ML20030D212
| ML20030D212 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 08/21/1981 |
| From: | Cleeton A, Cleeton M CLEETON, INTERVENORS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8108310530 | |
| Download: ML20030D212 (6) | |
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NUCLEAR REGULATORY COMMISSION (9\\'
N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD n t \\ \\ eC '
In The Matter of
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Boston Edison Company, et al
)
Docket No. 50-471
)
( Pilgrim Nuclear Generating
)
Station, Unit 2)
)
INTERVENOR CLEETONS' CONTENTIONS ON THE MATTERS OF EMERGENCY PLAN-NING AND THREE MILE ISLAND II UN-RESOLVED ISSUES.
1.
Boston Edison, et al, have not clearly demonstrated that an adequate emergency response and evacuation plan is possible since no actual test or drill of the current emergency response plans for Pilgrim I has ever been conducted; only telephone tree cimu-lations.
In addition, we question that the site specific plans as set forth by Boston Edison Co.
would assure suf#icient space and manpower for the anticipated needs of. those evacuated from any or all of the sectors in the emergency response plans.
2.
Boston Edison, et al, have not identifie'd specific public or private buildings out to a 50 mile radius, nor have they certified to anyone that authority to use those buildings in the event of an emergency.
3.
Boston Edison, et al, have not identified authorities and personnel who have been advised and trained to respond to any influx of evacuees into their facilities and buildings.
4.
Boston Edison, et al, have not indicated where por in what manner or method, procurement of and storage of emergency supplies and provisions have been or will be made.
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Cleeton 2 l
5.
Boston Edison, et al, have not indicated by what policies and priorities such emergency provisions and supF 'es shall be distributed to what segments of ths jopulation, other than those designations of personnel associated with the operation of Pilgrim I and proposed Pilgrim II and thereby have failed to give required protection for the health and safety of potentially affected populations in the evat of an accident.
6.
Boston Edison, et al, have not explained nor stated whose fiscal responsibility, nor verified any accept-ance of any such responsibility, to fund and purchase and store emergency supplied and provisions, out to a fifty mile radius, including all of Cape Cod, nor even in the ten mile immediate evaculation zone.
7.
Boston Edison, et al, have not stated by what manner nor method security forces would be emplaced in the evacuated area (s) to assure private property holders that their property an6 valuable possessions would remain safe when ordered cut of their places of dwelling and business for reasons not of their own choosing.
8.
Boston Edison, et al, have not indicated under what statutory authority anyone may be ordered to leave their property or premises in the event of an ordered evacuation.
9.
Boston Edison, et al, have not indicated any studies or research that would indicate that anyone would leave if they had to choose between undetermined risk to health and the protection of ' valuable lifetime possessions or property that cannot be removed on short notice.
10.
Neither Boston Edison, et al,; the Nuclear Regulatory Commission; the Federal Emergency Management Agency; nor the Department of Defenes has indicated whether or not National Guard or other security forces would be allowed, required or ordered into the evacuated area already judged to be unsafe for ordinary citizens.
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11.
Neither Boston Edison, et al, nor the Nuclear Regulatory Commission are able to state clearly what all of the TMI II issues or findings are, because the consequences of the accident at TMI II are still in process: The contaminated water in the containment building is still accumulating by a specific quantity - the amount once estimated to be from 500,000 callons to 600,000 gallons is now es-i timated to be upwards of 750,000 gallons
- placing those residents and property holders downstream at uncertain and unknown risk in the event of a breach of conts'? ment and the sudden release of enormous amounts of irradiated water.
12.
Neither Boston Edison, et al, nor the Nuclear Regulatory Commission will be able to fully assess, for fifteen to twenty-five years, the long range consequences t) physical and mental health of the i
release of above permitted levels of irradiated gasses, liquids and possibly particulate matter, upon unknown and undesigne'ed geographical sectors and populations during the ancontrolled and unmeasured per..ods immediately following the accident at 4:JO a.m.
on March 28, 1979, until monitoring was established hours later.
No complete or satisfactory find..gs may ever be available until years of study ar e carried out.
13.
The Nuclear Regulatory Commission has not provided any information to the applicant (s) c' e potential values of new findings about the effe upon bio-logical populations, includinc hum =.
41ations of the higher levels of gamma rad 3ti.,
,-n the victims of Hiroshima and Nagasaki in asseis.Ini the long range consequences of the releases upor. biological and human populations following the incident at TMI II.
14.
The Nuclear Regulatory Commissi n has not provided any information to the applicant (s) of the potential values of new findings about the effects upon bio-logical populations, including human populations, of a surfeit of neutrons., an effect upon which the DOE is basing its development of the Neutron Bomb. Such data would be helpful in clarifying the potential consequences of releases such as occurred at TMI II.
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.s Cleeton 4
15.
Neither Boston Edison, et al, nor the Nuclear Regula-tory Commission have modified their dependence upon theoretical and hypothetical speculations about the biological effects of ionizing radiation upon human populations, although some new real evidence is available from the initial studies of the consequences of the releases from TMI II on March 28, 1979 and for some period of time following from which.some initial partial findings are certainly known to the Nuclear Regulatory Commission and its staff.
16.
Neither Boston Edison, et al, nor the Nuclear Regula-tory Commission have issued or abided by any final modification of regulations, but are wholly dependent upon " interim decisions " for which no formal pro-mvigation of new regulations has been set forth.
17.
It is the contention of the Intervenor Cleetons' that the critical issues of ' emergency respodse planning and the consequences of the accident at TMI II on March 28, 1979 have been adequately ad-dressed and that neither the adequacy of the emergency response plan nor the actual cons,equences of an ac-cident at Pilgrim I and II cite :an be assessed without and actual drill or demonstration to alert and educate the public.
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- Alan R.
Cleeton
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N Marion W.
Cleeton Augbst 21, 1981 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter ot
)
)
BOSTON EDISON COMPANY, _e_t _al.
)
Doc!:et No. 50-471
)
(Pilgrim Nuclear Generating Stition,
)
-Unit 2)
)
CERTIFICATE OF SERVICE We hereby certify that the within Contentions have been served on the following by deposit of copies thereof in the U.S. Mail, postage prepaid, August 21, 1981.
Andrew C. Goodhope, Esq.
Patrick J. Kenny, Esq.
Chairman, Atomic Safety and Edward L. Selgrade, Esq.
Licensing Board Deputy Director, Massachusetts 3320 Estelle Terrace Office of Energy Resources Wheaton, Marylmd 20906 73 Tremont Straet Boston, Massachusetts 02'.08 Dr. A. Dixon Callihan Union Carbide Corporation William S. Abbott, Esq.
P. O. Box Y Suite 925 Oak Ridge, Tenne'ssee 37830 50 Congress Street Boston, Massachusetts 02109 Dr. Richard F. Cole Atomic Safety and Thomas G. Dignan, Jr., Esq.
Licensing Board Ropes and Gray U. S. Nuclear Regulatory 225 Franklin Street Commission Boston, Massachusetts 02110 Washington, D. C. 20555 R. K. Gad III, Esq.
Henry Herrmann, Esq, Ropes and Gray Room 1045 225 Franklin Street 50 Congress Street Boston, Massachusetts 02110 Boston, Massachusetts 02109
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Atomic Safety and Licensing Office of the Secretary Appeal Board Docketing and Service Section C.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commisrion Washington, D. C. 20555 Washington, D. C. 20555 Chief Librarian Atomic Safety and Licensing Plymouth Public Library Board Panel North Street U.S. Nuclear Regulatory Plymouth, Massachusetts 02360 Commission Washington, D. C2 20555 William S. Stowe, Esq.
Boston Edison Company Jack R. Goldberg, Esq.
800 Boylston Street Office of the Executive Legal Boston, Massachusetts 02199 Director U. S. Nuclear Regulatory Francis S. Wright, Esq.
Commission Berman & Lewenberg Washington, D. C. 20555 211 Congress Street Boston, Massachusetts 02110 Thomas S. Moore, Chairman Atomic Safety and Licensing Dr. John H. Buck Appeal Board Atomic Safety and Licensing U. S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Stephen H. Lewis, Esq.
Jo Ann Shotwell, Esq.
Office of the Executive Legal Assistant Attorney General Director Environmental Protection Division U. S. Nuclear Regulatory Public Protection Bureau Commission Department of the Attorney General Washington, D. C. 20555 One Ashburton Place,19th Floor Boston, Massachusetts 02108 The Board of Selectmen Town of Plymouth Plymouth, Massachusetts 02360 g
Mr. Lester B. Smith M,
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N" Director of Conservation Massachusetts Wildlife Federation Alan R...Cleeton P. O. Box 343 Marion W. Cleeton Natick, Massachusetts 01761 1