ML19256E524
| ML19256E524 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/22/1979 |
| From: | Keck H ANTI-NUCLEAR GROUP REPRESENTING YORK |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 7911070568 | |
| Download: ML19256E524 (10) | |
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UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
METROPOLITAN EDISON COMPANY (Three Mile Island Docket No. 50-289 Nuclear Station, Unit No. 1)
CONTENTIONS OF ANTI-NUCLEAR GROUP REPRESENTING YORK (A.N.G.R.Y.)
In compliance with the Atomic Safety and Licensing Board's September 21 Order setting a schedule of pre-hearing procedures, intervenor Anti-Nuclear Group Representing York hereby submits the contentions it intends to advance in the course of the proceedings in the above-captioned matter.
I.
The development and effectuation of adequate and effective Emergency Response Plans by the licensee and by state and local governmental units are necessary for the public health and safety to be adequately protected and therefore should be made a pre-condition to the restart of TMI-1.
II.
The conditions set forth in the NRC's August 9 Order (44 F.R. 47821-25) for TE-l's resumption of operation are insufficient to provide reasonable assurance that such resumption can occur without endangering the public health and safety for :he reason that they fail to require the development 3,"3 080 7 C1107 OS&
and effectuation of adequate and effective Radiological Emergency Response Plans to protect the population surrounding TMI-l from the consequences of any future nuclear accident.
Such insufficiency is in particular demonstrated by the following flaws:
(A)
There is no requirement that restart be conditioned on the Radiological Emergency Response Plan of the Commonwealth of Pennsylvania being brought into compliance with reasonable standards of adequacy and effectiveness for such plans which include but are not limited to standards promulgated by the NRC itself (e.g.,
NUREGS 75/111 and 0396; GAO EMD-78-110; H.R.
Rept.96-413);
(B)
Resumption of operation would be permitted before the licensee had completed the process of extending its capability to take effective emergency response actions to a distance which defines the area within which such capability is deemed necessary in order to protect public health and safety; (C)
The distance to which the NRC Order requires the licensee to extend its emergency planning capability Ten (10) miles is insufficient to ?on3 081
provide adequate protection of the public health and safety in the event of a TMI-2-type (Class 9) accident.
Such insufficiency is clearly demon-strated by the fact that evacuation of the entire population living within a radius of Twenty (20) miles of the TMI-2 reactor was given serious consideration during the March, 1979 accident.
(H.R. Rept.96-413, p.
5)
As a matter of general principle, ANGRY contends that emergency planning capability should exist for all areas which could be adversely affected by the consequences of a nuclear accident.
Such areas exist at distances up to One Hundred (100) miles frcm the reactor site.
(Beyea-Von Hippel report) ;
(D)
There is no requirement that restart be conditioned on the Radiological Emergency Response Plans of local governmental units (counties) surrounding the reactor site being brought into compliance with reasonable standards of adequacy and effec-tiveness for such plans which include but are not limited to standards promulgated by the NRC itself.
(See paragraph II (a) ) ;
(E)
There is no requirement that the licensee's
" test exercise" of its upgraded Emergency Plan be
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conducted jointly and in concert with appropriate state and local emergency response officials, nor is there any provision for monitoring, critique, and correction of deficiencies that might be. disclosed by such a joint exercise; (F)
The NRC's vague instruction to the licensee to " upgrade" in generally unidentified respects its "offsite monitoring capability" is insufficient to assure 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 register all forms of ioniring radiation and which can be remotsly read.
(2)
Information analysis capability equal tc or greater thr.n that provided by the Atmospheric Release Advisory Capability System (ARAC).
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a III.
The Emergency Response Plans of the licensee, of the Commonwealth of Pennsylvania, and of surrcunding local governmental units in fact do not satisfy reasonable standards of adequacy and ef 'ectiveness.
(A)
The licensee's emergency response plan is still as cf the date of the drafting of the contentions herein undergoing revision.
ANGRY expressly reserves the right to interpose supplementary contentions at such time as such revised plan is made available to it.
(3)
The Ccmmonwealth of Pennsylvania emergency tesponse plan is likewise undergoing revision at the present tqne.
ANGRY expressly reserves the right to inter-pose supplementary contentions at such time as such revised plan is made available to it.
In any event, such plan must provide for adequate stockpiling and methods for distribution of chemical iodine blocking agents such as potassium iodide.
(C)
York County " Evacuation Plan" is seriously deficient in the following primary respects:
(1)
There is no assessment of the approp-riateness or effic3cy of specific protective actions in light of such pertinent accident parameters as aarnin7 time and plume travel speed.
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( 2)-
The plan is based on the assumption of a warning time greatly in excess of that which NUREG 0396 has concluded may be available.
(3)
The road capacities of selected egress routes are insufficient, given warning times and plume travel speeds that are within the boundaries postulated in NUREG 0396 to pernit the evacuation of the full population at risk as defined in the Plan.
(4)
There is insufficient provision for decontamination and medical services at relocation centers.
(5)
Inasmuch as principal reliance is placed upon school muses for transpor-tation of those without independent means of travel, the plan would be impossible to execute if an accident were to occur while school was in session.
Reliance is placed on out-of-state vehicles for evacuation of hospitalized persons, which will prove to be unworkable because of distances and response times postu-lated in NUREC 0396.
(6)
There 1" -o provision for informing the population at risk of the existence or contents of the plan.
IV.
The licensee lacks the management capability to operate a Nuclear Generating Station without endangering the public health and safety.
This fact is conclusively demonstrated by the numerous negligent and imprudent actions committed by the licensee before and during the TMI-2 accident which are enumerated in Appendices I5 and IIF of NUREG 0600.
In support of its contentions, ANGRY places particular emphasis on '.he following:
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(a)
Loss of an antire safety system, i.e.,
auxiliary feedwater to the steam generator.
(b)
Failure over an extensive period of time to correct leakage of reactor primary coolant through the pressurizer relief valve, causing excessive temperatures in the relief valve exhaust to be regarded as a normal operating condition, and thus preventing such temperatures from alerting plant operators as they normally would to the stuck-open position of the PDRV valve during the accident.
(c)
Throttling of high-pressure injection flow from the Emergency Core Cooling system in total disregard of abnormally low reactor coolant system pressure, and in apparent conformance to an " operating philosophy" concerning actuation of reactor HPI which placed greater emphasis on considerations of convenience and avoidance of down time than on safety.
V.
The NRC Order fails to require conditions for restart following modifications in tne design of the TMI-l
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a reactor without which there can be no reasonable assurance that TMI-1 can be operatea without endangering the public health and safety :
(A)
Installation of a Hydrogen Recombiner as recommended by a minority position in NUREG 0578; (B)
Installation of instrumentation providing reactor operators direce information as to the level of primary coolant in the reactor core.
(C)
Performance of an analysis of and implementation of modifications in the design and layout of the TMI-l control room as recommended in NUREG 0560.
(D)
Installation in effluent pathways of systems for t.he rapid filtration of large volumes of contaminated gases and fluids.
VI.
The TMI-l reactor was designed and constructed in accordance with General Design Criteria within which the particular constellation of events which caused the TMI-2 accident were considered too improbable to be included.
For instance, as stated in NUREG 0578, in TMI-2 analyses of containment isolation actuation, " minimum ECCS function has always been assumed".
None of these analyses has assumed the failure (through human error) of emergency core. cooling.
The failure of the TMI-1 reactor design to anticipate such multiple failures in equipment and operational functioning 1"^3 087.
renders it peculiarly vulnerable to a breakdown comparable in severity to the TMI-2 accident.
All safety related systems in TMI-l must be subjected to thorough analysis and modification to assure their ability to withstand hypothetical accident suenarios that reflect all conceivable combinations of human and mechanical failures.
The measures specified in the NRC's Order fail to impose this essential condition to the restart of TMI-1.
I Dated: Ch a k
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, 1979 York, Pennsylvania Holly Keck Legislation Chairman A.N.G.R.Y.
245 West Philadelphia Street York, Pennsylvania 17404
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J CERTIFICATE CF SERVICE I, Holly S. Keck, hereby certify har I have this 223eday of October, 1979, served cop;..es of the foregoing Contentions of ANGRY on each of the following persons by causing same to be deposited in envelopes addressed to said persons, first class, postage prepaid, and deposited with the United States Postal Service.
Secretary of the Commission United States Nuclear Regulatory Comnission Washington, DC 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, DC 20555 George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, DC 20036 Counsel for NRC Staff Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ivan Smith, Esquire Atomic Safety and Licensing Board Nuclear Regulatory Ccmmission Washington, DC 20555 Nik D WLk Holly S. Keck Legislation Chairman ANGRY
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