ML20062D526

Supplementary Response to First Set of Interrogatories. Related Correspondence

ML20062D526
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	08/02/1982
From:	Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC.
To:	ARMED FORCES RADIOBIOLOGICAL RESEARCH INSTITUTE
References
NUDOCS 8208060119
Download: ML20062D526 (29)

Text

- _ _ _ _ - . _ _

00tKETO UWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.g ,, n .] t.

BEFORE THE ATOMIC SAFETY AND LICENSINGiBOARD?

a , ,9 g 7 In the Matter of Docket No. 50-170 ARMED FORCES RADI0BIOIOGY RESEARCH INSTITUTE (Application to Renew (TRIGA-Type Reactor)

INTERVENOR CNRS's SUPPLEMENTARY RESPONSE TO _

LICENSEE's FIRST SEf 0F INTERROGATORIES NOW COMES the Intervenor in the above-captioned case and pursuant to 10 C.F.R. g2.740b and the Board ts Order dated July 12, 1982, supplements rts response to the Licensee's first set of interrogatories as follows:

~

INTERROGATORY 6 ,,

Answered by Entwisle. Unless designated otherwise, every Interrogatory hereinafter is answered by Entwisle.

At the present time CNRS has tentative commitments from only two of the expert witnesses it listed in its Motion to Enlarge Discovery Period and Restrict Scope (October 31, 1981, Docket No. 50-170), Drs. Irving Stillman and Ernest J. Stern- . . ~

glass, to present testimony at the hearing.

Dr. Sti11 man's address and professional qualifications are set forth in CNRS's responses to the Licensee's Interroga-tories 2 and 4 (December 29, 1981, Docket No. 50-170). The name of Dr. Stillman's employer has been withheld at his request, for reasons of privacy and freedom from harassment. With his consent, CNRS will disclose this information to the Atomic Safety and Licensing Board under a protective order.

In the event that CNRS is unable to secure a commitment to testify from the other expercs listed in its above-referenced Motion, Dr. Stillman is expected to testify as to every conten-tion at issue in this case. The substance of his expected testi- .

mony is contained in CNRS's written responses to the Interroga-tories submitted to it by the Licensee and the NRC Staff, inclu-ding its initial responses and its supplemental responses filed pursuant to the Board's Order dated July 12, 1982.

CNRS has a tentative commitment from Dr. Sternslass to testify as to the responses to the Licensee's Interrogatories 27, 28, 29, 30. Dr. Sternglass's address, employer, and pro-fessional qualifications were set forth in the list of experts 3 accompanying CNRS's above-referenced Motion. CNRS does not at ~

8208 60119 820802

()

' ~ '

{DRADOCK 05000170 PDR

_ - i

U this time have knowledge of the substance of Dr. Sternglass's expected testimony. CNRS is aware of its obligation to inform the parties to this action if and when it secures a firm commit-ment from Dr. Sternglass or any other expert to testify and to inform the parties of the substance of their expected testimony ;

when tha t information becomes available to CNRS.

INTERROGATORY 7 7b-d, el,e2,e4, j, n. See CNRS's Response to NRC Staff Request for Admissions and CNRS's Response to NRC Staff's First Set of Interrogatories, Questions 1-13, Stipulated Con-tentions, pp. 4-8 (filed 12-3-81). Said responses are.sincor-porated by reference into this supplementary response ~to the Licensee's first set of interrogatories.

INTERROGATORY 8

b. An accide5t of " greater severity" is one in which there are releases of radionuclides into the environment in quantities and concentrations greater than those postulated in the AFRRI Hazard Summary or Safety Analysis. This level is selected because the Intervenor believes that the accident scenarios leading to it are credible and becau'se it presents significant health and safety concerns that should be addressed ,,

in the context of this proceeding.

c. In view of the fact that the Rasmussen Report and the other WASH Reports, commissioned by the NRC to develop a methodology for assessing quantitative probabilities of nuclear reactor ac'cidents, have,after large expenditures of money and time, not been able to produce a method that can be relied on with precision (e.g. the Three Mile Island accident was statistically very improbable), the Intervenor believes it is unrealistic and unduly burdensome to require it to attempt the same for the accident scenarios it poses, given its limited resources. ,

p INTERROGATOY 10

a. In the context of this contention, an "experi-ment failure" means a malfunction of confinement safeguards, such as those described in subparts (a) - (d) of the contention, that occurs while an experiment is being conducted.

INTERROGATORY 12 a., c., d. To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the physical design of the dampers and CAM alarm system. The Intervenor therefore reserves its right to promul-gate questions regarding the same in its second set of interro-gatories to the Licensee.

-+ ,

l

)

INTERROGATORY 12, cont'd.

b. The letter from LaWayne R. Stromberg, Director, DNA, to the Directorate of Reactor Licensing, NRC, docketed 9-3-75, in which the incident is described, states in pertinent part:

Upon investigation the Chief Supervisory Officer found that by tapping the damper solenoid control box l

he could make the damper close. Closer inspection revealed that the two wires in the control box were loose.

...an audible and visual alarm associated with the ..

CAM still worked. In the event of a CAM alarm an operator would immediately notice that the dampers had not closed and could take corrective action.

INTERROGATORY 13

a. - e. To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the physical design of the lead doors and the struc-ture surrounding them and the reactor. The Intervenor therefore reserves its right to promulgate questions regarding the same in its second set of interrogatories to the Licensee.

INTERROGATORY 14

a. - c. To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the physical design of the reactor core safety interlock system and related systems. The Intervenor therefore reserves its right to promulgate. questions regarding the same in its second set of interrogatories to the Licensee.

INTERROGATORY 15_

a. The only knowledge _ CNRS has regarding the inci-dents cited in subparts (a) - (g) of this contention is that which is on public record in the NRC. None of those documents state whether the cited failures resulted in any releases to the environment. The following documents were examined by CNRS in an attempt to respond to this interrogatory and are, to the best of CNRS's knowledge, the only public records of the cited failures:

(a) Letter from Paul Tyler,- Director DNA, to Collins, Director, NRR, docketed 4-1-80.

Letter ~fromTgjer,DirectorDNA, to Director, Region 1, NRC (b)Office of Insp'ectiEn and EnforesE'e'nt','8:15-79, and enc 1. report.

(c) Letter from Tyler, Director DNA, to Director, Region 1, Office of Inspection and Enforcement, NRC, 8-1-79

. (d) Letter from Tyler, Director DNA, to Director, Region 1, Office of Inspection and Enforcement, NRC, 7-31-79 (e) Letter cited in CNRS's response to Interrogatory 12b, supra.

, c i

INTERROGATORY 15, cont'd.

( f) Letter from Myrcn Varon, Director DNA, to NRC Direc-tora te of Reactor Licensing, docketed 5-14-7L , and accompanying report.

(g) Letter from Myron Varon, Director DNA, to Directorate of Reactor Licensing, NRC, docketed 6-21-73, with enclosures.

b. - d. The public records of the malfunctions cited in subparts (a) - (g) of this contention are inadequate to give the Intervenor insi'ght into how they began, developed, and were ultimately mitigated, and how human error played a part. The Intervenor is therefore unable,without more information from the Licensee, to develop scenarios of similar malfunctions that would lead to. excessive releases, to predict which regulatory limits would be exceeded, or to recommend design safeguards to enhance safety. For this reason the Intervenor reserves its right to promulgate questions regarding the same in its second

~

set of interrogatories to the Licensee.

INTERROGATORY 16 -_

a., b., f. To answer these sub-interrogatories,: the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the -

physical design of Safety Channel One and related systems, and the scram operation. The Intervenor therefore reserves its right to promulgate questions regarding the'same in its second set of interrogatories to the Licensee, '

c. CNRS is unaware of any public recorf in which such 'a failure is documented to have caused releases to the environment in excess of 10 C.F.R. 20.*"-  ;

I

d. Report entitledc '! Electronic Damage .to Safety Channel One," p. 1, paragraph 2, accompanying letter referred '

to in CNRS's response to Interrogatory 15a(a), supra.

e. According to the report, the malfunction was r discovered by AFRRI personnel rather than an NRC inspector.

INTERROGATORY 17

a. CNRS is unaware of any public record in which such a failure is documented to have caused releases to the environment in excess of 10 C.F.R. 20.

b. The report accompanying the letter referred to in CNRS's response to Interrogatory 15a(b), supra, states:

. . . Probable cause of the malfunction has been ~

determined to have been due to a power surge which resulted in the failure of the transformer in EF-1 cubical (sicj of the MCC, thus causing the fire.

the malfunction resulted in damage, by burning, of the step down transformer, motor control contact and' associated wiring.

INTERROGATORY 17, cont'd.

c., d. To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the reactor exhaust system, the electrical wiring in the EF-1 cubicle, and related systems. The Intervenor therefore reserves its right to promulgate questions regarding the same in its second set of interrogatories to the Licensee.

DTTERROGATORh 18 a., c., d. To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the fuel element temperature sensing circuit, and related systems. The Intervenor therefore reserves its right to promulgate questions regarding the same in its second set of interrogatories to the Licensee.

b. Letter referred to in CNRS's response to Interroga tory 15a(c), supra, states in pertinent part:

At 1117 a.m. on 30 July 1979 a reactor operator noticed that the fuel temperature indicators were not functioning properly while preparing to perform an experiment. -

INTERROGATORY 19 a.,c.,f.To answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the pool water level sensing float switch and wiring, and related systems. The Intervenor therefore reserves its right to promulgate questions regarding the same in its second set of interrogatories to the Licensee.

b. Letter referred to in CNRS's response to Interroga tory 15a(d ), supra , sta tes in pertinent part:

At 11: 52 a.m. on 10 July 1979 a reactor operator discovered that the float switch, which senses the reactor pool level, was not operable.

d. No. See CNRS's responser to Interroga tory 15a, supra,

e. CNRS is unaware of any public record in which such a failure is documented to have caused releases to the environment. -

IITTERROGATORY 20 a., b., d. To postulate a scenario that would result in excessive releases, to propose additional safeguards, and to otherwise answer these sub-interrogatories, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the radia-tion monitoring system, wiring, ventilation dampers, and related

. systems. The Intervenor therefore reserves its right to promul-gate questions regarding the same in its second set of interroga-tories to the Licensee.

o. CNRS is unaware of any public record in which such a failure is documented to have caused releases to the environment.

INTERROGATORY 21 a., e. To posit how this malfunction could result in excessive releases and to propose additional safety features, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the fuel temperature-automatic scram system, the'T2 output meter, and related systems. The Intervenor there-fore reserves its right to promulgate questions regarding.the same in its second set of interrogatories to the Licensee,

b. See CNRS's response to Interrogatory 15a(f), supra.

No.

c. CNRS is unaware of any public record in which~

such a failure is documented to-have caused releases to the environment.

l d. The report entitled " Malfunction of T2 Puel Temperature to in CNRS'sScram Contacts,"

response to Interrogatory accompanying 15a (the letter referred f), rupra, states in pertinent part: .

on 29 January 1974 at 0745, the reactor operator was accomplishing the' scram checks (Inclosure 1,Section VIII, Item,18) for the daily Start-Up Checklist, and when the operator activated the test circuit for fuel element thermocouple (T2), the mechanical contacts on the meter failed to pick up and initiate and.

[ sic) automatic reactor scram.

INTERROGATORY 22 a., d., e. To posit how excessive releases may occur and to propose additional safeguards, the Intervenor needs more detailed information from the Licensee regarding the sequence of events in this malfunction, the physical design of the reactor core position safety interlock system, and related systems. The Intervenor therefore reserves its right to promulgate questions regarding the same in its second set of interrogatories to the Licensee.

b. See CNRS's response to Interrogatory 15a(g),

supra.

c. CNRS is unaware of any public record in which such a failure resulted in or contributed to a release to the environment above MPC.

1

INTERROGATORY 23

. a. - j. See CNRS's Response to NRC Stsff's First Set of Interrogatories, Questions 8-10, Stipulated Conten-tions, pp. 5-8. Said responses are incorporated by reference, in their entirety, into the responses to a.-j. herein.

INTERROGATORY 24

a. -

h. See CNRS's Response to NRC Staff's First Set of Interrogatories, Questions 30 - 37, Unstipulated Conten-tions 1 and 2, pp. 11-14 (filed 12-3-81, Docket No. 50-170).

Said responses are incorporated by reference, in their entirety,

.into the responses to a. - h. herein.

1. Na tura1("Act of God") accidents referred to by CNRS in this contention include but are not limited to earth tremors, earthquakes, hurricanes; tornadoes, and other severe weather conditions and geological events that threaten the physical integrity of the reactor parts and/or the structures and building surrounding them.

De CONTINUED ON NEXT PAGE e

A

Interrogatory 25 25a. 10 C.F.R. Part 50, Appendix E, Section I, para-

~

graph 2 states, inter alia, that the Appendix " establishes minimum requirements for emergency plans for use in attaining an acceptable state of emergency preparedness."

Moreover, Licensee has stipulated to the following contention as an appropriate issue for determination in this proceeding:

Whether the Emergency Plan proposed by the applicant complies with the standards set forth at 10 C.F.R Part 50, Appendix E.

See Board's Special' P' rehearing Conference Memorandum andlorder,

~

September 1, 1981, at pp. 4 n.3,118', see also Stipulated ,,

~

Contentions, March 31, 1981.

It is the Intervenor's position that Licensee's Emergency Plan fails to comply with the requirements of both 10 C.F.R. Part 50, Appendix E, an'd the USNRC Regulatory Guide 2.6.

25b. The Intervenor maintains that the AFRRI Emergency Plan '("the AFRRI Plan") 'does not adequately fulfill the require-ments of the USNRC Regulatory Guide 2.6 ("the Guide") in the following manner:

Augmentation of Facility Emergency Organization Section 3.2 of the Guide requires a description of the j

extension of the organizational capability for handling emer-gencies to be provided by ambulance, medical, hospital, and firefighting organizations. The Guide also requires that l

l any such arrangements be described and any written agreements reached with such organizations be included.

The Plan is deficient because it does not describe these capabilities. The Plan merely states that AFRRI has a Host-Tenant Support Agreement with the National Naval Medical Center (NNMC), and the Plan lists a few services which the NNMC is supposed to provide. However, the Host-Tenant Support Agreement included in the Appendix to the Plan (Section 8.21, appears to consist

~

solely of a lease-type arrangement between the NNMC and AFRRI.

The support agreement makes almost no reference to the fact that the " tenant" is using the facilities to house and operate a nuclear reactor. The only indication of_the existence of the nuclear reactor is a provision requiring the " host"-to provide development and interpretation of film dosimeters and provide radioanalysis service-should' tenant's equipment be inciaerative.

The Support Agreement ~does not describe the extension of the o

organizational capabilities for handling emergencies that may

. be associated with a nuclear reactor.

Other emergency plans for other reactor facilities licensed by the NRC include a more complete description of the emergency capabilities to be provided by ambulance, medical, hospital and firefighting organizations. See for example, University of Virginia, Reactor Facility Emergency Plan, Docket No. 50-66, August 27, 1981, Section 3.2, p. 3. This section of the Virginia Plan identifies the various emergency service organizations that have agreed to respond to emergencies at the reactor facility and describes the services that these organizations would provide.

\

t 4

Also, other plans for other reactor facilities in-clude copies of written agreements with emergency organizations that specifically provide for nuclear emergencies.

See, for example, University of Maryland, Emergency Plan, Docket No.

50-166, March 1980, Appendix 8.2, pp. 19-24. These pages of the Maryland Plan consist of letters confirming emergency medical assistance for contaminated personnel by Walter Reed l Medical Center and an agreement for the transportation of contaminated persons.

1 Coordination With Participating Government Agencies Section 3.3 of the Guide requires that the principal state agency and other governmental agencies having action responsibilities for radiological emergencies be identified.

A description should be given.of the authority and respon-sibility of each such agency for emergency preparednes5 planning and for emergency response, particularly in relation to the responsi-it bilities of the Licensee and of other agencies. Copies of any written agreements with such agencies should be included.

2 The AFRRI plan simply specifies that the Defense Nuclear 9

Agency is the principal agency with responsibility for AFRRI and lists other federal agencies which may be contacted in event of an emergency. The plan does not describe the authority and responsibility of each such agency for emergency preparedness planning, nor does the plan include any written C

i agreements with such agen'cies. Nor does the AFRRI plan include any such copies of agency emergency response plans.

Section 4 of the Guide requires that specific response measures should be identified for emergency class and related to action levels or criteria that specify when the measures are to be implemented. The AFRRI plan does specify response measures for each emergency class, but it does not relate the measures to action levels or criteria that specify when the measures are to be implemented.

Furthermore, the AFRRI plan does not completely comply with the requirements of the specific provisions of Section 4 of the Guide. The defi-ciencies identified by the Int'ervenors,following the format laid out in AFRRI's plan,.are as'follows Personnel Emergency Activation of Emergency Organization i

Section 4.1.1 of the AFRRI plan does not note the l

existence of a message authentication scheme for offsite agencies as is required by Section 4.1 of the Guide.

Corrective Action Section 4.1.3 of the AFRRI plan merely states that in situations involving airborne radioactivity, ventilation and,

~

l l

air control measures shall be initiated. The AFRRI Plan does not describe corrective actions for any other form of f

radioactive contamination as is required by Section 4.3

~ ~

of the Guide.

Emergency Alert -

Activation of Emergency Organization Section 4.2.1 of the AFRRI Plan identifies several people who shall be notified in the event of an emergency, but the plan does not describe how these people.are to be notified nor what the. activation. levels are for the notifi- ..

cation of offsite agencies as is required by Section 4.1 of the Guide. Also, the AFRRI Plan does not no'te the existence of a message authentication scheme for offsite agencies as is required by Section 4.1 of the Guide.

Assessment Action Section 4.2.2 of the AFRRI Plan states that if the AFRRI facility is to be evacuated, the Director in conference with several others shall monitor the situation to determine whether to upgrade or downgrade the emergency classification.

The AFRRI Plan does not describe the methodologies and techniques to be used.

t

. . . . . . . . _ _ . . . .. -]

4 This section of the AFRRI Plan does not appear to

- comply with Section 4.2 of the Guide which requires that the plan include a description of the methodologies and techniques to be used to an extent sufficient to demonstrate, with reasonable assurance that in a timely manner (1) the magnitude of radioactive materials can be determined, (2) the magnitude of any resulting radioactive contamination can be determined, (3) projected exposures to person _s.

within or beyond the facility boundaries can be estimated, and (4) emergency action lev-1s specified can be determined.

Protective Action

~ ~ ~

~

Section 4.2.4 of the AFRRI Plan merely states that ..

the Director will effect evacuation of the buildings ,

surrounding the AFRRI facility. The plan does not specify the criteria for implementing the protective' actions or the means for notifying or warning the persons at risk as required by Section 4.4 of the Guide.

Reactor Emergency Activation of Emergency Organization Section.4.3.1 of the AFRRI Plan does not describe action levels for notification of offsite agencies, nor does it note the existence of a message authentication scheme for such agencies as is required by Section 4.1 of the Guide. The AFRRI Plan does describe some of the people to be. notified, but it does not describe how the notification is to occur.

, -o

Assessment Action Section 4.3.2 of the AFRRI plan does not appear to comply with section 4.2 of the Guide. For example, the Plan merely states that both fixed and portable radiation monitoring devices are available for assessment. The Plan does not indicate how the monitors will be read if evacuation is.necessary, nor who will read them in the event of an emergency.

Contamination Control Measures Section 4.3.4.4 of the AFRRI Plan states that monitoring programs will be established to provide the information needed to ascertain when reentry can occur. However, the plan does ,,

not include the criteria for permitting return to normal use as required by Section 4.4.3 of the Guide. Also, this section of the plan does not include measures for isolation or quarantine areas as required by the Guide.

f other emergency guides for other reactor facilities provide much more complete information on what to do to prevent contamina-tion. See, for example, University of Maryland, Emergency Plan, Docket No. 50-166, March 1980, pp. 31-35. This part of the Maryland Plan concerns the actions to be taken in the event of release of radioactivity. Specific instructions are included i about how to cope with the contamination created by several dif-ferent kinds of radiation release accidents.

i o

Emargancy Parsonnel Exposura Section 4.3.5.1 of the AFRRI Plan does state exposure guidelines for rescue personnel. However, the plan merely states that the PIC shall determine the allowable dose for any personnel involved in emergency action in consultation with Health Physics. The plan does not ensure that methods for permitting volunteers to receive radiation exposures will involve expeditious decision-making and.a reasonable balance of relative risks as required by Section 4.5.1 of the Guide. Nor does the AFRRI plan identify the criteria or types of criteria to be used in weighing risks.

Decontamination and First Aid Section 4.3.5.2 of the AFRRI Plan briefly describes first aid and decontamination efforts for injured persons.

By comparison, other plans for other reactor facilities set forth the first aid and decontamination procedures to be con-docted for injured personnel in much greater detail. See, for ,

I example, University of Maryland, Emergency Plan, Docket No. 50-166, March 1980, pp. 31-35. This part of the Maryland Plan gives specific instructions concerning decontamination and first aid for injured.

persons. See for further example, University of California at Los i

Angeles, Emergency Response Plan, Docket No. 50-142, February 28, 1980, p. iv/1-4, Attachment C, Attachment D. Page iv/1-4 describes transportation of contaminated personnel. Attachment C sets forth radiation accident procedure and management of contaminated personnel and those with other injuries. Attachment D is a checklist for handling contaminated and/or injured

Medical Treatment Section 4.3.5.4 of the AFRRI Plan merely states that the National Naval Medical Center has agreed to provide medical treatment in the event of a radiological emergency and asserts that the NNMC facilities-and personnel are equipped to handle decontamination efforts. The plan does not describe the arrangements as required _by Section 4.5.4 of the Guide, but simply mentions their existence. Also, the plan does not give sufficient description in detail to provide adequate assurance that the required services are available and that the persons providing them are pre-pared and qualified to handle radiological emergencies. .

By comparison, the UCLA Emergency Plan, for example, states that the UCLA Emergency hospital has approved procedures for dealing with radioactively contaminated victims, and includes a description of these procedures in the appendix. University of California

! at Los Angeles, Emergency " Response Plan, Docket No. 50-142, 1

February 28, 1980, p. iv/1-4, Attachment C.

! Furthermore, no written agreements with respect to I

arrangements are included in the AFRRI plan. Other emergency plans, such as the University of Maryland's plan, includes such an agreement arranging for medical services for con-taminated personnel. University of Maryland, Emergency Plan, Docket No. 50-166, March 1980, Appendix 8.2, pp. 20-21.

l l

Facility Emergency Section 4.4 of the AFRRI Plan states that no accident can be i l

postulated for the TRIGA reactor in the AFRRI facility that could result in a facility emergency,~but the AFRRI Plan could be expanded to accommodate emergency situations greater than a reactor emergency. However, according~to Section 2.1,4 of the Guide, it is necessary and' prudent to-plan for a Facility Emergency if the reactor'is authorized to operate at power levels of greater than 100 KW. Also, Section'4 of the Guide requires that emergency response me'asures should' be identified for each emergenc'y^ class, including Facility. ,,

Emergencies.

Activation of Emergency Organization j ._

l Section 4.4.1 of the AFRRI Plan states that the PIC shall determine if a facility emergency exists and shall I notify the Director. The Plan also says that the Director shall decide whether additional emergency support from the i

NNMC and outside groups is required. It is not apparent l

l that any actual emergency plans exist for this type of l

emergency class. The AFRRI Plan does not describe communica-( tion steps to be take.n to alert emergency personnel nor does it describe the action levels for notification of offsite agencies as required by Section 4.1 of the Guide. Also, the existence of a message authentication system for such agencies is not noted.

. Assessment Action Section 4.4.2 of the AFRRI Plan states that the Director in conference with several other people shall monitor the situation to determine whether to downgrade the emergency classification. The AFRRI Plan only addresses downgrading, the emergency class, but does not. address the measures to be taken to assess the situation and classify the emergency in the first place as is required by Section 4.2 of the Guide.

First Aid and Medical Facilities- .

~

Section 5.4 of the Plan does not provide reasonable assurance that appropriate measures can and will be taken to protect health and safety. For example, it does not describe any medical or first aid facilities which would be available to' handle an.

emergency involving leaks, contamination, irradiatio'n , or-other i l radiological emergencies.

Maintaining Emergency Preparedness Section 6 of the Guide requires that the plan include a description of how the plan will continue to be effective throughout the lifetime of the facility. The AFRRI Plan does not include any such description.

l 1 I

e

Organization Preparedness Training Section 6.1.1 of the Guide requires that the plan include a description of specialized training to be provided to emergency personnel. The corresponding section in the AFRRI Plan, section 6.1, merely states that a general training session will be held for all AFRRI personnel to familiarize them with AFRRI Instruction 3020.2. The training is not described. The AFRRI Tlan states that specialized training in emergency procedures will be'given to those staff members ,,

with specific responsibilities in emergency situations, but this training.also is not described.

Drills and Exercises .

Section 6.1.2 of the Guide is very specific concerning I

the requirement of drills and exercise. Generally, the Guide requires a description of the drills and exercises and that they may be accompanied by preplanned simulations and l

l I .

- scenarios. The Guide requires provisions for emergency test exercises and coordination with offsite emergency personnel.

The Guide also requires that provisions should be made for critiques of all drills and exercises. The corresponding section of the AFRRI Plan, Section 6.2, simply states that the Radiological Safety Department shall 'onduct c semiannual drills of the on-site emergency plan, and drills involving full coordination with offsite organizations will be conducted biannually. The AFRRI Plan does not describe the drills in any of the detail required by the Guide.

~

Review and Updating of the- Plan and Procedures ..

Section 6.2 of the Guide requires that provisions be made for a biennial review of the emergency plan Sor for updating and improving procedures to incorporate the results of training and drills and to account.for changes in the facility or in I

the environs. The AFRRI Plan, Section 6.3, merely states i that review shall be conducted, but it does not make provisions for incorporating the results of training or to account for ,

changes.

i Maintenance and Inventory of Emergency Equipment and Supplies Section 6.3 of the Guide requires that the operational readiness of all items of emergency and supplies should be ensured. The Guide requires that provisions for performing S

.= - - - -

/

4 ,

s maintenance, surveillance, testing, and inventory on The 7 emergency equipment and supplies should be described.

plan has no provisions addressing this section's requirements.

Recovery Section 7 of the Guide requires.that general plans, includ-i ing applicable criteria, for restoring the facility to a safe

-i status be described. The plan generally-states that recovery efforts shall be initiated by the Director, and that he will assign responsibilities to others. The plan does not ir.clude the applicable criteria for restoring the f acility to a . _

safe status.

Appendix Section 8.1 of the Guide requires that the plan include ~

The AFRRI )

general building layout p1ans and area maps.

Plan does include maps which appear to be of the building and of the area.

However, the maps are deficient in that they would not be useful to persons attempting to use them in the event of an emergency. The. building layout plan does not clearly indicate stairways, exits or escape routes. The area map does not even indicate in which building the reactor is located.

Section 8, part.5, of the Guide requires that the appendix of the plan include an analysis that sets forth the basis for the emergency plan. However, the. Guide states if this analysis has been submitted previously to the NRC, a clear ,

79

.,a y ,

1 -,

g

' [ t

/

/ j#

r

. and specific reference thereto is acceptable. The plan l

does not include such an analysis o the basis for the cmergency plan nor does the plan make a clear and specific n I

reference to any e.nalysis that has been submitted previously to NRC. -

' l i 1. .

'- l The Intervenor maintains that the AFRR1 Plan does not '

is -

contain the following elements required by 10 C.F.R.' Part 50,(

,,i* '

, /

Appendix E. - > '

A. Organization

1) Description of the normal plan opera't'ing organiza-

~

tion. s:

s t

2) Detailed discussion of plan staff emergency assignments and duties of an onsite emergency coordinatoriin charge of exchanging information with offsite emergency authorities.

3) Description of Applicant's headquarters personnel who will be sent to the plan to augment the onsite emergency q organization.

4) Identification of and methods used by Applicant's -

personnel responsible for making offsite dose projections and transmitting the results to State and local authorities, NRC and other appropriate governmental entities.

5) Identificatioh of Applicant's employees and consultants with special qualifications for coping with emergency conditions.

6) Description of local offsite emergency support services. -

, 7 *

.f .

..y d+

2 l ,

y, ,0 - ,

ip_ +

's l' 7) Identification of, and assistance expected from State, .

s ;-.. _I i

' , local and Federal agencies with emergency responsibilities.

• 4- ., 8) Identification of State and local officials responsible

, a for planning protective actions, including evacuations.

^'

+l lt B. Assessment ;Actions ~ -

. 1) Description offoffsite monitoring methods for deter- l

, ,/

r mining the magnitude ancy c9ntinually assessing the impact te .

,j of radioactive releases. l t; 1 W,

C. Activation of Emergency Organization

"' 'l) Description of emergency' actions for notifying offsite .

.. [

1, agencies and notation that a message authentication scheme l - -

exists for such agencies.:

l:

D. Notification Procedures ,

1) DescriptIonofmeansfornotifyingandagreementsreached f 1

with local, State and Federal officials and agencies for the r prompt notification and evacuation of, and other protective

- t .

measures for,~the public.

A l i- 2) Identification of the State and local government  !

l agen'cies within Applicant's Emergency Planning Zone (EPZ).

3) Description of provisions for yearly dissemination to the public within the plume pathway EPZ of information on emergency planningi nature and effects of radiation, and a listing of local broadcast stations.

t . _

4) Demonstration that the State / local officials can make a public notification decision promptly on being informed of an emergency. i E. Emergency Facilities and Equipment ,-

1) Description of arrangements for transporting contami-nated individuals to identified treatment facilities outside the side bcundary (i.e., facilities other than the National Naval Medical Conter).

2) Description of arrangements for treatment of said individuals at said facilities.

- ~3) Description of a near-site emergency operations facility '

and offsite communications systems with a backup power source.

F. Training l

1) Description of provisions for conducting a rad [ological orientation training program for local Civil Defense, law .

enforcement, and news media personnel. ,

G. Recovery  !

1) Description of criteria for determining when  !

l Applicant's facility may be re-entered or its operation may be resumed. .

l .

t I

9 t

\ .

. 25c. The Intervenor has compared the AFRRI Emergency Plan with those pre ared by licensees and/or applicants for relicensing for nuclear reactor facilities that have been approved by the NRC, and with Regulatory Guide 2.6, and 10 C.F.R., Part 50, Appendix E. Certain requirements of the Regulatory Guide and of 10 C.F.R., Part 50, Appendix E, are not complied with in the AFRRI Plan. For example, certains bypes of provisions included in these other emergency plans (and identified in the Answer to Interrogatory 25b.', above) are not included in the AFRRI Emergency Plan. ,

(Answers continued on next page.)

m INTERROGATORY 2o

a. Presumably the radionuclides found by the Washington Suburban Sanitary Commission (see WSSC reports on AFRRI effluents) are generated by routine operations I

at AFRRI.

g., 1. To state how the Licensee's corrective actions are inadequate and to propose safeguards, the Intervenor needs more detailed information from the Licensee regarding the Licensee's methods of collecting and describing specimens, analysing , redu-cing and reporting data, and the use and calibration of its

.! environmental monitoring equipment. The Intervenor therefore reserves its right to promulgate questions regar, ding these and related matters in its second round of interrogatories to the Licensee, in particular questions that will enable the Intervenor to more ful1y respond to Licensee's Interrogatories 26 - 31.

INTERROGATORY 27 - '

10 C.F.R Part 20 and Appendices B.and C thereto, d.

h. See CNRS's response to Interrogatory 26a,; supra.

INTERROGATORY 28 _

a. The environmental . monitors should, a t a minimum, be able to detect the isotopes listed in Appendices B and C of 10 C.F.R. Part 20. Please refer to CNRS's responses to the NRC -

b.- k.

Staff's first set of Interrogatories, Stipulated C9ntention~.4, l

]

Qucations 14-27 (pp. 8-10, filed 12-3 81) for responses to the Licensee's interrogatories regarding environmental monitoring and measuring, j The Licensee is bound by the following in conducting and reporting the results of its environmental monitoring and measuring program:

1. 10 C.F.R. (20.1 (ALARA principle).

2. 10 C.F.R. 320.106(c).

3 10 C.F.R. g20.201( b) .

4 NRC Regulatory Guide 4.15 (2/79). This reguia-tory guide provides guidance for " assuring the quality of measurement of radioactive material in effluents and the environment outside of nuclear facilities" for which monitoring is required. The Guide states in pertinent part:

Every organization actually performing effluent and environmental monitoring, whether an NRC licensee or the licensee's contractor, should include the quality assurance program elements pr6sent&d in'this guide.

. . . 3. Operating procedures.

Written procedures should be prepared, reviewed, and approved for activities involved in carrying out the monitoring program, including sample collection . . . ,

preparation and analysis of samples; maintenance, storage, and use of radioactive reference standards; calibration

_ _ _ . .- _ . _ , . - , . . , , . , , , - _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ . , - . . - . - . . . _ , , . . . _ _ , _..m . _ _ _. .-., , ... _ - . _ - , _

r_ .___. _ _ - - - _ _ _ - _ _ _ . . __ ._... - - - ._ _ _ _ _ . _ . _ .. _ _

INTERROGATORY 28, cont'd.

4 and checks of ' radioactivity measurement systems; and

! reduction, evalua tion, and reporting of data.

4. Records The records necessary to document the activities performed in the monitoring program should be specified in the quality assurance program.

Regulatory Guide 4.15 goes on under " Records" to state that a key aspect of the quality assurance program is to keep records that track the progress of a sample through the entire sequence of the monitoring process, frem initial collection and descrip-tion through data reduction and verification.

5 NRC Regulatory Guide 8.25 -(8/80). This regula-tory guide cites 10 C.F.R. g20.106(c) for the proposition that a licensee's obligation to measure unrestricted area concentrations requires in many cases air monitoring beyond the restricted area.

This guide also cites the American Conference of Governmental Industrial Hygienists' manual, " Air Sam ling Instruments for Evaluation of Atmospheric Contaminants,p' 5th Edition,1978 (copies available from ACGIH, P.O. Box 1937, Cincinnati, OH 45201). The Guide states that Part II,Sec. I, of the manual "7provides instructions for acceptable methods of calibrating air volume and flow rate metering devices;" in particular ..

Tables II,III, and IV provide sources of recommended and standard methods. The Guide supplements the manual's instructions by adding guidance for frequency of calibration, for acceptable error limits in volume measurement, and for documentation. The Guide states that " theilicenseercsh6did maintain records of all routine and special calibrations of airflow or volume;; metering devices, including the priman or secondary' standard:used, Jmethod employed ( emphasis added),

and estimates of accuracy of the calibrated metering devices."

Regulatory Guide 8.25 states in its introduction that 10 C.F.R 820.106(c)(4) " requires that licensees provide information as to the highest concentration of each radionuclide in an unrestricted area CNRS takes the position tha t the regulations, regu-latory guides, and manual cited above require AFRRI to have a particulate monitor, an isokinetic gross activity detector, and other methods and devices recommended by CNRS in its response to the Staff's Interrogatories, because these things are neces-sary to meet the monitoring and documentation standarde set forth in the cited references and to meet the standards imposed by the quality assurance program and the ALARA principle.

INTERROGATORY 29

a. - f. See CNRS's response to Interrogatory 28, supra.

2 INTERROGATORY 30 a.-d. See CNRS's response to Interrogatory 28, supra.

INTERROGATORY 31

b. -c. See CNRS's response to Interrogatory 28, ..

supra.

4 INTERROGATORY 32

c. See CNRS's response to the NRC Staff's Inter-r'ogatories 31 and 32, Unstipulated Contention 1 (filed 12-3;81).

INTERROGATORY 35

e. See CNRS's responses to the NRC Staff's Inter-rogatories 12-3-81, .pp. 34,12-14 35,)and

. 36, Unstipulated Contention 2 ( filed

f. - 1. See CNRS's response to the N'RC Staff's Interrogatory 37, Unstipula ted Contention 2 ( filed 12-3281,

p. 14).

~

INTERROGATORY 36_

a( 2) -(4),. c, d, g. See CNRS's responses to the NRC Staff's Interrogatories 14 - 27, Stipulated Contention 4 ( filed 12-3-81, pp. 8 - 10) . .

In supplementing its responses to the Licensee's First Set of Interrogatories, the Intervenor hereby incorpor-ates by reference'its responses, in their entirety, to the NRC Staff's Request for Admissions and First Set of Interk rogatories. To the extent that any of the Licensee's interrogatories have not been adequately addressed in this Supplement, the Licensee is referred to the responses to the corresponding contentions in the incorporated document.

i i

Respectfully submitted, dd . bxD n El(pabbth B. Entwisle 'T Counsel for Intervenor

T. U *. *

-=

AFFIDAVIT OF ELIZABETH B. ENTWISLE j C.?ls,5l

e. O

+

.. . :l I, Elizabeth B. Entwisle, being duly sworn, do state:

1. That Intervenor CNRS's Supplementary Response to Licensee's First Set of Interrogatories was prepared under my direction and supervision.

2. That the responses contained therein are true to the best of my knowledge, informa tion, and belief.

i f l,r b. ,D ..

Eliz beth B. Entwisle

!)? [gf

~

~dU /

SUBSCRIBED AND SWORN to before me this d' day of August, 1982.

s Mt'YSk Wj U V Notary Public p QW W M"""~ j Yb JfN Y Y , / f

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _