ML20009B383
| ML20009B383 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/10/1981 |
| From: | Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20009B374 | List: |
| References | |
| NUDOCS 8107150345 | |
| Download: ML20009B383 (47) | |
Text
SHAw, PITTMAN, PoTTs & TROWBRIDGE 1800 M STR ECT, N. W.
WASHINGTON, D.C. 2OO36 RAuaAY D. POTTS M ATiAS r. TRAviESo.Diaz (202) 822-sOCO STEUART L. PfTTM AN VICTORIA J. PERKINS
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GEoi.GE r. TRowsmiDGE JOHN M. O'N EI LL, J R.
ETEPMEN D. POTTS JAY A. EPSTIEN yg gggg pq gg 6ENALD CHANNCFF RA N D L. A LLE N PMLLip D. BOSTwlCK TIMOTHY B. Me8 RIDE (202) 822 8099 & 822 fl99 E R M.ROG RS. J R.
CY LI A S
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FkED A. LITTLE PAUL A. R APLAN TELEX JOHN 8. RMIN CLANDER MARRY M. GLASSPIEGEL Li4UCE w. CHURCHILL RANDAL 5. KELL h
89 2693(SHAWLAW WSM)
LE3 LIE A. NICHOLSON.JR.
THOM AS M. McCORMICK 00 7 y,g h
CAB LE 'SHAwLAw*'
M AftTIN O.MRALL SUSAN D. FALKSON ElCHARD J. N ENDALL WILLI A M P.BARR JAY E. SIL8 ERG SUSAN M.FREUND 8*
'j t;AGGARA M. ROSSOTTI MARM SCHULTZ
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EDWARD B. CROSLAND
'llUL 1 O'710 0{
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C ECIG E V. ALLEN. JR.
JOH N L. CA R R. J R.
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- COUNSEL wM. CRADFORD REYNOLDS PHILa p J. HARvEY FXED ORASNER ROBERT M. GORDON Q
NATHANIEL P. 5 REED, JR.
JEANNE A. CALDERON
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ExN EST L. s LA= E. JR.
eCNNiE S. GOTTuCs EI;27 MAWM AUGEN BLICM BARBARA J. MORGEN L.
WRITER'S DIRECT DIAL NUMBER w/
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8 (202) 822-1130 CAELETON S. JONES ALFRED M. POSTELL TwoM AS A. sAxTER MOwARD H. SMAFFERMAN
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.;aM ES M. SURGER DEBORAM L. SERNSTEIN QMELCON J. WEISEL SCOTT A. ANENBERG JOHN A. McCULLOUOM S ETH M. MOOGASIAN f
h J. PATRICK MICR EY SHEILA E. MeCAFFERTY g j~
G EO%G E P. MICH AELY. JR.
DELISSA A. RIDOWAY JAM ES THOMAS LENHART MENNETH J. HAUTMAN kTEVEN L. M ELTZER DAVf D LAWRENCE MILLER
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0"!E"'C f *LE 7/
TMI-l Restart Hearing i
eTEPH EN.. MuTTtE R GORDON R.. ANOFS"'
Docket No* 50-289 wtNTHROP N. BROWN SALLY C. ANDREws JAMES 5. HAMLIN JEFFREY S. GIANCOLA gg{gf {Q
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LOCERT E.2AHLER M ANN AM E. M. LIEB ERM AN GsCHARD E.GALEN SAN DRA E. FOLSOM ko IERT 8. RO584NS M A RCI A R. NIRCNSTEIN CTEVEN M.LUCAS JUDITH A. fLANOLER MEMORANDUM TO THE SERVICE LIST At the Board's suggestion (Tr. 23112-13), Licensee is providing copies of the working outlines it is using in pre-paring proposed findings on emergency planning issues.
The Board's view was that a consistent organizational scheme among the parties would assist the Boatd in preparing its Recommended Decision (Tr. 23114).
l Enclosed is Licensee's current draft Table of Contents, l
a draft summary outline identifying those contentions that will be addressed in each section, and a listing of each l
contention, or appropriate part, consistent with the organiza-tion of the Table of Contents and summary outline.
Re y sub itted, 8107150345 810710 Robert E.
Zahler
{DRADOC.' 05000289 Counsel for Licensee PDR i
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iluL 131981
- L 23,112 t
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2 ceipt of findings on the 23rd if you plan to file any.
3 CHAIRMAN SMITH:
I don't see any need for reply 4 fin dings.
5 MR. BLAKE:
The Licensee will waive reply findings l
6 on this.
t 7
CHAIRMAN 5 TH:
I don't see any need.
Mrs.
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8 Aamodt has been approach q the commitments as if it is new 9 evidentiary material, and it s not new evidentiary 10 material.
It is in the form of lief and relief which 11 could be argued f rom the evidentiary ecord as it exists 12 n o w.
So I see no need for reply finding and the entire 13 record is here, and it can be addressed.
14 So our ruling vill be that findings on he shift 15 manning issue and the commitments by the Licensee sha be is:c ;cd :n r bef :: July 22:1.
i 17 Now, we indicated before that we want tables of i
18 contents with the proposed findings, and I want to remind 1
l 19 the parties that it is very, very difficult to take just a l
20 flo wing narrative discussion of the whole case and try to
[
21 pinpoint without some guidance in the table of contents.
l 22 Moreover, it might be helpful if this is possible, and M s.
I 23 Bradford brought it up before she left, if there could be an 24 agreed upon organizational f ramework, that is, the same 25 subject headings among the parties on emergency preparedness l
ALDERSON REPORTING COMPANY. INC.
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1 i
i; 1 findings.
3 33 d
2 Ms. Bradford was wondering if perhaps you, Mr.
e J Zahler, migh t make available to her your outline, if you 1
3 11 ready have in mind an outline of how you're going to 4
5 propose your finding, and I can tell you it would be very 5
2 6 helpf ul to the Board.
Everyone has their own idea, and we 7 have to master so many 8
MR. ZAHLER4 Mr. Chairman, that is already done.
i
.g 9 In fact, Ms. Bradford came over at lunchtime and inquired 10 about that.
I handed her a document tha t unf ortuna tely is
-f 11 about so thick (Indicating) that reproduces every 12 con tention, and they are divided up because some conten tions 13 have multiple issues, and has an outline structure of the 14 o utline that Licensee was going to use for proposed findings is in each of the contentions that will be addressed therein.
16 I had previously provided that to Mr. Gray.
I l
17 will provide it to the members of the Board and to the f.
te state.
I must tell you, though, Licensee is really not 19 interested, given the tight schedule, in spending much time 20 noving this around here and there.
er 21 I t's got subject headings, it makes sense to y
i 22 Licensee, and I will share it with everyone.
g.:
[i 23 CHAIRMAN SMITH:
I would expect, considering the 24 allocation of the burdens in this proceeding, that the 25 Licensee by sharing their outline has done all that we can ALDERSON REPORTING COMPANY, NC,
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23,114
';5 1 ask them to do.
But we do advise the parties that if we 2 have an understandable with which we are familiar, we can
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3 find your findings much easier.
There's less opportunity d
4 that they will be overlooke..
s 5
Okay.
Tha t's good.
I'm glad you arranged tha t.
6 I wonder now if Licensee could provide an update 7 on the list of exhibits and the list of testimony.
N 8
MR. ZAHLER:
Mr. Chairman, we will serve that on i
9 Wednesday I am told.
p eT to CHAIRMAN SMITH:
Those have been very helpful to 4C 11 us.
That's fine.
We would like to have that.
hi N
12 Okay.
Is there anything further?
Any other 3
13 miscellaneous business?
y; 14 It looks like at last we've arrived at this z
15 mom en t.
I didn 't know tha t we ever would.
I thought W
16 there'd be enough new matters to keep this hearing going on 2
17 perpetually.
i 18 Of course, while we're pleased th e hearing is
~
19 over, we also have had a lot of professional satisfaction J
20 from this hearing, and we do want to thank the participants 21 a nd the parties for their professional courtesies and their 22 personal kindnesses to us.
23 sven though it was a very long hearing, it could 0:
24 have been much longer.
The hearing as long as it was, I
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25 believe, van Cccupied very sufficiently with substantive ALDERSON REPORTING COMPANY,INC, u
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DEAFT cocy@ED g
.lUL 131981
- e' EMERGENCY PIANNING 'IABIE OF CCNTENTS C
Cloca y n[fe 8[ 8
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Introduction O
4 N
A.
Short-and Irmg-Term Emergency Planning Order Items B.
Coupliance with Emergency Planning Rule II.
Findings of Fact on Intervenor Ctntentions A.
Organization and Staffing B.
Accident Assessment C.
Initial Notification of Gov?.Inmental Units D.
Public Education Jarning and Emergency Instructions E.
Definiticn of Emergency Planning Zones F.
Protective Acticn Decisicnmaking G.
Inplementaticn of Protective Actions 1.
Unmet Needs and Intters of Agreement 2.
hmicaticns 3.
Chain of Ccamand 4.
Police, Fire and National Guard Support 5.
Wrecking and Fuel Servi Su[. port G.
Transportation - General 7.
School Children Transportaticn 8.
Individuals Without Private Transportation 9.
Transportation and Care of Invalids and Hceebounds 10.
Post-Evacuaticm Support 11.
Mcal Facilities and Decontaminatim 12.
Distributicn and Achunistration of Potassiun Iodide 13.
Farners and Livestock 14.
Coordinaticn H.
Maintaining Emergency Preparedness III. Cbnclusicos of Law j
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g Of r?h 13/ggf, lI OUTLINE OF EMERGENCY PLANNING FINDINGS 6~ olll'~.,
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I.
Introduction L-
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-d A.
Identify witnesses, testimony and exhibits YLX-B.
Explain organization of findings 1.
Rulings and organizational problems with intervenor contentions 2.
Commission short and long. term order items and Staff SER 3.
Compliance with new rule (a)
Emergency Planning Evaluation (0746)
(b)
FEMA findings and determinations C.
Standards for Emergency Planning 1.
Prehearing conferences 2.
New rule 3.
Intervenor contentions (3A, 3B) 4.
Funding for emergency response (14GG)
II.
Findings of Fact on Intervenor Contentions A.
Organization and Staffing 1.
Licensee Emergency Response Organization (40, 4D) 2.
Local Emergency Response Organizations (a)
Staffing of local emergency coordinators (16B (in part) 14II)
(b)
Functions and qualifications of local emergency personnel (14F, 14G) 3.
Availability of Emergency Workers (SC) i i
n 9,
.. -., B.
Accident Assessment 1.
Classification (7,8,9) 2.
Radiation Monitoring (a)
Mobile monitoring teams (4I, 18 (in part))
(b)
Offsite remote readout monitors (Board Ques.4, 3C(1))
(c)
Analysis capability (3C(2))
(d)
REMP (18 (in part))
C.
Initial Notification of Governmental Units 1.
Sequence of Calls (4G) 2.
Information Transmitted (l (in part),
4 (E))
D.
Public Education, Warning and Emergency Instructions 1.
Education (4C, 140, 14C (in part))
2.
Warning (5D,140,14T, 14A,14B,16E, 16M) 3.
Emergency Instructions (a)
Concept of operations (14Y,14C (in part),1 (in part))
(b)
EBS (14FF)
(c) 911 System (14P (in patt) 160)
(d)
News Releases (12)
E.
Definition of EPZs (17A) l t
- F.
Motective Action Decisionmaking 1.
General Criteria (4H,5E,5B) 2.
Evacuation Time Estimate (14KK,14HH, 14M4,14EO, 16P) 3.
Consideration of Contingencies (14NN,14U, 16N) 4.
Investion PAGs (11)
G.
Implementation of Protective Actions 1.
Unmet needs and letters of agreement (14W,6D,4B) 2.
Communications (T,14N,14D, 16C,16F, 14P (in part) 14E,14C (in part),16D) 3.
Chain of Command (14H,14R,16I) 4.
Police, Fire and National Guard Support (14X,1400,14J, 14L,14S (in part))
5.
Wrecking and Fuel Service Support (6B,140C, 14C (in part))
6.
Transportation - General (14V,14AA,16T) 7.
School Children Transportation (14B (in part) 16J) 8.
Individuals Without Private Transportation (16G,16R,16H) 9.
Transportation and Care of Invalids and Homebounds (6F,14I,14C (in part),
160,16K) 10.
Post-Evacuation Support (13,16L,14EE, 16A,16S,14II) 11.
Medical Facilities and Decontamination (6A,10,14JJ, 14K,14S (in part),14Z)
i5-
. 12.
Distribution and Administration of Potassium Iodide (KI)
(SA,6E,14M, 14C (in part))
13.
Farmers and __vestock (2,4A,5G, 14BB,6G) 14.
Coerdination (15E)
H.
Maintaining Emergency Preparedness 1.
Training (5F,5H) 2.
Exercises and Drills (4F, 14C (in part))
3.
Audit and Review of Plans (17B)
III. Conclusions of Law l
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FINDINGS OF FACT ON INTERVENOR CONTENTIONS-D*, e in f$y7 V
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A.
Organization and Staffing s>
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1.
Licensee Emergency Response Organization W?
4(J).
The licensee's Onsite Emergency Organization staffing provisions as set forth in Table 8 of its EP fail to conform to the standards of N.
0654 Sec.
B5 in the following respects:
1.
Under said standards two control room operators are assigned the function of " plant operations and assessment of operational aspects."
Another shift employee is given the exclusive task of providing communications liaison with offsite officials.
Under the licensee's staffing provi -
sions, by contrast, the two control room operators are assigned to " operate equipment in control room and act as communicator" (emphasis added).
This divided responsibility compromises the licensee's ability to provide prompt offsite notification of emergency conditions.
The inadequacy of these staffing provisions is aggravated by the absence of any provision for the addition of three more persons with communications responsibilities within 30 minutes, as required by the aforemen-tiened acceptability standard.
2.
A similar confusion of assignments exists with regard to the shift supervisor and shift foreman, l
who are expected to fill three roles between them.
3.
Although N.
0654 requires the emergency operations facility director to assume his assignment within 30 minutes, under the licensee.'s plan this will not occur for as long as four hours.
4.
Two radiological analysis support engineers, who are the only employees identified as having the training and primary responsibility for perform-ing " dose projection calculations and source term calculations" (EP, p. 5-10) will not be available for as long as 60 minutes.
'4(D).
The licensee's "Onsite Emergency Organization" (Sec. 4.5.1.3) contains insufficient personnel and l
expertise in the area of Health Physics to discharge I
adequately the responsibilities of dose assessment l
and projection in the event of a rapidly developing l
accident sequence.
The time required for the mobiliza-l tion of offsite health physics support (2-4 hours -
see Table 8), which is given responsibility for "overall assessment of the impact of liquid and gaseous effluents with respect to.
. protective action l
guides" (p. 5-12), is inconsistent with adequate radiological assessment capability.
L.
,.4s' 2.
Local Emergency Response Organizations (a)
Staffing of local emergency coordinators 16(B) (in part).
Appendix 2 of Annex E of the Dauphin County Plan lists Dauphin County Local Emergency Preparedness Directors and Coordina-tors; however, those coordinators do not list any substitutes in the event of an emergency.
If these individuals cannot be reached at the telephone numbers listed, it would lead to con-fusion within their particular areas of responsi-bility.
Therefore, until and unless substitutes are listed as local emergency coordinators, it is Intervenor's position that the Plan is deficient.
14(LL).
The York County Plan contains a thin staffing of all emergency coordinators and does not list any substitutes in the event that an emergency coordinator is ill, on vacation or otherwise indisposed.
Without substitutes or standby emergency coordinators, the Plan is defective.
(b)
Functions and qualifications of local emergency personnel 14(F).
Appendix 2,Section I, Subsection B of the York County Plan provides that the Emergency Manage-ment Coordinator will insure that briefings are presented to the Commissioner and he will interpret displays and technical reports for the Commissioners.
There is no statement in the Plan that the person occupying the position of Emergency Management Coordinator will have educational requirements sufficient to insure that he will be able to interpret any displays of technical reports for l
the Commissioners.
It is Intervenor's contention that unless the Emergency Management Coordinator is required to have an expertise in the area of nuclear science, he will be unable to sufficiently and accurately interpret the displays and technical reports for the Commis:sloners and thus may leave the Commissioners who ultimately are responsible for the safety and welfare of the people of York County uninformed or misinformed of actual events taking place at TMI.
. 5. '.
_3_
14(G).
Appendix 2,Section II, of the York County Plan provides that the Situation Analysis Group will receive reports of plant safety degradation, poten-tial/ actual radioactive release and radiation in-tensity.
Again, there are no job requirements for persons who sit on a Situation Analysis Group to qualify them to make such reviews and, therefore, again, without qualified people to sit on such a group, their advice to the county's commissioners may be misinformed and unenlightened which could again then lead to chaos and confusion.
3.
Availability of Emergency Workers 5 (C).
In order to assure proper execution by emer-gency response personnel of duties assigned to them the Commonwealth should adopt and apply to all levels of the emergency response network the principle that such personnel should "not have more important com-mitments to families within the immediate area of TMI" (Dept. of Health Plan, App.
I, p. 5).
B.
Accident Assessment 1.
Classification l
7.
The fractions of EPA PAGs listed on p. 4-1 of the Plan, with their associated action levels, do not take into account the total accumulated dose and dose commitment.
As a result, the total exposures may ex-ceed by large margins the listed PAG fractions prior to the advancement to a higher emergency category.
8.
The various emergency categories (p. 4-2 to 4-8) each list a number of triggering events or conditions.
Many of these are questionable indicators.
For in-stance, on p.
4-3, " Valid" alarms are referred to.
But there is no mention of the definition of a " valid" alarm, or what would be an invalid alarm.
A number of reactor coolant activities (50, 130, and 300 ci/ml) are referred to, but no mention is made of how much fuel damage it takes to produce these readings.
In addition, there is no indication of how or how rapidly these coolant activities will be determined.
9.
Reliance on " adverse meteorology" (p.
4-5, 4-6),
can prove to provide little or no " built-in conserva-tism" (p.
4-7, 4-8) since, for instance, such condi-tions were not at all uncommon during the nighttime in the nights following the TMI-2 accident (for
~
instance, the night of March 29, from 10 p.m.
to 8 a.m., March 30; night of March 31, about 8:00 p.m.
to 8 a.m.,
April 1).
,. 2.
Radiation Monitoring (a)
Mobile monitoring teams 4(I).
The time provided in the EP for accident assessment, 1/2 hour (EP, p. 6-7), is in excess of the maximum permissible therefor specified in the Standard Review Plan, NUREG-75/087, Sec.
- 13. 3 (11) (3).
(EP fig. 21 shows the thyroid PAG of 5 rems being reached in 12 minutes at 600 meters.)
Moreover, the estimate given is un-supportable for monitoring of offsite locations on nearby islands or on the west shore of the Susquehanna River.
Such factors may become critical in the event of a general emergency, which produces a " shift in emphasis to greater offsite monitoring efforts" (EP, p.
6-6).
(See EP-3 (C) (1). )
18 (in part).
It is also contended that the Licensee does not possess adequate portable radiation monitors to provide additional infor-mation in the event of an offsite radiation re-
' lease, and that the Licensee does not exercise adequate administrative control over the mainten-ance of these units, nor the training of personnel in their use.
It is contended that the radiation monitoring program of the Licensee must be greatly upgraded prior to restart to ensure adequate protection of the public health and safety.
(b)
Offsite remote readout monitors l
Board. Question 4 (Tr. 2393).
Has the licensee considered stationing a a.
limited number of dose rate meters near the site, with the datt telemetered to the control room or the reeponse center?
b.
Has the licensee considered placing meters which publicly measure background radiation levels at a number of public places, thereby enabling the populace to know what the level is?
3 (C) (1).
The NRC's vague instruction to the licensee to " upgrade in generally unidentified respects its "offsite monitoring capability" is insufficient to assure that such upgrading will result in the ability to obtain and analyze the type and volume of information essential for pro-tection of the public health and safety.
ANGRY contends that such capability must at minimum en-compass the following elements or their equivalent:
~
. (1).
Permanent offsite monitoring devices which register all forms of ionizing radiation and which can be remotely read onsite.
(c)
Analysis capability 3 (C) (2).
The NRC's vague instruction to the licensee to " upgrade" in generally unidentified respects its "offsite monitoring capability" is insufficient to assure that such upgrading will result in the ability to obtain and analyze the type and volume of information essential for pro-tection of the public health and safety.
ANGRY contends that such capability must at minimum en-compass the following elements or their equivalent:
(2).
Information analysis capability equal to or greater tnan that provided by the Atmospheric Release Advisory Capability System (ARAC).
This contention now challenges the adequacy of the licensee's MIDAS radiological assessment system (EP, p. 6-9) to the extent that the informaiton analysis capability it provides does not equal or exceed that provided by the ARAC system.
(d)
REMP 18 (in part).
It is contended that the Licensee's environmental radiation monitoring program con-tains an insufficient number of monitoring sites and an inadequate distribution of monitoring sites within twenty miles of the Unit 1 site to provide sufficient protection of the public health and safety.
It is further contended that there is in the Licensee's environmental radiation monitor-ing program an unwarranted reliance on the use of thermoluminescent dosimeters (TLDs) for providing information used to calculate radiation exposure data and that this unwarranted reliance on TLDs seriously underestimates radiation doses to the public.
C.
Initial Notification of. Governmental Units 1.
Sequence of Calls l
l 4(G).
The licensee's emergency notification procedures (pp. 6-2, 6-3, 6-4; Figure 15) (see also Pa. DOP Ap-pendix 3) are inadequate with respect to certain areas directly at risk in the event of a nuclear accident, namely, York and Lancaster Counties.
Although the Dauphin County Emergency Operations Center receives immediate notification of an emergency declaration, l
l notification of York and Lancaster Counties must follow an excessively circuitous path:
7
. 1.
Licensee to Dauphin 2.
Licensee to PEMA 3.
PEMA to PORP 4.
BORP to Licensee 5.
Licensee to BORP 6.
BORP to PEMA 7.
PEMA to Dauphin 8.
PEMA to York, Lancaster, and Cumberland Counties.
Such a notification sequence is in direct conflict with requirements that " delegations of authority that will permit emergency actions (such as evacuation) to be taken with a minimum of delay should be carefully considered" (NUREG-75/lll, 5 A3) and that "Upon declaration of a ' general emergency' bnmediate notifi-cation shall be made directly to the offsite authori-ties responsible for implementing protective measures
" (EPRG II(A) (5)) (emphasis in original).
- Also, N. 0654 J7.
I 2.
Information Transmitted 1 (in part).
All data and plant operating personnel l
observations relative to all radioactive releases must be transmitted immediately and simultaneously to the NRC, Pennsylvania Department of Environmental Resources, the commissioners of Dauphin, York and Lancaster Counties and the licensee's management.
It is further contended that licensee must provide this capability before restart of TMI-1.
4(E).
The licensee's EP fails to provide for furnish-ing to the-Pennsylvania Bureau of Radiation Protection l
j (BORP) information called for in the latter's plan such as " nature of the failure, the status of safe-guards, the condition of consequence mitigating features" (p. VI-1).
D.
Public Education, Warning and Emergency Instructions 1.
Education
i.>
. 1 4 (C).
The adoption of the Commonwealth of Pennsyl-vania Disaster Operations Plan Annex E (DOP) desig-l nation of "the ' risk county' as responsible for the preparation and dissemination of information material on protective actions to the general public" (p. 6-8)
I conflicts with the requirements in EPRG II(A) (7) and RG 1.101 S 6.4(2) to i
make available on request to occupants in the LPZ information concerning how the emergency plans provide for notifi-cation to them and how they can expect to be advised what to do.
Also, N. 0654 G4.
14 (Q).
Annex E of the York County Plan, Subsection III, provides that the local Emergency Management Directors are responsible for the distribution of printed handout material to the populace within their l
respective municipalities.
TI:e Plan is defective in this area in that there is no set timetable for the i
distribution of said materials to the local Emergency Management Directors, and, likewise, there are no provisions within the Plan as to how local Emergency Management Directors are going to distribute the information to the local populace.
Again, it is sub-I mitted that, in the event of an incident at the TMI i
nuclear facility, local volunteers will not be able to be counted upon to effect such distribution and that without mome other means of distributing the materials, local Emergency Management Directors will be impotent to effect such a Plan.
The same problem arises in Sec-tion K of this area in that the Public Information Officer is responsible for the posting in all public areas, parks, etc., of public information and evacua-tion instructions for transient populations.
14(C) (in part).
The York County Plan in Section VI, Subsection (c) provides that posting of evacuation maps and semi-annual distribution of evacuation routes in local newspapers will be accomplished.
It is sub-mitted that there is no set designation of the respon-sibility for the effecting of this part of the Plan and it is Intervenor's contention that unless the Plan directs and places responsibility upon someone to effect this part of the Plan, the Plan is defective.
l l...
. 2.
Warning 5(D).
The physical means to provide warning to all persons within the plume EPZ in a manner conforming to the standards set forth in N. 0654 Sec. E6 (and App. 3 referenced therein) and in the Pa. DOP, App.
13, Sec. IIIA(6) should exist before TMI-l is allowed to restart.
14 (O).
Annex C of the York County Plan is deficient in that its total concept of operations is based upon tone-coded siren control and that nowhere in the Plan is it stated that all individuals are within hearing distance of the sirens located within a 20-mile radius of the TMI nucler: plant.
Moreover, the Plan provides as a backup or supplementary system to the siren system that police and fire vehicles would travel throughout the communities and again it is raised that the townships, boroughs and municipalities located within the 20-mile radius of the TMI nuclear facility do not have the necessary commitments of manpower to effect such a plan.
Therefore,.it is Intervenor's position that the York County Plan remains deficient.
14(T).
Appendix I of the York County Plan regarding warning is deficient in that it assumes that local fire companies will be able to alert all members of a rural community by direct notification such as knocking on doors.
There is absolutely no conceivable l
way in which individual direct notification can be made in Newberry Township because of the number of residents versus the number of volunteer firemen and it is submitted that the same conditions exist in all i
local municipalities located within the 20-mile l
radius of the TMI nuclear facility.
Therefore, until and unless a system is designed that can adequately ensure that a substantial majority of the population can be notified of an incident at TMI, the Plan is deficient.
14(A).
Section VI, Concept of Operations, Subsection l
7(a) is deficient in that there is an assumption that notification by siren can be heard throughout Newberry Tct;nship and surrounding communities.
It is question-able at best whether this is, in fact, true in that at least in the York County Plan there is an assumption of one Civil Defense siren being in place in Newberry l
Township which does not exist.
Oversights such as this may still exist within the Emergency Plan drafted by York County and verification of all sirens must be required in order to ensure at least minimum siren
1 j '
coverage of the county.
Therefore, it is Intervenor's position that there are not sufficient numbers of Civil Defense warning sirens in place in the county in order to adequately ensure that all membcrs of the community are within hearing distance of a siren.
It is Intervenor's contention that until the Emergency Plan specifically states that a siren alert system is in place and that the warning emitted by the system can be heard at any point in the county surrounding the plant site, that the Emergency Plan as drafted is unacceptable.
14 (B).
Section VI, Subsection ~7 (L).
The York County Plan as drafted indicates that selective evacuation of pregnant women and pre-school children aid their families would be effected upon order of the Governor.
Again, the notification would be by a five (5) minute steady siren which cannot be assured will be heard in all points within the affected areas.
Moreover, the Plan assumes that there will be appropriate EBS announcements followed by door-to-door notification which would be conducted by appropriate boroughs and townships.
Again, the Intervenor raises the conten-i tion that the time factor required in order to recruit volunteers to man vehicles and the many miles of road which are located in the various rural communities which would have to be traveled in order to ensure that notification of all members of the population of the impending emergency conditions would render the Plan as written inoperable.
Moreover, it is con-tended by the Intervenor that the selected evacuation notification is initially effected by the same type of notification that owuld be required in a general evacuation.
Both evacuations are initiated by a five (5) minute steady siren tone, then followed by ap-propriate EBS announcements.
It is Intervenor's con-tention that similarity and warning evacuation tones may lead to confusicn on behalf of the public and that orderly evacuation of the affected areas could not be effected.
16(E).
Appendix 5 of the Dauphin County Plan provides that alert warnings will be initiated through siren activation.
Again, this part of the Plan makes a broad base assumption that the populace within the county can hear the sirens at all locations and it is Intervenor's position that this is not true.
Therefore, until and unless a sufficient number of sirens are placed throughout the county area at loca-tions that will ensure that the total populace of the county-is within hearing distance of the sirens, the Plan will remain deficient.
i !
16(M).
The Dauphin County Plan'does not specifically state a differentiated commonlv recognized evacuation signal that could be recognized by the citizenry throughout the county.
The Plan does not indicate whether the alarm system that is to be used is to be driven by a regular' power system 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 Emergency Plan inadequate.
3.
Emergency Instructions (a)
Concept of operations i
14(Y).
Annex N, Subsection VII, Subsection G provides for ce~rtain duties and responsibilities for a County Director and these duties and responsibilities conflict directly with those of the Emergency Management Coordinator.
Speci-fically, this section provides that the County Director shall provide appropriate notice of information receivad and emergency actions taken and proposed to the York County Police and Fire Departments, other echelons and emergency opera-tional chains, and local news media for emergency public information and news announcements, whereas, Appendix II provides that the Public Info'rmation i
Officer is responsible for,the issuance of official information, advice and instructions l
from the county to the public.
This conflict renders the Plan deficient.
14(C) (in part).
Section VI, Subsection 7(c).
This section of the York County Plan is deficient in that it depends upon the York County Chamber of Commerce to notify and pass on the general evacua-tion information to ousiness and..idustry.
There is no assurance that the Chamber of Commerce has the necessary manpower, equipment, and training to pass on such information to the general public.
For example, does the York County Chamber of Commerce possess necessary trunk lines to advise all industry within an affected area?
What happens in the event that telephone communications are jammed or overloaded and that notification l
of industries cannot be effected by the York l
County Chamber of. Commerce?
Furthermore, does i
the York County Chamber of C]mmerce and all industry within the possible affected area have radio communication capabilities?
, 1 (in part).
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.
It is contended that licensee must make informa-tion available to the public which will allow
' appropriate action to be taken to protect per-sons, livestock, foodstuff and feed in the event of a discharge of significant proportion.
(b)
EBS 14(FF).
The York County Plan contains only one EBS station, that being WSBA in York, Pennsyl-vania, and lists no other secondary station in the event that WSBA loses power or in some other way is placed out of operation.
It is Inter-venor's contention that the Plan is deficient in that a secondary EBS station is not included in the Plan.
(c) 911 System 14(P) (in part).
Furthermore, Subsection VI of this particular section provides that the common carrier system within the Emergency Operations i
Center is the 911 system, of which 49 out of 79 emergency telephone trunk lines are committed.
Furthermore, 6 of the lines are standby rumor-control lines, leaving 24 emergency telephone trunk lines for those areas not contained within the 911 system.
The Newberry Township, Fairview Township, Goldsboro and Lewisberry areas are without 911 service.
It is Intervenor's conten-tion that, in the event of an incident at the TMI nuclear facility, the telephone grid system would become so overloaded during such an inci-dent that the making of a phone call to the remaining 24 committed lines at the Emergency Operations Center would be difficult if not im-possible.
Therefore, it is claimed that this part of the Plan also is deficient in that there are not enough emergency trunk lines available for all residents within the 20-mile radius zone of TMI with a special emphasis en those areas in York County which are closest to the nuclear power facility.
i 16 (O).
The Dauphin County Plan lists only two (2) 911 operators in place in the event of an evacuation.
It is submitted that two operators are grossly insufficient when it is taken into consideration that the York County Plan incor-porates 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 Plan remains deficient.
(d)
News Releases 12.
ECNP contends that the routing of all infor-4 J
mation through the Governor's Press Secretary to the public adds unnecessary complexities to the entire plan.
For example,_since the Press Secre-tary of the Governor can reasonably be expected to be a political appointee and not necessarily knowledgeable at all in the area of nuclear acci-dents and their consequences, or the nature of radiation injury, the designation of the Governor's Press Secretary as the official and sole spokesperson adds one more pathway for and perhaps impediment to information in the cumber-some and circuitous route between an event or accident at TMI and the public.
There is no need for this extra step.
In addition, this extra step offers one more opportunity for errors and omissions to be introduced into the informa-tion and only adds further delay.
It is not ex-pected that this extra step will result in the removal of errors from the messages.
Further-more, the possibility exists, with this extra, unnecessary step, for political pressure to be brought to bear to alter, delay, or even with-hold crucial information from the public.
E.
Definition of EPZs 17(A).
Licensee's acceptance, without formal analysis or evaluation, of a circular 10-mile radius for the Plume Exposure Emergency Planning Zone (as designated by the Pennsylvania Emer-gency Management Agency) does not discharge Licensee's responsibility to ensure that adequate emergency response plans exist to protect the public health and safety in the event of an emer-gency at TMI-1.
Further, acceptance of or desig-nation of a circular 10-mile radius Plume Exposure EPZ for TMI-l is unjustified because such an EPZ
\\.
fails to adequately consider local emergency response needs and capabilities as they are affected by demography and jurisdictional boundaries.
These considerations, among others, are specified in NUREG-0396, NUREG-0654, and the new emergency planning rule published in the Federal Register on August 19, 1980.
The following specific local conditions should be reflected in the Plume Exposure EPZ for TMI-1:
1.
The proposed 10-mile radius circula" EPZ includes within the EPZ portions or aumer-ous jurisdictions at the township, city, borough, and town levels of government.
Calling for an evacuation of only a por-tion of any political jurisdiction due to a hazard which affects a large geographic area and basing emergency plans and response capabilities on such a limited evacuation will lead to problems due to spontaneous evacuation of a much larger area, with a concommitant increase in traffic and supply requirements at shelters.
Therefore, the Plume Exposure EPZ for TMI-l should in-clude the entire geographic extent of all governmental jurisdictions at the township, city, borough, and town level which are bisected by the proposed circular 10-mile EPZ.
2.
There are heavily populated areas in and near the cities of Harrisburg and York represented by the city proper and adjacent continuation of the urban areas into the suburbs.
In the event tha~t the wind is blowing toward either of these areas when a large release of radioactivity occurs, such areas would constitute a large per-centage of the total population dose (in the case of the TMI-2 accident, for instance, Harrisburg contributed 25% of the total population dose despite the fact that most of the city is more than 10 miles distant from the plant).
The urbanized areas in and around Harrisburg and York are concen-trations of population for which preplanning for an, evacuation is a necessity for success-ful implementation (for instance, preplanning would have to include evacuation routes,
U V
t transportation needs, host area requirements, and problems posed by special populations such as prisons).
Therefore, the urbanized areas around and including the cities of Harrisburg and York should be included within the Plume Exposure EPZ for TMI-1.
3.
Numerous members of the Old Order Amish com-munity reside in relatively close proximity (within 10 miles) of the oucer boundary of the Licensee's Plume Exposure EPZ in Lancaster County.
Because the Old Order Amish eschew the use of electricity, tele-phones, and automobiles, they present unique problems with respect to warning, communica-tion of protective action advisories, and transportation.
These unique problems war-rant the special consideration the inclusion of Old Order Amish within the Plume Exposure EPZ would provide.
4.
To the extent that the Licensee relies upon the decision of county officials in the Three Mile Island area to develop and maintain a 20-mile emergency response capability as a substitute for making a determination that i
the 10-mile circular EPZ is adequate, the adequacy of such a 20-mile capability must be established as a condition to the restart of TMI-1.
F.
Protective Action Decisionmaking 1.
General Criteria 4 (H).
RG 1.101 Sec. 6.4 requires the licensee to specify " criteria for implementing protective actions The Licensee's EP fails to set forth the following mandatory items of information regarding the time required for protective action inplementation:
1.
Expected accident assessment time.
RG 1.70, Sec. 13.3.1-2.
2.
Time required to warn persons at risk.
RG 1.101, Sec. 6. 4.1-2 (b) ; RG 1.71, Sec. 13.3.1-3,4.
3.
Time required for a general evacuation.
RG 1.70, Sec. 13.3.1-5,6; November 29, 1979 letter to "All Power Reactor Licensees" from Brian K.
- Grimes, Director, NRC Emergency Preparedness Task Group.
. 4.
Time required to evacuate special facilities (e. g., hospitals).
November 29, 1979 letter, supra.
See N.
0654 J8.
5(E).
There is no reasonable assurance that appropri-ate protective measures will be taken in the event of a nuclear accident with offsite radiological consequences for the following reasons:
1.
The Commonwealth's criteria for appropriate pro-tective action choice, as set forth in Sec. VIII of its BORP plan, are inconsistent with those of the Licensee (EP, p. 6-13).
According to the Licensee evacuation is the appropriate protective action if dose projections approach the lower linits of EPA PAGs.
According to BORP this would not be the case unless the upper limits of the PAGs were approached.
Although the Licensee indi-cates that sheltering is the appropriate choice for atmospheric releases of short duration,.the BORP plan proposes evacuation for " sudden severe accidents."
The Licensee would not recommend evacuation in the event of a continuous release 4
if " evacuation ~cannot be well underway prior to plume arrival," while BORP would order an evacua-tion in such a case regardless of wind speed and warning time.
2.
The BORP plan failt to quantify protective action selection cri teria such as " time to onset of re-lease time required to effect relocation,"
and the definition of " puff release."
Such quantification of criteria is a necessary ing,redi-ent in effective planning and is required by N.
0654 Sec, J10(m).
3.
The Commonwealth does not comprehend the distinc-tion between " core-rt alt and " melt-through" acci-dents as those termr are empl6yed in NUREG CR-ll31.
l 4.
The Commonwealth declines to employ " state-of-the-art" calculational methodology, as set forth in ESA 520/1-78-001B, in turn referenced in N.
0654 at p. 55, n.l(3), in conjunction with hypothetical accident release characteristics to assist it in making appropriate protective action ':. election.
5.
The Commonwealth's discussi.on of the shelterirg option is inadequate in th.it it fails to emphasize the importance of the use of building basements (see NUREG CR-ll31) or of ventilating the shelter
. at the appropriate time (see WASH 1400, App.
VI, Sec. 11.1.2) as means to maximize the ef-fectiveness of this measure.
This inadequacy is carried through to instructions to be pro-vided the public as set forth in county plans.
5 (B).
The Emergency Planning Review Guidelines re-quires state / local plans to designate " protective action guides and/or othe~r criteria for implementing specific protective actions (Sec. IV(B) (1) ;
emphasis added) and "information needs" for bnplementing such protective actions (Sec. IV(B) (2) ).
The BORP Plan both fails to explicitly impose upon the Licensee clear responsibility for fulfilling such information needs or, where required, to undertake to satisfy them at its own initiative.
1 1.
Section VIII(A) of the BORP Plan indicates " time to onset of release" as a significant factor in determining the appropriateness of recommending evacuation.
However, nowhere is the Licensee given explicit responsibility for providing such j
information, nor does the Plan contain an analysi?
of how variation of this factor will affect the choice of appropriate protective action.
- See, e.g.,
NUREG 0610, p. 13, par. 4 (c).
2.
A second factor listed is " time required to effect relocation."
NUREG 75/111, Sec. J(6) requires an adeqv. ate state plan to include development of
" bases and time frames for evacuation" resulting in " estimates of the time required to carry out evacuation procedures" that reflect consideration of such factors as " impaired mobility of parts of the population" (Sec. J(7) (c)) and " potential impediments to use of egress routes, such as rush hour traffic and inclement weather" (Sec. J(7) (f)).
The availability of this and other information l
specified by the President's Commission is an l
essential prerequisite to adequate emergency planning and decisionmaking whether or not in the context of an actual emergency situatAon.
See also, N.
0654, Section j (10) (k; note require-ment for specification of " contingency measures"),
(1) & (m).
2.
Evacuation Time Estimate 14(KK).
The York County Plan contains no time sequence for the removal of the exposed at-risk population.
I There is only assumption that there would be adequate time in which to remove all individuals; however, there
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1 is no estimate as to the number of hours that would be required to effect a selective evacuation or a general evacuation.
Moreover, there is attached to the York County Plan an estimate of the number of vehicles per hour that could be handled by various major arteries and access roads; however, there ap-pears to be a conflict in the estimates in that urban roads with parking are estimated to handle at least 1,700 cars per hour whereas major arteries could only handle 1,300 per hour and it is submitted that such a gross distortion renders the Plan deficient.
Further-more, there is absolutely no hard-core statistical data to back up the calculations relied upon in the York County Plan.
14(HE).
The York County Plan has no provision in its population calculations for periods of time during the day when most people are working and outside of the area, during the day when there may be an increase in population because of industries located within the areas, or during summer periods when many individuals may be on vacation or there would be an influx of individuals coming into the area to vacation.
Without i
that type of population differential tables, it is Intervenor's contention that the Plan is deficient.
14(MM).
The York County Plan does not state how many businesses are located in risk areas and what the population of those businesses are during working hours.
Without this information, it would be im-possible to determine the number of hours that would be required to effect a general evacuation in the event one was ordered.
Therefore, it is Intervenor's position that the' Plan remains defective.
i 14(DD).
The Evacuation Plan contained in the York County Plan does not contain any sensitivity analysis or differentiation between the time xME day, the seasons of the year or weather conditions at the time of the evacuation.
In light of these deficiencies, it is Intervenor's contention that the Plan is deficient.
16(P).
The Dauphin County Plan as set forth does not provide for differentiation 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 assumption of best-case analysis.
Therefore, it is Intervenor's position that without taking these factors into consideration, the Plan remains deficient as concerns the time needed to effect an evacuation.
i.
, i 3.
Consideration of Contingencies i
14(NN).
As a general overall comment, evacuation
~
routes as set forth are not wind-dependent, and therefore, in the event of an evacuation, wind direc-l tion is a factor that would be required to be taken into consideration in order to formulate an effective evacuation plan.
The Plan as set forth does not pro-vide for this factor and, as such, persons evacuating the evacuation areas.may be directed into a poten-tially more hazardous situation in the manner in which they are routed.
i 14 (U).
l Annex H of the York County Plan provides in its general concept of operations that evacuation
' routings would be inherently dependent upon climatic conditions, time factors involved, etc.
The Plan also provides that residents would be evacuated on major interstates and state highways.
There is no mention as to the condition of the access roads to these major arteries and.it is submitted that evacuation genera]ly is dependent upon climatic conditions and the 'condi-tions of the access roads within the individual town-ships and local communities.
Access roads within Newberry Township vary from a 20 to a 26-foot width and it is Intervenor's contention that in tlT event of an evacuation, traffic flow on these access roads could quickly become terminated as a result of the vehicles running out of gas or being involved in auto accidents for which there would be no way in which to remedy the situation.
Moreover, in ice and snow con-ditions, it is submitted that these access roads which are located in generally hilly areas would be generally impassable and, therefore, there would be no access to the evacuation routes.
Until and unless the evacuation plan provides for a means to assure l
that access roads will be passable during a general evacuation, it is submitted that the Plan is deficient.-
16(N).
The Dauphin County Plan does not specifically state how the following occurrences would be dealt with in the event of an evacuation:
1.
Accidents on the highways; 2.
Cars running out of gas; 3.
Generally disabled vehicles; and 4.
Individuals who need ambulance service for removal from accidents.
\\. The Plan does not state 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 atmospheric and weather conditions would exist at the time of the evacuation.
What would take place in the event of a snowstorm and how would that affect 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 con-sidered in a total evacuation plan and the location and placement of staging areas.
4 Ingestion PAGs ll,.
The BRP plan (Appendix 8) relies on the infant thyroid dose (1.5 rem) as the dose from milk inges-tion to be avoided (p. IX-4).
This does not take into account the fetus, whose sensitivity may greatly exceed that of the infant.
In addition, the value of 1.5 ;em to the thyroid from milk ingestion does not take into account the inhalation exposure.
G.
Implementation of Protective Actions 1.
Unmet needs and letters of agreement 14(W).
Annex L of the York County Plan provides for resource requirements which, it is assumed, would set forth what would be required to set the whole evacua-tion plan of York County into operation with regard to manpower, equipment and other resources.
The Plan as of this date remains under development in this area and until and unless the Plan is completely finalized, it is Intervenor's contention that the Plan is deficient.
6(D).
There are numerous assignments of responsibility to persons and organizations that are not documented by written agreements demonstrating knowledge of and ability to perform assigned roles as required by N. 0654 Sec. A3.
The most important of such delega-tions are:
1.
American Red Cross (operation of relocation centers; Annex I).
2.
Maryland Dept. of Health (provision of ambulances and helicopters for hospital evacuations; Annex J).
. 3.
Amateur radio operators (communications with local governmental units and school districts; Annex D S VE).
4.
" State C.D."
(50-2 passenger ambulances for evacuation of nursing homes; Annex J, App. 2).
5.
School Districts (transportation of school children to relocation centers and provision of facilities for such centers; Annex 0).
6.
York Area Transit Authority (evacuation of nursing home patients; Annex K).
I 7.
State of Maryland (overflow mass care capacity; Annex I Sec. IVD).
8.
Adams County (relocation center; Annex I).
i 9.
York Chamber of Commerce (notification of business and industry; Sec. VIA(7) (a) ).
10.
York County USDA Lisaster/ Emergency Board (monitoring crop and animal surveillance; Annex R).
4 (B).
The perfunctory form letters _found in Appendix C to Licensee's EP provide no indication, let alone l
assurance, of the existence of " mutually acceptable criteria" for implementation of emergency measures as required by Emergency Planning Review Guideline No. One, Revision One (EPRG) IV (A) (1).
Also N.
0654 A3.
l 2.
Communications 6(C).
There is no assurance of the operability of county-local governn ent communications links on a 24-hour basis as required by N.
0654 Sec. Fl(a) and Pa. DOP Sec. IXB (1) (f).
14 (N).
Annex B of the York County Plan indicates that the order of notification from York County is to executive group members and then to local coordinators within the risk area with priority to those nearest the facility, then to school superin-tendents and then to Emergency Operations Center staff.
Nowhere in the Plan is it indicated haw these people would be notified of the impending emergency.
Intervenors again raise the issue that in the event of an incident at TMI, members of these organizations should be able to be reached without dependence upon telephone communications.
Until and unless it is l
l-
, indicated that these individuals can be contacted without dependence upon telephone communications, the plan is deficient.
14(D).
Section VI, Subsection (d) (1) prcvides that, upon notification from PEMA, the County Director will assemble and consult with appropriate members of the county staff and elected officials.
There does not seem to be included in the Plan any means in which to contact the local elected officials unless it is the assumption that these officials would be contacted by telephone.
It is Intervenor's contention that, in the event of an emergency situation at Three Mile Island, once the public has any notice or indication that something has occurred at TMI, that the telephone lines will become overloaded and that incoming calls to local officials will not be able to be effected.
4 Moreover, the Plan does not indicate where local officials will assemble, how they will know where to assemble and when to assemble and thus the Plan is still deemed to be deficient.
16(C).
Appendix 3, Annex E of the Dauphin County Plan indicates that approximately 65 people will be notified in the event of an emergency.
It indicates that notification of these people will be by radio whenever possible and then by telephone.
Nowhere in the Plan is it indicated that the individual listed have radios which are compatible with that of the County E.O.C.
Moreover, there's no indication that the frequencies to be used for cummunicating with these individuals would be free of any outside dis-turbance.
Therefore, until and unless it is indi-cated in the County Plan that these individuals have compatible radio equipment and that frequencies are being used that are relatively free from any other type of traffic, it is Intervenor's position that the Plan remains defective.
i 16(F).
Appendix 6 of Annex E of the Dauphin County Plan provides that the American Red Cross, military unit assignments, fire and ambulance units, and police i
units will be assigned various frequencies for radio operations and will have various radio equipment at their disposal.
Nowhere in the Plan is it indi-cated that there is in existence presently of the equipment necessary to operate on the indicated frequencies or that if the equipment is presently available, that it is being maintained.
- Moreover, the Plan as written indicated that the police only have two frequencies on which to operate in the event of an emergency.
Furthermore, fire, ambulance, Red Cross and military units will all share the same
. frequency and it is submitted that in the event of an emergency, the traffic on those frequencies will cancel effective communication among all of the groups.
Therefore, untzl and unless it is stated that each of these units has its own frequency for operation and that there are sufficient numbers of frequencies in order to ensure e'fective operations, f
the Plan is deficient.
Moreover, until and unless the Plan indicates that there is an existence of compatible equipment in order to effect this part of the Plan and that there is a responsibility for maintenance of the equipment, it is Intervenor's position that the Plan remains inadequate.
14(P) (in part).
Annex D,Section V, provides that the concept of operation will be effected by the regular communications staff augmented by " qualified volunteers" as required.
The Plan also indicated that amateur radio will be relied upon in the event of an incident at TMI nuclear facility.
There is no assurance that any amateur radio operators have agreed to participate in such an operation or that each school district has had an operator assigned to it to coordinate the utilization of school buses.
- Moreoter, there is no definition of who is a qualified volunteer in the event that volunteers are required to be used by the communications staff.
14(E).
Annex A of the York County Plan provides that the alternate EOC site will be the new Hanover Borough Building in Hanover, Pennsylvania.
Intervenors again raise the contention that there still is no indication at this time that trunk lines have been laid for the transfer of the Emergency Operations Center to the Hanover location, and, as such, it renders the Plan
)
insdequate.
14 t 0) (in part).
Finally, the concept of operations in this section provides that RACES would provide in-terim communications at the Hanover site until full communications capability could be restored.
It is Intervenor's position that the Hanover site must be placed in an immediate ready condition in order to effectively serve as an alternate site for emergency operations control.
It is Intervenor's position that until and-unless the Hanover site is placed in a ready condition, that,the Plan remains deficient.
16 (D).
Appendix 4 of Annex E of the Dauphin County Plan provides that the alternate E.O.C. office will be located in the Millersburg Borough Building.
l.
Nowhere in the Plan is it indicated that the Millers-burg Borough Building is presently in an emergency readiness condition.
In short, the Plan does not indicate whether, as a matter of fact, the Millers-burg Borough Building can accommodate the requirements of the E.O.C. with regard to telephone trunk lines, 4
radio communications, and other E.O.C.
requirements.
I Until and unless this information can be verified, it is Intervenor's position that the Plan remains deficient.
3.
Chain of Command 14(H).
Appendix 2,Section III, of the York County i
Plan provides that the Assistant Director of Police Operations is responsible for the overall management i
of law and order, traffic control and security.
In the event the National Guard is ordered to assist local communities, it is questionable whether the Assistant Director of Police Operations would be in a position to direct orders to a military organization as is assumed he would be in the York County Plan.
There seems to be no coordination between the National Guard chain of command and the chain of command in the operations group in Annex 2,Section III, and there-l fore, it is Intervenor's position that the Plan is deficient in that there is no stated area of responsi-bility concerning police operations, vis-a-vis the National Guard.
14 (R).
Annex F,Section II of the Plan is inconsistent with Appendix 2, Subsecticn III, Subsection A in that the Assistant Director of Police Operations is stated to be responsible for all management of law and order, traffic control and security, whereas Annex F provides i
that the Pennsylvania State Police are responsible for coordinating law enforcement and traffic control and the Pennsylvania National Guard is responsible for providing security for the evacuated areas.
Intervenor is of the oosition that until and unless the order of command is sufficiently, adequately and clearly stated, there lies the possibility in the Plan for mass chaos and confusion with regard to who is responsible for police services.
The Plan is deficient until it states in a succinct and clear manner who will be responsible for giving direct orders to the Pennsyl-vania State Police, the sheriff in local police departments, and the Pennsylvania National Guard in the event there is an incident at the Three Mile Island nuclear facility.
_._,_____.__..,__A._,__,.-..____._.._.
l.
t
. 16(I).
Appendix 9 of the Dauphin County Plan regard-ing police policy and procedures durinc relocation indicates that when evacuation is ordered, units will proceed to predesignated stations.
The Plan does not indicate where the predesignated stations are located and how the chain of command will operate in the event of relocation of local pelice departments and their interaction with National Guard units arriving to pro-vide additional manpower to local departments.
Until l
and unless a definite chain of command is stated and the relationship between civil police departments and the National Guard regarding chain of command is documented, it is Intervenor's position that the Plan is deficient.
4.
Police, Fire and National Guard Support 14(X).
Annex M of the Iork County Plan providing for military support states that the Pennsylvania National Guard will enter into active duty upon an order of the Governor.
Moreover, they will respond to any individual local political subdivision's needs upon request of the local political subdivision for aid.
The Plan does not j
state with any specificity whether the Guardsmen will be protected by radiation-proof equipment, under whose orders and directions they will remain during their encampment in a local political subdivision, and when they will arrive in the local political subdivision after requested to do so.
Until and unless these deficiencies are rectified, it is'Intervenor's con-tention that the Emergency Plan is deficient.
14(00).
Because of the experiences of the past, even the limited evacuation of pregnant women and children i
under five years of age left many of the areas surround-l ing the Three Mile Island Nuclear Power Station deserted and open to looting without proper security.
The assumption that the National Guard would, in the i
event of an evacuation, be called up by the Governor, I
is one that is a void in the evacuation plan and the National Guard is not called up or does not respond to the Governor's request because its members are busily evacuating their own families.
14(J).
Appendix 2,Section III, Subsection (i) pro-vides that it will be anticipated that the Pennsyl-vania State Police would be prepared to support York County disaster operations in the event c
'n inci-dent at the TMI nuclear facility.
Moreover, it indicates-that the Pennsylvania State Police would coordinate with the Pennsylvania Department of
. Transportation for the placement of temporary signs in support of evacuation area security.
It is im-portant to note that there is no formulated and stated plan for the involvement of the Pennsylvania State Police in the event of an incident at TMI.
It is also anticipated in the Plan that there would be the placement of some sort of temporary signs to support the evacuation of the area; however, there is no statement that such temporary signs presently exist or that they would be existing at a time of need.
It is therefore contended that the York County Plan is deficient because it does not state the exact assignment of the Pennsylvania State Police in connection with all other support groups in York County.
14 (L).
Appendix 3, Annex A, providing for police operations in a selective evacuation and a general evacuation provides that the police would support and assist in notification and, on request, that police operations provide fire and police support for traffic control and security.
It is submitted that support and assist in notification and support for traffic control and security are mutually ex-clusive operations.
It is Intervenor's contention that police in local communities cannot be asked to both support traffic control and security and, at the same time, support and assist in the notification of j
area residents of the impending dangers and evacua-l tion notification in the event of an incident at TMI.
14(S) (in part).
Annex G of the York County Plan is deficient-in that it assumes that local fire companies will have sufficient manpower to effect emergency operations procedures as outlined in the Plan.
As is previously been pointed out by the Intervenor, l
there is usually insufficient staffing of the indi-i vidual fire companies to assure that all residente l
in rural areas would be notified of an incident at the TMI nuclear facility because of the number of miles of raod located in each township.
l 5.
Wrecking and Fuel Service Support 6(B).
Although the Pa. DOP, Sec. IXB (1) (p) delegates the responsibility for arranging for emergency wrecker and fuel services to risk counties, the York County i
plan assigns this responsibility to the Pa. National Guard (Sec. VIA(7) (c) ).
t 14(CC).
Nowhere in the York County Plan does there exist a catalog of the tow trucks available for use in York County.
Until and unless a catalog of the tow trucks available for use is attached to the Plan, the Plan remains deficient.
14(C) (in part).
The Plan is also defective in that it is anticipated that the Pennsylvania National Guard will provide tow trucks and gasoline along evacuation routes; however, nowhere in the Plan does
~it indicate that the Pennsylvania National Guard has the necessary tow trucks and fuel trucks to effect such a plan.
Finally, it's noted that there is no reaction time indicated in the Plan in order to assure that such tow trucks and fuel trucks could even arrive within the evacuation area due to traffic flow on the interstates and access highways.
6.
Transportation - General 14(V).
Annex K of the York County Plan provides for the transportation of various individuals out of the evacuation area.
Intervenor's contention in this area is that there is no direct stated coordination of plans between YATA, local school districts, the Balti-more Transit System, and the Pennsylvania and Maryland Railroad Company.
The Plan as set forth in the con-cept of operation indicates that total coordination of the system will be left to the county Transporta-tion Coordinator who will establish a system, but it doesn't identify when he will establish a system to identify priority use of transportation resources.
Moreover, it states that any buses without missions would report to the Vo-Tech school located in York and be dispatched from that point.
There is no pro-vision for the refueling for any of the buses in any particular area and there is no guarantee that school buses driven by volunteer drivers would be willing to return to a risk area.
Furthermore, the transportation area of the York County Plan has totally disregarded the initial five-hour plan which had been included in the initial evacuation plan.
Nowhere in this Plan does it appear that transpor'ta-tion could be effected in any set time period and, therefore, this section again, by implication, con-tains the realistic admission that, regardless of whether school was in session, the evacuation plan would be inoperable and unrealistic.
Until and un-less the Plan shows exact designation of buses, com-mitment by bus companies to react within set stated ov--,
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9,
i times and letters of agreement between the surround-ing school districts and the York County Commissioners with regard to assurances of delivery of local school buses, the Plan will remain deficient.
14 (AA).
Annex 0 of the Emergency Plan is deficient in that the concept of operations division does not re-quire mandatory preparation of local plans for emer-gency notification of bus drivers and the organiza-tion of mobilization of transportation necessary to meet the needs of evacuating their student populations..
Moreover, the Plan does not include any direction or plan to the local school superintendents as to rerout-l ing their buses for general evacuation of local resi-dents.
For example, in an emergency, is a principal of Fishing Creek Elementary School to send a bus to the Vo-Tech School for rerouting while area residents we.it for transportation?
Until and unless there is I
some type of generalized plan for each school l
district as to the rerouting of school vehicles not in use for removal of school population, the Plan will remain deficient.
16(T).
Moreover, the plan does not envision the method of notifying school and CAT bus drivers and assumes that all drivers will respond in an emergency situation.
Moreover, it doesn't indicate anywhere that the CAT bus drivers will know what is expected of them in an emergency situation and know where they are going and how to get to the appointed emergency staging areas.
This is a contingency that can be planned for in advance, should be specifically set out in a plan, and thus, the absence of such specificity in the plan renders the plan inadequate.
7.
School Children Transportation 14 (B) (in part).
.Furthermore, this section of the York County Plan anticipates parents and/or families evacuat-ing the area will be able to pick up children at schools.
This again would lead to confusion within the Plan in that if a selected evacuation was ordered and pre-school children were to be removed from the area, the Plan anticipates that action would be taken by school super-intendents in the evacuation of the children from schools and that there may be interference or lack of effective execution of the Emergency Plan set forth for the school systems.
. 16(J).
Appendix 12 of Annex E of the Dauphin County Plan provides that during school hours, upon receipt of a condition yellow alert, school districts shall begin returning school students to their homes.
Moreover, the Plan continues, that in the event parents are not home, children shall be returned to one pickup point as listed in the Appendix.
There is an exception to this rule indicated in the Plan.
it is Intervenor's contention that the Plan is deficient because it first of all allows the busing of the children during a condition yellow situation.
It is Intervenor's contention that a much more sensible approach to this problem would be to bus all the children to a predesignated area outside of the 20-mile EPZ and allow parents in an orderly fashion to pick their children up of a condition yellow alert does not change.
There is a potential, as the Plan is now written, that in the middle of busing children home during a condition yellow situation that the situa-tion could degrade to a condition red situation and there would be no means of notifying the bus drivers of the change in a situation and the change in the school policy plan under a condition red emergency situation.
Finally, Section J of this part of the Plan indicates that evacuation plans of the various school districts will be on file with the County Emergency Preparedness Agency.
It is Intervenor's contention that the plans of the school districts should mandatorily be on file and reviewed periodically j
by the County Emergency Preparedness Agency.
Until or unless this deficiency is corrected, it is Inter-venor's position that the Plan is defective.
8.
Individuals Without Private Transportation l
16(G).
Appendix 8, Attachment 8-1, indicates that there are local pickup points for individuals who are without transportation.
There is no indication within
~
I the Emergency Plan as now drafted that there will be police protection for people waiting at the pickup points in order to ensure security.
Moreover, the pickup points as listed do not ensure that individuals l
who assemble at these points will be sheltered for their protection under some type of cover.
Until or unless it is assured that there will be police protec-tion provided and that sheltering will be provided, the Plan is deemed inadequate.
i.
16 (R).
The. Dauphin County Plan as presently written envisions mass transportation 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 mass 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 effectively deal with mass transportation and until and unless those local regionalized areas are stated in an emergency plan, all plans will remain deficient.
4 16 (H).
Appendix 8, Attachment 8-2 of the Dauphin County Plan provides that local municipalities shall provide one personal lead vehicle to.the E.O.C.
Reception Area from the Staging Area.
The problem with this particular part of the Plan is that there is no designation of who will be the person to lead vehicles to the E.O.C. Reception Area.
- Moreover, there is a candid admission that there is the chance that municipalities will hijack vehicles intended for other communities.
Until and unless there is some type of security provided for incoming and outgoing j
units, the Plan shall remain deficient.
- Moreover, there is no. provision in this Plan to provide for refueling of the incoming buses and ambulances and 4
until and unless there is some indication of how refueling is going to take place, there is the risk that incoming buses and ambulances would run out of fuel and be rendered useless.
9.
Transportation and Care of Invalids and Homebounds 6(F).
The preparation of a " list of homebounds and invalids" and a plan for their evacuation (Annex J) aind satisfaction of unmet " resource requirements" (Annex L) should be accomplished prior to TMI-l re-start.
14 (I).
Appendix 2,Section III, Subsection (g) of the York County Plan indicates that the Area Agency on Aging should develop a system to identify the homebound and invalid personnel that require special transporta-tion needs and coordinate a consolidated listing with the transportation group.
Unitl and unless the Area Agency on Aging is directed to effect such a system, it is Intervenor's position that the York County Plan is deficient because, without such listing, there I
would be no way in which local communities could be assured that all invalids and homebound persons would be removed from an evacuation area.
. r 14(C) (in part).
The Plan in Subsection (c) also assumes that homebounds and invalids will be able to be transmitted by means of ambulance and bus and that individuals with no transportation could request the same through local fire companies for bus pickup.
The capabilities to effect such a plan within Newberry i
Township are nonexistent.
For example, Newberry Town-ship has two ambulances that could be placed into ser-vice, assuming that a volunteer would operate the same.
Local communities surrounding the Newberry Township area include Goldsboro Boro 2gh and Lewisberry Borough, each borough having an ambulance to effect evacuation of their homebounds and invalids.
It is submitted i
that within the 34-mile square area that encompasses Newberry Township and the boroughs of Lewisberry, Goldsboro and York Haven that four (4) ambulances would not be sufficient to evacuate homebounds and invalids.
Moreover, transportation through local fire companies will be impossible, as local fire chiefs have indicated that they could not guarantee that any personnel could or would effect such an evacuation service.
Finally, it is submitted that if local volunteer fire companies cannot assure man-power staffing during a general emergency situation, that they cannot be again counted upon to provide transportation to designated areas for bus pickup for those individuals who are without transportation.
16(O).
The Dauphin County Plan indicates that it has a total need of approximately 600 ambulances for the evacuation of all members of the exposed populace and indicates only 45 are available.
The Plan also indi-cates 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 problem indicated in the Plan.
16(K).
Appendix 13 of Annex E of the Dauphin County Plan indicates that there are approximately 4,000 long-term patients that would require relocation in the event of a general evacuation.
The Appendix also includes a listing of hospitals that would be amenable to accepting long-term patients in the event of an emergency.
While the Plan indicates the total number of beds available at hospitals, there is no statement as to the number of beds which would be available on an average at any set time.
Until and unless the Plan indicates the number of possible available beds that could be afforded to Dauphin County in the event of an emergency, it is submitted that the Plan is deficient.
l
4 10.
Post-Evacuation Support 13 The evacuation plans for Cumberland, York, and Lebanon Counties are based, at least in part on the assumption that many if not most, evacuees will stay with friends or relatives outside the evacuation zone.
This assumption is highly questionable, since during the early days of the still-ongoing TMI-2 accident, after women and children were ordered out of the area 4
within five miles of TMI, many tens of thousands of people outside this area themselves evacuated volun-tarily.
In the event of another accident at TMI which causes a twenty-mile evacuation, for which each of the five counties expresses preparedness, the resultant voluntary evacuations of persons beyond the 20-mile radius might well mean that there will remain no friends and/or relatives for the 20-mile evacuees to reside with temporarily.
16(L).
Appendix 14 of Annex E indicates that within a 5-mile radius there are 24,426 individuals who would require evacuation from the area and there is an assump-tion made that 50 percent of the individuals would require sheltering.
The total number of positions available for sheltering in the Plan equals 6,800.
There is an obvious deficiency in the number of sheltering site positions available within the County Plan and until and unless there can be some type of acceptable levels of sheltering, the Plan will remain deficient.
Moreover, it is Intervenor's position that 1
there is an error in the addition that appears within this Appendix concerning the total capacity of the shelters and that the figure of 7,625 is in error.
Furthermore, it is Intervenor's position that until and unless the Plan of Dauphin County indicates that there are auxiliary emergency ~ power ~ systems located in each one of the sheltering systems and emergency auxiliary heating systems at such sheltering locations, the Plan will remain deficient.
14(EE).
The mass evacuation centers contained in the York County Plan do not state that the centers have auxiliary backup electrical powe'r and heating plants in the event that they are placed into use.
It is Intervenor's contention that, without such auxiliary 1
power and heating systems, that the Plan is deficient in that evacuees would arrive either at a darkened or cold evacuation center.
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_ _,.. - ~ _ _. _ _ _ _,. _.
' 16(A).
The Dauphin County Plan, in Section V, makes the assumption that persons evacuated from a risk area will only have to remain outside of the risk area for a period of three (3) days and that adequate lead time will be available to implement the provisions of the Plan.
It is Intervenor's contention that a plan based upon these assumptions is inadequate based upon past experience.
In the past it has been recognized that a five (5) day selective evacuation was ordered by the Governor of Pennsylvania and that basing an assumption upon a three (3) day sheltering is a defect within the Plan itself.
Moreover, there is no definition as to adequate " lead time" and whether or not a definition of that term would mean a short period of time or a relatively long period of time, and until or unless the term is specifically defined, the Plan is deemed to be inadequate.
16(S).
The Dauphin County Plan is deficient in that there is no long-term management provision in the i
event of an evacuation which would last greater than three days.
Without such long-term planning, there is a possibility and a probability that confusion would reign after an evacuation of three days and it is submitted that in the March l'979 incident, the evacuation lasted for five days.
Therefore, until and unless there is greater long-term management planning provided for in the emergency plan, the Plan remains deficient.
1 14(II).
The York County Plan provides that the American Red Cross would provide for distr.ibution of certain food-stuffs, clothing, and other personal articles.
There is no mention in the Plan whether the Red Cross would have at its disposal the estimated foodstuffs required to feed the evacuated population, the cots needed for the sheltered area and the evacuation centers.
Until and unless the Plan contains the statement that these items are in storage and available for distribution, it is Intervenor's position that the Plan remains deficient.
l 11.
Medical Facilities and Decontamination 6(A).
There is inadequate provision in the York County Plan for providing medical services for contaminated individuals, for training persons providing these ser-vices, and for transporting radiological victims to medical facilities, all as required by N. 0654 Sec.
L.
t
33 -
10.
Appendix D of the Plan contains reference to the need for the decontamination of radiologically con-taminated individuals (p. 16) but does not provide any information as to how many people may be contamin-ated, the kind and degree of contamination expected or to be planned for, or the number of facilities and medical personnel appropriately trained in decontamina-tion and radiation injury treatment techniques which may be necessary.
14(JJ).. The York County Plan provides that there would' be care provided for victims of radiation exposure; however, there is no statement th~at there are supplies on hand for radiation care or that there are sufficient numbers of supplies on hand to take care of a large mass evacuation in the event that there was a radia-tion leak.
It is Intervenor's contention that, in order to provide sufficient medical care for the popu-lace at risk, it is necessary that the Plan contain statements that inventories are available and are presently in place.
Without such statement, the Plan j
renains defective.
~
14 (1Q_.
Appendix 3, Annex A, Situation Analysis Group, of the York County Plan provides that it Elll support the State Bureau of Rad. Health with available par-sonnel and equipment and that in the event of a general evacuation on request it will support fire and mass care operations with monitors for decontaminations.
i Nowhere in the Plan does it state that the Situation i
Analysis Group will have the necase ry equipment re-quired in order to support the various bureaus and fire and mass care operations with the necessary equip-ment monitors for decontamination operations.
14(S) (in part).
The,P.lan also contains a concept that the county would distribute radiological monitoring equipment to individual fire companies to be monitored by the fire company personnel.
There is no indication in the Plan that volunteer firemen have been trained I
to operate such equipment and there is no assurance that such equipment is presently located within the county for distribution.
Until these deficiencies are resolved, it is Intervenor's position that the Plan is deficient.
14(Z).
The York County Plan provides for the decon-tmmination of personnel and vehicles and Subsection C of that Plan provides that all vehicles passing through a designated reception center will be decontaminated and also that all vehicles that will be on major routes leaving the county will be decontaminated.
The inclu-sion of this in the Emergency Plan of York County
.- - - - - - - - - - - - - - - - -~
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.. i renders the Plan deficient and inoperable.
It is Intervenor's position that, by decontaminating vehicles and personnel at the designated locations as set forth in the Plan will only cause the projected traffic flows to be severely diminished as a result of the decontamination.
The Plan is deficient also be-cause there is no projection as to the number of cars that would be able to travel on the evacuation routes after the initial jam-up occurs at the decontamination routes.
In other words, the decontamination areas will provide a bottleneck for the evacuation of area residents out of risk areas that will. effectively render the evacuation plan inoperable.
Unless the decontamination points are removed to some other point besides the major evacuation arteries, it is submitted that the Plan is deficient.
/
12.
Distribution and Administration of Potassium Iodide (KI) 5 (A).
The Commonwealth's plan for distribution of a thyroid bloc:-ing agent to persons at risk in the event of a nuclear accident with offsite radiological con-sequences (Pa. Dept. of Health RERP, App. I) is de-ficient for the following reasons:
1.
The plan assumes an advance warning time (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />;
- p. 2) that is in excess of that which NUREG-0654 concludes may be available before an initial re-lease of radioactive materials to the environment.
2.
The postulated warning time is that which is deemed the minimum necessary to enable Dept. of Health officials "to move ahead of evacuees in their distribution efforts."
However th'e plan is silent with respect to the auch more critical time period that would actually elapse between the initial notification of the Commonwealth of an emergency situation and the availability to the public of the medication.
ANGRY submits that given the logistics of the distribution process as set forth in the plan such a time period would be well in excess of one hour.
The " assumption" stated in Sec. IVA (1), p. 13, of the distribution plan is unsupportable as a planning basis.
3.
In the case of York County, the movement of large numbers of people to the single designated distribution point for the medication, the County Courthouse, would require complete de-parture from predetermined evacuation routes, particularly for residents of Fairview and northern Newberry Townships.
It would also cause massive traffic congestion in the center of York City.
~
I 4 4.
The plan would be useless in the event of a nuclear emergency for which sheltering was the chosen protective action.
It is also useless to those farmers who " consider evacuation un-feasible and elect to seek or use sheltering for themselves (Pa. Dept. of Agriculture Plan, p. 17).
The stated condition to the ad-
-vice to "take prescribed dosage of SSKI" (Ex. 9 to App. 1, sec. 3(c)), namely, its availability, would of course not be met under the plan as presently outlined.
For all the foregoing reasons ANGRY submits that the only method of distribution capable of insuring the availability of a thyroid blocking agent is its Lre-distribution to all potentially affected households and businesses, and that such predistribution should be accomplished prior to the restart cif TMI-1.
6(E).
The provisions in the York County plan for thyroid blocking agent distribution (Annex A, App.
3, Health-Medical Opermtions) are not coordinated with the state plan.
14(M).
Appendix.3, Annex A, Health Medical Operations, provides that that group would be prepared to assist the State Department of Health in the distribution of thyroid blocking and other radiological health materials.
Nowhere in the Plan is it stated that these materials are readily available and until and I
I unless the Plan specifically designates that these materials are located within the York County area, it is Intervenor's contention that the Plan is deficient.
14 (C) (in part).
Subsection (c) of this Plan also pro-vides that a County Medical Officer will coordinate with the Pennsylvania Department of Health the distribu-tion of thyroid blocking agents and other radiological health materials.
The assumption is that these materials would be stored in an area in close proximity to the l
affected area without any assurance that such thyroid blocking agents and other radiological health materials l
- are even available and could be delivered to the Exit 6 area of I-83 within a timeframe that would be suffi-cient to effect the Plan.
J i
13.
Farmers and Livestock 2.
It is contended that present evacuation plans do not provide for care and/or relocation of livestock.
It is further contended that such provision should be made befora restart of TMI-1.
4(A).
There is no provision in the EP for the preven-tion of damage to property (e.g.,
livestock) in the area surrounding the plant site as required by Appendix E to 10 CFR 50, SS II(C), III, and IV(C).
5(G).
The Commonwealth's Dept. of Agriculture Plan is inadequate for the reason th.at it provides no.informa-tion on measures for the self-protection of farm per-sonnel who " consider an evacuation unfeasible and elect to seek or use sheltering for themselves.
(p-17).
The plan offers the farmer no choice between the two extremes of exposing himself to potentially dangerous levels of radiation or complete abandonment of his investment in his livestock.
14(BB).
Annex R of the York County Plan does not pro-vide for any evacuation of domestic farm animals and until and unless the Plan does provide for a plan of evacuation,.the Plan remains deficient.
Domestic' farm animals cannot be left for any period of time without j
human care and attention and, therefore, it is assumed that farmers who have such large investments in live-stock will not leave their investment unattended and, thus, they are left at risk.
Moreover, the agricul-tural part of the York County Plan provides that the County Emergency Management Agency Director will charge and distribute dosimeters for agricultural personnel who are required to enter the designated risk area but does not. state who will provide the dosimeters and who will interpret the dosimeter read-ings.
Until and unless these two facets of the York County Plan are remedied, it is Intervenor's conten-tion that the Plan remains deficient.
6(G).
The York County Fairgrounds is an inappropriate location for the agricultural "Information Center" (Annex R, Sec. IVF) since it is within the 20-mile distance from the plant to which under the plan's.
assumptions a total evacuation may be required.
The provision establishing this center fails to provide also for the necessary predetermination by farmers wishing to avail themselves of its services of the nature and timing of the " essential functions" for l
their farms, the number of persons needed to perform t
.. such functions, and the identity of such persons.
Dissemination of information concerning this program and the compiling of information provided in response thereto should be accomplished prior to TMI-l restart.
14.
Coordination 15(E).
Section 4.6.5.1(2) of the Emergency Plan pro-vides that the responsibility for actions to protect persons an the offsite areas rests with the Common-wealth of Pennsylvania and that the Pennsylvania Emer-gency Management Agency shall be the agency with which the responsibility rests for the placing, in effect, of protective options such as evacuation, sheltering and thyroid prophylaxis.
The same section indicates that in the event of a general emergency, precautionary measures may be taken such as sheltering, evacuation and evacuation of certain sectors based upon wind speed and direction.
It is again Intervenor's conten-tion that this particular section of the Emergency Plan providing for the precautionary measures cited have not been coordinated with local county plans to any measurable extent.
For example, in the county plans, there is no indication of how the counties would instruct its local Civil Defense Directors to evacuate only certain sectors within a community in-i stead of within radial distances of the Three Mile Island nuclear facility.
This is again only but one example of a lack of coordination between the Emergency Plan and the various county plans and it is Inter-venor's position that this lack of coordination is symptomatic of the entire Emergency Plan as it is now written.
The Emergency Plan submitted by the Licensee should encompass a total coordination of all Emergency Plans formulated by, federal, state and county agencies.
This lack of coordination creates a deficiency which has to be remedied.
I H.
Maintaining Emergency Preparedness i
1.
Training 5(F).
TMI-l should not be permitted to restart until persons responsible for implementing emergency response plans at all levels of the response network within the plume EPZ have successfully completed the training mandated by N. 0654 Sec. 04 and provided for in Pa.
DOP App. 10
. a e A
- 5(H).
Tho Commonwealth plan for hiring and training a nuclear engineer to be dispatched to the TMI-l con-trol room upon the occurrence of any future nuclear accident should be completed before restarting is authorized.
2.
Exercises and Drills 4(F).
The provisions for'the conducting.of a "Radia-tion Emerger7y Exercise" of the Licensee (EP, p. 8-8) and of the Commonwealth (Pa. DOP, App.14) are in-adequate in that they do not clearly provide for the participation therein of federal agencies.
The necessity for such participation is clearly established by.the extensive involvement of federal agencies in the TMI accident.
Second, the aforementioned appendix to the Commonwealth's emergency plan indicates that "all major. elements of the plans and preparedness organizations" may be tested only over a period of five years.
All such elements should be tested in an exercise prior to the restart of TMI-1.
14(C) (in part).
Moreover,Section VI, Subsection (c) (4) provides' that there will be an exercise and training of emergency service forces to include at least one annual exercise conducted in connection with PEMA.
It is submitted that this part of Pe Plan is deficient because it does not require mu:.datory participation of all of the local emergency service l
forces.
A most recent test conducted by PEMA in July of 1980 did not include the participation of a majority of the local townships and boroughs because the persons who would have been involved in that training exercise are volunteers and would not or could not obtain leave from their employers to par-i ticipate in such a training exercise.
It is contended l
that the Plan is still deficient in this area unless i
and until the Commonwealth of Pennsylvania through its police powers provides that those who are con-sidered to be emergency service forces within the local boroughs and townships are given nonprejudicial paid leave time by their employers in order to partici-pate in such an exercise.
3.
Audit and Review of Plans 17(B).
Licensee's Emergency Plan fails to adequately provide a mechanism which will assure the effective-ness of the Emergency Plan throughout the operational lifetime of the TMI-l facility.
- -.