ML19345F344
| ML19345F344 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/09/1981 |
| From: | Aamodt N AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8102170306 | |
| Download: ML19345F344 (8) | |
Text
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Matter of Metropolitan Edison Company, Three Mil'lNJ.S g th Unit 1, Docket 50-289 9
AAMODT TESTIMONY TO SUPPORT AAMODT CONTENTION 4 Intervenor is pleased to note that Licensee has made con-siderable progress toward meeting the concerns of contention 4 as evidenced in the January 1981 modified revision 2 of the TMI-l Emergency Plan.
However, several deficiencies remain.
To enhance clarity of the testimony, I will state con-tention 4 in the form of its four elements:
1.
It is contended that licensee has not made provision for timely dissemination of information in the event of accidental release of airborne radioactive gases or particulates.
2.
It is contended that licensee must make information available to the public which will allow appropriate action to be taken to protect persons, livestock, foodstuff and feed in the event of a discharge of significant proportions.
3.
All data and plant operating personnel observations relative to all radioactive releases must be trans-mitted immediately and simultaneously to the NRC, Pennsylvania Department of Environmental Resources, the commissioners of Dauphin, York and Lancaster Counties and the licensee's management.
4 It is further contended that licensee must provide this capability before restart of TMI-1.
Testimony will cover three cases where intervenor will demonstrate that licensee's Emergency Plan inadequately ad-dresses one or more of elements 1-3 and, therefore, element 4 holds:
Case A - In the event of an airborne radioactive release of significant proportions inadequa.a time is avail-930D D
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h able after anticipated notification to a ssure the ability of residents in the 10 mile EPZ to take appropriate action.
Case B - Licensee has not provided the information to the public needed to provide assurance that proper protective actions will be taken by the public.
Case C - Licensee endangers the lives of children during their fetal stage by failing to inform the public (pregnant women) of all releases of radioactive Iodine.
CASE A Section 4.6.3.5 states that a minimum of 30 minutes will elapse after the declaration of an emergency before initial off site radiation monitoring data will be received at the plant.
In addition, section 4.41 states that the licensee classification system will result in the declara-tion of emergencies within 10 minutes of event initiation.
Should the event be one where a significant airborne radioactive release occurred at the outset of the event, an additional delay is encountered thru the guidelines of 4.6.3 when integrated doses are calculated and communicated to BRP.
At best, assuming off-site confirmation is by-passed, 20 minutes will have elapsed before BRP and PEMA obtain the data (10 minutes for declaration of emergency and 10 minutes to make proj ec tions and calculations and notify BRP).
At worst, more than 50 minutes may elapse if off-site confirmation is ob t a in ed. Assuming the "best" case, and a gentle 10MPHwind/, the plume w ou ld be more than 3 miles from the plant before any county other than Dauphin is alerted; in the " worst" case, it could be ap-proaching Lancaster or York.
Recommendation:
As a mimimum action, in the event of any emergency (alert, site emergency or general emergency) where there is a kncwn release of airborne radioactive material, all five counties must be notified of the release
G2D and its' proj ected path of travel by the shift supervisor immediately upon his becoming cognizant of its' existance, simutaneously with the declaration of the emergency.
CASE B Interogatory 14 (5th set, 3/31/80) inquired into the effect of utility public relations efforts to gain public acceptance of nuclear power on the willingness of the public to evacuate during an emergency, asking specifically, "b.
Does it condition complacency, therefore not assuring public participation in emergency conditions?"
NRC responded "b.
It is the staff's judgement that (1) con-fidence and trust in local response agencies, (2) an advance educational program relating to the hazards of radiation and (3) prior instructions.on emergency actions, will provide assurance that proper protective actions will be taken by the public".
Intervenor accepts the staff conclusion.
Neither licensee nor the staff nor the Commonwealth have made available to the public in the 10 mile EPZ that information needed to meet these three stated requirements.
Recommendations:
(1) that Licensee institute a suitable information release program to accomplish actions 2 and 3 and (2) ebne a joint effort be made with local agencies to assure accomplishment of action 3, prior to restart.
CASE C We have entered into the record, through interrogatories answered by Dr. Evelyn Bouden-and Dr. George Tokamata, evidence relative to infant thyroid exposure to radio-active Iodine resulting both from the accident at TMI-II and routine emissions from many if not all oper4 ting nuclear facilities.
We assert that this data warrants serious evaluation before restart of TMI-Unit I.
Because Mrs. Aamodt is fully occupied in the preparation of cross-examination relative to our contention, and cross examination.
begins February 10, we have requested an extension until
i February 16 to complete testimony on matters pertaining to this specific. issue only.
Nevertheless, we would like to enter into testimony our recommendations relative to minimum actions to be taken by the Licensee to adequately address potential thyroid exposure of infants:
Recommendations 1.
Element 3 of contention 4 2.
Licensee provide daily public reports of radioactive emissions from TMI-Unit I which can be used in a format similar to air quality reports given hourly on local radio stations.
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Norman O.
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February 9, 1981 United States of America Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board.
In the Matter of Metropolitan Edison Company, Three Mile Island i
Unit 1, Docket 50-289.
i CERTIFICATE OF SERVICE l
I hereby certify that AAMODT TESTIMONY TO SUPPORT AAMODT CONTENTION 4 was served on the Licensee at its' Harrisburg offices for distribution to the attached service list, this ninth day of February, 1981.
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Norman O.
Aamodt t
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Aamodt Testimony To Support Aamodt Contention 4, dated February 9, 1981, which was hand delivered to Licensee at 34 N. Court Street, Harrisburg, Pennsylvania, on February 9, 1981, were served upon those persons on the attached Service List by deposit in the United States mail, postage paid, this 9th day of February,_1981
%1 te.49 Ernest L. Blake, Jr.
Dated:
February 9, 1981 L
UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Ivan W.
Smith, Esquire John A. Levir., Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm.
Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Harrisburg, Pennsylvania 17120 Commission Washington, D. C.
20555 Dr. Walter H. Jordan Karin W. Carter, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel 505 Executive House 881 West Outer Drive Post Office Box 2357 Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little John E. Minnich Atomic Safety and Licensing Chairman, Dauphin County Board Board Panel of Commissioners 5000 Hermitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire (4)
Walter W. Cohen, Esquire Office of the Executive Consumer Advocate Legal Director Office of Consumer Advocate U. S. Nuclear Regulatory 14th Floor, Strawberry Square Commission Harrisburg, Pennsylvania 17127 Washington, D. C.
20555 Docketing and Service Section (3)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555
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Jordan D. Cunningham, Esquire William S. Jordan, III, Esquire Fox, Farr & Cunningham Harmon & Weiss 2320 North Second Street 1725 Eye Street, N.W.,
Suite 506 Harrisburg, Pennsylvania 17110 Washington, D. C.
20006 Ms. Louise Bradford Robert Q. Pollard TMI ALERT 609 Montpelier Street 315 Peffer Street Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17102 Chauncey Kepford Ellyn R. Weiss, Esquire Judith H. Johnsrud Harmon & Weiss Environmental Coalition on 1725 Eye Street, N.W.,
Suite 506 Nuclear Power Washington, D. C.
20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C.
Sholly Union of Concerned Scientists Marvin I. Lewis 1725 I Street, N.W.,
Suite 601 6504 Bradford Terrace Washington, D. C.
20006 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt ANGRY R. D.
5 245 West Philadelphia Street Coatesville, Pennsylvania 19320 York, Pennsylvania 17404 Attorney General of New Jersey John F. Ahearne Attention:
Thomas J. Germine, Esq.
Chairman Deputy Attorney General U.S. Nuclear Regulatory Commission Division of Law - Room 316 Washington, D. C.
20555 1100 Raymond Boulevard Newark, New Jersey 07102 Victor Gilinsky Commissioner Peter A. Bradford U.S. Nuclear Regulatory Commission Commissioner Washington, D. C.
20555 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Joseph M. Hendrie Commissioner U.S. Nuclear Regulatory Commission Washington, D. C.
20555
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