ML19262C114

Forwards Comments on NUREG-0553, Beyond Defense-In-Depth, Supports Funding of Emergency Plans by Imposition of User Fee.Contentions 5 & 8 Re League of Women Voters of Rockford Petition to Intervene Encl

ML19262C114
Person / Time
Site:	Byron
Issue date:	12/29/1979
From:	Johnson B LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	Ryan R NRC OFFICE OF STATE PROGRAMS (OSP)
References
RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 8001280453
Download: ML19262C114 (6)

Text

____

1907 Stratford Lane Rockford, Illinois, 61107 December 29, 1979 Robert G. Ryt.n, Director Office of State Programs U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Mr. Ryan,

Enclosed you will find copies of two of the contentions contained in the League of Women voters of Rockford's Intervention in the Operating License of the Byron, Illinois Nuclear Power Station. Contention 5 refers to Emergency Preparedness and Contention 8 on radiation mor.itoring is applicable to Emergency Preparedness in many areas which I have included in Coments on the Final Report"Beyond Defense-in Depth" which is also enclosed.

Because some of these Contentions were being revised and are not yet in final form, I delayed sending in comments and was glad that the time was extecded to Dec. 31st.

If you have any questions, please contact me.

Sincerely, f f & '.~ _, s

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Betty Johnson, diai;rperson of the r

Natural Resources and Energy Committee of the League of Women' Voters of Rockford, Illinois 8001290 1816 282'

December 29, 1979 COMMENTS ON THE FINAL REPORT "BEYOND DEFENSE-IN-DEPTH: COST AND FUNDING 0F STATE AND LOCAL GOVERNMENT RADIOLOGICAL EMERGENCY RESPONSE PLANS AND PREPAREDNESS IN SUPPORT OF COMMERCIAL NUCLEAR POWER STATIONS, NUREG-0553, OCTOBER L(&(

I. The concept of the cost of Emergency Response Plans ano Preparedness being paid by a user fee with ultimate payment by the consumer is sound and important. As stat-ed on p. I-ll and 12. "the ultimate costs should be paid by the consumers of elect-ricity which is the most equitable way of doing business." All of the costs should be clearly. understood to be costs of generating electricity with nuclear power, and they should be included and considered fully in the cost-benefit analysis for every nuclear olant to be granted a construction and/or license to operate, as well as retroactively for operating plants. As suggested on p. I-il, the defense-in depth basic philosophy in the national interest as defined by Congress should be enlarged to include State and Local Government radiological emergency response plan? and pre-paredness.

II. The goal of attaining concurrence of State plans with NRC guidelines is a good w&

one. The concept of setting up a~ National Fund where necessary,but encouraging 5i.ates to have their own Plan and Fund where possible is sound. As suggested this is needed to insure continuity of funding and priority for the plans, Wish local communities might not do, (p.106-Major dihnding), since they arr. told plant revenues can be used for schools and other community development, and long term care after plant shutdown ma1 not bring in revenues.

The proposed plan is excellant as acutlined, though it should be expanded to include facilities included in Other Actions to enhance Plans and Preparedness as on p. I-14 (see below). Setting up a Fund for State and Local government with monies for the Fund from a Fee of $1 million levied on the operator of each nuclear power station, with a review and adjustments made at least every 5 years to assure full recover of costs because of inflation, new reulations, and any changed circumstances is a good plan.

Also very good are provisions for any State that has NRC Concurrence to be reimbursed for previous expenditures for up to 2 years to encourage concurrance, and the suggest-ed plan that local governments should pay back any Federal costs advanced initially for training, planning and exercise review and othe rFederal costs related to State and local costs.

1816 283

Coments on "Beyond Defense-In-Depth" (Ookk.h

p. I-14 Other Actions to enhance Plans and Preparedness:

1) The Training Institute is a very good idea, but it is important that there be local input in developiqcurricukand also in the set up of the Instituie~.

2) It is very important that spent fuel shipments, away-from-reactor storage and other non-comercial and fixed nuclear facilities be added to response pland and preparedness and that additional funds be required for this.

III. It is important that plans should include automatic alarm systems around the site that simultaneously notify local and State authorities.

p. II-69. The Public has good reason to question notification left to Utilities and local and state government. i.e. what happened at 3-Mile Island; also for instande the w a s +<

release of radioactive water'\\in Dec. at Cordova, Illinois nuclear plant without knowledge of the Utility, etc. The automatic alanns are important for this reason and because not only don't adequately monitor radiation releases, but may in th)ir self-interest delay notification, when fast emergency response to minimize consequences of the accident is essential for protection of the health and safety of the PUblic. The State also can-not always be relied 'on for radiation monitoring. i.e. Fallout from the Chinese Nuclear ests were recorted by the State 66 Illir.ois to show no increase in radioactivity in the State, though local increases were picked up by the Winnebago County Radiologiccal Defense Officer, and though levels of I-131 were elevated in Illinois milk, the discov-ery by the State was too late te notify and warn the Public.

IV. Additional areas of agreement with proposed plans and response:

1) Need for cooperative multi-state planning where emergency planning zones cross state lines.

2) Need to include in plans both the 10 and 50 mile zones.

3) p.II-64.A mixture of the 3 types of systems may be the most desirable and necessary and also, II-61ff, Comunications systems may need a combination of systems for re-dundancy and to fit local circumstances. (see III above). Also, i.e. When a recent tornado touched down in a local rural comunity emergency radios were not operative. Full scale field exercises should be included in plans once a year to avoid this type of proble

4) p.II-89 Factors that limit cost by using existing programs must be carefufly worked out so needed infonnation is available quickly and at less cost.(see III above)

V. ESPECIAL COMMENT on p.I-5,etc. re. evacuation of areas with 100,000 population-1816 284

page 3 Coments on "Beyond Defense-In_ Depth" (cont.)

within the 10 mile zone.

There must be considration of teraporary poulations which will pose special problems in some areas, i.e. Rockford, Illinois has 150,000 population within 15.8 miles of the Byen plant site, and there are also within 10 miles of the site as many as 50,000 temporary population which may be in the area at recreational facilities, schools,et'c., who are not considered in present plans. This emphasizes the need for tayloring the plans and response to local plant-environs conditions,and the need for local input in training, etc.

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Betty Johnson, enairperson of the natural Resources,'and Energy Comittee of the League of Women Voters of Rockford, Illinois 1816 285

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CONTENTION 5. The Intervenor contenus tnat tne Applicant':. e.:.ergency c.

...s o fI plans are inadequate because they do not provice reasonable assurance

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I, equate protection for the public health and safety as required by lG C.F.R. Part 4

r f1 50, Appendix E and as detailed in suggestions of NRC NUreg-0396. To be adequatel.

3 acceptable these plans should include:

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1) The interrelation of tne Applicant's emergency plan wi th the pl.u.<,

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offsite agencies which will be responsible for implementation or cfi..le en.. -,rc 1'

response in the Byron Plant area and all areas which could be pote..t..1: 7..

MA from a serious accident. These agencies should include agencies m....i.

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sible for implementing emergency response measures wnich lie within c. %... ie 4

1 radius of the Byron Plant site.

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' 2) How accidents' in' plsnts, as descr.. ii.:..:.

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relate to emergency planning, includinyexpl ci t guicance as. ta tne t...

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magnitude of releases to the environment, whicn should oe consiaered ment of plans.

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3) Provisions made for interstate plans needed because, for instance.

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Wisconsin is within the 50 mile area pote :tially affected b-,

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a Byron plant.

4) Modifying existing plans to include explicit references, cucr.ec Li :.3 s..

offsi te" to low popula, tion zones or other geograpnical arv.,.y tw Wua p,6

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5) Including ingp,.,lans: ohow to develop plans for evacuatior/..r 4rce n.

7 populations present in tne low population :pnes in the Syron plan t a.

6) Full cost assessment as related to tne cost-cenefit ana.ysis or to.

plant, including social and economic sosts born by other agencies tn...

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.. jl and the area population, such as tnase in tne new(1979) Illinois dur,..

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7) Use of results, where applicable, of experience from emergenc/ ce,

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Thre Mile Island accident in Peensylvania, as assessed by special Buoc

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including tne present one of the NRC.

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8) Need for puolic education and awareness of plans to ir.ir.n.az,. cordsu.. u:n

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hazards and maximize public participation and cooperation in case d oe6 4,.7.

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4. The[tfef 6 enu o 7e,4>,% f M e,1 p,ec 47 h4 's "5.1'""T

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of NEPA and 10 C.F.R. Part 50. 34 (a) and 50,36 (bf ecause tne Applicant has r.ot adequately monitored and provided provided a design base for the Syron plant wnica will keep radiation levels "as low as reasonably acntevaole" as required for oper-ation of the plant to protect the health and safety of the puolic.

To keep radiation levels "as low as reasonabley achievable" the Applicant snould provide and utilize:

I. More adequate environmental and discharge monitoring of radioactive emissions from the Byron Plant, which includes:

a) Monitoring devices at more locations within and without the plant site.

b) Provisions for more frequaent reading of monitors by independent analysts.

c) Better monitoring devices wnich include $ut are not lim.ted to:

1) An automatic system of monitoring anat notifies local autrorities ey an alarm when discharge emissions exceed design limits.

2) Monitoring devices that measure differences in alpna, beta and gaan dose levels, wnica presently aren't being adequately considered ano.reasured.

3) Monitoring and recording of emissions of all dangerous long lived racia-nuclides, including tspecially !_129 and Plutonium.

4) Bioaccumulative testing in a tiered system to assess tne watane of racio-active and'cnemical pollutahts from bottom sediments or soil to low orgw. n.s and to contamination of the food cnain of man and other 11fe.

II. More accurate calculation of design doses wnicn can be acccmplisned oy ot2.: Z-ation of infomation from the improved monitoring suggested aDove and.isa cy:

a) Utilizing new evidence of effects of !aw levels of radiation wnicn.ere..s considered in design of tne plant.

b) including in calculation of doses tne large tr4ient populaticns ir, tr e.c..

population zones around the plant, including scr.ool children anen present ir. 3 scnools, and otners participating in recreational activities.

c) Including in calculation of radiation cases cur.ulat:ve deses to tne gewr, po$ulation outside tne site coundary caused by. overlapping circ;es.n ca.iotic.a M '" # %

• c6 * ' 'bding Zicn Sta" ion, Orescen Station me..e from several nuclear facilities 4 inci t

/ 2 S tation, Quad Ci ties S tateion, '4arris '.a te e sosai s i te, 2.,

• a..y facilities, sucn as tite Savannan Station, and ocai tional uni ts <r.

d) internal radiation doses caused by inhaled aac/or ingest.m o di.u.t;..m are deposited in different parts of t.'1e socy rere they give re.m t.:'1 doses until/if tnsy are eliminated fro.; 0.o

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e) calca;a tion of doses to ; Gale Oy wt. ;it

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fooa. antmals, plants, soil. nd water Li t% envun..ent w....

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(see.. c.4) o~o "o93

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