ML19257C345

Revised Contention on Emergency Preparedness & Response. Objects to Licensee 800102 Response Re Recommended Procedures.Urges Open Public Review of Emergency Plan & Implementation Procedures.Certificate of Svc Encl

ML19257C345
Person / Time
Site:	Three Mile Island
Issue date:	01/07/1980
From:	Kepford C Environmental Coalition on Nuclear Power
To:
References
NUDOCS 8001280463
Download: ML19257C345 (16)

Text

I p.. .

e g ,k%

A 1E \g t UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION $ ,6 c

o . \s -

In the Matter of .

e -

METROPOLITANEDISONCOMPANYl Docket No. 50-289 l License Suspension  :

(Nuclear Generating Station, Proceedings Unit 1) l ECNP INTERVENORS' REVISED CONTENTION'ON -

, EMERGENCY PREPARE 0 NESS AND EMERGENCY. RESPONSE l , . -

.. ,3  !

. v.

ECNP hereby submits its revised contention on emergency preparedness and emergency response for possible acceptance as an issue in controversy by the Licensing Board. The bases for those contentions for which external bases are needed are listed at the end of the revised contention. The bases are listed as references without additional explanation. These bases are so listed because of the short time period available for reviewing one complete " MetropolitanI Edison Company Emergency Plan for Three Mije Island Nuclear'Statiaa, Unit 1"(the Plan). This. effort was hampered'by the' fact that the susp$ded licensee (Metropolitan Edison Company, or Met. Ed.) has not provided the parties with Appendix A to the Plan, which is the implementing document for the Plan.

With regard to the implementing document, ECNP objects to the procedures recommended by the suspended licensee . (Licknsee's Response to Emergency Planning

, t

Contentions, Jan. 2, 1980, at n. S.). Here, it is suggested that the implementing r

, document be revieted "outside the hearing process by the Staff." ECNP submits that for a subject as important and as complex  ; as emergency: planning and pre.,parednes especially:in the light of the sorry state of preparedness at the THI-2 accident, open review of the implementation procedures for the emerg$ncy plan is called for to protect the public interest. Such a cozy and closed review of matters of vital concern and importance to the public, as suggested by the suspended licensee lOl9 G 8001280463

- . _ _ . - . - :.:.- = = - = . . . . . - - - -

2 i

.c,, .

• s

~

would do Qttle to. rebuild public confidence in the suspendeo licensee or the regulatory agency. .

The sole justification offered by the suspended licensee for its cloak of secrecy is that the " implementing procedures always have been reviewed by the Commission Staff." The failures of the nomal review process of the Comis-i sion Staff are detailed in numerou of the Technical Staff Reports and thc. Report of the President's Comission on the Accident at Three Mile Island itself. In i

fact, as the President's Comission found

' With its present organization, staff, and attitudes, the NRC is unable to fulfill its responsibility for l

providing an acceptable level of safety for nuclear power plants. (Report, p. 56).

i Since there is nothing in the implementing procedures that is proprietory, it r

l would certainly be in tne public interest to have an open review of this

important subject.

? ECNP contends that the emergency plan of the suspended licensee is totally inadequate to protect the health and safety of the members of the potentially affected public in the event of a radiological emergency at TMI.

The plan is filled with promises of things to be done in the future, expectations of smooth, unimpeded operation, and is devoid of contingency plans or even the justificationr for the few assumptions that are given. However, one extremely serious deficiency of the plan is that it is nothing but a plan. There is no assurance provided that this plan will be any more workable than the original THI-2 emergency plan. Until it has been realistically tested, its efficacy can only be considered speculative. Another serious deficiency'.is that notifi-cation of the public that an accident is in progress and that local radiation exposure rates are rising is delayed, and then notification only takes place after the infomation has passed through a number of levels of corporate and political bureaucracy. In addition, the Plan offeres no assurance that the information released to the public will be accurate, complete, candid, honest,

_ . . . . .__j.E 9. .1L4_9.___ ._. _ _

and timely, and devoid of political tampering or modifications designed to satisfy corporate public relations purposes rather than the public's need for full and reliable infomation. m. .- ,

. ,9, S But the most troubling aspect is the subtle underlying' assumption that L

(. . .

permeates the entire plan, which is that the members of the public do not have s W- ., ,1 the fundamental right (legal, moral or ethical.) '

~.~.

(a) to be infomed that they are being or are about ,

to be exposed to radiation dose rates much higher than the nomal background rate, and, -

f (b) to be allowed to make their own decisions as to what level of unwanted, unnecessary, and unjustified radiation exposure (for which they receive no comensurate benefit whatsoever) they deem acceptable and what level of exposure they deem unacceptable for themselves and their children, and, (c) to act accordingly, even if that means to vacate  ;

the area themselves at the first occurrence of trouble, if they so desire.

The THI Plan implies thrcoghout that the affected populace should simply sit tight in ignorance of events that might threaten their health or their ,

lives and await word of their fate from far-away bureaucratic " authorities."

t ECNP contends that this plan should not be deemed acceptable until these major deficiencies are corrected such that -

(a) live drills, including evacuation, are carried out in' the avers potentially affected by accidents et THI; (b) the public can be guaranteed that it will receive accurate. -

candid, honest, complete, and timely notification _of unplanned radioactive releases as soon as or before they actually occur (should such infomation be available to p1 ant operators); , ,i (c) the public can ge guaranteed that it will receive accurate, candid, honest, complete, and timely notification of accidents and of the course of accidents from their inception; (d) the right of those members of the public who wish to avoid' exposure to accidental releases of radioactivity or the releases of radioactivity occurring during accidents is recognized, honored, protected, and. guaranteed. ,,

1819 050

.. - - - - - d. _ - . .. . .. _ _ _

4

~

v

-ECNP further contends that the plan is based on numerous assumptions (only six of which were deemed by the suspended licensee of sufficient import to acknowledge, and these do not appear until Appendix D (p. 4) of the 114I Plan) which receive no discussion as .to their validity. ECNP below presents a list which ECNP believes comprises the majo assumptions behind the TMI-l Emergency Plan.

1. Accurate predictions ..an be made concerning the probability

- of occurrence and temporal distribution of reactor accidents, and also the period of danger or period of greatest concern during a reactor accident.

2. The inadequacies of emergency planning and response at all levels during the TMI-2 accident can and will be prevented from recurring at the next accident at TMI.

3. There will be no sabotage at any nuclear power plants and in particular at TMI. .

4. Evacuation planning and preparedness around TMI can be limited to some arbitrary distance from the nuclear reactor.

5. The next serious accident at TMI will occur only after all f emergency planning and all emergency preparations have been complete.

6. Instiumentation exists in TMI-1 to give the plant personnel accurate, unambiguous infomation so that the reactor operators can (a) react and respond intelligently and correctly to prevent core damage, and (b) accurately and in a timely manner inform plant management and all other officials of current plant conditions.

7. Reactor operators are sufficiently well trained such that when an unanalyzed, unanticipated accident, like that at THI-2 does occur, operators will not be confused, and will know which instruments and indicaters in the control room to rely upon to prevent core damage.

8. The control room is designed to minimize' confusion at the time of an accident, and is designed to infom the reactor operators of the necessary information with a priority over less impor-tant or relevant information.

9. The designated employees of Met. Ed. can be trusted to transmit accurate and complete information in a timely fashion to the .

potentially affected public and officials.

10. . The NRC will transmit information openly and accurately and in

_ _.1319_031

a timely manner to the public throughout the emergency.

i

11. The State will transmit information openly and accurately and in a timely manner to the public throughout the emergency.

12. No political pressure will be applied to encourage any involved organization to 'own-play d the' severity of the accident or conceal some relevant component of infomation about events ,

at TMI and their; effects. r

. y  ! -

13. The members of the affected or potentially af.fected public do not have either the right to or the need for accurate and timely infomation throughout an emergency 3. a nuclear power plant.

{

14. Tf@inembers of the affected public will not panic when infomed that large releases rf radioactive gases (104 ClXel33) have already taken place durjr ; another accident at TMI.

15. Members of the affected or po'tentially affected public have neither the needfnor.the rights to be able to take actions.

j on their own to prevent. unwanted exposures to radiation at levels which the:NRC and other governmental agencies deem' to be accep' table ('as fii'NUREG-0610 and NUREG-0396).

.- q. .J .  ; M., ,

16 Evacuation, in the' event of another accident at THI, can be counted on as a general elevated exposures even: procedure to reduce (but not eliminate) ithough'

.s t

(a) much time will have already been wasted by Met. Ed.

prior to alerting 1the',public to .the accident (no notification of ths public in Unusual Event and 4 Alert categories);fand;-

'4 j

.e w: ,

(b) there may not be eno' ugh time for members of the public to carry out their necessary domestic functions, including but not limited to (1) collecting necessary documents, such as deeds,

, insurance policies, birth certificates, and so on.

. (2) turning off gas, oil, electricity, and closing ~

windows, locking house, etc.

$ (3) gathering all non-school family members (off

~

shopping,etc'.).

i.vi? ./ , 41 s (c) no consideration 'has been given to. the care of fam

~

animals.in areas %here owners might be expected to evacuate; .

, ;- " ".F (d) no consi#eration has been given to the time required to evacuate the affected ' institutionalized individuals (hospitals, prisons, etc.);

(e) little or no consideration has been given to the method of evacuation of individuals without cars; (f) no consideration has been given to the availability of cgasoline; 1819 052

• * * ' , _ . _ __ _ . ! _

• i *12.1 . . . .. _ . . . . _ _ . . . . .

F

! (g) no consideration has been given to the amount of

m. cash on hand which the evacuees may hsve for their own support for an unknown length of time.

17. The offsite radiation levels which might occur at TMI prior to the public announcement of an emergency and radiation levels prior to and during evacuation as described in NUREG-0610

. constitute acceptable it 'els of exposures to the affected members of the public even though (a) such levels of exposure do not take into account the variability of humans of all ages to the effects of radiation; or (b) the increased average sensitivity of children to radiation; or (c) the greatly increased average sensitivity of the developing fetus to radiation; (d) prior exposures of residents in the vicinity of TMI.

' 18. Both State and local officials around TMI are capable of evacuating all who need evacuating, and (a) there will be enough cars, buses, etc. for everyone; t

- (b) roads will not be jammed to the stalling point; (c) there will be no gas shortages, and

}

(d) all necessary volunteer emergency personnel will be available for duty and will continue to be I available and to respond adequately to orders through the duration of the evacuation.

19. Members of the affected public do not need to be told that the main justification for their being ordered to stay indoors during an emergency may well be that they cannot be evacuated.

20. If orders are given for the members of the public to close windows and stay indoors, conditions at the pir.st will not change so as i' to make these orders a mistake, or that members of the public will be properly and timely infomed to take other precautions.

21. If there is a reactor core meltdown, and the containment does not rupture early in the accident, then all is well, and there will be no need for further concern.

ECNP submits that the THI Plan should be deemed unacceptable until these and any and all other assumptions upon which the Plan is based are thoroughly discussed and evaluated as to their validity in public adjudicative proceedings.

1819 053 i

. ._. .._ - - =- -~_

7 I ECNP further contends that the Plan, including its various parts and appendices, contains a large number of serious deficiencies, incon ,.,

sistencies, and inaccuracies, which render the Plan questionable in its utility, purpose, and workability. These deficiencies ~are enumerated below.

1. The " prime obje.ctives" of the plan are said to be (p.2-1)

=- to provide a "means for. mitigating the consequences of emergencies" and to provide"" implementing procedures" to ensure preparedness.1 Yet'>no discussion is! offered as to the degree oftconsequence mitigation offerid for protective measures possible and the array of accidents from which the public is to be protected. '

..\

2. The TMI Plan is said to be based on a 10 nile radius, (p. 2-5) and that the plan is co6rdinated with all five counties -

within,that radius (p. 2-7). Yet all five of the counties have emergency plans.which are based on 5,'10, and 20 miles .-

radii from TMI. .. . .

r e. .

t

3. The suspended licensee states it has developed an " Emergency Public Infomation Plan." Yet the suspended licensee has

! not offered a single reason why anyone should believe any statements from the suspended licensee. Tliis problem is obliquely recognized in theiPublic Information Plan, pages 10-11, but nei.ther the ca'use nor the solution of the problem '

4 appears in the'P.lang... ,. l ,

4. The Plan provides "a means for classifying emergency conditions in a manner compatible "with various State and County organi-zations (p. 3-1). Yet the Comonwealth and the five counties use different classification schemes.

5. The Plan counts'on " training,' drills, reviews,- and audits" '

(p. 3-2) to result in emergency preparedness. However, there

u. is no amount of t'rainino, etc.,#that cannot be rendered irH effectual by licensee manacement,'once tiie license suspension

• has been lifted. ,

..a .

6. The accident an'd conditionsl listed for the .various emergency categories are nothing but.a rehash of thefSAR accidents.

Not only is the THI-2 accident not. listed,'the broader scope of accident an'alyses recomended'.in.NUREG-0578 (p. A-42-5) is ignored completely as.are the Alternate Event Sequences of. the Technical.. Staff Analyses Report of the President's d

. Commission. V ". ,- l.,p,

~

ja ( ,.

1 ECNP notes here that ECNP has not received Appendix A to the Plan, which is the Implementation Document for the Plan. ECNP submits that this plan '

should be made available to the parties of this proceeding for their perusal well prior to the start of the TMI-1 Restart Hearings. Only in this way can the proper public; scutiny of the complete emergency plan be made. J' 1819 054

'~. . . .

7. The fractions of the EPA PAGs listed on p. 4-1 of the Plan

• ~' -

are illustrative of the utter contempt and disdain felt

, toward the neighbors of TMI by the management of the suspended j licensee. The fractions represent large doses to the thyroids i of children and fetuses, and at 50 mR/hr to this glands

{ represent dose rates to be avoided. Yet in the " Alert" category, Met. Ed., the suspended licensee, does not even provide fo disseminating the news of the current conditions to the public.

f 8. The fractions of EPA PAGs listed on p. 4-1 of the Plan, with their associated action levels, do not take into accour.t the total accumulated dose and dose comitment. As a resule,

- the total exposures may exceed by large margins the listed PAG fractions prior to the advancement to a higher emergency category.

9. The various emergency 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" alams are referred to. But there is no mention of the definition of a " valid" alann, or what would be an invalid i alann. A number of reactor coolant activities (50,130, 6 and 300 ci/ml) are referred to, but no mention is made of how much full damage it takes to produce these readings.

In addition, there is no indication of how or how rapidly j these coolant activities will be determined.

V

10. Reliance on " adverse meteorology" (p. 4-5, 4-6), can prove i to provide little or no " built-in conservation" (p. 4-7, 4-8)

since, for instance, such conditions were not at all uncomon during the nighttime in the nights following the TMI-2 accident (for instance, the night of March 29, from 10 pm to

• 8 am, March 30; night of March 31, about 8:00 pm to 8 am, April 1.) ,

11. The Plan lists a series of accidents from the FSAR for THI-l and instrumentation to detect the condition or accident.

However, it does not appear that the radioactive gas monitoring devices are of sufficient range to prevent the condition that prevailed at TMI-2, namely, monitors off-scale high.

12. The " General Emergency" category (p. 4-7) acknowledges that the lower limits of the PAGs (1 rem whole body or 5 rem thyroid exposures, p. 4-1) are likely to be exceeded. Not only does this represent an outrageously high exposure to those most sensitive individuals of all ages, it does not even represent the total dose received. As stated on p. 1-4, "The protective action guide does not include the dose that has unavoidably occurred prior to the assessment." Emphasis added.

ECNP submits that the occurrence of an " unavoidable" dose is due solely to the refusal (or inability) of the suspended licensee to provide the public with timely, accurate, honest and complete information concerning the course of the accident.

! ECNP submits that this contemptible disregard for the health I

and safety of the public in and of itself is sufficient grounds to render the entire plan unace p bl.055

== - -.

i .

9

13. ECNP submits that reliable assessments of offsite conditions and dose rates cannot be made from the TMI site without an extensive array of live, real time, offsite radiation detectors.

The Plan admits to the possibtlity of off-scale monitors with the expectation of using " contingency dose release factors". ;

Contingency dose release factors are, however, not defined. "

This eventuality;..along with the complexities bf offsite dose-projections and.' estimations from inside thissite and the S associated errors and opportunitie, for misdalculation unde.-

tanergency conditions render effsite detectors a necessarv safety device. Furthennore, live . offsite detectors could have direct output teminals at various. State and County sites, and thereby bypass the cumbersome titne-c6nsuming reporting procedures e'!tlined bythesuspendeplicensee. '

15. The overall Plan suffers from serious defects, including but not limited to:

(a) .The Plan offers no understanding of'different time ;

factors for unfolding of accidents,. changing conditions during ?r.-eccidents, and so'on, (b) The Plan ha; no cEntingencies Cf a11' operations.

equipme!itketc. don't function exactly as planned.

p' <

1 ..

(c) The Plan is exceedingly cumbersome, with much more attention)eingpaidtoMet.~Ed.'s"publicimage"than

. to the protection of the health and safety of the .

public; or even to the release of accurate, honest.

complete"and timgly infomation to the public.

• i .t. "u..

16. The Offsite Emergency Suppoit' Organization (k 5-10, Fig.13) offers little substance or issurance-to the p]an since it suffers from having been put to the~ test at'TMI-?. andifound sorely wanting.

There, for ext.mple, it was shown that, with regard to the first five " responsibilities" listed on p. 5-10, the Organization was hopelessly incompetent. , .

17. Workers in normal and emergency conditions, including temporary

~

workers, are not given objective or even factual infonnation about the risks of.. radiation dosesqto which they may be exposed.

n.. -

p

18. The assessment actions;fon the General Emergency are based on

(

whole body and thiroid' dose for accidents as specified in TID-14844 and assume engineered safety. features are cperable (p. 6-6). ,

ECNP submits thatJID-14844 is out of date (pubalished in 1962) and must be updated; !.n addition,; such re',;3nce is incMsistent with the " General Emergency" conditions, where, as noteo 7n page 4-7, the possibility of. multiple loss of engineered 13fety features is implied. Loss of' containment integrity implies loss of other engineered safeguards previously. As a result, any .

. reliance on the curves in Fig. 21 & 22, and the assumptions .

therein (Fig. 23) may lead lto a gross underestimation of offsite doses,and,hence('ofconseqi.ances. ECNP notes that the fact that the TMI-2 containment structure now reportedly contains 44,000 curies of Kr85, over 50% of the core inventory, demonstrates 1819 056

. . ,_m* *. 1.'. .r r Z

. ._..m.____ . . . . - - - - =

10

+' > the inadequacy and inconsistency of the assumptions upon which

-- the Plan is based. .

19. Table 12 does not list the needs for more adequate training of all reactor operators in accident understanding and response, a matter observed as being inadequate in the Report of the President's Commission on the Accident at Three Mile Island, pp. 49-50.

,. 20. The REMP of the Plan is only slightly'less inadequate than the grossly inadequate REMP prior to the TMI-2 accident. In ticular, the new REMP envirsions only 2 TLDs in each 22.5, par--

compass sector, one at the site boundary and one 4 or 5 miles from the

- site. This approach in the Plan implies a dedication to continued use of meteorological nodels' to project doses in situations where such models are known to be inadequate and/or inapplicable (complex topography, long distance-a few miles, and so on.)

21. The Plan relies on " drills and exercises' to give the impression of emergency preparedness. Yet the Plan offers no assurance that just the conducting of drills of licensee employees and governmental officials, and volunteers once a year or once every five years (p. 8-5 through 8-8) will actually result in real emergency preparedness.

22. The " Emergency Public Infomation Plan," Appendir B to the Plan, reflects the dedication of the suspended licensee to pay for more attention to nurturing its public image than to provide accurate, candid, honest, and timely information to the public. This is revealed in the purpose of the "Information Plan," pp. 4-5.

"The stated objective of the plan is prompt, complete, and cen-sistent dissemination'of information," (See also, pp.10-11)

Yet the Plan then sets up an elaborate, cumbersome, multi-step, I

hierarchical information manipulation scheme (see pp. 24-6) with the major emphasis on "a single company voice" (emphasis in pian,

p. 5). The Plan itself defeats the prompt dissemination of infor-mation, and contains no mention whatsoever of any need for or intent to provide accurate information. The stated need for "a single company voice," with the time-consuming steps necessary to achieve this goal of questionable value during an accident, outweighs the need for timely and accurate infomation in the priorities of the suspended licensee, and this judgment results in what the suspended licensee refers to as "the dose that has unavoidably occurred"to the public (Plan, p. 1-4).

23. The abbreviated descriptions of emergency classifications in .

Appendix B (p 9) mention " actual or iminent core degradation or melting with potential for loss of containment integrity."

This result would appear to correspond to that general accident category known as Class 9 accidents which may have resulted from multiple plant failures. The Plan contains no discussion of the routes to this end result. Nor does the Plan discuss the 1819 057 long-tem fate of the components, electrical and mechanical, inside the containment structure in the event of a core meltdown, and the public health and property consequences of a reactor with a melted core. The plan makes no mention of how long contain-ment integrity can be maintained post-accident, or what are the

. . - - . . .- -. - =-. -. - . ---

. ~ - -- -.

11 consequences of containment failure at some future time.

24. The "Infomation Plan" contains no mechanism whereby a tr2mber of the public can obtain directly from the suspended licensee infomation which he (or she) can be assured will be accurate, esndid, honest, and timely. The THI-2 accident illustrated the va',t ability of t.his suspended licensee to distribute inaccurate, incmiplete, misleading, wrong.:and out-of-date,jinfomation. Appendix B sf the Plan remedies none of these demor.strated defjciencies of thi.s suspended licensee or its emergency plan. " g. .gg , i.Q ,-

% ' '3. s'  ?

25. ECNP submits that Appendix D of the TMI Plan and2 Annex E of the i Pennsylvania Disasten Plan (Annex E) shares many of the inadequacies of 'thesTMI Plan. Howe ~ver, in contrast to the TMI Plan, Annex E does reveal six assumptions.upon which it is based, but offers no discussion '

aslto the validity lof the psumptions.

26. AnnexEisinterna11ybnconsistent. It assumes there will be adequate time to implement the provisions of the plan, including evacuation (p. 4) b"t t!:en admits than notification times "following an incident may vary" (p. 7). Yet no discussion is offered as to how much notification time would be availsble fcr the . range of accidents for which planning must be basedt orlhow much timeksould be required to carry out an evacuation, or,what contingency plan _ and procedures may be needed. g ;.9 q y --

27. LiketheTMIPlan(wi5hAppendixB),AnnexEcontainsnoprcYisions for assuring that accurate, candid, complete, and timely infomation will, br even can j e: b disseminated to the public (see Annex E, i Appendix 5).

28. Appendix D of. the Plan cont'ains reference to tije*need for the decon-s tamination of radiologically contaminated iridividuals (p.16) but does not provide any infomation as to hoWmany' people may be contam-inated, the kind and degree of contamination expected or to be planned for, or the number of facilities and medical personnel appropriately trained in decontamination' andjradiation injury treatment techniques which may be necessaryA -l ^

o m.t ,

29. Appendix D suggests the possibility that membersiof the Amed Forces

' may-be needed for use:in the event of an accident. No assurance :is offered that these large.ly: volunteer members Nill not be exposedi,to largeJoses of radiation. , Nor is there any assurance that these troops'.will be monitored for radiation exposure or that, if they 5 arejexposed, their health will continue to be monitored throughout -

and'past the length of the cancer latency period or the period of genetic damage. ,j .

. c. -

30. The REMP of the TMI Plan (see #18, above) runs the risk of being totally inadequate to measure off-site exposures.in the event of a

" puff" or series of " puff" r,gl. eases. i The small humber of dosimeters atthe4-5miledistancef(romTHIleavesthevastmajorityofthe region at these distances totally unmonitored, since the width of the " Puff" may weli de very smali compared with the distance between 1819 058 these distance detectors. As a result. the probability is high that a plume can pass undetected. As a result, substantial exposures may well occur, but go essentially unrecorded. The situation is worse yet at further distances, where the level of monitoring is greatly

- - - - _ . . ..__...A*-.~.'.7l_ . . . . . . - - _

l- . . _ . .

12 *

. diminished, even though there is distances to confim the applicability of meteorological models.

need for dosimeters at larger .7 l

o . ,% 31. Appendix D assumes that in the event of another accident at TMI, A, trade-off is to be made between some alleged social Aisruption due to' evacuation and population exposure mitigation. Such an assumption

. , blames the process of evacuation itself for the alleged social' disruption while ignoring the fact that the casse of the need for evacuation, and hence the cause of any associated social disruption is the nuclear power plant. This assumption also assumes that the social disruptien due to evacuation in the event of a nuclear accident is greater than the social disruption in the event of a nuclear accident without evacuation. These assumptions and conclusions are without basis or justification. -

32. Appendix D of the TMI Plan assumes thi. availability of lead time to effectuate the Plan (p. 4). However, Appendix 8 of that Plan which is the BRH Plan, assumes the event itself will, among other things, dictate the time available (p. VII-1). This fundamental inconsistency mandates the need for all assumptions of each and every component of the entire plan to be revealed and to have the validity of each assumption fully assessed.

33. The BRH plan (Appendix 8) relies on the infant thyroid dose (1.5 rem) as the dose from milk ingestion to be avoided (p. IX-4). This does not take into account the fetus, whose sensitivity may greatly exceed that of the infant. In addition, the value of .l.5 rem to the thyroid from milkingestion does not take into account the: inhalation exposure.

(See #8 and 11, above). -

34. The BRH method of assdssing exposures to the infant thyroid by the cow-I, milk pathway is ultimately based upon the dose conversion factors found in Reg. Guide 1.109. Reliance upon these dose conversion factors in the event of an emergency at TMI may lead to actual exposures many times larger than obtained by Reg. Guide 1.109 dose conversion factors. (See ECNP Contention 3, Oct. 5, 1979, and the related dis-cussion at the Special Prehearing Conference, November 14,1979, page unknown, because these Intervenors thus far have not been granted access to transcripts.) Similar considerations apply to the Protective Action Guides for food (p. IX-8). .

35. The BRH plan (Appendix 8) states that "the Governor's Press Secretary will be the single centralized point for release of public information to the news media..." if the State plan is to be activated. However, the Lancaster County Plan (April 8,1979, addition), for example, states that the responsibility for " preparing and issuing all emergency public infomation within the county..." lies with the Lancaster Emergency Management Department.

36. ECNP contends that the routing of all infomation through the Governor's Press Secretary to the public adds unnecessary complexities to the entire plan. For example, since the Press Secretary of the Governor can reasonably be expected to be a political appointee and not necessarily knowledgeable at all in the area of nuclear accidents and their con-sequences, or the nature of radiation injury, the designation of the Governor's Press Secretary as the official and sole spokesperson adds one more pathway for and perhaps impediment to information in the

} O .1 9 0 5 9 cumbersome and circuitous route between an event or accieene at TMI and the public. There is no need for this extra step.

~

In addition, this extra step offers one more opportunity for errors and emissions to be introduced into the information and only adds further delay.

It is not expected that this extra step will result in the removal

AJ '

4 i

l of errors from the messages. Furthemore, the possibility exists, i

' with this extra, unnecessary step, for political pressure to be brought to bear to alter, delay, or even withhold crucial information from the public, s :H

37. The Dauphin County Plan (Appendix E of the TMI Plan) contains a state-ment by Representatfrve Stephen R. Reed, Chaiman,lDisaster Servcies Comittee, Harrisburg River Rescue:, Inc., which states that "It may

• take 10 or 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to evacuate the entire city. It is my understanding

, that:we will receive at least a 43.hcur notification to evacuate."

S Here?again is a fundamental' inconsistency concern.ing the time available

^  :(see #24 and 29~, above). ECNP for te'vacuation .

l reiterates its contention that until all assumptions behind the entire Plan { are revealed and the validity of these assumptions is fully assessed, the Plan in'its entirety must be regarded as wholly unacceptable.

38. The evacuation lans foNCumberlaYif, York, and Lebanon Counties are based, at least in part on the assumption that many if not most, '

evacuees will stay with friends or relatives outside the evacuation zone. This assucption is highly: questionable, since during the early days of the still-ongoing TMI-2 accident, after women and children were ordered out of the area ylthin five miles of TMI,."many tens of thousands of people outside this 'irea themselves evacuated' voluntarily.C In :the event of another accident at TMI wtjich causes a twenty mile evacuation, for which each of the five counties expresses orecaredness, the resultant voluntary evacuations of persons beyond the 20-mile radius might well mean that there will remain no friends and/or relatives for the 20 mile 9 evacuees to reside with. temporarily.

.tN ji As a result of the abovednaccu,racies, inconsistencies and deficiencies, ECNP sut;mits ttjat no evacuation plan can be devised which.hll prevent large

' '. H ti numbers of the residents within any giyen radius of TMI from receiving unaccepted 2 'W

exposures to radiation should the.' kinds'of accidents occur at TMI which i-

,,w

" involve actual or iminent substantial core degradation or melting...and/or j loss of Reactor Building (containment) integrity." (TMI Plan, p. 4-7, emphasis in the origina'T)! ECNP contends'that the nly sure method of ensuring the pro-

?.  !

tection of the4 health and safety of the u public from a utility that, even after g ..

four and one 6alf years of operating TMI-1, "did not have sufficient knowledge, expertise, and personnel to operate (TMIM!) and maintain it safely." (Report

..{. -

of the President's Commission oh t$e,Acc@.. nt at Three Mile Island, p. 44), is

~

to pemanently suspend the operating license for THI-1, and to order the complete

^

2  ;

Here, unaccepta'ble exposures are any above the EPA PAGs. Of course, it is acknowledged that many individuals regard such exposures:as totally unacceptable.

1819 060

=- = . = . . .

14 l ...- .

i dec'ommissioning of the TMI-l and TMI-2 nuclear power reactors. ...

BASES AND REFERENCES Humber 10. " Assessment of Offsite Radiation Doses from the Three Mile Island Unit 2 Accident," Pickard Lower, & Garrick, #TDR-TMI-ll6. See Rable A-3 for the days listed in the contention.

Number 11. "THI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" NUREG-0578.u See pages A-36 through A-40.

Number 16. See, in general, " Report of the President's Commission on the Accident at Three Mile Island."

Number 19. Same as No.16, see pages 49-50.

Number 20. Workbook of Atmospheric Dispersion Estimates" USEPA AP-26. See p. 40.

Number 26. Reactor Safety Study, WASH-1400, Appendix VIII, p. VIII-11 to .16.

~

Nunber 31. "Three Mile Island Telephone Survey" Draft Report. NUREG-CR-1093.

See Table II-5.

Number 34. See Contention 3, Oct. 5,1979 of ECNP and "Radioecological Assessment of the Wyhl Nuclear Power Plant". NUREG-TR-520.

I In the present absence of the necessary substantiations of the assumptions underlying the Emergency Plan,the information essential to further articulation of the bases of these contentions is lacking. In the absence of the Suspended Licensee's Appendix A Implementation Plan for the Emergency Plan, the ECNP Intervenors cannot here provide additional explication of the bases of these contentions beyond those statements incorporated in the contentions' listed above taken;in conjunction with the references here cited.

Respectfully submitted, t

January 7th, 1980.

Chauncey Kepford Representative of Intervenors 433 Orlando Avenue State College, Pennsylvania (814) 237-3900 J

1819 061

.. CERTIFICATE OF SERVICE --

I hereby certify that copies of ECNP INTERVENORS' REVISED CONTENTION ON EMERGENCY PREPAREDNESS AND EMERGENCY RESPONSE were served on the following by deposit in the U. S. Mail First Class, postage paid, this 7 day ofJanuary, 1980:

^ - ~-~ - -

SERVICE LIST Ivan W. Smith, Esquire Karin W. Carter, Esquire Chairman Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House U.S. Nuclear Regulatory P.O. Box 2357 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Safety and Licensing Countv of Dauphin Board Panel P.O. Box P 881 West Outer Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17108 Dr. Linda W. Little  : ' John E. Minnich

,I Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James A. Tourtellotte, Esquire Office of the Executive Legal Walter W. Cohen, Esquire Director Consumer Advocate U.S. Nuclear Regulatory Commission Department of Justice .

Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary Jordan D. Cunningham, Esquire U.S. Nuclear Regulatory Commission Attorney for Newberry Township Washington, D.C. 20555 T.M.I. Steering Committee.

2320 North Second Street John A. Levin, Esquire Harrisburg, Pennsylvania 17110 Assistant Counsel Pennsylvania Public Utility Theodore A. Adler, Esquire Comission Widoff Reager Selkovitz & Adl P.O. Box 3265 P.O. Box 1547 '

Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania # 5 D N Il- \

j GQ 1819 062 ya p e

cd

.....~ . .. . . _ . . . . _ . . . _ _ _ _ _ . . _ _ , . _ . - __.._.____:.__.._.___.

I

Ellyn Weiss, Esquire Robert Q. Pollard Sheldon, Harmon & Weiss Chesapeake Energy Alliance Suite 506 609LMontpelier Street 1725 Eye Street, N.W. ~ Baltimore, Maryland 21218 Washington, D.C. 20006 ,

Steven C. Sholly

. .Ce rge F. Trowbridge, Esquire 304 South Market Street Shaw, Pittman, Potts & Trowbridge Mechanicsburg, Pennsylvania 17055 Washing on . C. 0036 Holly S. Keck *'

~ ~

a Legislation Ch'irman / Marvin I. Lewis *4 Anti-Nuclear Group Representing 6504 Bradford Terrace York '

Philadelphia, Pennsylvania 19149 245 West Philadelpliia Street ,

York, Pennsylvania 17404 Marjorie M. Aamodt R.D. 5 Karen Sheldon, Esquire Coatesville, Pennsylvania 19320 ~

Sheldon, Harmon & Weiss ~~~~

Suite 506 i .' 2b06 I

. ,.-m.~--

l

.~ I I

5 G

l

c m.ae -jf)  !

Chaunceykepf004///[ f I

. . . .J A.

1819.063 m ~F d

-- -- , ,, . m. . e. 4, . <.-.... .