ML20040D913

Comments on Immediate Effectiveness of ASLB 811214 Partial Initial Decision.Issue of Inadequate Supplies of Dosimeters for Emergency Workers Not Resolved by Decision.Portions of Transcript & Certificate of Svc Encl

ML20040D913
Person / Time
Site:	Three Mile Island
Issue date:	01/26/1982
From:	Adler R, Straube M PENNSYLVANIA, COMMONWEALTH OF
To:
References
NUDOCS 8202020386
Download: ML20040D913 (21)

Text

PA 1/26/82

.O-

' UNITED STATES OF NERICA 00CKETED NUCLEAR REGULA1 DRY (DIEISSION N BEFORE TIE C0 EMISSION

.ey },y3 y g In the Matter of )

)

FETROPOLITAN EDISON ODMPNU )

) Docket Ib. 50-289

-(Three Mile Island Nuclear ~) (Restart)

Station, Unit Ib.1) ) r :o S

00btDNWEAL1110F PEINSYLVANIA'S 00Ft

. TigECE!VED $

IFLiEUlhiifid412Y1VIsiFXS Uf TIE 2 FEB1 1982> T ASLB_ PARTIAL INITIAL DECISION - ma  !-p DATED DECEFfBKR339B1 V tr a tsa m m u I 110c . s g @

I. I_nt_ro_ duction m -

By order dated tbvember 30, 1981, the Comnission invited the parties to this proceeding to file comnents on whether the Licensing Board's Decenber 14, 1981 partial initial decision should be nude innediately effective. 1 The Comionwealth elects to comrent on only one aspect of the ASLB Partial Initial Decision, Volume 2 (Energency Planning Issues).

In its Proposed Findings of Fact and Conclusions of Law on Diergency Planni$1g Issues, the Connenwalth addressed the issue of currently inadequate supplies of dosinnters for energency worlmrs. This issue was not resolved in the ASLB decision, as discussed below. The Comtunwealth opposes granting innediate effectiveness to the ASLB decision until this inportant issue is adequately resolved by the Atomic Safety and Licensing Appeal Board or by the Conmission.

1. Tinn deadlines associated with this order wre nodified by subsequent Conmission orders dated December 23, 1981 and D SO3 5 January 11, 1982.

/

8202020386 820126

• PDR ADOCK 05000289 C PDR

II. Discussion The Cormonwealth's proposed findings of fact and conclusions of law on the issue of dosinetry for emergency wurkers are appended to these conments as Attachment 1. In brief, the Connorr.malth's proposed findings of fact denonstrated a shortfall of pernnnent-record dosinetry (then:oluminescent dosincters, or ILD's), to distribute to energency workers in the plume exposure pathway energency planning zone for 1m-1.

(PF 574). These deficiencies are inconsistent with the requirments of 2

both the emergency planning rule and IUREG-0654.

The Connonwealth also noted in its proposed findings that it was requtsting additional TLD's from FFIL\, and would distribute these TIE s to the county level as soon as possible. (PF $76). As of January,1982, the Coranonwealth has received no definitive response from FDL\ regarding additional supplies of penTunent record dosinetry.

See Attachments 2 and 3. The Connonwealth asked the Poard to conclude

2. 10 C.F.R. 550.47(b)(10) requires that "a range of protective actions have been ' developed for the plune exposure pathway EPZ for energency workers and the public . . . " 10 C.F.R. 550.47(b)(11) requires that "neans for controlling radiological exposures, in an energency, are established for energency j wurkers." NUREG-0654 specifically interprets this standard as requiring " provisions for di.stribution of dosineters, both self-reading and permanent record devices."

~ ~

P1h~nriliifSEnibrdY,"EviiliEtibn"CEi~terioF3.T.~ (emphasis added).' In addition, 10 C.F.R. 50.47(b)(8) requires that

" Adequate energency facilities and equipnent to support

- the energency response are provided and unintained." This

-is intended to include radiological nonitoring equipuent.

.See. NUREG-0654, Planning Standard 11, Evaluation Criterion 11.

3. In swurn testinony be ore r the ASLB in the Susquehanna Steam Electric Station operating license proceeding (Pennsylvania Power and Light Co. , Docket Mos. 50-387, 50-388), a FELL \ repre-sentative (Mr. Bruce Swiren) indicated that requests to FDL\

for supplenental dosinetry kuuld no,t be net by FDL\.

(Tr. 2672-73, 76-77, appended to these conments as Attachnent 4).

2

that IMI-1 should not be permitted to restart until adequate ' supplies of penmnent record dosinetry are predistributed, or until other cans of assuring the health and safety of cnergency wrkers are provided. (PF 4

577.2).

The Connetrmalth's Faergency Plan provides that both self-reading and pernnnent-record dosinetry is required to be distributed to energency wrkers. This is based on a IHn docunent entitled " Guidance on Offsite Frergency Radiation Systems, Phase 1, Airborne Release," dated September 1980, as well as the energency planning rule and NUREG-0654. '1he Connetrmalth has received no official notification that this guidance has been changed or cancelled. tbr has Filn notified the Connornsealth of other neans, in the absence of 11D's, to provide reasonable assurance ~

that the health and safety of energency wrkers can be protected.

Therefore, adequate supplies of TLD's are necessary to provide reasonable assurance that the health and safety of energency worl ers in the plume exposure pathway EPZ will be protected. These dosincters are not currently available.

dis inportant issue involving the current availability of adequate dosinetry for energency workers essentially was not addressed in the ASLB decision. tb reference to the Connotimalth's proposed findings and conclusions is nude in the section of the Board's decision on energency workers (11420-28). The section of the decision on radiation nonitoring

4. 1he Connonwealth also raised the issue of predistribution of self-reading dosinnters. ' (PF 177.1) . "Ihe Conuumscalth has '

determined independently that these measures have been coupleted. Therefore, there is no reason to raise this issue before the Conuission.

3

section of the decision on radiation nonitoring (%) 1466-1502) involves offsite radiological dose assessnent rather than radiological nunitoring for energency workers. The section of the decision on nedical facilities and decontamination (%) 1888-1905) again refers to offsite dose assess-nent, as wil as nonitoring of contaminated individuals, but not to radiological nonitoring for energency workers.

The question of dosimetry for energency workers was discussed tangentially by the Peard in its findings of fact related to agricultural energency woc kers:

PHM is currently attenptin which will be reseliTeif fcE~gY6rY to procure 1000 TLDs 6tidty.~~~nf. , at R-16, R-18. Thus, th6 Y6rk 6 tid)~~Fm6rge6cy~ Plan does indicate the source of the dosinetry to be provided to York County energency wrkers, including those agricultural personnel who are considered to be energency wrkers. The evidence also indicates timt a sufficient qi .ntity of self-reading dosineters is in . stock and that PDM is in _the_ process of securing TLDJ)sinetry_for energency workers, of which there is a current shortf3H. Tr. 22,327-Y8 (Bath); Staff Ex. 21.

~

PID 11936 (emphasis added). As noted alxwe, PHM has not been successful in securing ILD dosinetry for emergency wrkers. Thus, the Ibard sidestepped the issue of whether adequate supplies of TLD's are re,qtnired to be predistributed prior to 1MI-1 restart, as nundated by the energency pleinning rule and NUREG-0654.

The Connenwalth does not intend to purchase additional TLD's for energency wrkers in the 1ML-1 pitne exposure patluay EPZ. Pather, the Connenwealth believes that these deficiencies should be net either by FDIA or by the Licensee. Absent a requirenent imposed by the Conmission that adequate supplies of permanent record dosimetry be predistributed prior to restart, it appears that these deficiencies will not be addressed. Incal energency wrkers, nuny of whom are volunteers, will 4

have to be asked to perform their duties in the plume exposure pathway EPZ without the benefit of dosinetry required by NRC and FDM regulation and regulatory guidance. The Conuunwealth respectfully requests, therefore, that the Comnission not grant innediate effectiveness to the ASLB partial initial decision until the Connonwealth's proposed findings of fact and conclusions of law on dosimetry for enurgency workers are addressed adequately by the Appeal Board or by the' Conmission. 'IMI-l should not be pennitted to restart until adequate provisions are' unde for the health and safety of energency workers in the 'IMI-l plune exposure patlway EPZ.

III. Conclusion ,

For the reasons stated above, the Connonwealth requests that the Conmission not_ grant innediate effectiveness to the December 14, 1981 ASLB Partial Initial Decision, pending resolution of the issue of pennanent record dosinetry for energency workers, raised in 1567-77 of the Connonwealth's Proposed Findings of Fact and Conclusions of Law on Emergency Planning.

Respectfully submitted, R TERT W. ApIf ,

f@E Attorneys for tha Connonwealth of Pennsylvania 5

ATTACIEMfr 1 V. Emergency Workers

67. Emergency workers, as a category, are specifically referred to in the energency planning rule and bTREG-0654. Planning Standard J of NUREG-0654* requires that (a) range of protective actions have been

- developed for energency workers. . .". The specific evaluation criteria make reference,, to the suggested use of radioprotective drugs for emergency workers as a protective action. hTREG-0654, Planning Standard J, Criteria 10.e and 10.f. Planning Standard K of hTREG-06544* requires that the "[m]eans for controlling radiological exposures, in an energency',

are established for energency workers." The specific evaluation criteria refer to dosimetry, both self-readin'g and permanent record devices, as the suggested means of controlling radiological exposures.

68. The Contenwealth of Pennsylvania has incorporated both suggestions-in its plans regarding mergency workers during a fixed nuclear facility

incident. Comnorr.sealth Ex. 2, Appendix 16,Section V. In fact, since evacuation and sheltering are almost by. definition inappropriate _ for emergency workers, the Conrem

ealth relies on the use of a thyroid i

prophylactic drug and dosimetry as the protective measures to be taken for this group.

69. At the close of hearings on energency planning issues, serious i'

problens regarding the capability to implement both methods of protection I

for energency workers had been identified. In addition to inadequate I

supplies of both the drug and dosimetry, the existing supplies had not been fully predistributed to the energency response organizations, nor had adequate distribution plans for use during an emrgency been developed.

• This is the same langu' age as used in the energency planning rule, 10 C.F.R. 550.47(b)(10) .

S* This is the same language as used in the emrgency planning rule, 10 C.F.R. S50.47(b)(ll) .

}

FD% found that this state of affairs provided "relatively little l assurance" that radioprotective drugs and dosimetry could be used as

. protective actions for mergency wrkers during an emergency, or that a

" desirable level of protection" wuld be achieved. Tr. 22, 772-773

-(Adler); Tr. 22, 764-765 (Adler) . Furthermore, FB% rated the pre-distribution of the drug'and dosimetry for mergency wrkers as one of the most important . issues to be addressed after the June 2 exercise.

Staff Ex. 20, at 1-2, No. 5; Tr. 22, 753 (Adler) .

70. Le Board finds that improvments must be made in the area of protective actions and radiological exposure control for mergency

, workers. he individual types of protective measures will be discussed separately, infra.

A. Dosircatry

71. L e function of dosimetry is to determine the radiological dose received by an individual. In the case of mergency workers, dosimetry is the method used to determine the a:Tount of exposure s/he is receiving, specifically for purposes of advis*,g the wrker to leave the phne exposure pathway EPZ once the pre-determined level of exposure has .been f reached.- Comommalth Ex. 2; Appendix 16,Section V.B.

l

72. Le state plan, as reflected in Cormomealth Exhibit 2, presently l calls for distribution of dosimetry to the e.ergency wrkers at the time of an incident. Comonwealth Ex. 2, Appendix 16,Section V.B. Central l storage of the equipment muld be at Fort Indiantown Cap, with distribution to the county, and from there to the individual crergency workers. Tr.

22, 768-769.(Adler). FBfA has been unable to assess whether timely distribution of dosimetry to the individual workers can be accadplished

, under this plan. Staff Ex. 21,' at 20. Le June 2 exercise sba md the i

i

. infeasibility of this particular plan of distribution. Although a large

amount of dosimetry was predistributed to the counties in anticipation 1 of the exercise, at least one county did not have any means of distributing

the dosimetry equipment to the participating municipality. Tr. 22, 386 (Bath); Staff Ex. 20, at 21. FEMA indicated that "[t]his would have been a major problen had there been an actual incident at 1MI." Staff Ex. 20, at 21.

1

73. The Board agrees with FB4A's frequent statements that dosimetry -

must be predistributed to the local level before there can be any 1

assurance that the equipc:ent will actually be available for use by the t arergency workers. Staff Ex. 21, at 20; Tr. 22, 768-769 (Adler); Adler l an,d Bath (3/16 Testimony), ff. Tr.18, 975, at 2 (outline), 31. Although' 1

the energency workers can still perfom their assigned functions without dosimetry, the Board finds that predistribution to at least the ccunty level is necessary to avoid having energency workers remain in the EPZ without protection. Tr. 22, 388 (Bath) . The Board also finds'that each organization to which predistribution is made must have a plan or -

implementing procedure for distribution to the individual erargency workers in the event of an energency. These actions are required before

. - restart to provide reasonable assurance that the radiological exposure 1

I of the energency workers can be monitored, so as to protect their health

and safety.

! 74. The~second problem identified with dosimetry was the inadequate t

supply of permanent record dosimetry to distribute to all energency I

workers. Staff Ex. 21, at 15. Following the June 2 exercise, it was determined that an adequate supply of self-reading dosimetry (CDV-730's and CDV-742's), is available for pre-distribution to the counties for i

i

emergency workers in the pltrae explosure pathway EPZ for 'IMI-1. Staff Ex. 21, at 15, 20; Tr. 22, 476_(Bath); Staff Ex. 20, at 21; Tr. 22, 386 (Bath). here is, however, a shortfall of permanent record. dosimetry (TLD's). Tr. 22, 387 (Bath); Staff Ex. 21, at 15, 20; Tr.-22, 476 (Bath); Staff Ex. 20, at 21; Tr. 22, - 771 (Adler) . TLD's are used as a warning mechanism regarding _acetatlated dosage. Tr. 20, 803 (Curry).

75. Le Board believes that a supply of both self-reading and permanent-record dosimetry, sufficient to equip each mergency worker according to the state plan, should be available prior to restart. Bis i

]

is consistent with the mergency planning rule's requirment that adequate equipment to support the mergency response must be provided and maintained. 10 C.F.R. 550.47- (b)(8); huEG-0654, Planning Standard H*;-

Bath, ff. Tr. 22, 350, at 4; Staff Ex. 21, at 15. We Board notes that

. FB% has identified possible alternate methods of compliance with this standard, given ths lack of dosimetry equipment. Rese include rotating i

, emergency worlers more frequently then otherwise planned for, _or using one dosimeter for several mergency workers stationed in the same area.

! Tr. 22, 772-773 (Adler). Fa% has not, however, indicated e.d2 ether these

alternatives are included in the state's planning, or whether they have l.

i been found adecuate. Based on the record in this proceeding, the Board l cannot, therefore, rely upon these possible alternatives as constituting L

j reasonable assurance that an adequate anount of dosimetry will be i

l provided to each mergency worker during an mergency.

l 76'. We Corunwealth has', in its Proposed Findings of Fact, made

[ several comitments regarding the distribution of dosimetry. It has

• Re evaluation criteria for Planning Standard H indicate that this requirstent is specifically intended to encompass radiological monitoring equipment, such as dosimetry. hEREG-0654, Planning Standard H,-Criteria 10 and 11.

comaitted to predistribute all necessary self-reading dosimetry (CDV-730's and CDV-742's) to the risk counties prior to restart. It is requesting additional supplies of TLD's from MR, and will predistribute available ILD's to the county level as soon as possible. In addition, the ComTonwealth has stated that it will assist the counties in developing plans for further distribution of the dosimetry during an emergency. and such distribution plans will be a part of the county plans when they are submitted to m a for formal review. The Comronwealth has also comnitted to review and revise, where necessary, its plans regarding rotation of energency workers; this will be accomplished prior to restart.

77. Therefore, the Board directs the NRC Staff to certify to the Comnission that the following itens have been accomplished prior to restart:

1. Sufficient supplies of self-reading dosimetry have been predistributed to the 5 risk counties to equip each emergency turker fully according to the state plan;

2. To the extent that sufficient supplies of penmnent record dosimetry have not been predistributed, state and county plans include other means to provide reasonable assurance that the health and safety of energency wrkers will be insured;

3. Prior to restart each county plan includes procedures for further predistribution of dosimetry, or procedures for timely distribution of dosimetry to individual emergency wrkers during an emergency.

B. Equitxnent Training

78. The energency planning rule requires that "[r]adiological energency response training (be] provided to those who tray be called on to assist in an energency." 10 C.F.R. 550.47(b)(15); NUREG-0654, Planning Standard O. Testimony presented by the Commnwealth indicated that, for the most part, training programs for emergency response personnel had ATTAC11Eifl' 2 t

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PENNSYLVANIA EIAEP.GElR Y /AANAGE/AENT AGENCY

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nARRl5 BURG, PENNSYLVANIA 17103 ,

January 7,1982 tir. Robert Adamcik Acting Regional. Director Federal Energency Management Agency Region III, Curtis Building 6th and thinut Street s Philadelphia, Pennsylvania 19106

Dear Mr. Adancik:

During the final development of the Commonwealth of Pennsylvania Radiological Energency Response Plan f or fixed I;uclear Facility Incidents, we identified in our August 31, 1981 letter to lir . Adler tt'o major short falls in requisite dosimetry f or emergency workers pursuant to Federal planning standards and eval uat ion c rit eria.

At t. ha t t ime ue reqocated FEt1A to provide , or arrange for the provision of, the following dosimetry requirements f or emergency trorkers concerned with the Three flile Island Nuclear Station, Susquehanna Steam Elect r ic St at ion, Peach Bot ton Atomic Power Station and the Beaver Valley Parer Statien.

QUANTITY DESCRIPTION 5,054 Cl) V 730 Dosimeter (0- 20 r )

11,184 TI,D (Thermal tninesc en t ,fbsimeter)

The f o l.l owin g important considerat ions ' rela t ive to the request were also cited:

a. During the initial planning ef fort we opted for distribution of dosimet ry at the time of energency since fewer total resourecs uould he required and UllREG-0654 doer, not specify the type of distribut inn.

h. The current plan was changed to predistribution of dosimetry before t he ener gency on t he ban i:

of Federal observations, and recommendat ions c ited in (1) Review and (?) Exercise of Pennsylvania REP Sit e-Spec i f ic to Three Mile Isinnd Fixed Nuclear racilit y.

I- 6

-. .~'

Mr. Robert'Adancik January 7, 1982 Page Two

c. 'The rationale for FEMA to identify t.he CD V 730 as a possible national resource to meet State.RERP dosimetry needs.

.d. The rationale for' Federal procurement of all TLD.RERP dosimetry needs.

. in the State Plan we have specified that a' suf ficient supply of personal dosimetry will be issued to each risk county to permit pre-distribution of two scif-reading and one permanent-record dosimeter each emergency vorker. While we have enough CD V 742 Dosimeters (0-200r),

'there is the shortage of CD V.730s and TLDs indicated also. Our decision

.to opt for three dosimeters for cach emergency. worker is based on paragraph .7.3b, page 7-5 of the FEMA document entitled " Guidance on Offsite. Emergency Radiation. Measurement Systems, Phase' 1, Airborne-Release," dated September 1980, short t i t.le , FEMA-REP-2. While it is. )

' indicated in the abstract that the document "provides interim guidance j to State and local agencies," we have received no official not'ification i that the guidance has been cancelled, modified or superseded.

During t he October 1981 ASLE Ilearings for the Susquehanna ,

Steam Electric Plant, FDIA testified that it would not supply the unmet l dosimetry needs of the State. It was further ind.icated that either the State or the utility should finance the purchase-of this dosinetry.

~

In view of FEMA's strong recommendation for predistribution of dosimet ry, this dogmatic position uns surprising since an answer to our August 31~

letter has never been received. In response to another question, FEMA testified t.here was no requirement in NUREG-0654 for two scif-reading dosimete.rs as called for in the State Plan. During subsequent cross-cxamination, however, FDLi was questioned regarding TEMA-REP-2 and testified that this document uas 'not being continued, though in f act it had not been canec11cd. i ISille the sworn statenents made by FEr!A at the referenced I ASLB Hearings may not be conclusive, they are a matter of public record I and in the absence *of any other statements f rom TDIA are of concern to i To clarify these matters I ask that the following he provided by

! us.

l your office or fella Hational:

a. A formal reply to our letter of August 31, 1981 i to Vernon Adler, then Region III, Director, .!

1

! Plans and Preparedness flivision.  ;

l

b. A definit ive written statement as to whether the guidance in PDIA-REP-2 relat ive t o the i self-reading and permanent -record dosimeters j is still valid.

5 1

I

o Mr. Robert Adancik January 7, 1982 Page Three

c. If the FEftA-REP-2 guidance is no longer t o be followed, then what specifica11y is the FEMA requirement for predistributed dosimetry to offsite caergency workers.

Sincerely, 1

~

(

DeWitt C. Smith, Jr.

Director DCS: sam (Tel: 717-783-8150) l l

l l

1

' -.- u n acic u rt 3 1 m,w. '

l y{ Federal Emergency Management Agency *

's y Region Ill 6th & Walnut Streets Philadelphia, Pennsylvania 19106

.s GAN 181982 -

Lt. ' Gen. DcUitt C. Smith, Jr.

Director Pennsylvania, Emergency !!an.1genent bgency P.O.-Box 3321 .

Harrisburg, PA~ 17105

Dear General Smith:

We hiave received your letter of January 7,1982 in which you requested fella assistance in thr: provision of dosinetry for energency workers located around f our >(4) nuclear power plant sites in Pennsylvania. In the same letter you

.also inquired as to whether the guidance on docimetry contained in the publication entitled " Guidance on Off site Emergency Radiation Measurenent Systems, Phase 1 - Airborne Itclease," also known as FEMA-REP-2 still-is valid .

or if it has been superseded by some other guidance.

Your questions reflect issues which are of national interest and policy. There-f ore, as your letter suggests, and as we did uit.h your letter of August 31, 1981, ue are forwarding your letter to our central ' office uith .the request that they reply directly to you. You should receive their reply shortly.- Picase . ~

let us know if you do not.

We look foruard to continuing our mutual efforts in inproving our radiological energency preparedness capabilities. Please contact ne if we can be of a g -- .

tional assistance.

\

S nce ly y.>ur ,

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\npcher Joh,1)lDirector Regi Ta t

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2 NUCLEAR REGULAIORY COMMISSION

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In the matter oft  :

5 i PENNSYLVANIA'F0WER L LIGHT COMPANY a I 6 '

, and  : DOCKET NCS. 50-397

, j 7  : 50-388

,{ ALLEGHENY ELECTRIC COO P E R AT IV E , INC. :

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2 (Susquehanna Steam Electric Station, 9 Units 1 and 2) 7 d jo_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _x ,

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) 11 Empress Poom, Genetti Motor Inn j 12 77 Ea s t Ma rke t .S treet-Wilkes Barre, Pennsylvania

. 13 ,

I Thursday, Cctober 22, 1981 14 i

15 -The hearing in the above--entitled ma tter was i* 16 con vened , pursuant to notice, at 9:00 a.m. "

17 1, _ BEFORE:

18 I

JAMES P. GLEASON, Esq., Chairman,

{ 19 Atomic Safety and Licensing Boa rd 20 . GLEHN 0. BRIGHT, Adninistrative Law Judce-21 f 22 5

23 24 25 ,

Y s

At OL I4 SON FIEPORilNG COMPANY,INC.

i 1

2672 1 MR. CUTCHIN: I have one question before making 2 Mr. Swiren available for cross-examination.

3 BY MR. CUTCHIN: (Resuming) 4 0 Mr. Swiren, in the questions and answers between 5 the examiners and the personnel from PEMA who were just on 6 the stand, there was a discussion'of a possible shortage'in  ;

7 the availability of TLD's. Do you ha ve an opinion on how 8 the shortage, if real, could be cured if an emergency '

9 occurred ? '

l 10 A Yes, I do. ,

l 11 Q Would you state i t, please?

< 12 A Well, actually it is a two part answer I would l

l 13 h av e to give to that question. The best cure for the .

14 shortage of the TLD's would be the purchasing of sufficient l 15 amount of TLD's for all the emergency workers.

I 16 Short of that option, the State of Pennsylvania 17 would"have to -- the next option would be to try to procure 18 o n a loan basis a supply of TLD's to the best of their 19 a bility to meet their needs in the Susquehanna area.

20 The third option would be to rely on self-reading 9

21 dosimeters and the few available TLD's that the Bureau of

...~ .

l 22 Radiological Protection does have for its use; in essence, 23 spread then around some wha t amongst the county emo;qency i 24 workers to come up with an approximate coverage.

.5 MR. ADLER: Excuse me. Mr. Swiren, is your i

ALUE%oN REPORTING cop.8PANY, INC,

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I 2673 I h

g. 1 microphone on?

2 THE WITNESS: Yes, it is. I will just talk closer i 3 to it.

)

4 MR. ADLER: Thank you.

5 MR. CUTCilIN: Thank you, Mr. Swiren.

6 No f urther questions, Mr. Chairman, and the 7 witness is available f or cross-examination.

8 CHAIRMAN GLEASON: Dc I understand tha t last i 9 question -- the answer to your question is that in layman's i

10 terms, the state had better finance the, purcha se of those or 11 they will not be available? t 12 THE WITNESS: Or the utility.

i j

13 CHAIRMAR GLEASON: Or the utility, yes. .All l

14 righ t.

I 15 Does the Applican t have cross-exa mina tion.

16 MR. SILBERG: Yes. I have one short question. '

17 CROSS-EXAMINATION 18 BY MR. SILBERG: ,

19 Q Mr. Swiren, along the lines of the question I 20 asked the PEMA panel, could you give me your general overall 21 opinion as to the state of emergency planning in the area 22 a round the Susquehanna facility?

23 A Yes. The plans themselves a re generally of a high l

24 quality , the county plans. They are designed along the 25 quidance of NUREG-0654 and they are set up to address that i

l I

ALDEHSON REPORUNG COMPANY. INC.

. 1

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1 i

) s 1 things, yes. However, I should add just one thing. Th e re 2 sre many plants in operation now tha t do no t have written '

'3 school plans in place.

, 4 (Counsel for the Commonwealth conferring.)

5 0 Let's go to the question of dosimetry. Do you-6 agree wi th the figures, the-deficiency figures given in the 7 PEM A testimony, the PEMA testimony?

8 A Yes, I do.

9 Q Your statement just now -- well, first of all, is to it your statement that FEMA vill not supply the additional 11 dosimeters prior to oteration of this plant?

12 A That FEMA will not supply?

13 0 That is correct.

14 A Yes, tha t is correct.

15 0 One of your statements in response to the problem 16' i s th a t the state can rely on existing TLD's. Do you know 17 how "many TLD's are in the possession of the state Bureau of 18 Radiation Protection?

19 A I believe in the neighborhood of 300.

20 0 300 for the entire state?

21 A For the entire state.

22 0 Do you believe that d osime tr y should be 23 predistribu ted prior to an emergency?

24 A . Yes, I do.

25 0 llo w many operating sites are there f or nuclea r i

ALOLRSoN REPORTING COMPANY,INC.

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1 2677 1 pla n ts in the Commonwealth?

2 .A Currently three.

3 0 And if :MI goes into operation?

4 A Then currently four.

5 0 And it is your opinion that those 300 TLD's can be 6 allocated among all of the emergency workers, all of the 7 sta te and local personnel in the entire Commonwealth for 8 those reactor sites?

9 A No, that is not my opinion.

10 0 Do you know where the money will come from .in I

11 order to purchase those TLD's and self-reading dosimeters to 12 m a k e u p tha deficiencies tha t ha ve been identified?

13 A No, I do not. The logical assumption would be i

14 either from th e state or arrangemen t wi th the utility to 15 purchase them for the state.

16 0 And to date such arrangements have not been made?

17 A No, they have not, to my knowledge.

18 Q And again to summarize, your opinion is that the I

19 adequa te number of dosimeters should be predistributed p rio r '

20 to an emergency?

21 A That would be the best way of doing it.

22 (Counsel for the Commonwealth conferring.)

23 0 What is the source of the recommendation tha t each 24 eme rgency worker be provided with two forms of self-reading 25 dosimeter, a 730 and a 742, as well as a thermoluminescent ALDLRSoN REPORTING COMPAf4Y, INC.

O UNITED STATES OF MERICA NUCLEAR REGUIAIORY C0t141SSION

_BEFORE 'UE COI141SSION, In the Matter of )

)

METROPOLITAN EDISON 00MPAfri, )

) Docket Ib. 50-289 (Three Mile Island Nuclear ) (Restart)

Station, Unit Ib.1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the attached "Connunwealth of Pennsylvania's Connents on the Innediate Effectiveness of the ASLB Partial Initial Decision dated Decenber 14, 1981", with attachnunts, were served on the persons on the attached service list, this 27th day of January,1982. Parties denoted by an f were served by Express thil . All other parties were served by first class nnil.

C{

O c rQ,4 h l' , b)eL '

l([/

rnre#~u. ADMR Attorney for the

- Connonwealth of Pennsylvania P. O. Box 2357, 505 Executive Ibuse liarrisburg, PA 17120 717-787-7060

+

IR11TED STATE' 0F All0UC\

!1UCLEN! REGULATORY C0tt!ISSIGI EEFORE T!E C0tt!ISSIQ1 In the lhtter of )

)

, MEIRDPOLITN3 EDISati GIIPMN, )

') Docket ib. 50-289 (Tiree !!ile Island !bclear ). (Restart)

Station, thit Ib.1) )

SERVICE LIST Ibcketing and Service Section tir. Stevm C. Sholly Office of the Secretary thion of Concemed Scientists U.S. Ibclear Regulatory Comission 17251 Street, N.W., Suite 601 Washington, D.C. 20555 Washington, D.C. 20006 Ivan W. Smitik, Esquire, Qiairunn 11. Iouise Bradford Atomic Safety and Liccnsing Peard Panel "D!I Alert U.S. tbclear P,gulatory Camission 315 Peffer Street Washington, D.C. 20555 lbrrisburg, Pennsylvania- 17102 Dr. Walter H. Jordan Ellyn R. Ueiss Atomic Safety and Licensing Board Panel Sheldon, IIanon, Roismn & Weiss 881 West Outer Drive 1725 I Street, ?!.W., Suite 506 Oak Ridge, Tennessee 37830 Washington, D.C. 20006 Dr. Linda W. Little thrin P. Shehlon, Esquire (PNJE)

Atomic Safety and Licensing Board Panel Shchbn, llanon, Roisman & Weiss 5000 liermitage Drive 1725 I Street, fl.W., suite 506 Raleigh, tbrth Carolina 27612 Washington, D.C. 200t%

1 George F. Trowbridge, Esquire TJames A. Tourtellotte, Esquire Shaw,.Pittman, Ibtts & Trowbridge Office of the Executiv. Irgal Director 1800 !! Street, N.W. U.S. !!uclear Regulatory Cbmission Washington, D.C. 20006_ Wshington, D.C. 20555 Hs. Ihrjorie It Aamodt John A. Irvin, Esquire R.D. #5 Assistant Omnsel e Coatesville, Pennsylvania 19320 Pennsylvania Public Utility Comission P.O. Pox 3265 Ms. Gail Bradford liarrisburg, Pennsylvania 17120 Anti-tbclear Group Representing York (A!URY) Robert L. Knupp, Esquire 245 W.11111adelphia Street Assistant Solicitor, County of Dauphin York, Pennsylvania 17404 P.O. Fox P, 407 thrth Front Street liarrisburg, Pennsv1vania 17108

• !unzio J. Pall =Hno, Chairman

• John F. Ahearne, (bmissioner U.S. Nuclear Regulatory Ormission U.S. thelear Regulatory Ozmission Wash 2ngton, D.C. 20555 Washington, D.C. ~20555 .

• Victor diinsky, Ctrmissioner

• Ihmas M. Ibberts, Ccumissioner . U.S tbclear Begulatory Ctmrtission U.S. tuclear Regulatory Ormission Washington, D.C. 20555 Washington, D.C. 20555 JOroan U. wnnmfJtra, Esquire

.. Attomey for 13cuberry Township T.H.I. Stecting Comittee .

W lter W. Cohen Esquire 2320 tbrth Second Street Constrner Advocate llarrisburg, Pennsylvania 17110 Departmmt of Justice Strawberry Sqture,14th Floor !brvin I. levis ihrristurg. Pennsylvania 17127 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 h Dr. Qiauncey Kepford Judith II. Johnsrud

• Peter A. Bradford, Ccrmissioner Enviremental Coalition on tbclear U.S. Nuclear repalatory Ctruission Power Washington,

~ ~ " ~ ~

D.C. 20555 433 Orlando Avenue State College, Pennsylvania 16801 Tinms J. Cemine, Esquire Deputy Attomcy Cencral, Division of im Pmfessor Gary L. ftilhollin Ib n 316, 1100 Raymond Boulevard 1315 Jefferson Street Ikwark, tkw Jersey 07102 thdison, Wisconsin 53711

- _ _ . _ ,,_ ,