ML20010A721

Brief on Emergency Planning Contention & Kaku Supporting Testimony.State & Local Officials' Ignorance & Misunderstanding of Potential Impacts of Accidents Threatens Ultimate Adequacy of Plan.Certificate of Svc Encl

ML20010A721
Person / Time
Site:	Summer
Issue date:	08/07/1981
From:	Bursey B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8108120106
Download: ML20010A721 (5)

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IINITED STATES OF AMERICA pf g ,

NUCLEAR REGULATORY COMMISSION 000%Cro

{ owe 2, ;p ATOMIC SAF Kg NSING BOARD AUG1oiggt,g!

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1. N: , -]7 In the Matter of: ) , ,

C 5-Y k d)%L SOUTH CAROLINA ELECTRIC AND GAS COMPANY, et. el. C 50-395-0L cyll ic [ W A

Virgil C Sumer Nuclear h "'UG m#S"5

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ros fo QT - g INTERVEN0R'S BRIEF ON EMERGENCY PLANNING CONTENTION AND DR. KAKU'S SUPPORTING TESTIMONY The ignorance and misunderstanding amongst state and local officials as to the potential impacts of accidents they may be called upon to respond to, threatens the ultimate adequacy of the plan. For example, George Douglass, Director of the Fairfield County Office of Emergency Preparedness, (the host count of the reactor) )

' agreed with me that the public should be educated as to the possibility and impacts of a major nuclear accident (tr. 2163-3). Yet Mr. Douglass states he believes the chances ofr a serious accident are "almost approacning nil" (tr. l 2164-1) and he do' ,n't "think there would be the type of release that would be the type of release that would be the cause of any deaths." (tr. 2167-25)

NUREG 0654 recognizes the potential severity of core melt sequences. 0654 anticipates consequences from the worst core melt sequence as possibly exceeding Protective Action Guidelines and posing life threatening doses outside the EPZ.*

(D. Planning Basis. 2. Emergency Planning Zone B & C) 0654 aniticipates thoroua'h emergency plans for the 10 mile EPZ will allow for adequate emergency mea-sures outside the zone in the event of life threatening consequences beyond ten miles.

State and local officials' admissions of ignorance as to consequences of d Core melt accident raise serious doubts of the efficacy of their plans within the 10 mile zone. If Mr. Douglass doubts there will be any accidents that could cause fatalities, he doesn't understand the planning basis for 0654. If Mr. Douglass 8108120'106 810807

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doubts there will be any accidents that could cause fatalities, he doesn't under-stand the planning basis for 06E4 If Mr. Douglass imparts his underestimation of serious accidents to his planning and the local citizens, the adequacy of the plan to adeouately mitigate serious consequences is doubtful.

The TMI cccident that gave rise to 0654 was beyond design basis. The premise of 0654 is 'a enable the realistic mitigation of accidents - including core melts l

beyond design basis. The Staff and Applicant's position'is that if the mechanical steps of Part II are comitted to paper memorandums, emergency plans are adequate.

• I contend that without understanding the seriousness of accidents beyond design basis - as reflected in Part I of 0654 - it is unrealistic to believe that Part II of 0654 can be abstractly implemented to adequately cope with all emergency contingencies.

Nowhere in 0654 is Mr. Goldberg's assertion that Part I of the document is to be ignored in the Board's assessment of adequate planning. Nor is there any-thing in 0654 that states Part I should not be taken into consideration and under- I stood by state and local agencies.

Goldberg sunsnarized his objections to Dr. Kaku's testimony as three-fold:

(1) irrelevant; (2) challenges Commission rules; (3) Dr. Kaku is allegedly unqualified.

Relevance. Judge Grossman stated that "Dr. Kaku's testimony supplies basically I the nature of the releases that could be expected within those zones and something that should be taken into account in the emergency planning."

Without Dr. Kaku's testimony there will be nothing on the record to reflect the nature and magnitude of radioactive releases from which to determine whether:

or_ not " adequate protective measures can and will be taken in the event of a i

radiological emergency." (10 CFR Part 50.33(3)). [

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.u I have continued to assert that Dr. Kaku's testimony does R Rule Challence.

not challenge Comission rules. It is my position that a discussion of probabi- s lities of core melts, the inventory of radioactive releases, their impacts on the 4 10 mile EPZ and the 50 mile Ingestion Zone are all within permissible parameters g.

of litigation in this proceeding. The Commission's Policy Statement of TMI-2 Issues in Operating License Proceedings, allows litigation that would refine the {

0654 regulations. Parties may also challenge the sufficiency of the new require- y 5

ments. -

i; Qualifications. Dr. Kaku has presently completed nearly five hours of }

j voir dire. I believe this lengthy examination more than adequately established his qualifications to testify as to: ,

b (1) PWR probabilities; "

3 (2) rad!oactive inventories released in the event of a serious accident; {=

(3) the nature and behavior of the radioactive plume in the event of a release-.

In summary, Mr. Goldberg's assertion that accidents have "nothing to do ..

3 with the ability to successfully implement the emergency plan" (tr. 1719-13) strives to eviserate the heart of the contention's concerns for adequate public safety.

It seems nec'essary for the emergency forces to have a realistic understanding of the probabilities and potentialities of the catastrophe they are being asked l l {

to mitigate.

The transcript reflects that none of the local or state officials (with one j

exception) had any notion of whether they would be dealing with 4, 40, 400 or  !

4,000 potential fatalities in the event of a major core melt. t General George Wise, Director of the State Office of Emergency Preparedness, illustrated a critical ignorance of the magnitude of a core melt by claiming the radiation of a " reactor meltdown is quite insignificant compared to" a 20 KT nuclear weapon. (tr. 2213-14)

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This comparison is drawn simply to illustrate that the state and local officials are unaware of post-TMI core melt considerations. Dr. Kaku's testi-many is essential for the record to reflect the nature of accidents that officials $<

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must plan for (which could eventuate a radioactive release thousands of times greater than a 20 KT nuclear weapon.)

3 Bringing state and local officials' understanding of accident impacts up  ;

to an adequate level to comprehend and prepare for major accidents is nnt a p lengthy or complicated endeavor. The basic problem lies in the Applicant (and nuclear industry) down-playing accident probabilities and impacts. This problem 7

is compounded by the NRC position reflected by Mr. Goldberg - that if the I

paperwork is right, you don't have to look any further into the adequacy of y

emergency planning. n f

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COD!ISSION [.9 ,  : n.- 4 '

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BEFORE THE A*CMIC SAFETY AND LICENSING BOARD i] . .; 1 y .d. .

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SOUTH CAROLINA ELECTRIC &

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GAS COMPANY and )

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SOUTH CAROLINA PUBLIC ) Docket No.59-395 OL SERVICE AUTHORITY )

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(Virgil C. Summer Nuclear )

Station) )

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CERTIF[CATEOFSERVICE I hereby certify that copies of "Intervenor's Brief on Emergency Planning Contention and Dr. Kaku's Supporting Testimony" were served upon the following persons by deposit in the United States mail, first class postage, this 7th day of August, 1931:

Herbert Grossman, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel Licensing Board U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 George Fischer, Esq.

Dr. Frank F. Hooper Vice President & Group School of Natural Resources Executive - Legal Affairs University of Michigan S. C. Electric & Gas Company Ann Arbor, Michigan 48109 Post Office Box 764 Cclumbia, S. C. 29202 Mr. Gustave A. Linenberger Member, Atomic Safety and Steven C. Goldberg, Esq.

Licensing Board Panel Office of the Executive U. S. Nuclear Regulatory Leyal Director Commission U. 5. Nuclear Regulatory Washington, D. C. 20555 Co::nission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board Panel Mr. Chara R. Stephens U. S. Nuclear Regulatory Docketing and Service Section Co:amission Office of the Secretary Washington, D. C. 20555 U.S. Nuclear Regclatory Comission Washington, D.C. 205E3 Richard P. Wilson, Esq.

Assistant Attorney General J.B. Knotts, Jr. , Esq.

South Carolina Attorney General's Debevoise & Libennan Office 1200 17th Street, N.W.

P.O. Box 11549 Washington, D.C. 20036-Columbia, S.C. 29211 Larry Mahan South Carolina Electric & Gas Company P.O. Box 764 Columbia, S.C. 29218 -

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Brett 'ursey, Intervenor