ML19290B976
| ML19290B976 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/17/1979 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001090003 | |
| Download: ML19290B976 (10) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O
BEFORE THE ATOMIC SAFETY AND LICENSING BOA In the Matter of Doc METROPOLITAN EDISON COMPANY sa (Three Mlle Island Nuclear Station, Unit No. 1)
PETITIONER's REVISED EMERGENCY PLANNING CONIENTION BY STEVEN C. SHOLLY, PEIITIONER Pursuant to the date set forth during the Special Prehearing Conference, Steven C. Sholly, Petitioner, sets forth herein a revised " Emergency Planning" contention which replaces in its enttrety Contention No. 8 from the Final Contentions filed 22 October 1979.
Petitioner notes that Licensee has amended his Emergency Plan during the period provided for review of Licensee's original submittal, and therefore Petitioner specifically reserves the right to revise this contention by filing such revisions within 30 days of the date the Licensee's revised Emergency Plan was received by the Peti.tioner.
In addition, Licensee's Plan and the Kemeny Commission documents both point out the need for a copy of the Emergency Plan Implementing Document in order to fully determine the adequacy of the Ltcensee's Emergency Plan.
In spite of a call to Counsel for Licensee (specifically, Mr. Zahler), Petitioner was unable to either obtain a copy of the EPID or a location where the EPID could be revtewed; Petitioner was informed by Mr. Zahler that the EPID was in the process of revision and was not now gget0900D3 1729 066
2-available for review.
Petitioner therefore reserves the right to revise and amend this contention within 30 days of receipt of the EPID or receipt of information as to its availability in the Licensee's Reading Room.
Contention # 8 It is contented that Licensee's Emergency Plan for Unit 1 ts inadequate and insufficient to permit a finding of reasonable assurance that the public health and safety will be protected under emergency conditions at Unit 1.
The following specific defects in the Licensee's Emergency plan are contended and must be resolved prior to restart to protect pubite health and safety:
A.
There is insufficient documentation presented in the plan of the sufficiency of communication links with Federal, State, and local governments and offiste support organizations (such as medical and firefighting) under emergency conditions :
B.
The Emergency Action Levels chosen by the Licensee are inappropriate because they permit too high a dose of radiation to the population at risk before protective actions are taken :
C.
The Ltcensee's chotee of a 10-mtle radius for the plume Emergency Planning Zone (FPZ) is arbitrary in that no methodology is discussed which indicates that the Emergency Plan EPZ takes appropriate consideration of local conditions such as topography, land use, demography, access and egress routes, jurtsdictic.nal boundaries,
and the presence of two large population centers and York) proposed 10-mile near the plume EPZ (Harrisburg D.
Inasmuch as Class 9 accidents are known to occur at a much greater frequency than believed prior to the Unit 2 accident, and NUREG-0585 tdentifies Class 9 accidents as "... the dominant contributors 1729 067
. to overall risk from nuclear power plants, " (NUREG-0585 at pages 3-4 and 3-5), and NUREG-0396 emergency planning considerations list as consistent with this document the consideration of Class 9 accidents in emergency planning, Licensee's Emergency Plan give' no evidence that Class 9 accidents have been appropriately considered E.
The energency plans of the Licensee and the State and County governments within the plume EPZ are not sufficiently coordinated in that the State and Local emergency plans do not have compatible emergency classification schemes which take adequate nocice of the wide spectrum of possible consequences and time sequences which are p,ossible as a result of an accident at Unit 1; F.
The Licensee's emergency plan falls to address the problem posed by the unusually large number of persons within 10 miles of Unit 1 (Three Mile Island has the fourth largest population within 10 miles of any operating nuclear reactor in the United States according to NUREG-0553 at page II-90)
G.
The Licensee's emergency plan fails to address the low esteem in which it is held as a source of information by the general pubite (60% of those interviewed rated Metropolitan Edison Company as " totally useless" as a source of informatien during the Unit 2 accident according to a prelim-inary report prepared under NRC contract 04-78-192);
H.
The Licensee's emergency plan fails to provide sufficient information on time estimates required to recognize and assess an emergency condition, complete required notifications, implement necessary protective actions, and confirm that such actions have been successfully implemented; I.
The emergency plan contains inadequate description of the methods which will be employed to ensure timely notification of the public within the EPZ:
J.
The emergency plan contains insufficient descriptions of the nature and scope of support services provided by outside contractors and the qualifications of these contractors to provide such services K.
The emergency plan fails to contain a sufficiently detailed description of the specific response 1729 068
. capabilities for each government agency involved with the emergency plan in terms of the expertise of personnel and other resources available to such agencies:
L.
Letters of Agreement and Understanding incorporated into the emergency plan as Appendix C are outdated (nearly all pre-date the Unit 2 accident), fati to indicate with sufficient detail specific commit-ments for support operations, and fail to indicate a clear concenpt of radiological emergency response operations:
M.
There is inadequate planning in the emergency plan for not'ification of transients within the plume EPZ of emergency conditions and expected actions to be taken to provide protection of health and safety in the event of an emergency:
N.
The Licensee's emergency plan fails to adequately address the ingestion exposure pathway EPZ as per the requirements of NUREG-0396:
O.
The emergency plan fails to specify exposure guidelines to be followed for emergency personnel providing medical, firefighting, and decontamination services, and falls to specify how these guidelines are to be implemented and that the necessary support organizations are aware of these guidelines and understand their implications in terms of providing the required services:
P.
The emergency plan fatis to provide evidence that hospital and medical personnel are prepared and qualified to accomodate radiological emergencies, especially injured persons who may also be radioactively contaminated:
Q.
The emergency plan lacks sufficient provisions to assure the effectiveness of the plan throughout the operational lifetime of Unit 1:
R.
The emergency plan fails to contain a letter of agreement and understanding with Cumberland County, portions of which fall within the proposed plume EPZ:
S.
The emergency plan contains letters of agreement and understanding which fall to specify emergency assistance to be provided and fail to provide 1729 069
. mutually acceptable criteria for their implementation; T.
Licensee's emergency plan does not, in the light of the Unit 2 accident, demonstrate adequate recognition of the potential complexity of emergency conditions, the rapidity with which relatively minor initiating events can escalate into more serious accidents, and the limited response time which may be available to diagnose the event properly and implement in timely fashion the appropriate corrective. actions :
U.
The proposed 50-mile radius ingestion EPZ contains parts or all of the following counties for which there is no evidence within the emergency plan of contact with and/or letters of agreement and understanding with these counties:
Adams, Franklin, Chester, Perry, Mifflin, Juniata, Snyder, Berks, Northumberland, Columbia, Schuykill, and Northum-berland.
The proposed 50-mile radius ingestion EPZ also includes portions of the state of Maryland, for which no evidence is in the emergency plan of appropriate contact and/or written agreements; V.
There is nothing within the emergency plan to suggest that the Licensee will not continue, under emergency conditions, to interpret events in the manner which casts themselves in the best light (i.e., minimizing negative information and emphasizing positive information), to the detriment of the concept of emergency preparedness:
W.
There is nothing within the emergency plan to ensure that the Licensee has taken appropriate precautions to provide a sufficient number of operational and properly calibrated radiation monitoring instruments, along with qualified personnel to operated these instruments, such that such instruments will be available to provide needed emergency radiation surveys of and onsite and offsite areas which may be affected under emergency conditions ;
X.
The emergency plan falls to include the means and time required to warn or advise persons involved in protective actions, including businesses, property owners, tenants, transients, schools and recreational facilities, hospitals and nursing homes, and the general public; 1729 070
. Y.
The emergency plan contains numerous maps which are not clearly legible (as per Reg. Guide 1.101, Section 10), specifically Figures 2, 3, 4, 5, 6, 7, and 8:
Z.
The Exclusion Area specified in the Emergency Plan contains water surface area.in the Susquehanna River over which Elcensee has no legal means to control access:
AA.
The emergency plan states that the Emergency Plan Implementing Document is coordinated with the Emergency Plan, the Security Plan, the Radiation Protection Plan, and other unspecified procedures, yet no evidence of this. coordination is provided:
BB.
The emergency plan incorporates numerous documents by reference, a practice which will, under emergency conditions, significantly slow response times due to lack of a single source for necessary emergency information and procedures CC.
The emergency plan states that the emergency classification system proposed by the Licensee
"... is designed to permit rapid evaluation of plant conditions against emergency action levels so as to promptly recognize and declare emergencies (within 10 minutes o f event)...",
yet no supporting documentation as to how this 10-minuate limit is achieved is provided, in spite of the occurrences during the Unit 2 accident.
Specific documentation as to training and instrumentation uttitzed to provide this assurance of 10-minute warning capability are required to accpet such a statement frcm the Licensee DD.
The Licensee's emergency classification scheme contains numerous emergency action levels which are inappriate, including:
1.
Under UNUSUAL EVEhT, reactor trip followed by unanticipated automatic ECCS initiation, near or onsite release of toxic or flammable substances which affect the habitability required for normal plant operations, and valid Reactor Building evacuation alarm 2.
Under ALERI, measured RCS pressure of in excess of 2500 psig, reactor butiding pressure of equal to or greater than 4 psig, failure of PORV to shut, and loss 1729 071
. of all offsite power coincident with loss of both Diesel generators:
3.
Under SITE EMERGENCY, loss of all offsite power and loss of both Diesel generators coincident with total loss of vital AC and DC power, failure of ECCS to start and run following automa'tte initiation such that the number of components available is below the minimum assumed for accident analysis, and offsite radiological monitoriq report of 50 mR/hr at any location (gamma).
EE.
The classification of hypothetical accidents which are compared with the Licensee's proposed new classification scheme for emergency classes is insufficiently broad to determine that all events which can be hypothesized for Unit 1 fall into the given classification scheme FF.
The Shift Supervisor, assigned responstbtlity as Emergency Director, is responsible under certain situations to make emergency response recommendations to offsite authorities, yet this position has with it no requirement for a health physics or public health background which would qualify this position to make such recommendations with any degree of authority; and, GG.
The Shift Supervisor, during emergency conditions until relieved as Emergency Director, has far too many duties to devote adequate time to assessment and response activities relating to the emergency.
dated:
17 December 1979 Respectfully submitted, CERTIFICATE OF SERVICE J)A4,. <
t.-y By my signature above, I, Steven C. Sholly, hereby certify Steven C. Sholly (/'
that a single copy of PETITIONER's 304 South Market Street REVISED EMERGENCY PLANNING Mechantcsburg, PA 17055 CONTENTION BY STEVEN C. SHOLLY, (717) 766-1857 PEIITIONER, has been served on (717) 566-3237, 3238 John Wilson, Metropolitan Edison Company, on 18 December 1979, in accordance with Licensee's procedures for service to other parties.
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g 9 CEC 1919791> b UNITED STATES OF AMERICA dj NUCLEAR REGULATORY COMMI ION q
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BEFORE THE ATOMIC SAFETY A.
' LICENSING BOARD
's
..mi In the Matter of
)
METROPOLITAN EDISON COMPANY e art (Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Revised Emergency Planning Contention of Petitioner Steven C. Sholly, dated December 17, 1979, which was hand delivered to Licensee at Three Mile Island Observation Center, Middletown, Pennsylvania, on December 18, 1979, were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, this 19th day of December, 1979.
- $WM" John F. Wilson Dated: December 19, 1979 1729 073
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
METROPOLITAN EDISON COMPANY Re rt (Three Mile Island Nuclear
)
Station, Unit No. 1)
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 Co= mission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Robert L. Knupp, Esquire Dr. Walter H. Jordan Assistant Solicitor Atomic Saf ety and Licensing County of Dauphin Board Panel P. O. Box P 881 West Guter Drive 407 North Front Street Oak Ridge, Tennessee 37830 Harrisburg, PA 17108 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board of Board Panel Co=missioners 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 Cocmission 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 Dublic Utility Theodore A. Adler, Esquire Commission Widoff Reager Selkowitz & Adler P. O. Box 3265 P. O. Box 1547 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17105
- Person on whose behalf service is being made.
Only Certificate of Service is enclosed.
I729 074 m'
Ellyn Weiss, Es'guire Robert Q. Pollard Sheldon, Harmon'& Weiss Chesapeake Energy Alliance 4
Suite 506 609 Montpelier Street 1725 Eye Street,.N.W.
Baltimore, Maryland 21218 Washington, D.C.
20006 Chauncey Kepford Steven C. Sholly
- Judith H. Johnsrud 304 South Market Street Environmental Coalition on Nuclear Power Mechanicsburg, Pennsylvania 17055 433 Orlando Avenue State College, Pennsylvania 16801 Frieda Berryhill Chairman, Coalition for Nuclear Marvin I. Lewis Power Plant Postponement 6504 Bradford Terracc 2610 Glendon Drive Philadelphia, Pennsylvania 19149 Wilmington, Delaware 19808 Marjorie M. Aamodt Holly S. Keck R. D. 5 Legislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York Jane Lee 245 West Philadelphia Street R. D. 3 Box 3521 York, Pennsylvania 17404 Etters, Pennsylvania 17319 Karen Sheldon, Esquire George F. Trowbridge, Esquire Sheldon, Harmon & Weiss Shaw, PL?tman, Potts & Trowbridge Suite 506 1800 M Street, N.W.
1725 Eye Street, N.W.
Washington, D.C.
20036 Washington, D.C.
20006
- Person on whose behalf service is being made.
Only Certificate of Service is enclosed.
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