ML19330B452
| ML19330B452 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/29/1980 |
| From: | Ridgway D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Sholly S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19330B443 | List: |
| References | |
| NUDOCS 8008040037 | |
| Download: ML19330B452 (16) | |
Text
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REFATED CORRESPONDENGE O
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Lic 7/29/30 Voextra USNRO a-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OION 4
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
~'
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S INTERROGATORIES TO INTERVENOR STEVEN C. SHOLLY ON REVISION 2 OF LICENSEE'S EMERGENCY PLAN These interrogatories are filed pursuant to 10 C.F.R.
S 2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation, and the Board's Memorandum and Order of July 15, 1980, autho-rizing discovery requests based upon new information in Revi-sion 2 of Licensee's Emergency Plan.
The schedule for respond-ing to these interrogatories is set forth in the referenced Board Memorandum and Order.
1.
A new Section 4.6.3.5 has been added to describe radio-logical assessment and offsite monitoring.
As explained in that section, Licensee does not rely on TLD's to provide radiation exposure and dose data to responsible officials having decision-making responsibilities.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 4 are valid?
8008040 o g Q
. (b)
If so, explain the basis of your conclusion.
(c)
If you still maintain that the protection of public health and safety requires Licensee to have on-site TLD processing capability, explain the basis of that view.
2.
Section 4.7.5 of the Emergency Plan includes a greatly expanded discussion of the communications links with offsite agencies.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(A) are valid?
(b)
If so, explain the basis of your conclusion.
(c)
Identify with particularity each communica-tion link you believe to be inadequate.
For each such link identified, describe the changes which you believe are necessary to provide for adequate communications.
3.
With respect to proposed Contention No. 3(C), do you con-tend that the preplanning done within the 10-mile EPZ is inadequate to provide a basis for emergency actions outside the 10-mile zone, if such actions are deemed necessary?
If so, explain the basis of that conclusion.
4.
With respect to proposed Contention No. 8 (C), do you con-tend that the preplanning done by the counties in connection with their 20-mile evacuation plans is inadequate to resolve your concerns?
If so, explain the basis of that conclusion.
. 5.
With respect to proposed Contention No. 8 (C) (a), describe what you perceive to be the significance of not including the en-tire City of Harrisburg within the plume exposure EPZ.
In respond-ing to this interrogatory, your discussion should include, but not necessarily be limited to, consideration of the following matters:
(a)
Ability of those outside the EPZ to receive information about the Emergency Plan; (b)
Ability of those outside the EPZ to receive early warning of a possible emergency condition at TMI; (c)
Ability of those outside the EPZ to receive notice of a decision to take protective measures (i.e.,
sheltering or evacuation);
(d)
Ability of those outside the EPZ to take shelter; (e)
Ability of those outside the EPZ to evacuate the area.
6.
With respect to proposed Contention No. 8 (C) (b), describe what you perceive to be the significance of not including the City of York and surrounding urbanized area within the plume exposure EPZ.
In responding to this interrogatory, your discussion should include, but not necessarily be limited to, consideration of the following matters:
(a)
Ability of those outside the EPZ to receive
-information about the Emergency Plan; (b)
Ability of those outside the EPZ to receive early warning of a possible emergency condition at TMI;
. )
(c)
Ability of those outside the EPZ to receive notice of a decision to take protective measures (i.e.,
sheltering or evacuation);
(d)
Ability of those outside the EPZ to take shelter; and (e)
Ability of those outside the EPZ to evacuate the area.
7.
With respect to proposed Contention No. 8 (C) (c), de-scribe what you perceive to be the significance of not including the entire geographic extent of all township, city, borough, town or village jurisdictions crossed by the 10-mile EPZ within the plume exposure EPZ.
In responding to this interrogatory, your discussion should include, but not necessarily be limited to, consideration of the following matters:
(a)
Ability of those outside the EPZ to receive information about the Emergency Plan; (b)
Ability of those outside the EPZ to receive early warning of a possible emergency condition at TMI; (c)
Ability of those outside the EPZ to receive notice of a decision to take protective measures (i.e.,
sheltering or evacuation);
(d)
Ability of those outside the EPZ to take shelter; and (e)
Ability of those outside the EPZ to evacuate the area.
. 8.
With respect to proposed Contention No. 8(C), do you have any reason to believe that:
(a)
The proposed access and egress routes for l
an evacuation are inadequate to carry the planned numbers of vehicles?
(b)
There will be a " conflict" in use of access and egress routes in the event of a general evacuation?
If so, explain separately for parts (a) and (b) above the basis of that conclusion.
9.
Are you adopting proposed Contention No. 8 (C) (d), set forth by ANGRY?
If so, answer the following questions:
(a)
Identify the basis of your claim that
"[n]umerous members" of Old Order Amish reside within close proximity of the plume exposure EPZ.
(b)
Define thz geographic extent (e.g.,
loca-tion) of the Old Oruer Amish community referred to in this contention and state the number of Old Order Amish which you contend reside within that area.
(c)
Explain why the 20-mile evacuation plan set forth in the emergency response plan for Lancaster County is inadequate to resolve your concerns.
10.
Section 4.4.2 of the Emergency Plan has been revised l
. to indicate that the state and five-county emergency plans now use the same emergency classification scheme as Licensee.
(a)
In light of these changes do you still main-tain that the concerns set forth in Contention No. 8(E) are valid?
(b)
If so, explain the basis of your conclusion.
11.
Revision 2 of the Emergency Plan includes an entirely new Appendix B - Emergency Public Information Plan for the Three Mile Island Nuclear Generating Station.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(G) are valid?
(b)
If so, explain the basis of your conclusion.
12.
Revision 2 of the Emergency Plan includes an entirely new Table 11 on offsite groups that may provide assistance.
This includes a description of the trained personnel and equipment available from those organizations.
In addition, Section 4.6.6.4 includes a discussion of the qualifications possessed by Hershey Medical Center and Radiation Management Corporation.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8 (J) are valid?
(b)
If so, explain the basis of.your conclusion.
4 13.
Section 4.5.3 has been greatly expanded to include a more detailed discussion of the expertise and resources available from state agencies.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(K) are valid?
(b)
If so, explain the basis of your conclusion.
14.
Revised and updated letters of agreement are included in Appendix C to the Emergency Plan.
These letters describe in greater detail the expertise and resources available to Licensee.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(L) are valid?
(b)
If so, explain the basis of your conclusion.
(c)
For each letter of agreement which you still maintain is inadequate, describe the shortcomings of that letter and what changes you believe will be neces-sary for an adequate letter of agreement.
15.
Revision 2 of the Emergency Plan includes a new Section 4.5.3.1.4 describing the responsibility of the Pennsylvania Depart-ment of Agriculture to provide for agricultural, dairy and food product control up to 50 miles downwind of a fixed nuclear facility.
In addition, the most current version of the Pennsyl-vania Department of Agriculture Plan is included as Appendix 7 of the State Plan.
I.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(N) are valid?
j (b)
If so, explain the basis of your conclusion.
(c)
If you are of the view that Licensee's Plan should contain additional information about the ingestion exposure pathway, explain what you be-lieve to be necessary.
16.
Section 4.6.6.1 has been expanded to include thyroid limit (in addition to whole body dose limit) exposure guidelines for emergency activities.
That section also contains an expanded discussion on the criteria to be used by the Emergency Director i
in authorizing exposures in excess of the 10 C.F.R. Part 20 limits.
Section 4.8.1.1.4 describes the training provided to support personnel, including basic health physics training.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(O) are valid?
(b)
If so, explain the basis of your conclusion.
17.
Revision 2 of the Emergency Plan includes a new Section 4.6.5.3 on maintaining emergency equipment readiness, a more ex-tensive.and more frequent set of drills and exercises are de-scribed in Section 4.8.1.2, and Section 4.8.2 has been revised to transfer responsibility from the Technical Support Staff to the-Quality Assurance Department for auditing the Emergency Plan at least once every two years.
. (a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8 (Q) are valid?
(b)
If so, explain the basis of your conclusion.
.18.
Revision 2 of the Emergency Plan includes in Appendix C an updated letter of agreement from PEMA.
In that letter PEMA states that the Cumberland County emergency organization is actively working with PEMA in the current emergency planning effort, and that the Cumberland County emergency organization has pledged its full and active assistance in the event of an emergency at TMI.
In addition, Appendix H of Licensee's Emer-goncy Plan includes the current emergency response plan for Cumberland County.
That plan includes the responsibilities ac-cepted by Cumberland County (S V.B).
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8 (R) are valid?
(b)
If so, explain the basis of your conclusion.
s 19.
Appendix C of the Emergency Plan includes a revised and updated set of letters of agreement.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(S) are valid?
(b)
If so, explain the basis of.your conclusion.
. (c)
For each letter of agreement which you still maintain is inadequate,. describe the shortcomings of that letter and what changes you believe will be neces-sary for an adequate letter of agreement.
20.
Consistent with the Board's directive at page 9 of its Third Prehearing Conference Order (January 25, 1980) -- relating to your Contention No. 8(T) -- specify separately for each sub-section below how Revision 2 of the Emergency Plan does not demon-strate adequate recognition of:
(a)
"the potential complexity of emergency con-ditions";
f (b)
"the rapidity with which relatively minor initiating events can escalate into more serious acci-dents"; and (c)
"the limited response time which may be avail-able to diagnose the event properly and implement in timely fashion the appropriate corrective actions."
21.
Appendix 7 to the revised State Plan includes the Pennsyl-vania Department of Agriculture's Plan for implementing necessary protective actions within the 50-mile ingestion exposure EPZ.
In light of this Plan:
(a)
Describe the need for letters of agreement between Licensee, on the one hand, and the State of
~ Maryland and the counties identified in your Contention No. 8(U), on the other hand.
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~
~
. (b)
State whether you contend there is a regu-latory requirement for such letters of agreement.
If so, identify and explain that requirement.
22.
Section 4.5.1.3.1 has been revised to include a list of 13 information items which the Emergency Director is to ensure 1
are transmitted to the proper offsite authorities.
In addition, a new Emergency Public Information Plan has been included as Ap-pendix B.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(V) are valid?
(b)
If so, explain the basis of your conclusion.
23.
Revision 2 of the Emergency Plan includes a new Section 4.6.5.3 on emergency equipment readiness.
Those provisions apply to the equipment described in Section 4.6.5.2, including the radiation monitoring equipment at the Processing Center which would be used for survey purposes.
New Table 8 describes the per-sc.'nel available for conducting the onsite and offsite monitoring.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(W) are valid?
l (b)
If so, explain the basis of your conclusion.
24.
Appendix C to the Emergency Plan includes updated letters of agreement from the Pennsylvania State Police and the United
. States Coast Guard.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8 (Z) are valid?
(b)
If so, explain the basis of your conclusion.
(c)
If you believe Licensee's means for control-ling access to the Exclusion Area is still inadequate, describe the methods you believe are necessary to effect adequate means of control.
25.
Section 4.6.5.1.2 has been revised to include a fuller explanation of the criteria to be used for recommending offsite protective actions.
These criteria are based on BRP guidance.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(FF) are valid?
(b)
If so, explain the basis of your conclusion.
26.
Section 4.5.1.3.1 has been revised to indicate which responsibilities the Emergency Director may not delegate, and by implication, those which he may delegate to others.
New Table 8 describes the personnel available to the Emergency Director and the duties they are responsible for in the event of an emergency.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 8(GG)
. are valid?
(b)
If so, explain the basis of your conclusion.
Respectfully submitted, SHAW, PITTMAN, POTTS.& TROWBRIDGE 3
By:
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Ridgway (
' "I Robert W. 2dhJ$r Delissa A.
i Dated:
July 29, 1980 i
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RELATED CORRP.SPONDENrJ 11 59 s
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Lic 7/29/80 Emnch l fp yCL',/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket Zo. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of --
(1)
Licensee's Interrogatories to Intervenor Marjorie M. Aamodt on Revision 2 of Licersee's Emergency Plan; (2)
Licensee's Interrogatories to Intervenor Environmental Coalition on Nuclear Power on Revision 2 of Licensee's Emergency Plan; and (3)
Licensee's Interrogatories to Intervenor Steven C.
Sholly on Revision 2 of Licensee's Emergency Plan --
were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 29th day of July, 1980.
oEn, Y ninw "iDelissa 4. Rydgyay (f Dated:
July 29, 1980
r e
e 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 John A. Iavin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Ccrmt'n Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Carmtission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atcznic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little' Chairman, Dauphin County Board Atomic Safety and Licensing of Camissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Parket Streets Paleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Iagal Director Consumer Advocate U. S. Nuclear Regulatory Comnission Office of Consumer Mvocate Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 office of the Secretary I
U. S. Nuclear Regulatory Comnission l
Washington, D.C.
20555 1
1 r
& Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against Nuclear T.M.I. Steering Cornmittee Enercff 2320 lbrth Second Street Sheldon, P2.rmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006
'Iheodore A. Adler, Esquire Widoff Reager Selkowitz & Pdler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nuclear Sheldon, Harmon & Ikiss Power 1725 Eye Street, N.W., Suite 506 433 orlando Avenue itshington, D.C.
20006 State College, Pennsylvania 16801 Steven C. Sholly Marvin I. Inwis 304 South Market Street 6504 Bradford Terrace Nechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt Ibily S. Keck R. D. 5 Iegislation Chairman Coatesville, Pennsylva.s 19320 Anti-Nuclear Group Pepresenting York 245 West Philadelphia Street York, Pennsylvania 17404