ML20049A559
| ML20049A559 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/28/1981 |
| From: | Kevern T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20004B928 | List: |
| References | |
| NUDOCS 8106010325 | |
| Download: ML20049A559 (33) | |
Text
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UNITED STATES OF At1 ERICA NUCLEAR REGULATORY C0tiMISS10tl BEFORE THE SAFETY ATOMIC AND LICENSING BOARD In the Matter of
)
SOUTri CAROLIllA ELECTRIC & GAS Docket No. 50-395 COMPAtlY
)
)
Virgil C. Summer Nuclear Station,
)
Unit 1
)
TESTIMONY OF THOMAS A. KEVERN ON FAIRFIELD UNITED ACTION CONTENTIONS 7, 8, 9, 10, 11 AND 13*
Q.l. Could you please state your name, place of employment and professional qualifications?
A.
!!y name is Thomas A. Kevern.
I am employed by the U.S. Nuclear Regulatory Commission as a nuclear engineer and emergency preparedness tean leader in the Division of Emergency Preparedness, Office of Inspection and Enforcement (I&E). A copy of my professional qualifications is attached (Attachment B).
Q.2. Could you briefly describe your role with respect to the review of emergency planning for the Sumer nuclear plant?
A.
I performed the NRC Staff review of the applicant's emergency plans for the Sumer nuclear plant as presented in the Safety Evaluation Report and supplements.
- See statement of these Contentions in Attachment A.
8106010 %
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Q.3. With respect to Fairfield United Action (FUA) Contention 7, I understand that you are only offering testinony on subparts (a),
(b), (c), (d), (e), (f), (g), (i), (j), (1), (m), (n), (nn), (o),
(p), (r), (s), and (t).thereof.
Is that correct?
A.
Yes.
Q.4. FUA Contention 7(a) asserts that the Applicant's emergency plan does not meet the minimum staffing requi-r e ts as set forth in NUREG-0654, Rev. 1, Table B-1.
Does ue Staff have a position on this?
A.
Table B-1 of NUREG-0654, Rev.1 sets forth the criteria on minimun staffing requirements for both on-shift personnel and the augmentation of shift personnel.
The applicant's Emergency Plan i
(April 1981) provides for staffing which meets the criteria pertaining to on-shift staffing, except for the absence of_an on-shift Rad / Chem Technician, and provides for timely shift augmentation which meets the criteria with respect to manning.
Additionally, the applicant has committed to resolving the area of l
staffing requirements either by complying with the specific criteria l
and implementation date or meeting an alternative acceptable to the Staff. The Staff, therefore, finds the applicant's proposed j
staffing acceptable.
Q.5. FUA Contention 7(b) asserts that the applicant's emergency plan i
includes agreements with local organizations which fail to delineate l
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the Staff have a position on this?
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A.
Appendix C to the applicant's Emergency Plan includes letters of
,4, agreement with local organizations. These letteri of agreement can '
be categorized into two groups: (1) agreementh,with fire,ilaw s f(
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enforcement, and medical servf,ces arp((2) agreements witbcounty h
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governments' emergency management agencies.
In the fiftt category.
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each organization indicates t.n'at upon notification it will furnish /
These letters of agreement,j/
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support in the event of an emergeacy.
arranged with organizationsMbich respond to emergencies or,' a daily
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basis, document the agreepent t[*the organizations,to' prov{de,1 r' -
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services to the applicart,and thus provid3, reasonable as,s
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emergency services would be provided f r/ tra event of an emergency, i,n-i
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which assistance is requireds Inese ledters would be iraroved if e
expanded to include the specifi'c equipmst.and p'ersonnel to be
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provided. However, the servicesio be provided by these 7
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.t organizations are those which are pGrfonned routinely by the i<
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organizations. To,crisure these, orgar.17a*. ions are familiar with e s special problems as.[ociated:witMthe applicant's facility, the
,6 applicant is required to conduct tfatning for the personnel of these i
l organizations and to hold per1 odic drills and exercises involvin/
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h Thesc{condcategor.Moflettersinvolves s
these organizations.
I dgreements reached with ene,rgency management agencies for those l
Sinc.e cach county has ' developed
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counties in the plume exposure EPZ.
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its own emergency preparedness plans designed'to respond to a t
radiological emergency, which provide detailed descriptions of such y
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a response, detailed letters of agreement are not required.
In fact, the county emergency nanagement agencies are legally recognized agencies responsible to direct and perfona energency services, and, as such, letters of agreenent are not required under the new emergency planning rule or the criteria in NUREG-0654.
Q.6. FUA Contention 7(c) asserts that the applicant has failed to demonstrate the ability to notify local emergency preparedness officials within 15 minutes.
Does the Staff have a position on this?
A.
The criteria of NUREG-0654 specify that prompt notification of offsite authorities is to be initiated within about 15 minutes for the unusual event class and' sooner (consistent with the need for other emergency actions) for other classes. The applicant has 24 hour-per-day communication capability with the State and counties of Fairfield, Lexington, Newberry, and Richland. Offsite authorities must be prepared to alert the public within about 15 minutes of notification from the plants. The applicant is required to demonstrate the ability to meet the notification criteria by means of communication drills and/or energency preparedness exercises.
The applicant performed their function satisfactori',y
'he !!ay 1, 1931 joint exercise.
The capability of offsite authoritles to take timely actions was considered by FEMA in its evaluation of the joint exercise.
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' 47.
FUA Contention 7(d) asserts that the applicant has not adequately planned for the distribution of informational materials. Does the Staff have a position on this?
A.
Tne applicant has provided an emergency information brochure to the residents within the plume exposure emergency planning zone by means of bulkmailing through local post offices. Additionally, the dppilCant has committed to providing this information in local business establisnments, e.g., motels, gas stations, and restaurants, and to posting emergency information/ instructions signs at recreation areas. The applicant's Emergency Plan (April 1981) provides for the annual update of emergency information for members of the public within the plume exposure emergency planning zone and the conduct of an annual statistical sample of the public to assess awareness of actions to be taken in the event of an emergency.
Q.8. FUA Contention 7(e) asserts that the applicant has not developed realistic estimates of evacuation times and has not employed the methodology set forth in Appendix 4.
Does the Staff have a position on this?
A.
Appendix J to the applicant's Emergency Plan (April 1981) contains an evacustion time assessnent study pertaining to the area surrounding the applicant's site.
The staff has reviewed this evacuation time assessnent study against the criteria of NUREG-0654 and determined that it is adequate.
- Q.9. FUA Contention 7(f) asserts that the applicant has failed to provide adequate means for protecting those whose lack of mobility is impaired by lack of vehicles.
Does the Staff have a position on this?
A.
The applicant has included in the emergency information brochure disseminated to the public a statement requesting those persons who have special transportation needs to contact their local Civil Defense Office or Department of Public Safety and notify that organization in advance that they will require assistance in an emergency.
Q.10.
FUA Contention 7(g) asserts that no plans have been made for the distribution and use of radioprotective drugs, such as potassium iodide (KI), as a protective response for the general public. Does the Staff have a position on this?
A.
No provision for distribution of KI for the general public is required by the NRC/ FEMA criteria. The NRC has requested that the Food and Drug Administration and FEMA conduct extensive studies into the utilization and distribution of KI to the general public as a protective action measure.
Q.11.
FUA Contention 7(i) asserts that Table 6.2 in the applicant's energency plan suggests that sheltering is the only Protective Action contemplated for the general public.
Does the Staff have a position on this?
A.
Protective actions for members of the public in the event of a radiological emergency include sheltering and evacuation.
The applicant's Emergency Plan provides for recommending protective measures to those offsite authorities responsible for actions to protect the public. The recommendation made by the applicant will be dependent upon the specific emergency situation and the expected dose to be received by the public. Table 6-1 of the applicant's Emergency Plan summarizes the protective actions, including both sheltering and evacuation, to be recommended for the general public.
Table 6-2 indicates the initial actions of both sheltering and evacuation for a site area emergency and sheltering as the initial action for a general emergency in accordance with NUREG-0654, Appendix 1 guidance. The applicant's plan calls for evacuation for certain general energency cases based on the results of more detailed analyses of plant conditions.
Q.12.
FUA Contention 7(j) asserts that the emergency plans do not set forth the basis for the choice of recommended Protective Actions for the plume exposure pathway during emergency conditions.
Does the Staff have a position on this?
A.
The NRC requires that all licensees develop a four level Classification / Emergency Action Level Scheme.
This classification systeu is required by 10 CFR 50, Appendix E.
The basis of the accident classification scheme and Energency Action Levels is contained in NUREG-0654, Appendix 1.
Using this system, the various accidents are classified based on their seriousness and the 1
9 i
1 l '
l potential for offsite release. This system provides for worsening of accident conditions by providing prompt notification for minor I
events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized. A gradation is provided to assure fuller response preparations for more serious indicators. By classifying each potential accident into one of the four classes, Notification of Unusual Event, Alert, Site Area Emergency, and General Energency, and by identifying various instrument and radiation monitor readings and alarms which correspond to accidents or occurrences in each of these categories, accident recognition and classification is enhanced. The applicant's Emergency Plan incorporates a four-tiered accident classification system which meets the requirenents of the regulation. These Emergency Action Levels (EALs) classify accidents in the Site Emergency and General Emergency categories at radiation readings or EPA Protective Action Guides (PAGs) recoi.. mended by HUREG-0654, Appendix 1.
The applicant may recommend, and the State may choose, however, to take actions at lower levels of radiation readings and at lower fractions of PAGs than those specified in 14UREG-0654 for particular emergency classes.
Q.13.
Fl% Contention 7(1) asserts that onsite first-aid is inadequate. Does the Staff have a position on this?
A.
The applicant's Emergency Plan (April 1981) identifies the following capability pertaining to first aid:
9-(1) Two personnel on each shift qualified in first aid techniques by attendance at the multimedia National Red Cross First Aid course.
(2) First aid kits located throughout the plant.
(3) An onsite medical roon and a dispensary which contain a variety of medical supplies.
(4) An arrangement (letter of agreement) with the Pinner Clinic for a physician to respond to the site if medical treatment is required.
(5) An arrangement (letter of agreement) with the Fairfield County Emergency tiedical Service to provide transportation of a victim (s) to a hospital. We conclude that this capability is adequate.
Q.14.
FUA Contention 7(m) asserts that the News Media Center is not located at the Applicant's Emergency Operations Facility. Does the Stoff have a position on this?
A.
Colocation of the News fledia Center with the Emergency Operations Facility is not an NRC requirement. The applicant's interin llews tiedia Area is currently located in a building adjacent to the applicant's interin Emergency Operations Facility. The applicant has made provisions for equipaent and facilities at the interim News Media Area to accomodate various media representatives.
Q.15.
FUA Contention 7(n) asserts that the Interim Energency Operations Facility does not comply with the requirements of NUREG-0696, Rev. 1.
Does the Staff have a position on this?
A.
NUREG-0696 sets forth the criteria pertaining to the energency operations facilities required of licensees and applicants.
The NRC
. has established the date of October 1,1982 by which the emergency operations facilities must meet the criteria of NUREG-0696.
The f4RC and the applicant are aware that the applicant's interim Emergency Operations Facility (EOF) does not presently comply with the criteria of fiUREG-0696 for a permanent E0F.
The staff has reviewed the applicant's facility and determined that in the interim, the facility is acceptable. The applicant has committed to meet the requirements pertaining to the emergency operations facility either by complying with the specific criteria or meeting an alternative acceptable to the Staff. The applicant's proposed permanent emergency operations facility will be reviewed by the staff to assure that the facility is operational prior to the required date.
It is expected that this date may be later than the date the operating license is issued.
Q.16.
FUA Contention 7(nn) asserts that the Applicant's meteorological monitoring equipment does not meet the requirements of flVREG-0654, Rev.1, Appendix 2, in that it lacks a viable back-up system with emergency power and is not seismically qualified.
Does the Staff have a position on this?
A.
Appendix 2 to I4UREG-0654 sets forth the meteorological criteria for energency preparedness at nuclear power plants. The criteria do not call for emergency power or seismic qualification for meteorological equipment. Appendix 2 contains a time schedule by which the upgrading of meteorological capability is to be accomplished in stages. The applicant's meteorological capability, as it currently
- exists, does not meet the criteria of Appendix 2.
The applicant has committed to meet the requirements pertaining to meteorology either by complying with the specific criteria and implementation dates or neeting an alternative acceptable to the Staff prior to license issuance. The applicant's proposed meteorological capability will be reviewed by the Staff to assure that this capability is present prior to the required date.
It is expected that this date may be later than the date the operating license is issued.
Q.17.
FUA Contention 7(o) asserts that the Applicant has failed to denonstrate that its siren system will meet the requirements of NUREG-0654, Rev. 1, Appendix 3.
Does the Staff have a position on this?
A.
Appendix 3 of NUREG-0654 sets forth the criteria pertaining to the means for providing prompt alerting and notification of the population within the plume exposure pathway Emergency Planning Zones.
The criteria do not require seismic design of the public notification system.
The applicant has developed, provided a description to the staff of, and is currently installing an alert dnd notification system to be used to promptly inform the public within the plume exposure pathway Emergency Planning Zone and which is intended to meet the criteria of Appendix 3.
The staff has reviewed the systeu description and found it conceptually acceptable.
The alert and notification system, upon completion, will be evaluated by the Federal Emergency Management Agency by means of a demonstration of system operation.
. Q.18.
FUA Contention 7(p) asserts that the Applicant has failed to comply with the requirenents of fiUREG-0654, Rev.1, Appendix 4 for determining and describing evacuation times, has failed to establish the acceptability of criteria used to establish evacuation times, and has failed to demonstrate the capability of the Applicant and State and local governments to assure timely evacuation under accident conditions.
Does the Staff have a position on this?
A.
Appendix J to the applicant's Emergency Plan (April 1981) contains an evacuation time assessment study pertaining to the area surrounding the applicant's site. The staff has reviewed this evacuation time assessment study against the criteria of fiUREG-0554 and determined that it is adequate.
The criteria of fiUREG-0654 were developed by the f4RC and FEtiA and subjected to a public comment period before being made final.
The criteria assure that evacuation times are quantified in a manner adequate to aid planners in optimizing their response (e.g. by planning to augment traffic controls at key points) and to aid decision-makers in choosing between protective actions such as sheltering and evacuation given the actual conditions of an emergency.
The capability of State and local governments to respond will be evaluated by FEtiA based on a review of the offsite plans and the recent joint exercise. Actual evacuation of the general public in an exercise is not required by the f4RC regulations or f4RC/ FEMA guidance.
Q.19.
FUA Contention 7(r) asserts that the Plume Exposure Pathway EPZ boundaries established in local plans are not based upon reasonable
criteria which have been explicitly stated and demonstrated.
Does the Staff have a position on this.
A.
The basis for the Emergency Planning Zone sizes is the collective judgment of the NRC/ EPA task force and the basis for this judgment is set forth in detail in NUREG-0396/ EPA 520/1-78-016.
The Commission has now adopted the EPZ sizes in the NRC regulations af ter extended rulemaking.
Q.20.
Contention 7(t) asserts that the Applicant, state and local plans otherwise fail to comply with some unspecified requirements set forth therein.
Does the Staff have a position on this?
A.
The Staff has reviewed and evaluated the applicant's Emergency Plan (April 1981) against NUREG-0654/ FEMA-REP-1, Revision 1.
The staff evaluation is documented in the Safety Evaluation Report NUREG-0717 Supplement No. 2.
Q.21.
FUA Contention 8 asserts that public information materials distributed by the applicant relative to radiological emergency response planning is inaccurate, intentionally deceptive regarding the potential health effects of radiation and present evacuation routes which could result in persons unwittingly evacuating through the plume.
Does the Staff have a position on this?
A.
The applicant has prepared and disseminated to the po,nulation within the plume exposure pathway Emergency Planning Zone an emergency informotion brochure (see response to Question 7).
This brochure has been reviewed by the staff and the Federal Emergency Management Agency. The joint agency review resulted in the following comments:
i
. (1) The overall evaluation is that the brochure is well done.
It presents the information in a brief, readable format and the scope of the information meets all requirements.
(2) With respect to the contamination levels in the secondary loop, the applicant somewhat overstates the level of cleanliness of the secondary loop fluid.
However, the purpose of this section of the brochure is to explain, in layman terminology, a pressurized water reactor nuclear power plant including the concept of a primary loop and a secondary loop.
The brochure provides an acceptable explanation of the applicant's power plant.
- (3) It would be useful to add to the scope of the map the locations of the reception centers and indicate that the public may be instructed to take alternate routes under some accident conditions.
(4) The information presented on low-level radiation contains several items of controversy. The level of radiation which is clinically detectable is probably in the range of 10,000 to 25,000 mrem.
The staff is not familiar with the background levels noted for parts of Brazil.
The staff believes the average natural background radiation in Colorado to be 170 mrem.
(5) The section pertaining to notification of the public by means of a siren fails to identify the specific siren signal to be utilized.
a
1
. (6) It would be desirable to provide instructions on the cover of the brochure which instruct the public to' retain the brochure (e.g. by clipping it in the telephone book).
It would also be desirable to print the map, routing instructions and the information in the sections on notification, sheltering and evacuation on a page in the telephone book.
The Staff finds it appropriate that the next scheduled revision to the eiaergency information brochure incorporate comments (3), (4),
(5) and (6). See also the response to Question 7.
Q.22.
FUA Contention 10 asserts that the applicant, State and local plans have been formulated without reference to the Supplement to the Draft Environmental Statement (NUREG-0534) and thus fail to address appropriate protective measures needed to provide radiological protection to all residents in the vicinity of the Summer station who might be threatened with injury or death from an accident greater that a design basis accident.
Does the Staff have a position on this?
A.
The applicant's emergency plan has been formulated to incorporate the joint NRC and FEttA guidance set forth in NUREG-0654 and to comply with the requirements of 10 CFR 50 and Appendix E thereto.
The attached figure (Attachment C) shows results for the Summer site plotted on Figure I-11 of NUREG-0396. As indicated in NUREG-0396, this figure formed part of the basis for the size of the plume exposure emergency planning zune which was subsequently made part of the Commission's regulations (10 CFR 50.33(g) and 50.47(c)(2)). The
- doses indicated are for the cloud centerline location as a function of distance. The unplanned evacuation case from NUREG-0396 in Figure I-11 assumed that, even without formal plans, action would be taken to relocate individuals from areas of high ground radiation (resulting from cloud deposition of fission products) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of cloud passage. No movement of people was assumed before that time. Two cases are plotted for the specific meteorology and power level of the Summer plant, one for 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ground deposition exposure and one for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ground deposition exposure (leaving individuals in a high radiation area for many hours is judged highly unlikely).
The Summer cases were prepared using the same numerical techniques as for the Draft and Final Environmental Statements.
The figure in Attachment C illustrates that the part of the rationale of NUREG-0396 relating to high consequence accidents by which the emergency planning zone size was determined at about 10 miles is consistent with similar calculations made specifically for the Summer site within the same probability range.
c As indicated in the FES, it is possible to calculate numbers of fatalities or early injuries at distances substantially greater than 10 miles from the plant. This is considered so unlikely as to not warrant specific emergency planning measures.
Q.23.
FUA Contention 11 asserts that the applicant and the surrounding counties do not possess the experience and technical ability adequately to plan for emergency preparedness, to prepare for a radiological emergency, or the capability for implementing
17 -
protective measures based upon protective action guides and other criteria as required under NUREG-0654, Rev. 1, at II.J.9.
Does the Staff have a position on this?
A.
The flRC has upgraded its emergency preparedness regulations in 10 CFR 50 and Appendix E thereto in order to assure that adequate protective measures can and will be taken in the event of a radiological emergency. As provided in 10 CFR 50.47, no operating license for a nuclear power reactor will be issued unless a finding is made by NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. The NRC will base its finding on a review of the Federal Emergency fianagement Agency findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the applicant's emergency plans are adequate and capable of being implemented.
The staff has reviewed the applicant's Emergency Plan against the criteria of NUREG-0654 and documented the evaluation in the Safety -
Evaluation Report, NUREG-0717 Supplement No. 2.
The staff concluded that the applicant's Emergency Plan, upon satisfactory completion of those items for which the applicant has made commitments as identified in the Safety Evaluation Report, Supplement No. 2, will provide an adequate planning basis for an acceptable state of emergency preparedness and will meet the requirements of 10 CFR 50 and Appendix E thereto. The final NRC approval of the state of
1 -
emergency preparedness for the applicant's site will be made following review of the findings and determinations made by FEliA on State and local emergency response plans, and review of the joint exercise held to demonstrate the capability to implement the applicant, State, and local plans. The NRC evaluation of the emergency exercise dispels the notion that the Applicant does not possess the capability to adequately prepare for, and carry out, its emergency planning responsibilities in the event of an emergency at the plant.
See I&E Inspection Report No. 81-09, dated llay 26, 1981 (AttachmentD).
Q. 24.
FUA Contention 13 asserts that the NRC and Applicant have failed to comply with the requirements of NUREG-0694 that 50 thermoluminescent dosimeters be placed around the site.
Does the Staff have a position on this?
A.
The guidelines of NUREG-0654 state that approximately 50 TLDs should be placed around a plant site.
See separate testimony of Edward F. Branagan. TLDs are not relied upon to provide the applicant's emergency operations personnel with information by which decisions are made regarding the health and safety of the general public under accident conditions. Measurement of offsite radiation levels (e.g.
monitoring teams with portable detectors and the reading of prepositioned TLDs) are confirmatory actions used to supplement information available onsite.
Decisions regarding protective action i
recommendations for the public are based upon existing plant l
l
- conditions taking into account potential or projected offsite consequences which could result from such conditions. Specific plant parameter values and effluent monitor levels must be used as Emergency Action Levels which trigger the declaration of emergency classes.
Appendix 1 to flVREG-0654 sets forth the criteria and basis of the accident classification scheme and Emergency Action Levels.
Using this system, the various plant conditions are classified based on their seriousness and the potential for offsite release. This system provides for notification for minor events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized. A gradation is provided to assure fuller response preparations for more serious indicators. By classifying each potential accident into one of the four classes, flotification of Unusual Event, Alert, Site Area Emergency, and General Emergency, and by identifying various instruments and radiation monitor readings and alarms which correspond to accidents or occurrences in each of these classes, accident recognition and classification is enhanced.
A.1 Corte-:icn 7
.ne Emerge *.:y sponse r.,ans c. :,.e.::,;:ar.:s, :.e s;- cu.:ir.;
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a.oun'.ies, and *".e.C***e o#. S o v '. ". "..* * - l i n a *..* "..- *. a, r.. #. - :. ****-.**.:.
assurance that adecuate prote::ive reasJ'es Ca. 2*:
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"e*:s of NUO.E3 0654, Rev.1, in t*.at:
al
(**. 3.1.) The Applican's Dia" C:i! n : ree tre -ir.i
" sta#fi".;
re:uire e'. s as set forth in Tatie E-1.
b)
(.E.9.)
The Applicants's plan inciv:es a;*se ee.:s w' a 10 :a '.
crgani:ations.hich fail to delineate the au n:rity, res::nsiri'i:ies, ard lirits :*. t eir a:: ions.
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'.'.'..:. '. ) '. ne Appl i c = n 6 s h.a ve.
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com ve :a:i:rs centers, within 15 rir.utes.
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(.':. 3.1. ) The Applicar.:s have n: a:e:.a:ety :la-ne:-#:e -e c1str10.:icn or informational cateria3.s.
e)
(:I.J.E and Apoendix :.) ine ::lica-: has n:: cese:::e: -e.
alis:i: esticates of evacuaticn tires and has no: e:' eyed tr.e me: :-
dology se: forth in Appendix 4
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rear.s fcr erote::ing tnose whose la:i e'
- ility is ir:ai-e: ty 15:.
of vehicles.
g)
(II.J.10.e.) No plans have been mace for the cistritation ar.d use of radiopre:ective drugs, su:b as Potassiu-Ic:i:e,.as a
- rete:-ive
- esponse for the general publi:.
A-2 h)
(II.J.;.h.)
- ele:ation ce.ters are not le:ated at less: 5 miles from the ciure Essesu e Patnway EP2, e.g., k.'innsb:-o Hig. Sch::1 is a scant 2-3 riles fr:r the E:2.
All of tne relo:sti: cen:e-s in
~ airfield Cour::. are witrin 12 riles of tne E':.
i)
(II.J.'.;.)
Ta:ie E.2 in A::licant's Oian su;;ests :ma: s e:-
e teeing is the :nly :*::e:: ve A::icn cor.terciated for tre ;e e a lic.
j)
( ( ! !. J.13. '4. ) Tne plans do not set for:n the beses #0- :ne encice of recorrended Protective Actions from the plure ex::sure :a: -
way during ere gency cor.ditiens.
k}
(!I.L 1.)
Hestita'. and redical servi:e5 for : e ;e e a* :.:-
lic are net pr:vice: fer.
1)
(II.L.2.) Or-site e ergency first aid catadili ;. is i a:e:.a:s.
e)
(II.3.3.t.) The News P.ecia Cente-is ne locate: a tre
- ::li:ent's Ere ;ency Coerations facility.
n)
(I!.:.2. ) The Interie Emercency Operations facility ::es t
corrly with the re:uirerents of NL' REG 0696, Rev.1.
n)
(Appendix 2.) ine Apolicant's meteorological monitorin; e:;i -
re r.: does not rest the re:uirerents of Accendix 2.
It la:is a via:'e ba:k-up syster with erergen:y power and is not seisrically 0,a'd #ie:.
o)
(*ppendix 2.B.2.)
Tne :colicant has failed te dencnstrate r
I tnat its siren system will reet the reQairements of Aprendi> 2. t.a:
the tests condu:ted by the Apolicant on audibility were su fi:'e :, a".d e
that the siren syste-to be installed has a hign level c' relia:i::.
I including under seismic conditions whien might occasien a rati:::;d:::
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A-3 e~ergency.
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(A:?e. ix 4.)
The A::licant has faile: to coroly with the recuirer.ents Of AL encix 4 for deterrining an: destricing evacuation tires, has # tiled t: establish tne accertatility c# trite-ia used to es*a:lis eva:uatior. tires, an nas failed to de.C s*"a'e *ne CaLabili-ty :# ;::li: art an: State and local governrer.ts t: assure tirely eva:u-ation art ' a :iden* OOncitions.
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A: licant's and local plans denCnstrate a la:k of co0peration in tneir ceveloprent and planned imolementation.
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The :lu e Ex00sure Fatnway E:: boundaries established in local plans are *:t tasa: ur:n reescnarle criteria which ha'.e been exclicitly
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and s:1ent-- :a,..y/ defensit,ie bases wnich cive reasons:,:e assurance
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y ex;cses siste-ts at Kelly Miller Eienentary Scheci anc Greentrier Head Start Center ir Fairfiel: County to unwarrante: risks to tneir health and safety.
- ) A9: in otr.er ways tne Radiological Erergency Peso 0nse :lans of the A::'.icant, the State of South Carolina, and tne surrouncing counties fail tc cor:ly with the re:uire er.ts set fortn t"e ein.
BASIS FC: CON'ENTION 7 Fetitioner and itsrerbers pcssess uni:ue knewlec;e of the pecole, roads, traffic patterns, and torograchy of Fairfield C:unty and nearby communities an: w ul: assist the Licensing 3:3-d ::
Jild - record on ta.e a:e:ua:y o# erergen:y Olannir; for the re; ion.
A-4 In a::iti:. :: tases t "e-e: in :ne state ent of tne Or.;e-icn, petitioner w ul: sr:w :.3 : (:ases are liste: by sut- 0ntenti r ie* er) a) A::Ii:a t's a: e 5.' se S f r:r. tna: A::licant woul: ce ur-able t: Cr:~.' e :a:i-u: s;;;;-: fer several functions witnir te re-
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postal heider.
a y rail addresses in tne area se ve severai n:;se-holds, sc tna; a single " Occupant" r. ailing to each pesial box w:.':
not rea:n e e y -casent!d.
Festing of informational materials ir loca'.
busir. esses wi n:: s.##i:ie-tiy su:oleren; inade:uate tailin;s.
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L' arra.;e ents ':- redi:a1 se vi:es at the inner ;dai: in ;3-,
Scuin a-:lir.a. an: Ri c r.l a r.: Ye :-ial Hespital in Colurcia, 50 :- Ca-:-
lina, a:: ace':1 a::iy Only :: e :loyees of :ne A;;lica-; an: r:: ::
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A::li:a":'s clar : alls fer only one person cuali'ie:
- i -s d-aid techni;ues en ea n s*.ift.
Iniury to that person er a::icer.: :O r. -
ditions re:ui de; #irst attention c accider.: con:rcl duties ::.1:
nullifj tr.a: cara:ili:y.
I n) Tne Inte-ir Erergency Operations facility is 1 cated
.-site.
The fa:ility is a te ::-ary office stru::ure whien is n:: enginee-ed for the design li'e cf the ;1ar., does not provide a pr:tectier 'a:::-
equal to or greate-than 5, ar.d lacks adequate ventilation pr :e::i:n as require,,1n,.....:::,.ev.
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All cerser.s in Fairfield Ceunty are ex:ected to eva:uate te Wirrs :r: Fish 5:hool. Under tyoical wird conditions, that would te tne least a;;rc;riate resconse for the rajority of persons in
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!' #ield C:Unty. Those in the scu he-n :a*: ef t"e County
.:.': te sa#er eva: Latin; ~ owarts the F.icnland County facility.
incse in t*e c.: - ser. :a-t cf tne E:2 woai: m re wisely eva:ua:e to tne Ne at e -.s
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No such cocr:ination exists, ho.ever, s ',
Yo r.; cersons are especially susceotible to radiatier. injury.
s n:v.s.er, the Flune Expesure Pathway EFZ, which extends to nearly 12 miles jus: ner:n c# Kelly Miller School in Fairfielc County, swings in to riss incis:ic; tr.at schoci in the E:2 by, cuite literally, "sncuting cista :e'.
Kelly Miller is an all-cla:k eierentary s:nocl.
The Green-c -sa: E:ar: Center is located nearty and also within view cf the E:: ta: n:: inclu:e: in it.
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F' 21 clans have not been available to etitioners from the f:;- cc.. ties and the State of South Carolina, i
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- ttentien E Public Infer ation Materials distributed by the Ap:licant relative reciclogi:al e er;e :y response planning are ina: curate, ir.:ea:ior. ally
- e:e:tive regar:te; the cotential health effects of radiaticn, at: :re-sert e.a:ue i:n routes whi:5 could result in persons unai::in; y e.atu-a:dn; inrea;h ne plu e.
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Tne trochure entitlec "V.C. Summer Emergency Inforraticr,' wr.i:n
- .e *:;li:ar.: says will be mailed to every househole in the Fiume Ex-c teway, in:ludes the following untruthful and inat:u-ate in': -
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- a: tre se:cndary water system in tne steam line is un::n:a-i-
- ate:'a: ": i'ution-free";
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- na: racia-ion nealth effects can only be dete::e: at leve'.s
- 25,00: milli-e s at: above.
Tnese state erts and additional verbiage in the br::nu-e are essi;ne: :: give residents a false sense of security.
By failir; ::
at:urately describe the genuine health hazards, which are re: ;ni:ed by
- ne bO:y o' :ne 5:ientific community, the Applicant may lea: resi:e :s
- teliese :na; a::idents with long-term health consecuen:es are n::
sv##i:iently important to warrant evacuation.
Further, the evacuation routes laid out in the bro:nure are ir-rational and could result in individuals unwittingly eva:ua:ir; :n-:v;n tne plume. A resider of Southwest Fairfield County (Zenes C-; and C-2) is directed to drive toa' arts Winnsboro, which is the dire::i:e ice :-e-sailing winds c vid be exce: ed to carry the plume.
A-7 Cee.:ee. tion 9
=
The State of South Carolina and the courties surroundinc tr.e Summer station do not have the ca:atility for i s'.e e tir; : rete::ive reasures based upon protective action guides and c 5er criteria as
- ney as ly to resicents of the Flu e Ex::sure Oa:naay wn: :: n: can or have access at all tires to criva e've.icles.
EASIS F00 CONTENTION 9 The area within the Plure Exposure Fa:hway is : eco-ir.ar.:ly rural and no public transportation system exists.
Many c' the residents of the area are old, sick, or poor and co nct have transo:rtation cr are wi:neu: transportation during signifi: ant eriods cf the cay.
Existin; plans in Fairfield County, for exanole, call fer t e use c' a' sc :el busses w en schoci is not in session, b) vans fror tne Coun:i1 cn A;ing e
and Com.ranity *ction Program, or c) city : asses br:v;*: in fe:r Colu tia.
5:hool busses in South Carolina are c-iven ey hi;r s: noel s acents.
If sent:1 were not in session, the crivers w uld nc be available.
The nur:ee of vans is limited and inadecuate.
The city busses frc-C01u :ia could net arrive in time, are unsuited to many of our coun ry roads, and would be driven by drivers unfamiliar with the many nocks anc crannies of the County.
Moreover, no door-to-door survey to identify the neet r.as beer under-ta l er..
fiewspaper ads were placed in the 'n'inr.sbor; pa:ers askin; cer:le who needed transportation to call the Emergency Fre;are: ness Dire::cr's office.
A good many people in rural Fairfi ld Cour:y de n:: read.
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A-8 Ocete-ticr. 10 Radiological Erergency Response plans of the Apolicant, the State cf South Carolina, and the surrounding communities have been formulated without referen:e to the Draf t Environmental Stater.ent, Supolerent (N.* E3 0i3 *, Sup lerent) and thus fail to accress a:Orcpriate protec-tive tensa-es needed to provide radiolocical protection to all residents in the vicinity of the Succer station who might be tnrettened with in-jury or death fror an accident greater than a design basis accident.
5 515 FDP. CO*4TE'4T10t; 1_0 During testimony before the ACRS Subcommittee on Electric Pcwer (r trun y 25,1921}, Ere gency Coordinator Ken Esale conce:ed that no e
re'e ence had been cade to the Draft ES in pre:arin; tne emergency plans.
Tne first ES wnich evaluates the environrental impec*s of a sc-called Class 9 a::ident, tnis Sucolement should have served as tne cornerstone cf e e gen:y clar.ning.
Instead, it was ignored.
m A-9 Contentice 11 The Applicant and tLe surrounding cour. ties do not possess the experience and te:hr.ical ability ade:untely to plan for erergency pre-paredness, to pre:are f0r a radiological e ergency, or the capability for implerenti.9 protective ressures base: uoen prote:tive a:tien gui:es and other criteria as re:uired under ti'JRE3 0552, Fev.1, at II.J.9.
EtS15_ FOP. CC'JEC10'; 11 The capability to plan and carry out protective measures in the ever.:
of a radi: logical er.ergency presumes the personnel with experience and training in erergency planning and an understanding of the characteristics of radiolegi:al e "luents and their potential health effe::s.
The *:plicart and the gevern ents of the surrounting cou. ties lack that ca:atility.
Corocrate Ere ;ency Coordinator, Ken Eeale, of the Acolicant, has training and experience as a Healtn Pnysicist. His resume reveals neitner training noe ex:erience which would cualify hin for his current position and rescensibilities.
His assistant, Site Emergency Coordinator, is totally lacking in any cualifications for a role in er.ergency planning or any training beyond a brief practicum on nuclear power generation at an eierentary level.
Fairfield County Director of Emergency Preparedness ad-its tnat he knows nothing about nuclear power or the health effects of radiation.
A-10 pe.' ale in western Fairfield Cour,ty read tre Winnsboro pa e's.
Ma*y people in the area co not have telephone, and for mary it is a long-cistance telean "e call :: Wi nr.s t:ro.
fio: surprisingly, tr.: ads crea no response.
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A-ll
- rtentien _13 ine NRC and the A:clicant have failed to comply with the re:uire-rent of NUREG 0634 (111.D.2.4) that 50 thermoluminascent cesitete-s be claced around :ne site in coordination with the State and the Applicant.
sn:vktbere:viredtodenonstratethattheseTLsare:a:able T e 5 n'#
- ' accurately reading Co**.
By themselves, the TLDs are n0: a:ecuate to revicing eree;ency operations personnel with the inforcation re:uired to c: rete.tly make the decisions required to reasonably assure the healtn a r,: sa'ety of the general public under accident conditions.
Real-time monitors capable of reading gamma radiation levels should be re:uired at
- ne sites wnere TLDs are currently planned.
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c: rcing :: the SER (NURE3 0717) at 22-99, the NRC will only pla:e
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Cn:er acciden; conditions, ILDs do not provide infornation :uickly enougn to ade:uately assist appropriate decision-making.
Only real-tire nonite-s tiec into the acclicant's DAMS system with monitors placed at nany locations and not just within 1,000 m. of the plant can provide those necessary inputs.
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Tild1AS A. K1VERil i
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II an a nuclea Tengineer in the Emergelicj Ity name is Thomas A. Kevern.
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Preparedness Licensing Brandi, Divi,sME. of-Em(ergency Preparedngs, 0ffice of ' s. _
3 Inspection and Enforcement.
Ia;rd posjtlon as Emuru.:ncy Preparedness Team 3...
l Leader, I am responsible for the review and ek,1;9*t'jon-ofiemergency plans j
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"yg ineeririg hdiee from 0hio State I received a Bachelor M' Indistrici Eng\\
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Ohio State Universitj 5E 1969.- %c$mp'le[hdhe' U. S. tlaty' nuclear power 5
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training prograra for commissiored office s in 1971.
Ireceivedafasterof i
Science Degree in Sp/.ms !!anagemtut frora the University of Scathern te
?x California in 1978., Additionallh I have Mapleted two tiRC coursy *.a the e
design and operatica-Of coramercial nuclear fhier plants.
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d-c I was e commissioned officer in the U.,S( jicvy frola December 1969 until p
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January 1975 a I received Ltitsiderable treining and experience in(Iii.
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>9 operation and supervision of r.d. fear power; plants and was qualified as Chief L
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I was the Divis.cM0fficer 05 several engineering divisions on.two
-U nuclear-powerer'osubuari,nes, responsibie-for tne operation and -maintenance of.,., -
1 thereactor'n<Jauppertsystemsand,i'6':thetr.Gai;s.andsqpervisionof a
,7, enginoccing igyst mel.. For three yea l yas directly.inv'olved in the l
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During ny last-r 4
}tdur in the flavy, I was a staff officer to the flavy's nanager.for
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aacquisition of nuclear pcwored attack subaarines and was responsible for r,
'n' h :,iseveral aspects of the construction and testing progren for new construction i['
nuclear submarines.
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'I' joined the ilRC..in January 1979 and, until June 1980, was the project l'
r canager for two operating nuclear power plants.
In this capacity I managed p
l the review and evaluation of safety and enviroaental considerations associated with the design and operation of these plants.
In July 1980 I.
was assigned my present position in the emergency preparedness organization.
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ATTACHMENT C i
i ie i i i s.
1, i i i sing i
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i i iising W
g 1 REM Q
>0 5 REM 8$
0.1 "i 9
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ob zm 5 lE U$ E 50 REM M8 O2 C 5 0.01 Summer 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 3 5 ground exposure
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200 rem Summer 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ground 5
exposure 200 rem 2
REM f
t 0.001
~-
1 10 100 1000 DISTANCE (MILES)
Figure I 11. Conditional Probability of Exce: ding Whole Body Dose Versus Distance. Probabilities are Conditional on a Core Melt Accident (5 x 10-5).
Whole body dose calculated includes: external dose to th2 whole body due to the pa: sing cloud, exposure to radionuclides on ground, and the dose to the whole body from inhaled radionuclides.
Dose calcubtions assumed no protective actions taken, and straight fina p!ume trajectory.
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