ML19332A917

Second Amended Final Addl Contentions 12,13,16,17,18 & 19 Re Dauphin County Emergency Plan.Plan Deficient Due to Lack of long-term Mgt Planning.Affidavit & Certificate of Svc Encl

ML19332A917
Person / Time
Site:	Three Mile Island
Issue date:	09/11/1980
From:	Cunningham J NEWBERRY TOWNSHIP TMI STEERING COMMITTEE
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8009180571
Download: ML19332A917 (6)

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S- t:sMC f UNITED STATES OF AMERICA h SEP 15 C >

NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY ANU LICENSING BOAR 0g 5 .

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In the Matter of:  :

METROPOLITAN EDISON COMPANY,  : Docket No. 50-289 et al.  :

TThTee Mile Island Nuclear  : Restart Station, Unit No.1)  :

SECOND FINAL AMENDED CONTENTIONS OF NEWBERRY TOWNSHIP TMI 5TEERING COMMITTEE, ET AL. TO THE Md RiiPOLITAN EDISON

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EMERGENCY PLAN; YORK COUNTY PT0TECTIVE ACTT6N PLAN FOR THE~

THREE MILE ISLAND NUCLEAR POWER PLANT; AND DAUPlilN COUNTT71YED NUCLEAR FACIEITT INCILIENT RESPONSE PLAN ADDITIONAL CONTENTIONS DAUPHIN COUNTY PLAN

12. The chain of command as set forth in the Dauphin County Plan is defi-cient in that the Plan does not state who is in charge of evacuation with regard to specific areas; the Plan does not state who is in charge of emergency personnel once they have been withdrawn to a staging area. The Plan dos not list the second in command to local Emergency Coordinator Directors and this raises the issue of whether there are seconds in command to replace those who have somehow becoae disabled or not present at the time of the emergency.

There is no indication in the Dauphin County Plan that if there are Assistant Directors, how they will know they are in command, and if there are no seconds in command, who will assume the responsibility of the Emergency Coordinator Directors in their absences. All of these deficiencies rer.2er the Dauphin County Plan inadequate.

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! 13. The Dauphin County Plan does not specifically state a differentiated 4 com1only recognized evacuation signal that could be recognizedo 'y the citizenry g throughout the county.

The Plan does not indicate whether the alarm system g

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. S I that is to be used is to be driven by a regular power systen and if the source was terminated, whether the system would still work. The Plan does not indicate whether all areas within the county are within hearing distance of the sirens.

Such deficiencies render the Einergency Response Plan inadequate.

14. The Dauphin County Plan does not specifically state how the following occurrences would be dealt with in the event of an evacuation:

(a) Accidents on the highways; (b) Cars running out of gas; (c) Generally disabled vehicles; and (d) Individuals who need ambulance service for removal from accidents.

The P1an does not s, tate whether gas stations will be mandatorily required to be open in order to meet the demands of the evacuating public.

Finally, the Plan seems to assume that the best of all atnospheric and weather conditions would exist at the time of the evacuation. What would take place in the event of a snowstonn and how would that effect the evacuation? What would be done in order to clear the roads? These are all questions that have to be considered and are necessary to be considered in a total evacuation p1an and the location and placement of staging areas.

15. The Dauphin County Plan indicates that it has a total need of approxi-

.nately 600 ambulances for the evacuation of all cembers of tha exposed populace and indicates only 45 are available. The Plan also indicates that it could obtain an additional 226 ambulances from outside the county, still leaving a shortfall of approximately 300 ambulances. There is no solution to the problen indicated in the Plan and it is submitted that there are other deficiencies, conflicts as to the number of ambulances required within the Plan and that without further specification, the Plan renains deficient.

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16. The Dauphin County Plan as set forth does not provide for differen-tiltion of time of day or seasons or weather conditions at the time of the evacuation. There is no sensitivity analysis as to these factors, and the Plan is based upon an assu:nption of best-case analysis. Therefore, it is Interve-nor's position that without taking these factors into consideration, the Plan renains deficient as concerns the time needed to effect an evacuation.

17. The Dauphin County Plan lists only two (2) 911 operators in place in the event of an evacuation. It is submitted that two operators is grossly insufficient when it is taken into consideration that the York County Plan incorporates forty-nine (49) 911 operators in order to deal with an evacuation.

Until and unless there is a commitment for more 911 operators to be in place during an emergency, the Dauphin County P1an remains deficient.

18. The Dauphin County Plan as presently written envisions mass transpor-tation vehicles to assemble at two staging areas. Upon arriving at the staging areas, the vehicles would then be dispatched to various areas to be led by community leaders. It is submitted that such a plan without the provision of security being placed on the buses and .nass transportation vehicles does not ensure that said vehicles will be able to carry out their intended functions.

It is submitted that more staging areas would be required in order to effec-tively deal with mass transportation and until and unless those local regional-i i::od areas are stated in an emergency plan, all plans will remain deficient.

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19. The Dauphin County Plan is deficient in that there is no long-term  !

management provision in the event of an evacuation which would last greater I than three days. Without such long-tenn p15nning, there is a possibility and a probability that confusion would reign af ter an evacuation of three days and it'l i submitted that in the March,1979 incident, the evacuation lasted for five 1 1

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. days. Therefore, until and unless there is greater long-tenn management planning provided for in the emergency plan, the Plan remains deficient.

FOX, FARR & CUNNINGHA'i l

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/,Af320 Nor ' econ # Street V Harris rg, Pery6ylvania 17110 717/238-5570 Attorney for Newberry Township TMI Steering Committee Date: September 11, 1980 I

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e COMMONWEALTH OF PENNSYLVANIA )

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COUNTY OF DAUPHIN )

I, WENDY R. LOOS, Word Processing Operator of the fir:n of Fox, Farr &

Cunningham, do hereby swear and affirm the following:

1. On Monday, September 8,1980, I was programming into the Vydec Word Processor in the effice of Fox, Farr & Cunningham the Second Final Amended Contentions of Newoerry Township Tit! Steering Committee;

2. That upon printing said Second Final Amended Contentions, a certain section of the Contentions, namely those contentions enclosed herein and referenced as " Additional Contentions, Dauphin County Plan" were not displayed and printed out for inclusion in the original Second Final Amended Contentions.

3. That on Thursday, September 11, 1980, the oversight was discovered, the additional contentions were printed out, are enclosed herewith entitled

" Additional Contentions, Dauphin County Plan" and should be included with the Second Final Amended Contentions as previously sub:nitted.

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Sworn and subscribed to beforemethisl day of ,

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:  :

METROPOLITAN EDISON COMPANY,  : Docket No. 50-289 et al.  :

TTh7ee Mile Island N'uclear  : Restart Station, Unit No.1) .  :

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Additional Second Final Amended Contentions was aailed First Class, postage prepaid, this lith day of September,1980, to the following:

Secretary of the Comission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 g Attn: Chief, Docketing Service Section ' M, ,,

N Y q" Ivan W. Smith, Chaiman . . . -

Atomic Safety and Licensing Board 7 ~

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 7 e._

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\g 0'% :M.**wn C Or. Walter H. Jordan C: M i e :: Ac 881 West Outer Drive 1. cu g 4 l l pf \ V Oakridge, Tenn. 37830 /

Dr. Linda W. Little 5000 Hermitage Drive Raleigh, N. C. 27612 George F. Trowbridge, Esq.

SHAW, PITTMAN, POTTS & TR0WBRIDGE 1800 M. Street, N.W.

Washington, D.C. 20036 James A. Tourtellotte

, Office of Executive Legal Director

U. S. Nuclear Regulatory Commission I

Washington, D. C. 20555

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