ML19309C815

Further Response to First Set of Interrogatories.Includes Info Re Hydrogen Control,Eccs Flow Rate,Use of Radiation Monitoring Devices & Health Physics Procedures

ML19309C815
Person / Time
Site:	Three Mile Island
Issue date:	03/17/1980
From:	Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
Shared Package
ML19309C810	List: ML19309C809 ML19309C815
References
NUDOCS 8004090295
Download: ML19309C815 (22)

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March 17, 1980 UNITED STATES OF AMERICA' - -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

. Station, Unit No. 1) ) .

LICENSEE'S FURTHER RESPONSE TO INTERROGATORIES (FIRST SET) FROM STEVEN C. SHOLLY INTERROGATORY NO.03-005 What means are utilized to assure that if concentrations of hydro-gen are detected in the reactor containment which are in the range of either combustion or detonation that inadvertent combustion or detonation are avoided? ,

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j RESPONSE Purging, as discussed in the TMI-l FSAR, Supplement 1, Part II and SER Section 6.2.5., is one of two means of assuring hydro-gen control. Second, hydrogen recombiner capacity will be pro-vided as described in the Restart Report, Section 2.

System capacity has been specified in accordance with the hydrogen generation criteria contained in 10 C.F.R. SS 50.44 and 50.46, and sized to meet the provisions of Regulatory Guide 1.7, Rev. 2. These criteria assure hydrogen concentrations can be maintained below flamability limits for design basis events.

INTERROGATORY NO.03-010 Specify conditions under which operators are permitted to either reduce ECCS flow rate or cease ECCS flow. U 8004090 N

RESPONSE

Conditions under which operators are permitted to either s

reduce ECCS flow rate or cease ECCS flow are specified in operator guidelines contained in Licensee's Restart Report, Supplement 1, Part 1, attachment to Question 45 response.

INTERROGATORY NO.03-011 Who must verify that the conditions referred to in 03-010.have been met and how is this verification accomplished?

RESPONSE

Only individuals maintaining a current Reactor Operator or Senior Reactor Operator license on TMI-l can certify that the appropriate conditions have been met. This restricts the author .

ity to control room operators, shift foremen, shift supervisors, or other licensed members of the operating staff. It is th,e licensed operators responsibility to assure that the appropriate conditions are met. This typically is done by cross-corollation of diverse parameters or comparison of redundant channels.

INTERROGATORY NO.04-001 What are the bases for determining the number, locations, and types of radiation monitoring devices used to determine radia-tion doses to offsite locations around Unit I?

RESPONSE

Under routine (normal) use, the number. locations, and types of radiation monitoring devices were chosen to allow for effec-tive environmental radiation dose assessment in all directions, o

and at various distances, from Three Mile Island. The number, locations, and types of radiation monitoring devices are in ac-cordance with proposed TMI. Technical Specifications and with the

NRC Branch Technical Position memorandum of November 1979. In .

addition, locations were chosen so as to pro. vide appropriate in-formation for discrete population centers near TMI. Thermolumi-nescent dosimeters ("TLDs") were chosen as the monitoring device because of their high inherent precision, accuracy and ability to integrate doses over time.

Under (abnormal) conditions of off-site releases of radio-active materials, the TLD program becomes a back-up to a program which requires that a series of radiation monitoring teams be sent out into the environment for immediate, real-time monitoring of the environment. These teams are equipped with portable radia-tion detectors to measure gamma immersion dose and to monitor .

Iodine-131 levels, including the resulting radiation dose. The first available offsite team is dispatched on the basis of , exist-ing meteorology, with the team being dispatched to the location of anticipated highest radiation dose and likely radioactive plume touchdown.

INTERROGATORY NO.04-002 How much time is required under ideal conditions to collect, pro-cess, read, interpret and communicate radiation dose results for TLDs utilized in the environmental radiation monitoring program?

RESPONSE

For the TLD system to be installed prior to restart, it will take approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to collect, process, read, interpret, and communicate radiation dose results.

INTERROGATORY NO.04-003 With reference to the actions described in 04-002, how much time would be required under adverse conditions such as bad weather,

severe traffic congestion due to a protective evacuation, ar.d '

, strikes affecting the number of personnel available for such l activity? , .

RESPONSE _

Licensee has not made a time estimate based on adverse con-ditions since Licensee would not rely on environmental TLDs to l make a real-time estimate of radiation dose. _

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INTERROGATORY NO.04-004 Provide verification that Licensee has the capability to comply  :-

with the requirements of Health Physics Procedure 1670.6 or its current equivalent.

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RESPONSE

Procedure 1670.6 (Revision 2, 1/16/78) provides for the deployment of special emergency TLDs as an option -- not a re-quirement. These TLDs are the type used for monitoring plant

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personnel exposures. There are sufficient numbers of these TLDs

• onsite to implement Procedure 1670.6 and capabilities for reading these dosimeters onsite do exist.

, With respect to the environmental TLDs already deployed around the site, Licensee does not now have onsite capability.

to read such monitors. The absence of such onsite capability does not impair emergency response since the environmental TLDs are not relied upon by Licensee to make a real time assessment of.

offsite doses. See Licensee's response to Interrogatory No.

,04-001. This is because emergency response is based upon doses expected to occur in the future and not on doses from past re-i leases; environmental TLDs give data for releases which occurred I

! in time past. Nonetheless, there is presently being' developed t an'onsite capability for reading the environmental I-l l

TLDs. See also Licensee's response to Interrogatory No.- 04-011.

INTERROGATORY NO.04-005 Specify procedures utilized to calculate radiation doses for off-site locations which do not contain a TLD within the same compass direction and same distance range from Unit I.

RESPONSE

. Health Physics Procedure 1670.4 is utilized to compute off-site doses during an emergency. This procedure does not rely on TLD monitor data at any location for estimating doses. Rather, the dose estimates are made using precomputed atmospheric disper-sion values, and are based on current meteo.rological conditions ,

as well as radiation release information. The computed dose esti-mates are supplemented by measurements made by offsite monitoring teams. See Licensee's response to Interrogatery No.04-001.

INTERROGATORY NO.04-006 With reference to 04-005, further specify the accuracy of these procedures in terms of confidence limits or other similar appropri-ate statistical expression.

RESPONSE

Uncertainties in the projection of radiation doses are diffi-cult to quantify. However, the calculation methodology used is designed to conservatively overestimate dose. Supplementary _

measurements from mobile monitoring teams can be used to reduce the uncertainty.

-INTERROGATORY NO.04-007 Identify the name, address, and technical capabilities-of all con-tractor firms utilized in the environmental radiation monitoring program.

RESPONSE

,As part of its environmental radiation monitoring program, Licensee utilizes the services of the following contractors:

(a) Teledyne Isotopes 50 Van Buren Avenue Westwood, New Jersey 07675 (b) Radiation Management Corporation Post Office Box 8068-5107 Philadelphia, Pennsylvania 19177 (c) Porter-Gertz Consultants, Inc.

76 Rittenhouse Place Ardmore, Pennsylvania 19003 (d) Pickard, Lowe & Garrick, Inc.

1200 18th Street, N.W.

Suite 612 Washington, D.C. 20036 ,

Material describing the technical capabilities of these contractors is being placed in Licensee's Discovery Reading Room. .

INTERROGATORY NO.04-008 With respect to the firms identified in 04-007, further specify the nature and extent of services provided by each contractor firm.

RESPONSE

Laboratory analysis of all environmental radiation monitoring samples is performed by Teledyne Isotopes. In addition, part of the samples are split and sent to Radiation Management Corporation as part of Licensee's quality assurance program. General consult-ing in the areas of radiological protection and environmental ser-vices is provided by Porter-Gertz and Pickard, Lowe & Garrick.

INTERROGATORY NO.04-009 Specify on a year by year basis the dollar amount spent by Licensee on activities related to off-site radiation monitoring.

activities.

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RESPONSE

,1975 1976 1977 1978 1979

$438,774 $316,459 $285,285 $220,525 .$2,030,318* ,

• Includes some nonenvironmentally-related services provided since the Unit 2 accident.

INTERROGATORY NO.04-010 Provide the time necessary under ideal and adverse. conditions to provide officials with emergency preparedness responsibilities in the Plume Exposure EPZ with radiation exposure data.

RESPONSE

The time necessary to provide preliminary dose rate projec-tions using Health Physics Procedure 1670.4 is less than 10

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minutes. It is not expected that " adverse"' conditions would sub - -

stantially alter the time needed to implement Procedure 1670.4.

Radiation monitoring team members could also be rapidly dispatched.

It is anticipated that the initial results from the mobile monitor-ing teams would be available in about 30 minutes following their dispatch.

INTERROGATORY NO.04-011 <

Describe the on-site TLD processing capacity which is currently possessed by the Licensee and that which will exist at the time of Restart.

RESPONSE

At the present time, there is no system on site for process-

'ing the environmental TLDs. The TLDs are sent to Teledyne Iso-topes in Westwood, New Jersey for reading.

At the time of Restart, Licensee will be using a Panasonic TLD system, and will have onsite processing capability.

INTERROGATORY NO.05-001 Specify the gaseous effluent radistion monitoring capabilities which'will exist at the time of Restart for all effluent di's--

charge pathways required under General Design Criteria No. 64, 10 C.F.R. 50.

RESPONSE

Current radiation monitoring capabilities are described and specified in FSAR Section 11.4. This capability includes process radiation monitors (for airborne pc a ticulates, iodine and noble gas) in the auxiliary, fuel handling and reactor buildings ~. In  :

addition, the capability now exists at TMI for measuring very high levels of gaseous effluent I-131 by removing the charcoal cart-ridge and counting it on a GeLi Detector Multi-Channel Analyzer Counter System. A similar procedure can be used to measure high .

levels of noble gas release by GeLi-counting grab samples in a Maranelli Beaker. .

These capabilities will be expanded to measure higher effluent levels as described in Sections 2.1.2.1 and 2.3.2.7 of the Fe-4 start Report. These expanded capabilities will be provided for:

(a) Reactor Building purge exhaust .

t (b) Auxiliary and Fuel Handling exhaust (c) Condenser exhaust (d) Steam safety valve discharge.

INTERROGATORY NO.05-002 For each device which is in place to monitor gaseous radioactive  ;

effluent, provide the operating range in terms of curies per second, precision of the measurement, and the accuracy of each device in the ranges of 0-10% and 90-100% of full scale in terms of confidence limits or other appropriate statistical expression.

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RESPONSE

, Table 1 (attached) provides representative data for. currently installed devices. Sections 2.1.2.1 and 2.1.2.7 of the Restart Report provide additional information on the devices that will.be installed prior to restart. ,

INTERROGATORY NO.05-003 Specify the procedures by number, title, and summary which are utilized to convert gaseous effluent radiation monitoring. device data into radiation dose estimate for off-site locations. .

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RESPONSE

The procedure presently used to convert radiation monitoring data to dose rate in the environment is Health Physics Procedure 1670.4.

INTERROGATORY NO.05-004 ,

With reference to 05-003, specify the confidence levels with re-spect to the accuracy of these conversions or describe same in other appropriate statistical expressions.

RESPONSE

See Licensee's response to Interrogatory No.04-006.

INTERROGATORY NO.05-005 Specify the gaseous effluent radiation monitors which can provide on-scale data under conditions of the maximum release rate exper-ienced in the Unit 2 accident, as well as for releases one and two orders magnitude higher than those maximum release rates (suggested as possible in NUREG-0578).

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INTERROGATORY NO.05-002 '

TABLE 1 Accuracy 2/ Accuracy 2/

Bias 2/ at Blas2/ at Range Range Range1 ! of Noble Cas Precision - 5% of 95% of at 5% of. at 95%

Monitor No. In C1/sec at la Full Scale Full Scale Full Scale Full Scale auxiliary & Fuel RMA-8 1.6x10~ to 1.6 122% 48% +7% +30% to -14% +29% to -15%

Handling Building at 120,000 cfm

-5 -1 Reactor Butiding ' lutA-9 6.1x10 to 6.1x10 122% -4% -5% +18% to -26% +17% to -27%

at 50,000 cfm

-8 -0 Condenser Vacuum RMA-5 3.5x10 to 3.5x10 -+22% -9% -10% 413% to -31% +12% to -32%

at 30 cfm 1/ Ilased on Xe calibration.

2/ 1978 Annuat Book of ASTM Standart; - Part 31. American Society for Testing and Materiale. Phi!adelphia. 1978.

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RESPONSE

Therrange of existing effluent radiation monitors is' pro-The vided in the response to Interrogatories05-002 and 05-006.

maximum release rates in the Unit 2 accident were:

Noble gases 26 Ci/sec Iodine 131 13 pCi/sec Increased range of radiation monitors is discussed in Rest' art Re- .-

port, Section 2.1.2.7.

1 INTERROGATORY NO.05-006

• Specify the maximum release rate which can be accurately deter- .

mined by gaseous effluent radiation monitors for radiciodine.

RESPONSE

uCi/cc 'Ci/sec .

_4 _2 I-131 MRR* for normal range RMA 8 = 8x10_g 4x10_q I-131 MRJ* for normal range RMA 9 = 8x10 2x10 I-131 MRR* for extended range RMA 8** = 1 47  :

I-131 MRR* for extended range RMA 9** = 1 24 I-131 MRR* for grab samples from RMA 8 2 3 analyzed by lab analysis = 10 4.7x10 I-131 MRR* for grab samples from RMA 9 2 3 analyzed by lab analysis = 10 2.4x10 Maximum Release Rate

• • To be installed by 1/1/81 INTERROGATORY NO.08-001 1

Provide copies of all documents, transcripts, tapes, memoranda, letters, and files which relate to the basis for the 10-mile Plume Exposure Emergency Planning Zone as proposed in Emergency Plan.

RESPONSE

The 10-mile plume exposure Emergency Planning Zone ("EPZ"),

as provided for in Licensee's Emergency Plan, is based on guidance found in NUREG-0396. Additional guidance on this subject is also

provided in NUREG-0654,Section I.D - " Planning Basis". Copies of ,

these. documents have been placed in Licensee.'s Discovery Reading Room.

INTERROGATORY NO.08-002 Specify the methods of analysis utilized in determining the ade-quacy of the 10-mile radius for the Plume Exposure EPZ and provide calculations used to support this distance.

RESPONSE

Information relative to the methods of analysis utilized in .H determining the adequacy of the 10-mile plume exposure EPZ is con-tained in NUREG-0396. Additional guidance on the basis of the 10-mile EPZ is provided in NUREG-0654.

INTERROGATORY NO.08-003 Identify by name, title, affiliation, and professional background (i.e., engineer, health physicist, etc.) all persons who provided

• input to or performed analyses used in the determination of the 10-mile Plume Exposure EPZ.

RESPONSE

These individuals are unknown to Licensee. To Licensee's knowledge, NUREG-0396 and NUREG-0654 (including the documents refer-enced therein) identify some of the individuals who provided input i

to those documents.

INTERROGATORY NO.08-004 Provide a copy of the entire contents of the Emergency Plan Imple-menting Document, including all Emergency Procedures.

RESPONSE

These documents and procedures have not yet been completed.

Copies will be placed in Licensee's Discovery Reading Room when i they are completed.

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INTERROGATORY NO.08-005 Specify the methods utilized to determine the sufficiency.of the ~ ' ~

Emergency Action Levels proposed by the Emergency Plan. ,

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The Emergency Action Levels, as designated in Licensee's

! Emergency Plan, are based on NUREG-0610. ,

! INTERROGATORY NO.08-006 Identify specifically, based upon guidance contained in NUREG-0396, how the Emergency Plan considers the impact on emergency .- l i

planning of Class 9 accidents.

RESPONSE

i Licensee will provide a response to this interrogatory on l

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Friday, March 21, 1980. . .

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INTERROGATORY NO.08-007 .

Specify the means to be utilized by the Licensee to notify.the people in the EPZ's (both Plume and Ingestion) in the event of an emergency at Unit 1, including evidence that these means are always available in a timely manner for the use of the Licensee in conveying appropriate emergency notifications. ,

RESPONSE

In the event of an emergency, Licensee will notify the Pennsylvania Emergency Management Agency ("PEMA") in the manner described in the Emergency Plan. PEMA is the responsible. state

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agency for notification of the public. PEMA currently has a siren 1

system in place, and has access to the Emergency Broadcasting ,

System, which they may use to notify the public.

INTERROGATORY NO.08-008 Identify specifically how the Licensee intends to notify transients within both EPZ's (both Plume and Ingestion) in the event of an .

emergency. .

RESPONSE

In the event of an emergency, transients would be notified as described in the response to Interrogatory No.08-007. The educational program of state and local agencies to provide in-formation for transients is under development as described in section 4.6.6.2 of the Emergency Plan (page 6-15).

l INTERROGATORY NO.08-009 l Provide copies of the most recent letters of agreement with local government agencies, local support organizations, contractor sup-port organizations, and state and federal agencies.

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RESPONSE

Copies of the most recent Letters of Agreement are included

, in Appendix C to Licensee's Emergency Plan. .A program is cur-rently underway to update these Letters of Agreement. As the updated letters are received, they will be placed in Licensee's Discovery Reading Room.

I INTERROGATORY NO.08-010 l

With regards to the letters of agreement noted in 08-009 above, e provide details of any such group which has refused to update a letter of agreement since the Unit 2 accident, including copies of letters requesting such updates, copies of responses from the groups, and cny communications with the Nuclear Regulatory Commis-sion regarding such refusals.

RESPONSE -

No group has refused to update its letter of agreement.

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INTERROGATORY NO.08-011 Specify how the Emergency Plan is coordinated with the Security Plan, the Radiation Protection Plan, and all other plant operating procedures and plans.

RESPONSE

Licensee's Security Plan, Radiation Protection Plan, and operating procedures form the foundation for specific portions of the Emergency Plan and in some cases require implementation of the Emergency Plan. Specifically, the Security and Emergency Plans are coordinated in the areas of site accountability, access control, search and rescue, and emergency organization. The Radia-tion Protection Plan serves as the basis for several of the Emer-gency Plan Implementing Procedures ("EPIP's"). The plant operating l

procedures contain action steps based on plant parameters and system status indications which trigger the implementation of 1

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the Emergency Plan.

INTER'ROGATORY NO.08-012 i

Specify the bases for the Licensce's classifications of events in the revised Reg. Guide 1.101 classification of types of emergencies. .

RESPONSE

Licensee assumes that the " Revised Reg.. Guide 1.101 Classi- 1 fication of types of emergencies" is a reference to NUREG-0610 which replaced the classification scheme identified in Reg. Guide  ;

l.101 (Rev. 1, March 1977). The action level criteria described.

in NUREG-0610 were used as a basis fcr Licensee's classification J

of events.

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INTERROGATORY NO.09-001 Provide copies of plans, procedures, and diagrams which detail the ,

Licensee's radiological monitoring plans under both normal and emer- -

! gency conditions.

RESPONSE

Sections 3/4.12.1 of the Three Mile Island Nuclear Station Unit 1 Draft Radiological Effluent Technical Specifications (sub-mitted to the NRC on October 30, 1979) set forth Licensee's  ;

radiological environmental monitoring program during normal operating conditions. These specifications conform with the NRC Branch Technical Position memorandum of November 1979.

During an emergency condition, the existing offsite monitors would provide backup support (see Licensee's Emergency Plan, S 4.7.6.2 & Table 10) for the offsite radiological monitoring ,

teams (see Licensee's Emergency Plan, S 4. 5.1. 3. 2 (e) & (h)).

See also Licensee's response.to Interrogatory No.04-001.

INTERROGATORY NO.09-002 Specify the types of TLDs utilized in the radiological monitoring -

program, including bounds of accuracy and the sensitivity of each type to beta radiation.

RESPONSE

Prior to the Unit 1 restart, the environmental TLD system will be upgraded by placement of dosimeters designed to detect beta radiation. The dosimeters, developed by Panasonic, consist of a four element, two phosphor badge. Variations in the phos-phors and shielding allow discrimination between radiation ~ sources. .

With respect to beta sensitivity, the lithium phosphor of element-1 has a lower limit of detection of 1 mrem. TLD sensitivity will be checked periodically as part of the quality assurance program for offsite radiological monitoring. The bounds of accuracy for each' type of phosphor are as follows: o=5% for Li Bq07 2 and o=2.5% for CaSOg<

These bounds are within the acceptable limits set forth in Ameri-can National Standard Procedure ANSI N545-1975.

INTERROGATORY NO.09-003 Specify the training which radiation protection and health physics personnel receive, and how this training has been updated since the Unit 2 accident.

RESPONSE

The training program for Radiation Protection and Health Physics personnel is conducted in two programs: (a) initial training for newly employed Radiation Protection and Health Physics personnel, and (b) annual recurring training for Radia-tion Protection and Health Physics personnel other than newly employed.

The new Radiation Protection and Health Physics employees .

are initially assigned to a six-week training program. This program includes instructional training on the following material:

A. Basic Radiation Protection Concepts Mathematical Manipulations Exponents and Logarithms Graphic Presentations Presentations of Mathematical Data The Atom

. Radiation Interaction of Radiation with Matter Radioactive Decay ^]

Induced Nuclear Reactions -

B. Health Physics / Academic Subjects Basic Radiation Administrative Concepts Decay and Interactions Radiation Detection and Measurement ~

Dosimetry Radiation Survey Instruments and Techniques Reduction of Radiation Exposure Contamination Control -

Measurements and Statistics Liquid Sampling and Preparation for Activity Analysis Laboratory Counting Systems Airborne Radioactivity Exposure Control Portable Instrument Calibration Semiportable and Fixed Instrument Calibration Shipment and Receipt of Radioactive Material Standards and Regulations Environmental Considerations Administration Personnel Relations Through Effective Communications C. Laboratory Practical Sessions Radiation Dosimetry Radiation Surveys Contamination Control Liquid Sampling and Sample Preparation Laboratory Counting Systems Airborne Activity Surveys and Analyses Respiratory Protection Equipment Survey Instrument Calibration Semiportable and Fixed Instrument Calibration

D. TMI Unit 1 HP Systems Following successful completion of this program, the new Radiation Protection and Health Physics employee is assigned to one of the existing six shifts. Each of the six shifts receives training on a rotational basis one week out of every six weeks.

During various training shifts the following material will be 1-covered on a recurring schedule: i Health Physics / Academic Subjects ,.

Basic Radiation Administrative Concepts Decay and Interactions Radiation Detection and Measurement Dosimetry Radiation Survey Instruments and Techniques Reduction of Radiation Exposure Contamination Monitoring -

Contamination Control Measurements and Statistics Liquid Sampling and Preparation for Activity Analysis Laboratory Counting Systems -

Airborne Radioactivity Airborne Radioactivity Exposure Control Portable Instrument Calibration Semiportable and Fixed Instrument Calibration Shipment and-Receipt of Radioactive Material Standards and Regulations Environmental Considerations >

Administration Personnel Relations Through Effective Communications In addition, classes on unusual incident drills, systems, pro-cedures, information on items of noncompliance and emergency plan training will also be presented during shift training.

Since the accident, Licensee has revised its training pro-gram in the following manner:

(a) A review of the training program for Radiation Protec-tion and Health Physics personnel was made by members of the Health Physics group, the Training Department,

-and consultants. Based on the review, a more compre-

hens 4.ve training program was established which includes ,

a formal student text with supporting lesson plans.

(b) A training shift was established for the Radir. tion Proi.ection and Health Physics personnel to provide tra.ning one week out of six on a rotational basis.  ;

(c) A formal program for newly hired Radiation Protec-tion and Health Physics personnel was established.

INTERROGATORY NO.10-001 Specify the basis on which reasonable assurance exists that de-contamination and restoration activities at Unit 2 will not affect the safe operation of Unit 1.

RESPONSE

Reasonable assurance that Unit 2 decontamination and restora-tion activities will not affect safe operation of Unit 1 is based on separation and independance of physical components, work force, and management of the two units. Section 7 of Licensee's Restart Report describes the radwaste separation and isolation of the Units.

In addition to the physical independence of process systems discussed in the above referance, each unit is independently staffed to cover all modes of operatinn (including emergencies) so that no unusual condition jn Unit 2 processing would reduce the capability of the Unit 1 staff to maintain Unit 1 in a safe condition.

All process steps carried out in Unit 2 decontamination are reviewed from a potential hazards standpoint. Prior to actual

processing, the impact of such processing is evaluated for both i

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I onsite and offsite risks, including potential for impact on t Unit,1 operation. NRC approvals of TMI-2 work are obtained in accordance with TMI-2 Technical Specifications, l n'

1 INTERROGATORY NO.12-001 Provide copies of all information provided to the Nuclear Regula-i tory Commission in conjunction with the Staff's " environmental ap- ,

praisal" of the Restart of Unit 1.

RESPONSE

i Other than the material included in the Restart Repo'rt, e 5

l Licensee has not provided the NRC with information for use in its " environmental appraisal".

INTERROGATORY NO.14-001 , -

Specify the technical resources which Licensee has as its command i

within 30 minutes of a declaration of a Site or General Emergency.

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RESPONSE

Personnel available after declaration of a Site or General Emergency are listed in Table 8 of the Emergency Plan. Table 8

} also indicates the resources available continuously and the esti-3 mated maximum time for the identified personnel to report to their assigned locations. Some of the personnel listed will be available within 30 minutes along with all of those listed as r.

l available immediately.

4 INTERROGATORY NO.14-002

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Specify exactly how plant operating procedures have been modified i to assure prompt initiation and completion of all steps required in emergency situations.

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RESPONSE , ,

, Emergency Operating Procedures are being modified to.. include steps to trigger the Emergency Plan responses. In addition, i

Emergency Plan Implementing Procedures are being developed that also implement the Emergency Plan. When completed, copies of this material will be placed in Licensee's Discovery Reading Room.

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Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:

7 Rober %T Zahler 1

Dated; March 17, 1980 s'

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