ML19350B499
| ML19350B499 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/16/1981 |
| From: | Bath F, Chestnut S Federal Emergency Management Agency, Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19350B494 | List: |
| References | |
| NUDOCS 8103200666 | |
| Download: ML19350B499 (25) | |
Text
. o.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear Station,
)
Unit 1)
)
JOINT TESTIM 0hT OF NRC STAFF'S STEPHEN CHESNUT AND FEMA'S FREDERICK J. BATH ON CONTEhTIONS RELATED TO ONSITE/0FFSITE EMERGENCY PREPAREDNESS l
f
. MARCH 16, 1981
~
I l
A L
i
'810_320 0 s
v
--rr-
OUTLINE JOINT TESTIMONY OF NRC STAFF'S STEPHEN CHESNUT AND FEMA'S FREDERICK J. BATH ON CONTENTIONS RELATED TO ONSITE/OFFSITE EMERGENCY PREPAREDNESS This testimony addresses eight contentions in the TMI-l restart pro-ceeding, each of which is related to both onsite and offsite emergency preparedness and/or the interface between onsite and offsite emergency planning.
The. testimony is subdivided into the major areas of emergency planning of:
(A) Protective Action Decisions; (B) Public Warning and Emergency Instructions; (C) Implementation of Protective Actions; (D) Emergency Training and a general category dealing with standards and criteria for energency planning.
The licensee's provisions for transferring information on the emergency and plant conditions to the Commonwealth-are addressed as is the need for an evacuation time estimate study for use in protective action decisionmaking.
The requirements for a public education and information program are addressed and the current status of such a program for TMI, now under development, is discussed.
The coordination of licensee, State and County planning with regard to limited evacuation is addressed.
The need for planning for protective actions out to 20 miles from the TMI site, in view of the fact that certain counties provide for protective actions out to that distance, is addressed.
The training required for licensee, State and local emergency workers is' discussed and the provisions made for'such training are outlined. In 1
9 -
i the same vein, the need for and existence of a trained nuclear engineer for j
l emergency response on-the part of the Conunonwealth is addressed.
4 Finally, the standards and criteria to be applied in judging the adequacy of onsite and offsite emergency preparedness are addressed.
i m
)
i f
i 4
1 9
i i
i.
i i
f 1
r-v T
i i
L 6
i a..
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, Unit 1)
)
JOINT TESTIMONY OF NRC STAFF'S STEPHEN CHESNUT AND FEMA'S FREDERICK J. BATH ON CONTENTIONS RELATED TO ONSITE/0FFSITE EMERGENCY PREPAREDNESS ANGRY Contentions II.A (EP-3A)
II.D (EP-38)
III.B(E)
(EP-58)
III.B(I)
(EP-5F)
III.B(K)
(EP-5H)
Sholly Contention 8 I(B)(4)
(EP-17B(4))
Newberry TMI-Steering Committee Contentions York Plan 16-2 (EP-14Q)
Met. Ed. Plan 6 (EP-15E)
JOINT TESTIMONY OF NRC STAFF'S STEPHEN CHESNUT AND FEMA'S FREDERICK J. BATH ON CONTENTIONS RELATED TO ONSITE/0FFSITE EMERGENCY PREPAREDNESS Q. l.
State your name and title.
A.
(Mr. Chesnut) I am Stephen H. Chesnut.
I am an employee of the U.S.
Nuclear Regulatory Comission (NRC) assigned to the Emergency Preparedness Licensing Branch, Division of Ecergency Preparedness, Office of Inspection and Enforcement.
(Mr. Bath) I am Frederick J. Bath, an Emergency Management Specialist for the Federal Emergency Management Agency (FEMA), assigned to FEMA Region III, Philadelphia, Pennsylvania.
Q.2.
Do you have statements of professional qualification?
A.
(Mr. Chesnut) Yes.
A copy of my statement is attached to the "NRC Staff Testimony of Stephen H. Chesnut on Contentions Related to Onsite Emergency Plannir,g and the Licensee's Emergency Plan" which was filed in this proceeding on February 9,1981.
(Mr. Bath) Yes. A copy of my statement is attached to the " Testimony of Frederick J. Bath and Vernon E. Adler of the Federal Emergency Management Agency on Certain Offsite Emergency. Planning Contentions" which was filed in this proceeding on February 23, 1981.
. - Q.3.
What is the purpose of this testimony?
1 A.
The purpose of this testimony is to address certain contentions in the TMI-1 restart proceeding, each of which is related to both onsite and offsite emergency preparedness and the interface between onsite and offsite emergency planning.
In this testimony, these contentions have been categorized in various major emergency planning areas as follows:
A.
Protective Action Decisions ANGRY Contention IIIB(E' (EP-58);
B.
Public Warning and Emergency Instruction Newberry Contention York Plan 16-2 (EP-14Q);
C.
Implementation of Protective Actions Newberry Contention Met. Ed. Plan 6 (EP-15E); and Sholly Contention 8I(B)(4) (EP-17B(4));
D.
Emergency Training l
ANGRY Contentions IIIB(I) (EP-5F) and IIIB(K) (EP-5H); and 1
E.
General ANGRY Contentions IIA (EP-3A) and IID.(EP-38).
r L
_ _ _ _ _ _ _ _ _ _ A.
Protective Action Decisions f
i Q.4.
ANGRY Contention IIIB(E) (EP-58) states:
The Emergency Planning Review Guideline requires State, and local plans to designate " protective action guides and/or other criteria for implementing sDecific protective actions..."
(Sec. IV(B)(1); emphasis added) anc "information needs" for implementing such protective actions (Sec. IV(B)(2)).
The BORP Plan both fails to explicitly impose upon the licensee clear responsibility for fulfilling such information needs or, where required, to undertake to satisfy them at its own initiative.
1.
Section VIII(A) of the BORP Plan indicates
" time to onset of release" as a significant factor in determining the appropriateness of recommending evacuation. However, nowhere is the licensee given explicit responsibility for providing such information, nor does the Plan contain an analysis of how variation of this factor will affect the choice of appropriate protectiv'e action.
(See, e.g., NUREG 0610,
- p. 13, par. 4(c)).
2.
A second factor listed is " time required to effect relocation." NUREG 75/111, Sec. J(6) requires an adequate state plan to include development of " bases and time frames for evacuation" resulting in " estimates of the time required to carry out evacuation procedures" that reflect consideration of such factors as
" impaired mobility of parts of the population" (Sec. J(7)(c)) and " potential impediments to use of egress routes, such as rush hour traffic and inclement weather" (Sec. J(7)(f)).
The availability of this and other information specified by the President's Commission is an essutial prerequisite to adequate emergencv planning and decisionmaking whether or not in the context of an actual emergency situation.
See too, NURdG-0654, Section J(10)(k); note requirement for specification of " contingency measures"), (1) and (m).
As to Part (1) of this contention, what are the provisions in the licensee's emergency plan for providing to the Bureau of Radiation Protection (BRP) information on the " time to onset of release?"
1 A.
The TMI-1 Emergency Plan provides a list of follow-up information which will be provided to the BRP in the event of an accident at TMI-1.
This includes information on the release which will be used by the State in making protective action decisions.
Such information will include:
(1) Class of emergency, nature of emergency, and plant status; (2) type of actual or projected release and projected affected areas; (3) estimate of quantity of radioactive material released or being released and height of release; (4) chemical and physical form of released material, including estimates of relative quantities and concentration of noble gases, iodines, and particulates; (5) prevailing weather information; (6) actual or projected dose rates and integrated dose; (7) estimates of surface contamination; and (8) recommended emergency actions, including protective measures.
Furthermore, a direct line, the " Radio-logical Line," which connects the TMI-1 control room, EOF, and the BRP will be manned to provide information requested by the BRP.
The licensee's Emergency Plan does not, however, explicitly stipulate that the " time to onset of release" will be provided.
Q.5.
What deficiency exists in the licensee's plan from the failure to f
explicitly provide for information on the " time to onset of release?"
l l
A.
None.
Though the licensee's plan does not call for providing the
" time to onset of release" per g, the detailed information regarding the plant conditions and radiological release characteristics, coupled with the use of the " Radiological Line" on which the BRP could request
5 additional information it deems necessary, constitute adequate provisions on the part of the licensee for providing follow-on information to the State.
By means of the " Radiological Line," BRP can request, at any time, the licensee's estimate of the time to onset of release.
Q.6.
As to part (2) of this contention, what are the requirements for State and licensee plans with regard to providing and accounting for "the time required to effect relocation?"
\\
\\
A.
The emergency planning rule states that " guidelines for this choice of protective actions during an emergency consistent with Federal guidance should be developed and in place." Additionally, NUREG-0654 specifies that the licensee's plan shall contain time estimates for evacuation within the plume exposure EPZ which are in accordance with Appendix 4 to NUREG-0654. Criterion J-10 of NUREG-0654 specifies that State and licensee plans should provide the basis for the choice of protective actions, including evacuation time estimates.
Q.7.
What purpose is servei 9y such estimates?
A.
Together with information on the projected or measured offsite dose, plume travel, duration of the release, and the type of release (such as noble gas, iodine, particulate), information on the time to evacuate a particular area is useful in determining whether ev3cuation is a viable protective option or if sheltering should be recommended.
Q.8.
What are the provisions of the TMI-1 licensee and the State emergency plans with regard to evacuation time estimates?
A.
The amount of time required to conduct evacuations of the population within the plume exposure Emergency Planning Zone estimated in accord-ance with the guidance of NUREG-0654 is not included in either the State or THI-1 emergency plans and hence these plans do not satisfy the criteria of NUREG-0654 in this regard.
As described in the NRC Staff testimony addressing ANGRY Contention IIIA(J) (EP-4H), the licensee has prepared an evacuation time estimate study to comply with Appendix 4 of NUREG-0654.
Since a decision on appropriate protective actions is dependent, in part, on decisionmakers having adegaate estimates of the time it will take c wacuate the populace in the plume exposure pathway EPZ, the NRC and FEMA staff position is that adequate evacuatit.n time estimates should be factored into licensee and State emergency plans prior to restart.
It should be recognized that the actual conditions which exist at the time of making a decision of evacuation is most important. The State has established an adequate directior and control / reporting system through PEMA and the county emergency management agencies to provide timely reporting of actual conditions which would affect evacuation.
Q. 9.
How should evacuation time estimates account for " impaired mobility of parts of the population" and " potential impediments to use of egress routes, such as rush hour traffic and inclement weather?"
A.
Appendix 4 to NUREG-0654 specifies the acceptable criteria for evacu-ation time estimate studies. These criteria include provisions for estimating the times for evacuating the special facility population such as prisons, medical facilities, and schools.
The means of transportation of such groups should be described as well.
Appendix 4 to NUREG-0654 further specifies that the evacuation time estimates should include adverse conditions which would affect the evacuation of the plume EPZ populace.
This would depend on the character-istics of the particular site and could include adverse conditions of flooding, snow, ice, fog, or rain. The ARC staff will review the evacuation time estimate study submittal from the licensee and will report on its acceptability.
Q.10.
Newberry Contention York Plan 16-2 (EP-14Q) states:
Annex E of the York County Plan, subsection III, provides that the local Emergency Management Directors are responsible for the distribution of printed handout material to the populace within their respective municipalities. The Plan is defective in this area in that there is no set timetable for the distribution of said materials to the local Emergency Management Directors, and, likewise, there are no provisions within the Plan as to how local Emergency Management Directors j
are going to distribute the information to the local populace.
l Again, it is submitted that, in the event of an incident at the TMI nuclear facility, local volunteers will not be able to be counted upor to effect such distribution and that without some other men.'s of distributing the materials, local Emergency Management Directors will be impotent to effect such a Plan. The same problem arises in Section K of this area in that the Public Information Officer is respon-l sible for the posting in all public areas, parks, etc., of public information and evacuation instructions for transient i
populations.
~
contention addresses an important aspect of public education and l
information. What are the regulatory requirements and criteria in this regard?
l
[
I 1
l i
- A.
10 CFR Part 50, Appendix E lists the planning standard for emergency ple?s wito regard to public education and information. This standard states that information should be made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), that the principal points of contact with the news media for dissemination of information during an emer-gency (including the physical location or locations) should be estab-lished in advance, and that procedures for coordinated dissemination of information to the public should be established.
NUREG-0654 SII.G l
provides the detailed criteria used by the NRC Staff and FEMA in evaluating the public education programs. These criteria essentially state that a coordinated, periodic (at least annually) program for disseminating information to the public regarding how they will be notified and what their actions should be in an emergency, including information on radiation, protective measures, special needs of handi-capped, and contact points for additional information, should be established. The criteria further provide that the program should reach the permanent and transient adult population in the plume exposure EPZ.
Additionally, the criteria specify that the licensee, State, and i
j local emergency response organizations should also establish contact i
points for news media, identify spokespersons, and make other arrange-ments for timely exchange of information among the designated spokespersons.
l These are requirements on public education prior to a radiological emergency. The public education program is to be carried out prior to
-g-an accident, not after an accident occurs.
Thus, insofar as the quoted contention contemplates distribution of educational materials and the posting of transien+ weas during the course of an accident, it misconceives the pub ic education requirements.
Q.11.
Who is responsible for meeting these requirements in public education and pre-emergency information?
A.
The emergency planning regulation 10 CFR Part 50, Appendix E, lists the planning standard for public education and information and indicates that this standard must be adequately addressed in emergency prepared-ness plans.
The criteria in NUREG-0654 state that the response organi-zations (licensee, State, local) are to provide a coordinated public information system. This does not mean that the licensee, State, and Iscal governments shall each develop separate public information and education programs, but that these organizations collectively shall ensure that a program meeting the requirements of the planning standard for public education and information is met, that the information is coordinated and consistent, and that it is made available to the entire permanent and transient population.
Q.12.
What provisions are included in the State or York County plans for providing and distributing printed emergency information to tl
.oublic?
A.
The public education and information program is still under development by the State and local governments and the licensee and as such an evaluation of this program has not been made. The FEMA and NRC Staffs have reviewed a draft revision of Appendix 15 to Annex E of the Pennsylvania Disaster Operations Plan dealing with Public Education and Information. The provisions of Appendix 15 include providing a comprehensive pre emergency public education and information program which includes dissemination through facility mailings of State devel-oped public education materials dealing with hazards of radiation and protective action information. Additionally, the State plan indicates that telephone directories, radio, television, and newspapers will be utilized as available to educate the public.
The State plan also charges risk county emergency management agencies (including York County) with the responsibility to distribute annually within the risk area a public information pamphlet which details potential protective measures in an incident at TMI-1.
This pamphlet is to contain infor-mation on sheltering, respiratory protection, evacuation routes, reception centers and contact points for additional information or assistance. The York County Plan provides for the preparation and distribution of such material to the permanent population (a brochure has been distributed within the EPZ in York County) and also provides for maintaining canera-ready material (high quality, reproducible material) at the Ycrk County E0C.
The NRC and FEMA Staffs have been j
informally provided with some drafts of State and County prepared j
public education material; however, further details such as the methods l
and frequency of distribution, the schedule for distribution, and the means for educating transients must be provided before a determination as to adequacy of the public education and information program can be made.
l
,_ C. Implementation of Protective Actions Q.13 Newberry Contention Met-Ed Plan 6 (EP-15E) states:
Section 4.6.5.1(2) of the Emergency Plan provides that the responsibility for actions to protect persons in the offsite areas rests with the Commonwealth of Pennsylvania and that the Pennsylvania Emergency Management Agency shall be the agency with which the responsibility rests for the placing, in effect, of protective options such as evacuation, sheltering, and thyroid prophylaxis. The same section indicates that in the event of a general emergency, precautionary measures may be taken such as sheltering, evacuation, and evacuation of ce S sectors based upon wind speed and direction.
It is again Intervenor's contention that this particular section of the Emergency Plan providing for the precautionary measures cited have not been coordinated with local county plans to any measurable extent.
For example, in the county plans, there is no indication of how the counties would instruct its local Civil Defense Directors to evacuate only certain sectors within a community instead of within radial distances of the Three vile Island nuclear facility. This is again only but one txample of a lack of coordination between the Emergency Pian and the various county plans and it is Intervenor's position that this lack of coordination is symptomatic of the entire Energency Plan as it is now written.
The Emergency l
Plan submitted by the licensee should encompass a total i
coordination of all Emergency Plans formulated by Federal, State, and county agencies.
This lack of coordination creates a ceficiency which has to be remedied.
l How, in general, will the decison to implement protective actions such as evacuation or sheltering be coordinated between the various response I
organizations?
A.
The TMI-1 Emergency Plan provides for assessing an accident and for disseminating information on the accident along with the licensee's l
assessment and recommendations for taking protective actions offsite.
Consistent with this, the projected threat areas or affected sectors l
based on observed meteorological conditions will be provided to the State (BRP). NUREG-0654 specifies that wind speed and direction be l
l l
. provided so that the offsite organizations will be aware of the affected population and time frame for which protective actions, such as shelter-ing or evacuation, should be taken.
PEMA, based on technical advice of the BRP, will then direct the counties to implement protective actions in a coordinated fashion, whether they be precautiorary measures taken only in certain sectors or throughout the plume EPZ.
The State plan includes provisions for taking protective actions in sectors and states that such sectors would be approximately 90* centered around the direction of plume travel.
The PEMA has directed the five counties within the plume EPZ to include within the county emergency plans, maps which show sectors as utilized by the licensee so that the affected areas could be clearly identified to local emergency response personnel.
Furthermore, discussions between the FEMA and PEMA staffs indicate that even though protective action recommendations would include information on the affected or risk sectors, protective actions would sctually be implemented by jurisdictions or other clearly defined boundaries. Thus, for example, a sector evacuation will not necessarily involve an evacuation of only part of a community.
Q.14.
Under present planning, how would the cou.ities instruct local civil defense directors to implement protective measures for a particular sector?
l l
A.
As noted in the response to the previous question, PEMA has directed the'five county emergency management agencies within the plume EPZ to l
utilize and incorporate sector maps similar to those shown in the i
. TMI-1 emergency plan into their respective emergency plans.
Using a uniform system of maps will serve to identify the various sectors in common terms.
Since the responsible organizations will possess such maps, misunderstandings aind confusion of terms or affected sectors among response organizations and local civil defense directors will be minimized. The incorporation of these sector maps, into State and county plans, combined with the direction of coordinated protective actions by PEMA should provide a clear understanding of protective actions to be implemented.
Q.15.
Sholly Contention 8.I.(B)(4) (EP-17B(4)) states:
To the extent that the licensee relies upon the decision of county officials in the Three Mile Island area to develop and maintain a 20-mile emergency response capability as a substitute for making a determination that the 10-mile circular EPZ is adequate, the adequacy of such a 20-mile capability must be established as a condition to the restart of TMI-1.
What guidance has been provided by the NRC or FEMA with regard to the size of the plume exposure Emergency Planning Zone (EPZ)?
A.
The new NRC emergency prepardness regulation 10 CFR 50, Appendix E, and NUREG-0654/ FEMA REP-1 state that the capability to implement protective actions should exist ft,r a plume exposure EPZ, of about 10-mile radius around the site. A more detailed discussion of the planning basis for the plume exposure EPZ appears in NRC Staff testimony of Stephen Chesnut in response to Sholly Contentions 8.I.B(1-3).
Q.16.
Several of the emergency plans for those counties with populations within the plume EPZ have provisions for implementing protective actions such as evacuation out to 20-miles, which is beyond the planned plume exposure EPZ.
In view of this, is it necessary that the emergency response capability required for the plume EPZ (approximately 10-miles) be extended to 20-miles?
A.
The five counties within the THI-I plume EPZ have developed some provisions for taking protective actions out to 20-miles from TMI-1, in addition to the required emergency planning and response capability associated with the plume exposure EPZ promulgated by PEMA. This additional planning is in excess of that required by the NRC, and is not relied upon by the licensee on the Pennsylvania Emergency Management Agency (PEMA). The PEMA plans call for directing emergency protective actions for the plume exposure EPZ. Detailed planning is required to protect the population within the plume EPZ including provisions for evacuation plans and a prompt alerting and notification capability.
The time required for a plume to travel beyond 10-miles would allow additional time to extend the area for taking protective actions, if necessary.
Thus, those provisions of the county plans which describe evacuation plans beyond the plume EPZ, are not required and are not i
relied upon.
However, to the extent that planning goes beyond the plume EPZ, it will aid in assuring that planning for the plume EPZ is adequate.
. D.
Emergency Training Q.17.
AN}iYContentionIIIB(1)(EP-5F) states:
TMI-1 should not be permitted to restart until persons responsible for implementing emergency response plans at all levels of the response network within the plume EPZ have successfully completed the training mandated by NUREG-0654, Sec. 04 and provided for in PA DOP App.10.
What training is called for in the emergency planning regulations or criteria?
A.
The new NRC emergency planning regulation requires that radiological emergency response training be provided to those who may be called on to assist in an emergency.
NUREG-0654 SII.0.4 !r.dicates that special-ized initial and retraining programs should be provided for licensee, State, and local personnel in the following catergories:
(a) directing or coordinating of the emergency response organization; (b) personnel responsible for accident assessment; (c) radiological monitoring teams and radiological analyses personnel; (d) police, security, and fire fighting personnel; (e) repair and damage control / correctional action teams (onsite); (f) first aid and rescue personnel; (g) local support services personnel including Civil Defense / Emergency personnel; i
(h) medical support personnel; (i) licensees' headquarters support personnel; and (j) personnel responsible for transmission of emergency information and instructions.
l l
[
Q.18.
What has been done by licensee, State, and local response organizations to ensure response personnel are adequately trained?
l l
i
. A.
The TMI-1 Emergency Plan has been aodified to include training commitments for emergency response personnel consistent with the criteria of NUREG-0654.
The details of the training program are still being developed, however. Training of licensee personnel has been ongoing in the form of walk throughs, drills, and seminars.
Further-more, the licensee has committed (TR-13843-13845) to completing one complete iteration of a multiphase training program which will provide instruction to the licensees' onsite and offsite emergency organization as well as offsite support agencies interfacing with the TMI-1 plan.
Programs which will provide training to the State and local emergency response personnel necessary to perform the emergency functions called for in State and county emergency plans are under development and have not been reviewed by FEMA. The objectives of the training program which will be adopted by PEMA are listed in Appendix 10 to Annex E of the Pennsylvania Disaster Operations Plan.
Q.19.
What training of emergency response personnel, in your opinion, should be conducted prior to restart?
A.
Training programs which provide instruction to personnel who will implement radiological emergency response plans should be established and initial training of these personnel should be provided before restart.
Further, the training should be sufficient to demonstrate i
that the key emergency functions are satisfactorily performed in the forthcomming joint exercise which is required by the Commission's August 9, 1979, Order.
- ___ _ __ -_. Q.20.
ANGRY Contention IIIB(K) (EP-5H) states:
The Commonwealth plan for hiring and training a nuclear engineer to be dispatched to the TMI-1 control room upon the occurrence of any future
}
nuclear accident should be completed before restarting is authorized.
What are the requirements of the emergency planning rule with regard to the stationing of a nuclear engineer at the licensee's control room in the event of an emergency?
A.
The new NRC emergency planning rule 10 CFR 50, Appendix E requires that arrangements should be made to accommodate State and local staff at the licensee's nearsite EOF.
NUREG-0654 Criteria C.2.A indicates that each principal offsite organization may dispatch representatives to the licensee's EOF, and that State technical analysis representatives at the nearsite EOF are prefered. There is no requirement that State and/or local emergency response organizations station a nuclear engineer or other technical analysis representative in the facility control room.
Q.21.
What provisions has PEMA made for providing representatives capable of technical analysis at the EOF?
A.
The Commonwealth does have a nuclear engineer on the staff of its Bureau of Radiation Protection (BRP) ir. Harrisburg.
He is to respond to BRP headquarters in the event of a nuclear incident and will be directed to report to the TMI EOF, not the control room. He will provide the needed interface for technical assessment and analysis between the State and licensee.
NUREG-0654 specifies that arrangements should be made for the State's technical analyses personnel at the E0F, rather than the control room, since it is the function of the EOF to assess the offsite impact of an accident and to direct offsite tronitoring efforts and emergency response.
Furthermore, the control room personnel will be concerned primarily with the operation of the plant and mitigation of the accident, and as such stationing a State engineer in the control room could distract control room personnel.
In any event, the State does now have a trained nuclear engineer who is a part of the State's emergency response organization.
E.
General Q.22.
ANGRY Contention IIA (EP-3A) states:
There is no requirement that restart be conditioned on ice Radiological Emergency Response Plan of the Commonwealth of Pennsylvania being brought into compliance with resonable standards of adequacy and effectiveness for such plans which include but are not limited to standards promulgated by the NRC itself (e.g., NUREGS-75/11 and 0396; GA0 EMD-78-110; H.R. Rept.96-413);
l l
similarly, ANGRY Contention IID (EP-38) states:
l There is no requirement that restart be conditioned on the Radiological Emergency Response Plans of local governmental units (counties) surrounding the reactor site being brought into compliance with i
l reasonable standards of adequacy and effectiveness for such plans which include but are not limited to standards promc1 gated by the NRC.itself.
(See Paragraph (A)).
1
. These contentions express the intervener's belief that there are no standards which will be applied to the Commonwealth of Pennsylvania and County Radiological Emergency Response Plans.
What are the current standards, and how will they be applied to the State and county emergency plans prior to the restart of TMI-1?
A.
The standards which are applicable to the State and county emergency plans are included in 10 CFR 50.47(b), and 10 CFR 50.54(q), (s), (t),
and (u), and 10 CFR Part 50, Appendix E.
These requirements should be met prior to restart.
The criteria which will be used by the NRC and FEMA staffs as a means of determining compliance with the emergency planning standards are included in NUREG-0654/ FEMA-REP-1, Revision 1,
" Criteria for Preparation and Evaluation of Radiciogical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
The Federal Emergency Management Agency (FEMA) is the Federal Agency charged with evaluating the State and county emergency plans with regard to the planning standards.
FEMA will provide the NRC with findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented. The FEMA findings will be used by the NRC staff in its findings on the overall preparedness for the TMI-1 site and environs.
. u.
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0 MISSION BEFORE THE AT0 HIC SAFETY-AND LICENSING BOARD In the Matter of
)
)
METROPOLITAH EDISON COMPANY,
)
)
)
(Three Mile Island, Unit 1)
)
I hereby certify that copies of "NRC STAFF'S LETTER TO LICENSING BOARD TRANSMITTING TESTIMONY OF FEMA'S VERNON E. ADLER NiD FREDERICK J. BATH ON CONTENTIONS RELATED TO OFFSITE EMERGENCY PREPAREDNESS NID JOINT TESTIMONY OF NRC STAFF'S STEPHEN CHESNUT AND FEMA'S FREDERICK J. BATH ON CONTENTIONS RELATED TO ONSITE/0FFSITE EMERGENCY PREPAREDNESS", dated March 16, 1981, in the 3bove-captioned prc:eeding, have been served on the following, by deposit in the United States cail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Corrission's internal mail system, this 16th day of March, 1981:
Ivan W. Smith, Esq., Administrative Judge-Atomic Safety & Licensing Board Panel Ms. Marjorie M. Aamodt 25 North Court Street R.D. #5 Harrisburg, Pennsylvania 17105 Coatesville, PA 19320 Dr. Walter H. Jordan, Administrative Mr. Thonas Gerusky Judge Bureau of Radiation Protection
-Atomic Safety & Licensing Board Panel Dept. of Envirencental Resources 25 North Court Street P.O. Sox 2053 Harrisburg, Pennsylv inia 17105 Harrisburg, Per.nsylvania 17120 Dr. Linde W. Little, Administ ative Mr. !!arvin I. Lewis Judge 6504 Bradford Terrace Atomic Safety & Licensing Board Panel Philadelphia, Pennsylvania 19149 25 North Court Stteet Harrisburg, Pennsylvania 17105 Metropolitan Edison Company ATTN:
J.G. Herbein, Vice President George F. Trowbridge, Esq.
p.o. gox 542 Shaw, Pittman, Potts & Trowbridge Reading, Pennsylvania 19603 1800 M Street, N.W.
Washington,-D.C. 20006 fis. Jane Lee R.D. 3; Box 3521 Karin W. Carter, Esq.
aOS executive House Etters, Pennsylvania 17319 P. O. Box 2357 Walter W. Cohen, Consumer Advocate Harrisburg, Pennsylvania 17120 Department of Justice Strawberry Square,14th Floor Honorable Mark Cohen 512 D-3 Main Capital Building Harrisburg, Pennsy'vania 17127 Harrisburg, Pennsylvania 17120
Thomas J. Gemine Deputy Attorrey General Division of Law - Room 316 1100 Raymond Boulevard Newark, flew Jersey 07102 Allen R. Carter, Chaiman John Levin, Esq.
Joint Legislative Committee on Energy Pennsylvania Public Utilities Com.
Post Office Box 142 Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 29202 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 liontpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 21218 Louise Bradford Chauncey Kepford 1011 Green Street Judith H. Johnsrud Harrisburg, Pennsylvania 17102 Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmon & !!eiss Ms. Frieda Serrjhill, Chairman 1725 I Street, N.W.
Coalition for Nuclear Power Plant Suite 506 Postponement
!!ashington, D.C.
20006 2610 Grendon Drive Wilmington, Delaware 19808 Mr. Steven C. Sholly Union of Concerned Scientists Gail P. Bradford 1725 I Street, N.W.
klGRY Suite 601 245 W. Philadelphia St.
Washington, D.C.
20006 York, Pennsylvania 17401
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Co. mission
-Washington, D.C.
20555
- Atomic Safety and Licensing Board Panel
/fosephR. Gray /
g U.S. Nuclear Regulatory Comission
/Courtsel for NRC Sta f
!!ashington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Comission ATTN: Chief, Docketing & Service Br.
Nashington, D.C.
20555 William S. Jordan, III, Esq.
Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 i
._