ML19254F645

Response to People Against Nuclear Energy Final Contentions. Objects to Contentions 1 & 2.Contention 3 Should Be Revised W/Specific Objections to Licensee Emergency Preparedness

ML19254F645
Person / Time
Site:	Three Mile Island
Issue date:	10/31/1979
From:	Trowbridge G METROPOLITAN EDISON CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19254F625	List: ML19254F624 ML19254F628 ML19254F630 ML19254F633 ML19254F635 ML19254F639 ML19254F641 ML19254F645 ML19254F646 ML19254F647 ML19254F649 ML19254F650 ML19254F651
References
NUDOCS 7911160144
Download: ML19254F645 (3)

Text

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October 31, 1979 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 RESPONSE TO FINAL CONTENTIONS OF PEOPLE AGAINST NUCLEAR ENERGY Contention No. 1. Renewed operation of Three Mile Island, Unit 1 (TMI 1) would cause severe psychological distress to PANE's members and other persons living in the vicinity of the reactor.

The accident at Unit 2 has already impaired the health and sense of well being of these individuals, as evidenced by their feel-ings of increased anxiety, tension and fear, a sense of helpless-ness and such phycical disorders as skin rashes, aggravated ulcers, and skeletal and muscular problems. Such manifestations of psy-chological distress have been seen in the aftermath of other dis-asters. The possibility that TMI Unit 1 will reopen severely aggravates these problems. As long as this possibility exists, PANE's members and other persons living in the communities around the plant will be unable to resolve and recover from the trauma which they have suffered. Operation of Unit 1 would be a constant reminder of the terror which they felt during the accident, and of the possibility that it will happen again. The distress caused by this ever present spectre of disaster makes it impossible for the NRC to operate TMI 1 without endangering the public health and safety.

Licensee's Response Licensee objects to this contention. PANE here attempts to raise the issue of psychological distress. For the reasons set forth in Licensee's accompanying brief on this issue (see Licensee's Brief Opposing Admission of Psychological Distress Contentions),

such a contention is not cognizable under either the Atomic Energy e Act of 1954 or the National Environmental Policy Act of 1969.

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Contention No. 2. Renewed operation of TMI 1 would cause severe harm to the stability, cohesiveness and well being of the communities in the vicinity of the reactor. Community institutions have already been weakened as a result of a loss of citizen confidence in the ability of these institutions to function properly and in a helpful manner during a crisis.

The potential for a reoccurrence of the accident will further stress the community infrastructure, causing increased loss of confidence and a breakdown of the social and political order. Sociologists such as Kai Erikson have documented sim-ilar phenomena in other communities following disasters.

The perception, created by the accident, that the communities near Three Mile Island are undesirable locations for business and industry, or for the establish-ment of law or medical practice, or homes compounds the dam-age to the viability of the communities. Community vitality depends upon the ability to attract and keep persons, such as teachers, doctors, lawyers, and businesses critical to economic and social health. The potential for another acci-dent, should TMI 1 be allowed to operate, would compound and make permanent the damage, trapping the residents in dis-integrating and dying communities and discouraging the influx of essential growth.

Licensee's Response Licensee objects to this contention. PANE here attempts to raise the socio-economic impacts of fear and community stress. For the reasons set forth in Licensee's accompanying brief on this issue (see. Licensee's Brief Opr posing Admission of Psychological Distress Contentions),

such a contention is not cognizable under either the Atomic Energy Act of 1954 or the National Environmental Policy Act of 1969.

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• Contention No. 3. Evacuation planning done by Metropolitan Edison and the Nuclear Regulatory Commission is inadequate to assure the safety of the public, particularly those per-sons living within a five mile radius of the plant. Opera-tion of TMI 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.

Licensee's Response Licensee recognizes the right of PANE to raise contentions relating to emergency planning. In accordance with the position set forth at Section B of Licensee's covering memorandum, it is requested that the Board require PANE to revise and resubmit this contention with specific objections to Licensee's emergency preparedness following PANE's receipt of the updated Emergency Plan.

Dated: October 31, 1979 7

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