ML20039A195

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Proposed Findings of Fact & Conclusions of Law
ML20039A195
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 12/09/1981
From: Adler R
PENNSYLVANIA, COMMONWEALTH OF
To:
References
NUDOCS 8112160345
Download: ML20039A195 (17)
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l LUITED STATES OF AMERICA DOCKETED NUCLEAR REGUIATORY 0@tESSION N i

BEFORE WE AlmIC SAFEIY AND LICENSING BOARD '81 DEC -9 P2:23 In the Matter of: a SicaETAri/

l . P.G & SERVlCE H

PEtETLVANIA POWER & LIGIT 00.  :

and  :

ATIFrJ{ENY EECTRIC COOPERATIVE,  : Docimt Nos. 50-387

  • INC. (Susquehanna Steam Electric  : 50-388 #

Station, Units 1 and 2)  : es

,b 00HGEEALE OF PENNSYLVANIA'S a $7/Vgs '

PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF IAW - (fCJ O u,

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9; 198g $}l I. INIRODUCTION In its proposed findings and conclusions set forth below, the Comnonwealth takes advantage of its righc to adopt positions and " advise the Comnf.ssion" only on a number of discrete issues. 42 U.S.C. 52021(1);

10 C.F.R. 52.715(c). The Board should not infer from the Connonwealth's decision to propose findings and conclusions only on discrete issues that the Connenwealth has not reviewed the entire record. Ratbar, the Connonwealth sinply elects to exercise its right to advise the Comnission on specific energency planning issues on which the Connonwealth perceives deficiencies that need to be renedied. The Connonwealth does not adopt specific findings and conclusions proposed by any other party. Mareover, the Cermnwealth reserves its right to participate as a full party on all issues on appeal. Gulf State Utilities Co. (River Bend Station, Units 1 and 2) AIAB-317, March 4, 1976, 2 NUC. Reg. Rep. (.CQi) 130,053.

p58 Soi 8112160 3 YW; -

4 . l II. PROF 0 SED FINDINGS OF FACT AND CONCLUSIONS OF IR ON DERGENCY '

PUMDU 00tmNTIONS.

d A. Evacuation.Of Persons Without Transportation ~

> ' l.' h evacuation from the' plume exposure pathway EPZ of persons

, who do not possess their own means of transportation obviously is one of

the more difficult aspects of evacuation planning. TWo major groups of people fall into this category
(1) school children; and (2) other m ebers of the non-automobile-owning population. As the emergency ,
planning contentions in this proceeding are written, this important
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l issue cuts across a niunber of sections of contentions. However, due to the in.portance of this issue, and because the issue was the subject of a protracted oral debate during the hearing, the Board believes that it is i important to treat it as a discrete issue.

2. h applicant ertployed a contractor, IMi Associates, Inc. , to

' prepare the e acuation time estimates required by NUREG-0654, Planning Standard J, Criterian 10(1). Staff Ex. 7, at 63. See also id. App. 4.

h evacuation time estimates in the IMi study include the time required

, to evacuate special facilities within the plune exposure pathway EPZ, including schools, hospitals and nursing homes. It is assumed that departures from schools, which conprise the bulk of this population, will begin 90 minutes after an order to evacuate is given. McCandless,

ff. Tr. 2250, at 6-7.
  • Contention 20[7](a] deals, inter alia, with the evacuation of individuals without other means of tEansportation. As exp1=4naA more fully below, the evidence indicates that this issue is intertwined i

with the issue of school evacuation. Contention 20[71[d] daala with the relocation of both school children and other individuala without transportation. Contention 20[7][f] deals with evacuation time estimates. h Applicant's time estimates include estimates for the evacuation of. school children and other individuals without L triusirg tation. See 1 2 , infra. Contention 6(a) also daala with I

evacuation time estimates. h d has already ruled that the evacuation of persons without transportation is included in the-scope of this contention. Tr. 2287.(Chaimmt Gleason).

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3. Evacuation during the weekday, when schools are in session, was estimated by IMi to be nore time consuming than a night or weekend evacuation. McCandless, ff. Tr. 2250, at 8. 'Iherefore, evacuation of school children is an inportant consideration in detemdning the limiting evacuation scenario in terms of maximrn expected evacuation time.
4. School students conprise a high percentage of the population to be evacuated fmn the plune exposure pathway EPZ for Susquehanna (during a weekday). Of the 71,511 persons in the EPZ, 15,587 are school

, students, conprising approximately 22 percent. McCandless, ff. Tr.

2250, at 5.

5., 'Ihe non-auto-owning popnlaHm within the plune exposure

- pathway EPZ for SSES constitutes awwximately 13.5 percent of the population to be evacuated. 'Ihere are 9,679 people who are members of non-auto-owning households, out of a total of 71,511 cvacuees within the EPZ. McCandless, ff. "r. 2250, at 5-6. When added to the school population, a total cf 25,266 people, or over 35 percent of the population,

'will require bus transportation.

6. HMM assumed 40 students per bus in calculating the number of buses required to evacuate nearly 16,000 students. Tr. 2253 (McCandless).

'Iberefore, approximately 400 buses will have to be mobilized to evacuate all students within the plume exposure pathway EPZ in a single run.

Using the same assunption of 40 persons per bus, an additional 242 buses would be required to evacuate the estimated 9,679 non-auto-owning mecibers of the EPZ population.

7. Mr. McCandless initially testified that the 90-minute assumed school departure time was concurred in by state and local officials.

Tr. 2257 (McCandless). 'Ibe witness could not : acall, however, which l

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state official had agreed with this figure. Id. at 2258. 'Ibe witness later amended his testimony, pointing out that the state was not explicitly asked to agree with the 90-minute assmption. Rather, the entire evacuation time estimate report was reviewed with PD% staff, and no couraent was made on the 90-minute assmption. h existing county plans do not rely on an assumed 90-mirmte departure time for school students. Tr. 2295 (McCandless).

8. h Board has serious problems with the RM assmptions regarding the evacuation of school children, as well as other members of the non-auto-owning population, prior to the development of written school district plans. Ibst importantly, in developing time estimates for school children, RH did not consider aspects of inplementation of school evacuation. EM did not consider whether the school plans exist or are necessary in order to assume that school populations can be evacuated within the estimated time frames. Tr. 2258-59 (McCandless).
9. RM also did not specifically address the time required to initiate evacuation of the non-auto-owning population. Rather, they assuned that surplus buses will be available to evacuate the non-auto-owning population simultaneously with the school population. Tr. 2259 (McCandless). As with school evacuations, the RM study merely assumes that plans to evacuate the non-auto-owning population will be inplemented adequately. _I_d.

d at 2260. Essentially, to fill these voids in the analysis, IMI relied on assumptions made by other PP&L consultants as a basis for its time evacuation study. Tr. 2286 (Mcondless). 'Ihe applicant subsequently presented another witness to clarify the bases for the assmptions regarding school evacuations. 'Ihis witness was Mr.

Robert Carroll of Faergency Managenent Services, Inc. Tr. 2307. 'Ihis witness, however, did not convince the Board that there is reasonable l

assurance that schools can be evacuated within the Mmes estimated by 1994, under all circumstances, absent the preparation of writtan school district plans.

10. Mr. Carroll testified that he had conversations with representatives of all of the affected school districts within the plune exposure pathway EPZ. During these discussions, Mr. Carroll received oral opinions that the 90-minute nobilization time for school evacuations was a reasonable assucption. h se opinions were based on previous experiences with school bus cobilization during early school dismissals in cases of heavy snow. Tr. 2312-14 (Carroll). Mr. Carroll's efforts j

provide scxne assurance that school evacuation would proceed scoothly in the event of an accident at SSES. The Board does not believe, however, that "some assurance" is adequate. According to Mr. Carroll's own testimony, "the evacuation of school children is one of the primary concerns of any evacuation scheme . . ." Tr. 2317. h Cocmi.ssion's emergency planning regulations require " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." 10 C.F.R. 550.47(a)(1) . To base such a finding on mere

, oral affirmations by the offiMnla responsible for carrying out an evacuation would defeat the purpose of the emergency planning rule.

11. h fact that schools have successfully nobilized buses for early closings due to snow does not provide reasonable assurance that the same could be accouplished during a nuclear emergency. The Applicant's witness could not equate the two situations in terms of the l availability of drivers during a nuclear emergency. Tr. 2320 (Carroll).

Moreover, a large percentage of some schools is cocprised of students who normally do not receive bus transportation. For exacple, in the

Berwick school district, only 23 buses are needed for students who nomally receive bus transportation. Yet 76 buses are needed to transport the entire student population during a nuclear emergency. Tr. 2327 (Carroll). During a nuclear accident, even those students who normally walk to school will be evacuated to student pick-up points by bus.

Under no circumstances will students be sent or taken home. Tr. 2333 (Carroll). Therefore, past nobilizations involving smaller numbers of buses than would be r_ quired to respond to a nuclear emergency may not necessarily be indicative of the problems that would occur during a nuclear accident.

12. Written school district plans would provide far greater assurance that school evacuation would proceed smoothly. There are currently no written school district plans in place to deal with a nuclear emergency at SSES. Tr. 2317 (Carroll); Henhson, ff. Tr. 2546, at 28. A number of uncertainties remain absent such plans

(1) There are no written agreements between school districts and bus cccpanies describing the responsibility to provide buses during a nuclear mergency. Tr. 2318 (Carroll).

(.2) There are no written identifications of bus drivers responsible for resmnding during an emergency; nor is it clear whetwr there are __r_rz a

identifications of alternate drivers. Tr. 231T-19

(_ Carroll) .

(31 Perhaps nest immrtantly, there are no written routes to direct %s drivers to the pre-allocated student pickup points." Tr. 2319 (Carroll).

(41 One school district (Berwick) does not have sufficient buses under its own control to evacuate its entire school population. The Berwick school district intends to receive buses from surrounding districts to fill this deficiency. But there are no written agrements between the Berwick school district and the surrounding districts.

Tr. 2312-13; 2320 (Carroll).

  • Parents of school children will be directed to these points to pick up their children during an mergency.

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a (5) According to the Applicant's witness, I the 90 minutes assuned for nobilization of school buses includes the time for the school district official to contact the bus contractor, the time for the contractor to locate the bus, and the time to bring the bus to the school and load the children. Tr. 2314 (Carroll). Yet nost of the drivers are enployed in other jobs, and uould first need to be contacted. Tr. 2325 (Carroll).

'Ihen the drivers would need to go home to get the buses. Tr. 2332 (Carroll). Applicant s contractor did not investigat.e the canunications system to the drivers, whether alternate comunications exist, or whether the buses have radios. Tr. 2325, 2332-33 (Carroll).

13. 'Ihe Board attributes particular weight to the testimony of- the Comorsealth's emergency planning witnesses. 'Ihe PDR panel testified repeatedly that there can be no reasonable assurance that school. children will be evacuated in a Hmaly fashion until school district plans have been prepared and coordinated with the county plans. In their written

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testimony, the witnesses stated:

(3) An adequate response to the issue as to whether all school children can be evacuated without buses making a return run can only be made after the school districts have developed their respective plans. 'Ibere are obviously sufficient buses that could be moved in from areas surrounding the plane exposure pathway EPZ to effect the evacuation of school children by using only a single run. 'Ibere is, however, the time factor that nust be considered as well as the period needed to notify drivers and their availability whether within or outside the EPZ.

'Ihis is an iten that can only be resolved after school district superintendents cocplete their plans and coordinate them with the.Luzerne County Civil Defense Agency. 'Ihis should be accouplished prior to full o, eration of the Susquehanna Steam Electric Station.

Belser, et al., ff. Tr. 2586, at 25.

14. Mr. Belser further opined during oral testimony that the preparation of written school district plans prior to plant operation is the nost important element of offsite emergency planning for SSES. Tr.

2607-08 (Belser). &. Belser elaborated by stating that there "is probably nothing of nore concern to a parent than the welfare of the children." Id. at 2609. In addition, Mr. Belser pointed out that the requiring school districts to prepare plans is not an easy accenplishment.

! AlthouSh a letter from the Director of PDR and the Secretary of FAration was being prepared to encourage school districts to prepare emergency plans, this effort provides no absolute assurance that the plans will be developed prior to plant operation. Tr. 2609-10 (Belser).

15. Appendix 11 (Schools and Colleges Energency Plans) to the Comonwealth's emergency plan clearly indicates that school district plans are necessary to ensure the safety of school children. The objective of Appendix 11 is to "specify responsibilities for developing plans needed for the safety of school children and college students

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during a nuclear facility hidant . . ." Comonwealth Ex. 7, at E-ll-1 (emphasis addad).

16. In fact, until the availability of buses is verified and until school district plans are coupleted, PHR will not accept the current

't R M evacuation time estimates. Instead, PER will accept for planning purposes a normal weekday estimate of evacuation time as 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, 45 minutes. Belser, et al., ff. Tr. 2586, at 27. Bis is to account for the possible need for a double run of buses. Tr. 2604-05 (Hippert).

17. 'Ihe PHR panel reached similar conclusions regarding other menbers of the non-auto-owning populations:

The logistics of coving individuals without transportation have not been fully developed, nor can they be until school district plans are coupleted by the respective district superintendents. When schools are in session, first priority for buses is evacuation L of school children.

Belser, et al., ff. Tr. 2586, at 24. See also Tr. 2612-13 (Hippert).

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18. Witnesses for both the Applicant and the Staff agree that school distric'; plans should be prepared prior to plant operation. Tr.

2317, 2328, 2335-36 (Carroll); Tr. 2675-76, 2685 (Swiren). In fact, Mr.

Carroll stated that "the evacuation of school children is one of the primary concerns of any evacuation scheme that we have and certainly consideration of evacuating schools should enter into that." Tr. 2317.

Yet the Applicant asks the Board to find that planning for the evacuation of school children and other members of the non-auto-owning population has been adequately addrcosed, on the assunption that written plans will be in effect at the time of plant operation. See Applicant's Proposed Finding 85. The Board rejects this apprcach. h emergency planning rule requires reasonable assurance that adequate protective measures can and will be taken. 10 C.F.R. 550.47(a)(1) . The Applicant also argues that no school district plans have been prepared around the state.

Applicant's Proposed Finding 85. The Board views this as irrelevant.

This Licensing Board has the responsibility to adjudicate issues involving the safe operation of SSES. Its jurisdiction does not extend to other nuclear plants in Pennsylvania. bbreover, the Cocmonwealth's views regarding the need for school district plans for other nuclear plants in Pennsylvania are no different than for SSES. Tr. 2666 (Belser).

19. The Board concludes that there can be no reasonable assurance that adequate protective measures can and will be taken for school children and other members of the non-auto-owning population until the school district plans are developed. Therefore, SSES should not receive a full power license until this important development is denonstrated.

t B. Dosimetry

20. Two sections of Contention 20 allege deficiencies regarding dosimetry for emergency wrkers. Contention 20[5][b] alleges, in part, that no reference is made to required reserves of emergency equipment and instninents. As explained further below, dosimeters for emergency workers are included in this category. Contention 20[8][a] alleges that there are inadequate procedures to ensure that dosimeters are read at appivpciate frequencies and that dose records are maintained for emergency workers as required by NUREG-0654. Staff Ex. 7, at 67.

Obviously, this contention cannot possibly be met unless there are adequate supplies of dosimeters to distribute to emergency workers at the time of an emergency. 'Ihe Board finds below that adequate supplies of dosimeters do not currently exist for SSES.

21. 'Ihe function of dosimetry is to determine the radiological dose received by an individual. In the case of emergency workers, dosimetry is the method used to determine the amount of exposure he is receiving, specifically for purposes of advising the worker to leave the pitzne exposure pathway EPZ once the pre-determined level of exposure has been reached. Cocnx:rawealth Ex. 8, Appendix 16,Section V.B.
22. Emergency workers, as a category, are specifically referred to in the energency planning rule and NUREG-0654. Planning Standard J of NURED-0654*i requires that "[a] range of protective actions have been developed for emergency workers...". Staff Ex. 7, at 59. Planning Standard K of NUREU-0654** requires that the "[m]eans for controlling l

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radiological exposures, in an emergency, are established for emergency workers." Staff Ex. 7, at 66. % e specific evaluation criteria refer to dosimetry, both self-ramHng and permanent record devices, as the suggested means of controlling radiological exposures. d Criterion I_d.

3a, b. See also Tr. 2678 (Swiren).

23. The Qxmomealth of Pennsylvania has incorporated both suggestions in its plans regarding energency workers during a fixed nuclear facility incident. Cnmenwealth Ex. 8, Appendix 16,Section V. In fact, since evacuation and sheltering are alnost by definition inappropriate for energmcy workers, the Ccononwealth relies on the use of dosimetry as the major protective measure to be taken for this group. h Qxmonwealth's plans regarding the use of dosimetry for emergency workers are consistent with federal guidance. Tr. 2700 (Swiren).
24. ~ h state plan, as reflected in Cocnomealth Exhibit 8, presently calls for distribution of dosimetry to the emergency workera at the time of an incident. Carmonwealth Ex. 8, Appendix 16,Section V.B. When available, dosimetry for emergency workers responding to an accident at SSES will be predistributed by the state to the counties so that adequate supplies will be readily available at the time of an incident. 'Ihe current state and county plans call for each emergency worker to receive three dosimeters: (1) a CDV-730 (self-reading with a range of 0-20 roentgens); (2) a CIN-742 (self-reading sdth a range of 0-200 roentgens); and a thernoluninescent dosimeter (TID) for permanent record dosimetry. Belser, et al_. , ff. Tr. 2586, at 19; see also Henderson, ff. Tr. 2346, at 40. hse plans are consistent sdth current federal 1

guidance for required dosimetry. Tr. 2700 (Swiren). l l

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25. The Applicant apparently agrees that mergency wrkers should receive self-reading dosimeters, as well as thermoluminescent dosimeters (ILD's) to establish an accurate permanent record of each individual's radiological exposure. Deery mergency wrker coming onsite from offsite response agencies will receive a IID.Cantone, ff. Tr. 2383, at 6 (113).

All emergency wrkers coming onsite from response agencies will also receive self-ramHng dosimeters. Tr. 2398-99 (Cantone). Ine importance of ILD's was explained by the Staff's witness. Tr. 2690-91 (Chestnut) .

26. However, the State currently has a substantial shortage of dosimetry for offsite emergency wrkers. Until these deficiencies are reedied, plans to predistribute dosimeters cannot be fully implemented.

The Comonwealth currently does not have a sufficient supply of CDV-730's to predistribute to mergency workers within the plume exposure patiraay EPZ. More importantly, the Comonwealth has n_o available 11D's to predistribute to the counties. Belser, et al., ff. Tr. 2586, at 19.

In the opinion of PDR's Director of Plans and Preparedness, this deficiency nust be addressed prior to the plant operation. Id.

27. Based on Mr. Swiren's testimony (Tr. 2678, 2698-2700), the Applicant has stated that " Federal Guidance, while calling for each emergency wrker to have self-reading dosimetry, does not require two self-reading dosimeters for each mergency worker." Applicant's Proposed Finding 104. The State plan to provide two self-reading dosimeters is based on FDR's " Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 - Airborne Release" (FDR-REP-2, September 1980).

Comorwealth Ex. 8, at 1. This publication has not been cancelled, and the State plan is currently consistent with FDR guidance. Tr. 2700 (Swiren).

28. PD% has forwarded a request to the Federal Emergency Management Agency (FDR) in Washington to provide the necessary TLD's and CIN-730's to couplete predistribution of adequate supplies of dosimeters. Belser, et al. , ff. Tr. 2586, at 19. The Camonwealth has not received a response to this request. Tr. 2607 (Belser). The FEMA witness, however, indicated in oral testimony that this request will not be met by FDR.

Tr. 2672-73 (Swiren). Essentially, Mr. Swiren testified that, unless dosimeters are supplied by the state or the utility, they will not be available. Id. No such arrang m ent has been made to date. Tr. 2677 ,

(Swiren).

29. The Board believes that a supply of both self-reading and permanent-record dosimetry, sufficient to equip each emergency worker according to the state plan, should be available. This is consistent with the emergency planning rule's requirment that adequate equipment to support the emergency response nust be provided and maintained. 10 C.F.R. 550.47(b)(8); NUREG-0654, Planning Standard H . Therefore, it is directed that no full power license should be issued to the Applicant until this deficiency is addressed.

C. Public Information

30. The adequacy of plans to provide information to the public prior to and during a nuclear emergency at SSES was the subject of a nunber of portions of Contention 20. See Contention 20[1][a], [2][b],

[4][a].

31. Witnesses frcxa all three parties who testified on this issue agreed that the provisions for public information in the written mergency
  • The evaluation criteria for Planning Standard H indicate that this requirment is specifically intended to encocpass radiological monitoring equipment, such as dosimetry. Staff Ex. 7, at 52-55 (Planning Standard H, Criteria 10 and 11).

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l plans are adequate. Henderson, ff. Tr. 2546, at 1-2, 7,15-16 (Applicant);

Belser, et_ al. , ff. Tr. 2586, at 2, 6-7,10-11,17-18 (Ccanomealth);

Swiren, ff. Tr. 2671, at 4-5, 11, 21. See also Cocznomealth Ex. 8,

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Appendix 15; Conmomealth Ex. 9, Annex (D).

32. h Board finds, therefore, that public infonnation is adequately addressed in the written ernergency plans of the Conmonwealth and the counties. Written plans alone, however, will not ensure that msnbers of the public will respond properly during an anergency.
33. The energency planning rule sets forth a planning standard which requires that "(i]nfonnation (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 energency . . .". 10 C.F.R. 550.47(b)(7). 'Ihe evaluation criteria of NUREG-0654 specify that such public information should include, at a minirn.rn, general information on the effects of radiation, information en eivacuation routes and protective measures available, and information for populations with special needs. Staff Ex. 7, at 49 (Planning Standard G, Criterion 1) . Obviously, in order for members of the public to know how they will be notified, and what their initial actions should be, this public education program cust be in place prior to the occurrerce of an emergency.
34. h primary means of alerting the public during a radiological emergency at SSES will be through a siren systen installed by the Applicant. The only purpose of sounding the sirens, however, is to alert the public to listen to the local Emergency Brnadent Station (EBS) on their radio or IV. Prepared messages will be broadcast over the EBS stations to advise the public of the apywp1.iate protective actions to take. Belser, et_ al_., ff. Tr. 2586, at 2. Obviously, this systen requires prior knowledge by the public that the sounding of the sirens sinply means to tune to EBS, rather than, for exanple, to begin evacuation. '(In fact, tDe couplete opposite action, i.e. , shelter, may be the appropriate protective action. EA , Tr. 2507-08 (Reilly).
35. Public information regarding ruclear accidents, therefore, must be disseminated both prior to and during an emergency. According to the emergency plans, this public education effort consists of three parts:

(1) general information regarding the nature of radiation, its hazards and effects, and the protective actions that can be taken to minimize these effects; (2) dissemination of pre-emergency information to inform the public of the plans and procedures that will be used during an emergency to notify the public and to implement protective actions; and (3) emergency information and instructions issued by the state at the time of an incident.

Belser, et al., ff. Tr. 2586, at 6, 17-18.

36. The need to disseminate written public information prior to plant emphasizes was ecphasized during oral testimony by PDR's public information officer, Mr. Comey. Tr. 2606 (Comey). Mr. Camey testified that pre-mergency distribution of information, to establish a firm basis of accurate public information and understanding, makes public information disse::ination during an emergency much nore effective. Tr.

2605 (Comey),.

37. Pre-emergency dissaination of public information is also

inportant to ensure the smooth evacuation of transient populations, i.e.

persons tho do not reside in, but may be present in the plume exposure patluay EPZ at the time of an irv idat. These populations include persons at businesses, motels, hotels, senior citizens' health care facilities, etc. After the initial dissemination of public information brochures, managers of such facilities will receive a personal letter from the respective county with another copy of the brochures and other information necessary to provide transients with information at the time of an emergency. Tr. 2616-17 (Hippert). Without pre-mergency dissmination of this information, transients will have even less basis to know what procedures to follow during an mergency than the resident population.

38. The witness from FEMA categorically agreed that public information nust be dissminated prior to plan operation. Tr. 2674 (Swiren).
39. The Board concludes that, in order to ensure that the public is adequately informed of the correct procedures to follow in the event of an accident at SSES, the public information program outlined in the state and county emergency plans uust be implemented prior to plant operation. Absent pre-emergency dissmination of public information, there can be no AnMng of " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological mergency."

10 C.F.R. 550.47(a)(1). The Board directs, therefore, that no full power license shall be issued to the Applicant until a showing has been made by the Applicant that public information brochures containing both general information on radiation exposure and specific instructions on actions to-take in the event of an accident have been distributed to members of the public within the p1tme exposure pathway EPZ for SSES.

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III. ORDER

[Ihe Caumormealth proposes that the following paragraph be inserted

. in the Board's orders] ..

Issuance of-the aforemenHmM operating license shall be subject to the following condition. No full power operating license shall be g N issued until the Director of Nuclear Reactor Regulation, in consultation

. with the Federal ~ Emergency Managment Agency, finds that:

(1) all school districts within the plune exposure pathway energency planning zone for Susquehanna Steam Electric Station have completed adequate emergency plans to cope with a fixed nuclear facility accident; (2) adequate numbers of self-reading and permanent record (thermoltminescent) dosimeters, consistent with ,

applicable federal guidance, are available for distribution to all offsite anergency workers identified in the state and county emergency plans as requiring dosimetry; and (3) the Applicant has distributed to members of the public within the plume e:gosure pathway emergency planning zone for Susquehanna Steam Electric Station, public infonnation brochures containing general information on radiation exposure and specific instructions on actions to take in the event of a nuclear accident.

Respectfully sulmitted, 4

G ROBERT W. ADL R JyU - lf

/

Assistant Counsel Conronwealth of Pennsylvania I

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