ML20040D906

Comments on Immediate Effectiveness of ASLB 811214 Partial Initial Decision.Commission Cannot Determine That Public Health & Safety Protected Since Health Impact & Psychological Stress Has Not Been Considered

ML20040D906
Person / Time
Site:	Three Mile Island
Issue date:	01/27/1982
From:	Phelps G ANTI-NUCLEAR GROUP REPRESENTING YORK
To:
References
NUDOCS 8202020380
Download: ML20040D906 (3)

Text

l

- AEGRY1/27/82 OQi5 UNITED STATES OF AMERICA 7

NUCLEARREGULATORYCCgIfgIdN3 BEFCRE THE COWISSION In the Matter of ) gg

) 'Up~luQ[ nth'h .

Metropolitan Edison Company ) Docket 50-289 s

) @ t Three Mile Island Unit One )

R

• Ecy,P

&O -

v- e 1 4 CCl4LTS,CF INTERVENCR I982r ANTI-NUCLEAR GRCUP REPRESENTING YCRK 'i h CN I!O:EDIATE EFFECTIVENESS OF THE /f ASLB PARTIAL INITIAL DECISION 'b @

The Conmission has invited comments from parties to the TMI-1 proceeding on the question of immediate effectiveness of the Partial Initial Decision (PID) which was issued by the Atcmic Safety and Licensing Scard on December 14, 1981. We appreciate this opportunity, and set forth our ecmments below on our principal area of concern which is the adequacy of emergency planning to protect the public in this area should there be another major accident at Tnree Mile Island which again requires hundreds of thousards of people to flee their homes in fear for their lives. We will keep our ccaments brief.

There are several major reasons why the Commission cannot at this time determine that the health and safety of the people of central Pennsylvania will be protected if the Unit One reactor at TMI is permitted to restart at any power levels

1) The health impact of restart at any power level has not been considered. In fact, the Commission has studiously ignored it.

2) The effects of psychological distress from the TMI-2 accident,,

9603 5

from a decade of clean-up process and expected clean-up process, from restart, and from a second Three Mile Island accident

/b 8202O20380 820127 GPDR ADOCK 05000289 PDR

o upon the efficacy of any emergency actions during a second Three Mile Island accident have not been considered. In fact, again, the Commission (and FEMA) has ignored this.

3) The Atomic Safety and Licensing Board has not yet decided on all of the litigated issues.

4) The Appeals Board has not yet even heard exceptions to the partial decisions of the ASLB. The Commission originally agreed to review the substance of the ASLB decision >and the record before lifting the license suspension. To consider allowing im=ediate effectiveness of the ASLB Partial Initial Decision before the Appeals Board has reviewed the many intensely litigated issues would compond the error in what, in our view, was a breach of faith by the Co= mission in reversing its earlier determination to review the record.

5) The plant has serious technical problems which preclude restart even if the Commission were to allow it. The company admits that it will be at least six months from now before the steam generator tubes vill be repaired. There is no practical need for the Commission to even consider granting immediate effectiveness to the ASLB Partial Initial Decision.

Emergency planning in this area for another radiological accident at Three Mile Island still suffers from many deficiencies which the ASLB acknowledged- there are no school plans to protect children (who were sent home walking through areas downvind of the plant during uncontrolled releases March 30,1979); the siren system is not finished; public infomation on emergency protective actions has not been distributed; and the Board was unable to determine what the effects of the psychological impact of the TMI-2 accident, of the clean-up, of restart, of radiation threats, or of a second accident at Three Mile Island would be on the efficacy of protective actions.

Even if the assumptions of the Licensee's evacuation time estimate are to be believed, there is no_ protection availabic to the public for rapidly developing accidents; an essential issue gracefully sidestepped in the PID.

e

.o s. ~

-3 In conclusion, there is no practical need for,the Commission to determine immediate effectiveness now. There is substantial need for the Commission to face the many intenably litigated issues and allow the Appeals Board to consider them.. And the Corzission must consider the psychological health of the people in this area as it is affected by restart at any power level, and as it would affect the protective actions taken in the event of a second Three Mile Island accident should the Commission permit restart.

Ve also invite you to come visit the Three Mile Island area yourselves to tell us how you will address the issue of psych 61ogical stress impacts and what your decisions on the many safety issues are.

We are the people whose health and safety you are charged with protecting, and we want to know n thoughts on the safety of restarting Three Idle Island.

Respectfull submitted, l'

' 0

,-j p Gail 3. Phelps, legal representative January 27, 1982. Anti-Nuclear Grcup Representing York 245 Wset Philadelphia Street York, Pa,171.04 717/ 843-7705