ML19343A263
| ML19343A263 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/12/1980 |
| From: | Smith I Atomic Safety and Licensing Board Panel |
| To: | Environmental Coalition on Nuclear Power, METROPOLITAN EDISON CO. |
| References | |
| ISSUANCES-SP, NUDOCS 8009170137 | |
| Download: ML19343A263 (2) | |
Text
Bd 9/12/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
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e ATOMIC' SAFETY AND LICENSING BOARD SEp '#%
Ivan W. Smith, Chairman k
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f Dr. Walter H. Jordan Dr. Linda W. Little 1
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n In the Matter of
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IfETROPOLITAN EDISON COMPANY
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Docket No. 50-289
( estart)
(Three Mile Island Nuclear Station, Unit No. 1)
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- O 'MO MEMORANDUM AND ORDER GRANTING LICENSEE'S
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MOTION TO COMPEL ECNP RESPONSE TO EMERGENCY PLANNING INTERROGATORIES (September 12, 1980)
The board's memorandum and order of July 15, 1980 reinstated a schedule for prehearing matters on emergency planning.
Pursuant to that order, the licensee on July 29, 1980 directed seven inter-rogatories to ECNP based on Revision 2 of licensee's emergency plan.
The interrogatories relate to ECNP Contentions 2-4, 2-7, 2-11, 2-13, 2-20 (as consolidated with 2-30), 2-26, and 2-28.
Each interrogatory references a particular subsection of the emergency plan which has been revised by Revision 2, describes the change, and asks ECNP whether the change satisfies ECNP's concerns in the particular contention relevant to the change, and if not, to explain why not.
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i ECNP did not timely respond to the motion to co=pel.
(Pur-suant to the July 15, 1980 order, the board should have received ECNP's response within five days of service of the motion to compel.)
In the course of filing proposed revisions to Contentions 2-2 and 2-4 on September 8, 1980, ECNP for the first time asks that we deny the motion to compel.
ECNP merely states it cannot now find the interrogatories, and implies it would be burdensome to require ECNP to respond.
We disagree.
As described above, it is clear that the interrogatories are very direct and concise and properly request information-to which the licensee,and indeed the board, is entitled.
Accordingly, ECNP is directed to respond to licensee's inter-rogatories within ten days of service of this order.
A copy of -
the interrogatories is attached.
We deem it premature to provide for a situation of l'CNF failing to comply with this order.
- However,
-we'invita licensee-to move for dismissal of the affected contentions in such event.
Such a further motion, if necessary, should discuss which other contentions, if any, cover the same emergency planning
-issues as the ECNP contentions for which dismissal is sought.
THE ATOMIC SAFETY AND l
LI c,NSING SOARD
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Mw W/ /p'fV r Ivan. W. Smitfi, Chairman ATTACHMENTi As stated Bethesda, Maryland September 12,19f 1 i
ATTACEMENT
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UNITED STATES OF AMERICA
-MUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S INTERROGATORIES TO INTERVINOR ENVIRONMENTAL COALITION ON NUCLEAR POWER 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
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separately and fully in writing and under oath or affirmation, and the Board's Memorandum and Order of July 15, 1980, autho-rising 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.
Section 4.4.2 of the Energency Plan has been revised to indicate that the state and five-county emergency plans now use the sane emergency classification scheme as Lice see.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Concention No. 2-4 seen m
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(b)
If so, explain the basis of your conclusion.
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Revision 2 of the Emergency Plan includes a revised I
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Emergency Public Information Plan as Appendix 3.
.That plan calls for' dissemination of information to the media in the event an alert is declared.
In addition,Section IX.A.3 of tr.e State Plan provides information on the means to be used by state offi-cials in disseminating information to the public.
(a)
In light of these changes, do-you still =ain-1 tain that the concerns set forth in Contention No. 2-7 are valid?
(b)
If so, explain the basis of your conclusion.
3.
Section 4.7.6.1.7 has been revised to cross reference m._
those sections of the Restart Report which describe the range
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and capabilities of the high-range effluent monitors.
(a)
In light of these changes, do you still main-tain that the concerns set forth in Contention No. 2-11 are valid?
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(b)
If so, explain the basis of your conclusion.
1' 4.
A new Section 4.6.3.5 has been added to describe radio-1 i
logical assessment and offsite monitoring.
i (a)
In light of these changes, do you still main-tain.that the concerns set forth in Centention No. 2-13
-are valid?
(b)
If so, explain the basis of your conclusion.
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.[]d (c)
If you still believe that real time, offsite monitors are'necessary, indicate the number needed the p
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approximate placement of the monitors, and the informa-
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tion to be provided-by the monitors that would not be available from a mobile, offsitel radiological monitor-ing team.
5.
Section 4.7.6.2.1 has been revised to reference a new Table 10, identifying the location of monitoring devices for the-upgraded RIMP.
j (a)
In light of these changes, do you still main-tain that the concerns set forth in Contention Nos. 2-20 and 2-30 are valid?
(b)
If so, explain the basis of your conclusion.
~~7-6.
Section IV of the State Pl'an has been revised to indi-
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cate that ' " [t]he amount of lead time may dictate the protective i
action to be implemented" (p. 6).
In addition, the BRP Plan i
(Appendix 8 to the State Plan) contains information on protective action options.
(a)
In light of these changes, do you still main-I tain that the conce ns set forth'in Contentien No. 2-26 are valid?
(b)
If so, explain the basis of your conclusion.
7.
Section. XIV.B.7 and Annex XIV. A of the BRP Plan (Appen-
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. dix 8 to the State Plan) and section X.I (p. 25) and Appendix 0 of the Department, of Health Plan- (Appendix 9 to the State Plan)
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=5fij contain infornation on radiation, radiation sickness, decon-
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tamination, and hospitals with special decontamination facili-ties.
i, (a)
In light of these changes, do you still main-i tain that the concerns set forth.in Contention No. 2-28 are valid?
(b)
If so, explain the basis of your conclusion.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:
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~1 Robert &.
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Delissa A. Ridgway G
Dated:
July 29, 1980 i
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