ML19332A496

Suppl to 800804 Response to Licensee Interrogatories Re Emergency Plan in Local Counties.Plans Do Not Address Evacuation During Significant Population Changes.Certificate of Svc Encl

ML19332A496
Person / Time
Site:	Three Mile Island
Issue date:	08/29/1980
From:	Sholly S AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8009160169
Download: ML19332A496 (5)

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' SHOLLY, 8/29/80

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w O A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 6 e D 2 ko #4n[0 _.

Before the Atomic Safety and Licensing Board In the Matter of N @

g METROPOLITAN EDISON COMPANY,-~ET AL. ) Docket No. 50-289

) (RESTART)

(Three Mile Island Nuclear )

Station, Unit No. 1)

INTERVENOR STEVEN C. SH0LLY SUPPLEMENTAL RESPONSE TO LICENSEE'S INTERR0GATORIES ON REVISED EMERGENCY PLAN The.following constitutes my supplemental response to interrogatories which were answered initially in a filing dated 8/4/80.

INTERROGATORY #2 Responses to previously outstanding discovery requests have not materially altered my prior response. The response to interrogatory #2 as filed 8/4/80 does not require supplementation as I had earlier presumed that it would.

INTERROGATORY #4 l

The emergency plans of the local counties do not constitute a sufficient basis to resolve the concerns of Contention 8(c). These plans contain unproven assumptions which, if incorrect, could have disastrous

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/ SHOLLY, 8/29/80

. consequences. These plans contain, in addition to problems identified i

in earlier filing, assumptions that presume sufficient lead time in the

. event of an accident requiring evacuation to fully implement the plan, including provisions for' traffic control . . prior to the evacuation annnuncement. This is an unproven assumption, and one which should not be relied upon in predicting the effactiveness of such emergency plans.

To select an example, the following specific defects in the Cumberland County Plan have been identified, the sum of which makes the plan unsuitable:

a. The plans consider only short-term evacuation. t!o j long-term evacuation plans are explained,

b. The evacuation of New Cumberland to Newville while evacuating Mechanicsburg only to Carlisle, less than 5 miles more distant from TMI than Mechanicsburg, is an. obvious defect. People from f*echanicsburg simply will not stop at Carlisle. To the extent that the

plan relies on support services and facilities in Carlisle to support evacuees from Mechanicsburg, the plan is defective.

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c. Chains of command are not well-delineated. In the l a!'.sence of key personnel, for whatever reason, appears I

co leave positions such as transportation open. The specific chains of command for each key position should .

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l be clearly explained. ,

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d. The plan fails to- recognize significant seasonal -

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SHOLLY, 8/29/80

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., population changes.

e. The " phased" evacuation presumes that other persons

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in lower priority areas will remain until they are called upon to leave. This assumption is unproven.

f. A sudden evacuation may result in a far higher than 507. need for care at relocation centers in host areas.

g. There are - references in the plan for care and/or transporta. i in of prisoners (for example, at the

' State Correctional Facility at White Hill).

h. It is unclear whether the EBS station (WHYL) has emergency power provisions.

-1. It is unclear that sufficient phone lines are available at the call-in location for persons without transportation. Such inadequate provision could cause panic.

j. There are ~ clearly insifficient provisions made for transportation; even where this is acknowledged in the plan, there is little specified as to how the required transportatice will be acquired.

This does not constitute an exhaustive list of defects in the Cumberland County plan, nor does it reference the other four county plans.

It is merely meant' to exemplify why these plans are insufficient as a basis for emergency planning outside the circular 10-mile EPZ proposed by Licensee.

SHOLLY, 8/29/80 INTERROGATORY #9 The specific data requested by this interrogatory is unavailable -

as of this date. The data is being sought by counsel ior ANGRY and mysel f. When we obtain the specific data, it will be provided in a supplemental response or in direct testimony.

INTERROGATORY #15 Despite assertions by Mr. Zahler to the contrary, I am not in possession nor have I received a copy of the Department of Agri. culture emergency plan. The only reference in the State Plan at Appendix 7 is that the plan is "under separate cover." I have never received this plan; I have never seen it. I cannot therefore respond to this interrogatory with more specificity.

INTERR0GATORY #21 See response to Interrogatory #15 above. I simply do not have

-and have not received this plan.

RESPECTFULLY SUBMITTED,

__ Dn DATED: 29 August 1980 M./4 Steven C. Sholly

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/ UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!' MISSION , _.

Before the Atomic Safety and Licensino Board .

' )

In the Matter of ~) l'

)

tiETROPOLITAN EDISON COMPANY, ~ET AL. - ) Docket No. 50-289 -

) (RESTART)

(Three Mile Island Nuclear ) '

Station, Unit No.1)

CERTIFICATE OF SERVICE By my signature below, I hereby certify that a single copy of INTERVENOR STEVEN C. SHOLLY SUPPLEMENTAL RESPONSE TO LICEtlSEE'S I TERR 0GATORIES ON REVISED EMERGENCY PLAN was served upon the parties on this service list in the manner in .cate .

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SERVICE BY: ' '

SteViln C. Sholly A--1st clasr mail -

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B~--Express mail ~

C--Hand delivered

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Ivan'W. Smith, Esq. .. Office of the Secretary Chairman, Atomic Safety and -

U.S. Nuclear Regulatory -

Licensing Board Panel Commission U.S. Nuclear Regulatory ~

-Washington, D.C. 20555 Commission 3

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ATTN: Docketing and Service Washington, D.C. .

20555 Section ,

Dr. Walter H. Jordan .- Office of the Executive Legal Atomic Safety and Licensing .. _ , Director -

Soard Panel . 2.-'- ?U.S. Nuclear Regulatory 881 West Guter Drive . Commission -

Oak Ridge, TN 37830 Washington, D.C. 20555 Dr. Linda W. Little

• George F. Trowbridge, Esq.

Atomic Safety and Licensing Shaw, Pittman, Potts & Trowbridge Board Panel .1800 M Street, N.W.

5000 Hermitage Drive - - . Washington, D.C.

20006 Raleigh, NC 27612 .

Service by Ist class mail on.9/1.0/80 e