ML20073L653
| ML20073L653 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/19/1983 |
| From: | Adler R PENNSYLVANIA, COMMONWEALTH OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| ALAB-698, NUDOCS 8304210201 | |
| Download: ML20073L653 (5) | |
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- e -+ LNITED STATES OF AbERICA l NUCEAR REGULATORY CONISSION " 9 l
8 O BEEDRE T11E 03MISSIW
! In the Matter of: 2 MSg 3 METROPOLITAN EDISW OWPANY, ) [%,3 A l, ) Docket No. 28 dip /%
(Three Mile Island Nuclear ) (Restart *)/
k p Station, thit No.1) ) ;
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Cat 0NWEALTH OF PENNSYLVANIA'S
, BRIEF AMICUS CURIAE IN SUPPORT OF PETITION FOR REVIE4 OF ALAB-698 4 Introduction The NRC Staff filed a Petition for Review of AIAB-698 on thvenber 12, 1982. In this Petition the Staff sought review of the Atomic Safety i and Licensing Appeal Board's decision regarding Licensee's staffing l plans for its Emergency Operations Facility (EOF). The Comnonwealth incorporates by reference the statement of procedural history on this
- issue contained in the Staff's Petition.
The Cmmission requested briefing on this issue in CLI-83-7, dated i
i March 21, 1983. Although the Cmmonwealth elected not to file a Petition for Review on this issue, the Conmission invited the Comnonwealth to I
[ file a brief if it so desired. The Conmonwealth participated extensively on this issue both before the Licensing and Appeal Boards, and continues to have an interest in the adequacy of connunications between the Licensee and the Connonwealth during the early stages of an accident at IMI-1. Therefore, the Cmmonwealth is filing this brief amicus curiae in support of the Staff's position.
Argument The conmonwealth's fmdamental legal position on this issue is contained in its Reply to License 5's Brief in Support of Exceptions to the ASLB Partial Initial Decision on Emergency Planning Issues 8304210201 830419 PDRADOCK05000g L .
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~(Exception No. 3) (May 10,1982) (copy attached), and need not be repeated here. Instead, the Comanwealth wishes to underscore briefly the Comonwealth's policy reasons supporting the transfer of protective action decisionmaking to the EOF as early as possible in the accident (i.e.
, within one hour after declaration of Site F2nergency).
The Cmmonwealth's emergmcy planning officials have nw participated in six full-scale EDE exercises, as well as nunerous drills, since the IMI-2 accident. As a result of this experience, the Commonwealth has developed a philosophy of dispatching a nuclear engineer to the EOF as soon as possible during an incident. This philosophy is also supported by the IMI-2 accident itself, where infonnation flow fra the Licensee to offsite officials was demonstrably inadequate. The Comonwealth has increased its staff of nuclear engineers (from 1 to 3) since the TMI-2 accident to inplement this new strategy.
The Commwealth is primarily concerned with the adequacy of the infonnation exchange and interface between Cmmonwealth and Licensee officials during the early stages of an accident. Licensee's accident managment philosophy, as accepted by the Appeal Board, presumes that the Licensee alme makes protective action decisions based on information 1
available in the control room. This decision, according to the Licensee,
- 1. The Appeal Board appears to believe that superior information in the control roan is necessary to support the fonnulation of pro-tective action recomendations. The Board does not explain why this infonnation is available between hours 1 and 4, after declara-tion of site emergency, but not after hour 4, when all parties agree that respcusibility for protective action decisions should be transferred to the EOF. Marcover, it is not clear why this critical information can be transferred by telephone to the Conmonwealth's nuclear engineer for purposes of making protective action recmmendations to the Governor, but not to the Licensee official in the EOF responsible for making protective action reemmendations to the Cmmonwealth s engineer. The Conmonwealth has strong doubts about whether this intonnation will reach the Camonwealth's engineer when the senior Licensee management official is in the control room. When the senior Licensee official is in the EOF, this infonnation is certain to be transmitted.
T need only be transmitted via telephone to the comonwealth's engineer in the EOF. But the Licensee only makes protective action reccomendations.
The ultimate decision regarding protective actions for the public is made by the Governor, based on reconmendations received frcxn his designated representative at the site. It is essential that the Conmonwealth's engineer be in a position to transmit a conplete report to the Governor, including not only raw protective action reconmendations but also the ccxnplete basis for, and the conplexities and uncertainties inherent in those recomendations. Such information can only come from the Licensee
)fficial making the protective action recomendations.
Moreover, the Appeal Board ignored the fact that the information exchange and interface sought by the Ccxmxxiwealth during the process of protective acticn decisionmaking is bidirectional. Protective action reconmendations should be based on the status of offsite preparedness and such intangibles as weather and road conditions in addition to the specific technical status of the plant. h EOF is a facility specifically designed to provide this broader overview of information and coordination between arcite and offsite officials. h plant control rocxn, on the other hand, is specifically designed to provide the data necessary to control the plant transient. The senior Licensee official in the control room should focus his efforts on responding to the accident from an l
l engineering perspective. The senior Licasee official in the EOF should focus his efforts on overall accident management and coordination, including the cooperative fornulation of protective action reccomendations with the Conmanwealth's designated representative, based on both onsite and offsite input. ,,
I Finally, the Commnwealth wishes to enphasize the fundamental legal requirement that the adequacy of any strategy for protecting public l
g health and safety must be proven prior to restart. h NRC Staff /Comnon-wealth accident management philosophy has been tested and approved during a full-scale exerc. :e at DiI. The Licensee's' accident management philosophy, now accepted by the Appeal Board, has never been danonstrated.
Particularly where the Licensee chooses to deviate from NRC Regulatory Guidance, the burden of proof is clearly m the Licensee to demonstrate the adequacy of the alternative means of conpliance. 'Iherefore, at a mininun, the Comnission should inpose the alternative remedy suggested by the Comnonwealth and supported by Adndnistrative Judge Edles in his partial dissent to AIAB-698. Licensee should be required to demonstrate, prior to restart, the adequacy of its strategy for control roan / EOF staffing during the early hours of an accident at Dil-1.
Respectfully submitted, o
~ BEfT W. ADLER Assistant Counsel Camrmealth of Pennsylvania Room 505 Executive House P. O. Box 2357 Harrisburg, Pennsylvania 17120 717-787-7060 Dated: April 19, 1983
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t; o , j ip UNITED STATES OF AIERICA NUCLEAR REGUIA70RY 00t!IISSION BEEDRE 7HE ATRIIC SAFEIY AND LICENSIZE APPEAL BOARD In the liatter of:
METROPOLITAN EDISON CCt4PAlW, :
(Three title Island Nuclear : Docket Ib. 50-289 Station, Unit Ib.1) : (Restart) 0@t0lMEALTH OF PEtREYLVANIA'S REPLY TO LICEtEEE'S BRIEF IN SUPPORT OF EXCEPTIOtB 10 THE ASLB PARTIAL INITIAL DECISION ON DIERGENCY PIAltmU ISSUES (EXCEPTI0t! NO. 3)
ROBERT W. ADLER Assistant Counsel Comromealth of Pennsylvania 505 Executive House, P.O. Box 2357
.. Harrisburg, Pennsylvania 17120 Telephone: (717) 787-7060 May 10,1982 y , _ r~ n n t,.J A11 Ll ,g q +u J i I" l ! D
o TABLE OF C0tTIENIS Page TABLE OF ALTm0RITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 00UNIERSTAIDfElff 0F QUEST 101E PRESEtTIED. . . . . . . . . . . . . . . . . . . . . . . . . . 1
. CDUNIERSTATHIEtfr OF BE CASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 APIRNENr. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 I. HE LICEtiltG BOARD RULI!U IS SUPPORTED BY RELIABLE A10 PROBATIVE EVIDENCE, DELUDIIU B0HI GEtERIC GUIIntCE DOCUMEtTIS AIO EXPERT TESTDONY ON LICEtEEE' S DIERGEtEY RESPONSE ORGANIZATION. . . . . . . . . . . . . 8 A. The Licensing Board Did Ibt Place Undue Reliance On Generic Regulatory Guidance. . . . . . . . . . . 9 B. The Weight Of The Evidence Supports The Licensing Board's Ruling......................... 11 II. THE LICEtEltU BOARD'S DECISION IS All APPPOPRIATE EXERCISE OF RE;UIATORY C0tTIROL OVER LICDEEE'S R!ERGENCY RESPO!EE ORGANIZATION IN A MATTER WHIOl IS CRITICAL TO PUBLIC HEAUDI A!O SAFETY. . . . . . . . . 21 III . C0lELUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 1
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TABLE OF AUIHORITIES Judicial Proceedings Page(s)
California Bankers Assn. v. Shultz, 416 U.S. 21 (1974).......... 8 Jaffke v. Dunham, 352 U.S. 280 (1957) . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 lbclear Regulatory Comission Proceedings Consumers Power Co. (Midland Plant, Units 1 & 2), AIAB-452 (Decanber 30, 1977), 2 IUC. REG. REP. (CG) 130,263........ 9 Duke Power Co. (Catawba lbclear Stations, Units 1 & 2),
AIAB-355 (October 29, 1976), 2 IUC. REG. REP.
(C G) 130,116.............................................. 9 Duke Power Co. (Perkins Ibclear Station, Units 1, 2 & 3),
AIAB-302 (Decmber 10, 1975), 2 IUC. REG. REP.
(C G) 130.,031.............................................. 9 Final Rule on Faarnency Planning, CLI-80-40, (Decenber 5, 1980), 2 IUC. REG. REP. (C G) 130,558........ 10 Gulf States Utilities Co. (River Bend Station, Units 1 6 2) , ALAB-444, 6 tRC 760 (1977) . . . . . . . . . . . . . . . . . . 10 Metrooolitan Edison Co. ('Ihree Mile Island Nuclear Station, Jnit Ib.1), LBP ,.14 NRC (Partial Initial Decision).......................................... 8, 9, 10, 11 Public Service Co. of Indiana, Inc. (Marble Hill Nuclear Generating Station, Units 1 & 2), AIAB 549 (February 16', 1978), 2 IUC. REG. PIP. (CG) 130,272.................. 8 I Vernent Yankee thclear Power Corp. (Vernant Yankee Ibclear Power Station), CLI-74-40, 8 AEC 809 (1974)............... 10 Regulations 10 C. F . R. 5 50. 47 (b) (1) n. 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 10 C . F . R. 5 50. 47 (b) (.2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 10 C . F . R. 5 50. 47 (b) (8) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 10 C . F . R. 5 50. 54 (S) (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 10 C.F.R. Part 50, App. E...................................... 5, 18
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Other Authorities Page(s)
NUREG-0654; FH %-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants". . . . . . 3, 4, 8,10, 11, 16 i NUROG-0696, Rev. 1, " Functional Criteria for Dnergency Response Facilities" . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4, 16 NUREG-0746, Supp.1, "Dnergency Preparedness
. Evaluation for 'IMI-1" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6, 16 g -iii-
000thERSTA'IBETF OF OUESTIOIB PRESBTIED
- 1. khether the Licensing Board was correct in ruling, on the basis of direct testimony presented by the IRC Staff and the Ccxmomealth of Pemsylvania, as well as two generic TE Staff regulatory guidance documents, that Licensee's failure to staff its offsite Emergency Operations Facility (EOF) with an Dnergency Support Director within one hour of declaration of a site energency, violates the requirements of the NRC emergency planning rule?
- 2. Whether Licensee met its burden of proof to deTonstrate that its offsite energency response organization meets the requirenents of the IRC energency planning rule, despite contrary direct evidence presented by the tRC Staff and the Contemealth of Pennsylvania, as well as generic tRC regulatory guidance documents?
- 3. Whether e Licensing Board ruling regarding the interface during a nuclear energency between Licensee's emergency response organization and the energency response organizations of federal, state and local agencies, and affecting protective action decisions for meiers of the general public, constitutes an umarranted intrusion into an " internal" Licensee managenent decision?
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9 00UIEERSTATEEtE OF THE CASE The issue addressed in Licensee's Exception Ib. 3 arose out of a finding by the IRC Staff that Licensee's offsite mergency response organization is deficient due to insufficient staffing of the offsite Duergency Operations Facility (EOF) during the early hours of an accident.
This finding generated a controversy between the Licensee on one side and the staff and the Conrnonwealth of Pennsylvania on the other. All three parties produced direct evidence on this issue, although Licensee's brief ignores entirely the evidence presented by the Connonwealth.
Ib party to this proceeding underestimates the importance of either the EOF or the Energency Support Director. Licensee's testimony refers to the EOF as the " central point for: (a) providing overall corporate managenent and direction in responding to an mergency, (b) coordinating adninistrative and logistical support, (c) interfacing with state and county representatives, and (d) establishing the basis for long-term recovery efforts." Rogan, et al., ff. Tr. 13, 756, at 21-22; see also, Licensee Ex. 30, at 7-3; Staff Ex. 8, at 16-24. The importance of the Emergency Support Director is set forth in Licensee's mergency plan:
- 1. The Energency Support Director vill be responsible for activating and directing tha offsite mergency support organization and ensuring that the functional groups provide a coordinated response in support of the on-l site mergency organization. The Emergency I
Support Director will serve as the senior managenent representative at or in the vicinity of the IMI site. As such, during emergency operations, the Dnergency Support Director will direct all mergency efforts and policies; the Emergency Director, however, will maintain responsibility for the operation and control.of the plant. In the absence of the Emergency Support Director, the senior most 111I-1 operations person will 3 ._ ___ _
4 assume his responsibilities. As emergency situations tend to stabilize, the Energency Support Director may relieve the anergency
, Director of more and nore accident
,' managenent responsibilities. This will provide a controlled means of shifting to a
, recovery organization should that type of organizational arrangenent be desned
.necessary.
Licensee Ex. 30, at 5-16 to 5-17. Once the energency support director arrives at the EOF, he assumes the responsibility for making protective k action rammandations to the Connonwealth's Bureau of Radiation Protection '
, (BRP). Tr.14, 779 (Rogan); 14, 781 (Giangi).
l The Licensee correctly observes that the IRC energency planning rule itself does not require a facility called an EOF or a position
. entitled an Dnergency Support Director. This analysis, however, exalts i
form over substance. As demonstrated below, the regulations clearly
- envision that the functions served by both the 00F and the Dnergency Support Director are required to be in place during an energency. This
- interpretation is supported by the IRC Staff's applicable regulatory i guidance.
! First, planning s.tandard 8 of the regulation reads: " Adequate 1
energency facilities and equipment to support the emergency response are provided and maintained." 10 C.F.R. 550.47(b)(8) . As interpreted by IEEG-0654, there are two pertinent FDF requirenents:
- 2. Each licensee shall establish an Emergency Operations Facility from which evaluation and coordination of all licensee activities related to an energency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to radiological energencies in accordance with IUREG-0696; Revision 1.
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-4. Each organization shall provide for timely activation and staffing of the facilities and centers described in the plan.
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Staff Ex. 7, at 52 (sphasis added). WRm-0696, Revision 1, states, in pertinent part:
The EOF shall be staffed to provide the overall managment of licensee resources and the continuous evaluation and coordination of licensee activities during and after an accident. Upon EOF activation, designated personnel shall report directly to the FDF to achieve full functional operation within one hour. A senior management person designated by the licensee shall be in charge of all licensee activities in the FDF.
The S F staff uill include personnel to manage the licensee onsite and offsite radiological monitoring, to perfonn radiological evaluations, and to interface with offsite officials. The EOF staff assigments shall be part of the licensee's emergency plan. The specific number and type of personnel assigned to the EOF may vary according to the energency class. The staffing for each energency class shall be fully detailed in the licensee's emergency plan. Operati.ng procedures and staff training in the use of data systes and instrumentation shall contain guidance on the limitations of instrumentation including whether the infonration can be relied upon following serious accidents.
Staff Ex. 8, at 19 (emphasis added).
Second, planning standard 2 states:
On-shift facility Licensee responsibilities for energency response are unambiguously defined, adecuate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely aumnentation of response capabilities is available, and the interfaces anong various onsite response activities and offsite support and response activities are specified.
10 C.F.R. 550.47(b)(2) (e:phasis added) . Compliance with the timeliness elments of this standard are defined by Table B-1 of WRE-0654, which requires a senior ranager to serve as EDF Director within 60 minutes.
Staff Ex. 7, at 37.
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Third, Appendix E to 10 C.F.R. Part 50 requires that:
" Adequate provisions shall be made and i described for emergency facilities and equipment, including .. 8. A licensee onsite technical support center and a licensee near-site anergency operations facility from which effective direction
. can be given and effective control can be exercised during an energency." (anphasis added).
It is difficult to interpret ."during an energency" as precluding the first four hours of.an energency. Licensee atta: pts to avoid this result by arguing that "energency", according to the NRC Staff, does not include the te lowest classes of energency (unusual event and alert),
nor does it include the first hour of a site etergency. Licensee Brief at 46-47 n. 23. From a functional perspective, there is a tranendous
- difference between the lowest two classes of energency and a site energency. Ib actual reconnended protective actions are envisioned i
during the unusual event or alert stages. Thus, the interface between j onsite and offsite organizations becomes nest critical (from the standpoint ,
of EOF staffing) during a site energency. Compare Staff Ex. 7 at 1-4, 1-6 with id. at 1-12, 1-16. The one hour activation time recognizes that it is impossible to achieve innediate activation of the EOF on I
j declaration of site energency.
Contrary to the implications in Licensee's brief, the need to staff the EOF fully is supported by sound evidence in addition to generic LRC regulatory guidance. The IRC Staff testified from the outset that l
Licensee nust staff the Emergency Operations Facility (EOF) with a senior manager acting as EOF Director within one hour of declaration of I
an energency. Although many of the discrete functions performed by the Dnergency Support Director (Licensee's EOF director) can be performed by
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other personnel on Licensee's energency staff, the fRC Staff's position is based on the need to have "a senior mnager who can speak with authority to other energency organizations on radiological or operational matters ..." chesnut, ff. Tr.15, 007, at 23-24. &. Chesnut testifed-with knowledge of all applicable site-specific energency plans. The IRC Staff maintained this position with documentary and testimonial evidence throughout the proceeding. See, e.g. , Tr. 22, 971 (Chesnut); Staff Ex.
27, at 11-13 to II-14. (Emergency Preparedness Evaluation for 'MI-1, IUREG-0746, Supp.1).
Ibreover, the IRC Staff's position was supported by reliable and probative evidence presented by the Commonwealth. W. William Dornsife, Supervising Ibclear Engineer for the Pennsylvania Department of Environmental Resources' Bureau of Radiation Protection, testified as to the need to transfer the Frergency Support Director functions to the BOF as soon as possible following declaration of a site energency. Tr.
23, 012-16 (Dornsife) . This testimony is explained more fully below.
i Licensee's brief focuses on the Licensee / state interface as the primry reason for providing an Frergency Support Director within one hour of declaration of a site energency. In light of this realization, it is l
l difficult to understand hcw Licensee's brief could have ignored the Cormonwealth's expert testimny on this point. Ibtably, &. Dornsife is the state official responsible for reporting to the FDF once the FDF is fully mnned. Tr. 23, 012; 23, 014 (Dornsife) .
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- Licensee, of course, presented witnesses who testified that full staffing of the EOF within one hour of declaration of a site emergency is not necessary to comply with the,anergency planning regulation. The question before this Appeal Board is whether Licensee met its burden of 3 l . - . _
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proof on this issue, in light of the evidence to the contrary presented
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i l by the NRC Staff and the Comonwealth, in addition to the IRC Staff's generic regulatory guidance documents. The Comonwealth submits that this burden was not met, and that the Licensing Board's ruling should be upheld.
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ARGll!EITI ,
1 I. 11E LICEtBItU BOARD RULItU IS SUPPORTED BY RELIABLE AIO PROBATIVE '
EVIDE!UE, INCLUDItB B01H GHERIC GUIDANCE DOCLEDTIS AID EXPERT TESTROIN ON LICENSEE'S EMERGENCY RESP 0 TEE ORGAITIZATION.
Licensee urges the Appeal Board to reverse the judgment of the Licensing Board on the ground that " undue reliance" was placed on generic guidance documents that do not consider Licensee's site-specific emergency response organi::ation. First, Licensee ignores the presumptive validity given to IRC regulatory guidance, and particularly to IUREG-0654, as discussed below. Second, the ASLB decision was based on reliable and probative record evidence in addition to the IRC guidance docutents.
See, e.g. , Metropolitan Edison Co. (Three !!ile Island Nuclear Station, Unit Ib.1) (Partial Initial Decision on Plant Design and Procedures, Plant Separation, and Emergency Planning Issues), LBP , 14 N.R.C.
(December 14, 1981), 111386-88 [ hereinafter cited as P.I.D. 1 ].
Licensee appears to ignore this evidence. In addition, it must be noted that the Appeal Board is not limited to consideration of the reasons articulated by the ASLB. Successful parties before the ASLB may argue that the decision be sustained for any reason which finds support in the record. Public Service Co. of Indiana, Inc. (Marble Hill Ibclear Generating Station, Units 1 & 2), Docket Ib. SIN. 50-546, 547, AIAB 549 (February 16, 1978), 2 IUC. REG. REP. (CCH) 130,272.13, citing Jaffke
- v. Dunham 352 U.S. 280 (1957), and California Bankers Assn. v. Shultz, 416 U.S. 21 (1974) .
If the evidence is viesed in Licensee's perspective, the Board ignored Licensee's site-specific evidence and based its rulirg, solely on generic regulatory guidance. When viewed in the proper perspective, i.e. considering the direct site-specific evidence presented by all of 4
the parties in addition to the regulatory guidance, the Board weighed the evidence on both sides of the issue and determined that the evidence and argtunents presented by the IRC Staff and the Conurmealth were nore persuasive than the evidence and argunents presented by the Licensee.
PID 111367, 1392. This was a perfectly appropriate exercise of judgnent which should be upheld by the Appeal Board. khile the Appeal Board may substitute its judgment for that of an ASLB, it should not do so lightly.
i Duke Power Co. (Catawba Nuclear Stations, Units 1 & 2), Docket tbs. 50-413, 414, A1AB-355 (October 29, 1976), 2 NUC. REG. REP. (CCH) 130,116.03.
Duke Power Co. (Perkins Nuclear Station, Units 1, 2 & 3), Ibcket tbs.
STU. 50,488, 489, 490, AIAB-302 (Decenber 10, 1975), 2 IUC. REG. REP.
130,031.04. In short, presumptive validity should be given to the ASLB's findings and conclusions, Consumers Power Co. (Midland Plant, Units 1 & 2), Docket Ib. 50-329A, 330A, AIAB-452 (Decmber 30, 1977), 2 IUC. REG. REP. (CCH) 130,263.15, as long as the ASLB considered the appropriate evidence and factors, and made no errors of law. Licensee attenpts to evade this result by accusing the Board of ignoring Licensee's evidence, while Licensee itself ignores the evidence presented by the NRC Staff and the Conrotraealth.
l A. The Licensing Board Did Ibt Place Undue Reliance On Generic Regulatory Guidance.
Licensee acknowledges that it clearly bears the burden of proving l ccrupliance with the applicable energency planning regulations. Licensee Brief at 51, citing PID 11391. What Licensee fails to recognize is the presumptive validity of IRC regulatory guidance as an appropriate means of complying with the energency planning rule. In this context, the Licensing Board was cor ect in using first the regulation, and then the
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' regulatory guidance, ao the starting point for its analysis. See PID 111377-80. Following its discussion of these sources of authority, the ASLB states:
1380. We bear in mind in our subsequent findings these roles of the EDF and of the Emergency Support Director.
1381. We next present Licensee's case, as set forth in its proposed firdings.
It is clear from this language that the Board used the regulatory guidance only as a starting point. It then provided Licensee with the opportunity to rebut the presumptive validity of the regulatory guidance.
The nature and legal effect of regulatory guidance in tRC proceedings was discussed in the Conmxwealth's Brief on Exceptions to the ASLB Partial Initial Decision on Plant Design and Emergency Planning, at 8-10.
Briefly, regulatory guides represent one possible means of meeting the planning standards in the emergency planning rule. kMle alternative means of compliance are permissible, such coupliance must be denonstrated on the record on the basis of reliable and probative evidence. Gulf States Utilities Cc. (River Bend Station, Units 1 & 2), AIAB-444, 6 tEC 760, 772 (1977). In conducting this analysis, the accepted standard is that regulatory guides are entitled to " considerable prima facie weight."
Vernent Yankee Ibclear Power Corp. (Vermont Yankee Ibclear Power Station),
CLI-74-40, 8 AEC 809, 811 (1974). This concept was recently applied by the Cocinission with respect to IMEG-0654 In re Final Rule on Finergency Planning, CLI-80-40 (Decenber 5, 1980), 2 BUC. REG. REP. (CCH) 130,558 (Coninission stated its intent to be guided by FBR's judgment in IEREG-0654 as to how to comply with the emergency planning rule). Ibtably, NCREG-0654 is unique among regulatory guidance in that it is footnoted
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in the regulation. 10 C.F.R. 550.47(b)(1) n.l.
i B e Licensing Board gave the relevant regulatory guidance appropriate, I but not undue, weight in resolving this issue. We very language quoted by the Licensee (Licensee Brief at 52) is indicative of this fact: "In light of the Staff and Connomealth having come forward with this evidence, including [but not limited to) the guidance of WRG-0654 .. ." PID 11392 (.anphasis added). Be only rmaining question, therefore, is whether the Licensing Board erred in its judgment that Licensee failed to meet its burden of proving that its alternative method of compliance with the mergency planning rule is adequate, in light of the evidence to the contrary presented by the IRC Staff and the Camomealth.
B. He Weight Of he Evidence Supports he Licensing Board's Ruling.
Le Board's ruling is supported by direct testimony from FRC Staff and Connenwealth witnesses, all of whom were familiar with the applicable site-specific anergency plans.
Mr. William Dornsife testified on this issue on behalf of the Connonwealth of Pennsylvania.1 Mr. Dornsife is responsible for comnunicating with Licensee to detennine the operational status of the facility during an anergency, in order to provide insight into protective action reconnendations based on operational factors. % e Comnonwealth has determined, through drills at TII and at other plants, as well as during the TII-2 accident, that operational infonnation is a critical input into the protective action reconnendation. In order to perform this function, Mr. Dornsife will report initially to the state Bureau of
- 1. Mr. Dornsife is the supervising nuclear engineer for the Connmaealth of Pennsylvania. Biographic Infomation of Willian P. Dornsife, P.E., ff. Tr. 23,011.
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o Radiation Protection (BRP) headquarters in Harrisburg, and to the EOF as soon as the FDF is manned. Tr. 23,012; 23,014 (Dornsife).
Originally, it was envisioned that Mr. Dornsife could satisfactorily obtain the necessary operational information by ruraimng at BRP headquarters. During drills conducted in preparation for the June 2, 1981 conprehensive energency planning exercise at ?!I-1, however, the Comorwealth detennined that it was difficult to obtain the necessary operational information through dedicated telephone lines. Significantly, based on this deficiency in information flow, it was -Licensee who reconinended that Mr. Ibrnsife be dispatched to the EOF as soon as possible.
Tr. 23, 013-14 (Dornsife). The NRC Staff witness also agreed with this conclusion due to his observation of the June 2 exercise. Tr. 23, 062 (Gesnut).2 Another alternative would have been to provide for direct telephone conversations between the BRP nuclear engineer and the emergency director in the control room. See Licensee Brief at 60 n.28.
Licensee chose the EOF alternative, however, since the energency director's workload might prevent intnediate cormunications with the BRP representative.
i Tr. 23, 035 (Dornsife). The Contronwealth continues to believe that adequate operational infonnation cannot be obtained through the use of dedicated telephone lines.
- 2. The Staff's views regarding interface with offsite agencies was based, in part, on the assunption that the state nuclear engineer would report to the EOF. Tr. 15, 523 (Chesnut). Mr. Chesnut stated:
. . . one function the staff considers important is that of interface in coordination with other
- offsite agencies as well, and some coordination of the overall energency offsite response.
! Several other agencies will be responding to an energency at Three Mile Island thit 1, and they in many cases will report to the energency operations facility. Staff believes that this function should be available within one hour of the declaration of an emergency.
'Tr.15, 013 (Chesnut) . See also Tr.15, 036 (Grimes) .
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- 16. Dornsife explained further that, during drills conducted prior to the June 2 exercise, the status boards and other technical and radiological infomation available at the EF uns behind real time, and was not necessarily consistent with infornntion actually used to fomulate protective action recocmendations. Critical real time information was obtained through direct connunications between the mergency director and the mergency support director. FE. Dornsife expressed doubts as to whether such information would necessarily be transmitted to the EOF without the presence of the Fmergency Support Director. Tr. 23, 014-15 (Ibrnsife) . Fbreover, FE. Dornsife opined that face-to-face c.ontact between the state and the mergency support director was "very important not only for us directly understanding uhat the protective action considerations were, but for us being able to provide our input into that protective action reconmendation prior to it being made by the Licensee." Id. at 23, 016; 23, 045-35.
tk. Dornsife's view that the attention devoted to the FDF staff will diminish in the absence of the Fmergency Support Director also appears to be supported by Licensee's mergency plan:
- 2. The Frergency Staff Support located at the mF will assist the Fmergency Support Director by interfacing with the ofisite e.ergency support organi::ation leaders and providing status reports to the Fmergency Suppcrt Director. In the absence of the Emergency Support Director the Frergency Staff Stnoort will rot assume energency responsibilities rather it will be the most senior 1MI-1 operations person (i.e.: VP-1MI-1).
Licensee Ex. 30, at 5-17 (mphasis added) .
The Connenwealth's view is alse- supported by the runner in thich the June 2, 1981 comprehensive exercise was conducted. When ik. Dornsife
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arrived at Licensee's EOF, approximately one half-hour after declaration l of site emergency, the EOF was fully manned, including the emergency support director. Tr. 23, 015 (Dornsife) . Bus, the exercise can be i
used only as evidence that Licensee's energency response organization
- can function efficiently, including adequate interface with BRP, with i the EOF manned and the emergency support director present early into the i accident sequence. By centrast, Licensee's witness, Mr. Rogan, was not aware of any drills conducted at 'IMI-l that did not involve activation ,
1 of the EOF when the exercise was carried through to making protective 4 action recomendations to the state.3 %us, there is no denonstrated I
i capability to interface with the state in terms of transmitting protective action recomendations absent full activation of the BOF. Clearly, l Licensee has failed to meet its burden of proof on this critical point.
Mr. Dornsife also deonstrated, by using an exanple from the June 2 exercise, that some types of operational status information are not available through the normal display panels available at the EDF. Tr.
i 23, 022-24 (Dornsife) . Indeed, ntraerical parameters alone could ret i
possibly convey a complete and accurate depiction of the operational
- status of a facility as complex as a comercial nuclear power plant.
Again, Mr. Dornsife expressed doubt as to whether such infonnttion uould be conveyed to the EDF without the presence of the energency support director. Id. at 23,.023-25. 'Ihe burden of proof is on Licensee to denonstrate the workability of its emergency plan. Since Licensee t
conducted the June 2 drill with the EOF manned as envisioned by the IEC Staff and the (cmonwealth, the Licensee deconstrated the workability of the IRC Staff's and the Cormorraealth'.s concept of operations, rather than their own.
( 3. Mr. Rogan is the Ifanager-Emergency Preparedness for GPU Nuclear.
! Rogan, et al., ff. Tr. 13,756, at 1.
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I he Connerreealth's position, norcover, transcends the need to' obtain raw operational data. He Connetraealth's preference is to ccxmunicate directly with the official actually responsible for making protective action reconmendations. Tr. 23, 053-56. As explained by -
counsel for the Comonwealth, the Commonwealth views the interface between Licensee and the state for the purpose of conveying protective action reconmendations as an overriding consideration in emergency i
planning. Tr. 22, 982-83; 23, 063 (R. Adler) . We focus of the cmergency planning rule is " reasonable assurance that appropriate protective measures can and will be taken ..." 10 C.F.R. 550.54(S)(2) . Le transmission of protection action recocmendations from Licensee to the state is the initial, and hence a critical step in the process of taking appropriate protective measures to safeguard the health and safety of the public in the event of a radiological energency. We importance of this initial interface, therefore, cannot be understated.
Licensee, apparently, does not disagree completely with the Connonwealth's reasoning. On cross-examination, Fr. Rogan agreed with Fr. Dornsife that the adequacy of connunication of protective action reconmendations is a valid concern. Fr. Rogan stated that:
"he mechanical process of connunicating is an essential elcrent of making the reconmendation to the state. In teres of connunicating the basis for that recocriendation certainly the nore information that was made available to the state the nere of an appreciation they would have of the licensee's reasons for making the recocmendations and, therefore, I presume, would be in a.better posture to determine whether to accept or reject that recmmendation.
Tr. 23, 086-87 (Rogan) . ..
In fact, earlier in the hearing,16. Rogan recognized the benefit
of face-to-face contact between the BRP representative and the anergency support director:
upon activation of the energency offsite facility, a representative of the ERP is stationed in that facility and will be aware both of the identification of the energency support director and will have access to the same infonnation that the emergency support director has, so that in effect that representative could serve as the verifying process within his own agency should there be any question as to whether or not the person who picked up the phone as designated energency support director and made a protective action reconmendation was doing so properly.
Tr.14, 783 (Rogan) .
Mr. Rogan also agreed that deficiencies in the use of dedicated phone lines, particularly in terms of receiving operational infonnation, hampered conmunications between Licensee and the Cotuomealth. Mr.
Rogan apparently feels that such connunication probles can be resolved through amended procedures. Tr. 23, 088-89 (Rogan) . Licensee has in no way danonstrated that this problaa has been corrected, however, and therefore has not met its burden of proof.
As noted repeatedly above, the Camomealth's position was supported by IRC Staff testimony. The tac Staff submitted documntary evidence on this point as well. In Supplanent 1 to the IRC Staff's Energency Preparedness Evaluation for 1MI-l (tURED-0746), the IRC Staff indicated l
l that full staffing of the FDF within about one hour of an emergency declaration was necessary for compliance with both IUREG-0654 and IUREG-0696. This document further indicated that " staffing falling below the mininun staffing guidelines of Table B-1 to IUREG-0654 should, by September 1,1981, be capable of being augmented within 30 minutes and that deficiencies should be fully removed by July 1, 1982." Staff Ex. 27, at I
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'II-13 to 11-14. The IRC Staff's view is essentially that there is a:
need to have a separate individual responsible for making protective action reccarandations and performing some of those nonplant related functions, and that he should be renoved from the control room to eliminate some of the confusion that exists . . .
Tr. 22, 971 (Chesnut). Thus, the IEC Staff suggests a separation of functions between operation tasks to be performed in the control room and non-operational tasks, such as protective action recomendations.
Licensee accuses the Board of misunderstanding or misrepresenting Licensee's position and testimony on this issue. Even as presented in Licensee's brief, however, Licensee's arguments fall far short of rebutting the testimony presented by the IRC Staff and the Comonwealth and the applicable regulatory guidance.
Licensee argues first that it balanced the need to minimize the nturber of people and functions performed within the control room with the need to statica the person making the protective action recoranendation inside the control room so as to improve the accuracy of information on which the recomendation is based. Licensee Brief at 54-56. Licensee does not explain how the information flow between the control room and the EOF is improved between one and four hours after declaration of a site energency. If the information available in the FDF is inadequate for purposes of formulating protective action reconmendations at hour one, it will be similarly inadequate at hour four. Second, and more importantly, Licensee's argument fails even to consider, nuch less overcome, the basic thrust of the Carmemealth's position. Protective action reconmendations are made by the Licensee (as well as the IRC).
Protective action decisions are mad [ entirely by the state (ultimately by the Governor). It is critical that such decisions be based on l
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' timely, accurata, and complete information, including an understanding of the subtleties of the ovrall plant status. The Cocronwalth learned through direct experience that this information cannot be obtained unless the protective action recocurndations are fornulated at the place of interface with the state liason official, so that the state will understand not only the reconmendation, but also the reasons for and the information underlying the reconmendation. Incredibly, Licensee's analysis focuses entirely on Licensee's functions, and ignores the interface with the state offsite response organization and the manner in which the information conveyed from the Licensee to the state is used.4 Next, Licensee launches into a long, self-serving but irrelevant, discussion of the adequacy of staffing of the control room during an energency. The Coctoruealth does not question the adequacy of the current control room organization during an energency to perform the functions that should be handled in the control rocm. This discussion simply misses the point. The question is whether protective action r e m wndations should be (rather than "can be") made in the control room. Licensee fails to address the Camonwealth's concern in this regard.
Licensee's real concern, as represented by Licensee's counsel, is that the separation of functions between the FDF and the control room may result in a less senior corporate official in the FDF than in the control room. Tr. 22, 972-73 (Zahler). See also, Tr. 23, 074-75 -(Rogan);
- 4. Licensee lamely argues in a footnote that adequate coordination and control can be achieved by sending six individual representatives from six segments of Licensee's organization to the EOF. Licensee Brief at 56 n.26. Surely this control by Cccmittee is not what the Conmission had in mind in requi~ ring a "near-site mergency operations facility from which effective direction and effective control can be exercised during an mergency." 10 C.F.R., Part 50, App. E, SIV.E.8.
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- Licensee's Brief at 62. Licensee's concern is contradicted, however, by Licensee's own testimony throughout the record that a multitude of 'IMI-l officials are trained and qualified to make protective action reconnendations, down to the level of shift foranan. E.g., Bogan, et al., ff. Tr.'13, 756, at 26-27; Licensee Ex. 30, at 5-6 to 5-7.
Licensee's first two choices for energency support director are Mr.
Arnold and 11. Clark.5 Both of these officials are located at GPU's corporate offices in Parsippany, New Jersey, and therefore may not be available during the early phases of an anergency. Licensee acknowledges, however, that there are other officials who untld be well-qualified to serve as emergency support director until the arrival of lir. Arnold or Mr. Clark. Tr. 23, 039-40 (Rogan) . The Caumonwealth would not object to such substitution. Tr. 23, 016 (Dornsife) . Ibr would the IRC Staff, Tr. 22, 973-74 (Chesnut).
Previously, Mr. Rogan had identified four possible candidates for Fznergency. Support Director. These individuals all will receive the same training in making protective action reconmendations as all of the emergency directors. Tr.14, 784-85 (Rogan) . Mr. Chesnut had also testified earlier that the EDF Director function could be filled by any
" senior site or corporate manager who could arrive and who had knowledge j of the plant's procedures." Tr.15, 022 (Chesnut) . See also, Tr.
15, 024 (Grimes); Tr. 22, 969 (Chesnut); Tr. 22, 974 (Chesnut) (acceptability of F2nergency Directors as Emergency Support Directors). It is not clear why the insertion of one of these officials as an interim energency support director for purposes of making protective action recontendations during a three-hour period early into, an accident would be detrimental to public health and safety. ,
- 5. Mr. Arnold is the Chief Executive Officer of GPU Nuclear Corporation; Mr. Clark is his deputy. Arnold, ff. Tr. 11, 434, at 7-10, Figure 1.
1 In sun, Licensee has not tnet its burden of proof to deronstrate that its proposed alternative method of compliance with the requiranents of the emergency planning rule will provide an adequate interface for the forunlation and transmittal of protective action reconmendations to the state. The workability of Licensee's plan was not proven on the record of this proceeding; nor was it proven in a single drill or exercise. Consequently, the Board's ruling that Licensee failed to meet its burden of proof on this issue should be upheld.
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- II . THE LICEIBItU BOARD'S DECISION IS AW APPROPRIATE EXERCISE OF PSGUIATORY 00tTIROL OVER LICENSEE'S DIERGDCf RESPOtEE ORGAITIZATION IN A MATIER WIG IS CRITICAL TO PUBLIC HEALTH AND SAFETE.
Licensee argues in Part C of (and implies throughout) its brief that the Board's action is an impermissible, unwarranted, and unprecedented intrusion upon Licensee's " internal" manag ment decisions. Underlying this argment is the premise that only Licensee is substantially affected by, and hence has a right to determine the outcome of, the question of where protective action recommendations are made, and by whom. The very fact that the parties litigated this issue so extensively belies this l
assumption. In fact, the outcome of this question has a potentially significant effect on the approximately 135,000 individuals in the TMI-l plure exposure pathway mergency planning zone. Iabelling the key decisiomaking process to determine the appropriate manner of protecting
- the general population during a nuclear power plant mergency as an
" internal" decision, affecting no one but the Licensee, borders on the absurd.
It should be noted that the inadequacy of information flow to offsite response organizations, including BRP, was one of the major lessons learned from the TMI-2 accident. An investigation into l information flow during the V1I-2 accident, conducted by the IRC Office of Inspection and Enforcement, concluded that "information was not I
adequately transmitted to the Nuclear Regulatory Corruission or the l
l Bureau of Pzdiation Protection (BRP) ... The predominant factor was the absence of an effective onsite systen to accut:ulate, evaluate and diss minate information." Staff Ex. 5, at 10; see also id. at 10-11
! (Conclusions 1, 2, 4, and 8). In light of these conclusions, the Cormotteealth's concerns cannot be taken lightly.
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Tha Comorsmalth does not imply that either the IRC or the Camonwealth should intrude in Licensee's internal managenent decisions lightly. Miere the managenent decision in question, however, bears a direct and substantial relationship to the Comonwealth's ability to provide for the protection of public health and safety in the vicinity
-of a nuclear power plant, the intrusion is appropriate. Nor does the Ocxmonwealth believe that the intrusion here is particularly onerous.
Therefore, the Licensing Board's judgment constituted a necessary and appropriate exercise of the IRC's regulatory authority.
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III. CONCWSION For the foregoing reasons, Licensee's Exception No. 3 should be denied, and the Licensing Board's decision on this issue should be upheld.
Respectfully submitted, f~~) 1)( n C
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. j' ROBERT W. ADIER r Assistant Counsel Comonwealth of Pennsylvania May 10, 1982 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY 00t141SSION BEFORE 'IHE AlaIIC SAFETY AND LICENSING APPEAL BOARD In the Matter of:
FEIROPOLITAN EDISON OTIPANY, :
(Three Mile Island Nuclear : Docket Ib. 50-289 Station, Unit No. 1) : (Restart)
CERTIFICATE OF SERVICE This is to certify that the foregoing "Conmonwealth of Pennsylvania's Reply to licensee's Brief in Support of Exceptions to the ASLB Partial Initial Decision on Emergency Planning Issues (Exception No. 3)" was mailed to the persons on the attached service list this 10th day of May, 1982, by deposit in the U.S. mail, first class postage prepaid.
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C ITdBERTW.ADLER L .( g .m(., , [
Assistant Counsel '
Corm:nealth of Pennsylvania l
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UNITED STATES OF MERICA NUCLEAR REGUIEIORY OTHISSION BEFORE TIE COMISSION . .,
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In the Matter of:
IEIROPOLITAN EDISON C04PANY, ) ppa 20 W '23
) Doc No. 50-289 (Three Mile Island Nuclear ) (Restart)
Station, thit No.1) ) . sc
. imCH CERTIFICATE OF SERVICE I hereby certify that copies of the "Comonwalth of Pennsylvania's Brief Amicus Curiae in Support of Petition for Review of AIAB-698" wre served on the persons on the attached service list this 19th day of April, 1983. The Cmmissioners, the Licensee, and the Staff wre served by Express Mail. All other parties wre served by first class mail.
ROBERT W. ADLER Assistant Counsel I
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UNITED STATES OF MERICA NUCLEAR REGULATORY CTMISSION BEFORE THE C@ MISSION In the Matter of:
!EIBOPOLITAN EDISON COMPMN, )
) Docket No. 50-289
' hree Mile Island Nuclear
. ) (Restart)
Station, Unit No. 1) )
SERVICE LIST Nunzio L. Palladino, Chainnan Ivan W. Smith, Esquire, Chairman U.S. Nuclear Regulatory Cmmission Atomic Safety and Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 John F. Ahearne, Conmissioner -
U.S. Nuclear Regulatory Conmission Dr. Walter H. Jordan Washington, D.C. 20555 Atomic Safety and Licensing Board Panel 881 West Outer Drive Thanns M. Roberts, Conmissioner Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Consission Washington, D.C. 20555 Dr. Linda W. Little Atomic Safety and Licensing Board Panel Victor Gilinsky, Conmissioner 5000 Hennitage Drive U.S. Nuclear Regulatory Conmission Raleigh, North Carolina 27612 Washington, D.C. 20555 George F. Trowbridge, Esquire James K. Asselstine, Conmissioner Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Cmmission 1800 M Street, N.W.
Washington, D.C. 20555 Washington, D.C. 20006 Judge Gary J. Edles, Chairman Joseph R. Gray Atomic Safety & Licensing Appeal Board Office of the Executive Legal Director U.S. Nuclear Regulatory Cmmission U.S. Nuclear Regulatory Cmmission Washington, D.C. 20555 Washington, D.C. 20555 Judge John H. Buck Ellyn R. Weiss Atomic Safety & Licensing Appeal Board Harmon & Weiss U.S. Nuclear Regulatory Cmmission 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Judge Reginald L. Gotchy Karin P. Sheldon, Esquire (PANE)'
Atomic Safety and Licensing Appeal Board Harmon & Weiss U.S. Nuclear Regulatory Camission 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Docketing and Service Section Henry D. Hukill, Vice-President Office of the Secretary .. GPU Nuclear Corporation U.S. Nuclear Regulatory Cmmission P. O. Box 480 Washington, D.C. 20555 Middletown, Pennsylvania 17057 1 .
Ms. Marjorie M. Aamodt R.D. #5 Coatesville, Pennsylvania 19320 AtERY/1MI PIRC 1037 Maclay Street Harrisburg, Pemsylvania 17103 Dr. Chauncey Kepford & Judith Johnsrud Fnvironmental Coalition on Ibclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Steven C. Sholly thion of Concerned Scientists 1346 Connecticut Avenue, N.W.
Dupont Circle Building, Suite 1101 Washington, D. C. 20036 Ms. Iouise Bradford 1MI Alert 315 Peffer Street Harrisburg, Pennsylvania 17102 John A. Levin, Esquire Assistant Counsel Pennsylvania Public Utility Conmission P. O. Box 3265 Harrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esquire Attorney for Newberry Township T.!!.I. Steering Conmittee 2320 tbrth Second Street Harrisburg, Pennsylvania 17110 l
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