ML20058G668
| ML20058G668 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/29/1982 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| References | |
| ISSUANCE-OLA, NUDOCS 8208030388 | |
| Download: ML20058G668 (7) | |
Text
,
July 29, _)S2 p
DOCKET,ED UNITED STATES OF AMERICA USNRc NUCLEAR REGULATORY COMMISSION BEFORE TILE ATOMIC SAFETY AND LICENSING BOARD' ORANCH,$'c Y
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It. the Matter of
)
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Docket No. 50-155-OLA CO2SUMERS POWER COMPANY
)
(Spent Fuel Pool
)
Modification)
(Big Rock Nuclear Power Plant)
)
INTERVENORS PRO' POSED FINDINGS OF FACT AND CONCLUSIONS OF LAW CN CHRISTA-MARIA CON'I'ENTIONS 9 (4 ), 9(5) and 9(7)
Intervenors pursued three contentions that were concerned wi'.h emergency planning.
Two of these contentions assert that current lists of invalids in the area need to be kept and that Licensee should assist in the evacuation of such persons.
Christa-Maria Contention 9(4)
Applicant should be required to assist persons without vehicles to leave the area during an emer-gency evacuation.
Christa-Maria Contention 9(5)
A current list of invalids should be kept so that they can be assisted in times of etargency.
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Te third contention asscrts a necc for a change in h
Applicant's plan so.that in relies upon adequate personnel.
l Christa-Maria Contention 9(7)
Applicants emergency plan should be revised so that it relies on pecple who exist and have been properly identified and so that there will be adequate co-ordination among responsible personnel.
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Accisting Persons Without Vehicles and Invalid Lists
- 1) The Carrent Energency plan calls for the use of school and church buces for tne evacuation of invalids and persons without carc from the area.
- 2) Thece buces have a prinary connittnent to renove school children from the area and would return later for other persons.
- 3) There are approximately 24 bucos, 2 vans and 3 cnall buses and only five drivers trained in energency procedures. (Benent I 1481)
The official of the Federal Energency Planning Administration (F2A) responsible for Charlevoix County in Mr. Benent. He ic A
Unaware if any bundrivers are trained to handle invalids.
(Benent T. 1501) 4)
Mr. Benent is also unaware of how long it would take the busec to v.
nect the prinary obligation of noving school children and when the bucca would be available to trancpcrt invalids. (Benent T.1484)
There has been n; analycis as to the distribution of invalids on the lict and therefore how long it would take to pick up these people.
(Ecnont T. 960)
- 5) The cheriff naintains a lict of invalids for purposes of evacu-i.
ation. An individual enrolls him or hercelf on the list.
The nothod of informing the public about the list and enrollnent has been through the energency panphlet or after seeing a newspaper ad.
Adverticonente have been run la the paper in April of 1980 l
and the spring of 1982.
Mr. Benent accunec a high nunber of the local pernanently dicabled persons are enrolled baced on the idea l
that door-to-door panphlet dictribution occurred. (Bonent 2. 964) 5 5)
It ic uncertain if bus capacity matchec the attendance at the local schools. (T. 1483) l
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- 6) The adterticcmenta for enrolltent were run in the apring when the largo numbarc of,trancients were not in the arca.
(Eement T. 834)
- 7) In addition to invalids and perconc without trancportation,
" group two" persons at local hospitals (not needing ambulence care) nay also need to use the bus cervice in order to leave the
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area. (Benent T. 965) a) Ifapersonistemporarilydicableditisaccumedthatc/hewill l
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remember the newcpaper adc and call the Sheriff's office or call a number to be announced over radio and television during an i
I emergency. There la currently no method of ascertaining the I
I number of temporarily alcabled persona or of informing such persona l
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of what to do, i
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- 9) There ic no opccific phone number assigned to the caer6cncy phone t
I tanks, no there in no cuch number in the pamphlet or in the phone l
book. (T. 394-696) l i
I DISCUSSION j
It in clear that the local officials have no clear idea as to wnat f
l the transportation needs in an caergency will be.
From the record, it i
appearc that the individuals in charge of planning have no idea how l
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many school children there are and in the busca reet transportation i
f needs.
It is highly lik'ely that a large number of local children It is also h1 hly likely that Charlevoix, like nany walk to school.
5 school dictrictc, may run the buscs in shifts or use the same buson for grade and high schoolc in order to keep the nunber of buses at a minimum.
There has been no thorough investigation to find out how i
many additional people there may be who need assistance in leaving the area. These others would include " group two" hocpital patients, I
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'"tenporary" invaliac and perconc without cars. It is forececable that not all tho schoolchildren could te noved in one trip, which wculd
'I Creatly change any current evacuation time projections.
There are only five bundrivers trained in emergency procedures.
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Many of the drivers, cuch ac the chrrch bundrivorc, are volunteers.
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)i It is foreseeable that an untrained driver may beccae frightened, ac anyone in the general population wculd, and leave the area ircodi-ately or refuse to make multiple trips into the emergency area.
.s)l Untrained drivers who do return tc the energency area will be exposed
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i to higher levels of radiation without being knowledgable as to the
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f rickc involved. There is also the chance that an untrained driver may i
I inadvertant1: injure an: invalid due to lack of knowledge on how to handle such a percon.
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In addition, local officialc rely on the idea that there will be 1
electricity during an energency no that personc may obtain energency phone numbers over the radio or television.
Inplicit in this plan is the iaca that all persons in the locale own radios and televicions.
There is a sizeable population of Native Anericans in the EPZ who do not.
i The area around the plant has extensive tourism in the sunner and I
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winter months. Thero needs to be a nothod of informing transients i
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(such as the pamphlet) as to what should be done if one is tenporarily dicabled, such ac regintering with the Sheriff's office.
The adc for cuch registratien were run in the off-acason for tourica.
j Mr. Benent of FEMA believea that the enrollnent of invalide with i
the Sheriff's office is a large percentage of the local permanently I
disabled persona based upon the assumption that the emergeny planning i
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panphletc were distributed dcor-to-dcor. Ac Intervenorn indicated in i
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earlier findings of fact, the panphletc were not distributed door-to-I i
door to arca residentc. No curveys or follow-ups were taken ac to the 1
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l minbcr of invalidc in the area, no currently there is no way of knowing-l
' f the lict in an accurate representation.
i s
For the above licted reaconc, Licencoe's application for a spent I
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fuel pool expancion chculd be denied due to current inadequacica in enercency planning whi,ch would only be exacarbated by cuch an i
l exiancion.
If the application ic not denied, conditionc chould be impocod j
to a) requiro Licencee to train or acciat in the training of bus I
drivers. Thic training chould be r.andantory for the drivers and should cover both energency procedures and the handling-6f invalido; b) a phone nunber chould be accigned to the energency operations conter and be publiched in tne next pamphlet; i
c) there should be como method of inforaing temporarily dicabled personc of enrollnent, cuch ac tnrough bullitens to local doctorc and health care agencies.
L d) a determination must be made as to the number of people needing trancportation for evacuation.
Thic chould not prove too Lurdencono as many of ther.;e figures are available through the school district, hocpitalc, nurcing honen etc.;
e) Licencoe chould accist the local area in nocting these conditionc.
It in obvious tnat the local con:aunity ic ceverely lackins in the recourcec necescary to conpleto adequate caergeny planning.
It c the daty cf Licencue ac beneficiarien of the plant and an a recpon-cible party for oncrcency planning to accict in thic endeavor and incure h
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I that it ic dono properly.
Respectfully cubnitted, f
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i dortort Sennel Attorney for Intervenors l
Chricta-ihria, Killa and Bier Anticch School of Law 2633 loth Street !;.'J.
I
'Jachington D.C. 20009 j
1 I
I hereby certify that the foregoing Findingc of Fact were cerved on the attached list by U.S. mail, postage prepaid, first class on the 30th day of July 1982.
(
bu. k)d /o u Denice L. Wiktor Legal. Intern Antioch School of law 4
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