ML18026A515

Response to NRC Interrogatories Re Contention 6 on Emergency Planning.Certificate of Svc Encl

ML18026A515
Person / Time
Site:	Susquehanna
Issue date:	03/30/1981
From:	Halligan T CITIZENS AGAINST NUCLEAR DANGERS
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8104140393
Download: ML18026A515 (5)

Text

REGUL ~V INFORMATION D IS TRI BUT I VS TEM (R IDS)

ACCESSION NBR:810JJ1JJO393 OOC,DATE: 81/03/30 NOTARIZED: NO DOCKET FACIL:50 387 Susquehanna Steam Electric Stations Unit ig Pennsylva 0 50<<388 Susquehanna Steam Electric Stationi Unit 2'i pennsylva 5000388 AUTJi,NAME AUTHOR AFFILIATION HALLIGAI'JiTDA ~ Citizens Against Nuclear Dangers RECIP ~ NAME RECIPIENT AFFILIATION Office of the Executive Legal Director

SUBJECT:

Response to NRC interrogatories re Contention 6 on emergency TITLE:

planning, Certificate of Filings CODE: DSOSS (lJot Orig by NRC)

Svc CORTES RECEIVED:LTR encl'ISTRISUTION

/ENCL /

IIJOTES:Send IFE 3 conies FSAR JT all amends, 05000387 Send I8,E 3 copies FSAR Jt all amends, 05000386 RECIPIENT COPIES REC IP IENT COPIES IO CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL ACTION: RJJSHBROOKRM ~ 1 1 STARKrR ~ 1 1 INTERNAL: ASLAP 5 ' 5 ASLB 1 IRE 2 J'JRC POR 1 1 OELD,RLANTON 1 1 OGC 1 1 PUSLIC AFFAIRS 1 1 EG F LE 1 1 EXTER."JAL: LPOR 1 1 NSIC 1 1 gpR 15 1S$ 1 TOTAL NUilBER .OF COPIES REUUIRED: LTTR 17 ENCL 17

~Q March >0, 1983.

UNITED STATES OF AMERICA . ~

NUCLEAR REGULATORY CO:94ISSION In Tge',Jf~ Berwlck Atomic Power Plant PEl$ NS~LnVkp~

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Susquehanna Units l snd 2 Docket Nos. SO-$ 87 + 50-y8 XNG.

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EL'hCJP@QIOjOOPERATXVE, 6'lLLEORENX 8),+ CITIZENS AGAINST NUCLEAR DANGERS

~ke'wSNk 8 TO DXSGOVERY SUESTXONS ON GONTENTXON 6 m~. ~ c

'RC SPQILlIEI8 OGATORIES CONTENTION-, Numbers: 6-1, 6-2, 6-), 6-4.

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The Citizens Against Nuclear Dangers (Citizens) contention is tha the Applicants Zmergency Plan must address the problems associated. with I

the special needs of evacuating elderly and handicapped persons ~safel from the affected. areas of contamination (approx. 50 mile radius) immed.iately following a major accident at the Berwick Nuke. The NRC staff, interrogatoriea.numbers S-6-1 thru. S-6-4 appear to deal only with Revels of unsafe doses of radiatiori that could occur in the event of an accident. The. Citiiens did:not raise these questions. The Citizens

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will not be submitting &rect testimony regarding these technical aspects of Contention 6. Therefore, questions 6-1 thru 6-4 are not applicable, so there's- no information to submit. The Citizens will accept the revised. exposure standards of the NRC unless. scientifically refuted by the testimony of the other interveners.

The main concern of the Citizens is this: what happens to 'the classes of people least able to flee a .potential holocaust after the alarms have been sounded by the EFM, and Civil. Defense groups are ordered by the Governor to evacuate the environs of Berwick. Vill these people just be left behind to die, in the ensusing panic2 This is a Catch 22 tXpe loaded question. The long awaited revised Applicant Emergency Plan fails to satisfy the Commission s Kth ~t'p regulations in as much as the regulations are virtually non-existant bl f t' 1 above, both institutionalized and non-institutionalized. The basis for fp pl '0'd the conclusion that the Evacuation Plan is not a satisfactory plan (which the HBC may rubberstamp anyway) is simply. that the government apparently doesn't give a damn about the lives of real people living near atomic reactors. The technocrats tend to treat these people only as statistics snd expendible items 'in the cause of "progress." So,.y5.

they paper over t'e human problems with pseudo regulations that're > (

meaningless in a real emergency. The fiasco at TNX is Sufficient proof

'of that.'ome of the officials responsible for that debacle panicked

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and misled, the people a ut the seriousness of tha orisis. The Applicants Emergency Plan, although not exactly a carbon copy of the TMI plan, is nonetheless grossly deficient in terms of human needs The Citizens will have a great deal more to say about this state of affairs at public hearings, and, in other public forums in the months ahead.

'o exclude workable provisions for the s ecial trans ortation and medical needs .of the infirm,. the elderly and handicapped (which comprise a substantial percentage of the general population) in the plan. is inhumane and an unconscionable outrage. It emergency'vacuation threatens

. to deprive these .citizens of life, liberty and property, and also denies equal protection. of .the law,. ~d places an unf'air burden on the disabled as opposed, to able bodied citizens who might otherwise be able to escape an atomic disaster at Salem Township.

APPI ICAMT lHZEZROGATORIZS CONTENTIOH 6 No.- 6-l. The Citizens identify all areas within a $ 0 mile radius, especially. downwind from the Salem Township fluke as being affected hy a nuclear accident The usual course of the prevailing winds flow in an easterly by northeast direction, which encompasses the Whoming Valley "arid the city of Vilkes-Barre Ho. 5-2 6-5'6-4." These interrogatories az.e not applicable because the Citizens did not contend that the width of roadways necessiarly would impact on the evacuation. That is the contention of another intervener.

~Eo. 6- '. The adverse weather conditions include the severe snow stones of four inches or more that occur frequently in the mountains of Hortheast Pennsylvania from november thru March...five months each year.

Ho. 6-6. The Emergency Plan fails to account adequately fox adverse weather conditions in the following way. Experience has 'shown that the

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' 'h Interstate highway system and connecting roadway arteries become lvf f and not promptly removed. 'by highway work crews using the proper th f equipment. 37uring the height o'f an emergency evacuation, which could well occur late at night during a snowstorm, and. with thousands of vehicles backed 'up on U.S. Interstate Bl, the likelihood, of the necessary highway REKlEP work crews showing up to remove the heavy snow during the radiation alert and widespread panic, is hi hl unlikel , thus bringing the evacuation caravans to a standstill, stranded in the freezing weather on isolated streachcs of the Interstate. Such an .immobalization,

0 of 'people are while thousands being bombarded w'ith high levels of radza"ion'. coming down with the snowy precipitation, would ensure the death of some persons, and severe long-term radiological physical damage to all the evacuatees.

No. 6- . Based on their trac'k record at TKE, the Pennsylvania Bureau of Radiation's assigned functions would appear to be to collaborate with the public. relations departments of the applicants during a reactor accident, and dissiminate false information to )he public about the seriousness of'he situation.

No. 6-8. This is not applicable. The Citizens do not have any knowledge concerning this question.

No. 6-9. Because of the public outrage over the Bureau of Radiation's fudging and.procrastination in the aftermath of TKE, this bureau. has apparently. gone'nderground in an attempt to avoid detection and risk another bad press. The state's radiation staff would, thus, probably become immobilize'd.with fear and unable to. act responsibly in the event of another major reactor accident in Pennsylvania.

No.'-10. It can certainly be assumed that the Bureau of Radiation, as now constituted, will not be able to fulfilllegitimate public health functions in', a reactor crisis situation. This failure of the Bureau of of Radiation would, however, have an insi ificent impact on the implemention of an emergency plan because the bureau has contributed virtually nothing to the safeguarding of the public from radiation dangers at TEE or any operating reactor in Pennsylvania. The effect would be detrimental, howe'ver, because the Bureau has a responsibility to monitor these reactors, an assignment which they have failed to carry out satisfactorily for whatever reasons.

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Zn a similar way, the Bureau of Radiation has from the outset of these proceedings failed. to carry out its. duty'to actively and openly participate in the Berwick operating license review. The Bureau has the responsibility to insure that the citizens of the Commonwealth are protected from radiation dangers in the environment. Yet, the Bureau has failed misserably, thus far, in its nfission. It has not filed one single motion, contention, .or statement of policy. It has not questioned any of the arbitrary actions of the Applicants or the NRC staff, rior responded, as requested by the Licensing Board, to axe directive, memorandum, or appeal...during two and:orhalf years of deliberafions. This official inaction by the state is a shameful

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it disgrace, and could be proceedings, in 'Federal court.'n a major basisf for appeal of these.

Every citizen of the'ommonwealth of Pennsylvania is su osed to be guarenteed, under the state Constitution, the right to breath clean air and drink pure water, rights that the Bureau of Radiation are not protecting. The Bureau, as- exclusive custodian of vital pertinent radiation records and environmental monitoring studies, must participate actively. in this licensing case or the review. process will l>ecome a sham.

It would be reasonable to predict .that persons in the Bureau of Radiation could be charged. with nonfeasance or misfeasance of office for their Rack of performance in the. Berwic'k license case thus far.

No . 6-11 6-12 6-1'5. . The various aspects of the Emergency Plan that are insufficient, especially in the areas of radi'ation-hazard safeguard.s "and the necessary training for lo'cal emergency units should be dealth with primarily at s ecial public meetin s and-hearin held in the

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affected communities, allowing all interested individuals and organizations to testify concerning 'all aspects ef the Applihants

, Bnergency Plan. This either is, or certainly shou1d be, a HRC .

requirement'. Such meetings and hearings could 'be held prior to, or concurrently with, the Licensing Board's hearings on Contention 6, and the transcripts .of a11 testimony and exhibits become a part of'he record in this licensing case. The Citizens have no specific information to offer on No. 6-11, 6-12, 6-15. These questions pertain to aspects of Contention 6 filed by another intervener .

Dated.: March 30, 1981. Correspondeet CERTIFICATE OF SERVICE I hereby certify that cop1es of Citizens A ainst Nuclear Dancers Answers To Discover Questions On Contention have been served. on the following by depos1t 1n the Unite States ma11, first class, this /0th day of'March, 1981.

SERVICE LIST Mr. James P. Gleason, Chm. Dr. Judith H. Johnsrud Mr. Glenn O. Bright Mr. Gerald Schultz, Esq.

Dr. Paul V. PQrdom. Mrs. Colleen Marsh Ms. Jessica H. Laverty, Esq. Mr. Robert Y. Adler, Esq.

Sec. NRC Comm. Docketing 4 Service Mr. Jay Silberg, Esq.

Atomic Safety R License Bd. Bc Appeal Bd.

cc: Governor Dick Thornburgh Members Pa. General Assembly