluations were conducted by License? employees, contractors, consultants, or those of General Public Utilities Corporation or General Public Utilities Service Corporation. ' In the event that appropriate documentary records do not exist, describe in writing the guidance from PEMA, including analyses and/or 7
evaluations of that guidance. Identify persons in the e= ploy of Licensee, GPU, and/or G?USC who have direct knowledge of the PEMA guidance and/or analyses or evaluations thereof.
Identify the person or persons at PEMA who provided the guidance and the authors of the guidance, if known.
F 2.
Section 4.3.1.1 of the EP has been changed.
The EP dated November 1979 l
(Amendment 10), states:
"In su==ary, the' TMI Energency Plan provides:
1.
A means for classifying emergency conditions in a manner compatible with a system utilized by State County c=crgency response agencies and organizations."
Revision 2 of the EP provides:
"In sucmary, the TMI E:ergency Plan provides:
1.
A means for classifying emergency conditions."
Does this alteration imply that Licensee's classificarica of c=crgency conditions is i= compatible with State ane County emergency response agencics and organisations' classification sc? cme? If so, identify the agencies and organizations which utilize a classification schece which is different from the sche c used by Licensee; detail the differences;.and explain how the public health and safety is adequately protected by these i
differing classification schemes when such differences could lead to j
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misinterpretation of the seve.ri'ty of an emergency (and potentially leading such agencies and organizations to mistakenly f ail to call for protective actions, or mistakenly call for protective actions when none are required).
If differences in classifichtion schemes exist, has Licensee entered into negotiations with these agencies and organizations in' crder to arrive at a mutually agreeable classification system? If not, why not? If so, describe the status of these negotiations and detail any changes which have been made or vill be made prior to Restart, 3.
Section 4.4.1.1 of the Ep has been changed.
The EP dated Nove=ber 1979
( A=endments 6 and 10) states:
"The emergency action levels that shall require an Unusual Event declaration include (but are nct necessarily limited to) the following:
2.
Any reacter trip followed by an unanticipated automatic ECCS actuation."
Revision 2 of the EP provides:
"2.
Any reactor trip followed by an unplanned autenatic ECCS actuation."
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How does an " unanticipated automatic ECCS actuation" ditfer from an " unplanned autonatic ECCS actuaticn"' Explain why this wording l
has been changed. Does the new wording tend to result in fewer Unusual Event declarations than the old wording? If so, explain why.
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1 4.- Section 4.4.1.2 of the EP has been changed.
The EP dated Nove=ber 1979 (Amendsent 10) states:
"The energency actica levels that shall require an Alert to be declared include (but are not necessarily limited to) the following:
10.
Loss of all off site power coincident with loss of both l
-diesel generators."
I Revision 2 of the EP provides:
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"10.
Loss of all offsite power coincident wi;h the failure of l
both diesel generators to ctart for les than 15 minutes.
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Loss of all onsite DC power for less than 15 minutes."
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- Explain the bases for these changes.
Include within your explanation the ireasonsVhythesechangesSremoreconservativethantheoldwording.
i j Further, explain the significance of the 15-minute time period cited in I
- both new state =ents in terus of its impact on the safety of
- he plant and the status of engineered safeguards f eatures.
5.
Section 4.4.1.2 of the EP has been changed.
The EP dated :fove=ber 1979 (Arendment 10) states:
"The etergency action levels that shall require an Alert to be declared ir.clude (but are not necessarily limited to) the following:
14.
Tornado warning."
Revision 2 of the EP provides:
"15.
Any tornado striking the faciliev."
Explain the bases for this change, including within your explanation why the new wording is more conservative than the old werding.
6.
Section 4.4.1.2 of the E? has been changed.
The EP dated ;ovatber 1979 (Amendren 10) centains no provision for the declaration of an Alert based upon of f-site gan=a dese levels (actual reasured levels).
Revision 2 cf the EP provides:
"23.
Of fsite radiological renitoring reports of > 10=R/hr (gamma) at any location."
Other provisions in the E? in this section provide for the declaration of an Alert when exclusion boundary doses are calculated (based on conservative adve:se meteorology circumstances) to equal or excee'd 10 mR/hr (gamma).
The provision for an Alert declaration based upon i
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N a field measurement of an actual dose rate as opposed to a calculated dose rate based on conservative assusptions is not as conservative as relying on the ca,1culation. Why dose this inconsistency exist in the provisions for declaration of an Alert? Why should not an actual' easurezcat i
of a dose not cause a higher level of classification to be initiated?
7.
Appendix C to. the EP, Revision 2, does not cot.tain, contrary to statements
=ade in,Section 4.5.2.1, a letter of agreement from Radiation Management Corporation.
Provide a copy of the cost recent letter of agreement with RMC. If older than two years from the date of the plan, explain why.
8.
Section 4.6.3.5 of the EP, Revisica 2, refer nces procedures in the Etergency Plan I=plementing Procedures which are used to cake contingency dose calculations in the event that instrumentation used for radiological assess cat is off-scale or inoperative. Are these procedures available in Licensea's Reading Room? Have they been approved by the PORC since the TMI-2 accident began on 28 March 1979? Do the referenced procedures account for the potential for an accident to release quantities of radiation i
1 equivalent to those released during the TMI-2 accident? If not, explain in detail why not.
If so, specify how such a release is accounted for in the procedures.
Further, when st -h contingency dose calculations are used, is this fact reported to PEMA and/or SEP? - If not, why not? If so, what information is provided under such circumstances to enable the agency to 4 :termine that the cor*.3ct choice of' contingency dose factors
. 'has been made?
9.
Section 4.6.3.5 of the EP, Revision 2, references procedures in the Emergency Plan Implementing Procedures which are used as a basis for the notification l:
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. SHOLLY, 7/23/80 s s, of downstrada water users if projected concentraticas of radienuclides in the river water exceed levels specified in the procedures.
Are these 4
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procedures in Licensee's Reading Room? Have they been approved by the
. PORC since the TMI-2 accident began on 28 March 1979? Specify the leve19 which must be exceeded before notification of devnstream users takes place.
Provide a list of all such users, including name, address, and telephone numbers.
Spe'cify the basis for the levels in.the procedures, referencing ispecific documents which support the levels used.
10.
Section 4.6.5.1 of the EP, Revision 2, is expanded from the EP dated Novenber 1979 ( Amendments 6 and 10), by providing specific guidance on protective actions for sheltering and evacuatien.
This guidance is contained en page 6-13 of Revision 2 of the EP.
What are the bases for these considerations contained in the EP as specified above? Identify specific references s
(including title, publisher, date, and authers) which support these considerations.
Also, identify and provide copies of docu: ente.ry records in the possession of the licensee, GPU, and/cr GPUSC relating to these considerations, and any analyses or evaluations which support their use, 11.
Section 4.6.5.1 of Revisien 2 of the E? states:
"The means to warn or advise persens involved is cesignated a responsibility of the ' Risk County' in Annex E of the State's Disaster Opera tions Plan."
Centrary to this, page 3-1 of NURIG-0654, which Licensee's Energency Plan references as being complied with in Revision 2, states as follows:
"NRC and FEMA recognice that the responsibility for activating the proept notificaticn system called for in this section is properly the responsibility of the State and local govern =ents.
NRC and FEMA also recognize that the responsibility for assuring that the means exist for putting such a systtn into place rests with Facility Operators."
Has Licensee conplied with the quoted require =ent from NUREG-0654? If so,
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. N.., SHOLLY, 7/23/80 specify how Licensee has determined that the facilities for pro =pt notification exist, referencing and providing copies of studies supporting Licensee's position. Furthe'r, describe how Licensee reconciles the quoted statement
. from Revision 2 of the EP dith the !iRC/ FEMA requirement quoted above.
12.
Section 4.6.6.3 of the EP, Revision 2, contains a provision for training of off-site emergency squad = embers in the treat:ent and transportation of contaminated injured individuals; che previous EP contained no similar provision. Describe the training provided. Will such training be provided to all potentially-involved cf f-site emergency squads prior to Restart?
Doe's the training include provisions to train the squad members to avoid contar.inatica of other persons, either en-route or while at a hospital facility? If so, describe.
If not, explain why not.
13.
Section 4.7.1.2 of the EP, Revision 2, contains a provision f or future installation of a CRT Monitoring Systen at the Technical Support Center.
A si ilar provision is lacking in.the previous plan. When will this capability to conitor plant, computer and required radiological information on a 'not-to-interfere-with-the-operator' basis be ins talled? Will installation occur prior to Restart? If not, explain how such inferration will be transmitted to the TSC, describing provisions to ensure that power f ailures will' not impact on the availability of such information, Similarly, Section 4.7.2.4 contains provision for a CRT systeE at the Parsippany Technical Functions Center (a ;irovision which is lacking in
- the previous EP). When will this installation take place? Will the installatica take place prior to Restart?
If not, explain how such infot=ation will be trans=itted to. the Parsippany TFC, describing provisions to ensure that power failures will not ihpact on the availability of such inforcation.
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~0-SHOLLY, 7/23/S0
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w DATED:
23 July 1980 RESPECTFULLY SU3MITTED, I
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hTCLEAR REGULATORY COMMISSION g
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W 3EFORE THE ATOMIC SAFETY AND LICENSING 30ARD
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In the Matter of
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METROPOLITAN EDISON COMPAh'Y
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Docket No. 50-239
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(Restart)
(Three Mile Island Nuclear
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Station, Unit ':o, 1)
CERTIFICATE OF SERVICE I hereby certify that ccpies of Intervenor Steven C. Sholly Discovery Requests to Licensee on Revision 2 of Licensee's Energency to Me=orandu and Order Dated 15 July 1980 frc: ASLB Plan, Pursuant dated July 23, 1930, which was hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania on July 23, 1980, vert served upon those persens on the attached Service List by depcsit in the United States nail, postage paid, this 24th day of f
July, 1980.
-Jd:c
/ John F. Wilson Dated:
July 24, 1980
g UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.TfISSION 3EFORE THE ATOV,1MAFETY AND LICENSING BOARD
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In the Matter of
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UsHR0 Docket No. 50-239 METROPOLITANEDISCNCOMP}y
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1Semca Station, Unit No. 1) gym S
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SERVICS LIST Ivan W.
Scith, Escuire Karin W.
Carter, Esquire Chairman Assistant Attorney General Atenic Safety and Licensing Commonwealth of Pennsylvania l
Scard Panel 505 Executive House U.S. Nuclear Regulato:y P.O. Box 2357 Harrisburg, Pennsylvania 17120 Commission Washington, D.C.
20555 Ecbert L. Knupp, Esquire Dr. Walter H. Jordan Assistan: Solicitor Atc=ic Safety and Licensing County of Dauphin Board Panel P.O.
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$31 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 1710E Dr. Linda W.
Little Jchn E. Minnich At omic Sa f e ty and Licensing Chairman, Dauphin County Soard of Board Fanel Ccemissioners 5000 Hermitage Drive Dauphin County Courthouse Raiciph, North Carolina 27612 Front and Market Streets sHarrisburg, Pennsylvania 17101 Jares A. Tcurtellotte, Esquire Office of the Executive Legal Walter W.
Cohen, Escuire Consumer Advocate Director U.S. Nuclear Regulatory Conmission Department of Justice Cashington, D.C.
20555 14th Flecr, Strawberry Square Harrisburg, Pennsylvanir 17127 Docketing and Service Srction Office of she Secretary Jordan D.
Cunningham, Escuire l
U.S. Nuc1 car Regulatory Cennission Attorney f or Newberry Townshi; Washing:en, D.C.
20555 T.M.l. Steering Committec 2320 North Second Stree:
l Jchn A.
Levin, Escuire Harrisburg, Pennsylvania 1711C l
Assistant Counsel Fennsylvania Public Utility Tnecdore A.
Adier, Es:uire l
Uideff Reager Seikowit: 6 Adic:
l Commission l
P.O.
Box 3265 P.O.
Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 1720!
- Person on whose behalf service is being nade.
Only Certific.ite cf Service is enciesed.
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Chauncey Kepford Judith H. Johns rud Ellyn Weiss, Esquire Environ = ental Coalition on Nuclear Pv o Sheldon, Harmon 5 Weiss _
433 Orlando Avenue Suite 506 1725 Ey'e Street, N.W.
State College, Pennsylvania 16801 20006 Washington, D.C.
Marvin I. Lewis 6504 3radford Terrace Steven C. Shollv.
304' South Market Street Philadelphia, Pennsylvania 19149
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Mechanicsburg, Pennsylvania 17055 Marjorie M. Aanodt R..D.
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Holly S. Keck Legislation Chair =an coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing
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George F. Trowbridge, Escuire 245 West Philadelphia Street-Shaw, Pite=an, Poets & Trowbridge York N.W.
York, Pennsylvania 17404 1800 M Street, 20036 Washington, D.C.
Karen Sheldon, Esquire Shelden, Har=on & Weiss Susan 5arley 129 Cocoa Avenue Suite 506 Hershey, Pennsylvania 17033 N.W.
1725 Eve Street, 20006 Washington, D.C.
l Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street 21218 l
Esiti= ore, Maryland l
Only Certificate of Service
- Persen on whose behalf service is being made.
is enclosed.
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