ML19331C372

Response to Sc Sholly Interrogatories.Discusses Revision 2 of Emergency Plan.Certificate of Svc Encl

ML19331C372
Person / Time
Site:	Three Mile Island
Issue date:	08/12/1980
From:	Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
Shared Package
ML19331C371	List: ML19331C370 ML19331C372
References
NUDOCS 8008150397
Download: ML19331C372 (39)

Text

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Lic 8/12/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICETSING BOARD In the Matt;r of )

)

1 METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

l Station, Unit No. 1) )

LICENSEE'S RESPONSE TO INTERROGATORIES FROM STEVEN C. SHOLLY ON REVISION 2 OF THE EMERGENCY PLAN INTERROGATORY NO. 1 Section 4.2.1.5 of the Emergency Plan (EP) has been changed.

The EP dated November 1979 (Amendment 10) states:

" Metropolitan Edison Company ha.s, in defining the Emergency Planning Zones (EPZ) for Three Mile Island Nuclear Station, taken into consideration the information and data presented above as well as other important factors such as organizational capabilities, availability of emergency facili-ties and equipment, and the methods for implement-ing the TMI Emergency Plan."

Revision 2 of the EP provides:

"GPU Nuclear Corporation has, in defining the Emergency Planning Zones (EPZ) for Three Mile Island Nuclear Station, taken intc consideration

, the information and data presented above, guidance provided by the Pennsylvania Emergency Management Agency, and other important factors . . .

With regards to the ". . . guidance provided by the Pennsylvania Emergency Management Agency . . .", provide documentary records (including, but not limited to memoranda, notes, letters, reports, records of telephone calls and/or meetings) which describe or dis-cuss the referenced " guidance" from PEMA. Further, to the extent 8 0 08150033$b

that such documentary records are in the possession of Licensee, provide documentary records which contain analyses or evaluations of the PEMA guidance, whether such analyses or evaluations were conducted by Licensee employees, contractors, consultants, or those of General Public Utilities Corporation or General Public Utilities Service Corporation. In the event that appropriate documentary records do not exist, describe in writing the guid-ance from PEMA, including analyses and/or evaluations of that guidance. Identify persons in the employ of Licensee, GPU, and/or GPUSC who have direct knowledge of the PEMA guidance and/or analy-ses or evaluations thereof. Identify the person or persons at PEMA who provided the guidance and the authors of the guidance, if known.

RESPONSE

The guidance provided by the Pennsylvania Emergency Management

! Agency ("PEMA") on the extent of the 10- and 50-mile EPZs is reflec-ted in the Commonwealth of Pennsylvania Disaster Operations Plan, Annex E, Fixed Nuclear Facility Incidents. Relevant information from that document on the extent of the plume exposure EPZ is summarized below.

(a) Fixed nuclear facility incident consequences may require protective action of up to 10 miles and may require actions for agricultural, dairy and food product control up to 50 miles (S IV.A).

(b) The 10-mile evacuation distance includes an adequate safety margin which precludes the need for evacuation of institutions, facilities or people be-yond the 10-mile radius (S IV.F).

(c) The " risk area" around the TMI site is de-fined as a 10-mile radius including the counties of Dauphin, Lancaster, York, Cumberland and Lebanen (Appendix 1, p. 1-4).

(d) The State Plan includes a discussion of site characteristics around the TMI site (Appendix 4,

pp. 4-7 to 4-12).

(e) The State Plan includes an evacuation plan map (with routes, traffic volume, and time estimates) that covers the 10-mile area and beyond (Appendix 6A) .

The State Plan also includes material on agriculture control out j to 50 miles (Appendix 7). Aside from this information, Licensee l

l possesses no other " documentary records" relating to this matter.

I Licensee has performed no formal analysis or evaluation of t

this information. Licensee, however, believes that the EPZ l

boundaries used by PEMA, and the factors considered in developing those boundaries, are consistent with NRC guidance provided in i

NUREG-0396, NUREG-0654, the NRC Policy Statement on EPZ, and the emergency planning rule recently adopted by the Commission.

I i

! Mr. George Giangi, Emergency Planning Coordinator at TMI, has direct knowledge of the PEMA guidance. The " author" of the State Emergency Plan is PEMA, Division of Plans. Mr. James Lothrop is the head of that division. Licensee's chief contact at PEMA on the State Plan has been Mr. Lamison.

l l

INTERROGATORY NO. 2 Section 4.3.1.1 of the EP has been changed. The EP dated November 1979 (Amendment 10), states:

"In summary, the TMI Energency Plan provides:

i

1. A means for classifying emergency conditions in l a manner compatible with a system utilized by State County emergency response agencies and

! organizations."

Revision 2 of the EP provides:

"In summary, the TMI Emergency Plan provides:

1

1. A =eans for classifying emer ency cond.itions."

Does this alteration imply that Licensee's classification of emergency conditions is incompatible with State and County emer-gency response agencies and organi:ations' classification scheme?

If so, identify the agencies and organi:ations which utill:e a classification scheme which is different from the scheme used by Licensee; detail the differences; and explain how the public health and safety is adequately protected by these differing classification schemes when such differences could lead to mis-interpretation of the severity of an emergency (and potentially leading such agencies and organizations to mistakenly fail to call for protective actions, or mistakenly call for protective actions when none are required). If differences in classification schemes exist, has Licensee entered into negotiations with_ thesa__. -

agencies and organizations in order to arrive at a mutually agree-able classification system? If not, why not? If so, describe the status of these negotiations and detail any changes which have i been made or will be made prior to Restart.

RESPCNSE The change to Section 4.3.1.1.1 of the Emergency Plan does not impiv. that Licensee's classification of emergency . conditions is in-cc=patible with the scheme used in the state and county plans. To the contrary, as revised Section 4.4.2 explicitly states, all classification schemes are new identical. At the time Revision 1 of the Plan was submitted, Licensee had adopted the NUREG-0610 classification scheme; the state and county plans had not yet made this change, althcugh adoption of the NUREG-0610 scheme was anti-cipated. Therefore, Section 4.4.2 of the old plan indicated that a correlation between Licensee's plan and the state /coun:v .Olans .

was necessary. The su==ary section cited in this interrogatory reflected this difference by noting that Licensee's scheme was "ccmpatible" with the state /ccunty scheme. This was dropped in Revision 2 since the classification schemes were new identical.

No response is necessary for the other questions posed in this interrogatory.

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INTERROGATORY NO. 3 Section 4.4.1.1 of the EP has been changed. The EP dated November 1979 (Amendments 6 and 10) states:

"The emergency action levels that shall require an Unusual Even declaration include (but are not neces-sarily limited to) the following:

2. Any reactor trip followed by an unanticipated automatic ECCS actuation."

Revision 2 of the EP provides:

"2. Any reactor trip followed by an unplanned auto-matic ECCS actuation."

How does an " unanticipated automatic ECCS actuation" differ from an " unplanned automatic ECCS actuation"? Explain why this wording has been changed. Does the new wording tend to result in fewer Unusual Event declarations than the old wording? If so, explain why.

RESPCNSE In making this change, Licensee did not intend to. alter those events for which an Unusual Event might be declared. Rather, the change was made to alleviate a possible ambiguity in meaning of the word " unanticipated". The concern was that under certain con-ditions operators might view an automatic ECCS actuation as anti-cipated although unplanned. This situation might occur, for example, if plant trips of a certain type routinely caused an automatic ECCS actuation when no such actuation was planned for.

In such cases, an operator might reason that the routine occur-rence no longer made such actuations " unanticipated". To clarify that an Unusual Event should be declared in such situations, the word " unanticipated" was changed to " unplanned".

INTERROGATORY NO. 4 Section 4.4.1.2 of the EP has been changed. The EP dated November 1979 (Amendment 10) states:

"The emergency action levels that shall require an Alert to be declared include (but are not necessarily limited to) the following:

10. Loss of all offsite power coincident with loss of both diesel generators."

Revision 2 of the EP provides:

"10. Loss of all offsite power coincident with the failure of both diesel generators to start for less than 15 minutes.

11. Loss of all onsite DC power for less than 15

- - minutes."

Explain the bases for these changes. Include within your explana-tion the reasons why these changes are more conservative than the old wording. Further, explain the significance of the 15-minute time period cited in both new statements in terms of its impact on the safety of the plant and the status of engineered safeguards features.

RESPONSE

The changes cited in the interrogatory have the effect of making the emergency action levels more precise and more conserva-tive.

In Revision 1 to the Emergency Plan the following scheme existed:

(a) Loss of offsite power and no power from the diesel generators -- declare an Alert. ,

(b) In addition, if no vital AC and DC power --

declare a Site Emergency.

In Revision 2 to the Emergency Plan the following scheme exists:

(a) Loss of offsite and no power frcm the diesel generators -- declare an Alert.

(b) If this condition exists for more than 15 minutes -- escalate to a Site Emergency.

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(c) , Loss of vital DC power -- declare an Alert.

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minutes -- escalate to a Site E=erc.encv..

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Revision 2 of the EP provides:

"15. Any tornado striking the facility."

Explain the bases for this change, including within your explana-tion why the new wording is more conservative than the old wording.

RESPONSE

The change adopts the language of :UREG-0610, which lists

"(a]ny tornado striking the facility" as an Alert. The change is also consistent with the degree of severity of the other natural phenomena listed as Alerts. A tornado warning does not constitute either an actual or potential substantial degradation of the level of safety of the plant, and therefore is inappropriate for listing as an Alert.

INTERROGATORY NO. 6 Section 4.4.1.2 of the EP has been changed. The EP dated November 1979 (Amendment 10) contains no provision for the declara-tion of an Alert based upon off-site gamma dose lavels (actual measured levels). Revision 2 of the EP provides:

"23. Offsite radiological monitoring reports of >10mR/hr (gamma) at any location."

Other provisions in the EP in this section provide for the declara-tion of an Alert when exclusion boundary doses are calculated (based 1 on conservative adverse meteorology circumstances) to equal or ex- i ceed 10 mR/hr (gamma). The. provision for an Alert declarrtion based :

upon a field measurement of an actual dose rate as opposed to a I calculated dose rate based on conser7ative assumptions is not as I conservative as relying on the calculation. Why does this incon- j sistency exist in the provisions for declaration of an Alert? Why i shculd not an actual measurement of a dose not cause a higher level of classification to be initiated?

RESPONSE

1 Including an actual offsite monitoring report of >10 mR/hr l 1

(gamma) as an Alert is consistent iith Licensee's classification l scheme. As indicated in Section 4.4.1 there is a direct correla- i tion between Licensee's emergency action levels ("EAL") and the

protective action guides (" PAG"). This relationship is listed below:

Fraction of PAG Alert .01 Site Emergency .05 General Emergency .1 On this basis, a Site Emergency is declared if, for example, calculated doses using adverse meteorology are projected to equal or exceed 50 mR/hr (gamma) or 250 mR (thyroid) ($ 4.4.1.3 nos. 9, 10 & 11), or if actual offsite monitoring reports equal or exceed 50 mR/hr (gamma). Similarly, Revision 1 required declaration of an Alert if calculated doses using adverse meteorology projected doses equal to or exceeding 10 mR/hr (gamma) or 50 mR (thyroid).

In order to complete this scheme, an offsite monitoring report of 10 mR/hr (gamma) was added as an Alert.

This value is such a low fraction of the lower limit PAG (i.e., one one-hundredth of 1R) that a higher emergency classifi-cation is not warranted.

INTERROGATORY NO. 7 Appen' dix C to the EP, Revision 2, does not contain, contrary i to statements made in Section 4.5.2.1, a letter of agreement from I

Radiation Management Corporation. Provide a copy of the most recent letter of agreement with RMC. If older than two years from the date of the plan, explain why.

RESPONSE

An updated RMC letter of agreement was unavailable in early June 1980, when Revision 2 of the Emergency Plan was submitted.

Attached hereto is the RMC letter of agreement dated Tune 19, 330.

INTERROGATORY NO. 8 Section 4.6.3.5 of the EP, Revision 2, references procedures in the Emergency Plan Implementing Procedures which are used to make contingency dose calculations in the event that instrumenta-tion used for radiological assessment is off-scale or inoperative.

Are these procedures available in Licensee's Reading Rocm? Have they been approved by the PORC since the TMI-2 accident began on 28 March 1979? Do the referenced procedures account for the poten-tial for an accident to release quantities of radiation equiva-lent to those released during the TMI-2 accident? If not, explain in detail why not. If so, specify how such a release is accounted for in the procedures. Further, when such contingency dose cal-culations are used, is this fact reported to PEMA and/or BRP?

If not, why not? If so, what information is provided under such circumstances to enable the agency to determine that the correct choice of contir.gency dose factors has been made?

RESPONSE

This procedure is available in Licensee's Discovery Reading Room. It is undergoing final review and approval by PORC. The procedure specifies five different release scenarios, one of which is to be chosen by the Emergency Director on the basis of his understanding of the emergency event. The Case I LOCA included in the procedure assumes severe core damage and fuel melting.

Releases are based on the assumptions set forth in Regulatory Guide 1.4. These postulated releases lead to offsite doses greater than those experienced during the Unit 2 accident. The results of the contingency dose calculations are provided to the Radiological Assessment Coordinator wno is responsible for communicating this information to BRP. Since BRP also is provided with operational information, they will be able to determine for themselves that a correct choice of contingency scenarios has been made.

INTERROGATORY NO. 9 Section 4.6.3.5 of the EP, Revision 2, references procedures in the Emergency Plan Implementing Procedures which are used as a

basis for the notification of downstream water users if projected

concentrations of radionuclides in the river water exceed levels specified in the procedures. Are these procedures in Licensee's Reading Room? Have they been approved by the PORC since the TMI-2 accident began on 28 March 1979? Specify the levels which must be exceeded before notification of downstream users takes place. Provide a list of all such users, including name, address, and telephone numbers. Specify the basis for the levels in the procedures, referencing specific documents which support the levels used.

RESPONSE

The referenced procedure is in Licensee's Discovery Reading Room. It presently is undergoing final review and will in the near future be submitted for PORC approach. The procedure specifies the levels which must be exceeded before no*ifications are made.

Since these levels have not yet been finally specified, Licensee

is unable to specify their bases. This information will be pro-v.ded in a supplementary response. The downstream users are identi-

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i fiad in the procadure. Their telephone numbers are included in the Additional Assistance and Notification Procedure (although telephone numbers have been deleted from the Discovery Reading i Rocm ccpy of this procedure).

INTERROGATORY NO. 10 Section 4.6.5.1 of the EP, Revision 2, is expanded from the EP dated November 1979 (Amendments 6 and 10), by providing speci-fic guidance on protective actions for sheltering and evacuation.

T tis guidance is contained on page 6-13 of Revision 2 of the EP.

What are the bases for these considerations contained in the EP as specified above? Identify specific references (including title, publisher, date, and authors) which support these considera-tions. Also, identify and provide copies of documentary records in the possession of the Licensee, GPU, and/or GPUSC relating to these considerations, and any analyses or evaluations which support their use.

RESPONS?

.*e referenced guidance is based on information included in l

the 3RP E_an (Appendix 8 to the State Plan) and in interrogatory

responses by SRP in this proceeding. This guidance draws upon the EPA Manual for Protective Action Guides.

II."!ERROGATORY NO. 11 Section 4.6.5.1 of Revision 2 of the EP states:

"The means to warn or advise persons involved is desig-nated a responsibility of the ' Risk County' in Annex E of the State's Disaster Operations Plan."

Contrary to this, page 3-1 of NURIG-0654, which Licensee's E=er-gency Plan references as being cc= plied with in Revision 2, states as follows:

"NRC and FEMA recognize that the responsibility for activating the prc=pt notification system called for in this section is properly the responsibility of the State and local govern =ents. NRC and FEMA also reccgnize that the responsibility for assuring that the =eans exist for putting such a system into place rests with Facility operators."

Has Licensee cc= plied with the quoted requirement frc= NUREG-0654?

If so, specify how Licensee has determined that the facilities for prc=pt notification exist, referencing and providing copies of studies supporting Licensee's position. Further, describe how Licensee reconciles the quoted statement frc= Revision 2 of the EP with the NRC/ FEMA requirement quoted abcve.

RESPONSE

The interroc,atory

. assumes that the c.ucted lanv uage frc= NURIG-0654 is an "NRC/ FEMA require =ent". In point of fact, the only regulatory requirements are these specified by statute er regula-tion. With respect to the warning criterion, the recently adepted emergency plan rule represents a change frc= the apprcach set fcrth in NUREG-0654. Licensee will cc= ply with the require =ents 1

of the new reculation. A crecise schedule for achievinc cc=-

l pliance by the date specified in the regulation has nct yet been

! developed.

INTERROGATORY NO. 12 Section 4.6.6.3 of the EP, Revision 2, contains a provision for training of off-site emergency squad members in the treatment and transportation of contaminated injured individuals; the previous EP contained no similar provision. Describe the train-ing provided. Will such training be provided to all potentially- -

involved off-site emergency squads prior to Restart? Does the training include provisions to train the squad members to avoid contamination of other persons, e':her en-route or while at a hospital facility? I. so, descr! a. If not, explain why not.

RESPONSE

The training to be offered to offsite support agencies is described in Section 4.8.1.1.4 of the Emergency Plan. In par-i ticular, local medical support organizations will be offered training which includes, among other topics, basic health physics, radiological aspects of emergency medical treatment, plant pro-cedures for decontamination, RMC radiation emergency procedures, and transportation techniques for contaminated injured individuals (p. 3-5) . This training will be offered prior to restart. As indicated above, the training does include techniques to avoid contamination of other persons, both enroute and at the hospital facility. The training is being offered annually in conjunction with the annual medical emergency drill conducted by RMC, a pro-fessional medical radiation emergency management organization.

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"ITERRCGATORY NO. 13 1

Section 4.7.1.2 of the EP, Revision 2, contains a provision for future installation of a CRT Monitoring System at the Techni-cal Support Center. A similar provision is lacking in the previous plan. When will this capability to monitor plant computer and required radiological information on a 'not-to-interfere-with-the-operator' basis be installed? Will installation occur prior to Re s ta rt? If not, explain how such information will be trans-I mitted to the TSC, describing provisions to ensure than power failures will not impact on the availability of such information.

Similarly, Section 4.7.2.4 contains provision for a CRT system at the Parsippany Technical Functions Center (a provision which is l

l l

lacking in the previous EP). When will this installation take place? Will the installation take place prior to Restart? If not, explain how such information will be transmitted to the Parsippany TFC, describing provisons to ensure that power failures will not impact on the availability of such information.

RESPO!!SE The CRT monitoring systems referenced in the interrogatory will be installed prior to restart.

Respectfully submitted, SHAW, PITTMMI, POTTS & TRCUBRIDGE Sy: 2 Ch Robeza/E. fahlet Dated: August 12, 1980

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June 19, 1980 ,

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J. G. Herbein

.V.P. , Ganeration T.ree Mile Island Nuclear Statica P.O. Sex 480 -

Middletesn, Pa. 17057 SLL icr: Energency I' dical Assistance Pr: gram (DKP) 4 Cear Mr. Herbein:

mis ccnfi .s an agreemnt beeseen Radiation Panagement Cc:gration PRESIDENT (MC) and Metrcpolitan Edisen Cu.py, wherein DC agrees to furnish certain sa: vices to nuclear generatien statiens operated by Metro-politan Ediscn C_. p y. 2ese services cceprise a program that is identified by DC as an Emergency Medir 21 Assistance Program (DRP) . With regard to T.ree Mile Island R: clear Statien, the i

DSP, cen"4~.s the folicwing previsiens:

1. Semi-annual revies of plant procedu es, eculpment and

. supplies and hespital procedures; one of these audits will be in cenjunceica with (7.) beles;

2. Tsenty-fcur-hour-per-day asallability of expert censul-taticn en ranage ent of radiation accidents;

3. Availability of Bicassay Izberatory fer evaluation of radiatica accidents;

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4. T enty-four-hour-per-day access to a Padiacien Erergency

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Medical 'Deam censiscing of a physician, certified health

• physicist, an' ~ * -icians with g reable instrumentatica I,

to locatien of accident victi.t; PfiN1]lw),qil 4 9 U1 l.

5. Availability and access to a medical centar ewipped for the definitive evaluation and trearaent of ra'i= tion v.vnsity c;:.y injuries;

sscs ca.stu 6 '. Annual training for the plant, ambulance and hospital perscnnel who ray be directly or indirectly involm d

n uAust stassi in the executien of the radiatica redical emergency pro-

'LCELPHIA. PA 19104 NII

;1I) 243 27

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7. Preparatica of an " accident" scenario for use as a training aid in a radiatien medical emergency drill;

8. Coordinatien of a radiatica mMical e-ergancy drill based cn the scenario; t=pired, video ta,ced and criticued by DC; '

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9. Submissien of t.c crill Evaluaticn Faperts; cne relating to

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' de cbser /atiens rada at 62 stacica, and another relating f to cbservations rade at tha hespital; and

10. Participaticn in an annual ene-day serinar in Philadelphia .

ca the canagarent of radiacion accidants for hvsicians.

Each plant ray send cne physician, and each utility c:x --

pany ray send cne physician.

ACCIEL'" FESPC"SE Cce.sultaticn and laboratory services by .9C perscnnel at no charge, increrental ecsts associated with censultative acti@les, such as travel, lodging and other related expenses.

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Lic 8/12/80 l

UNITED STATES OF AMERICA NCCLEAR REGULATORY CO!!!!ISSION 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) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Interrogatories From Steven C. Sholly on Revision 2 of the Emergency Plan", were served upon those persons on the attached Service List by deposit in the United States mail, posrage pre-paid, this 12th day of August, 1980.

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e " 7 De11ssa E. R1Agvay G Dated: August 12, 1980 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING SCARD In the Matter of )

1 )

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Ia in, Esgaire Chai= an Assistant Ccunsel Atmic Safety ard Licensir4 Pennsylvania Public L+mef Cer:n'n

! Scard Panel Pest Office Sex 3265

U.S. !Mclear Pagulatcry hission Harris u.g, Pennsylvania 17120 5

Washingten, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atenic Safety ard Licensing 505 Executive Ecuse l Scard Panel Pcst Office Sex 2357 l .881 West Cuter Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 Jchn E. Minnich Dr. Linda W. Little Chairnan, Dauphin Ccunty Scard Atxic Safety and Licensirs of Ca missicners Scard Panel Dauphin Ccunty Courthcuse .

5000 He=nitage Drive F=:nt ard Parket Streets Paleigh, Nc: th Carolina 27612 Harrisburg, Pennsylvania 17101 James R. 'Iturtellotte, Esquire Walter W. Cchen, Esquire l

Office of the Executive Iagal Directer Cersaner ,2,u:a'a U. S. Nuclear Pagulatory Ccmnission Office of Cersaner Mvoca*a Washington, D.C. 20555 14th Flecr, Strawberry Sq m l Ha W., Pennsyhv.ia 17127 tbcketing a:xi Service Secticn Office of the Seretary C. S. Mclear Pegulatory Ccrrissicn Washirgten, D.C. 20555

Jordan D. Cunningban, Esquire Will4 e S. Jcrdan, III, -@e Attorney for Newberry ':cwnship Attorney for Pecple Against Nuclear T.M.I. Steering Cm mittee Energy 2320 North Second Street Farren & Weiss Harrisburg, Penrsflvarda 17110 1725 Eye Street, N.W., Sui.a 506 Washington, D.C. 20006 2.eodcre A. Mler, Esgaire Widoff Peager SeIAcwit: & Mler Pebert Q. Pollard Post Office acx 1547 609 Mcntpelier Street Harrisburg, Pennsylvania 17105 Balti:ncre, Mar (land 21218 Ellyn R. Weiss, Esquire cpm:rr.ey Keptord AttcIney fer t.5e Unicn of Concerned Jui.th H. Jchnsrud Scientists Err,1rcrunental Coalition en Nuclear Ha=cn & Weiss Pcwer 1725 Eye Street, N.W., Suita 506 433 Criando Avern:e Washingtcn, D.C. 20006 State College, Penrsf1vania 16801

• Steven C. Shelly .%riin I. I4wis 304 South .%1rket Street 6504 Fradford Terrace MecPanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Mad cric M. Aamodt Holly S. Keck R. D. 5 Iagislatien Chai= nan Coatesville, Pennsylvarla 19320 Anti-Nuclear Grcup Rapresenting York 245 West Philadelphia Street Ycrk, Penrsf lvania 17404 i

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Steven C anolly 304 So,ch Market Street Meenaticsburg, Pennsylvania 17055

Dear Steve:

Enclosed is Licensee's response to your interrogatories on Revision 2 of the Emergency Plan. A copy of a signed affidavit supporting these responses is not enclosed, but will be forwarded soon.

Sincerely yours, i

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Robert E. Zahler . ,

enclosure l

cc: Service Lis:

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Lie 8/12/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEb' SING BOARD In the Matter of )

)

METROPOLITAM EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSE TO INTERROGATORIES FROM STEVEN C. SHOLLY ON REVISION 2 OF THE EMERGENCY PLAN INTERROGATORY NO. 1 Section 4.2.1.5 of the Emergency Plan (EP) has been changed.

The EP dated November 1979 (Amendment 10) states:

" Metropolitan Edison Company ha.s, in defining the Emergency Planninc :enes (EPZ) for Three Mile Island Nuclear Station, taken into consideration the information and data presented above as well as other important factors such as organizational .

capabilities, availability of emergency facili-ties and equipment, and the methods for implement-ing the TMI Emergency Plan."

Revision 2 of the EP provides:

"GPU Nuclear Corporation has, in defining the .

Emergency Planning Zones (EPZ) for Three Mile Island Nuclear Station, taken inte consideration the information and data presented above, guidance provided by the Pennsylvania Emergency Management Agency, and other important factors . . . "

With regards to the ". . . guidance provided by the Pennsylvania Emergency Management Agency . . .", provide dccumentary records (including, but not limited to memoranda, notes, letters, reports, records of telephone calls and/or meetings) which descri:.c or dis-cuss the referenced " guidance" from PEMA. Further, to the extent

I l that such documentary record.3 are in the possession of Licensee, i provide documentary records which contain analyses or evaluations of the PEMA guidance, whether such analyses or evaluations were conducted by Licensee employees, contractors, consultants, or those of General Public Utilities Corporation or General Public Utilities Service Corporation. In the event that appropriate documentary records do not exist, describe in writing the guid-ance from PEMA, including analyses and/or evaluations of that guidance. Identify persens in the employ of Licensee, GPU, and/or GPUSC who have direct knowledge of the PEMA guidance and/or analy-ses or evaluations thereof. Identify the person or persons at PEMA who provided the guidance and the authors of the guidance,

• if known.

RESPONSE

The guidance provided by the Pennsylvania Emergency Management Agency ("PEMA") on the extent of the 10- and 50-mile EPZs is reflec-ted in the Commonwealth of Pennsylvania Disaster Operations Plan, Annex E, Fixed Nuclear Facility Incidents. Relevant information from that document on the extent of the plume exposure EPZ is summarized below.

(a) Fixed nuclear facility incident consequences may require protective action of up to 10 miles and may require actions for agricultural, dairy and food 1

product control up to 50 miles (S IV.A). l (b) The 10-mile evacuation distance includes an adequate safety margin which precludes the need for evacuation of institutions, facilities or people be-yond the 10-mile radiu.= (S IV.F).

(c) The " risk crea" around the TMI site is de-fined as a 10-mile radius including the counties of Dauphin, Lancaster, York, Cumberland and Lebanon (Appendix 1, p. 1-4).

(d) The State ?lan incI les a discussion of site characteristics aroun the TMI site (Appendix 4,

pp. 4-7 to 4-12).

(e) The State Plan includes an evacuation plan map (with routes, traffic volume, and time estimates) that covers the 10-mile area and beyond (Appendix 6A).

The State Plan also includes material on agriculture control out to 50 miles (Appendix 7). Aside from this information, Licensee possesses no other " documentary records" relating to this matter.

Licensee has performed no formal analysis or evaluation of this information. Licensee, however, believes that the EPZ boundaries used by PEMA, and the factors considered in developing those boundaries, are consistent with NRC guidance provided in NUREG-0396, NUREG-0654, the NRC Policy Statement on EPZ, and the emergency planning rule recently adopted by the Commission.

Mr. George Giangi, Emergency Planning Coordinator at TMI, has direct knowledge of the PEMA guidance. The " author" of the State Emergency Plan i's PEMA, Division of Plans. Mr. James Lothrop is the head of that division. Licensee's chief contact at PEMA on the State Plan has been Mr. Lamison.

INTERROGATORY NO. 2 Section 4.3.1.1 of the EP has been changed. The EP dated November 1979 (Amendment 10), states:

"In summary, the TMI Emergency Plan provides:

1. A means for classifying emergency conditions in a manner compatible with a system utilized by State County emergency response agencies and organizations."

Revision 2 of the EP provides:

"In summary, the TMI Emergency Plan provides:

1. A means for classifying emergency conditions."

Coes this alteration imply that Licensee's classification of emergency conditions is incompatible with State and County emer-gency response agencies and organizations' classification scheme?

If so, identify the agencies and organizations which utilize a classification scheme which is different from the scheme used by Licensee; detail the differences; and explain how the public health and safety is adequately protected by these differing classification schemes when such differences could lead to mis-interpretation.of the severity of an emergency (and potentially leading such agencies and organizations to mistakenly fail to call for protective actions, or mistakenly call for protective actions when none are required). If differences in classification schemes exist, has Licensee entered into negotiations with these agencies and organizations in order to arrive at a mutually agree-able classification system? If not, why not? If so, describe the status of these negotiations and detail any changes which have been made or will be made prior to Restart.

RESPONSE

The change to Section 4.3.1.1.1 of the Emergency Plan does not imply that Licensee's classification of emergency conditions is in-compatible with the scheme used in the stata and county plans. To the contrary, as revised Section 4.4.2 explicitly states, all classification schemes are now identical. At the time Revision 1 of the Plan was submitted, Licensee had adopted the NUREG-0610 1

I classification scheme; the state and county plans had not yet made this change, although adoption of the NUREG-0610 scheme was anti-l cipated. Therefore, Section 4.4.2 of the old plan indicated that a correlation between Licensee's plan and the state / county plans was necessary. The su= mary section cited in this interrogatory reflected this difference by noting that Licensee's scheme was l

l "ccmpaticle" with the state / county scheme. This was dropped in Revision 2 since the classification schemes were now identical.

l No response is necessary for the other questions posed in this interrogatory.

1

5-INTERROGATORY NO. 3 Section 4.4.1.1 of the EP has been changed. The EP dated November 1979 (Amendments 6 and 10) states:

"The emergency action levels that shall require an Unusual Event declaration include (but are not neces-sarily limited to) the following:

2. Any reactor trip followed by an unanticipated automatic ECCS actuation."

Revision 2 of the EP provides:

"2. Any reactor trip followed by an unplanned auto-matic ECCS actuation."

How does an " unanticipated automatic ECCS actuation" differ from an " unplanned automatic ECCS actuation"? Explain why this wording has been changed. Does the new wording tend to result in fewer Unusual Event declarations than the old wording? If so, explain why.

RESPONSE

In making this change, Licensee did net intend to alter those events for which an Unusual Event might be declared. Rather, the change was made to alleviate a possible ambiguity in m'eaning of the word " unanticipated". The concern was that under certain con-ditions operators might view an automatic ECCS actuation as anti-cipated although unplanned. This situation might occur, for l example, if plant trips of a certain type routinely caused an

! automatic ECCS actuation when no such actuacion was planned for.

i In such cases, an operator might reason that the routine occur-i rence no longer made such actuations " unanticipated". To clarify that an Unusual Event should be declared in such situations, the l word " unanticipated" was changed to " unplanned".

INTERRCGATORY NO. 4 Section 4.4.1.2 of the EP has been changed. The EP dated l

November 1979 (Anendment 10) states:

"The emergency action levels that shall require an Alert to be declared include (but are not necessarily limited to) the following:

10. Loss of all offsite power coincident with loss of both diesel generators."

Revision 2 of the EP provides:

"10. Loss of all offsite power coincident with the failure of both diesel cenerators to start for less than 15 minutes.

11. Loss of all onsite DC power for less than 13 minutes."

Explain the bases for these changes. Include within your explana-tion the reasons why these changes are more conservative than the old wording. Further, explain the significance of the 15-minute time period cited in both new statements in terms of its impact on the safety of the plant and the status of engineered safeguards features.

RESPOUSE The changes cited in the interrogatory have the effect of making the emergency action levels more precise and more conserva-tive.

In Revision 1 to the Emergency Plan the following scheme existed:

(a) Loss of offsite power and no power from the diesel generators -- declare an Alert.

(b) In addition, if no vital AC and CC power --

declare a Site Emergency.

In Revision 2 to the Emergency Plan the following scheme exists:

(a) Loss of offsite and no power from the diesel generators -- declare an Alert.

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(b) If this ccndition exists for more than 15 minutes -- escalate to a Site Emergency.

i

(c) Loss of vital DC power -- declare an Alert.

(d) If this condition exists for more than 15 minutes -- escalate to a Site Emergency.

These changes are likely to result in an event being placed in a higher classification than the earlier draft. For example, if offsite power and the diesel generators were lost, under the old plan that event would be an Alert regardless of the length of the event, unless the Emergency Director escalated the event to a Site Emergency on his own discretion. Under the new scheme, escalation to a Site Emergency must occur if AC power is lost for longer than 15 minutes. Similarly, loss of DC power triggered the Emergency Plan only if all AC power also was lost. Under the re-vised plan, loss of vital DC power alone is sufficient to trigger an Alert and possibly a Site Emergency.

The 15-minute interval represents an engineering judgment as to the severity of the event. If power is regained within 15 l minutes, damage to the reactor is unlikely. Even after 15 minutes, i reactor damage is not likely for a substantial period of time.

l However, an extended loss of power does represent a failure of plant functions warranting declaration of a Site Emergency.

INTERRCGATORY NO. 5 Section 4.4.1.2 of the EP has been changed. The EP dated November 1979 (Amendment 10) states:

"The emergency action levels that shall require an Alert to be declared include (but are not necessarily limited to) the following:

14. Tornado warning."

1

Revision 2 of the EP provides:

"15. Any tornado striking the facility."

Explain the bases for this change, including within your explana-tion why the new wording is more conservative than the old wording.

RESPONSE

The change adopts the language of NUREG-0610, which lists

"[a]ny tornado striking the facility" as an Alert. The change is also consistent with the degree of severity of the other natupal._

phenomena listed as Alerts. A tornado warning does not constitute either an actual or potential substantial degradation of the level of safety of the plant, and therefore is inappropriate for listing as an Alert.

INTERROGATORY NO. 6 Section 4.4.1.2 of the EP has been changed. The EP dated November 1979 (Amendment 10) contains no provision for the declara-tion of an Alert based upon off-site gamma dose levels (actual measured levels). Revision 2 of the EP provides:

"23. Offsite radiological monitoring reports of 1 10mR/hr (gamma) at any location."

Other provisions in the EP in this secrion provide for une declara-tion of an Alert when exclusion boundary doses are cilcalated (based on conservative adverse meteorology circumstances) to equal or ex-ceed 10 mR/hr (gamma). The provision for an Alert declaration based upon a field measurement of an actual dose rate as opposed to a calculated dose rate based on conserFative assumptions is not as conservative as relying on the calculation. Why does this incon-sistency exist in the provisions for declaration of an Alert? Why should not an actual measurement of a dose not cause a higher level of classification to be initiated?

RESPONSE

Including an actual offsite monitoring report of 110 mR/hr (gamma) as an Alert is consistent with Licensee's classification scheme. As indicated in Section 4.4.1 there is a direct correla-tion between Licensee's emergency action levels ("EAL") and the

protective action guides I' PAG"). This relationship is listed below:

Fraction of PAG Alert .01 Site Emergency .05 General Energency .1 Cn this basis, a Site Emergency is declared if, for example, calculated doses using adverse meteorology are projected to equal or exceed 50 mR/hr (gamma) or 250 mR (thyroid) (S 4.4.1.3 nos. 9, 10 & 11) , or if actual offsite monitoring reports equal or exceed 50 mR/hr (gamma). Similarly, Revision 1 required declaration of an Alert if calculated doses using adverse meteorology projected doses equal to or exceeding 10 mR/hr (gamma) or 50 mR (thyroid).

In order to complete this scheme, an offsite monitoring report of 10 mR/hr (gamma) was added as an Alert.

This value is such a low fraction of the lower linit PAG (i.e., one one-hundredth of 1R) t." a t a higher emergency classifi-cation is not warranted.

INTERROGATORY No. 7 Appendix C to the EP, Revision 2, does not contain, contrary to statements made in Section 4.5.2.1, a letter of agreement from Radiation Management Corporation. Provide a copy of the most recent letter of agreement with RMC. If older than two years from the date of the plan, explain why.

RESPONSE

An updated RMC letter of agreement was unavailable in early June 1980, when Revision 2 of the E=ergency Plan was submitted.

Attached hereto is the RMC letter of agreement dated June 19, 1930.

INTERROGATORY NO. 8 Section 4.6.3.5 of the EP, Revision 2, references procedures in the Emergency Plan Implementing Procedures which are used to make contingency dose calculations in the event that instrumenta-tion used for radiological assessment is off-scale or inoperative.

Are these procedures available in Licensee's Reading Rcom? Have they been approved by the PORC since the TMI-2 accident began on 28 March 1979? Do the referenced procedures account for the poten-tial for an accident to release quantities of radiation equiva-lent to those released during the TMI-2 accident? If not, explain in detail why not. If so, specify how such a release is accounted for in the procedures. Further, when such contingency dose cal-culations are used, is this fact reported to PEMA and/or BRP?

If" not,'IHiy not? If so, what information is provided under such

~

circumstances to enable the agency to determine that the correct choice of contingency dose factors has been made?

RESPONSE

This procedure is available in Licensee's Discovery Reading Room. It is undergoing final review and approval by PORC. The procedure specifies five different release scenarios, one of which is to be chosen by the Emergency Director on the basis of his understanding of the emergency event. The Case I LOCA included in the procedure assumes severe core damage and fuel melting.

Releases are based on the assumptions set forth in Regulatory l

Guide 1.4. These postulated releases lead to offsite doses greater i

i i than those experienced during the Unit 2 accident. The results of

(

l the contingency dose calculations are provided to the Radiological i

Assessment Coordinator who is responsible for communicating this I

information to BRP. Since BRP also is provided with operational l information, they will be able to determine for themselves that a correct choice of contingency scenarios has been made.

INTERROGATORY NO. 9 Section 4.6.3.5 of the EP, Revision 2, references procedures in the Emergency Plan Implementing Procedures which are used as a

basis for the notification of downstream water users if projected concentrations of radionuclides in the river water exceed. levels specified in the procedures. Are these procedures in Licensee's Reading Room? Have they been approved by the PORC since the TMI-2 accident began on 28 March 1979? Specify the levels which must be exceeded before notification of downstream users takes place. Provide a list of all such users, including name, address, and telephone numbers. Specify the basis for the levels in the procedures, referencing specific documents which support the levels used.

RESPONSE

The referenced procedure is in Licensee's Discovery Reading Room. It presently is undergoing final review and will in the near future be submitted for PORC approach. The procedure specifies the levels which must be exceeded before notifications are made.

Since these levels have not yet been finally specified, Licensee is unable to specify their bases. This information will be pro-vided in a supplementary response. The downstream users are identi-fied in the procedure. Their telephone numbers are included in the Additional Assistance and Notification Procedure (although telephone numbers have been deleted frcm the Discovery Reading

! Rocm copy of this procedure).

INTLRROGATORY !J. 10 l Section 4.6.5.1 of the EP, Revision 2, is expanded from the EP dated November 1979 (Amendments 6 and 10), by providing speci-fic guidance on protective actions for sheltering and evacuation.

This guidance is contained on page 6-13 of Revision 2 of the EP.

What are the bases for these considerations contained in the EP as specified above? Identify specific references (including title, publisher, date, and authors) which support these considera-tions. Also, identify and provide copies of documentary records in the pcssession of the Licensee, GPU, and/or GPUSC relating to these considerations, and any analyses or evaluations which support their use.

RESPONSE

The referenced guidance is based on informacion included in the 3RP Plan (Appendix 8 to the State Plan) and in interrogatory

responses by BRP in this proceeding. This guidance draws upon the EPA Manual for Protective Action Guides.

INTERROGATORY NO. 11 Section 4.6.5.1 of Revision 2 of the EP states:

"The means to warn or advise persons involved is desig-nated a responsibility of the ' Risk County ' in Annex E of the State's Disaster Operations Plan."

Contrary to this, page 3-1 of NUREG-0654, which Licensee's Emer-gency Plan references as being complied with in Revision 2, states as follows:

"NRC and FEMA recognize that the responsibility for activating the prompt notification system called for in this section is properly the responsibility of the State and local governments. NRC and FEMA also recognize that the responsibility for assuring that l the means exist for putting such a system into place l rests with Facility Operators."

Has Licensee complied with the quoted requirement from NUREG-0654?

If so, specify how Licensee has determined that the facilities for prompt notification exist, referencing and providing copies of

studies supporting Licensee's position. Further, describe how Licensee reconciles the quoted statement from Revision 2 of the EP with the NRC/ FEMA requirement quoted above.

RESPONSE

The interrogatory assumes that the quoted language from NUREG-0654 is an "NRC/ FEMA requirement". In point of fact, the only regulatory requirements are those specified by statute or regula-tion. With respect to the warning criterien, the recently adopted eme.gency plan rule represents a change from the appecsch set forth in NUREG-0654. Licensee will comply with the requirements of the new regulation. A precise schedule for achieving com-l pliance by the date specified in the regulation has not yet been developed.

INTERROGATORY NO. 12 Section 4.6.6.3 of the EP, Revision 2, contains a provision for training of off-site emergency squad members in the treatment and transportation of contaminated injured individuals; the previous EP contained no similar provision. Descrine the train-ing provided. Will such training be provided to all potentially-involved off-site emergency squads prior to Restart? roes the training include provisions to train the squad members to avoid contamination of other persons, either en-route or wnile at a hospital #acility? If so, describe. If not, explain why not.

RESPONSE

The training to be offered to offsite support agencies is described in Sectica 4.8.1.1.4 of the Emergency Plan. In par-ticular, local medical support organizations will be offered training which includes, among other topics, basic health physics, radiological aspects of emergency medical treatment, plant pro-cedures for decontamination, RMC radiation emergency precedures, and transportation techniques for contaminated injured individuals (p. 8-5). This training will be offered prior to resrart. As indicated above, the training does include techniques to avoid contamination of other persons, both enroute and at the hospital facility. The training is being offered annually in conjunction with the annual medical emergency drill conducted by RMC, a pro-fessional medical radiation emergency management organizaticn.

INTERRCGATORY NO. 13 Section 4.7.1.2 of the EP, Revision 2, contains a provision for future installation of a CRT Monitoring System at the Techni-cal Support Center. A similar provision is lacking in the previous .

plan. When will this capability to monitor plant computer and required radiological information on a 'not-to-inte-fare-with-the-operator' basis be installed? Will installation occur prior to Re sta rt? If not, explain how such information will be trans-mitted to the TSC, describing provisions to ensure :.an pcwcr failures will not impact on the availability of such i-formation.

Similarly, Section 4.7.2.4 contains provision for a CRT s,ctam at the Parsippany Technical Functions Center (a provisica which c

lacking in the previous EP). When will this installation take ,

place? Will the installation take place prior to Restart? If l not, explain how such information will be transmitted to the ,

Parsippany TFC, describing provisons to ensure that power I failures will not impact on the availability of such information.

RESPONSE

The CPT monitoring systems referenced in the interrogatory will be installed prior to restart.

Respectfully submitted, SHAW, PITT.MN, POTTS & TROWBRIDGE i

l Sy: JF o Roberg/E . 2fahlet Dated: August 12, 1980 l

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o e Lic 8/12/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY CO?O1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three l'ile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Interrogatories From Steven C. Sholly on Revision 2 of the Emergency Plan", were served upon those persons on the attached Service List by deposit in the United States mail, postage pre-paid, this 12th day of August, 1980.

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l " 7 Delissa E, ~Rifgvay 0 Dated: August 12, 1980 l

, e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION SEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

! }

l METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, T@e John A. Ievin, Esqaire Chai=an Assisunt Counsel Atcmic Safety ard Licensing Pennsylvania Public Utility Cm m'n Board Panel Post Office Bcx 3265 U.S. Nuclear Regulatcry h ission Harrisburg, Pennsylvania 17120 Washingt n, D.C. 20555 Karin W. Carter, Esqaire Dr. Walter H. Jordan Assistant Attorney General Atcmic Safety ard Licensing 505 Executive Ecuse Board Panel Post Office Bcx 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 Jchn E. Minnich l Dr. Linda W. Little Chai_-.:an, Dauphin Ccunty Ecard Atcmic Safety and Licensirs of Ca missicners Board Panel Dauphin Ccunty Courthouse -

5000 Heritage Drive Front and Parket Streets Paleigh, North Carolina 27612 F r A ,7 Pennsylvania 17101 James R. Tourtellotte, Esgaire Waltar W. Cchen, E@e Office of the Executive Legal Director Censumer 2 n:ste

, U. S. Nuclear Pegulatory Ccmrissicn Office of C::nsumer 20:ste Washingten, D.C. 20555 14th Flocr, Strawberry Square Harra.sharg, Pennsylvania 17127 Docketing and Service Secticn Office of the Secretary C. S. :Mclear Pegulatcry Ccrrission Washirsten, D.C. 20555

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e o Jordan D. CLmningham, Esquim Wil14= S. Jordan, III, EsquLm Attcrney'for Newberry h nship Attorney for People Against htclear T.M.I. Steering Cm mittee Ene.g 2320 R rrh Secord Street H L m & Weiss Harrisburg, Perrsf h ania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Thecdcre A. Mler, Esquim Widoff Psager Selkcwit: & Mler Pcbert Q. Pol'a d Post Office Box 1547 609 Man *A-er Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218

{ Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Unicn of Ccncerned Judith H. Jchnsrud Scientists Emri.w.7tal Coalition en Nuclear Harnen & Weiss Power 1725 Eye Street, N.W., Suite 506 433 criando Avenue Washington, D.C. 20006 State (bliege, Pennsylvarla 16801

• Steven C. Shelly Pa: vin I. Lawis 304 South Market Street 6504 Eradford Terrace Mechanicsburg, Pemsylvania 17055 Ph.tladelphia, Penrsflvarda 19149

! Gail Bradford Parjorie M. Aaredt Holly S. Keck R. D. 5 I.egislatien Chai=ran Ccatesville, Pennsylvania 19320 Anti-Nuclear Grcup Fapresentirq York 245 West Philadelphia Street York, Pe=sylvaria 17404 t

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