ML20030D274
| ML20030D274 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/27/1981 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Perry S Federal Emergency Management Agency |
| References | |
| NUDOCS 8109010099 | |
| Download: ML20030D274 (19) | |
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August 27, 1981 D
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Spence A Perry, Esq.
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Office of the General Counsel
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Agency W
500 C Street, S.W.
Washington, DC 20472 In the Matter of Cincinnati Gas and Electric Company, et al.
(km. H. Ziamer riuclear Power Station, Unit ho.1 Docket 110. 50-358 Dear lir. Perry-Currently pending before the liRC is an application for an operating license for the subject facility which is located at Moscow Ohio, approxinately 20 to 25 miles east of Cincinnati on the Ohio River. A nur.6er of persons, organizations, and governcental agencies have intervened or are participating in an ongoing adainistrative proceeding regarding the operating license.
The present senedule calls for a hearing early in 1982.
In accord witn the itemorandun of Understanding between tiRC and FEIM cated flover.ber 4,1980, we are requesting tnat FEhA prepare testimony to address contentions relating to off-site energency preparedness. All contentions are enclosed herewith.
Our review pursuades us that contentions 4(d) and (f), 20, 21, 22, 23, 24, 27, 28, 29, 30, 31 and 32 all relate to offsite conditions and should be addressed by FEMA. Contentions 4(c) and (e) and 25 and 26 are mixed and should be dddressed by both IIRC and FEMA.
Under 10 CFR 9 50.47(a) of the liRC's regulations, no operating license for a nuclear power reactor will be issued unless a finding is nade by the HRC that the state of onsite and offsite emergency preparedness provides rea-sonable assurance that adequate protective measures can and will be taken in a radiological errergency (10 CFR S 50.47(a)(1)). The fiRC will base its findings in this regard on a review of the FE!!A findings and determinations on whether State and local ecergency plans are adequate and capable of being implenented and on the liRC assessnent as to whether the applicants' onsite emergency plans are adequate and capable of being implemented.
(10 CFR 6 50.47(a)(2)).
In view of these provisions of the flRC regulations, it will be necessary for the HRC Staff to prepare a written evaluation of the over-all adequacy of energency preparedness for Zitrer. This evaluation will be based in substantial part on FDiA's findings and determinations, pursuant to Section II.4 of FalA/liRC llenorandua and Understanding of flovember 4,1980,0S09
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g.-. i on radiological euergency planning and preparedness. The HRC Staff's evalua-tion and, thus, of necessity, the FalA's findings and determinations should be coupleted before the Zimer hearing reconvenes in eetly 1982.
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In the interest of getting FD%'s Zimer review underway expeditiously, I suggest that we arrange a meeting involving the HRC Staff's Zimer project r.anager and energency planning personnel and those FaiA personnel who will be involved in tne FEl% evaluation for Zimer. At such a meeting, the hRC Staff will provide its projected detailed schedule for the Zinner planning review and its views as to tne needed supporting reviews and evaluations frar,i FDA and we can commence to prt,are for the nearing.
Please contact ce at your convenience to set up such a meeting.
I can be reached at (301) 492-7455.
Sincerely.
Charles A. Barth Counsel for NRC Staff
Enclosure:
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CONTEN_TIONS__ IN__Z lFER CONTENTIONS OF DR. FANKHAUSER 1.
The Applicants will not meet the design objectives of Appendix I to 10 CFR Part 50 becuase too great a volume of spent fuel will be allowed to accumulate at the site to keep the emissions below said design objectives.
2.
The Applicants' plans for monitoring radiological releases from the plant are inadequate becuase:
(a) no provisions have been made to monitor said
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releases at the Moscow Elementary School which is approximately 800 meters from the proposed
- site, (b) no provision has been made for directly involving the citizenry in the vicinity of the site in the monitoring of the plant's activities, (c) it is unclear from the Applicants' plans whether all radioactive emissions will be monitored or whether only certain isotop'es will be monitored, l
(d) no monitoring readouts ai
,_ ~0eided at the City Water Works, (e) the statement by Applicants that the monitoring will be "as comprehensive as possible" is vague o
and monitoring methods are unclear, (f) no monthly assays of isotopic concentrations in area food-stuffs are provided for, and
3 (g) there are no plans for a ring of monitoring stations around the site to continuously moni-tor gaseous emissions.
3.
The Applicants' plans for monitoring radioactive afiiuents from the plant are inadequate to prevent contamination of the City of Cincinnati's drinking water supply because no direct links are planned between monitoring caufpment at the plant and the City Water Works.
~ 4.
The Applicants' plans for dealing with an emergency situation precipitated by an accidental release of radioactivity are inadequate to protect the populace of the vicinity of the proposed reactor because:
s(a) the Applicants leave to the discretion of'the emergency coordinator when and t,hom to notify in case of an emergency, N(b) there are inadequate provisions for notifying public authorities when a situation is developing which could Icad to en emergency, (c) inadequate provisions are made for a training and information program directed at the populace in the vicinity of the reactor to prepare it to deal with a possible emergency, (d) no contingency plans for emergencies are presently a nilable involving the Clermont County Disaster
- Service, a
(e) inadequate provisions are made f..r sufficient training of local safety officials and agencies to enable them to cope with emergencies precipi-l tated by accidental releases of radioactivity,
m 3-(f) inadequate provisions are rade to equip local agencies with safety apparatus adequate to cope with emergencies, (g) inadequate provisions are made for notification of local safety officials of occurrences which might result in an emergency situation.
(h) inadequate access to tht plant is permitted by Applicants to local safety officials for the purposes of inspecting safety precautions and procedures established and carried out by plant personnel.
5.
There are no plans to provide knowledge and training of the populace in communities through which radioactive ma*.erials will be transported sufficient to alow them to be able to cope with transporta-tion accidents.
6.
The Applicant.; will not meet the design objectives of Appendix !
to 10 CFR Part 50 beciuse the dose levels to the children at the Moscow Elementary School will exceed those which are permissible.
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QTYOFCII;CiritiATI 7.
The surface-water monitoring system proposed by the Applicants is inadequate to protect the populace in the Cincinnati area because Applicants do not provide sufficient information regarding permanent monitoring stations and may not provide for monitoring with continuous frequency of the Ohio River upstream from the City of Cincinnati water works intakes, 8.
The Applicants' emergency plans are inadequate to provide w
reasonable assurance that the health and safety of the citizens of Cincinnati will be protected because the Applicants do not provide sufficient or adequate emergency notice communications to the City's water treatment facilities in the event of accidental leakages or dis-charges from storage ' areas of excessive radioactive materials into the receiving waters of the Ohio River.
9.
The Applicants have not provided fo:- independent members of its Environmental Review Board who are, responsible to the interests of the citizens of Cincinnati. The Applicants' plans for monitoring radio-active emeissions from the Zimmer plant are inadequate because the Environmental Review Board created by the Applicants fails to include any members who would be directly responsible to the interests and welfare of the City of Cincinnati, and not solely to the interests of the Applicants.
10.
The Applicants have made no provisions for the transmission of nonitoring data to the City for surveillance of upstream levels of radioactive materials in the Ohio River.
The Applicants' plans for surface-water monitoring are inadequate because no provisions have been
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made for the transmission of surface-water rnonitorfcg data directly to the City for surtcillance of upstream icvels of radioactive materials in the waters of the Ohio River.
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r:IAMI VALLEY POWER PROJECT 11.
Current data demonstrates that there is no need for th'e Zimmer plant at this time because Dayton Power and Light's peak demand is and wil1 not be sufficient to justify the added power until af ter 1985.
12.
The Proju.t alleges that the Applicants cannot guarantee an adequate supply of nuclear fuel for the plant in question. The Board construes this allegation to be that Applicants will not have an adequate fuel supply to operate the plant which is sought to be authorized for operation.
13.
The equipment used in the construction and operation of the plant will be' excessively costly and, in effect, beyond the financial capability of Applicants. Applicants are financial unqualified to operate the plant because of escalating costs.
14.
Coble trays containing electrical wires have been inadequately welded by improperly qualified welders and there have been inadequate testing of these welds.
15.
Control rods which must be easily inserted into and removed from the reactor core,have been inadequately manufactured so that they do not meet the size specifications for such control rods.
16.
Almost all of the seals on the control rods, which tihen properly set prevent radioactive water from leaking out when the reactor is shut down for maintenance, do not meet minimum specifica-l tions for smoothness. Rough seals cannot set properly, making l
l servicing more difficult and unnecessarily endangering workers and the general public by causing leakage or radioactive water.
- 17. Fire insulation niaterial which is being used to protect the cables in the cable trays from fire is inadequate te protect the cables in light of the cable tray installation design and cable tray load. The tests of the fire insulation material were improperly performed in that conditions which will exist durine operation were not adequately simulated.
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CINCINNATI h!ifNDED 18 The continuous transmittal of monitoring data capable of showing releases from the plant in excess of Appendix I levels, with the capability of making a permanent record thereof, to the appropriate city agencies from the Station's already provided for cantinuous stack monitors and from any such other known paths of radioactive emissions into the air from the plant.
19.
A system of continuous air monitors to be situated in such a manner as to have the capability of detecting the direction and radio-active content of airborne radiation or radioactive plumes from plant releases in excess of the limitations prescribed by the NRC which monitors shall have the capability of making a permanent record of the i
monitoring data received and analyzed on a continuous basis, and the data from which can be transmitted continuously to appropriate city apncies.
The data sought in these c,ontentions is needed in order that the city may develop a neLork of qualified persons to interpret the monitoring data received from the Zimmer Station and develop nrocedures for acting appropriately upon that data.
This monitoring is intended to be in addition '.o thetmergency communications radiological monitoring requirements, evaluation procedures and other emergency plans required by the NRC of the Applicants pursuant to the granting of an operating license, and shall not be construed to limit c modify the Applicant's ether obligations in this regard to notify the city or other public agencies in the event of releases or potential releases or otner accidents or incidents at the Zimmer Station t.hich n.3y involve radio-active contamination in excess of prescribed !3C limitations for releases.
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-9 ZAC CONTENTIONS t
20 The evacuation plans for the plume exposure pathway of the Emergency Planning Zone, approximately a 10-mile radius of the Zimmer Pcwer Station and consisting of, and involving, parts of Clermont County, Ohio, Bracken County, Kentucky, Pendelton County, Kentucky and Campbell County, Kentucky, and potentially parts of Brown County, Ohio, and the municipal.and village political sub-divisions therein, are inadequate in their respective failures to timely and promptly evacuate the population within that zone to appropriately reduce, or minimize, radiation exposure for the pro-
.i tection of the safety and health of the public, due to:
a].
The absence of a loc-1 control site, or emergency operations facility, in any one, more, or all of the aforestated counties, as the emergency resource and command center, properly equipped and staffed, for offsite local and state personnel possess-ing the responsibility for controlling the area evacuation, directing, and altering as necessary, evacuation routes and directing and a
deploying local police, fire and para-medic personnel;
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b].
The absence of adequate communication system, or systems, both telephone and radio, for the coordination and directic
, of evacuation and receipt and dissemination of data and information within any involved county, among involved counties and between county or counties and the site, and for communications between the emergency resource and command center and the site and police, fire and para-medic personnel; c).
The public roadways, as access roads for the evac-uation of the Emergency Planning Zone populace of Clermont County, Ohio and Bracken, Pendelton and Campbell Counties, Kentucky, are inadequate to promptly and timely evacuate the involved population, and under circumstances of wind direction presenting the plume exposure pathway in the involved Kentucky Counties no adequate access road is available to afford evacuation of that population; d).
Bracken and Pendelton Counties, Kentucky have no local agency responsible for emergency. preparedness, creation of evacuation plans or monitoring for the protection of the health and safety of the residents of those communities, and have no emergency preparedness, evacuation' plan, oamunication system, monitoring control
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or coordinator for police, fire and para-medic personnel and the related summoning, directing and deployment of such personnel in an emergency situation; l
e].
The involved counties of Ohio and Kentucky possess no professional, full-time fire and life squads, relying totally upon volunteer, part-time personnel whose primary concern and respon-sibility is to other endeavors and who have 2emited training; and the involved counties rely in many respects upon volunteer, auxiliary policemen to supplement inadequately staffed local police units and the total full-time and auxiliary local police personnel, by number,
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are inadequate to provide immediate and necessary police control in an emergency situation and the emergency resource personnel of police, fire and para-medic are inadequate for utilization during initial emergency and evacuation; f].
During flood conditions of the Ohio River and its tributaries, access roadways to the Zimmer Power Station and access roadways for evacuation, situated in Ohio, are impassable, and in certain flooding conditions the Zimmer Station site is isolated and inaccessable to emergency vehicles and in such circumstances both population evacuation and offsite assistance to the Zimmer Station are impossible; h].
During inclement winter weather conditions, road-ways in the involved counties of Ohio and Kentucky are impassable due to accumulations of ice and snow, rendering evacuation of the re-spective populations and response of offsite energency units to the Zimmer Station impossible for substantial time periods, and the majority of access roadways for evacuation purposes remain impassable for prolonged pet."-Cs of times, measured in weeks, thereby prohibit-
, ing large segments of the Emergency Planning Zone populations of the j
involved counties frcie being evacuated by motor vehicle or other-wise being evacuated promptly and timely by other means; and a large segment of the Emergency Planning Zone populations of the l
involved counties are unable to reach access roadways from their residences for extended time periods during the presence and continuation of large accumulations of snow, thereby precluding l
either their evacuation by motor vehicle or the timely and prompt
evacuation by other means.
21 The evacuation plans for the plume exposure pathway of the Emergency Planning Zone includes 18 elementary and secondary schools situated in Clermont County, Ohio and Bracken County, Pendelton County.and Campbell County, Kentucky.
Evacuation plans for these schools are inadequate to evacuate the populations of such schools in a time period required to reduce, or minimize, exposure and protect the safety and health of the children, due to:
a].
An inadequate number of school personnel at each of the subject schools to direct, supervise and control the evacuation of school children to an approved receiving site; b].
The school personnel at each of the subject schools lack the training and qualifications to supervise and administer aid and comfort to school children, especially school children in the elementary schools, during evacuation and housing in reception sites during the emotional trauma occasioned by the emergency and evacuation, or to possess, control, supervise and administer the thyroid blocking agent, potassium iodine, as required, to such children; l
c].
The respective school districts do not possess a sufficient number of buses for a timely and orderly transportation from the school to a receiving site during evacuation; d].
The respective school districts do not possess either the capability or the number of buses necessary to afford transportation for the evacuation of school children where the emergency evacuation arises during bus transportation of children for the commencement or termination of the school day, because of 1
l the bus routing, multiple routes and trips, and a portion of the children being located at the school site and the remaining children being transported in the available buses; e].
Tne inability of the respective school districts to summon buses to schaal sites in a prompt and timely manner,or provide standby buses where school evacuation is required during the course of the school day, the buses being located and stationed at various sites, unattended by drivers and the inadequate and ineffective means, or no means, of communication to drivers to advise of the emergency and to require bus response to the subject school to commence evacuation.
22 There are no warning devices, siren or otherwise, or other communicative means to timely, promptly and effectively advise and alert the community, including the schools within the Emergency Planning Zone portions of Clermont County, Ohio, and Bracken, Pendelton and Campbell Counties, Kentucky, of an emergency and evacuation of the population; and the terrai, or topography, and land character-istics and population distribution of each of the subject counties is such that no universal warning device, siren or otherwise, is capable of alerting the public and informing them of an emergency and evacuation; and the respective counties, and each of them, is without financial means to employ various and numerous alternative devices and methods or the equipment and personnel necessary to warn, alert, advise and inform the public of emergency and evacuation within the time required for the protection of the health and safety of the subject communities.
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23.
The de:nography of the Emergency Planning Zone portions of Clermont County, Ohio and Bracken, Pendelton and Campbell Counties, Kentucky, is such that no adequate, effective and positive education, training and advice to the public can be presented for the public's responsive, orderly and timely evacuation in the event of acciden,t.
24.- Within the Emergency Planning Zones of the Zimmer Power Etation, inclusive of a 50 mile radius, there are inadequate medical facilities to afford the required bed space, medical and para-medical personnel, requisite medication, screening, treatment and isolation of persons sustaining radiological injury; and the absence of adequate emergency materials, supplies, equipment and vehicles necessary for the transportation of injured persons, injured onsite and offsite, during a radiological accident.
25.
The monitoring devices selected and their placement onsite and offsite for the monitoring of anticipated radiation releases ar.d accidential releases of radioactive materials, including plume exposure in the event of accident, as to the type and location are inadequate to protect the health and safety *of the populations of Clermont County, Ohio and Bracken, Pendelton and Campbell Counties, Kentucky, and as the same applies to the monitoring of releases into the Ohio River au the same affects the d.-inking water, plant and animal life of that waterway subsequently consumed by the population of the subject counties; and the inability of such devices and their location and l
types to adequately and timely inform the applicant and the respective local and state agencies and related dissemination of such information o
to and for the protection of the public's health and safety.
26 The monitoring equipment, as to number, type and location, I
onsite and offsite, is inadequate for the independent monitoring by l
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other sources, including at a minimum individuals and local and state agencies, in conjunction with applicant's monitoring, for the purpose of protecting the publics health and safety in radiation release, radioactive effluents and plume expocure in the emergency situation L.a the interest of the public in such information.
27.
-The absence of appropriate type and placement of monitoring devices at the 18 schools located within the 10 mile radius of the Zimmer Power StAtlon, the absence of trained local, state and school personnel to observe such devices and alert and advise accordingly, and the inadequacy of such devices to timely advise of dosage exposure sufficient under applicable standards to require protective action, jeopardize the health and safety of children continuing to be exposed to excessive dosage in the respective schools.
28.
The absence of trained local and state personnel to conduct observations of monitoring devices to alert and advise the public of excessive dosage amounts under applicable standards of radiation releases, radioactive effluents and plume exposure in the emergency situation; the absence df a local agency site in Clermont County, Ohio and Bracken, Pendelton and Campbell Counties, Kentucky; the absence of trained local personnel; the absence of sufficiently trained personnel for 24-hour surveillance and the requisite equipment for the surveillance of onsite informational equipment for independent monitoring and awareness by such local personnel of an unusual event, alert, site emergency or general emergency developing or in being at the site, for simultaneous and responsive action to the same; results in the failure of local and state support and response agencies to possess adequate and necessary emergency preparedness, h__
, institution of protectivo measures and correctivo actions, assessment of the situation, alerting and advising the public and the institution of prompt and timely response for the minimizing and reduction of exposure by the public for the public's health and safety.
29.
The inadequacy of meteorological equipment and related.
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monitoring of the plume exposure pathway during emergency and the alteration of such path while in progress to furnish prompt, timely and correct information to applicant, local, state and federal person-nel to achieve timely and correct decision and to so inform the public of evacuation routes and alterations in such routes as required where the plume exposure path changes directions while in progress, is detrimental to the health and safety of the transient and permanent population within the plume exposure pathway of the Emergency Planning Zone.
30 The absence of applicant's furnishing, or alternatively, inadequate furnishing, to the population within the plume exposure pathway of the Emergency Planning Zone of protective equipment and gear, is:1uding clothing, for use during an emergency and ensuing evacuation for that population's protection against radiological exposure, including whole body and inhalation, and such failure, or inadequacy, as the case may be, subjects the public to health and safety dangers and potential injury.
31.
Clermont County, Ohio and Brachen, Pendelton and Campbell Counties, Kentucky do not possess the requisite funds or the financial means for the purchase, installation and maintenance of the required
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0 equipment, the requisite personnel, the required training of its personnel or the creation of the necessary control centers to provide adequate protection for the health and safety of the public and the "M
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applicant must be responsible for the expenses necessary to achieve a state of emergency preparedness.
32 The adequacy of onsite and offsite organizations for coping with emergency and the adequacy of emergency preparedness-must be evaluated in a test conducted prior to commenceme-t of the..
operation of the Zimmer Power Station as a joint exercise-drill in-volving applicant's emergency resource personnel, local and state emergency response personnel and partial public participation, in-cluding partfal school participation, within the plume exposure path-way of the Emergency Planning Zone, demographical, topographical, accessable site and evacuation routes and local jurisdictional bound-aries being considered and examined, to determine the adequacy of implementing procedures and.nethods, the testing of emergency equip-ment and communication networks and timing, from which and due to the land characteristics, personnel, equipment and other relevent factors the state of emergency preparedness will not meet the required standards for the protection of the health and safety of the populace with the Emergency Planning Zone' in an emergency circumstance.
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