ML20040D807
| ML20040D807 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/26/1982 |
| From: | Aamodt N AAMODTS |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20040D806 | List: |
| References | |
| CLI-79-08, CLI-79-8, NUDOCS 8202020273 | |
| Download: ML20040D807 (7) | |
Text
j.1 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In The Matter Of
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Metropolitan Edison Company
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Three Mile Island
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Docket 50-289 Nuclear Generating Station
)
Unit I
)
Aamodt Exceptions To Partial Initial Decision Of December 14, 1981 - Emergency Planning Issues January 26, 1982 h
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,o-The.Aamodts herewith appeal to the Commission by filing the following exceptions to the Partial Initial Decision of December 14, 1981 - Emergency Planning Issues.
All exceptions address item 4 (b) of Commission order CL1-79-8, August 9, 1979.
1.
Board finding 1517 does not provide for direct and immediate notification.
2.
The Board errs at 1518 in finding that " Licensee has pro-l vided for transmissions of data...in a timely fashion".
3.
The Board errs at 1526 in assuming the Aamodts call for "an overly detailed public information program".
4.
Board finding 1527 fails to meet the standards of NUREG 0654.
5.
The Board errs at 1528 with regard to the availability of criteria relative to quality and content of public infor-mation programs.
6.
The Board errs at 1528 with regard to the accountability of responsible agencies with regard to determining, im-plementing and maintaining a public information program.
7.
The Board errs at
- 1528 in failing to provide for long term accountability.
8.
The Board errs at 1529 in finding sufficiency with regard to the Commonwealth public information program.
9.
The Board errs at 1533 in failing to find Licensees public information program deficient for failing to adequately address the hazards to the public of ionizing radiation.
10.
The Board errs at 1534 in its assertion that the PEMA analogy of ionizing radiation to sunlight is "not unduly strained".
11.
The Board errs at 1536 by denying the withholding of dis-tribution of county and PEMA brochures until correction and additions, including those sought by the Aamodts, can be included.
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- 12. LThe Board erre at 1537-when it asserts that sufficient guidelines are in place about which to structure the-l public information program (s).
' 13.
The-Board errs at 1587 by asserting that'" provisions for timely dissemination of information in the event of ac-cidental releases of airborne radioactive gases or particulates...would contravene the established concept of operations for public notification".
14.
The Board errs at 1588 in finding that Licensee has the 1
copability to promptly notify and transmit information to government response organizations.
I 15.
The Board errs at 1921 in incorrectly and inappropriately t
characterizing the Aamodt findings with regard to farmers and livestock.
.l 16.
The Board errs at 1921 in agreeing with Staffs character-ization of the Aamodt findings.
17.
The Board errs at-1924 in its interpretation of the applicability of the statement "public health and~ safety should take clear precedence over actions to protect property".
10 CFR Part 50, APPENDIX E.
18.
The Board errs at 1925 in finding that the Pennsylvania Department of Agriculture Plan presents " extensive-infor-t mation en measures that may be taken to protect animals and livestock".
19. - The Board errs at.1926 by ignoring best evidence with regard to the f arme'r s " choice of two extremes".
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20.
The Board errs at 1926 in asserting that " arrangements for.
help can help to preserve livestock left behind...".
21.
The Board errs at 1926 in finding that protective measures
.in the form of sheltering are available to farmers.
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22.
The Board errs at 1927 in finding that " guidance has been provided which should allow farmers to provide some form of sheltering protection for their livestock...".
23.
The Board errs at 1927 in finding this guidance (22' supra)
" suitable".
24.
The Board errs at 1928 in finding that the Commonwealth's planning "does provide a means whereby evacuating farmers may arrange for assistance in caring for livestock left behind".
25.
The Board errs at 1929 in finding that failure to provide for evacuation of livestock is not a planning deficiency.
26.
The Board errs at 1930 in finding that " assistance _can be arranged in caring for the farmers' livestock in the case
.where evacuation of the public will continue for a protracted period.
27.
The Board errs at 1931 in finding that "there are sufficient options and guidance for care...of... animals to reduce damage to them...".
28.
The Board errs at 1932 in assuming that farmers "should have access to necessary information on protecting them-selves and their families...".
29.
The Board errs at 1932 in finding that " sufficient measures have been taken to provide farmers with information and advice on self-protection...".
30.
The Board errs at 1937 in finding that "the emergency plans adequately provide for the protection of livestock in the event of an accident at TMI".
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31.
The Board errs at 1937 in asserting that "a proper balance has been made between protecting property and public health and safety.
32.
The Board errs at 1940 where it "cannot find that the current plans are sufficiently defective to cause us to recommend
s against restart of TMI-1...".
33.
The Board errs at 1940 in finding that "the deficiencies do not adversely affect the public health and safety...".
Re sp 'ct f ully submitted;
/d ht$n udad NORMAN O.
AAMODT e
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c DOCKETED USNRC
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'82 d"! 28 P3 45 This is to certify that copies of the foll'owing documents were served on the attached service iist by U.S. Mail January.27, 1982.
Those marked with an X were serviced by express mail.
Aamodt Exceptions to Partial Initial Decision of. December 14, 1981 - Emergency' Planning Issues.
Aamodt Comments Relative to the Immediate Effectiveness of Partial Initial Decision of December l4, 1981 &
Emergency Planning Issues.
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M ORIE M.
AAMODT January 27, 1982
.n
- Adninistrative Judge Cary L.
Milhollin
- 0ffice of Executive Legal e
q/o Ivan W. Smith, Chairman Atomic
- Director, U.
S.
Nuc1 car Sa fe ty and Licen sing Board.
Reg'ulatory Commission U.
S.
Nuclear Regulatory Commiasion Washington, D.
C.
20555 Washington, D.
C.
20555
- ocketing and Service Section D
- Administrative Judge Ivan W.
- Smith, Office of the Secretary Chairman, Atomic Safety and Licensing U.
S.
Nuclear Regulatory Comm.
- Board, U.
S.
Nuclear Regulatory Comm.
Washington, D.
C.
20555 Washington, D.
C.
20555 Steven C.
Sholly i
Administrative Judge Linda W.
Little Union of Concerned Scientists Atomic Sa fety and Licensirig Board 1725 Eye St.,
N.
W.
Suite 601 5000 Hermitage Drive Washington, D.
C.
20006 Raleigh, North. Carolina 27612 Robert Adler, Esq.
Administrative Judge Walter H.
Jordan Assistant Attorney General Atomic Safety and Licensing Board 505 Executive House 881 West Outer Drive P.
O.
Box 2357 Oak Ridge, Tennessee 37830 Harrisburg, Pa. 17i20
- Cary L.
Edles, Chairman -
Louise Bradford Atomic 'Sa.fety and Licensing Appeal TMIA
- Board, U.
S.
Nuc1 car Regulatory Comm.
315.~.Peffer St.
Washington, D.
C.
20555 Harrisburg, Pa. 17102 John H.'B.uck.;e -1 Jane Lee Atomic Safety and Licensing Appeil R.
D.
3, Box 3521 Board U.
S.
Nuclear Regulatory Comm.
Etters, Pa. 17319 Washington, D.
C.
20555 Ellyn R.
W e i s's
- Christine N.
Kohl Sheldon, Harmon, Roisman & Weiss Atomic Safety and Licensing Appeal 1725 I Street, N. W.
Suite 506
- Board, U.
S.
Nuclear Regulatory Comm.
Washington, D.
C.
20006 Washington, D.
C.'20555 Professor Gary Milhollin
^' Nunzio J. Palladino, Chairman 1815 Jefferson Street U.S. Nuclear Regulatory Commission Madison, Wisconsin 53711 Washington, D.C.
20555 E
Ms. Cail Bradford Victor Gilinsky, Commissioner ANGRY U.S.
Nuclear Regulatory Commission 245 W.
Philadelphia Street Washington, D.C.
20555 York, Pa. 17404
- Peter A.
Bradford, Commissioner M Reginald L.
Cotchy U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Washington, D.C.
20555
- Board, U.-
S.
Nuclear Regulatory Cor
- John F.
Ahearne, Commissioner U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
- Ce o rg e:. F. < Trowb ri dg 6,~
Esq.
Shaw, Pittman, Potts and Trowbridge w Thomas M.
Roberts, Commissioner 1800 M Street, N.
W.
U.S.
Nuclear Regulatory Commission Washington, D.
C.
20036 Washington, D.C.
'20555 4
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