ML20003B223: Difference between revisions
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6III G Public education (County plans) 6tes now Off SIII M County-plan assumptions dropped off .' | 6III G Public education (County plans) 6tes now Off SIII M County-plan assumptions dropped off .' | ||
Notes | Notes | ||
* Kr. Zahler objected to these contentions on Dec. 19 drop now --- means that ANGRY does nel seek this contention dropped--- means that Mr. Sholly dropped this contention accepted--- means that Board granted ANGRY this contention Jan 27 keep--- meane that ANGRY wishes to adopt this contention exchange--- (Sh 8I R) ANGRY wishes to " exchange" this for similar ANGRY contention nct as well worded. ANGRY will drop ANGRY IIIae if permitted to adopt Sh 8I R Off----means an "off-site contention (f.'.r. Gray's list) | * Kr. Zahler objected to these contentions on Dec. 19 drop now --- means that ANGRY does nel seek this contention dropped--- means that Mr. Sholly dropped this contention accepted--- means that Board granted ANGRY this contention Jan 27 keep--- meane that ANGRY wishes to adopt this contention exchange--- (Sh 8I R) ANGRY wishes to " exchange" this for similar ANGRY contention nct as well worded. ANGRY will drop ANGRY IIIae if permitted to adopt Sh 8I R Off----means an "off-site contention (f.'.r. Gray's list) | ||
On--- r.eans an "cn-site" contention (5'r. Gray's list) | On--- r.eans an "cn-site" contention (5'r. Gray's list) | ||
| Line 157: | Line 156: | ||
include contingency plans and procedures for coping with ? | include contingency plans and procedures for coping with ? | ||
this eventuality. This is especially important within the context of the time a$ 1able for implementing pro-tective actions in the Plume Exposure EPZ; this was recognized in NUREG-0396 at page 19 where it is stated ' | this eventuality. This is especially important within the context of the time a$ 1able for implementing pro-tective actions in the Plume Exposure EPZ; this was recognized in NUREG-0396 at page 19 where it is stated ' | ||
that the time available for action is "strongly related" ; | that the time available for action is "strongly related" ; | ||
f to the time consumed in notification. Notification can-not commence until an emergency is recognized and de- | f to the time consumed in notification. Notification can-not commence until an emergency is recognized and de- | ||
| Line 171: | Line 169: | ||
None of these assumptions is justified in the Annex E plan. Number 1 is not justified in any manner and if it is to be retained and relied upon as a planning basis, must be supported with agreements which specify what assistance is available, from whom it is available, and under what conditions is it available. Numbers 2 and 3 relate to planning assumptions for host counties and are without basis; reliance on these two assumptions, if they are incorrect, could lead to significant problems in host centers. | None of these assumptions is justified in the Annex E plan. Number 1 is not justified in any manner and if it is to be retained and relied upon as a planning basis, must be supported with agreements which specify what assistance is available, from whom it is available, and under what conditions is it available. Numbers 2 and 3 relate to planning assumptions for host counties and are without basis; reliance on these two assumptions, if they are incorrect, could lead to significant problems in host centers. | ||
l *0FF-SITE's* p:ga 2 (D) Evacuation routes and time estimates for TMI-l do not SEcllY reflect possible impediments to egrest routes, such as e II 3 rush hour traffic, inclement weather, or seascnal changes in traf fic flow (caused, for instance, by the State Farm Show or similar function, or by tourist l | l *0FF-SITE's* p:ga 2 (D) Evacuation routes and time estimates for TMI-l do not SEcllY reflect possible impediments to egrest routes, such as e II 3 rush hour traffic, inclement weather, or seascnal changes in traf fic flow (caused, for instance, by the State Farm Show or similar function, or by tourist l | ||
traffic). | traffic). | ||
| Line 277: | Line 274: | ||
Sho11y 8(I)(h) | Sho11y 8(I)(h) | ||
O D | O D | ||
j | j | ||
: 4. Logistics . ! | : 4. Logistics . ! | ||
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J 5000'Heilnitage" Drive j '.9??''YDauphiii' County.: Courthouse - O '..%'s'q | J 5000'Heilnitage" Drive j '.9??''YDauphiii' County.: Courthouse - O '..%'s'q | ||
't Raleigh',. North | 't Raleigh',. North | ||
* Carclina .27612 Frontiand Market' Streets- | * Carclina .27612 Frontiand Market' Streets-James R. Tourtellette, | ||
James R. Tourtellette, | |||
. Harrisburg, Pennsyl.vania 17101 - @( | . Harrisburg, Pennsyl.vania 17101 - @( | ||
. c f.s Esquire (4) ..Nalter.'W. Cohen, Esquire iM ; | . c f.s Esquire (4) ..Nalter.'W. Cohen, Esquire iM ; | ||
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{ . .c_ | { . .c_ | ||
. .- - 3 ' | . .- - 3 ' | ||
a Jordan D. Cunningham, Esquire- ". Harmon.6 William S. Jordan, III, Esquire .:- , | a Jordan D. Cunningham, Esquire- ". Harmon.6 William S. Jordan, III, Esquire .:- , | ||
Foxi Farr & Cunningham $ | Foxi Farr & Cunningham $ | ||
| Line 611: | Line 604: | ||
, 245 West Philadelphia' Street l Coatesville,. Pennsylvania 19320 York, Pennsylvania 17404 - | , 245 West Philadelphia' Street l Coatesville,. Pennsylvania 19320 York, Pennsylvania 17404 - | ||
?.*- | ?.*- | ||
A VAttorney. General of.New Jersey John' F. Ahearne-9 Attentions : Thomas J. Germine, Esq. d | A VAttorney. General of.New Jersey John' F. Ahearne-9 Attentions : Thomas J. Germine, Esq. d | ||
' Deputy Attorney General Chairman . | ' Deputy Attorney General Chairman . | ||
| Line 636: | Line 628: | ||
'. \ | '. \ | ||
lb \ | lb \ | ||
.4 L | .4 L | ||
.- . ~ ;;. .. . | .- . ~ ;;. .. . | ||
' l | ' l | ||
Revision as of 00:21, 18 February 2020
| ML20003B223 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/05/1981 |
| From: | Bradford G ANTI-NUCLEAR GROUP REPRESENTING YORK |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8102100529 | |
| Download: ML20003B223 (21) | |
Text
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.[ lj/ 3 ANGRY Q ,
N Lh N UNITED STATES OF A!GRICA ,
@5 D N ISSI m bUCLEAR REGULATORY C0!G!ISSION fh #~
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$$$R HI ATOMIC SAFETY AND LICENSTNG E0ARD U :' ~
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DOCKET 50-2 Metopolitan Edison Co. ', TMI-1 ANGRY REQUEST FOR RECONSIDERATION ON ANGRY ! ACTION TO ADOPT E!*.ERGENCY PLANNING CONTENTIONS AEANDCMED BY ?.*R S:-:CLLY Intervenor Anti-Nuclear Group Representing York moves to adept the following contentions of Mr. Sholly which he abandoned: BI F. 8I G. 8I J. (all "on-site" in I'.r. Gray's list): FII B. BII D. BII G. BIII A. BIII E. EIII F. (all "off-site" in Mr. Gray's list) and. ANG:Y noves to adopt f.*r. Sholly's 8I R (off-site) "in exchange" for a similar contention. ANGRY III (a)(e). If ANGRY is not granted Mr. Sho11y's 8I R. ANGRY do:s not wish to drop ANGRY III (a)(e), and conversely. ANGRY will drop III(a)(e) if allowed to adopt Mr. Shelly's contention 8I R. ANGRY considers Mr. Sholly's BI R more litigable and specific the concern is excetly the same. I The Contentions Mr. Sholly's contentions that we wish to adopt are appended. I ANGRY assures the board that none of the Sholly contentions are duplicated in ANGRY contentions (except as noted above-- BI R). At the Emergency Planning meeting amoung intervenors on Dec. 19, 1980 Mr. Zahler, counsel for licensee, presented a table of contentions indicating which contentions he requested intervenors dror (enclosed). Mr. 7.ahler verbally went through all contentions listing his reasons for asking intervenors to consider dropping contentions. These reasons were 1) duplicated in another party's conterntion. 2) duplicated in reference to another county or state agency, and 3) contention "too specified" reiterating same point in a series of examples or l contention too long. Mr. Zahler's objections to 4 holly contentions are indicated on the enclosed chart of Shelly contentions by '. In all, he objected tc 66 contentions: six of Sholly's 17 of ANGRY's, and 43 of Newberry's. l 3 g , a n oo S.Tf- g p sos*b l
. . . =
j . Of the six Sholly contentions Mr. Zahler found one (8I E) to be not as litigable as ANGRY IIIa j. This contention (8I I) we are not requesting the Board to allow us to adopt. Another Sholly contention. SII A, on the 10-mile EPZ concept. Mr. Zahler found repetitive of the ANGRY /3 holly contention BI B ("old Sholly 8C') and ANGRY will not press the point of the distinctinn and will not ask to adopt that one. Of the remaining four Sholly contentions Mr. Zahler found inferior to. .or repetitive of, other contentions, all were conpared to Newberry contentins. ANGRY is asking to adopt all four of these that Mr. Zahler asked Sholly to drop on Dec. 19 Intervenor Censolidation Problems Early on in this hearing the Eoard asked Intervenors to consol- ' idate on issues as much as possible. We have tried. Consolidations i have, perhaps, simplified issues but intervenors have suffered because i of it, and more important the record has suffered. As an example, the Board denied ANGRY's " Class 9" contention and allowed us to adopt UCS 13 L'a d i d . For their own reasons (which we understand) UCS finally decided not to be present for " Class 9" ' testimony. ANGRY counted on UCS and was very disappointed to find out at a very late date that UCS could not litigate " Class 9" to ANGRY's satisfaction. Can the Board assure, positively, that Newberry will litigate : ANGRY's concerns to ANGRY's satisfaction? Is the Board sure that Newberry will not have to drop out for financial reasons as so many parties have? We think not. ANGRY isn't willing to risk it. ANGRY arranged with Mr. Sholly a year ago that he would concen-trate in some areas, we in others. We did this at the Board's request. The. Board will find that we have few overlaps and have worked tocether to form " joint" contentions. Now, Mr. Sholly has found that he is not able to litigate his Emergency Plinning Contentions. We are arain very disappointed. We would have ' staked out" more Emergency i Planning " turf" when filing reconsiderations had we not known tha. Mr. Sholly was " covering" areas. We chose to not duplicate his efforts at the Board's request. ANGRY and Newberry do have overlapping concerns, the difference. 2 l
l l l which may not be evident from the contentions, is that we have dif- l 1 ferent viewpoints on how to litigate our concerns. l We doubt that "even without any intervenor contentions, a full and complete record on emergency planning matters will be developed" as Mr. Zahler asserted in his objection of 1/19/81. Intervenors have special expertise unavailable to any other party: we live here, and we know the area. The record needs our help. Even today Mr. Gra" tells us FEMA is still not ready on some of the off-site study. Timeliness ANGRY agreed with Mr. Zahler to present a report o.~. Emergency l Planning by Jan. 9 We reported on Jan 8 and offered to present a finalized cross-referenced full version of surviving contentions divided by issues and by on-site /off-site. We studied carefully to see if we could drop any contentions. ANGRY decided not to drop more than two: ANGRY III (b)(h).3: and ANGRY III lb)(k). (Both content-ions relate to the Commonwealth's plans and we are satisfied on both counts.) Then we got into trouble. We moved orally to adopt Sholly 8-9 . contentions that survived. ile should have provided the Board with more information and' specifics. Cn January 19 the Licensee responded. 'le
.- don't mean to be too picky, but that response was after the ten-day response period. .. e were not served a copy until 2pm on Jan 27. and we do mean to be picky about that. The Licensee has been lax several times now about getting ;
services to ANGRY in time. Mr. Zahler may have been " busy" and unable to answer sooner, we all understand that. However we must ! insist that the Licensee is the one party not entitled to an,y excuses by way of lateness. They insist on this brutal pace the hearings barrel along at. They must be prompt. ANGRY brought our procedural concern about the Board's Ja 27 ruling to the Board's notice as soon as possible. We were not able to see the Jan 8 transcript in Washington, w'cere ANGRY's representative * . was until January 30 when it was available at the PDR at 1717 H 5t. ANGRY's representative looked for the transcript there on Jan 29 - It was not yet shelved and available. 'ie brought our concern to the Board's attention Feb 3 which was[the next day of hearings.
~
3 9
The Staff had no objections to ANGRY's adoption of the curviving 3 holly 8-9 contentions. We asked Mr. Tourte11otte for procedurai > advice as soon as we realized what our procedural problem was and found the transcript reference. he said that filing a motion fer reconsideration of the Board's Jan 27 ruling might be ir. order. We said we would do that. That was on Jan 29 So. between Jan 3 and now the Staff has only had two days when the Shelly conter. tier.s were not "in limbo." All of these contentions were filed lart September and are not new to parties. We're sorry if the Jtaff was put off schedule on the three on-site contentions we want to adert. ' These three on-site contentier.s relate to two subjects. The
- first is the letters of agreement the Licensee has with off-site sfoncies to provide services to Net-Ed employees and to the Island in the event of an emerrency. These two contentions (8I F. BIO.
are a pair that set forth the concern and very cpecific failinre of the Licensee's letter of agreement. ANGRY has a similar sort of contention (which covers letters of arreement between York County I and supportinc services) and we were extensively cross-exanir.ed or. it durint disc 0very as was F.r. Shelly on his. We think the Licensee has had more than ample time to consider how to address this cuestien. . They have either changed the letters or they haven't. Either way, a few days can't matter after all the discovery they did. (..e would grant them an extention to the length of the hearings if they wanted.) The second on-site issue is crucial. It asserts that the operators may not recognize that an accident situation has started within the 10 minutes that that is supposed to happen in. The TV.I-2 accident is surely an example of operators not realizinF a serious accider.: was in progress. (Sholly 8I J). None of the Shelly contentions we want is any less valid as a contention just because Mr. Sholly no longer lives in the Harrisburr area. The contentions have all been around sinn Jeptember (at least Licensee and Staff and Commonwealth have had ample time to ask discovery questims. F.r. Sholly chose his issues carefully. phrased then well. and we have selected only those we truly want and car. liticate. derved on Staff. Licensee RoJppetfully. l ar.d Commonwealth in Harrisburg i t. ' on Friday morning ?/6/81. l A. J N~'rd Gail*Bradio g for ANGRY J l l \ l _
CHARY OF SH0LLY D2RGDCY PLANNING CCNTS.NTICtd AND STATUd 81 A timely reliable communications dropped Cff
*! ! 10-mile*DZ accepted Cff 81 C 4th largest pop. DZ dropped Ofc
~
8! 3 Licensee credibility to public dropped Cn j
- 81 I Yime estimates (see ANGRY III sj) d-on new cn i
- LLI scope and nature of support services keen on i
. ILJg specifics of letters of agreement v .n Cn 81 M In.*estion exposure RZ planning 6*es Off SI I Audit
- Review of plan for life of plant accepted Cn AL,f, CT:rator recognition of accident beginning kaes cn 81 K Cn-site radiation equipment readiness drev *ew Cn SI k'-P Cumberland County dropped Cff 81 0 Licensee plan to pre-inform public dree new on .
- 6I R Public education (exchange for ANGRY III me). keen off
- HTI A to-mile plume D Z. 20-n11e readiness dren new Off ,
BII 5 State's planning assumptions keep (ff SII C State's rad monitors in inclement weather dren now Cff .
- SII D time estimates affectes by events - weather keen Cff B II .? Use of contaminated stuff after accident dropped Cff .
~
SII G June 16.1980 drill and drill concept keen Cff -
- BIII A reliance on non-existing municipal resources keen Off SIII 3 .* Cumberland County dropped Cff ','
9?II I 15-minute notification ability keen cff BIII F 15-minute notification of transients keer Cff ' 6III G Public education (County plans) 6tes now Off SIII M County-plan assumptions dropped off .' Notes
- Kr. Zahler objected to these contentions on Dec. 19 drop now --- means that ANGRY does nel seek this contention dropped--- means that Mr. Sholly dropped this contention accepted--- means that Board granted ANGRY this contention Jan 27 keep--- meane that ANGRY wishes to adopt this contention exchange--- (Sh 8I R) ANGRY wishes to " exchange" this for similar ANGRY contention nct as well worded. ANGRY will drop ANGRY IIIae if permitted to adopt Sh 8I R Off----means an "off-site contention (f.'.r. Gray's list)
On--- r.eans an "cn-site" contention (5'r. Gray's list)
TEXT OF THREE SHOLLY "0N-SITE" CONTENTIONS ANCP.Y SEEKS (F) Licensee's Emergency Plan contains insufficient descrip-tions of the nature and scope of support services pro-BI F vided by contractors, the qualifications of such con-tractors to perform the specified services, and mutually acceptable criteria for the implementation of such services. (G) The " letters of agreement and understanding" appended to 91 G the Licensee's Emergency Plan contain numerous defects as noted below. DEFECT l--Provides no clear concept of radiological response operations. DEFECT 2--Lacks sufficient details on the nature and scope of support. _ DEFICT 3--Fails to specify mutually acceptable criteria for the implementation of emergency assistance. DEFECT 4--No letter of agreement provided, but should be.
- 1. General Public Utilities, 1 & 3.
- 2. PEMA, 1.
- 3. York County, 1 & 3.
- 4. Lancaster County, 1 & 3.
- 5. Bureau of Radiation Protection, 1 & 3.
- 6. U. S. Coast Guard, 1 & 3.
6 4 l *:, l 'a! l a
y "0N-SITE's" page 2 t
.}
- 7. Conrail, 1.
- 8. NRC, 1 & 3. .j 1
SF.0LLY 9. Middletown Fire Department, Liberty Fire 81 G ' Co. 41, 1.
- 10. Rescue Hose Co. 43, 1. ifri
- 11. Union Hose Co. 61, 1. ;j
- 12. Bainbridge Fire Company, 1. [
- i. .
(J) Licensee's Emergency Plan, in section 4.4.1, asserts, ,. SHOLLY OI J without explanation or basis, that Licensee's emergency , i!' classification system is designed to permit operators to recognize and declare emergencies within 10 minutes ,
.:}
of the initiating event. In the light of events during the TMI-2 accident (3/28/79 et seq.), there is no basis [Y.. for reliance on this time limit for recognition of and ' .5 3 declaration of an emergency at TMI-1. Licensee's Emer- } gency Plan should reflect the potential for failure to .j promptly recognize and declare an emergency, and shculd 4 include contingency plans and procedures for coping with ? this eventuality. This is especially important within the context of the time a$ 1able for implementing pro-tective actions in the Plume Exposure EPZ; this was recognized in NUREG-0396 at page 19 where it is stated ' that the time available for action is "strongly related" ; f to the time consumed in notification. Notification can-not commence until an emergency is recognized and de-
- clared.
g m
CFF-SITE SHOLLY CONTENTIONS ANGRY SEEKS TO KEEP (SIX) ] (B) The assumptions stated on page 6 of the Revised Edi-tion of Annex E as noted below are without basis and
,Nff3 reliance on these assumptions during an emergency may place the public health and safety at significant risk depending upon the severity of the emergency at TMI-1:
- 1. Federal agencies will provide for the Common-wealth's essential " unmet" needs on a timely basis.
- 2. For planning purposes, persons evacuated from a risk area will prepare to remain outside that risk area for at least three days.
- 3. At least 50% of the population at risk will mske independent provisions for sheltering An the event of necessity to evacuate.
None of these assumptions is justified in the Annex E plan. Number 1 is not justified in any manner and if it is to be retained and relied upon as a planning basis, must be supported with agreements which specify what assistance is available, from whom it is available, and under what conditions is it available. Numbers 2 and 3 relate to planning assumptions for host counties and are without basis; reliance on these two assumptions, if they are incorrect, could lead to significant problems in host centers.
l *0FF-SITE's* p:ga 2 (D) Evacuation routes and time estimates for TMI-l do not SEcllY reflect possible impediments to egrest routes, such as e II 3 rush hour traffic, inclement weather, or seascnal changes in traf fic flow (caused, for instance, by the State Farm Show or similar function, or by tourist l traffic). The Commonwealth's method of testing its emergency pre-paredness by using drills where the specific scenario ] is known to all participants well ahead of the scheduled S II G date for the exercise lihits the effectiveness of such l testing to very low levels. The June 16, 1980 drill is I a prime example of this situation, wherein even though the parties to the drill knew ahead of time the start-ing and conclusion times for the exercise, the accident scenario that would be used, add the fact that the exer-cise would end in a call for an evacuation, major problems developed, especially regarding the Health ! l Department and the relationshio of PEMA and BRP. This drill shows conclusively that the Commonwealth's readi-ness for an emergency at TMI-l is not sufficient to adequately protect the public health and safety. Until such time as thorough improvements in planning and by drills which.are unannounced that the Commonwealth can
\ demonstrate an adequate level of emergency preparedness, restart of THI-1 should be denied. .
1 i f e
-l
/. <
.(
"0FF-SITE's" para 3 )
s e I k EP-19 (Shollv) ,Y
.i Defects in the county and local government plans:
I (A) The county plans are inadequate due to the inadequacy g , of municipal resources and services needed for effectua-pg g tion of the county plans. (E) None of the five county plans within the proposed Plume - Exposure EPZ has demonstrated that they have the caps- s. l .a bility of meeting the new prompt noti::. cation require- I-l # ments of the NRC emergency planning rule (10 CFR Part i
.httu'/
- 50, Appendix E, IV, D, 3) requiring the capability of !
k
@[ -
essentially complete notification of the public within , the Plume Exposure EPZ within about 15 minutes. Until ,y
;l this capability is demonstrated to exist, TMI-1 restart ,
4
, bMCLLY must be denied.
(F) None of the five county plans within the proposed Plume [[[ Exposure EPZ has demonstrated adequate planning for l notification of transients during an emergency at TMI-1. l
*~
l k ! ANGRY CONTENTION EXCHANGE FOR SHOLLY CONTENTION i.i , .l l The adoption of the Commonwealth of Pennsylvania ', l Disaster Operations Plan Annex E (DOP) designation of "the ' risk county' as responsible for the prepara- ,
- l tion and dissemination of information material on l\ \N protective actions to the general public" (p. 6-8) ,
{ gf conflicts with the requirements in EPRG II(A) (7) and RG 1.101 5 6.4 (2) to make available on request to occupants in - the LPZ information concerning how the - emergency plans provide for notification , to them and how they can expect to be ad-vised what to do. Also, N. 0654 G4. , The new emergency planning rule (10 CFR 50.47b7 and 10 .., CFR Part 50, Appendix E, IV, D, 2) imposes new responsi- ., bilities on the Licenses regarding dissemination of j, information to the public on a periodic basis on how i they will be notified in the event of an emergency and (;(,,L,N) what their initial actions should %:. Provision is made in the new emergency planning rule that annual dissemination of such information to the public within the plume exposure pathway EPZ shall be made, and that signs be posted to disseminate such information to transients. Licensee's emergency plan lacks information on how these requirements will be met. As a precondition
ANGRY /SHOLLY EXCHANGE page 2 to restart, Licensee must be required to demonstrate ' reasonable Frogress toward achieving compliance with ' these provisions. If restart is permitted after the required compliance date, April 1, 1981, Licensee must, as a precondition to restart, demonstrate full compliance with these provisions. The first dissemination of the
$ildLi required information, in this instance, should be re-l -
quired to take place several weeks prict to restart to ensure that the public has sufficient time to read and understand the information. Dissemination of such information through distribution with utility bills is insufficient since many of the residents of the plume l exposure pathway EPZ are not customers of the Licensee, ) and ,many residents are not directly customers of at:y utility, and would not, therefore, be reached by such : a distribution system. , l
- 1 gyGm , a > a; o a s, s u i yn,-
t, l
.. . . p
,,p . g( c' s
(THI3 CHART ..A5 FRETARE: u. v. p. ;. . : .. ) ONSITE EMF.RGENCY PLANNING , A. Organization and Coordination i
- 1. Han er M pgtelub gn JSL M 0 , p . ')
C k(D) ANGRY III(a) (f) E.2 e( ) ?::::: :::(::(=; 1
- 2. Letters of Agreement
-4'S; 700027 :::'e;'d; :.
11 ';.; ::;uier:3 .":: Od I w 1? (T; Ch:11a "!!! f; :.1
,p p 17 (G) Sholly 8 (I) (g) E.1 1
- 3. Coordination with other Plans l i
- 15 (C; :::rt::ry ":t If f ':t included ,
15(I; Neuberry "et !! ! - '*e t included i B. Initial A=cident Assessment j
- 1. Classification j I
8 ECNP 2-9 Not included 9 ECNP 2-10 Not included 17(J) Shelly 8 (I) (j) A ,
- 2. Radiation Monitoring ,
ANGRY II(f) . I 72:0nY :::( ) (h; 7.
~
17 (K) sho11y 8 (I) (k) 2 20 Sho11y 9 I C. Initial Accident Notification
- 1. Communications 1 Aamodt 4 Not included f(! ?.rCSY !!!!:!(;; O
-44s; ?" cay :::(::(i; 15(?! ": rte::3 ";t to ? ?
. 2. Alerting the Public
-45(i; :::rWry ".;; d ' O 17 (P) sholly 8 (I) (q) D
t . D. Onsite Emergency Response
- 1. Mobilization of Resources
- 2. Offsite Resources
- 3. Recovery E. offsite Emergency Response
- 1. Definition of EPZ's 17 (B) sholly 8 (I) (b) Not included
- 2. Education Program 4'0; AN0r.' :::'el 'e; ;
17(o) sholly 8 (I) (r) D
- 3. Protective Action Options and Decisionmaking 4 (H) ANGRY III(a) (j) A 7 ECNP 2-8 Not included 11 ECNP 2-33 Not included hp U 17 '::
17 (H) O h ; 1 13- O ' : '; ; Sho11y 8(I)(h) O D j
- 4. Logistics . !
P. Maintaining Emergency Preparedness . I
- 1. Emergency Training i
- 2. Exercises and Drills !
,,.. ......,,,,_i,ti ,
. J ' ', ' . 31'.TE: .., _1.".'-.. '!! .--
3 -, L i
- 3. Audit and Review of Plans 17(I) Shelly 8 (I) (1) R I
. (THIS CHART WAS PREPARED BY LICENSEE) 7 k
- CFFSITE EMERGENCY PIANNING 1t h <
- A. 1. Manpower 5 (H) ANGRY III(b)(k) Not included 14, ... (F) N.ewberry York. 6 *E. 2.
._.x._..,-
. , . , .._.1,_ .... . . . .
.,---.., .n
,. .. . a . ;
E .1 , , , i N..ewberry York 3,_8 14. (.,,LL. ) _.x____.
... ...., ... _,_t..... . . ...
- 2. Police
-...., ... ...t.. - -..
- ' R; ;;; ; b; ; ;y "; ;h 1 0 : .1 : .d 5. 2 -
14 (L) Newberry_ .__ York,. 1,2 , E.1 ,
.,w,
.._.x._._._,
.. . - a . .n .. ~..
14 (X) E.1
. . _ _ Newberry
.._.1___
York,_ o.._._ 2
, 3,o_, .,, ,,
a i s y v. ,. _- _ . . _ . . . - _ __.._t,_ 6eia, ...--.., --.r..... ... t 3. Fire Companies 14(5) Newberry York *18 E.1
- 4. Red Cross l' ' ) :::wt; ; ;y ";;% : :: .1 :. . '. !'
- 5. Letters of Agreement 6 (D) ANGRY III(c) (10) E.2 l i
B. 1. Classification
- 2. Radiation Monitoring .
Is (C) sho11y s(II)(c) I C. 1. Comunications 6 (C) ANGRY III(c)(9) Not included
- 14. (.D) ...
N..ewberry _.1_ _. Y_ork,. 4, , E.1 l' '0) " ri:::y :::pr.in 2 : : d 0.1-
- 2. Alerting the Publia
- e. ...,u,
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b UNITED STATES OF AMERICA . NUCLEAR REGULATORY COPJtISSION .) BEFORE THE ATOMIC SAFETY AND LICE!! SING BOARD '{ In the Matter of ) 4
) v METROPOLITAN EDISON COPPANY ) Docket No. 50-289 i.
) (Restart) 'g (Three Mile Island Nuclear ) :
Station, Unit No. 1 ) l CERTIFICATE OF SERVICE ,,
.E I hereby certify that copies of Intervenor ANGRY's Request For Reconsideration On ANGRY Motion To Adopt Emergency f.
Planning Contentions Abandoned By Mr. Sholly dated February 5, f. 1981, which was hand delivered to Licensee at 34 N. Court $ Street, Harrisburg, Pennsylvania, on February 6, 1981, were r served upon those persons on the attached Service List by 0 deposit in the United States mail, postage paid, this 6th !
'I day of February, 1981. ;
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'NilliamgIMiller g
Dated: February 6, 1981
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UNITED STATES OF AMERICA u . NUCLEAR REGULATORY COMMISSION
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METROPOLITAN. EDISON COMPANY . ). . ., . Doc'ket' No. '50-2 89 'e . i g, m.-, .,. p, . . , } t e . l.; .(Restart) ' (Three M11EiZsland ' Nuclear - ) ,.g.l . ,;. .- Station. d.. Un. it... No. 1).
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Ivan W. Smith,-Esquire -
.. John . .Q, '
Chairman.. . ,5 Assis[A.' tant 2,evin, Esquire A;73 Atomic Safety'and Licensing , Pennsylvan,counselia~Public Ut'ility Comm.
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. i Board Panel - '. ~ Post Office Box,3265 e.y U.S. Nuclear Regulatory.' ..... .Harrisburg, . Pennsylvania 17120 -
. .e Commission 71 ' '?:j.Y / : .* ' '/: " ". .
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Washington, D. C. 205'55j.e.,;,.,.,f.4,",f.; .
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Dr.'Wali.er H. Jordan" ^ .. .' .NIin'i,Y. 'Caitterd' Esquire . 4M Atomic. Safety and Licensing'.l' Assistant Attorney' Genitral' ; Board Panel: . . g.';Q 50.5(Executive.LHouse v.
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Board ~;7.; 4 Board Panel'.' '. .
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f a. J 5000'Heilnitage" Drive j '.9??YDauphiii' County.: Courthouse - O '..%'s'q 't Raleigh',. North
- Carclina .27612 Frontiand Market' Streets-James R. Tourtellette,
. Harrisburg, Pennsyl.vania 17101 - @(
. c f.s Esquire (4) ..Nalter.'W. Cohen, Esquire iM ;
i Office of the Executive Consumer Advocate ' Legal Director U. S. Nuclear Regulatory
' Office of Co:'sumer Advocate 14th Floor, Strawberry Square
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Harrisburg Pennsylvania 17110. . W shington, D. C. . 20006 7' Ms. Louise'*;radford' . ' , Robert Q. Pollard TMI ALERT v'. '. ,
- ~s . (l' "j609 Montpelier Street .
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. ; Baltimore, Maryland 21218 .,. ! ,
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.- i. -: .Chauncey1 Xepford j,d Ellyn R.~ Weiss,p' Esquire . l. .' f Cudith M. Johnsrud : .
.. -Harmon & Weiss ' .. ' ' 7 ' .f E
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Marvin'I. Lewis Union' of Concerned Scientists .
1725 I street, N.W.,-Suite 601 '6504.Bradford Terrace .dgl Washington, D. C..' 20006 .
. Philadelphia, Pennsylvania 19149 r
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Gail Bradford., . Marjorie M. Aamodt r ANGRY .R.'D. 5- 4;
, 245 West Philadelphia' Street l Coatesville,. Pennsylvania 19320 York, Pennsylvania 17404 -
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A VAttorney. General of.New Jersey John' F. Ahearne-9 Attentions : Thomas J. Germine, Esq. d
' Deputy Attorney General Chairman .
U.S. Nuclear Regulatory Commission Division of Law - Room 316 ... Washington, D. C. 20555 . 1100 Raymond Boulevard ,-
- ~ Newark, New Jersey 07102 .
Victor Gilinsky ,j ., (
- Peter; A.:Bradford Commissioner .
s .. U.S. Nuclear Regulatory Commission Commissioner ,., Washig' ton, D. C.. 20555 - ' 'U.S.' Nuclear Regulatory Commission i
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.. .' Washington, D..C. 20555 ::y Joseph M'."Hendrie <- ' f9
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