ML19345F387

Testimony of Re Rogan,Gj Giangi & a Tsaggaris Re Adequacy of Onsite Emergency Preparedness,Vol 2,figures,tables & Apps

ML19345F387
Person / Time
Site:	Three Mile Island
Issue date:	02/09/1981
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML19345F365	List: ML19345F364 ML19345F367 ML19345F384 ML19345F387
References
NUDOCS 8102170376
Download: ML19345F387 (69)

Text

,

Lic 2/9/81 l

l 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 TESTIMONY OF ROBERT E. ROGAN, GEORGE J. GIANGI AND ALEXIS TSAGGARIS ON THE ADEQUACY OF ONSITE EMERGENCY PREPAREDNESS AT THREE MILE ISLAND, UNIT 1 Volume 2 -- Figures, Tables and Appendices l

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TABLES i

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Planning Standard Required Corrective Action Status of Licensee's Bestonse E. Notification Establish physical and administra- Systan design engineering is couplete; Metlods and tive neans for providing pranpt siren procuramnt is ongoing; syston Procedures warning and instructions to the will be gerat lonal by July 1,1981.

public within the plume exresure pathway Bergency Planning Zone in cmpliance with Alpendix 3 of 10RIre0654.

G. Public hlucation Provide tie 150 staff with details Pa1A has the lead role and is and Information of the public information progran ocunpleting its Public Information regarding low the public will be section of the State Bergency Plan; notified and what their actions information already distributed should be in an anergency. Drafts in utility bills and by many local of this information and the means anergency managarent agencies.

of dissonination should be provided to the staff prior to restart.

I. Accident Specify the instrunentation for Additional equipnent/instnanenta-Assesment accident assessment required by tion will be g rrational prior to 10RIC-0578 as required by the restart.

Ccmnission's Festart Order of August 9, 1979.

Determino more exact assunptions Licensee is revieing present for contairment leak rates used asstmptions to determine need in dose projection. for change.

J. Protective Provide tine estimates for evacua- Evacuation tine estimate study Fesponse tions within the plume exposure to be otmpleted by mid-February; EPZ which conform with the require- information to be forwarded to ments of PURIrc0654, Appendix 4. tHC.

Establish provisions for stockpiling Awaiting Food and Druj Administra-thyroid blocking drugs for distribu- tion criteria on use of thyroid tion to onsite anergency workers. blocking drugs.

N. Exercises and 'Ihe frequency for tests of otmmunica- Fevision 3, Section 4.6.1.2 Drills tion links with States and Federal corrects this deficiency; response organizations within the quarterly cmmunication tests ingestion EPZ should be changed to at will be conducted.

least auarterly.

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TABLE 2 Number On-Shift Assignment Emergency Assignment 1 Shift Supervisor Emergency Director 1 Shift Technical Advisor Performs normal functions 1 Shift Foreman Performs normal functions 1 Control Rcom Operator #1 Operates primary plant 1 Control Room Operator #2 Communicator 1 Switching & Tagging Operates secondary plant Control Room Operator 4 Auxiliary Operators Radiological monitoring teams, fire brigade, emergency repair, plant operations 1 Radiological Controls Radiological Assessment Foreman Coordinator 1 Senior Radiological Radiological Controls Controls Technician Coordinator 2 Radiological Controls In-plant radiological Technicians controls (assess control surveys,~etc.), radio-logical monitoring teams 1 Senior Chemistry Chemistry Coordinator Technician 1 Shift Maintenance Foreman Operations Support-Center Coordinator 4 Maintenance Personnel Emergency repair, search and rescue, radiological monitoring team drivers

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TABLE 3 '

Protective Action Guides i

i Projected Whole Body Projected Thyroid Dose Gamma Dose from due to Inhalation Airborne Radioactive Materials from a Passing Plume Population at Risk (Rem)b/ (Rem)b/

General Population 1 to 5 8! 5 to 25 8/

Emergency Workers 25 125 Lifesaving , No Specific Activities 75 Upper Limit Ingestion Exposure Pathway Protective Action Guides Dose Corrr.itment to the Whole Body,~ Bone Dose Commitment to Infant Marrow or any Organ Thyroid (Rem) c/ (Rem)c/

Preventive PAG 1.5 .5 Emergency PAG 15.0 5.0

-a/

Use lower limit in absence of constraints; in no case should higher limit be exceeded in determining the need for protective action.

b/

- Source: EPA, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" (EPA-520/1-75-001, Sept.

1975), at pp. 2.3 & 2.5; Department of Environmental Resources / Bureau of Radiation Protection, " Plan for Nuclear Power Generating Station Incidents", Appendix 8 to State Emergency Plan, at p. V-2.

-c/

Source: Food and Drug Administration, Proposed Rule 21 C.F.R.

S 1090.400(c), 43 Fed. Reg. 58790, 58795 (December 15, 1978); Department of Environmental Resources / Bureau of Radiation Protection, " Plan for Nuclear Power Generating Station Incidents", Appendix 8 to State Emergency Plan, at pp.-IX-4 & IX-8.

, 17-MPENDIX A -- PROFESSIONAL QUALIFICATIONS l

.u ROBERT E. RCGAN.

Business Address: TMI Nuclear Station P. O. Box 480 Middletown, Pennsylvania 17057 Education: B.S. (with honors), Chemistry, Jacksonville State College, Alabama.

M.S., Nuclear Physics, Tulane University.

U.S. Army War College, Masters Degree equivalency program in business administration, management and political science.

Experience: Manager-Emergency Preparedness, GPU Nuclear October 1980 to present. Responsible for l GPU Nuclear emergency preparedness programs at TMI and Oyster Creek nuclear power plants.

Supervised development of emergency plans to assure site planning provided an appropriate state of emergency preparedness and compliance with NRC regulations and guidance.

Senior Strategic Analyst and Study Group Manager, U.S. Army, June 1977 to October 1980.

Managed multi-disciplinary teams performing research and analysis concerning national strategic issues.

Commander, U.S. Army Recruiting District, Omaha, Nebraska, June 1975 to July 1976.

Senior executive of U.S. Army's second largest recruiting district. Responsible for all management, administrative, operational, training and logistic functions.

Commander, U.S. Army Mechanized Infantry Battalion, November 1973 to June 1975. Also served as Chief of Staff and Executive Officer

for headquarters and subordinate organizations.

Senior Operating Executive and Project Manager, U.S. Army, July 1970 to July 1973. Responsible for supervising and coordinating joint nuclear research and development programs.

Senior Operations Officer, U.S. Army Combat Brigade, Vietnam, July 1969 to July 1970.

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GEORGE J. GIANGI Business Address: TMI Nuclear Station P.O. Box 480 Middletown, Pennsylvania 17057 Education: B.S., Chemistry, Syracuse University, 1974.

Candidate for M.S., Inorganic Environrental Chemistry, Rensselaer Polytechnic Institute (course work completed,1978; thesis submitted).

Training: Radiation Emergency Seminar, Southern Science Applications, Inc. (1/30/81 -

2/1/81) .

Primary Management of Radiation Injury Course, Northwestern University Medical School (11/80).

Emergency Planning Seminar - Mississagua Evacuation, NUS Corporation (11/80).

Emergency Preparedness Workshop, Institute of Nuclear Power Operations (10/80).

Public Notification Systems Seminar, Federal Signal Corporation (9/80).

! Radiation Medical Emergency Course, Radiation Management Corporation (9/80).

Radiological Emergency Response Course, i

Nuclear Regulatory Commission / Federal Emergency Management Agency (6/80).

l Experienca: Supervisor - Emergency Preparedness at Three Mile Island, November 1980 to present.

Emergency Plann3ng Coordinator at Three Mile Island, February - November 1980. Responsible for preparation of revised Emergency Plan and-Implementing Document for Three Mile Island Nuclear Station, and for ensuring compliance with NRC emergency preparedness requirements in areas such as public early warning systems, evacuation time estimates, radiological dose assessment, post-accident in-plant sampling, emergency drills and exercises,_and emergency plan training.

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Manager - Chemistry, Salem Nuclear Generating Station, July 1979 -

February 1980. Responnible for all chemistry controls at Salem Nuclear Station.

Health Physics / Chemistry Supervisor, Salem Nuclear Generating Station, January -

, July 1979. Supervised health physics program, including exposure permits; radiation, contamination and airborne surveys; and radiological postings.

Supervised chemistry program, consisting of analysis of primary and secondary chemistry parameters and issuance of environmental reports and radioactive release reports.

Auditor - Chemistry and Radiological Controls, Knolls Atomic Power Laboratory, 1978. Evaluation of all areas of chemistry and radiological controls at four nuclear power plants.

Chemistry and Radiological Controls Instructor, Knolls Atomic Power Laboratory, 1974 - 1978. Instructed Naval personnel in chemistry and radiological controls operations on nuclear powered ships.

Publication: " Case History: Application of Inert Resin In Mixed Bed Polishing," Presented to The Eighteenth Annual Liberty Bell Corrosion Course, October 1980, by Ralph F. Eherts and George J. Giangi.

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a nn qq ALEXIS TSAGGARIS Business Address: Energy Consultants, Inc.

121 Seventh Street Pittsburgh, Pennsylvania 15222 Education: B.S. Basic Engineering, Princeton University, 1970.

U.S. Navy Nuclear Power Training Program.

Experience: Vice President, Energy Consultants, Inc., 1980 to present. Responsible for engineering and consulting services, including engineering design, nuclear training and emergency planning.

Corporate Quality Assurance Manager, Schneider, Inc.,

Pittsburgh, Pennsylvania, 1980. Responsible for all corporate and field-site quality assurance /

control activities for nuclear and fossil power plant construction.

Director of Site Emergency Planning, Metropolitan Edison Company, 1979. Responsible for all post Three Mile Island accident emergency planning activities, including development of plans, procedures, organizations, facilities and communication systems, and the interface of these activities with NRC, state and local government agencies. Participated in hearings before the Advisory Committee on Reactor Safeguards and the Pennsylvania House Select Committee on Three Mile Island.

Supervisor of Maintenance, Metropolitan Edison Company, 1978. Responsible for all maintenance activities at a 3-unit coal fired generating station.

Director of Training / Supervisor of Nuclear Training, Metropolitan Edison Company, 1976 to 1978. Responsible for all training activities for generating station and corporate engineering personnel. This included all NRC required operations, maintenance and health physics programs at the Three Mile Island nuclear station. Planned, coordinated and executed the annual radiation emergency exercises.

Officer, U.S. Navy, 1970 - 1976. Trained at naval nuclear power school, prototype and submarine school.

Positions held included Staff Training Officer,. Lead.

Engineering Officer of the Watch at the DIG prototype plant, and various division officer positions aboard a fleet ballistic missile subrarine. Cualified as Chief Engineer, l

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<d APPENDIX B -- ABBREVIATIONS i

e i

i

~ . L Abbreviations

1. AEOF - Alternate Emergency Operations Facility

2. ANI - American Nuclear Insurers

3. ARAC - Atmospheric Release Advisory Capability System

4. B&W - Babcock & Wilcox

5. BRP - Pennsylvania Bureau of Radiation Protection

6. DGI - Digital Graphics Incorporated

7. EAC - Environmental Assessment Coordinator

8. EACC - Environmental Assessment Command Center

9. EAL - Emergency Action Level

10. EBS - Emergency Broadcast System

11. ECC - Emergency Centrol Center

12. ENS - Emergency Notification System

13. EOC - Emergency Operations Center

14. EOF - Erergency Operations Facility

15. EPA - Environmental Protection Agency

16. EPIP - Emergency Plan Implementing Procedure

17. EPZ - Emergency Planning Zone

18. FEMA - Federal Emergency Management Agency

19. FSAR - Final Safety Analysis Report

20. GPU - General Public Utilities

21. HPN - Health Physics Network Line

22. INPO - Institute of Nuclear Power Operations

23. MIDAS - Meteorological Information and Dose Acquisition System

24. NAWAS - National Warning System

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_2_

25. NRC - Muclear Regulatory Commission

26. OSC - Operations Support Center

27. PAG - Protective Action Guide

28. PEMA - Pennsylvania Emergency Management Agency

29. PennDOT - Pennsylvania Department of Transportaticn

30. PSP - Pennsylvania State Police

31. RAC - Radiological Assessment Coordinator

32. REMP - Radiological Environmental Monitoring Program

33. PMC - Radiation Management Corporation

34. TFC - Parsippany Technical Functions Center

35. TLD - Thermoluminescent Dosimeter

36. TMI - Three Mile Island Nuclear Station

37. TSC - Technical Support Center l

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GO MPENDIX C -- ONSITE EMERGENCY &LANNING CONTENTIONS l

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, s_ , tr NUMERICAL LIST OF ONSITE EMERGENCY PLANNING CONTENTIONS EP-1 EP-3(C)

EP-4(B)

EP-4(C)

EP-4(D)

EP-4(E)

EP-4(F)

EP-4(G)

EP-4(H)

EP-4(I)

EP-4(J)

EP-7 EP-8 EP-5 EP-15 ( A)

EP-15(B)

EP-15(C)

EP-15 (D)

EP-15(E)

EP-15 (F)

EP-17(A)

~ EP-17 (B)

EP-18 I[-

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EP-1 (Aamodt)

It is contended that licensee has not made provision for timely dissemination of information in the event of accidental release of airborne radioactive gases or particulates. It is contended that licensee must make information available to the public which will allow appropriate action to be taken to pro-tect persons, livestock, foodstuff and feed in the event of a discharge of significant proportions. All data and plant operating personnel observations relative to all radioactive releases must be transmitted i==ediately and simultaneously to the NRC, Pennsylvania Department of Environmental Resources, the co=missioners of Dauphin, York and Lancaster Counties and the licensee's management. It is further contended that licensee must provide this capability before restart of TMI-1.

i EP-3 (ANGRY)

The conditions set forth in the NRC's August 9 Order (44 F.R. 47821-25) for TMI-l's resu=ption of operation are insuf-i l

l ficient to provide reasonable assurance that such resumption can occur without endangering the putlic health and safety for the reason that they fail to require the development and effec-l tuation of adecuate and effective Radiological Emergency Response l Plans to protect the population surrounding TMI-l from the conse-i quences of any future nuclear accident. Such insufficiency is in particular demonstrated by the following flaws:

3(C) The NRC's vague instruction to the licensee to "up-grade" in generally unidentified respects its "Off-site monitoring capability" is insufficient to assure

.Cr ;

l that such upgrading will result in the ability to obtain and analyze the type and volume of information essential for protection of the public health and safety. ANGRY contends that such capability must at minimum encompass the following elements or their equivalent; (1) Permanent offsite monitoring devices which l

register all forms of ionizing radiation and which can be remotely read onsite.

(2) Information analysis capability equal to or greater than that provided by the Atmospheric Release Advisory Capability System (ARAC).

This contention now challenges the adecuacy of the licensee's MIDAS radiological assess-ment system (EP, p. 6-9) to the *xtent that the information analysis capability it pro-vides does not equal or exceed that provided by the ARAC system.

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EP-4 (ANGRY)

The licensee's Emergency Plan (EP) fails to satisfy reason-able and applicable standards of adequacy and effectiveness in  ;

l l the'folicwing principal respects:

4 (3) The perfunctory form letters found in Appendix C to licensee's EP provide no indication, let alone assur-l l

l ance, of the existence of "=utually acceptable l

criteria" for impler.entation of emergency measures

as required by Emergency Planning Review Guideline No. One, Revision One (EPRG) IV(A) (1) . Also N. 0654 A3.

4(C) The adoption of the Commonwealth of Pennsylvania Disaster Operations Plan Annex E (DOP) designation of "the risk county' as responsible for the prepara-tion and dissemination of information material on protective actions to the general public" (p. 6-8) l conflicts with the requirements in EPRG I!(A) (7) l 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 hou the" can expect to be ad-vised what to do.

Also, N. 0654 G4.

4(D) The licensee's "Onsite Emergency Organization" (Sec.

4.5.1.3) contains insufficient personnel and expe:-

tise in the area of Health Physics to discharge ade-quately the responsibilities of dose assessment and projection in the event of a rapidly developing acci-dent sequence. The time requi ed for the mobiliza-tion of offsite health physics support (2-4 hrs. -

See Table 8) , which is given responsibility for i "overall assessment of the impact of liquid and gaseous effluents with respect to . . . protective action guides" (p. 5-12), is inconsistent with ade-quate radiological assessment capability.

4 (E) The licensee's EP fails to provide for furnishing to the Pennsylvania Bureau of Radiation Protection (3ORP) information called for in the latter's plan such as

s: a ;

" nature of the failure, the status of safeguards, the condition of consequence mitigating features" (p . VI-1) .

4 iF) The provisions for the conducting of a " Radiation Emergency Exercise" of the licensee (EP, p. 8-3) and of the Commonwealth (Pa. DOP, App. 14) are inadequate in that they do not clearly provide for the participa-tion therein of federal agencies. The necessity for such participation is clearly established by the ex-tensive involvement of federal agencies in the TMI accident. Second, the aforementioned cpendix to the Commonwealth's emergency plan indicates tnat "all major elements of the plans and preparedness organiza-tions" may be tested only over a period of five years.

All such elements should be tested in an exercise prior to the restart of TMI-1.

4 (G) The licensee's emergency notification procedures (pp.

6-2, 6-3, 6-4; Figure 15) (See also Pa. DOP Appendix

3) are inadequate with respect to certain areas directly at risk in the event of a nuclear accident, namely, York and Lancaster Counties. Although the Dauphin County Emergency Operations Center receives imme iate notification of an emergency declaration, notification of York and Lancaster Counties must follow an excessively circuitous path:

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1. Licensee to Dauphin

2. Licensee to PEMA

3. PEMA to BORP

4. SORP to Licensee

5. Licensee to SORP

6. SORP to PEMA l

! 7. PEMA to Dauphin

8. PEMA to York, Lancaster, and Cumberland Counties.

Such a notification sequence is in direct conflict with requirements that " delegations et authority that will permit emergency actions (such as evacuacion) to be taken with a minimum of delay should be carefully I

considered" (NUREG 75/111, 5 A3) and that "Upon declaration of a ' general emergency' immediate notifi-cation shall be made directiv to the offsite authori-ties responsible for implementing protective me 4sures s

. . ." (EPRG II(A) (5)) (Emphasis in original) . \1so,

! N. 0654 J7.

4(H) RG 1.101 Sec. 6.4 requires the licensee to specify

" criteria for implementing protective actions. . .

The licensee's EP fails to set forth the following mandatory items of information regarding the time required for protective action implementation:

! 1. Ex=ected accident assessment time.

RG 1. 7 0 ,

Sec. 13.3.1-2.

2. Time required to warn persons at risk. RG 1.101, Sec. 6.4.1-2(b); Ru 1.70, Sec. 13.3.1-3,4.

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3. Ti=e required for a general evacuation. RG 1.70, Sec. 13.3.1-5,6; Nevenber 29, 1979 letter to "All Power Reacter Licensees" frc= 3rian K. Grimes, Director, NRC Energency Preparedness Task Group.

4. Time required to evacuate special facilities (e.g. , hospitals) . Nove=ber 29, 1979 letter, supra.

See, N. 0654 J3.

4(I) The time provided in the I? for accident assess =ent, 1/2 hour (IP, p. 6-7) , is in excess of the maxi =u=

per=issible therefer specified in the Standard Review Plan, NURIG 75/087, Sec. 13,3 (II) (3) . (I? fig. 21 shews the thyrcid PAG cf 5 re=s being reached in 12

=inutes at 600 =eters.) Moreover, the esti= ate given is unsupportable for =cnitoring of off-site locations on nearby islands er en the west shcre of the Susque-hanna River. Such facecrs =ay becc=e critical in the event of a general amargency, which produces a

" shift in emphasis to greater offsite : -4.tcring I efforts" (I?, p. 6-6). (See Cont.1 icn I?-3 (C) (1) ) .

4(J) The licensee's Onsite Energency Organization staffing l

previsions as set forth in Table 8 of its IP. fail to l

confor= to the atandards of N. 0654 Sec. 35 in the following respects:

1. Under said standards two control rec = operators are assigned the function of " plant cperations and assess =ent Of Operaticnal aspects." Another l

shift employee is given the exclusive task of pro-viding ccmmunications liaison with off-site offi-cials. Under the licensee's staffing provisions, by contrast, the two control room operators are assigned to " operate equipment in control room and act as communicator" (emphasis added) . This divided responsibility compromises the licensee's ability to provide prompt off-site notification of emergency conditions. The inadeqtacy of these staffing provisions is aggravated by the absence of any provision for the addition of three more persons with communications responsibilities within 30 minutes, as required by the aforemen-tiened acceptability standard.

2. A similar confusion of assignments exists with regard to the shift supervisor and shift foreman, who are expected to fill.three roles between them.

3. Although N. 0654 requires the emergency operations I facility director to assume his assignment within l 30 minutes, under the licensee's plan this will not occur for as long as four hours.

4. Two radiological analysis support engineers, who are the only employees identified as having the training and primary responsibility for perform-ing " dose projection calculations and source term calculations" (EP, p. 5-10) will not be available for as long as 60 minutes.

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2.4 09 EP-7 (ECNP)

The fractions of EPA PAGs listed on p. 4-1 of the Plan, with their associated action levels, do not take into account the total accumulated dose and dose commitment. As a result, the total ex-posures may exceed by large margins the listed PAG fractions prior to the advancement to a higher emergency category.

EP-8 (ECNP)

The various emer ancy categories (p. 4-2 to 4-8) each list a number of triggering events or conditions. Many of these are questionable indicators. For instance, on p. 4-3, " valid" alarms are referred to. But there is no mention of the definition of a

" valid" alarm, or what would be an invalid alarm. A number of reactor coolant activities (50, 130, and 300 ci/ml) are referred to, but no mention is made of hcw much full damage it takes to i -

produce these readings. In addition, there is no indicati,on of .

how or how rapidly these coolant activities will be determined.

EP-9 (ECNP)

Reliance on " adverse meteorology" (p. 4-5, 4-6), can prove to provide little or no " built-in conservation" (p. 4-7, 4-8) since, for instance, such conditions were not at all uncommon during the nighttime in the nights folicwing the TMI-2 accident (for instance, the night of March 29, from 10 p.m. to 8 a.m.,

March 30; night of March 31, about 8:00 p.m. to 8 a.m. , April 1) .

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EP-15 (Newberrv)

Evacuation planning being done by the Metropolitan Edison Company is inadequate to insure the safety of the public, par-ticularly those persons who live within a five (5) mile radius of the nuclear power plant located at Three Mile Island, Pennsylvania.

Operation of TMI Unit No. 1 should not be resumed until a plan is in place for the evacuation of the public in the maximum area which could be affected by an accident or incident and the plans submitted by the Metropolitan Edison Company to that end are deficient as follows:

15 (A) Section 4.5.2 provides that off-site authorities would provide certain services in the event of an amergency situation. The Plan does indicate that there are agree-ments between the various personnel, organizations and agencies listed in this section; however, the agreements of most local fire ecmpanies only indicate that certain manpower is available and certain pieces cf equipment are available. Moreover, it appears as though semebody produced documents for the local fire companies to sign, which would indicate the amount of manpower and re-sources available to each one of the fire companies who signed such an agreement. The agreements with the fire companies do not state that they know exactly what will be expected of them in an emergency situation. Without a sound contractual understanding in place, it is questionable that during a crisis situation off-site 1

authorities will knew exactly what is expected of them.

_ . . . . .-_. ____ _ _ . _ _ _. . _ _ _.-_._~ . ._9' 'i Detailed understandings should be drawn between the local police, firefighting authorities and the State Police and other off-site authorities and agencies in order to ensure orderly support in the event of an emergency. The absence of such documentation and under-standing Letween Metropolitan Edison Company and off-site authorities creates a deficiency in the Emergency Plan.

15 (B) Section 4. 5.1. 3 (1) (c) (i) states that the Emergency Director shall provide liaison communication with county, state and federal governments to ensure that notification and raports to these agencies are made in a timely manner and that he will communicate with off-site emergency support organizations. It is Inter-venor's ccntention that this part of the Plan which is critical to the coordination af all emergency activities does not state with specificity the exacc timeframe in which notification and ccmmunication is to be made with off-site emergency support organi ations and agencies.

l It is Intervenor's position that thi s is critical in order to ensure that licensee reports and ecmmunicates any abnormal and emergency condition to the respective organizations in a truly timely fashion. The Emergency Plan as now drafted leaves too much discretion with the l Emergency Director with regard to the contacting of these off-site agencies.

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15(C) Section 4.5.3.2 of the Emergency Plan irdicates that with respect to the 10-mile EPZ, the five counties identified in this section have c.re,b.ared emergencv_

l plans that are ccordinated with the State Dis' ester Operations Plan and with the TMI Emergency Plan as well.

It is Intervencr's centention that this obviously cannot be the case, since revision #2 of this Plan is dated June, 1980 and that the county plans still are-not adopted as final drafts. Moreover, a review of the' Dauphin County and York County Plans indicate there is absolutely no referencing to the TMI E=ergency Plan and that, in fact, it appears as though the county plans were written independently of the TMI Emergency Plan.

All plans must inter-ccordinate in order to ensure that i

all parties participating in the emergency will knew J

j what is expected of them. There is no provision in the Emergency Plan for the distribution and updates of the TMI E=ergency Plan and, based upon these deficien-cies, the Emergency Plan as new written is inadequate.

1ED) Section 4.5.4 of the E=argency Plan anticipates that f the Pennsylvania E=ergency Management Agency will con-i duct and participate in annual training exercises thst involve state, county and local government agencies and that the testing of ce=munications, radiological =oni-toring instrumentation and warning systems will be con-ducted. It is Intsrvencr's centention that at the l

present time, such ccmmunications, radiological l

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l monitoring instrumentation and warning systems are either not in place within the surrounding ce=munities or are not being maintained by operators within sur-rounding local ccmmunities. The Plan does not indi-cate who is responsible for the purchasing of ccmmuni-cation, radiological =enitoring instrumentation and warning systems and, furthermore, who is responsible for the maintaining of this equipment. The Commonwealth of Pennsylvania did begin a radiological =enitoring effort; however, since local monitoring readers were instructed as to how to read the monitors, the Common-wealth' of Pennsylvania has not been soliciting their readings and/or following up to determine whether the readings are being made by the readers. Is this burden to be shouldered by the local co== unity, the county, the state government or the licensee? It is Intervenor's contention that while emergency plans may, in theory, set forth a plan of training, it cannot realistically l

l be put in action because the Plan t;.cmes placement of communications systems, radiolcgical monitoring instru- -

! ments and warning systems. It is Intervenor's position j that until such systems are in place, it is determined who is responsible for the eq ment's maintenance and who is to burden the cost of .he placement and mainten-ance of such systems, the Plan is inadequate and un-acceptable.

15 (E) Section 4.6.5. l(2) of the E=ergency Plan provides that l

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. au the responsibility for actions to protect persons in l l

l the off-site areas rests with the Ccemonwealth of Pennsylvania and that the Pennsylvania Emergency Manage-ment Agency shall be the agency with which the responsi-bility rests for the placing, in effect, of protective options such as evacuation, sheltering and thyroid prophylaxis. The same section indicates that in the event of a general emergency, precautionary measures may be taken such as sheltering, evacuation and evacua-tion of certain sectors based upon wind speed and direc-tion. It is again Intervenor's contention that this particular section of the Emergency Plan providing for the precautionary =easures cited have not been coor-dinated with local county plans to any measurable ex-tent. For example, in the county plans, there is no indication of how the counties would instrue: its local Civil Defense Directors to evacuate only certain sectors within a community instead of within radial distances of the Three Mi.'e Island nuclear facility. This is again only bt one example of a lack of coordination between the Emergency Plan and the various county plans and it l

is Intervenor's position that this lack of coordination is symptomatic of the entire Emergency Plan as it is now written. The Emergency Plan submitted by the licensee should encompass a total coordination of all Emergency Plans formulated by federal, state and counry agencies. This lack of coordination creates a deficiency which has to be remedied.

._ _ . .. . . _ . 9 15 (F) Section 4.6.7.1 of the Emergency Plan deals with early warnings and information for transient areas. It is Intervenor's position that the methods depended upon in the Emergency Plan to warn the population at risk, are, at the present ti=e, not in place. For example, sec-tion 2 of this particular section of the Emergency Plan states that a siren alert system could be activated by counties in order to warn the populace of i=pending danger. As has been indicated earlier in Intervenor's contention with regard to Emergency Planning, there are not enough Civil Cefense warning sirens in order to adequately ensure that all members of the community are within hearing distance of the siren. Moreover, section 5 of this subsection of the Emergency Plan indicates that vehicles with loudspeakers could be dispatched to l broadcast warning messages. The problem with this ap-I proech is that it would take time to get volunteers to man the vehicles and, secondly, there are many miles l

of road which would have to be traveled in order to ensure that all mambers of the populace were informed of the impending emergency condition. It is Intervenor's contention that until the Emergency Plan specifically states that a siren alert system '.s in place and that the warning emitted by the siren alerts could be heard at any point in the county surrounding the plant site, the Emergency Plan as now drafted is unacceptable.

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l EP-17 (Shellv)

Defects in Licensee's Emergency Plan, Revision 2, June 1980 17(A) Licensee's acceptance, without formal analysis or l evaluation, of a circular 10-m11e radius for the Plume Exposure Emergency Planning Zone (as designated by the Pennsylvania Energency Management Agency) does not dis-charge Licensee's responsibility to ensure that ade-quate emergency response plans exist to protect the public health and safety in the event of an emergency at TMI-1. Further, acceptance of or designation of a circular 10-mile radius Plume Exposure EPZ for TMI-l is unjustified because such an EPZ fails to adequately consider local emergency response needs and capabili-ties as they are affected by demography and jurisdic-tional boundaries. These considerations, among others, are specified in ImREG-0396, ITUREG-0654, and the new emergency planning rule published in the Federal Register on August 19, 1980. The following specific local conditions should be reflected in the Plume Ex-l posure EPZ for TMI-1:

1. The proposed 10-mile radius circular EPZ includes within the EPZ portions of numerous jurisdictions at the township, city, borough, and town levels of government. Calling for an evacuation of only I

a portion of any political jurisdiction due to a hazard which affects a large geographic area and

bacing emergency plans and response capabilities l

l on such a limited evacuation will lead to problems

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i due to spontaneous evacuation of a much larger area, with a concommitant increase in traffic and supply requirements at shelters. Therefore, the Plume Exposure EP: for TMI-l should include the entire geographic extent of all governmental jurisdictions at the township, city, borough, and

town level which are bisected by the proposed circular 10-mile IP:.

2. There are heavily populated areas in and near the cities of Harrisburg and York represented by the city proper and adjacent continuation of the urban areas into the suburbs. In the event that the l wind is blowing toward either of these areas when a large release of radioactivity occurs, such areas would constitute a large percentage of the total population dose (in the case of the TMI-2 accident, for instance, Harrisburg contributed 25% of the total population dose despite the fact that most of the city is more than 10 miles distant from the plant). The urbanized areas in and around Harrisburg and York are concentrations of population for which preplanning for an evacuation is a necessity for successful implementation (for instance, preplanning would have to include evacuation routes, transpcrtation needs, host area requirements, and problems posed by special populations such as prisons). Therefore, the urban-1:ed areas around and including the cities of Harris-

a. m .

y . . - ,

burg and York should be included within the Plume Exposure EPZ for OiI-1.

3. Numerous members of the Old Order Amish community reside in relatively close prcximity (within 10 miles) of tha cuter boundary of the Licensee's Plume Exposure EPZ in Lancaster County. Because the Old Order Amish eschew the use of electricity, telephones, and automobiles, they present unique problems with respect to warning, communication of protective action advisories, and transportation.

These unique problems warrant the special considera-tion the inclusion of Old Order Amish within the Plume Exposure EPZ would provide.

4. To the extent that the Licensee relies upon the decision of county officials in the Three Mile Island area to develop and maintain a 20-mile amargency response capability as a substitute

, for making a determination that the 10-mile circular EPZ is adequate, the adequacy of such a 20-mile capability must be established as a condition to the restart of TMI-1.

17 (B) Licensee's Emergency Plan fails to adequately provide a mechanism which will assure the effectiveness of the Emergency Plan throughout the operational lifetime of the TMI-l facility.

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@gm w+

• e@h eg a w 9 EP-18 (Shellv)

It is contended that the Licensee's environmental radiation monitoring program contains an insufficient number of monitoring sites and an inadequate distribution of menitoring sites within twenty miles of the Unit 1 site to provide sufficient protection of the public health and safety. It is further contended that there is in the Licensee's environmental radiation monitoring program an unwarranted reliance on the use of thermoluminescent dosi=eters (TLD's) for providing infor=ation used to calculate radiation exposure data and that this unwarranted reliance on TLD's seriously underestimates radiation doses to the public. It is also contended that the Licensee does not possess adequate portable radiation monitors to provide additional information in the event of an offsite radiation release, and that the Licensee does not exercise adequate administrative control over the mainten-ance of these units, nor the training of personnel in their use.

It is contended that the radiation monitoring program of the Licensee must be greatly upgraded prior to restart to ensure ade-quate protection of the public health and safety. ,

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ucr.xr SUBJECT MATTER LIST OF ONSITE EMERGENCY PLANNING CONTENTIONS A. Organization and Coordination i

1. Manpower EP-4(D)

EP-4(J)

2. Letters of Agreement EP-4(B)

EP-15(A)

3. Coordination with Other Plans EP-15(C)

EP-15(E)

B. Initial Accident Assessment

1. Classification EP-8 EP-9

2. Radiation Monitoring EP-3 (C)

EP-4(I)

EP-18 C. Initial Accident Netification

1. Communications EP-1 EP-4(E)

EP-4(G)

EP-15(B) i 2. Alerting the Public EP-15(F) l D. Onsite Emergency Response 1

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. , F E. Offsite Emergency Response

1. Definition of EPZ's EP-17(A)

2. Education Program EP-4(C)

3. Protective Action Options and Decisionmaking EP-4 (H)

EP-7 F. Maintaining Emergency Preparedness

1. Emergency Training

2. Exercises and Drills EP-4(F)

EP-15(D)

3. Audit and Review of Plans EP-17(B) l I

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x . -- y A. Organization and Cecrdination

1. Manpower 4(D) The licensee's *Cnsite S argency Crya.1:ation" (Sec.

4.5.1.3) contains insufficient' personnel and exper-tise is the area of Health Physics to discharge ade- .

quately the respcnsibilities of dose assess =ent and projection is the event of a rapidly develeping acci-dent sequence. ""he st-- required for the = chili:a-tien of effsite health physics supper- (2-4 hrs. -

See Table 8) , which' is given responsibility .

fer

=*

"everall' assess =ent of the i= pact of liquid and gasecus effluents with respect to . . . p ctactive action guides" (p. 5-12), is incensistent with ade-quate radiclogical assessment capability.

l 4(J) The licensee's Onsite Energency Organization staffing l

l

( crevisions as set fcrth in Table a of its I? fail te l

1 confor= to the standards of N. 0654 Sec. 35 in the fcilcwing respects:

1. Cnder said standards two con:rcl rec = cperators are assigned the functicn of " plant cperaticns and assessment of cperational aspects." Another shift employee is given the exclusive task of pro-l t

viding cc==unications liaisen with eff-site offi-cials. Under the licensee's staffing previsions, by centrast, the two con:rcl rec = cperators are L

assigned c " Operate seuip=ent in centrol rec =

and act as ec=municater" (emphasis added). This divided respensibility ccmprc ises the licensee's ability ~;c p cvide prcspt eff-site notification of emer ency conditions. The inadequacy of these l

l l staffing previsions is aggravated by the absence of any previsien for the addition cf three =cre persens with cc==unications respcnsibilities within 30 minutes, as rec.uired hv. the aforamen-tiened acceptability standard.

2. A similar confusion of assign =ents exists with regard tc the shift superviser and shift foreman, who are expected to fill three roles between them.

3. Althcugh N. 0654 requires the emergency operations facility directer te assume his assignment within 30 minutes, under the licensee's plan this will not cccur for as icng as four hours.

4. Two radiological analysis supper: engineers, who are the only em=. lev.ees identified as having the traininv and erinarf responsibi y for cerform-ing "dese projection calculatiens and source term calculations" (EP, p. 5-10) will not be l available fer as long as 60 minutes.

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mm.- *..e = .%

2. Letters of Agreement 4 (3) The perfunctory fers letters fcund in Appendix C to licensee's I? provide no indication, let alene assur-ance, cf the existence of " mutually acceptable criteria" for implementation of emergency measures as required by Emergency Planning Review Guideline No. Cne, Revision One (I?RG) IV ( A) (1) . Also N. 0654 A3.

0 15 (A) Section 4.5.2 provides that off-site authorities would provide certain services in the event of an emergency situation. The Plan does indicate that there are agree-ments between the varicus personnel, organications and agencies listed in this section; hcwever, the agreements of = cst local fire companies enly indicate that certain manpcwer is available and certain pieces of equipment are available. Mersever, it appears as though somebcdy produced d cuments for the iceal fire ccmpanies to sign, which wculd indicate the amount of mangewer and re-sources available to each one of the fire ecmpanies who signed such an agreement. The agreements with the fire companies do not state that they knew exactly what will be expected of them in an amergency situation. Withcut a scund contractual understanding in place, it is questionable that during a crisis situation off-site authorities will knew exactly what is expected of them.

-_ _- _ _ - _ _ - _ _ . _ _ - _ . . __ _ A

a - -. . ..

v .r Detailed understandings shculd be drawn between the local pclice, firefighting authorities and che State

?clice and c:her Off-site authcrities and agencies in order to ensure crderly support in the event of an emergency. The absence of such dccu=entation and under-standing between Metropolitan Edison Cc=pany and off-site authorities creates a deficiency in the Emergency Plan.

3. Coordination with other Plans i

15(C) Sectica 4.5. 3.2 of the E=ergency Plan indicates that with respect tc the 10-mile E?:, the five counties identified in this section have c.recared emer encv.

plans that are eccrdinated with 'he t State Disascer Cperations Plan and with the TM: E=ergency Plan as well.

i It is Intervencr's contention that this cbvicusly cannot l

he the case, since revisien #2 of this Plan is dated June, 1980 and that the county plans still are not adopted as final drafts. Moreover, a review of the Dauphin County and York Ccunty Plans indicate there is absciutely no referencing to the TM E=ergency Plan and that, in fact, in appears as though the ccuntv. clans wars written independently of the TMI E=ergency Plan.

All plans must inter-ccordinate in order _to ensure that all parties participating in the emergency will knew what is expected of them. There is no prevision in the Emergency Plan for the distribution and rpdates of the TMI E=ergency Plan and, based upon these deficien-cies, the E=ergency Plan as new written is inadequate.

t

a.= w.: w .,

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15 (E) Secticn 4.6.5.l(2) of the Emergency Plan provides that the responsibility for actions to protect persons in s

the off-site areas rests with the Cc=menwealth of Pennsylvania and that the Pennsylvania Emergency Manage-ment Agency shall be the agency with which the responsi-bility rests for the placing, in effect, of prctective options such as evacuation, sheltering and thyroid prophylaxis. The same section indicates that in the event of a general amargency, precautionary measures may be taken such as sheltering, evacuation and evacua-tion of certain sectors based upon widd speed and direc-tion. It is again Intervencr's contentien that this particular section of the E=ergency Plan previding for the precautionary measures cited have not been ecor-dinated with 1ccal county plans te any =easurable ex-tent. For example, in the county plans, there is no indication of how the coun:les would instruct its local Civil Defense Directors to evacuate only certain sectors within a ecmmun!- .nstead of within radial distances cf the Three Mile Island nuclear facility. This is again i

only but one example of a lack of coordination between the Emergency Plan and the varicus cocnty plans and it is Intervencr's position that this lack of coordination is symptomatic of the entire E=ergency Plan as it is new written. The Emergency Plan submitted by the 1

L licensee shculd enccmpass a total cecrdination of all

\

Emer,encv. Plans fer=ulated bv. federal, state and ccunty agencies. This lack of cecrdination creates a deficiency which has to be remedied.

. u . LA . F B. Initial Accident Assessment

1. Classification

_r? _8_ (ECi?)

O.e various e=ergency categories (p. 4-2 to 4-8) each list .

a n-her of triggering events or conditiens. Many of these are For instance, on 4-3, " valid" alar =s c.uestion; dale indicators. m..

are referred to. But there is no =ention of the definition of a

" valid" alar =, er what would be as invalid alarm. A nc=ber of reacter cociant activities (50, 130, and 300 ci/ml) are referred te, but no nention is made of hcw much full damage it takes to prcduce these readings. In addition, there is nc indicatien of hcw or how rapidly these coolant activities will be deter =ined.

IP-9 (Ici?) .

P.e11ance on ' adverse =etecrology" (p . 4-5, 4-6), can prove to provide li le er nc

• built-in conserrati.on" (p . 4-7, 4-8) .

since, for instance, such conditiens were not at all unce==c during the night ine in the nights folic-sing the TMI-2 accident (for instance, the night of March 29, frc= 10 p.m. to 8 a.m.,

March 30; night of March 31, cbcut 8:00 p.m. to S a.m., April 1).

2. Radiation Monitoring i

3(C) The N?.C's vague instruction to the licensee to "up-grade" in generally unidentified respects its "off-site monitoring capability" is insufficient to assure that such upgrading will result in the ability to obtain and analy:e the ' type and volume of -infer =ation

l m .m ersantial for protecticn of the public. health and safety. ANGRY centends that such capability =ust at mini =u= enec= pass the following ele =ents of their equivalent; (1) Per anen offsite =enitoring devices which register all for=s of ionizing radiation and which can be remotely read onsite.

(2) Infor=atien analysis capability equal to or greater than that provided by the At== spheric Release Advisory Capabilitf System (ARAC).

This contentien new challenges the adequacy -

of the licensee's MICAS radiological assess-mest systes (I?, p. 6-9) to the extent that the information analysis capability it pro-vides does not equal or exceed that provided

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by the ARAC syste=.

4(I) The time provided in the I? for acciden assessment,

( 1/2 hour (I?, p. 6-7) , is in excess of the maximus permissible therefer specified in the Standard Review 1

Plan, NURIG 75/087, Sec. 13. 3 (II) (3) . (I? fig. 21 sheva the thyroid PAG cf 5 rems being reached in 12 i minutes at 600 meters.) Moreover, the estimate given is unsupportable for =cnitoring of cif-site 1ccatiens en nearby islands er en the west shcre of the Susque-hanna River. Such facecrs nay becc=e critical in e

the event of a general emergency, which produces a

" shift in emphasis to grea er offsite =enitoring l 1

efforts" (IP, p. 6-6). (See Contention EP-3 (C) (1) ) . l I?-18 (Shellv)

It is contended that the Licensee's environ = ental radia-tion monitoring progra= contains an ins._ficient n"-ker of

=enitoring sites and an inadequate distribution of =enitoring sites within twenty =iles of the Unit I site to provide sufficient p:otection of the public. health and safety. It is -

further contended that ther e is in the Licensee's environ = ental radiation'=onitoring p:cgra= an unva anted reliance on the use of ther=clu=inescent desi=eters (TLD's) for providing informa-tion csed to calculate radiation exposure data and that this unwarranted reliance on TLD's seriously underesti=ates radia-tion doses to the public. It is also contended that the Licensee does not possess adequate portable radiation =enitors to provide additional infor ation in the event of an offsite radiation release, and that the Licensee does not exercise adequate ad=inistrative control over the =aintenance of these units, no: the training of pe:sonnel in their use. It is contended that the radiation =enitoring progra= of the Licensee

=ust be g:eatly upgraded prior to restart to ensu:e adecuate protection of the public health and saf ety.

(

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_a- ,

- .vi C. Initial Accident Notification

1. Com :alcations

'?-1 ( Aa=edt)

It is contended that licensee has not =ade p cvision for ti=ely dissemination of infer =ation is the event of accidental release of airbor=e radioactive gases or particulates. It is contended that licensee =ust z.ke infer =atien available to the public which will allew appropriate action to be taken to pro-tect persens, livestock, foodstuff and feed in uhe event of a discharge of significant proportions. All data and plar.:

operating personnel chservatiens relative to all radioactive releases =ust be transmitted i==ediatelv. and si=ultanecusiv. to the NRC, Pennsylvania Department of Invironmental Resources ,

the cc-'ssioners of Dauphin, York and Lancaster Counties and the licensee's =anage=ent. It is further contended that t .

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licensee must provide this capability - beforc restart of T2C-1.

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l 4 (I) The licensee's IP fails to p cvide for furnishing to the Pennsylvania Bureau of Radiacion P c ectica (3 CPS) infor=ation called for in the latteE's plan such as

" nature of the failure, the stacus of safeguards , the condition Of consecuence mitigating features" (p. VI-1).

xpc 4 (G) Che licensee's emergency notification procedures (pp.

6-2, 6-3, 6-4; Figure 15) (See also Pa. DOP Appendix

3) are inadequate with respect c certain areas directly at risk in the even: cf a nuclear accident, na=ely, Ycrk and Lancaster Ccunties. Although the Dauphin County Emergency Operatiens Center receives i immediate notificatien cf an emergency declaratica, notifica:icn of Ycrk and Lancaster Ccunties =ust follcw an excessively circuitous path:

1. Licensee to Dauphin

2. Licensee to PEMA

3. PEMA to SORP

4. 3ORP to Licensee

5. Licensee to BORP

6. BORP to PEMA

7. PEMA to Dauphin

8. PEMA to York, Lancaster, and Cumberland Counties.

Such a notification sequence is in direct conflict with requirements that " delegations of authority that will permit emergency actions (such as evacuation) to be taken with a minimum of delay should be carefully considered" (NURIG 75/111, 5 A3) and that "Upon declaration of a ' general emergency' immediate notifi-cation shall be made directiv to the offsite authori-ties responsible for implementing protective measures

" Also,

. . . (EPRG II(A) (5)) (Emphasis in original) .

N. 0654 J7.

2,wy 15(3) Section 4. 5.1. 3 (1) (c) (d) states that the Emergency Director shall previde liaisen ec==unication with

~

county, state and federal governments to ensure that notification and reports to these agencies are made in a timely =anner and that he will ec=municate with off-site emergency support organizations. It is Inter-

venor's centention that this part of the Plan which is critical to the coordination cf all emergency activities dcas not state with specificity the exact timeframe in which notification and ccmmunication is to be made with off-site erergency support c ganizations and agencies.

It is Intervecor's positi:n that this is critical in order to ensure that licensee repcrts and ce=municates any abnormal and emergency conditien to the respective organi:ations in a truly timely fashion. The Emergency Plan as now drafted leaves tco much discretion with the Emergency Director with regard to the contacting of ir

these off-site agencies.

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j 2. Alerting the Public t

15 (F) Section 4.6.7.1 of the Emergency Plan deals with early warnings and infor=ation for transient areas. It is Intervencr's position that the =ethods depended upon in the Emergency Plan to warn the pcpulation at risk, are, at the present ti=e, nc in place. For example, sec-tien 2 of this particular secticn cf the Imergency Plan states that a siren alert system could be activated by

.c j i

counties in ordere te warn the ccculace cf impendine danger. As has been indicated earlier in Intervenor's contention with regard te Emergency Planning, there are not encugh Civil Cefense warning sirens in order to adequately ensure that all members of the community are within hearing distance of the siren. Moreover, section 5 of this subsection of the E=ergency Plan indicates

! that vehicles with icudspeakers could be dispatched to broadcast warning messages. The p chlem with this ap-proacn is that it would take time to get volunteers to man the vehicles and, secondly, there are many miles of cad which would have to be traveled in order to ensure that all members of the populace were informed of the impending emergency condition. It is Intervencr's contention that until the E=ergency Plan specifically states that a siren alert system is in place and that the warning emitted by the siren alerts could be heard at any point in the county sur:cunding the plant site, the Imergency Plan as new drafted is anacceptable.

1 D. Onsite Emergency Response l

g . W @ O f' w - - , v - g ,,e - . , r .--. g - - , , e

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I. offsite Emergency Response

1. Definition of IPZ's EP--17 ( A) Licensee's acceptance, without fc=.al analysis or evaluation, of a circular 10-=ile radius for the Plu=e Exposure I=e:gency Planning Zone (as designated by the Pennsylvania E=ergency Management Agency) does not dis- .

charge Licensee's responsibility to ensure that ade- ,

t J quate e=ergency response plans exist to protect the

public health and safety in the event of an e=ergency at M -1. Furuher, acceptance of c

designation of a

circular 10-=ile radius Ple=e Ixposure IP: for TMI-1

) is unjustified because such an IP: fails to adequacely consider local e=e:gency response needs and capabili-ties as they are affected by de=egraphy and jurisdic-l tional beundaries. These censiderations, a=ong others, are specified in NURIG-0396, NURIG-0654, and the new emergency planning rule published in the Federal Recister on August 19,.1980. Se follcwing specific l local. conditions should be reflected in the Plu=a Ix-pesure EP: for TMI-1: .

1. The proposed 10-=ile radius circular IP: includes within the IP: perniens of numerous jurisdictions at the township, city, borough, and tevn levels of gover==ent. Calling for an evacuation of only a portien of any political jurisdiction due to a l

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ha:ard which affects a large geographic area and basing e=e:gency plans and respense capabilit. ins .

en such a li=ited evacuatica vi11 lead to p:chle=s due to spontaneous evacuatic= cf a =uca larger area, with a cenec==itant increase in traffic and suc.civ

. . require =ents at shelters. 'Thereforei the Plure Ixposure IP: for W.I-1 should include the~ entire geographic extent of all govern = ental jurisdictions at the tevnship, city, bc:cugh, and town level which are bisected by the p:cpesed -

ci:cular 10-mile IP .

2. There are heavily pcpulated areas in and near the cities of Harrisburg and Ycrk represented by the city p cper and adjacent centinuation of the urhan areas into the suht:bs. In the event that the wind is blowing toward either of these areas when a large release of radicactivity occurs, such areas would constitute a large percentage of the total populatien dose (in the case of the T.M -2 accident, for instance, Harrisburg centributed 254 cf the total population dose despite the fact that =cs: of the city is =cre than 10 =iles distant f:c= the plant) . The urbanized areas is and a cund Harrisburg and York are concentrations of pcpulatien fe: which preplanning fe: an evacuatien is a necessity fer successful i=ple=entation (for instance, preplanning would have

i i

i to include evacuation cutes, transpertation needs, hest area require =ents, and proble=s pesed by special populatiens such as priscas). Therefore, the urban-1:ed areas around and including'the cities of Zarris-burg and Icrk should be included vd*'#- *ke Plu=e Ixposure IP: for T.E-1.

3. Nu=erous =e=bers of the Old order A=ish ec== unity reside is relatively close prcxi=ity (within 10

=iles) cf the cuter boundary of the Eicensee's Plu=e Exposure IP: in Lancaster Cct-*y. Because the Old order Amish eschew the use of electricity, teleph'enes, and aute= chiles, they present unique proble=s with respect to warning, ce==unication of protective action adviscries, and transportation.

These unique proble=s warrant the special censidera-tien the inclusion of old order A=ish within the Plume Exposure IP: wculd provide.  !

4. To the extent that the Licensee relies upon the decision of county efficials in the Three Mile Island area to develop and main *ain a 20-=ile amergency response capability as a subscicute for =aking a deter =inatica that the 10-=ile circular IP: is adequate, the adequacy 6.f such 4 20-=ile capability =ust be established as a ec=ditics to the restart of TMI-1. '

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2. Education Program 4(C) The adeptien cf the Cc==onwealth of Pennsylvania '

Disaster Operations Plan Annex I (COP) designation of "the ' risk ecunty' as responsible for che prepara-tien and dissemination of infer =ation material on protective actions cc the general public" (p. 6-8) conflicts with the requirements in I?RG II(A) (7) and RG 1.101 5 6.4(2) to make available on recuest to occupants in the LP: information concerning how the e=ergency plans provide for notification to them and how they can expect to be ad-vised what to do.

Also, N. 0654 G4.

3. Protective Action Options and Decision =aking 4(H) RG 1.101 Sec. 6.4 requires the licensee to specify

" criteria for imple=enting protective actions. . .

The licensee's IP f ails to set forth the following

=andatory items of infer =ation regarding the ti=e required for protective action i=ple=entation:

1. Expected accident assess =ent time. RG 1.71, Sec. 13.3.1-2.

2. Time required to wa_-n persons at risk. RG 1.101, Sec. 6. 4.1-2 (b) ; RG 1.70, Sec. 13.3.1-3,4.

l 3. Ti=e required for a general evacuation. RG 1.70, Sec. 1" 3 . 3.1-5 , 6 ; Nov=-ker 29, 1979 letter to "All l

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Power Reacter Licensees" frc= 3rian K. Gri=es, Director, N?.C D::ere.enev. Pre aredness Oc-h Group.

4. Ti=e required to evacuate special facilities (e.g. , hespitals) . Neve=ber 29, 1979 letter, su;ra.

See, N. 0654 J8.

r?-7 (ZCN7)

The fractions of IPA PAGs listed en p. 4-1 of the Plan, with their associated action levels, do not take into account the total et=ent. As.a result, the total ex-accu =ulated dese and dose cem pesures =ay exceed by large =argins the listed ?AG fractions prior to the advance = ant to a higher energency categcry.

F. Maintaining Emergency Preparedness

1. Emergency Training

2. Exercises and Drills 4 (F) The previsions for the conducting cf a "?.adiation E=crgency Ixercise" of the licensee (EP, p. 3-3) and of the Cc==onwealth (?a. CCP, App. 14) are inadequate in that they de not clearly provide for the participa-tien therein of federal agencies. The necessity for such participa icn is clearly established by the ex-tensive involvement of federal agencies in the CC accident. Second, the afere=entioned appendix 00 the Cc==cnwealth's energency plan indicates tha: "all

=ajor ele =ents of the plans and preparedness organiza-tiens" =ay be tested only over a period of five years.

All such ele =ents should he tested in an exercise pric: to the restart of CC-1.

. . _ . . , . , ~ , _ , . -

15D) Section 4.5.4 of the Emergency Plan anticipates that i

the Pennsylvania Emergency Mana,gement Agency will con-l duct and participate in annual training exercises that involve state, county and local government agencies and

that the testing of communications, radiological moni-I toring instrumentation and warning systems will be con-ducted. It is Intervenor's contention that at the present time, such commun'. cations, radiological l

monitoring instrumentation and warning systems are either not in place within the surrounding communities or are not being maintained by operators within sur-rounding lenal communities. The Plan does not indi-cate who is responsible for the purchasing of communi-

, cation, radiological monitoring instrumentation and warning systems and, furthermore, who is responsible for the maintaining of this equipment. The Commonwealth i

of Pennsylvania did begin a radiological monitoring effort; however, since local monitoring readers were instructed as to how to read the monitors the Common-wealth of Pennsylvania has not been soliciting their readings and/or following up to determine whether the readings are being made by the readers. Is this burden to be shouldered by the local ecmmunity, the county, the state government or the licensee? It is Intervenor's contention that while emergency plans may, in theory, set forth a plan of training, it cannot realistically I

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- . :,;.S he put in action because the Plan assumes placement of cc=munications systems, radiological =cnitori g instru-ments and warning systems. It is Intervenor's position i I that until such systems are in place, it 14 determined

/ . I who is responsible for the equipment's maintenance and who is to burden the cost of the placement and mainten- -

ance of such systems, the Plan is inadequate and un-acceptable .

3. Audit and Review of Plans Q

17(3) Licensee's Emergency Plan fails to adequately provide a mechanism which will assure the effectiieness of the E=ergency Plan throughout the operational lifetime of the TMI-l facility.

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