ML20055B122
| ML20055B122 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/16/1982 |
| From: | Christenbury E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Perry S Federal Emergency Management Agency |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8207200378 | |
| Download: ML20055B122 (5) | |
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July 16, 1982 Spence Perry, Esq.
Office of the General Counsel Federal Emergency Management Agency 500 C. Street, S.W.
Washington, D.C.
20472 In the Matter of CONSUMERS POWER COMPANY (Midland Plant, Units 1 and 2)
Docket Nos. 50-329 OL & OM and 50-330 OL & OM
Dear Mr. Perry:
A contention concerning emergency planning has been admitted in the Midland proceeding. Discovery is now being conducted and there are several inter-rogatories concerning this contention.
I am enclosing, for your information, a copy of (1) interrogatories which an intervenor has submitted to the Staff i
and (2) the contention upon which the they are based.
Since these interrogatories involve off-site emergency planning, they fall within the scope of FEMA's expertise.
In the past, FEMA has assisted us by providing us with responses to discovery involving off-site emergency planning. We would appreciate your assistance with these interrogatories.
We hope to respond to these interrogatories by the end of August.
The Staff presently plans to object to interrogatory v. and until such time I
that the Licensing Board determines that we must provide a response, information dealing with that question need not be provided. We suggest that a meeting of our respective staffs would assist in determining whether any -
other objections should be made.
It would also be a useful opportunity to clear up any questions that may arise from the interrogatories.
Our best estimate is that testimony on emergency planning will be presented in November 1982. After we have completed the discovery, we will be in contact with you to discuss preparation of testimony.
If you have any
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I questions or comments, please contact Staff attorney Michael N. Wilcove at 492-8579.
Sincerely, Edward S. Christenbury Director and Chief Counsel Hearing Division cc w/ enclosure:
Brian Grimes Robert Defayette Johnny Mathis l
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h Recently discovered information indicates that the Advisory Committee on Reactor Safeguards conditioned the acceptability of the present Midland site for the project
,on the existence of a highly effective evacuation system.
However, no adequate evacuation plans exist.
Aerial surveys of traffic conducted during the construction permit stage of these proceedings, and taken during shift changes, indicated that evacuation in an acceptable time cannot be accomplished.
Further, relying on the evacuation plans of Dow Chemical Com-pany is inadequate.
During the evacuation following the re-cent chlorine leak, evacuation procedures were chaotic and all communications weie either jammed or ineffectual.
In fa'ct, at an NRC conference held in Midland, Michigan on September 8, 1978, both the County Road Commission and the' Midland Planning Commission admitted that they have not considered evacuation routes.
As a result, the findines required by 10 C.F.R.
S 30.57 (a) (3) (i) and 5 50.57 (a) (6) can not be made.
28.
There' exists a serious water hammer problem regarding pressurized da er reactors of the Midland type -a7dd E
N involving a variety of com nents', some of which are critical safety items.
These safety re ated problems ha've been iden-tified by the NRC Staff as high p rity matters, both in
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NUREG-0410, "NRC Program For The Resol tion Of Genera 1 Issues Re11ted To Nucle'a'r Power Plants" (Janua,
1978), and the testimony of Staff witnesses M. 3. hycock,.
P.
- Crocker, and C.
O.
Thomas, Jr., recently presented in Pu lic Service
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Co. of Oklahoma, et al.
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Who were all the people involved in making this decision and in drawin up the May 25, 1982 letter to Mr. Cook ? Provide documentation that su tantiate the validity for coming to the decision that led to the May 25,1 82 letter to Mr. Cook.
ny members of the staff not agree with this letter? Who at(they?
- d. Did Document th r concerns.
4.
Contentions 2a and 21 on the nuclear fuel cycle and the lac' k of a method to store nuclear waste sh uld now be admitted for discovery since the U.S. District Court of Appeals struck own as invalid the S.3 Table (April 27, 1982) on which the NRC was relying for co.pliance with NEPA. I am resubmitting these issues in my amended list of conten ons.
5.
Contention 24 is now th basis for the on-going soil settlement hearings.
6 Contention 27 deals with the lack hf an adequate emergency evacuation plan at Midland.
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Questions:
a.
Who will decide when an emergency evacuation.is necessary?
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- b. The area warning sy, stem has frequently malfbetioned.How will people be convinced it is a real emergency ?
How high would radiation doses have to be before evacuation of a c.
10 mile zone is ordered? -
- d. Will the radiation dose limits for evacuation vary for men, women, children, pregnant women and infants ? In what way ?
When Dow had a major chlorine leak several years ago, all the-I e.
communications to the plant were jammed with people calling in or trying to call out. How v511 this be avoided if the Midland nuclear plant has an emergency ?
f.
Have parents been consulted about how their children should be taken care of if they are in school during an em'ergency ?
g.
During the Dow chlorine leak, people were driving into.the, cloud to look for their sick relatives, children and pets. Do the emergency
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plans allow for known human reaction patterns shown in past emergency situations ? What are these plans ? Provide documentation.
I h.
How much time does the safe shutdown of all critica! orocesses at 1
Dow require ?
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What protection wul tne wo,rkers nave wno.must stay, ouru g an er5iirge,ncy to complete the shutdown procesi?
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- j. What special training for an emergency will these workers have?-
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What guarantees do you have that they will stay as long as needed during an emerg'ency.?
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- 1. Will uncontaminated food and water supplies be kept available for-their use for several days in the event of an emergency'?
What are the host cities to which people in a 10 mile radius will m.
be evacuated ? Have they been notified and prepared foithis ?
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How will people who do not understand the English language be n.
notified ?
How.will people in nursing homes be evacuated ?
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How will people in hospitals be evacuated ?
q.
How will people who do not: own cars be evacuated ?
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How many_ beds for treatment of radiation poisoning does the Midland r.
Hospital have? iay City General? Saginaw General?
- s. What plans are in place to deal with changes in wind direction after I,
evacuation has begun ? How will people be notified of this change ?
t.
Are there segments of the population for whom no evacuation' plans
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can be made? Who are they ? Why can't they be evacuated?
l The NRC says there could be radioactiv,e fallout as far as a 50 rnile u.
radius. What prdtection will there be for residents beyond a 10 mile radias ?
Have their officials been included in the emergency planning process ?
Homeowners insurance policies specifically exclude coverage f r o
v.
1 loss due to a nuclear accident. Will homeowners be able to recover their' "
s losses from some other source, since the area could be uninhabitable for' l
t decades ?
7.
Contention 28 deals s th the water hammer problem of pressurized water reactors of the Midland type, his problem is identified as one o.f the unresolved safety issues applicable to Midla. d I & 2 in the SER, C-4.
l Questions:
a.
Since other reactors re now operating without having this p'roblem p
k fesolved, would failure to hav this problem resolved be sufficient reason l
l not to approve an operating licenje for Midland 1 and 2?
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