ML20058J738
| ML20058J738 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/06/1982 |
| From: | Aamodt N AAMODTS |
| To: | |
| References | |
| ISSUANCES-SP, NUDOCS 8208110192 | |
| Download: ML20058J738 (7) | |
Text
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UNITED STA TES OF AMERICA NUCLEAR REGULA TORY COMMISSION
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BEFORE THE A TOMIC SAFETY A ND LICENSING A PPEAL BOA RD
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'p, pM In the Matter of METROPOLITAN EDISON COMPANY
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Docket 50-289 SP T
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(Three Mile Island Nuclear
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Genera ting Station, Unit 1)
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AAMODT COMMENTS CONCERNING NEW INFORMA TION PROVIDED BY THE LICENSEE AND STAFF IN RESPONSE TO THE APPEAL BOARD'S ORDER, JUNE 29, 1982 In response to the Appeal Board's June 29 Memorandum and Order, the Aamodt Family submits comments as follows:
(1) with regard to the revised PEMA public information edcuational phamplet (2) concerning the' agricultural ' fact-sheets' and emergency planning for the farm community (3) observations relative to thbse issues with regard to Licensee and NRC management integrity.
L1)
The PEMA public informa tion /edeuational chamelet.
The revised (vndated) pamphlet entitled Emergency Information -
hha t You Should Know About Nuclear Power Plant Incidents reflects a positive response to cany of our concerns with the earlier version.
As the Board will recall, our principle call was for candor.
We argued that any overt attempt to engender complacency 4
was clearly contrary to the public interest.
Although we find the brochure much improved, as evidenced by the deletion of the particularly odius parallclism between ionizing radiation and sunlight, several departures from this standard (candor) remain to render the brochure inadequa te.
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The tenor of the Board's questions at the June 24 hearing suggested that recommended substitive phraseology would be helpful where we find the wording of the pamphlet inadequa te 1
or inappropriate.
In response,' we note the following deficiencies in the revised pamphlet and, where applicable, suggest substitive phraseology:
(a) Lt. Governor Scranton's letter. Daragrath II Where the Lt. Governor states that " positive measures are available for their safety if an accident should occur" (emphasis added), we would submit that it is not possible to assure the safety of all residents in all postulated accident scenarios.
Therefore, this phrase should read,
" protective measures are available to heln assure their safety".
(b) The section " PURPOSE OF THIS BOOKSETf'_
This section is not correct in content.
It is "
not "about nuclear power plants".
It is about nuclear power plant incidents.
It does not "(tell) what the effects of a nuclear power plant incident could be..." in a complete sense, at all.
It does not discuss in any detail the kind of effects described in Nuclear Reactor Safety studies, Wash 1400 for example.
We would suggest that the existing paragraph be replaced with the following:
"The purpose is to provide information which will be important for you to know in the event of a nuclear power plant incident.
It tells what the effects of such an We are not able to include page references to the transcript.
1 The transcript was not supplied to us.
It was not available at the Free Public Library of Philadelphia, a repository of the TMI restart proceeding,as of August 3,1982.
,_.n incident could be up to the time ovacuation might bs necessary and what you should do to protect yourself."
(c) The section entitled " WHA T IS RADIA TION" This section is acceptable in its revised form except for one statement.
The last paragraph reads (in part)
" Radiation doses of about 350,000 millirems in a short period can cause illness or even death if no medical care is received."
This dose can cause illness and death whether or not medical care is received.
Therefore, the. phrase "if no medical care is received" should be deleted.
(2)
The Commonwealth 's agricultural ' fact-sheets '.
We have not yet received the agricultural ' fact-sheets' which will, in effect, comprise the emergency plhn for farmers.
Contrary to the implication of the. Commonwealth's response of July 13, we trust that these fact sheets will be provided for comment before distribution, particularly in light of the Appeal Board's willingness to hear our arguments regarding the content of the ' fact-sheets'.
We urge that.the A ppeal Board submit the ' fac t-shee ts ' to a panel of practicing farmers and veteranarians to gain concurrance in a judgement of adequacy.
Failing such a concurrance, we urge the Appeal Board to direct the development of a suitable plan, structured on the input from the same agricultural group, We request that the Board direct that the Aamodt family be party to the selection of the agricultural panel and the deliberation in which the panel would be involved.
111 Concerning Licensee and NRC management inteerity.
We note with alarm that an essentially acceptable i
+
educational pamphlet could ba produced so promptly af ter oral arguments before the Appeal Board.
While the Licensee and the Staff were defending the earlier version to the letter, even before the A ppeal Board, they were, in private, making the very changes they objected to so strenously in the proceeding.
The revised vercion could-not have issued so promptly if this were not the case.- We can only view this attitude as harassment of intervenors, waste of taxpayer and ratepayer dollara and disregard for the appeal process.
We further note, with dismay, the arrogance of Licensee in stating that it will distribute the pamphlet to the public absent review by the A ppeal Board.
(Licensee Response to Appeal Board Order June 29,1982, dated July 9,1982), mocking the appeal process.
Licensee cannot justify this action on the basis that distributi,on was essential to assure public health and safety upon restart; the delay a ttendant to steam generator tube repair alone provides more than adequ' ate time for review and modification prior to distribution.
We reflec c with dismay on the incident during oral arguments where Licensee 's a ttorney lied.
(See Footnote 1.)
Were this an isolated case which could even remotely be ascribed to misunderstanding, we would make no comment.
However, this incident is demonstrative of a pervasive fault in the proceeding, at the very least in the course of the litigation of our contentions.
Licensee, Staff and the Licensing Board have found as a single party on notification, the educa tional pemphlet and emergency planning.for farmers.
Not once has the Staff or the Licensing Board departed from Licensee's view.
Confronted with the clear evidence of the record (particularly in the case of emergency planning for farmers),
the Staff and Licensing Board
promote Licensee's unsupported views.
Why this solid front of opposition?
Is it a conscious effort to subvert the process of public intervention?
It seems odd that we must persevere because NRC fails in its duty to serve The interests of the public.
This seems Additionally this perseverance has cost us dearly.
unjust in view of the mandate of the NRC.and threatening in view of the number of reactors within 50 miles of our residence.
We cannot help but conclude that the fears expressed in the i
l Rogovin report are indeed valid:
that the NRC does not function as a regulator in the public interest but as the handmaiden of Our concern deepens when we view the the nuclear industry.
Commission's Order of July 16, denying the Appeal Board jurisdiction in the matter of generator tube repair and the Who will defend the public 's evaluation of feedwater spargers.
interest?
The Commission is satisfied with NRC review whereas-we have experienced NRC review to be uhcritical or absent.
In the final analysis, however, the principle issue of I
the proceeding, pervading all'other issues, is the integrity of Licensee's management.
All mechanical deficiencies can be ' fixed' if they are acknowledged.
Proper training programs can be implemented'if they are adequately defined and hor?stly Suitable emergency plans can be drafted if the I
managed.
And requirements for protective action are candidly defined.
these emergency planc will work if they are managed by personnel of integrity.
If, however, Licensee is more concerned with its public and investor image than its performance and the NRC is m]re concerned with keeping the nuclear industry placated than with public safety, the population. surrounding TMI is in real jeopardy.
The integrity of Licensee and the NRC alike is the principle requisite to safety.
If assurance of such integrity I
does not issue from this procee. ding, we shall all have failed in our duty.
We urge the Appeal Board to address this larger issue in considering our appeal.
We have perused the two documents provided by the NRC in response to the Appeal Board's order.
We cannot determine l
whether the NRC has provided information would appear to modify our arguments before the Appeal Board.
The time available has not been sufficient to do more.
We have Also been involved with another matter (B~oard's Partial Initial Decision, July 27, 1982) for the past week.
We,. stand by our views as expressed to the Appeal Board in our written and oral, arguments except as modified by the comments of the present document.
Respect ully submitted, l'l.
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Norman O. Aamodt O
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UNITED STATES OF AMERICA NUCLEAR REGULA TORY CCMMISSION BEFORE THE A TOMIC SA FETY AND LICENSING APPEA L BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket 50-289 SP
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(Three Mile Island Nuclear Generating Station, Unit 1)
)
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uW. ICh, This is to certify that the document AAMODT COMMENTS r
CONCERNING NEW INFORMA TION PROVIDED BY THE LICENSEE AND STAFF IN RESPONSE TO THE APPEA L BOARD'S ORDERf ~ ~ 7 JUNE 29, 1982 have been served on he followin parties by deposit in U. S. Mail, first-1 ss, Augus; g,1982.
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A tomic Safety & Licensing A ppeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i~
A tomic Safe ty & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i
George F. Trowbridge, Esquire s
l Shaw, Pittman, Potts & Trowbridge l
1800 M Street, N. W.
Wa shington, D. C. 20036 l
Robert Adler, Esquire 505 Executive House, P.~0. Box 2357 Harrisburg, Pa. 17120 Mr. Joseph Gray, Esquire Executive Legal Offices Nuclear Regulatory Commission Washington, D. C. 20555 Secre tary, U. S. Nuclear Regulatory Commission Attn:
Chief, Docketing & Service Branch Washington, D. C. 20555 i
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