ML20003E156
| ML20003E156 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1981 |
| From: | Nettleship H ANTI-NUCLEAR GROUP REPRESENTING YORK |
| To: | NRC |
| References | |
| NUDOCS 8104020373 | |
| Download: ML20003E156 (4) | |
Text
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i My name is Hal Nettleship.
I'm speaking for MiGRY, the anti-nuclear group representing York.
We are involved in this hearing prir.cipally cn the issue of Emergency Planning, our contentieb being C at the present emergency plans are inadequater that if another accident occured the plans we have now would probably not work i This is an important issue because cu, the Board, have alreadv ruled chat TMI-1 cannot be allowed to operate before there are adecuate and effectuated plans in place. You agreed to that over a year ago as MiGRY contention #1.
If the record shows that tne plans are not adequate or effectaated - then pu will be bound to keep the plant shut until the state, the count.ies and MET ED make their plans da adequate.
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I think that phrase "vdoquate and effectuated"' is pretty impo
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and I'd like to go into it a little more.
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I think we all understand that the plans should be adequate.
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l really, the word effectuated is more i=portant, for this reasen: Th Y
word means, "can the plan be put into effect" ?
A plan can meet all th DI applicable regulations on paper, but if we can't put it into effect, it's really worthless.
Indeed, worse, in that the public will be told there is a plan in place, when there really is spq plan.
If another accident were to occur, and attempts were made to put the plan into effect, the public would suffer again.
In my judgment, this is the situation in which the Board now finds itself:- M2en the NRC gave operating licenses to TMI-1 and 2, it assured the public that the Emergency phand for TMI were adequate to pa:>tect the
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public health and saf ety....They met the " applicable regulations".
[' k But then we had the Class 9 accident at TMI-2, and we found the plans did not work.
The plans looked fine on paper, but tV v
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emergency, the state, the counties and MET ED were not pre ed Sq D
them out.
Your regulations were not good enough.
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Because of what happened two years ago, you, as representatives of the NRC, are in a very unusual situation.
Because the NRC approved plans that l
turned out to be worthless, the people in this area have lost confidence i
in the HRC.
In a very real sense, it is not just ME ED that's on trial in this hearing. The entire NRC is on trial.
At the same time *ycu're trying to judge TMI-l's fitness to operate, y'ou should be aware that the people here are watching and judging you.
khat all this means is - that if the NRC wants to win back the public's confidence, it will be necessary to be much more thorough than your predecessors have been.
It will not be enough to say that the plans reeet i
the current regulations, even though the regulations now are much str.icter than they were two years ago.
You're going to have to investigate whether the plans can actually be put into effect 1 This means, 31 least, full ccur.pliance with Nureg 0654.
And, it means compliance must be demonstrated in pahlic hearings.
If the record shows that the communications systems are dependent en telephones that may be Jamed in the event cf an r. srgency, then pther systems must be installed.
If the municipal plans are note ready, now-two years after the accide.t, the board must find out why the plans ared not now ready.
..You must also find cuc if it is reasonable to think these plans will SZeE 32e readvj or 11, the municinal coverfuments h_gv3 the ability to make plans, carry them out and pay for required equipnent without much more financial assistance.
If the plans do not now meet with approval from the Federal Emergency Management Agency,-it should be incumbent upon you, the board, to find out why, two y urs after the accident, the plans are st_ill not adequate.
14at you must NOT do is assume that the plans and deficiencies will be fixed sometime after the hearings. The Stata and the licensee have had plenty of time already.
We, and other intervenors, have provided detailed xx and specific faults in the plans for them to correct.
This is an extraordinary
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r contributions for citizens to make. We want results, not more empty promises.
If you do not detemine that the plans are adequate and effectuated during the hearings, when the state and the licensee have had two years to work on them, you must not leave us with the empty promise that the plans will be ready at some nebulous time in the future.
Your role, and the role of the NRC as a whole, is to protect u. Not J
to protect the licensee's investment, but to protect us_ !
r The NRC failed us before.
The NRC allowed TMI to operate before without adequate management, without adequate safety back=ups, and without adequato
'lans.
You allowed TMI-2 to operate and to have a class 9 accident.
p The NRC's " CUTAIN WEST" Study showed that we citizens had to spend S94 million to evacuate.
The courts have awarded $25 million in a class action suit.
Nothing will ever repay or repair the damages vou caused us, before by allowing TMI to operate.
We will never be able to forget the sufferings you caused us.
We think Three Mile Island should never be permitted to operate again.
We will have to live with the cleanup at TMI-2 for decades.
The York City Council tecently passed a resolution against allowing TMI to operate before the cleanup is complete, and we agree with that, too.
You failed us before and you will fail us again if you do not find out that the management is competent, the plant safety systems are adequate, and the emergency planning is cceelete, before you decide on whether or not to allow restart.
You owe it to is.
It is not our responsibility to prove our case to you, it is y_ogI resoonsibility j;g, erotect the ecblic.
-I'd like to speak of one other concern. Under normal NRC practice, if a
you decide the emergency plans are not good enough, you will give the NRC staff the power to allow restart, as soon as the staff decided that the pkans have been sufficiently improved.
I thin thau you should avoid doing that in this hearing.
The NRC should reconvene this hearing when the time comes to check on implementation of bpro
4 comes to check on implementation of improvements.
A quiet staff decision on the restart would just reinforce our mistrust.
The NRC can't win back the public's confidesce if it goes back to operating in the dark.
Only a full and open hearin, which considers the IejLL M, as well as the paper plans, can begin to win back the public confidence that y_ill he_ ao i
necessary during the cocaing years of cle,anup.
You owe it to us.
Thank you for coming out to hear our ctatements.
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