ML19290E617

Second Set of Interrogatories Directed to State of Pa. Includes Questions Re Emergency Population Zone,State of PA & York County Evacuation plans,siren-warning Capabilities Defined in NUREG-0553 & Emergency Personnel Training

ML19290E617
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1980
From:	Bowers J ANTI-NUCLEAR GROUP REPRESENTING YORK
To:	PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML19290E615	List: ML19290E613 ML19290E616 ML19290E617 ML19290E618 ML19290E623
References
NUDOCS 8003140295
Download: ML19290E617 (6)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L i kbg '

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METROPOLITAN EDISON COMPANY 1 Docket No. 50-289 (Three } Ele Island , (Restart)

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QUESTIONS OF ANTI-NUCLEAR GROUPiREPRESENTING YORK (ANGRY) TO COMMONWEALTH OF PENNSYLVANIA (SECOND SET)

Intervener Anti-Nuclear Group Respresenting York (ANGRY) hereby requests the Commonwealth of Pennsylvania ta assist in the development of a full and adequate record in this proceeding by providing answers to the foibring questions. ANGRY further requests the Commonwealth to supplement its responses in accordance with the standards set forth at 10 CFR 2. 740 (e) (2) . Parentheses shall identify the matters from ANGRY's first set of interrogatories as to which the questions herein are in the nature of " follow-on" inquiries.

15. (2 (a)) . Do "NRC guidelines" include anything other than NUREGS 75/111 and 06547 If yes please identify. _.

16. (4). Has the Commonwealth conducted an independent assessment of the adequacy of the 10-mile EPZ apart from NUREG 03967 If yes attach associated documentation.

17. (5). Identify each individual " response option,"" protective action," and

" emergency response" that the Commonwealth considers to be "available" to it in the event of a nualcar accident.

a. For each such " response" identify the minimum " lead time" that the Commonwealth considers to be " adequate" for the implementation thereof.

. b. What does the Commonwealth mean by " variables in the situation?" Identify pre-cisely how each such " variable" may influence the times set forth in response to question #17(a).

18. (6(a)). Identify the NRC official who communicat6d the " advisory" uhich recommended the extension of emergency response capability to 20 miles from TMI.

a. What reason did NRC give the Commonwealth, either at the time of the accident or subsequently, for such recommendation?

b. When and under what circrmstances (by whom and for what reason (s)) was this recommendation withdrawn?

soosi n 2-9 5

19. (8(b)). Identify the FDAA official who made this agreement.

a. Was this agreement limited in duration to the TMI accident? Is it in effect at the present time?

b. Where are these ambulances stored when not in use in response to a nuclear accident?

20. (9). When and by what NRC official was the minimum "30-hour warning time" advisory communicated to the Cocronwealth,

a. Does the Commonwealth believe that at the time it was issued such an advisory had a reasonable basis in either logic or fact?

b. What is the basis for the Commonwealth's belief in the reasonableness of the use of a 5-hour time frame as a basis for emergency planning in light of the information in Table 2 of NUREG 03967

c. Attach copies of all NRC-to-Cocmonwealth and Commonw4alth-to-County communi-cations which discuss nuclear accident warning times.

d. (9 (A)) . In the course of assisting York:Cbunty in the preparation of its plan or of reviewing it did the Commonwealth ever inquire into the basis for the quoted conclusion? If yes what information was elicited by such inquiry? What judgment did the Commonwealth make on the ef fect of this conclusion on the pinn's adequacy?

reason (s) for the

21. (10). Explain the A41fference between York County's heavy dependance on spontaneous evacuation in its plan and Dauphin County's decision to seek mass care space sufficienti to house the entire population of the 20-mile risk zone.

a. To what extent is the reliance in the York County plan en the self-evacuation 6f over half of.the 20-mile at_ rink population a consequence of the unavailability of sufficient mass care capacity within the county combined with a desire to avoid the logistical and financial difficnities of an interstate evacuatica inte Maryland?

b. Uhat is.the Cocmonwealth's sourcc(s) of information regarding the cited "recent Canadian evacuation" and the "other disaster experiences?"

c. Does the Cocconwealth agree or disagree with the judgment of the FEMA report, Euacuation Planning in the TMI Accident, that York County's use of informal polling of local efficials and businesses as a guide to evacuation behavior was ;' questionable in its precision and risky to use"? (p. 91) Explain.

d. (10 (a)) . Does the Commonwealth agree or disagree with the FEMA report's figure of.31,000 for York County's total mass care capacity? Explain any disagreement.

e. Specify the section in the York County plan which provides for use of

" additional mass care facilities in adjacent counties."

f. In the course of assisting in the preparation of the York County plan or cf a review thereof Hhs any Commonwealth official confirmed the agreements of Frederick, Harford, Baltimore, and Carroll counties in Maryland to furnish overflow mass care space to York County? If not, uhat evidence is there that such agreements exist? ,

22. (12). Does the Cocconwealth agree or disagree with the following evaluation of the warning capability of sirens from NUREG 0553, p. II-64:

Major disadvantages include: 1) the difficulty of hearing in residences during the winter because of sound absorption and well-insulated houses and during the summer in homes sealed up and air-conditioned. . .

Explain any disagreement.

a. (12 (b)) . At present is there a notification system in place in the THI EPZ capable of satisfying the " design objectives" of Appendix 3 to NUREG 06547

b. Dces the Commonwealth have the means, financial or otherwise, for putting such a system into place?

c. Describe in detail any efforts currently underway to satisfy the notification requirements of NUREG 0654.

d. (12(c)). How many Old Order Amish reside within 15 miles of TMI? 20 lules?

e. Has the Cot =onwealth made a deterr.ination as to whether the presence of such concentrations of Old Order Amish constitutes a demographic characterist-it warranting departure from a uniformly circular 10-mile EPZ for TMI?

If yes, specify in detail the bases for such a determination. If no, does the Commonwealth intend to make such a determination?

f. (See below)

23. (13). Did the Commonwealth decline to quantify the criteria in factor #2 of its response because 1) such quantified criteria do not exist, ,2) the Cocmonwealth does not believe quantification of emergency response criteria is necessary, or 3) sone other reason?

a. What does the Cocmonwealth mean by the phrase "well underway }rior to expected plume arrival"? 25% of the population evacuated? 50%? 75%?

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b. Assuming average travel conditions, a 4 mile 4per hour plume travel speed, and the notification and travel times stated in response to interrogatory

1. 16, state the most probable emergency response choice for each hourly ir. crease in warsing time from 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to one day.

24. (14). To what extent .does th'e perceptien of, an "egpected Jiut not yet- realized -

hazard" capable of triggering a precautionary -evacuation depend m. upon the assessment of such nuclear powerplant status parameters as temperature and pressure?

b. Does the Commonwealth possess the expertise required for making such assessments?

If yes, state name(s) and agenc; affiliation.

c. What action would the Com=onwealth have taken at 8AM on March 28 if it had knownorbeeninformedthatsaty'tionconditionsinthereactorhadcaused core uncovery and substantial fuel cladding damage? At 2PM on March 2S?

d. In light of the findings of the NRC/TMI Special Inquiry Group that THI personnel " failed to properly diagnose basic plant information that was known to them" (Vol. 2, pt. 3, p.64) and provided inforcation to 22(f). What is the time required for the selection of an appropriate protective action after notification by the utility of a nuclear emergency? How was this time estimate derived?

off-site authorities that was "often colored by individual interpretations of plant status" (pt. 3, p. 126) "when the mere provision of instrument readings would likely have been more definitive and could have led to an earlier realization of the true plant status" (pt. 3, p. 153), what is the opinion of the Commonwealth as to the necessity or desirability of instrumen-tation providing remote readouts directly to the Cocmonwealth of effluent concentrations and essential plant parameters?

25. (16 (a)) . ANGRY repeats its request for specification of egress routes, road capacities, and anticipated traffic volumes,

a. What.is the "1970 census tract population"?

b. How does the increase in population over the ensuing ten years affect the time estimates given in response to interrogatory no.16?

c. (16 (b)) . Specify the sections of the Cocmonwealth and/or County plans which provide for the stationing of " wreckers and other devices" along evacus-tion egress routes.

26. (17). What does the Commonwealth understand the term " scenario" to mean in the context of the quoted section from the final report of the Kemeny Commission?

b. Identify specifically sections of 91ther Cocronwealth or County emergency response plans where any such scenarios may be found.

27. What determinations, if any, has the Commonwealth made as to the existence intheenvironssurrypdingTMIofconditionssuchasdemography, topography, land characteristics, access routes, and local jurisdictional boundaries that warrant departure from a circular EPZ defined uniformly by a 10-mile radius from the plant? If none, does the Ccenenwealth intend to address this question?

a. Does the Commonwealth agree or disagree with the following conclusion reached by the NRC/TMI Special Inquiry Group (Vol.1, p.133):

Therefore, at the very least, significant centers of population beyond 10 miles from the plant must be considered in the planning as well.

Explain the reasons for any disagreement. If there is agreement, explain with reference to specific sections of Conmonwealth or County plans how this conclusion has been incorporated into emergency planning around TMI.

28. Identify the PEMA official (s) who assisted York County in extending its emergency response capability to 20 miles during tue TEE accident.

a. Did such officials concur in the routing provisions of the York County plan which, according to the FEMA report (p.100) would have resulted in the case of a 20-mile evacuation in "a major traffic problem" and in " people from one part of the county moving toward the hazard before moving away from it"?

29. What is the Commonwealth's position with regard to the need for prior arrange-ments for special deliver es of gesoline to service stations along evacuation routes?

a. If such arrangements presently exist provide details with reference to specific portions of Commonwealth or County plans which make provision therefor.

30. Identify the steps, if any, tho.concenwealth has taken to resolve each of the eight " recommendations" listed at pp. 14 and 15 of the "After Action Reoort" of the Pennsylvania National Guard, dated June 7, 1979.

31. Has the " guidance for the agricultural community in dealing with emergency nuclear incidents" called for in Section IX(A)(4)(g) of Annex E of the Commen-wealth D0P been " developed"? If so, where is it to be found? Identify the methods of connunication of such " guidance" that 1) have been effectively implemented, 2) have been developed but not implemented, and 3) remain to be developed.

32. In -ht of the provision of the Pennsylvania Emergency Management Services Code (35 Pa. C.S. 7101 et,. seq.) (EMSC) stating that " direction of disaster emergency canagecent services is the responsibility of the lowest level of government affected" (EMSC j7504(a)), is it the Commonwealth's position that effective emergency response capability for TMI depends upon the existence of local governmental emergency reponse organizations and plans which satisfy the standards therefor in the EMSC7 Discuss any respects as to which the Commonwealth does not subscribe to this position.

33. For each local governmental unit (township. borough, city, etc.) within a 10-mile radius of TMI provide the following information:

a. Whether or not a " local emergency management organization"(EMSC 7501(a))

which satifies the Cocconwealth's criteria therefor presently exists.

(1) Specify in detail the standards and criteria the Commonwealth employs in evaluating the adequacy of local emergency canagement organizations

b. The identity of the " local coordinator" (EMSC Q7502( .)) .

c. The qualifications of each " local coordinator" (EMSC 7502 (d)) .

(1) Specify in detail the Commonwealth's standards and criteria for local coordinator qualifications.

d. Whether the local coordinator has cocpleted in-service training in accordance with EMSC 7502(e).

(1) Describe in detail the Commonwealth's " career development program."

e. Whether or not a " disaster emergency canagement plan" (EMSC 7503(1))

which satisfies the Commonwealth's criteria therefor presently exists.

(1) Describe in detail the Commonwealth's standards and criteria for the adequacy of local disaster energency management plans.

f. Whether or not an "ezergency operations center" (EMSC 7503(2)) which satisfies the Commonwealth's standards and criteria therefor presently exists.

(1) State the location of each such local "EOC."

(2) Describe in detail the Commonwealth's standards and criteria for assessing the adequacy of local E0C's.

g. Whether or not "organisational and individual training programs" (EMSC 7503(3))

which satisfy the Commonwealth's criteria therefor presently exist, (1) Describe in detail the Commonwealth's standards and criteria for assessing the adequacy of local training programs.

h. Whether aufficient efforts have been undertaken to procure "all locally available nanpower, materials, supplies, equipment, facilitics and services necessary for

... emergency... response..." (EMSC Q7503(4)).

34. For each of the five "at risk" counties describe the communications system presently in effect between the county emergency operations center and local EOC's.

a. Describe the estent to which any sach system is not operable (i.e., local contact not available) on a 24-hour basis,

b. What is the Commonwealth's position as to the adequacy of these systems.

35. Provide copies of any " unmet needa" listing furnished to the Commonwealth by any "at risk" county since the TMI accident pursuant to Annex E gIX(B)(1)(x).

36. The NRC/TMI Special Inquiry Group concluded that:

Only an offsite, real-time-detector system could have provided the confirmation of offsite e::posure rates at a relatively inac-cessible location such as Goldsboro within the 10-15 minutes that the Board considered (Vol. 2, pt. 2, p. 173).

It further recommended that "real-time online radiation monitoring equipment should be installed around all nuclear powerplants" (pt. 2, p. 95).

Does the Commonwealth agree or disagree with this recommendation? Explain fully the reasons for any disagreement.

37. Do the high schools with pick-up routes for areas within 10 miles of TMI in York County own their own bus fleets or do they employ bus' fleets owned by outside contractors?

a. Identify each such outside contractor.

b. What assurance is there from each such contractor that its fleet with drivers will be available to fulfill the requirements of Annex VII of the York County plan?

38. What method does PEMA e= ploy to notify its off-duty officials of a nuclear emergency?

a. Should similar methods be adopted by county and local governmental units?

35. What is the time required for the removal of seats from the 30 buses Annex IV o'_ the York County plan indicates will be used to evacuate nursing home wheelchair patients?

Respectfully submitted, Anti-Nuclear Group Representing York By:

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% h+MJMF Qohn Bowers 245 U. Philadelphia St.

DATE: February 25, 1980 York, Pa. 17402