ML20114B554
| ML20114B554 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/25/1985 |
| From: | Trawbridge G, Trowbridge G GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC |
| References | |
| CON-#185-279 CLI-84-22, SP, NUDOCS 8501290317 | |
| Download: ML20114B554 (17) | |
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> =y UNITED STATES OF AMERICA b NUCLEAR REGULATORY COMMISSION - .
l500' BEFORE THE COMMISSION In the Matter of )
METROPOLITAN EDISON COMPANY Docket No. 50-289[,
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE'S RESPONSE TO AAMODT MOTION FOR RECONSIDERATION OF COMMISSION ORDER CLI-84-22 AND OPENING OF A HEARING On January 15, 1985, Norman and Marjorie Aamodt filed with the Commission a motion seeking among other things to reopen the TMI-l restart hearing.
As a basis for their motion, the Aamodts allege that "Li-censee personnel lied to the Commonwealth." They allege tha.t' TMI personnel discounted a 10 R/hr " projected release" at Goldsboro "by claiming, contrary to fact, that surveillance teams had been dispatched and verified that a significant re-lease had not occurred." Aamodt Motion at 4. This allegation is totally unfounded, as even the most cursory research would have indicated.
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D The Aamodts state the information came to their attention when "it was provided as the testimony of James (sic) Gamble."
Id. What the Aamodts are attempting to refer to is an early draft of a section of NUREG-0760, which was provided as an ex-hibit to the testimony of David Gamble in the remanded restart proceeding.1/ The draft addressed the reportability of an offsite exposure rate that had been predicted for Goldsboro on the day of the TMI accident. The draft was written before the NUREG-0760 investigators conducted any interview regarding this matter, and it summarized the evidence then in existence.2/
The draft of this section stated that a 10 R/hr dose rate for Goldsboro had been predicted by TMI personnel sometime be-fore 7:44 a.m. on March 28, 1979. At 7:46 a.m., an onsite mon-itoring team reported less than 1 mR/hr west of the Unit 2 re-actor building, and this measurement together with low containment pressure provided a basis for discounting the pre-diction. At about 8:30 a.m., the first offsite measurement was taken at Goldsboro. This measurement was also less than
-1/ Gamble, ff Tr. 30,522, exhibit 6. This exhibit to David Gamble's testimony was not admitted for the truth of its contents, but only to show that sections of NUREG-0760 had been drafted prior to the completion of interviews.
Tr. 30,502.
2/ The NUREG-0760 investigators had been instructed to rely, to the extent possible, on the evidence already developed in the NUREG-0600 investigation and elsewhere. See Gam-ble, ff Tr. 30,522, exhibit 2.
b 1 mR/hr. These draft findings were all ultimately incorporated into the final version of NUREG-0760. See NUREG-0760 at 31-32.
The draft, however, also referred to a May 3, 1979 I&E in-terview of Thomas Gerusky, the Director of the Pennsylvania Bu-reau of Radiation Protection. That interview suggested that the Commonwealth had been informed before 8:00 a.m. that a mea-surement of less than 1 mR/hr had been taken at Goldsboro. See Aamodt Motion, attachment 4 at 15, quoting NRC Interview of Thomas Gerusky (May 3, 1979) at 14. The NUREG-0760 investiga-tors then reinterviewed Mr. Gerusky and explored this inconsis-tency. Mr. Gerusky told the NUREG-0760 investigators that the Commonwealth had been informed of the Goldsboro dose rate pre-diction and of the onsite measurement before 8:00 a.m., but it was in fact about an hour later that an actual measurement at Goldsboro was reported to the Commonwealth -- a fact evidenced by the PEMA telephone log. NRC Interview of Thomas Geruaky (October 1, 1980) at 33-41 (attached). Not surprisingly, therefore, the portion of the NUREG-0760 draft which relied on Mr. Gerusky's first interview was not included in the final re-port. See NUREG-0760 at 31-33.
It is evident, therefore, that there is neither new nor significant information concerning the Goldsboro dose rate pre-diction. The statements which might have appeared at one time to provide a basis for the Aamodt's contention -- Mr. Gerusky's i
1979 interview -- have long since been publicly clarified by Mr. Gerusky himself.
The Aamodt's motion to reopen the hearing should be de-nied.
Respectfully submitted, SHAW, PITTMAN, FOTTS & TROWBRIDGE
/ Mr /
yorge/F.'Trowbridge,[.C.
David R. Lewis /
Counsel for Licensee Dated: January 25, 1985
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ATTACHMENT l
1 UNITED STATES OF AMERICA 2.
(E7 2 NUCLEAR REGULATORY COMMISSION 3 --------------------x k .. 4 In the matter of: :
e 5 METROPOLITAN EDISON COMPANY :
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(Three Mile Island, Unit 2) :
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2 7 - - - - - - - - - - - - - - - - - - - -x s
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8 Room 202, Federal Building 3 228 Walnut Street d 9 Harrisburg, Pennsylvania I
E 10 Wednesday, October 1, 1980
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- 5 12 INTERVIEW OF THOMAS GERUSKY z
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- E 13 was commenced at 1:30 p.m.
E 14 APPEARANCES: '
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'2 15 NORMAN MOSELEY, U.S. Nuclear Regulatory Commission, s ~
Office of Inspection & Enforcement.
16
$ JOHN CRAIG, U.S. Nuclear Regulatory Commission, g 17 i Office of Inspection & Enforcement.
5 I E 18 TERRY HARPSTER, U.S. Nuclear Regulatory Commission, 2 Office of Inspection & Enforcement.
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19 l 1 M l DAVID GAMELE, U.S. Nuclear Regulatory Commission, 20 Office of Inspector & Auditor.
21 RICHARD HOEFLING, ESQ. , U.S. Nuclear Regulatory Commission, Office of Executive Legal Director.
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33 1 Q Now you have testified to others, and in fact I
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2 notice on your note sheet of your knowledge of the 10-R per hour 3 prediction in Goldsboro --
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IM,E A That's what they gave us.
4
-e 5 Q Are there other records, notes, or reports or 5
6 accumulated recollections, any of those things, that might
{ 7 / contain additional information concerning --
.3 j 8- A That particular --
d n 9 0 -- that particular -- tar instance, that we could use 10 to nail down more precisely the time in which you received 5
.j 11 that information. Did you personally receive that?
m y .12 A I think it was on the speaker phone. If I wrote it h .=h 13 !
l down, I receivad it one way or the other, either on the speaker l 14 phone or direct phone. Margaret Reilly was there, and she
' 15 went to get the maps to start her plot of the wind direction, E
[ y' 16 wind speed, and she -- so we both received the information, I si
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believe, over the speaker phone.
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li 18- Q Do you recall what was told you -- what specifically i =
19 was told you which caused you to no longer give any credibility E
20 to the 10-R per hour reading? I'm talking about surveys. What 1
21 surveys were made, for instance?
ed- 22 A Yeah, we were told that there were no onsite readings tjs:
23 j of any consequence, in that wind direction. We were also told
_24 that the containment pressure was still very, very low, and 25 that this was designed -- that the calculation he was using was l
ALDERSON REPORTING COMPANY. INC.
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, l 34 1 designed for containment -- for containment design pressure,
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W 2 instead of what the pressure really was. So the explanation 3 that went along with this was that if we are following procedure:
.$ 4 our procedure says if it's reading 800-R per hour at the deme e 5 monitor, this is what the dose rate downwind would be at design W .
l j 6 lead pressure. However, it's not at design lead pressure, so 7 these numbers aren't real. However, we aren't going to take any-A g 8 chances. We are going to send a team over to check it out, tJ d 9 and then we notify PEl4A or Civil Defense to be prepared to 10 evacuate people on the west shore.
a j 11 BY MR. GAMBLE:
y 12 Q Fas this all told to you at the same time you received Ah 2 13 the first report?
w g l 14 A No.
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j 16 A ch, as we were -- as we were told that they were going m
g 17 to a general emergency, and I' recall Dick -- I think -- I'm sure h 18 it was Dick Dubeal on the phone talking to both Maggie and me,
.E 19 saying what the dome monitor reading was, and he was having X
20 the calculations performed at the point. It may have taken a 21 few minutes, but we also -- he also informed us of the pressure, gg 22 what the pressure was in the containment building, and that it
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23 ! had not increased significantly, and it was nowhere near design J;- 24 l pressure, so he wouldn't have expected these numbers to be over.
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25 , Q So let me make sure I understand it. It is in this l
- ALDERSON REPORTING COMPANY. INC.
l 35 1 order. First you learned about the dome monitor reading, and th<
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2 as they were performing the calculations, he talked about the 3 pressure and those things, and then at the tail end of that 1=:.
(iSF 4 conversation, you got the calculated reading. Is that the order:
e 5 i A That's about what I remember.
j 6 Q All within this general conversation?
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& 7- A Yes. And I was asking questions while all this was M
j 8 going on, Maggie was asking questions. "Do you have any people d
d 9 over there now monitoring?" "No, we are starting to and people h 10 over."
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g 11 I was under the impression they were going to go over a
j 12 by helicopter, for some unknown reason. I don' t believe they
- E dj) y 13 went over by helicopter. I thought there was a helicopter there
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[ 14 I and they were going over by helicopter and get the readings.
2 ' 15 They got the readings very quickly. At least the time was going g 16 by so darned fast. When we got the word back that they didn't w
d 17 have any detectable activity over there, it apparently was a lot
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M 18 longer period of time than I had anticipated, early on, anyway.
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$ 19 BY MR. MOSELEY:
M 20 Q So there was action taken to notify PEMA af ter the 21 first prediction?
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22 A Yes.
23 ! Q And then some time elapsed before pEMA was called back 1
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24 l and said --
25 A Yes, they have in their logs what that time was, and 4
3 ALDERSON REPORTING COMPANY. INC.
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36 I it appeared to be like an hour or scmething. But I don't L (W.Ei 2 remember.
t 3 BY MR. GAMBLE:
! Ei j (i? 4 Q And was it the reading on the other side of the river
. 5 that precipitated this second call to PEMA?
5 j' 6 l A Yes.
7- Q It wasn't an onsite reading, it was the actual reading A
- jl 8 A No, it was the actual reading from across the river d
n 9 saying they had found no detectable radiation across the river I
E 10 in Goldsboro or down in the general vicinity.
5 11 BY MR. CRAIG:
B y 12 Q Did you say earlier that --
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! !s; : 13 A Excuse me. We told PEMA to be prepared to evacuate 3
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p j 14 to warn York County to be prepared to evacuate people, but not l- k 2 15 to evacuate.
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g 16 Q Did you say earlier you were told that the calculatios t d i 17 was for design pressure, but it was less than that, and they has a
l l 18 an onsite reading?
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( 19 A No, that they didn't have onsite readings. They L
M 20 had onsite reading that indicated no leaks.
21 Q They told you that?
(.5h 22 A Yes, the people inside had detected no airborne 23 ! radioactivity.
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C= 24 Q Did they associate that with the 10-R per hour dose i
25 ; projection in Goldsboro?
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37 1 A Yes. 3 2 Q To say that, "We don' t really think it's real, 3 because"?
O Si? 4 A Well, it's a combination of our saying that, and 5 they' re saying, " Yeah, we know. " I don't know who said it first, j 6 . but they agreed they didn't believe that it was a real reading
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{ 7- in Goldsboro. We said, "Let's not take any chances, let's 4 get prepared just in case."
rJ d 9 Q But based on an onsite reading, that was part of the 10 basis 'for not believing: that?
j 11 A -That. and the very low pressure in containment..
B g 12 Q okay.
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. g ' 13 BY MR. MOSELEY:
14 Q Let me make sure - I'm not sure that I'm not confused!
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' 15 16 and I don't want to leave it unclear on the record. Let me tell you what my perception is from other testimony, and you can-L ., 88 17- correct me.
E 14 My perception is that first call indicated there E
19 was this 10-R per hour, but there was some reason to question X
20 the validity.
-21 A It was a calculated reading based upon -- a
.im 22 calculated dose rate based upon pre-planned offsite accident
- y 23 , r.easurements, using windspeed direction, chi over Q and so J
(6;; 24 forth.
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Q Okay. And then it's my understanding that that result!
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ALDERSON REPORTING COMPANY. INC.
4 38 g in the call to PEMA.'
k! 2 A Right.
3 Q And then at some --
(h 4 A We called PEMA.
. 5 Q You called PEKA, and then at some time later the l 6 surveys were made onsite?
f7 A No, no. The surveys had been made -- were bein'g made
[ 8 onsite at the time that call was --
O g 9 Q But you didn't have the results?
10 A Yes, we had results that they were not able to detect E
l3 11 any activity on the island itself.
J 12 Q And you had that information at the same time you were N
22i 3 13 told of the projection?
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E 14 A Yes.
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2 ' 15 Q Not some minutes later?
j 16 A No. Not before -- we had that information before w
g 17 we called PEMA, because when we called PEMA, we really didn't y -
k 18 believe there was any need to evacuate anybody, based upon 5
, 19 the onsite readings and based upon the pressure in the contain-M 20 ment.
21 Q Then subsequently readings were taken across the (ga. . 22 river which confirmed this discounting or, let's say, hesitancy s..
23 to believe anything in the first place s is that correct?
24I A That's right. And we received the information from I:==
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T.4 25 Met Ed that there were no -- that they detected no radioactivity 1
ALDERSON REPORTING COMPANY. INC.
r 39 1 in Goldsboro.
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%EF 2 BY MR. GAMBLE:
3 Q Can you tell from your notes, can you put some kind E=.
%QP 4 of finger on the time this would have occurred? Your notes e 5 started' at 0730.
b j 6 A It's probably in the letter.
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$ 7 BY MR. MOSELEY:
2 l 8 Q Maybe I can give it to you. You might can find it d
d 9 quicker.
10 A No, it was after 7:30. It's a feeling, and I really 3
5 11 haven't tried to verify it one way or the other to determine E
c 12 what these times were in the past year and a half, because I 3
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_ 13 didn't think it was that important, but I have a feeling it j 14 happened some time between 7:30 and 8:00 o' clock. I believe c
2 ' 15 'it was before Dornsife arrived, and it was after Reilly got N
- g 16 there, so Reilly got there about 7:30, and then Bill came in as w
g 17 we were doing things, and he was getting updated. I don't E
18 think h'e was there when we were doing that, but I'm not positive F' -
, 19 You know, the timeframe we -- it was prior to the office opening a
20 up, and there was a meeting going on of all the department over 21 at some place in another building. We were sending people over
. 22 to get them, to bring the secretary back, and to keep -- you 23 , know , try to inform as many people as possible, and to get our
, r-24 staff back from the staff meeting that was being held.
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25 , There was an awful lot of information, a lot of I
l l ALDERSON REPORTING COMPANY. INC.
. 40 1 activity going on in our office at the time. So time went by s=.
W# 2 awful f ast. I don' t remember eating that whole day. I wasn't 3 even hungry. I lost about 10 pounds during the first three 4 weeks. I didn't eat much.
g 5 Q During the day, didn't you have a secretary manning ii j 6 the phone, the direct line between your office and the site?
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7: A We had secretaries manning the phone at some times j 8 during the next -- during the first three weeks of the accident, d
d 9 but I don't believe we had a secretary on the phone during the Y
g 10 first day. We may have had a secretary on the phone just holdinc
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11 it until somebody came on, and then he would be given to somebod:
y 12 else for information, but the secretary would not have received 13 information during that first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
5 l 14 Q Okay. I was trying to get at maybe she took some t ' 15 notes.
E g 16 A No, not as far as I know. When we realized that the w
17 accident was extending out, we started worrying about 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> h 18 duty, who was going to cover, and we had girls from other E
g 19 offices coming in and just sitting by the phone, waiting for a
20 someone, and if there was a need from the utility side for them 21 to talk to somebody else, she would come and get us. If not, 22 she would just take down some information, and that's it. An 23 . ,
awful lot of the survey data was recorded that way.
.z- 24 Q But your belief now was this was after March 287 tr.
25i A That we had a secretary who was taking down informatio:
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. 41
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1 O Yes.
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- b. 2 A Yes. I think --
3 BY MR. GAMBLE:
- k. 4 Q Mr. Gerusky, during the time interval from when you
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g 5 received the calculated dose rate of 10-R per hour, and when R
j 6 you received the actual Goldsboro other-side-of-the-river R
R 7 measurements that caused everyone to discount the calculated l 8 reading, was there any other information passed during that d
d 9 time, any other onsite measurements or any other kind of infor 0
@ 10 tion which would tend to discount the original reading?
E i g i1 A I don't remember. I know that we were not very -- we a
j 12 didn't really believe that evacuation would have to take place.
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, 13 I don' t think the're was any time in there we felt we would have l 14 t o evacuate people. We just didn't want to take any chances,
'15 even, until that reading came back.
g' 16 BY MR. HOEFLING vi d 17 Q And how long was that, again?
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18 A I don't know. I think in reconstructing it, or at (Ci E
19 least the telephone -- the PEMA telephone duty log indicated R
20 it may have been an hour, which surprised me a little bit the 21 first time I heard that, six months ago at another one of these g; 22 briefings.
n::p 23 , BY MR. MOSELEY:
24 0 Going back, I have one more specific period to touch 25 , on, as we have done in others. George Kunder, who is the utilit i
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l i ALDERSON REPORTING COMPANY, INC.
I
January 25, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Aamodt Motion for Reconsideration of Commission Order CLI-84-22 and Opening'of a Hearing," dated January 25, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 25th day of January, 1985.
Avu _ WM' /
agforge/F.Trowbridge,P .
Dated: January 25, 1985
a i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart Remand (Three Mile Island Nuclear ) en Management)
Station, Unit No. 1) )
SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M. Roberts, Commissioner Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Gary J. Edles James K. Asselstine, Commissioner Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 John H. Buck Atomic Safety and Licensing Lando W. Zeck, Jr., Commissioner Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Ivan W. Smith Christine N. Kohl Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Docketing and Service Section (3)
Sheldon J. Wolfe Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
SERVICE LIST PAGE 2 Atomic Safety and Licensing Mr. Henry D. Hukill Board Panel Vice President U.S. Nuclear Regulatory Commission GPU Nuclear Corporation Washington, D.C. 20555 P. O. Box 480 Middletown, PA. 17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt U.S. Nuclear Regulatory Commission R. D. 5 Washington, D.C. 20555 Coatesville, PA. 19320 Jack R. Goldberg, Esquire Mrs. Louise Bradford Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C. 20555 Harrisburg, PA. 17102 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C. 20002 505 Executive House P. O. Box 2357 Lynne Bernabei, Esquire Harrisburg, PA. 17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C. 20036 1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Michael W. Maupin, Esquire 2001 S Street, N.W., #430 Hunton & Williams Washington, D.C. 20009 707 East Main Street P. O. Box 1535 William T. Russell Richmond, VA 23212 Deputy Director, Division of Human Factors Safety Office of NRR Mail Stop AR 5200 U.S. Nuclear Regulatory Commission Washington, D.C. 20555