ML20083M087
| ML20083M087 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/12/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404170463 | |
| Download: ML20083M087 (25) | |
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2 DOCKETED UNITED STATES OF AMERICA MC April 12,1984 NUCLEAR REGULATOBY COMMISSION
'84 APR 17 A10:47
, BEFOREWHE ATOMIC SAFETY AND LICENSING BOARD
- ," J Glenn O. Bright Dr. James H. Garpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant,
)
Unit 1)
)
ASLBP No. 82-1568-01
)
OL Wells Eddlenan's Contentions on the Energency Plan (2d Set) l These contentions are filed pursuant to extensions of tine and are thus tinely filed. Eddlenan contentions 2, 29D, 30 (part), 56,57,63,81,88,97,99,100, 103, 117, 118, 121, 124, 137, 139 and 140 were deferred to the Energency Plan stage.
These nust now be subnitted as is, revised, or withdrawn. All those for which revisions are not submitted herewith I an submitting %MW Wedetc & sca, as is for rulings.
GeMdc 5 factws t%rallow Dokn1<,,u' INd 2DnoGp 3 tereb,)92r41e I
Revised Contention 2r Because the plan allows offsite radiation release l' l(
before a general energency is declared (Iten 4.b, plan Part 1 p.32: cf Figure fI P.33 9 (cited in part 5 IV.A.5 p.32 ibid), top row,pW" site energency")m and does 4
not begin to study evacuation feasibility until a general energency in which radiation release nay be inninent (Iten IV.A.h.c ibid; conpare row 2 of fig. 9 (pt 1 p.33) under " General Energency": loss of 2 of 3 fission product barriers
- C cNc.f C Sta tI, h5 T cab "(posil C Acg kgg with loss of third barrier inninent"), evacuation cannot be ordered soon enoug l
h x to protect the public. This violates the requirenent o Q' g 06 g g 1 12 IDg (State and/or Local Offsite Authority Actions) iten 8 to Aassess protectkve acNons.
g Revised contention 30:x The plan's provisions (Part 1 pp 49-50)
I to 4
pg for procurement, storage, distribution and decisions to distribute Potassiu-M Iodide or other radmiological protective drugs do not comply with the requirements cla.o approved by Applicants' attorney Baxter, Staff counsel Earth, with the knowledge of the Board and the agreenent of Judge Kelley (for April 9) and apparent consent of Judge Bright on April 9.(when Judge Kelley was unavailable).
~
dSO,1
. of NUREG-0654 II.J.10.s (pg 63) that the plans must include " quantities, storage, "irt.ediate and means of distribution" for persons whose evacuation may be infeasible ofr rebt very difficult" who are in the plume EPZ. The plan gives no qua'ntities, provides no means of distribution, and permits up to 30 ninuts delay (item 7.c.1 thru 4, pgs149/50) in the decision to distribute these drugs.
Revised contention 30A. The plan's provisions for procurenent of radioprotective drugs do not specify the drugs or the quantities thereof (see Part 1 pp 49-50), andx do not identify those persons whose "immediate evacuation may be infeasible or very difficult" nor does the plan specify how radioprotective drugs would be distributed to such persons. The only locations of drugs identified are the County Health Departments (plan, p49, iten All these failures violate NUREG-0654 II.J.10.e (p.63)M*di8N'$evised 6a).
contention 30 above.
Revised contention 2A: The state and local governments must have independent monitoring capability for the Harris plant to meet the requirenents of NURE3-0654 Appendix 1 p.1-12 3d colunn, items 7 and 8 to " provide offsite monitoring results to licensee" et al and " continuously assess infornation from licensee and offsite monitoring" at the site emergency level. No such at capability is put into action in a site emergency untilt luzzi about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> i
after notification of site emergency (Plan pt. 1 p.39 iten 5b) There will be only 2 state teams until about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the accident (ibid). Accurate assessment of the plune requires independent fixed monitors around the site as well as mobile monitors (Pisello, et al, state that'to detect a release l
of a certain amount of radiation, at least 30 nonitors able to detect 10 of the release must be scattered within 10 miles of the plant).
New contention 206 The plan fails to provide for the sheltering and placing on stored feed of milk animals hi
) 2 miles of the plant fi 3d col iten 9, with in a site emergency, NUREG- 0654 Appendix 1, p 1-12, y -tat Ta1U2.L3-I e mvw '" p; pP assessment of need to extend-that distance,(ii) 10 miles of the plant in
/"I
$w a general emerkencylance. p.1-16, a 3d col iten lo, and assessing the need
[g ibid to extend tha dis
_3-GEERIc 5 factors for contention 206 and all other new contentions:
These contentions are timely filed under the Board's orders and extensions of time.
Therefore I don't think I have to address the 5 factors. but I will for safety's sake. Timeliness is OK per the above. So far as I know, no other party is pursuing the issues in these new contentions, and even if they do there There are is no guarantee the other parties' contention (s) would be admitted.
no other means to protect my interest. The thorough incompetence of the responsible state and local agencies is indicated by their massive failures CP&L to include required information in this plan that was served on me.
likewise appears incompetent (or in a rush) in serving a plan with so much There is no incompleteness and failure to conply with NRC requirements.
guarantee any of these parties will (that's the language of 10 CFR 2.714) protect my interest. Thereisconsiderablereasontodoubtgit.
I There is no reason why these contentions would broaden the issues, since emergency planning has been at issue from the start of this prosceeding.
The new contentions cannot delay the proceeding, since discovery has not begun, the emergency planning hearing is about a year away, and they were timely filed as noted abova. Without contentions, there can be no sound record on these issues. I have considerable knowledge of systems thecty and practice that is applicable to interactive systems like emergency plans.
I can do cross-examination and analyze plans and systems. From the plan as it now stands, it appears the state and county authorities have not demonstrated much, if any, greater capabilities in these areas. I!y nain concern is that if there is to be an operating nuclear plant here, near the State capital and many inportant facilities and institutions and near lots of people, the plan should work. It appears CP&L would accept just about any plan (this one is pretty atrocious -- so incomplete and full of NRC noncompliances) so they can't be relied on to develop a sound record.
Staff has a record of approving just about any plan also, so they can't be relied on. Only by critical examination of the plan can it be assured that it would work if it were needed.
l
4-
'Ihe above 5 factors would also apply to contentions 200 thru 205, previously filed.
Revised contention 57C: The prevailing winds fron Harris (i.e. the most frequent winds) blow past the plant in the general direction of Cary and Raleigh.
4 ER figure 2 3 5-3 (Harris site precipitation wind rose) shows the fastest wind speeds (10 mph) for the directions toward Cary (NZ) (NNE), with 9 mph in the direction of Research Triangle Park (N). NUREG-CR-2239 (p2 44 f1) shows that " worst case resultspor early fatalities are generally caused by rainout 4
of the radioactive plume onto a city further than 10 but less than 25 niles fron the reactor." Therefore the EPZ should be extended to 25 miles in-the N, IciE and NE sectors. Evacuation in such areas can significantly lower fatalities (NUREG-CR-2239, ibid; cf also pp C 4 and C-5 thereof: Harris mean early SST1 fatalities are 40 x P ; Indian Point, same case, 830 x P ; thus 1
1 the 42000 lives to be saved per p. 22 42, translate to ff!c "8 CE"7' i
X 80 1/26asmany,orabout1600 lives).
Revised Contention 57-C-2: Since the most frequent winds fro?. Harris 1
blow towards population centers (Cary, Raleigh) and a work center (Research Triangle Park) nore than 10 miles from the plant, it is appropriate to extend the plume exposure EPZ, based on these local conditions, out to 25 miles fron the Harris plant in the direction of those cities and the Park. NURE3-CR-2 2239, p. 2 42, shows that worst case results for early fatalities are generally causedt by rainout of a radioactive plune onto a city over 10 4
but less than 25 miles from the plant. Evacuation within 25 miles can greatly reduce fatalities in such a casa (ibid).
g c.Mb
$3f R
VWSW &t 00 O,f y&ss Wd% pmb43 (MCP'f0MbyRevised Contention 57-D-1.
Beoause the average Harris site wind
,g i
1 speed is about 7 7 mph (Harris ER, sec 2 3), even the unrealistically optinittstic evacuation ti~.es of Plan Fig.13 (Pt 1 p 51) in unrealistically good weather, the worst adverse weather biting heavy rain) at tir.es when people are awake, do not provide any meaningful possibility of evacuation.
E.g. the nininu:n evacuation time for a 2 mile radius is 1 hr 40 nine after notification. In t at" tine the wind (avg) goes 10 miles. Accord, fastest 5 and 10 niles evacs 2 hr 0 min. In that tine the wind (avg) goes over 20 miles.
. This violates 10 CFR 50.47(a)(1)'s requirement for reasonable assurance of NUREG-CR 2229 (p.7 43, Table 2 5-2) adequate protective measures wi31 be taken.
shows that evacuation can significantly reduce fatalities in a severe accident.
Similar logic applies to less severe accidents -- evacuation lowers exposure.
4 57-D 2.
The effective evacuation speeds shown in the Harris plan i
(Fig.13, page 51 of part 1) are, at naxinum,2 miles in 1 hr 40 nin (1.2 mph) i 5 niles in 2 hr 40 minutes 01.Cl nph), and 10 miles in 2 hr 50 nina (3,5 mph) under unrealistically favorable conditions (all people awake, weather good or, at worst, rain (HK: report on evac tir.es, p. 1-3 iter C)).
But NUREG-CR-2239 1
finds (p. 2 40) that an evacuation speed of at least 10 mph is required to avoid affects on early fatalities (i.e. increasing then). This plan is clearly inadequate to provide such an evacuation speed.
57-D-3, The palan does not assure that a plume of radioactive 1
material leaving the Harris site will be accurately located if the wind changes direction. A sudden wind shift could convert a narrow plume into a sweeping " flood" or " wave front" of radioactive naterial. That plan t
does not provide for wind shifts at any point I can find in it.
57-C-3 The plan does not have provisions for evacuation at night, e.g. in the hours between 1 an and 6 am when most people living near the plant would normally be asleep. Nor does the plan assure that they would i
be timely awakened to take sheltering action, as e.g. on a sunner night when j
many might have windows open or air conditioners on. The plan should provide i
auto?.atic phone-dialing equipment to transnit an emergency message to all I
households in the EPZ for Harris, asking people to alert their phoneless neighbors. Skh equipment is available according to Jesse Riley of Carolina Environmental Study Group. This equipment would also be useful in daytime i
evacuations.
l 57-C 4 The plan's provisions for ice, snow or fog are inadequate, i
t f
consisting as far as I can see of a one-sentence iten 8 on page 50 of part 1 saying that state DM and municipal public works departnents will be responsible
ir far clocring rsutss. This is a $ks. Tha equipmsnt is not idsntified ofr shown adequate to the task of opening all such routes or keeping same clear.
The location of the equipnent is not specified. Personnel availability for is these tasks aus not addressed. Yet snow, icy or foggy conditions could include substantial rainout or entrainment of the plume which would make sheltering less effective and efvacuation preferable.
57-C-5 Plan provisions for clearing debris, vehicle wrecks.
(e.g. fallen trees from a wind storm, tornado or other storm which nay have also caused or contributed to the accident, e.g. via Loss of Offsite Power)
{
are inadequate, see item 8, part 1 p.50.
No inventory of equipment, personnel, or estimate of time to clear sane, whether the equipment could reach places i
to clear wrecks or debris in the event of either a panicky or an orderly evacuation, is provided. The planning is clearly inadequate to accomplish the goal, and violates the requirement of NUREG-0654, item II.J.10.k page 63 to identify and provide means for keeping evac routes open, and to have contingency i
measures.
j 207 The plan makes no provisions for accidents involving radioactive material, including spent fuel, high level wastes, and" low level wastes" (which can contain highly radioactive material like CS-137 or damaged reactor control rods) in transit to or fron the Harris plant. Thus it doesn't adequately protect the health and safety of the public.
(5factore, see p. 3 supra) 57-C-6.
The plan, Part 1 p 625, gives an estimated maximu. response time of four hours (!) for the Harris E and E center to respond in radiological sampling. This is far too long. NUREG-CR-2239 shows that a j hour delay in evacuating nay not increase casualties, but longer delays will (p.?-43, Table PC-Gtovfe (/
2 5-1). It is not clear whether Duke University and 1 also have the four hour response time (estimated maximum), but UNC-Chapel Hill does, as does General Electric at Wilmington, which is a ?) hour drive fron Harris.
With a 7.7 mph average site wind speed, a radiation release will go 30.iles before a response from any of these labs is guaranteed.
i 57-C-7 The plan, Part 1 pp 66, 68-71, does not provide the plans of v'rious hospitals to treat radiation victims, can treat no more than 96 as palansstate,anddonotprovidefortrainingorprotectionofemergencyospita personnel transporting these victims to
/p l
-7 Quito obviously, more than 96 victins could be contaminated with radiation in an accident at Harris.
Cf. NURE3-CR 2239 p 2 43 data as adjusted per nunbers on pp C 4 and c-5 thereof (corrections for Indian Pt vs. Harris) gives Harris early injury figures about 5 51, of those in the tables 2 5-1 and 2 (ibid p. 2 43) or 200 or nore persons (except with evacuation to 25 miles,100 early injuries).
57-C-8.
The plan, p 68 (part 1) items 2a,c,d, and e are not provided.
Yet these are said to be standard procedures and reference naterials. The adequacy of the medical facilities in compliance with NUREG-0654 ite.,s II.10.
L.1, 3 and 4 cannot be evaluated without the information left out of the plan, as cited above. 'l\\t (W %
ESpDh tv/
p Q (['jk [0, ft 57-C-9 The plan for getting the SERT set up (pt.1, p?2) allows 2. or 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to set up SIRT and up to 7-9 hours to get a field command post activated.
These times are too long, since at TMI radiation releases occurred within 5 6 home
]
hours after the accident began and within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of declaring a general energency.
The state will not be able to rescond in a timely way to radiation releases, especially if time delays in alerting then to evaluate radiation releases are made (no alert til general e-ergency delclared, per pp II-34 and I-32)
This fails to comply with 10 CFR 50.47(a)(1)'s requirenent for timely action for taking adequate protective measures in the event of a radiological er.ergency and the requirenents of 10 ca 50.47 (a)(9).
57-e-10.
ne plan does not take account sufficiently of accidents P2-T:$[hs releasing groundlevel plunes or plu-es c r.ing rapid 1 to ground level A
(e.g.asatGinnain1982,NUREG-0909p.N)S&
EG/C8 223F ef
.A nversion conditions are g4 I
present about 50% of the tine near Harris. The plan (pt 1 p 45 and 50-5?:
Pt. 2 pp 29-30, pt 3 p26, pt 4 pp28-29, pt 5 p 31 ) provides no useful analysis or infornation on sheltering effectiveness; but without knowledge of sheltering effectiveness, the decision on that option vs. evacuation will be 111 informed and quite possibly wrong. The plan's discussion of protective actions is mostly i
a list of them and a little handwaving -- it's hopelessly inadequate.
57-c-11.
contrary to the plan s listing of adninisterin;; potassium a
l
. iodide as possible protective action for the public (part 1 p. 46 item 2 c 3).)
the plan makes no provisions for availability or distribution of KI to the or other radioprotective druCs public. This violates NUREG-0654 p 63 which requires KI for those "whose imnediate evacuation may be infeasible or very difficult". In a sheltering situation, that would be everyone. Delivery of KI through the plune wouldn't be ptactical. Tennessee (TVA) distributes KI to local residents nearN-plantsjHarrisshould.
57-C-12.
The plan's lists of protective actions (cited in 57-c-lo above) do not include elementary measures like breathing through a danp cloth or other filater, except for one county. This omission bespeaks a low level of senseand/orpreparednessand/orcompetenceanongplanners. It also violates 10 CFR 50.47(a)(1)'s requirenent for appropriate protective action to be assured.
In sheltering situations, actions such as breathing lthrough a filtering naterial are surely appropriate.
5;i7-C-13. The plan, in discussiing ptrotective actions, repeatedly refers to "the best Protection Factor" (PF) for sheltering. Yet it nowhere sets up criteria for identifying such protection factors or the highest PF in any structure (eg schools, hopspitals, prisons, day care centers, offices).
The highest PF areas need to be deternined in advance to conply with 10 CFR So.47(a)(1)'s require,ent for assurance of appropriate protective action.
If seeking the highest PF is appropriate action (as the plan states, Pt 2 pp29-30, pt 3 p 26, pt 4 pp 28-29, pt 5 p 31) then that action must be assured.
i 57-C-14. The plan is inadequate in its treatment of transport (pt 1 l
p 467,pt 2 pp 29 '1, pt 3 pp 27
'8, pt_4 p 29, pt 5 pp 3?-33 and the non-existent Annex I) and traffic capacities (pt 1 p 48) of evacuation routes, because it does not establish in advance pickup points for people without not assure adequato transport can get to these points transpor,
oe i
in time, and does not seek to identify in advance those without transport ~
and advise them where to go for pickup. The average person has no idea what
" nearest traffic control pointa is or where it is (pt ? p 31,3 p 28, 4 p ?9, 5 p 33)
Thus people wikthout transport are ddprived of acpropriate protective action violating 10 CFE 50.47(a)(1).
57-C-15 The plan as I read it has no provision for further transport of persons without transportation of their own. However, studies such as NUREG-CR-2239 assume that persons once moved 5 miles outside the evacuation zone "have means to avoid further radiation exposure". If these persons are taken to a relocation area or site (e.g. as schoolchildren) and have no further means 4
to move in the event of a radioactive plume coning to or over the site where 4
they are, they arenot adequately or appropriately protected (violates lo CFR 50.47(a)
(1)). Plumes can be very dangerous beyond 10 miles. NUREG-cr r2239 pp 2 49/43 2-74 57-C-16. The plan fails to meet the requirement of 10 CFR 50.47(a)(1) for reasonable assurance of appropriate protective action in severe accidents.
NUREG-CR-2259 (p. 2 48) observes "at short distances each of the seven scenarios (of Table 2 5 6, p 2 47) fails to provide sufficient protection for a substantial number of weather sequences" so that casualties stay high.
Using the 1/26 correction factor for Harris vs. Indian Poiht prompt fatalities (derived from pp C 4 and C-5 Py nultipliers and 900 vs 1120 L'e), this neans about 142 prompat fatalities for Harris (avg) and over 690 in the worst case.
Dead people are not appropriately protected.
57-C-17 The plan makes no prepared and clear prokvisions for protective actions beycnd 10 miles.. But NURIG-CR-2239 says(p.2-51) that protective actions beyond 10 miles can reduce peak early fatalities by about a factor of 10 and identifies 7 substantial inpact of e?.ergency response beyond 10 miles on peak early fatalities". The state of NC apparently takes a fatalistic attitude about such casualties; not plannaing for then vi&lates the Atonic Energy Act which places the protection of public health and safety above economic or other considerations.
57-C-18. The plan completely omits the Memorandum of Understanding between CP&L and the state. Filing of the plan without this important part indicates incompetence (or perhaps a desire to avoids making information available to intervenors) on the part of CP&L and/or the State of NC.
The menorandum is part of the plan and the plan isgot lete until a nemorandun in full compliance with 10 CFR 50.47"[NUnbgmoM3kthe Atom the
' Energy Act and all other applicable rules and regulations is incorporated i
45;8a.
57-C-19. The plan takes no account of rainfall distributions or intensities.
/ But NUREG-CR-2239, e.g. at page 2-9, says " washout of maaterial by rainfall is a very efficient removal metchanism (so) it is important to account for the frequency, intensity and spatial variability of rainfall" in modeling accident consequences for nuclear plants.
"High-consequences events",(lots of deaths) are associated with rainfall over population centers during nuclear accidents.
NUREG-CR-2239 observes. Without appropriate protective actions thought out and planned and operable before an accident, the public is insufficiently prostected from radioactive rainout, in vi&lation of 10 CFR 50.47 (a)(1).
Most gs to be used in the evacuation are two lane roads.
57-C-20.
(See ICE report on evac times, e.g Figs 5-1 and 5-2).
Under conditions of panic accidents can and will happen on these roads in an evacuation. Accidents will happen without panic also. The traffic carrying capacities of these roads have apparently not been assessed by the State. The only reference in Plan Appendix H to such 3
assessment is to Pt 1 p 48 which gives no analysis. NC 751, NC 42, NC 55, parts of US 401, 64 and 1 are 2 lane roads as are all state routes identified per that page. Lack of evaluation violates NU?23-0654 II.J 10.1 (approx p 61-65).
(NY3 all "57"63: contentions above are revised contentions)
Revised The plan fails to establish care for radiation victins on a m& bile basis, in terns of equipment, training, planning, staffing and assuring that staff for such mobile care will report and be continuously available during a nuclear accident. KobilecareisrequiredbyNUP23-0654Mik
!. c.M e
Revised 81. The Harris emergency plan has not been tested or otherwise fornally evaluated and shown to provide the assurance of appropriate protective action required by 10 CFR 50.47(a)(1). While NRC does not apparently require the plan to be tested before the plant operates, the State D8pt of Crime Control
& Public Safety has stated that it learns from each plan test and that a test of the plan should be made to show that it is workable, undeur 208. The darris energencymplan has not been tested ser adverse weather 4
e.g. snow, ice, fog, tornados or severe winds conditions or evacuation at the tines most people are asleep (e.g.1 am to 3
(
6 am). Even notification procedures have not been tested under such contritions.
TEhus the plan is a sham in terms of real problem evacuation conditions.
Sfagrs
209 The plan as filed does not contain the information asked for in conteintion 99 filed 5-14 82, with only a handful of exceptions. Thus the plan isn't proper for filing, and has failed to be sufficiently updated in its first version, violating 10 CFR 50 54(t) and 10 CE 50 Appendix E IV G and other rules and regulations including failure to fully comply with all require.ents of NURE3-0654 including those referenced in plan Appendix H which are mentioned or iinclude matters referenced in contention 99. Failure to produce this information knowing that a contention asking it was filed, would show incompetence by CP&L or the State.
(5 factors, p.3) 103 is submitted as is (note that all contentions for which no revised version (s) are given in this submission, have been submitted for ruling. None are withdrawn.)
210. I The plan (pt 1 pp 6163) fails to establish adequate decontanination or recovery procedures a to comply with 10 CFR 50.47(b)(13). This plan is not
" general" for these matters, but virtually nonexistent. The palan also fails to comply with NURE3-0654 itezas 10.M.1,2 and 31 in any meaningful way.
(5 factors, p.s3)
GEkhlt "LHtt s New and 'iny couldn't file earlier," for contentions 200 h
thru 210: What's new is the plan, the information in it providing basis for the contention, as cited in i each contention, or (when lack of infor-ation is alleged) the lack of information in the plar or lack of sufficient infernation in the plan. That is, what's new is the basis of each such contention in the plan, and that basis could not be established without the plan in hand.
hhy couldn't file earlier; Plan not available so basis not available.
Similar contentions to many of these were filed earlier, but could not have precise cites to basis in the plan since the plan did not then exist. Having to file contentions abat plans that don"t exist is a nuclear Catch-22 as this Board has observed previously, hhat's amazing to me is how the planners are so good at overlooking matters raised in longstanding contentions.
If the planners were subject to the sane sort of rules as intervenors (e.g.
no plans with mistakes that could have been identified earlier will be accepted),
no energency plan in this case could be filed accepted; surely not this one
l J 1 (k Annex I to the plan does not provide naps which are suitable,
accurate and up to date maps for (i) operations (ii) the ingestion pathway as required by NUREG-0654,/ II.J.10.a page 61, " Maps showing evacuation routes, evacuation areas, pre-selected radiological sampling and monitoring points, a
relocation centers in host areas, and shelter areas" shall be included in the plan.-
10.b likewice requires maps showing population distribution around the nuclear 4
facility which "shall be by evacuation areas" (ibid, p.61). This is inexcusably sloppy planning, to leave the naps out (NB the page of Annex I indicating that ps are in the plan, does not have a page nunber). b SCC f ( lk f 0 Q 4[,
DY )N f!NQft 0H/t/f V
.fj g $
1/J (Generic 5 factors covering this new contention, p.3,; p.11 has generic what's new and why couldn't file earlier which covers this contention also.)
3 Revised 117 The plan does not assessx the number and availability of wrecker trucks and equipnent to keep evacuation routes clear, either for ordinary accidents or for hazardous cargoes or accidents involving same, hhat if, for exanple, a car or truck tries to beat a train to a crossing i
during evacuation, derailing the train and releasing hazardous material from the train or the truck (or even the car)? 7he plan violates 10 C#R 50.47 i
(a)(1) and NUREG-0654, item II.J.10.k for these reasons.
New 212. The plan due to its numerous deficiencies as noted in contentions above and below, gives evidence that the planners have not been properly trained (violation of 10 CFR 50.47da)(16)), or of dereliction i
of duty by the planners, which would cast doubt on their ability to respond in a tinely or appropriate manner during an accident, in violation of 10 CFR 50.47(a)(1).
Properly trained planners would not have filed such a sloppy and incomplete plan, if they were taking their duties seriously.
(5 factors, p.3: what's new etc, p.11)
Revised 117-A. The plan takes no account of train schedules, particularly as they might affect or impede evacuations at any. time, but.especially at night-or under adverse.. weather of fog, snow, sleet, high winds, ~ tornados, ice etc.
The capacity of trains to block evacuation routes and/or contribute to car or truck wrecks which block such routes has not been analyzed, in violation of NUREG-0654, iten II.J.10.k.
R, vised 121. The radi& logical energency response plans of the State of NC and surrounding counties have been formulated without sufficient reference to the Harris DES and FES, and thus fail to address appropr4 ate protective actions under 10 CFR 50.47(a) for accidents greater thant the design basis, which the FIS (p 5 61) admits is possible, and the uncertainty of a factor of 10 to 100 ad itted on page 5-64 of FES to be inherent in NRC's estinates.
124 is revised to add at the end (page 61), so the last line is:
"other criteria as required under NUR G-0654, Rev.1, at II.J.9., page 61a New 213:
The boater notification plan (part 5, p.15) does not include the Harris lake, does not guarantee suficient boats or personnel to conduct warnings, and in particular nakes no provisions for boat or traffic accidents during evacuation of potentially thousands of boaters from the lake. This violates 10 cfr 50.47(a)(1) which requires appropriate protective neasures.
Such neasures should include liniting the nunber of boaters on the lake when the Harris reactor is critical or whenever fuel handling operations are in progress at Harris. Logically, adverse consequences to boaters can be reduced by reducing the number of boaters. The sane logic applies even more to swinners and water-skiers who will be harder to get out.
( 5 factors, p.3; what's new etc that applies to this is on p.11).(a si.ilar oontentions alleging no benefit of use of lakes near Harris due to evac risks etc was filed earlier.
213-a.
The plan, p. vii, says that the plan contains so much detail that " separate imolementing procedures arenot ddemed necessary".
Thus, the plan contains insufficient information about how it will be implemented.
This violates 10 CPR 50.147(a)(2) which requires that plans can be innlemented.
But it also orevents intervenors from seeing many imolementation documents.
Thus the plan is incomplete, violating
. (ste) 5 factors for all the following, p.3; what's nuew for' all, p.11 214 The plan (pt 2 op29-30, pt 3 p 26, ut 4 pn 28-29, et 5 pp 32-33) is deficient in its discussion of shieldlng.
It should at minimum comoly with items 3.212 and 313 of International Atomic 0
Energy Agency (IAEA) " Plans for Effsite Res"onse to Radiation Accidents in Nuclear Facilities", especially with regard to ninimal shielding by windows, desirability of staying in basements (which many homes near the Harris plant domn't have), and naking "A a theoretical or experimental determination of shielding factors for the different types of buildings" near Harris.
F,ilure to do this violatesNUREG-0654, item II.J.10.m, p.64 215 In violation of 10 CPR 50.47 (b)(10) CP&L's evacuation time study does not conform to NUREG 0654 Annendix k and will not provide accurate and useful guidelines for the choice or protective actions during an emergency because the study contains numerous so-called "conservatisms" including those referring to recreational vopulations and vehicle capacity factors (see e.g. sections 3-3 and 3-6) which may force avecuation time estimates unwards and provide inaccaurate estimates for decision makers during an emergency, in the oninion of exeert Paul Holmbeck.
Potential hazards of such "conservatisms" are discussed in the 1Rk984 Byron partial initial decision under emergency planning.
216. In violation of 10 CFR 50.47 (b)(10) and noncofanformance with NUMD-0654 Appendix 4, the CP&L evacuation time study ("HMM report") fails to divide population data into subgroups (e.g. those using autos and those not using autos, NUMEG-0654, Appendix 4, pp 4-2/3) in any meaningful manner.
Those without autos are simply assumed to have access to transport.
The exact method and type and availability of transport for those without autos are not specified, except for schoolchildren.
217.
In violation of 10 CFR 50.k7(b)(10) and NUREG-0654 Appendix 4, the CP&L evacuation time study fails to provide adequate information for choosing nrotective===*du actions duwing a nuclear accident because it fails to systematically consider the relative significance of alternative assumotions, day versus night, e.g. weather conditions,gpeak transient versus off-peak transient populations in accordance with NUREG-065h Aupendx 4 IV-A, p.k-7, 218.
In violation of 10 CPR 50 47(b)(10) and NUREG-0654 Appendix h, the same study fails to provide adequate information for choosing anpropriate protective actions during a nuclear accident because (A) it does not make evacuation time estimates for each snecial facility violates NUREG-0654, Appendix 4, see at on an individual basis (smaxlD0txxtu$r at II-c p.4-3, IV*B p.h-10 )
(B) it contains no information on industry shut down times consiktent h
with NUREG-0654 App 4 IV-B pp 4-9/10.
(S e also Byron 1984 initial partial decision, under emergency planning).
and reliability 219 Further inadequacies threaten the credibilityf or the or unreliable i HMM evacuation time study (if it's incredible it violat6e lo CPR 50 47 g
[d)(d,(a)(2) and (b)(5),(10) and (11)).
The study assumes, sec. 2 pn 2-2/3 that (1) "the auto owning permanent population segment will evacuate from their places of residence." (2) "the public will travel out of the plume exposure EPZ along evacuation routes designated.
Neither of these assumptions, nob the assu$nption (p.3-5) that all school children will be evacuated by bus, can hold true 1
because of the undeniable fact that some parents will go to schools to evacuate their children.
Parents cannot be expected to evacuate without their children.
l
220.
The 100( study is further incredible and unreliable in violation W OO of 10 CPR 50. 71a)(2) and (b)(5),(10), and (11) in that it assumes auto owners will evacuate from residences rather than workplaces (pp 2-2/3), ignoring traffic jamas at work places, and it assumes (pp 3-3,4) that sufficient vehicles will be available for the Boy Scout Camp south of the Harris reservoir to evacuate.
(In WE's experience as a Scout, the camos had only a few staff cars and maybe one bus, for populations of hundreds of campers, available during week days).
i (a)(1) and (2) and 221.
The IDet study, in violation of 50.47(b)(10) uses the untested and inadequate METVAC II computer simulation model.
The model purports to account for human decision making in route selection through a dynamic route selection model.
Driver pareference is assumed to be based on mz 2 criteria one of which assumes familiarity with the area (which cannot be assumed for transietnt population).
1 Further, the impact of hunan behavior under some degree v
of stress is not considered nor is the 1 impact of transients' unfamiliarity with the,, area.
Unrealis
- could lead to disastrous mis-decisions by emergency ponse personnel.
222.
The IDet study violates 10 CPR 50 47(a)(1) and (2) and (b)(10) r l
by not describing the special facilitiee8 highly individualized means of transportation or the availability of transportation resources which might be available for the various facilities (violates NUMPD-0654 App 4, II-C, p.4-3 ).
At section 3-5, the study discusses school 1
l evacuation, but no co-sparison of resources is made sufficient to determine the capability for single trip evacuation.
A second trio l
would expand time estimates for evacuation tremendously (obviously, it would more than double them, since 3 bus trips would be needed to do two evacuation runs).
I i
-17 2223. In 'fiolation of 10 C:'n 50.47(a)(1) and (2) and (b)(10) l (A)
{
the HMN study fails tojconsider highly individualised mobilisation times important to emergency decision making (vielates NUREG-0654
)
App 4, IV-B, p.4-9); (B) use time of day considerations (0654 Iv*B, n.
l 4
4-10) in special facility estimates at pp 3-4, 6-hs (etc);
(C) consider time of day in a nursing home evacuation times, or visiting i
hours impacts on eivacuation of nursing homes (violates o654 App 4 l
l
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IV-B, p. k-10, etc). These defects make it an improper guide for I
decision making four protective action during nuclear accidents.
224 In violation'of lo CFR 50 47(a)(1) and (2) and (b)(10)
I the HMM study is defective because it (A) does not use area-violating i
j specific weather conditions, NUMNa-0654 App k IV-A pp k-6 and 4-7; I
(B) does not identify the adverse weather frecuency used (Id. IV-A, L
i p.k-6) (C) does not give consideration to the innect of peak f
population including behavioral aspee s (Id. IV-B, p.14-10).
Such an defective study is unreliable for guiding emergency
(
response personnel in decisionmaking.
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in the plan, l
225. In violation of Nunsa-0654 ?.1.e,4engoins comunications j
l between, and notification of, emergency resnonse organizations (police, l
1 fire, medical etc) relies uoon comunercial Telenhone. Pt. 2 p 42 i
Pt 3 p 39 pt k p 40 pt 5 p 48.
Given the likelihood of large numbers t
of calls intend jd to confirm the accident, notify friends and relatives, or obtain information on emergency plans or conditions, and given the oertainty that many of these calls will be directed to omsvgency l
response personnel or persons at sites associated with the nian, it is
\\
i entirely inanoropriate to rely on much an overburdened and unreliable j
system of constunications for critical energency comuntentions, in i
l Holmbeck's opinion.
This violates lo cFR 50.47(b)(6).
f i
_ _, _ _ _... _ _ _ _ _ _ _ _ _ _... _ _ -, _.. _. - ~,. _ _ - -.. _ _ _.... _ _ _. _ _ _. -
226.
The use of commercial telephone for ongoing and notification i
comunications to and among emergency resnonse organizations (plan, j
pt 2 p h2, pt 3 p 39 pt 4 p 40 pt 5 p 48) violates the requirenent of 10 CFR 50.47(b)(6) for t
aprovisions exist (ing) for prompt communications 4
among principal response organizations to emergency personnel". Other j
means of communication have not been analyzed to show they can handle t
l the traffica of comunication necessary among all the emergency response organizations if phone lines are tied up with calls, or inoperable, e.g. due to storms, tornadoes, electromagnetic pulse etc.
1 I
( Note:
the plan, pt 2 p 42 IV D 1 mays "communicats on between Gaston l
county and the state" (WHOOPS).
Intervenor will accept a 150-mile EPZ) j 227.The emergency preparedness borchure, the primary means of public education under 10 CFR 50 47(b)(7) re "how they will be
)
notified and what their intial actions milk should be in an emergency"
)
etc, is==etwaty inadequate because (A) it's missing from part 1 p.k3 q>
of the plan; $ it lack information about radiation and its effects 1
on humans (C) listing of nrotective measures to be taken during l
l an emergency including evacuation, sheltering, respairatory protection, 1
)
radioprotective drugs, etc; (D) specific travel routes and alternative l
l routes from the area;(E) where to listen for or get emergency information; I
l (F) special measures for handicapped peonle during emergencies.
i j
228.
Applicant cannot be deemed to have met the requirements of 10 CFR 50.k?(b)(7) regarding public education and 4
information until it is at least demonstrated that the above-requested i
j information (in contentidn 227 (B) thru (F)) and other required
}
information will be or is in fact made available to the public on 4
a periodic basis.
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e.
229.
In plan sections danadgestuss re public education and infor-mation (pt.1 pp 42-45; Chatham Co. pt 2 pp 26-?8; Harnett co. pt3 pp 22-25; Lee Co. pt k pp 24-27; wake Co. pt 5 pp 27-30), Apn11eants have failed to demonstrate any means for the dissemination of information i
to the public that comolies with 10 CFR 50.k7(b)(7) and NUPEG-065h (up 50-51)
II.0 will be verified as having been successful in its task of informning the public.
Failure to demonstrate that the public is informed wiolvates 10 CPR 50.k?(a)(1) and (2).
E.g. the public could be provided with a tearoff mail-in (prepaid postage) card on the brochure with checkoffs for " received and understood" ofr "n6t i
l understood".
230.
In violation of 10 CPR 50.47(b)(10)and applicable l
evaluation criteria in NURIn-0654 II.J.10.g (p.63) emergency i
plans for Shearon Harris fail to demonstrate that adequate transportation
)
all resources to evacuateAschools in the EPZ are available.
Plans for providing "means of relocation" (pt 1 p 47, pt 2 pp29-31, pt 3 pp P7-28,
]
pt 4 p 29, pt 5 pp 32-33) contain no useful information to prove that 1
adequate vehicles will be available and onerable for school evacuations.
10 CF9 50.47(b)(1) requires that where evacuation depends on resources other than those of the snecific schools involved, the plan must include means to coordinate such action, and those involved must be able to execute the actioh.
1 4
231.
In violation of 10 CPR 50.k7(b)(10)and annlicab.le evaluation criteria of NUMEG-065h II.J. (pp 60-64) the Harris Emergency Response plans do not adequately address the need for notification of schools in the plume exposure pathway EPZ or the required 1
communications systems to coordinate their evacuation.
Two way radios on all school buses are necessary should evacuation be called for during i
pickup or dropoff times or in the event that buses must make additonal trips or change route due to plume shift in changing winds.
% - m_
s 232.
In vi6lation of lo CFR 50 47(b)(10) and NUREG-0654 II.J.
criteria (pp 60-64), communication with the schools, in the plume exposure EPZ is not assured, nor is comunication bet' ween these schools assured (their phones will be jamed with ir. coming calls in an emergency -
this hanpened at TMI).
Yet an evacuation may have to be called;f'or after a period of sheltering, so communication that cannot be blocked by phone h failures or jammed switchboards has to be assuhyd to all schools 'in the EPZ.
~
233 In ' violation'of 10 CFR 50.47(b)(4) and' evaluation criteria in NUREG-0654 II.D. (p.42) the Harris emergency plans fail to provide an adequate emergency classification and action' 1evel scheme (pt 2 e 34, pt 3 p 31 pt 4,p 32 and ut 5 p.3.7), give protective response options-for each different emergency classificatioti~ fdr' the counties of Cnatham, Lee, Harrlett and Wake or other areas in the EPKZ.
level
- p.1-12 (advocates assessment of sheltering at site em.
Contrary to Appendix 1 of NUREG-0654, these schemes defer assessment of appropriate protective actions for the public uiltil a " general emergency exists"or until " eveists have occurred or in are in parogress which involve immineht or actual substantial, core degradation or melting with potential of 1 Bas of containment".
^~'
234 Contrary to NURED-0654 App 'l p.1-12 that advocates assessment of need for sheltering at the site emergency action level, the Harris plan defers such assessments until doo late, i.e. until a general emergency, a meltdhwn or inninent or actual loss of s
s, containment of radioactive poison at Harris is in prog'ress (see page cites in contention'233.a ove). 'That's too' late and shows a callous l
m disregard for the public health and" safety in vi61ation of the Atomic Energy Act,10 CPR 50.h7f(a)(1) an.d. (b), and 10 CPR 50.47 (b)(k).
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235 Portions of the Harris emergency plan which purport to assure that the mobility-impaired will be adequately protected (pt 1 ph7 pt 2 p 30, pt 3 pp 26-27, pt 4 p 28, pt 5 pp 31-32) fail to assess for the resources necessary or available in this task.
Means for protecting persons whose mobility is impaired due to institu-tional or other confinement are required by 10 CFR 50.47(b)(10) and specified in NUMEG-0654 evaluation criteria II.J.10.d and g. (pp 61,63 Id. )
i 236.
In violation of' 10 CPR 50 47(b)(10), (a)(1) and NUREG-0654 evaluation criteria II.J.10.d. and g, (no 61,63), the Harris l
emergency plan for the mobility impaired (see page refs in contention j
235 above) does not (A) designate transportation resources for homebound, nursing home and hospital patients (and prisoners and the handicanped);
(B) establish self transport capability 8xists for all facilities for l
such persons as noted in (A) above in the Harris EPZ (C) Fail to prohvide timely access to radioprotective drugs (KI) for hospitals and nursing homes in the event of ranid accidents or radiciodine releases j
(violates NUREG-0654 II.10.*f, p.63).
237.
The Harris emergency plans suggest versons without personal vehicles walk to pickup noints where school buses will evacuate them (Pt 2 p 31, pt 3 p 28 pt 4 p 29 pt 5 9 33).
In violation of 10 CPR 50 47 (b)(10)' and NUREG-0654 II.J.10.tg p.63, there is no indication that such vehicles and drivers for them exist, that I
routes for them without conflict with evacuation traffic flow exist, or that any estimate of the time required for such procedures have abeen made.
Thus evacuation has not been determined superior to sheltering for personnel without vehicles under some evacuation conditions, but the plan d oss not give planners the information to say which conditions.
l l
l
238.
Provisions for the administration of radiological-protective drugs (KI) to emergency workers and persons in hospitals ofr hursing homes (pt 1 p 47 pt 2 p30 pt 3 pp 26-27 pt k p 28 pt 5 p 30) are inadequate to provide timely protection from radioiodines. KI is mainly to be stored at county health departments and distributed during an emergency.
Travel to supply these drugs will surely be difficult during an evacuation, and has not been planned for specifically, e.g. routes, alternative routes, timing.
Predistribution of KI with regular replacement of supplies to 4
azzssure it remains effective versus radiciodines would be better.
239.
Provisions to distribute KI at facilities in the Harris EPZ do not appear to designate individuals to distribute KI or other l
radioprotective drugs or to make sure each individual at risk receives it.
Risks of using KI, and obtaining informed consent in advance to use KI, are not addressed.
Patients must be infourned of the risks and benefits of KI or any other radioprotective drug they are asked to take, under medical ethics.
If this is not done in advance, distribution may be greatly delayed in an accident.
I 2h0.
Procedures for monitoring evacuees for radiation under 10 l
l CFR 50.47(b)(10) and NUREG-0654 II.J.10 and 12 fail to adequately protect the health and safety of evacuees, emergency versonnel and persons in the host community.
Local governments are responsible for shelter monitoring (pt 1 p 61,but their canabilities for decontamination have not been delineated.
Would contaiminated persons have to be turned away from shelters?
Locations for evacuee monitoring and decontamination (and availability of materials for decontamination) is knelear in the plan, pts 1, 567-61, pt 2,33-35, pt 3 pp 30-34, pt 4 pp 30-34, pt 45 -- 36-38, 241.
Ene plan's use of host sites (mainly schools) for decountamination-
' is entirely inappropriate and ill advised.
It would leave schools inkry chontaminated, where children susceptible to radiati6n (moreso than adults) will be later.
Evacuees should be monitored after they leave the EPZ before they continue to a host area.
Facilities j
and personnel to do this should be provided.
Othermiwise evacuees may spread contamination, induce panic, and make host areas unable to perform their functions.
242.
While benefits of economies of scale should be exnlointed by the NC Dept of crime control and public safety emergency planners, attention to site specific planning required by 10 CFR 50.h7(a)(L),(2) and (b) must not be compromised.
Frequent references to the McGuire nuclear plant and its locale, e.g. pt 2 p k2 ("gaston county"),
pt 2 p 26, etc, indicate the (A) the SENPP plan is a copy of the McGuire plan and (2B) officials in the vicinity of SHNPP hazve not seen this plan yet or they would surely have caught these a errors.
These errors indicate nossible violation of 10 CFR 50.47(b)(16).
243.
In violation of 10 CFP 50.k7(b)(15) radiological resnonse training has not been provided to all resnonse organizations and individuals who may be called upon to assist in an emergency, e.g. directors and coordinators of the resnonse organizations, first aid and rescue personnel, local support services personn&1 including fire and police; medical suonort personnel, and all offsite otrganizations (and members thereof) having mutual aid agreements with local. agencies inthe Harris x emergency plan.
244 In violation of 10 CFR 50.47 (b)(5) and (b)(6) the Harris emergency response plan d oes not adeountely provide for notification or connunication between and among emergency a response organizations and personnel so that communications necessary to timely and promet evacuation can be imolemented effectively.
Phores will get
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-2k-245 TheHarrisemergencyolanreliestooheavilyopkolunteer personnel to effect an evacuation.
The emergency plans fail to indicate the number of volunteer personnel who are necessary or who will be assuredly available to nernform the resnonsibilities assigned to daem.
The plans So not take into account nersonal conflicts between volunteer responshibilities and concern to protect families and relatives in the EPAZ, which mean that volunteers may not show up for their emergency jobs or may leave them (cf. Kai Erekson study in Shoreham case).
They don't account for volunteers possible fears of radiation which would not apoly in other tynes of emergencies.
l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0f0 FISSION In the matter of CAROLHA POWER k LIGHT CO. Et al. )
Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1
)
O.L.
CERTIFICATEOF SERVICE Eddle-n Contentions on Etergency I hereby certify that copies of YW6f ON (k (k
, lf,4 l32(C)2, 4 vsfilth wJ6mTH Plan (2d set)
HAVE been served this 12 day of Acril 198,J,, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are marked with an asterisk, for whom service was accomplished by evwsrman (N.B. Applicants have also arranged to physically pick un a cocy 4-12 84)
Jud es James Kelley, Glenn Bright and Janae Carpenter (1 cgy each)
E Atomic Safety and Licensirg Board US Nuclear Regulatory Commission Washington DC 20555 l
- George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel j
Washington, DC 20036 USNRC Washington DC 2055 5 111s Lotchin, Ph.D.
Office of the. Executive Legal Director Ph"sBridleRun Attn Docke ts 50-400/k010 L.
lo US11RC Chanel Fill NC 2751h Washington DC 20555 Dan Read Docketing and Service Section (3x)
CEA?W/FLP Attn Docke ts 50-h00/hol 0.L.
galeigh,$707 Waveross Office of the Secretary NC 27606 USNRC Dr. Linda W. Little Washington DC 20555 Governor's Waste Ngt. Bd.
John Runkle 513 Albemarle Bldg.
i 325 N. Salisbutw St.
I"
- Granville Rd
' Chapel Hill Ne 2751k Bradley W. Jones Robert Gruber USNRC Region II Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 Box 12607 Box 991 1
Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D.
Certified by h
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729 Hunter St.
Apex NC 27502 t
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