ML20010E688
| ML20010E688 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 09/02/1981 |
| From: | Blume M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Cleeton CLEETON, INTERVENORS |
| References | |
| NUDOCS 8109080150 | |
| Download: ML20010E688 (14) | |
Text
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c Septe.nber 2,1981 M @ W o> f UNITED STATES OF A!1 ERICA b
flVCLEAR REGULATORY C0ftMISSION f etC((d
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NRC STAFF RESPONSE TO INTERVEN0R CLEETONS'INTERR0GATORIES RELATIVE TO EftERGENCY PLANNING AND Tt11-2 RELATED ISSUES The Staff, reserving its right to Board rulings pursuant to 10 C.F.R. 9 2.720(h)(2)(ii), voluntarily answers Intervenor Cleetons' interrogatories filed August 14, 1981 to the extent that it has no objection on other grounds.
Instruction C of the interrogatories asking for documents whict " pertain to" the interrogatories cut not relied upon by the Staff in its answers, and Instruction E, asking for the names of Staff personnel who did not participate in the preparation of Staff's answers herein, are identical to Instructions C and E of the Commonwealth's July 5 interrogatories to the Staff.
For the reasons explained in Staff's " Response Pursuant To 10 CFR Q 2.720(h)(2)(ii) To The Comonwealth's First Set Of Interrogatories..." a 2-3, filed July 10, 1981, Staff objects to these instructions.
Interrogatory No. 1 Question:
What was the state of emergency preparedness in the llarrisburg area and in the Commonwealth of Pennsylvania on March 28, 19797 Please explain fully and in detail.
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Answer:
Staff objects to this interrogatory because it does not ask for information relevant to the issues in this hearing, and is not reasona61y calculated to lead to discovery of such information.
flonetheless, without waiving its objection, Staff voluntarily answers that the following documents describe the state of emergency preparedness in question:
Report of the Office of the Chief Counsel on Emergency Preparedness to the President's Commission on the Accident at Three Mile Island, October 1979; Staff Report to the President's Commission on the Accident at Three Mile Island, October 1979.
Interrogatory No. 2 Question:
Had fietropolitan Edison and the Commonwealth of Pennsylvania conducted any tests of emergency preparedness? Had they checked supplies, hospital readiness, traffic control plans and security troop emplacement for the protection of citizens and their property around the TMI complex? Please describe fully and give all bases for your answer.
Answer:
See answer to No. 1.
Interrogatory No. 3 Question:
In the opinion of Staff is the state of emergency preparedness in the immediate and extended area around the proposed Pilgrim II less adequate, equal to, or better than that around TMI-2 on March 28, 1979? Please detail all differences and similarities.
Answer:
Only preliminary emergency preparedness planning is required at the congtruction pennit stage of the licensing process.
In response to the Threc flile Island (Till) accident the Commission upgraded its energency preparedness requirements (see 45 Fed. Reg. 55403, August 19,1980)and published specific criteria concerning these requirements (NUREG-0654).
Once licensee and state and local emergency plans comply with these new requirenents they will provide a level of emergency preparedness beyond that existing at T!!I when **e accident occurred. The differences and similarities cannot be detailed since the final emergency plans for Pilgrim II (which are required at the operating license stage) have not yet been prepared. The NUREG-0654 requirements can be compared with the THI-2 emergency plans for any differences. The Staff has made no such comparison itself.
Interrogatory No. 4 Question:
To Staff's knowledge have any of the emergency planners spent more than a few hours inspecting specific problem areas described in the studies for evacuation at Pilgrim II? Please give full details of time spent, methods used, and qualifications of planners.
Answer:
Staff objects to this interrogatory pursuant to 10 C.F.R. 9 2.720(h)
(2)(11) to the extent that it asks for information available from others such as BeCo and state and local officials.
Staff also objects on the ground that it is unclear what " inspecting specific problem areas described
in the studies for evacuation..." refers to. Staff, based on its understanding of the question says that detailed evacuation planning will be condu,pted by state and local officials, and their efforts will be reviewed by FEMA. Therefore, the majority of the work on evacuation The NRC planning at Pilgrim will be conducted by these organizations.
and its consultants, however, have reviewed the studies prepared by the Applicant as described in NUREG-75/054, Supplement No, 5, and have themselves inspected the site and surrounding area.
Staff does not know exactly how much time has been devoted to this effort, though it exceeds one man-week.
Interrogatory No. S Question:
If a thorough study has not been done, why has a matter so crucial to the health and safety of the public been ignored?
Answer:
Staff objects to this interrogatory because it does not request relevant information and is not reasonably calculated lead to such information.
It is instead argumentative and ignores the requirements of 10 C.F.R. Part 50, Appendix E that only a " preliminary analysis" is necessary at the construction pennit stage.
Interrogatory No. 6 Question:
We were told by Mr. Froelich, of the Environmental Protection Division of the NRC, that the NRC had an evacuation plan for Cape Cod.
What is the evacuation plan? Please describe in detail.
Answer:
Staff knows of no NRC evacuation plan for Cape Cod.
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. O Interrocatory No. 7_
Question:
I N If the NRC has no plan for evacuating Cape Cod, does o
the Federal Emergency Management Agency have such a plan? Please describe fully.
Answer:
Staff is not aware of a FEMA evacuation plan.
Interrogatory No. 8 Question:
If there are no plans for evacuating Cape Cod, what are the reasons that a matter so essential to the health and safety preparedness 'of the public have been neglected? Please list all reasons.
Answer:
Evacuation planning is the responsibility of the licensee and state and local governments. NRC regulations do not require such planning beyond The basis for the 10-mile EPZ can ti found in NUREG-0396.
the 10-mile EPZ.
Interrogatory No. 9 Question:
Does Staff know whether any study of the voluntary, partial (pregnant women and small children), and general evacuation, which took place after the accident at TMI-2, has been done? Please give full results of such a study.
Answer:
NUREG/CR-1215 discusses the social and economic effects of the THI accident, including evacuation.
In addition, see Geographical Review 4
(January 1981), which contained the article " Evacuation from a Nuclear Technological Disaster" discussing evacuation at TMI.
Interrogatory No. 10 Question:
If a study of these evacuatiens has not been donc, why has this excellent opportunity to learn more t about the health and safety needs, and the behavior, of the public in an actual emergency been overlooked? Please explain fully.
Answer:
Staff objects to this interrogatory because it is argumentative, ani neither asks for nor is calculated to lead to the discovery of information relevant to the issues in this proceeding.
Interrogatory No. 11 Question:
What study has been conducted by the NRC, or by any agency or person (s) commissioned by the NRC, or by any other person (s), concerning the biological effects of ionizing radiation upon the general population in the immediate and extended areas surrounding THI-27 WhaL are the detailed findings, to date, of this study? What future health problems are projected?
Answer:
See The Report of the President's Commission on the Accident at Three Mile Island (October 1979); NUREG-0558, Population Dose and Health Impact at Three Mile Island Nuclear Station-Prelinindry Estimates Prepared by the Ad Hoc Inter-Agency Dose Assessment Group (tiay 1979).
Also, see answer to No. 9.
Interrogatory No. 12 Ouestion:
If the study referred to in 11 has not been done, when is such a study planned? Why has a study so vital to the health and safety of the public been delayed? Please give a full explanation.
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Answer:
See answer to No. 10.
tt Interrogatory No. 13 Question:
Has the NRC, or any person (s) or organization, conducted a study of persons in the inmediate and extended area around THI-2, who are at special risk, like Mrs. Cleeton? (See attached letter) This would include persons with respiratory illness, extended irradiation through medical and dental
- -rays, radiation therapy, and/or a family history of cancer.
If so, what are the findings? Please give full detail.
Answer:
See answer to No. 9.
None have been done by the NRC.
Interrogatory No. 14 Question:
If such a study has not been done, why has a matter which would necessarily involve the health and safety of a substantial percentage of the public been disregarded? Please explain fully.
j Answer:
See answer to No. 10.
Interrogatory No. 15 Question:
Has a study been done of the psychological and economic effects of the accident at TMI-2? How many people have had to sell their homes at a loss, in order to leave the area? How many people have had to consult psychologists or psychiatrists due to their concerns about the health and safety of themselves and their families? Please list all findings of such a study.
Answer:
See answer to flo. 9.
In addition, during the past two-and-a-half ye4rs there have been numerous studies of the psychological and economic t
effects of the accident at Tf11-2.
The results of an NRC study covering the econonic effects and general indicators of psychological effects are reported in:
U.S.N.R.C., Three Mile Island Telephone Survey, NUREG/CR-1093 (October 1979), prepared by flountain West Research, Inc.;
U.S.N.R.C., The Social and Economic Effects of the Accident at Three Mile Island, NUREG/CR-1215 (January 1980), prepared by flountain West Research, Inc.
The findings of these and other studies provided the basis for the environmental and socioeconomic impacts section of the Nuclear Regulatory Commission Special Inquiry Group, Three Mile Island:
A Report to the Commissioners and to the Public, Vol. II, Part 2, January 1980.
A study of the effects on real estate is reported in U.S.N.R.C.,
Effects of the Accident at Three Mile Island on Residential Pronqrtl Values and Sales, NUREG/CR-2063 (April 1981), prepared by Pennsylvania State University.
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The Commonwealth of Pennsylvania has also studied the psychological and economic effects of the accident. The results of these studies are reported in Commonwealth of Pennsylvania, Report of the Governor's Commission on Three Mile Island (February 26,1980). Greater detail on l
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the econoaic effects is provided in Commonwealth of Pennsylvania, Three Mile Island Socio-Econclic Impact Study, December 14, 1979, prepared by the Gove.rnor:s Of fice of Policy and Planning.
The mental health ef fects of the accident were extensively considered in Peport of the President's Commission on the Accident at 3
Three Mile Island, October 1979, and in the Technical Staff Analysis Continuing Report on Behavioral Effects _ to the President's Commission.
studies of the behavioral effects are being supported by the Pennsylvania Department of Health and the U.S. Department of Health and Human Services, National Institute of !! ental Health.
The NRC Staff is not aware of any specific data on how many people have had to sell their homes at a loss in order to leave the area; nor is it aware of data on how many people have had to consult psychologists or psychiatrists due to their concerns about the heal +h and safety of themselves and their families. The findings of the various reports are clearly laid out in those reports but they are too numerous to present here.
Interrogatory No.16 Question:
If such a study has not been done, can Staff explain why a matter deeply involving the health and safety of the public, as well as their economic welfare, has been omitted from consideration?
Answer:
See answer to No. 10.
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l Interrogatory No. 17 Question:
,In previous hearings-an opportunity for lim $ted tappearance statements from local citizens was l
deferred until the hearings on emergency planning.
i In Staff's opinion, at what times and locations are
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+hese Simited appearance statements likely to be authorized?
Answer:
See answer to No. 10. Staff also objects to this question because it asks for information available only from another source, i.e., the Board itself, ichael B. Blume Counsel for NRC Staff Dated at Bethesda, Maryland, this 2nd day of September, 1981.
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September 2, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t
it BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of BOSTON EDISON C0!!PANY, ET AL.
Docket No. 50-471 (Pilgrim Nuclear Genertting Station, Unit 2)
AFFID. WIT OF DIN 0 SCALETTI I am Project Manager in the Nuclear Regulatory Commission Staff's Division of Licensing.
The Responses to Intervenor Cieetons' Interrogatories Relative to Orrgency Planning and TMI-2 Related Issues filed on August 14, 1981, and numbered 11-13, 15 were prepared by me. The resportses given are true and accurate to the best of my knowledge.
I declare under penalty of perjury that the foregoing is true and d !Tr/
correct.
Executed on
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' Dino Scaletti Dated at Bethesda, Maryland, this 2nd day of September,1981.
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O September 2, 1981 UNITED STATES OF AllERICA NUCLEAR REGULATORY C0ftllISSION tt BEFORE THE AT0!!IC SAFET7 ANC LICENSING BOARD In the !!atter of BOSTON EDIS0N COMPANY, ET &.
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Docket No. 50-471 (Pilgrim Nuclear Generating Station, Unit 2)
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AFFIDAVIT OF THOMAS MCKENNA I am Euergency Prep..edness Analyst in the Nuclear Regulatory Commission Staff's Emergency Preparedness Licensing Branch.
The Responses to Intervenor Clectons' Interrogatories Relative to Emergency Pli.oning and Till-2 Relates Issues filed on August 14, 1981, and numbered 1-10, 15-16 were prepared by me. The respo,nses given are true and accurate to the best of my knowledge.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
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[L h-Thom y McKenna Dated at Bethesda, Maryland, this 2nd day of September,1981.
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UNITED STATES OF Af! ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _
t In the 11atter of
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Docket No. 50-471 (Pilgrim Nuclear Generating Station, Unit 2)
CERTIFICATE OF SERVICE I herehy certify that copies of "NRC STAFF RESPONSE TO INTERVEN0R CLEETONS' l'ITERROGATORIES RELATIVE TO EMERGEpCY PLANNIrlG AND TitI-2 RELATED ISSUES",
" AFFIDAVIT OF THOMAS MCKENNA", and " AFFIDAVIT OF DIN 0 SCALETTI" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal nail system, this 2nd day of September,1981 :
I Andrew C. Goodhope, Esq.
The Board of Selectmen Administrative Judge Town of Plymouth 3320 Estelle Terrace Plymouth, MA 02360 Wheaton,110 20906 William S. Abbott, Esq.
Dr. A. Dixon Callihan 50 Congress Str.eet, Suite 925 Administrative Judge Boston,fiA 02109 Union Carbide Corporation P.O. Box Y Jo Ann Shotwell, Esq.
Oak Ridge, TN 37830 Assistant Attorney General Environmental Protection Division Dr. Richard F. Cole
- Public Protection Bureau Administrative Judge One Ashburton Place,19th Floor Atomic Safety and Licensing Board Boston, itA 02108 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Lester B. Smith Director of Conservation Thomas G. Dignan, Jr., Esq.
Massachusetts Wildlife Federation R. K. Gad III, Esq.
P.O. Box 343 Ropes & Gray Natick,itA 01761 225 Franklin Street Boston,itA 02110 William S. Stowe, Esq.
Boston Edison Company Henry Herrmann, Esq.
800 Boylston Street 50 Congress Street, Room 1045 Boston, MA 02199 Boston,itA 02108
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2-Mr. and Mrs. Alan R.. Cleeton Patrick J. Kenny, Esq.
22 Mackintosh Street Edward L. Selgrade, Esq.
Franklin, MA 02038 Massachusetts Governor's Office of Energy Resources Francis S. Wright, Esq.
73 Tremont Street Berman & Lewenberg Boston,itA 02108 211 Congress Street Boston,,)tA 02110 Atomic Safety and Licensing.
Board Panel
- Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel
- Washington, DC 20555' U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section
- Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Michael B. Blume Counsel for NPC Staff e
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