ML20067A087

Comments on Immediate Effectiveness of Decisions & Suppls Responses to Commission Questions Re TLDs

ML20067A087
Person / Time
Site:	Three Mile Island
Issue date:	11/29/1982
From:	Adler R PENNSYLVANIA, COMMONWEALTH OF
To:	Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
NUDOCS 8212010186
Download: ML20067A087 (2)

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g/ y COM510NWEALTil OF PENNSYLVANI' A M

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w a imU& SERVC (717) 787-7060 BRANCH November 29, 1982 BY EXPRESS IMIL Nunzio J. Palladino, Chairman Victor Gilinsky, Comissioner John F. Ahearne, Comissioner Thomas M. Roberts, Comissioner James K. Asselstine, Comissioner Re: In the Matter of Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit Ib.1) Docket No.

50-289 (Restart)

Dear Chainnan Palladino and Mcmbers of the Caanission:

By Order dated Novanber 15, 1982, the Comission left open the record for innediate effectiveness comnents in this proceeding until Novanber 30, 1982. The Commealth appreciates this additional op-portunity to respond to arguments made by other parties. In addition, the Comission afforded the Commealth an opportunity to supplement its responses to questions posed by the Comission during the oral presentations. (Tr. 136).

All of the questions posed by the Comission during the tbvenber 9, 1982 oral presentations were ans m red by Ms. Straube and Mr. Belser in accordance with the Caronwealth's previously established positions, and require no modifications. However, due to the nature of the dosimetry question and time limitations during the hearing, the responses to this question were, at best, incomplete. For a more complete statement of the Comnonwealth's position that adequate supplies of permanent record dosimeters for anergency workers must be supplied prior to restart, I would encourage you to review the Comonwealth's Petition For Partial Review Of ALAB-698 (Novenber 12, 1982).

Comnissioner Ahearne asked why TLDs are "sufficiently essential that...it cannot possibly be done." (Tr. 139). It is not the Comnonwealth's position that, absent TLDs, a viable emergency response at 'IME-1 is impossible. However, as stated in the Connission's energency planning rule (10 C.F.R. 550.47), the appropriate standard is whether there is reasonable assurance that the health and safety of the public, including cmergency workers, will be protected during an anergency. As explained in the Petition for Partial Review of ALAB-698, without permanent record dosimeters, there is no reasonable assurance of an accurate and reliable measurenent of the radiological doses actually received by private 8212010186 821129 PDR ADOCK 05000289 3 563

Nuclear Regulatory Ccanission 2 November 29, 1982 citizens responding to an energency at M-1. In addition, the Comanwealth cannot predict that there is reascnable assurance that sufficient ntrnbers of emergency workers will respond to an incident at M without being provided a full emplement of dosimetry, as specified in the emergency plans.

' Finally, the Coranonwealth wishes to respond to only one point raised by other parties. The NRC staff and FE M, in response to a question posed by the Comission, stated that their position on'dosi-metry for anergency workers was explicitly established in, the Susquehanna operating license proceeding. (Tr. 165-66). 'Ihis is not completely -

accurate. First, while the Staff in the Susquehanna proceeding stated that total radiological exposures could be obtained by accurately reading and recording data from self-reading dosimeters, it also stated that the preferred dosimetry for emergency worlmrs includes the use of TLDs. Second, the FB% findings on planning and preparedness for the Susquehanna facility specifically conditioned its approval of the implementability of the Susquehanna emergency plan on the procurement of adequate supplies of TLDs. Thus, FB % and the NRC Staff establish one.

standard for dealing with Licensing Boards, Appeal Boards, and the Comission (No TLDs required for plant operation) while setting a more stringent requirement for approval of the Comxiwealth's emergency plans (TLDs necessary). Therefore, the Staff.'s representation to the Comission that it has clearly stated a consistent position on dosimetry require-ments for energency workers is in error. '

'Ihank you again for this opportunity to supplement the Connmwealth's comments on the imeuiate effectiveness of the ASLB decisions on M-1 restart. To sunmarize the Contmaalth's previously stated positions, restart should not be allowed until all individuals on GPU's staff with a demonstrated lack of integrity are prohibited from operating M-1, until Licensee demonstrates the competence of its operator training staff, and until adequate supplies of permanent record dosimeters are provided to support the emergency response at 'IMI-1.

Very truly yours,

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Robert W. Adler Assistant Counsel Conmonwealth of Pennsylvania cc: W -1 Service List (First Class Mail)

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