ML20084L618
| ML20084L618 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/10/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8405140550 | |
| Download: ML20084L618 (16) | |
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UNITED STATES OF AMERICA h
NUCLEAR REGULATOBY COMMISSION 1
- I htMNd D
c*o BEFORE THE A'!OMIC SAFETY AND LICENSING BOARD Glenn O. Bright-04 Dr. James H. Carpenter 0814 NOM 4 James L. Kelley, Chairman trr;;n3k,y..
GCCHE. iy;
- n.i;&
In the Matter of Docket 50 W OL CAB 0 LINA POWER AND LIGHT CO. , h . -
(Shearon Harris Nuclear Power Plant, 1 Unit 1) ) ASLBP No. 82-k66-01
) OL Wells Eddleman's Response on Emergency Planning Contentions The Board orally ordered filing of this resnonse at the special prehearing conference May 2, 1984 TheBoard had produced a cartial list of contentions they wanted to be addressed, and suggested (as I recall; transcript not yet here) that I address the kinds of concerns raised with resnect to other panties' contentions. Among these were referencing tlie plan, citing a rule or requirement, and not challenging NRC rules.
The Board's list of contentions was : Revised 2, 57-C-10, 57-C-13, 57-C-16, 30 & 30A, 214, 218, 219 and 222. Those are addressed first here. The Board indicated as I recall that it had not gone throug{
all of my contentions in making the list. Since Applicants' responses often go to the merits, I have not addressed this snecifically under thecontentibns. I think their improper arguments are obvious enough, and it will save time and pacer to not comment on each instance.
1 Judge Kelley orally granted a 2h-hour extension on the filing deadline for use if necessary (granted May 10, 1984).
kDOKOO O O PDR SC)h
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Contention 2 Revised contention 2 concerns failure of the plan to reouire the continuous assessment of protective actions in a timely manner. -
Such failure violates 10 CFM 50.47(b)(4) and (9) in that the assessment systens aren't required to onerate when radiation hac been released !
to the environment (b)(9), and the basis for not requiring such assessment be in place (b)(4) is missing from the plan sections cited, ,
and as far as I know, from the whole plan. This also violates 10 CPR 50.47(a)(1) because, unless assessment of what to do in an energency is required to begin at radiation rolease to the environment, there f cannot be assurance that adequate protectivo measures will be taken.
The argument that this can be optional and not in the plan
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is ridiculous. The plan must meet the requirements of 10 CFR 50.47 and the innlementation guidelines of NUREG-0654 It is sinple common l
i sense that inf assessment is delayed as long as .the plan now allows it to be, the protective action may well not be timely or adequate.
The worst case, with all the radiation barriers down and the last one failing BEFORE ASSESSMENT IS REQUIRED TO BEGIN (pt.1 pp 32-33 as cited in the contention) should nake this clear.
If an action is required by 10 CFa 50.h7, it cannot be made eptional in the nian, but should be exnlicitly required.
Contention 57-C-10 This contention concerns ground level plumes, e.g. of the sort that occurred at the Ginna accident and wnich Applicants rostulate in their meteorology of plume radiation doses (cf. Eddleman 80 and McFeaters affidavit for Applicants on sunnary dianosition thereof).
10 CPR 50 47(b)(10) requires a range of protective actions in the plan, and 10 CFR 50.47(n)(1) requires such actions to be adequate, with reasonable assurance that they"can and will be taken "
in an emergency.
NUREG-0654, section II.I.10 (p.58) establishes that each or6anization (involved in the emergency ' response) shall establish means for relating various measured parameters to dose rates. Surely the plune being on the ground is a parameter that affects dose rates (especially to sheltered pooulations in the oath of the plume). Section II.I.8, ibid, sane page, requires the ability in each organization to nake"rannid assessments of the actual . . . locations . . . of rad' ological hazards" (emphasis original) ao they should know if the plune is on the ground.
Section II.MD.4, ibid. p.42, requires actions consistent with
" local offsite condition at the time of the emergency" A clume on the ground could require evacuation where the same or a similar plune al&ft might leave sheltering the best resnonse.
NUREG-0654, II.J.7 (p.60) requ!res each licensee to establish a mechanism to recommend anpropriate nrotective actions, but without reasonable assessment of sheltering effectiveness, it cannot be said that the recomnendations are anpropriate.
NUREG-0654, II.J.10.m, p.64, states "The basis for the choice of recommended protective actions from the plune exposure cabhway during energency conditions:
This shall include exnected local nrotogti.on afforded in residential units or other shelter for direct and inhalation 4
exoosure ..." (emohasis added). Clearly, a. nlune on the ground is a greater inhalation hazard. Note that this action (including sheltering effectiaaveness information) is one required for plans (NUMEG-0654,itemII.10,n.hD:"Theorganization'aplansrex to inoloment protective neasures for the plume exnosure pathway shall includ (emphasis added). A plan that does not meet these clear requirements is obviously challengeable. There does not annear to be specific analysis of sheltering in the plan. Applicants (veen at 30-31) claim non-site-soecific documents are OK for this. But Ntf"FO-065h p64 n.(
only says they "may be considered". They clearly do not address the
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" local protection" required to be assessed under NUMEG-065h II.J.10/.m.
/ Contention 57-C-13 This contention concerns the lack of snecifies on nrotection factors and the "best nrotection factor" in the nian.
10 CFR 50.47(b)(10) requires a range or protective actiens, but these cannot be anpropriate (as required by 10 CFR 50.h7(a)(1))
unless their effects and feasibility are accurately known.
Concerning the choisce of recommended protective actions, NUREG-0654 says (II.J.10.m, p.64) that the basis of the choice of recommended protective actions from the plume EPZ durine emergency conditions: . . .shall include expected 1,oca,1 protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation timo estimates." This is required to be included in the plant (NUREG-0654, II.10, p.61 "organisation's plans shall include" itens listed below, including item m. Emnhasis added in both quotes).
That's about as definite a requirement as can be. Again, the footnote on n.6k saying that some documents may be maad considered, does nothing to release the planners from these clear requirements for knowing the expected local protedction in shelters and residential units for both direct and inhalation radiation exposure.
The Staff's discussion of this contention (p.37 their responne) indicates they either haven't read the contention or deliberately misre(
it. Applicants, pp 30-31, fail to address the requirement for local prostection, and the requirement that the basin be included in the vien It's not inclusion in_the plan to rePerence a document FU'EG-06F4 does not say that the use of these documents is presuned adequate for local sheltering effectiveness evaluation. Indded, plan Pt.1 p.h0 item 6.c nays EPA info wLil be used "to the extent narameters are neth.
This contention r,s quite snecific and even anya what needs to be done (determine highest nrotection factor arean in advance).
Contention 57-C-16 This contention concerns appropriate protection in severe accidents. While the correction factor for Harris from NUPPO-CR-2239 may not be exactly right, it would have to be off by a factor of nearly 300 for Harris to baring the expected deaths below a number that l
rounds off to 1; It would have to be off by a factor of 700 to be
! sure that the worst case deaths would dron below 1 (690/700 is less than one). Harris area rainfall is not that different from that ,
around Indian Point, though this is a warmer climate.
The key point, however, is that the plan does not have i an anoropriate provision ofr set of plans to adecuately protect l peonle from severe accidents even in an average case (per NUPFO.
l 09-2239). It's hard to give a specific cite to something that is 10 CFR 50.h7(b)(9) not in the plan, but the range of protective actions 4 oes d nog con: ply j with 10 CFP 50.47(a)(1) if it leaves a reasonable chance of killing l people. See NUMEG-065b , Item II.I.8, p.58, requiring ranio (sic)
I assessment of the sever $ ty of an accident.
The plan, Pat.1 pp 36-40 (referenced in Annex H to -0654 II.I.8) doesn't 61 ve any a special attention to severe accidents; nor can I l find any detailed provisions that would be workable (from the info stated) elsewhere in the plan to handle such accidents.
Pt. 1 p.38 does give mininum sampling timos of 5 minutes, plus co g uter time or calculating time (see iten 6, plan pt. 1 p.40) l plus you'd have to add in notification tine. Without knowing the l
sheltering effectiveness in advance, it might be too late to evacuate (due to delays e.g. as cited kbove) and still shelterin6 would not adequately protect people. The plan needs to deal with this probley, not duck it. Maybe some other neans might nrovide arnrontiate protection under these conditions, but it's not in the plan (as required by NUMEo-0654 Part IT.J.10 as cited above)(see C-13 and C-10
Contentions 30 and 30A These contentions concern radioprotective drugs like potassium iodide that can be given to avoid ingestion of radioactive iodine.
Concerning #30, Applicants (resp at 31-33) argue a lot. But the plan needs detail -- how many people will need KI, and who is available to distribute it and how will they get where they are going -- planned out in advance. As noted in above responses. NURPG-0654 II.J.10 says these things (including II.J.10.e re radioprotective drugs) must be in the plan. "To be determined by " is not having it in the plan (quantities of drugs, e.g. , vs. Apps response at 33).
NUREG-065k II.J.10.e requires means to administer the drugs as well, but the plan doesn't say how many people will be available to deliver the drugs, how long it will take them to do it, how long it will take to administer the drugs, or who are the backup personnel (and how many are available) to do these things if the primary personnel aren't available. The " plan" on these issues is just a sketch.
The description in the plan (cited in the contention, Pt 1 pp 49 '
does not conply widh 10 CPR 50 47(b)(1) which requires that each organization assigned primary emergency responsibilities (such as for radion'r otective drugs) have "the staff to respond and to augment its initial response on a continuous basis". The vlan must be detaile6 enough todemonstrate that this can be done, or 10 CPR 50.k7(a)(1) is not satisfied, i.e. there isn't reasonable assurance the nian can and will work. This requirement applies to all requirements of
'"" '**"* So does 10 CPR 1
50 47(b)(3)'s requirement for effectively W#c2R!!84112Be"l'nst18:47tE5hi).thenlanmustshowthis Contention 30A points out that other persons whose inmediate evacuation may be infeasible, other than emergency personnel or nursing home patients (or, including them -- the plan gives no sapecifS only generaklities about who can't be evacuated). For persons who
are not emergency workers or bedridden, the plan gives no means of distributing KI to them, either. NU9EG-0654 II.J.10.$e (p.63) does not limit the use of KI to emergency workers and the insti- ,
tutionalized, but says plans nust particularly cover them (cf.
Contention 30, above). Contention 30A regards the lack of v1anning for giving KI to others, which is clearly allowed by NUPEG-0654.
Comnona sense says that if radioiodines are released, KI can be of help to other persons.
The above arguments are also anplicable to contentions 238 and 239. As to delivery of drugs, Applicants attack the merits.
The plan contains no time study for distribution of KI, but the effectiveness of KI as a nrotective action under 10 CF9 50 47(a)(1) and (b)(10). Informed consent is necessary for administration of drugs (contention 239) and KI does have risks. The correct time to obtain this informed consent fron nursing home natients and others (including emergency workers and institutionalized persons) is clearly before the accident hits. This is just good sense.
Applicants claim (resp at 35) that staging areas are set un for KI distribution, but the actual nian, e.g. Pt 3 pp 26-27, contains no such information, only a storage site at the Harnett Co. Health Dept (not specified where in the health Dept) and standard authorization; to distribute KI. The plan simply doesn't have the detail to shou the KI distribution would be made where annropriate or that such distribution (and administration) would or could be made timely enough to be effective.
Contention 214 This is another chielding contention.
The basis for requiring shielding analysis under 10 CFR 50.47 and NUREo-0654 (particularly the part re II.J.10.m, p.64 thereof, cited >
in the contention) are discussed above re .h7-C-10,13 and 16, pp2 thru 5, '
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Although Applicants frequently say in their Rennonse that I haven't i told them what they should have done or what should be in the plan, here I do, highly specifically.
The IAEA items 312 and 313 simply require the kind of basic survey or determination of shielding effectiveness of buildings near Harris that is necessary to know the local protection factors l
required by NUREG-0654 section II.J.LO (" plans ... shall include")
l and II.J.10.m. To not do so is irresponsible and violates 10 CPR 50.47(b)Q ) which requires a way to chbose appronriate protective action. If you don't know sheltering's effectiveness, how can you accurately choose for or against it? Such noncompliance also violates 10 CFR 50 47(a)(1) which requires reasonable assurance that appropriatei protective action can and will be taken. This content $on could be consolidated with %R 57-C-10,13 and 16 (or narts thereof) and !
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other parties' contentions.
Contention 218 l This contention alleges a failure to make individualized ,
evacuation time estimates for each snecial facilitiey (part A), ,
and not uroviding individualized shutdown times for industrioc (Part B)
The HMM NETVAC study salina claims to have made an overall estimate l
l of evacuation times using a computer and input data on facilities, j
- i but it does not generate evacuation times for each facilit$p, nor l does it consider"means of mobilization of equipment and manpower (sic) -
to aid in evacuation, and the needs for designated emnleyees or ttaff ;
to delay their evacuation in order to shut down industrial facilities" l NUREG-0654 Appendix 4, pp 4-9/4-10. i i
The HMM Study describes the NETVAC code (section 2.2, pp2-3 >
I thru 2-6 and the following figure on the page after P-6), but it does not address these matters cited from NUREG-0654 above. '
I can find not discussion of them in the FP@t report that shows how (or even if) they were used in the study or the NrTVAC $nputs.
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9 The plan is no more adequate on these matters. E.g. at pt.1 p.h7 item 4 b it says patients are transported by private amabulances etc but does not discuss mobilization times, numbers, personnel for driving them, mi or how long it will take to evacuate all the ;
patients. Dr. Wilson has an ambulance contention that this one could be consolidated with.
Contention 219: The actual exnerience at TMI was that l
parents came to schools to get their children. The plan has a small number of traffic control points in all counties other than ,
Wake (see Table g-2 of HMM study: maximum of 6 in counties other than Wake. Note"a"says that an average of one person and one vehicle will be at each control point. Yet it is clear from the man that the zones K,L,M and N in Chatham County have far more than 6 intersections to control, so it can't be assumed with any sureness that the evacuation routes will be fbliowed. (Map, HMM Fig 5-1)0 Moreover, consider e.g. an auto owner who has gone shonning, e.g. in Apex, or Fuquay-Varina, but who has a home with small children present (or relative present who can't transport themselves) elsewhere in the EPKZ. This person won't start evacuation from a place of residence, but will have to go there first, perhans against the main flow of traffic (which can cause problems where traffic evascuating turns left, e.g.). Both Apex and Fuquay-Varina are towne with signifi-cant numbers of stores catering to local farm (and other) people.
This transient population isn't accurately considered in daytime 8am or 4 pm evacuation timing. Even the HMM study, sec. 3-3, assumes parents will gocontention, This to dky care re centers, N ,ickuo, schools and chicould 1H p bedhe get kids there.
consolidated with the similar joint contention. The evacuation start points could be consolidated with other contentions criticizing the evacuation time study.
i Contention 222. The best I can do for basis here is to enclose the Releigh Times front nage article of 4-P6-84 (af ter i these contentions were filed) which quotes Wake schools transnortation on <
director Donald G. Cotten, "The two major p"oblems in transnortation !
are the qua ntity and quality of the drivers and the quality of the maintenance" and describes aging, tardy buses as a ah "touFh
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problem" in the subheadline. At p.3A, this article continues by ;
saying that working buses have had to double-up or even trinle-up on some routes.
As to the first part, about the HMM study not discussing !
other facilities highly individualized means of transportation [
or availability of transportation resources, I can't find it either 3 ,
in the NETVAC model (HMM section 2, pp 22-2 thru 2-6) or in HMM section 3 There just isn't a highly individualized discussion of transport in it, which is no wonder since NETVAC is a etenda"d model from its own description.
NUREG-0654, App.4, II.c on page 4-3, says "the means of transportation are also highly individualized and shall be described" and " Schools shall be included in this segment". Applicants cite the FDDi study, section 3 3 against this. It's only a page long ;
l and does not describe hihgly individualized trananortation for each facility, by a long shot. It says "if"this ...."but if"that", which is anpropriate for discussing backup, but the adequacy of nunbers of vehicles to evacuate these snecial facilities is never discussed.
The availability of vehicles isn't discussed. Means of transportation I presume means working means, not broken down or unavailable vehicles.
This description must be highly individualized, and the HMM discussion is very generalized. It does not evaluate numbers or availabi31ty of backup drivers and buses to snecific schools or say how long thev would take to get to the schools, i
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> =a THE RALE GK ilMES A Vol 90,No.100 Pheae 82S4500 Re% Nereli Caroline, Thursday Afterneen, April 26,1944 44 Poe 25e e
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Behm. d-time C 1
l Aging, tardy buses add -tough problem to Wake schools' education effort ty W 113rM CostAN at I.igon, a gifted and talented less la transportataan are the percent, from about 5 percent, in 80,0:D miles should be considered 50 new Immes be purchased from-yg.,, ,g g ,,ge,, magnet school, result from sever. quaataty and qualaty of the drivers previous aienths. As a result, for replacement. "About one-third the schools' capital fund. Hacks al factors raagmg from broken and the quahty of the staante- about 12 mh'iasul buses need of our fleetis as that category,"he decimed to say, though, whether I
On any given day at Ligan . transon=miaan and bus drivers mance." repairs dady. saad. he has tactuded that figure na the Madr:se School, as many as 38 who oversleep, school efficaals To try to correct the problem, "Sance the first of the year, this I:us rrplacenient is the state's actual budget request.
students mass aD er part of their asy. Some buses are chronacally Cottaa has asked for 50 new school has been a tremendous problem responsabelsty. Any bus 12 years farst period elective class. At least one of r'astaa's trans-late at other =chaals too, such as buses, school offnenals have put for area supervisors who have to old or older should be replaced. portatian prioritaes, though, has Wble for most tagon students West Malibrook, Garner Hagh and . construction of a new bus mainte- look at the number of routes that according to state law. won the recommendation of top school begins at 8 o' clock It is not - Enloe Hagh. Dance garage as a top priority and have to be covered," Cotton saad. That does not always happee. school affacials: a new $2.5 mdhon
! uncasamast for **"d=='a le stream . "I'm sure late buses are a a campanga to elinunet, drivers "I understand that parents are For instance,33 replacement bus- bus service garage. Wake schnois am as to 45 auant** later. problem educationally," said who eversleep is under way. upset, and rightly so." es earmark =d for Wake County Supt. Walter 1. Marks
- 575 andlaan "Why are you so late'" LJgon . Donald G.Tartaa transportatana To diustrate the growmg prob- What's more, Wake's fleet is for this school year were never schools facdaties request docu.
science teacher Gayle M. Owens darector. "But more partacularly, lem,Cottaa sand that yesterday 58 rapidly agmg. Some 75 of the delsvered. Hacks sand those buses ment lasts the gjtrage as a top aded tardy students recently, at as a maiasensace and personnel of 675 schout buses, or S.S percent school buses are 12 years ild or are now expected an June. Hacks priority, although tr.e Wake com-I "Did your bus pat get here?" problem. Our solutana would be to of the fleet, were in the shop for older, accordang to Carla D. also sand 30 new vans wdl be masuoners std! must approve I Invariably, the students answer have a large and better equapped repaars. la fact, the percentage of Hacks, associate supermtandent purctiased to transport! handa- fundang.
I "yes," the bus had past arrtved. ""a'asiance facdaty and to have buses needsng repaars each day for admamstratsve servaces. Hacks capped chddren. -
late buses, a chrenac prahaam snare people.The two anajorprob. has crept upward to about 7 amad that any to yearold tma with Cotton also has rat =a8md that see g ATE,page 3 A 4
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u n,. pe m , n u.c.um., as a a. m4 3-A b27 Local data
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st i y.n d.,_ ss (kl
, LGie BUSES G Prob lem Of Schools -
15' as :- - z_ :v.esad.y 63 Deal Costimmed fiream page I-A buses, five also broke down. That also distributes lateness evenly.
Ek ven e s.w. an -3 (-Ici left the six working buses to Also, the uncertain transporta-
- @I Hacks also is working on ways to double-up,even triple-up,on some tion schedule has forced principal
, d 8** "'"*'""'s asconom areE 26 replace slee y or irresponsible routes, Cotton said. Susie VanDeVeer to make first
- ""~$7,,3l,et bus drivers. Chief among them is Meanwhile, at Ligon, the school period an elective, saving daily M A a proposal to pay bus drivers an day has been designed to match announcements and the basics for e neuromsm.e.s in peca.st cars.avses
- =< a rs =ce unspecified amount as a supple- the pecuharities of the bus sched- second period.
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yM"4*******C"d gas ment to, as Cotton put it," recruit ule. Bus supervisor Eddie Clinton "I have tried to get it corrected, said he tries to anticipate the surely," Mrs. VanDeVeer said, and retain" the best drivers.
g 3 % ,, g"*"
3 e,;. 4.35 e 'Ihe bus.related confusion has afternoon before which buses are "but that's why we moved basics taken its tollon some schools.For likely to be broken down in the to second period, because we do ,
v s, + 1.** in t. nee, yesterday 11 Garner mor:Qyg. That way, the troubled know some youngsters are going 70 v is, y , 2e.33 High buses were in the shop. But buses don't meet the same stu- to be late."
i Vaa.s I,w n.nn + 7.25 out of the 11 spare replacement den's every day. This practice i
tai,on.,y %
l 4"5",3 ,,,"',',
5'" 5 THE RALEIGH TIMES
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'" 5 Fost-moving furtle rewrites old sfory = _ g.m,1; saiid weesimels _ noaa we,,a,m,e,a nango
, , ,,, n _ ,,mn .. " Hey, what's that?" one of the "' T i "*_ O " 2 6 e
- O Applicants cite the plan, sections IVR.E.4.d and f of part 1 (p.h7) v ;
but it's just a generality, not saying how many backun hohicles are available, when, from what locations, or what "other available transportation" is. A plan has to have enough specifics to shew
- it can and will work, or it doesn't comnly with 10 CFR 50.h? (a)(1). l This plan, re transnoat %on schools and spec *al facilf tf es, does not do that. (/EN NM M OD h #
bO( M i This contention, re schools, could go into the EPJ school I contention. Me other special facilities, it could be cons &11 dated with nursing home contentions or Dr. Wilson's trananort-of-non-ambulatory persona contention.
Tnis connletes the Board's list. !
The Board niso asked me to find a reference requiring nlanninr 1 statenent beyond the 10-mile EPZ. I was incorrect. The correct munka fron i NUREG-065h item D.2.d on page 12, is that detailed pinnning within the 10 mile EnZ would probide adequate basis to expand efforts if that proved necessary. This nian doesn't do that because its planning inside the 10 mile EPZ is not detailedt for specifica, take a look at the discussion of contentions above, for exannle.
Re contentions 100,100 B and P10 (re-entry / recovery) 10 CFR 501 47(b)913) requires general pinnninr for this. Thane plans must be " developed" (ibid). But the pinn, na cited in content!on 210, is virtually nonexistent on these points. Nt1 PEG-065h, p.70,
" (4 the II.10.M itense o not annear to be meanirgfully addresned in the plan, section IV.H. in part 1, pp 61-6P. Particulnriy iten I 1 regarding general plans for re-entry and recovery, and iten 3 .
l concerning recovery operations and changes in organizationn, do nop ,(N
.hiseuc 94L
- appear to be covered. Where the plan is so general an (
not meet 50 47(b)(1])'a requirenents for general plans.
it would surely " developed i
Me constantions 57-c , 57-o-h, lifaxhkinA and nerhans JePSNTW To the extent these contentions cover medical facilities, they'll probably get clobbered under the San onofre decision. But I cannot withdraw them in good conscience, as I believe medical facilities need
- to be able to fulfill their functions, not just be listed. I hope it will not be too much work to handle these contentions.
Me Contention 221: NUMEG-0654, Appendix h, page 4-10, requires ennsideration to "shall be given to the innnet ofn peak populations including behavioral asnects" . The descrintion of NPTVAC see also 6 3 1 and chapter 6, e.g. 6.P.2,6.P.3,6.P.h (HMM pp 2-3/2-6) and HMM chanter 3 do not annaar to account for behavioral aspectma unique to otr typical of peak ponulations.
As noted above (HMH figure 8 2) traffic control is n'nimal outside Wske County (maximum of 6 control points per county except Wake),
so Applicants' view (resp at k9) is wrong ac well as going to the meritt 4
The innact of human behavior under some degree of stress (as the contention says) just isn't in these blithe guesstimates.
I reiterate that the HMM A study isn't IN the plan, which is recuired by NUMEG-0654, but that's probably moot by now.
! Me contention 245, the study cited would be basis; the une of volunteers in rescue squads, schbol teachers, bus drivers, and so on is nervasive in the plan and shouldn't have to be cited all that onec1rically. The plan simnly fatis to address how many people will show up to do their john. This contention is a candidate fon consolidation with others on the same point.
Me Contention 241 (schbols as hosts for evacuated venulations)
NUREG-0654 II.A.2.s.3 on page 32 requir es written agreer.ents with organisations in which have roles in the plan, and requires their signatures. There are no signatures in the nian now, and I question whether school boards will knowingly sign a document requiring (or which could require) their schools to alley radioactive decontamination
-13 at their sites / (the cross reference on this from II.J.10.h, n.63, is to iten K.8 which does not exist. However, it in clear that contaminated evacuees could reach a host site and wruld logically l
be best decontaminated there. This is exactly the issue I'm raising.
Having radioactive mnterial around a school where young persons (more sensitive to radiation than the general population) might 1
Yet it would follow from this be exposed, Set J.12 nowj*
e.g. 3. tomakes sangeb5-&LoM tvood) .f evitcu:e5 AmW& Ct Splan. f4//g Re contention b 240, the plan does say decontamination would be set up at anoropriate po',nts, but it doesn't pre-plan for likely h sites or a detail how this would b's done. E.g. the nnin decon -
method I know is just washing, with lots of water, scrubbing, maybe c79/
SGI haurist haircutting or shaving in addition. Where are the water g supplies? What are the decon methods? The plan doesn't rive g[g enough information to be workable under 10 CFR 50 47(b)(10) M6/4t/
(range of actions) and (a)(1)(assurnnee of workability) .
He contention 239, it is discussed above with 30 and 30A. d, nere I'd only add that the plan, pt 1 p.47, etc as cited in P38 4 directly above it) is what is referenced.
238 is quito specific about the problen. Use of KI is reconnonded by authorities such as TVA, for the general public around nuclear 1
plants (e.g. Sequoyah). l 237 is a candidate for consolidation. The nickup points are not specified, the vehicles to be used for pickpun are renerally described only, and the estimate of evacuation for non-nuto-owning populations must also take into account strees effects (behavioral aspects) and peak demand on trnAAAnsport (NURD1-065h, 1 App 4, pp 9-103 see !!MM study, section 6.2.12d paragranh or thereabouts for some handwaving that doesn't consider these factors in any sensibly detailed way.
l
-1k-Contention 236 on the mobility innaired, is snecific. Applicants appear to think a transport resource is " designated" by a generality like " local rescue squads or ambulance services will trans ont the
' patients". Wrong. Which vehicles will go where? When are these haki vehicles available? What's their backupl The measures have f to work,10 CFB 50.47(e)(1), or be reasonably assured to work. l l
You can't get such assurance from the plan's generalities. ]
Ditto for #235 (These were separated due to the 100 word rule, !
and might be consolidated with Dr. Wilson's contention on ambulance ;
transport). j Contentions 233 and 234 should be read as saying the plan :P is inadequate because it doesn't reouire the assessments they i talk about at early enough times to make evacuation workable. ;
This involves 10 C7R 50.h7(b)$10) in addition to the cites in !
the contentions. These might be consolidated with sinilar i
contentions discussed above. The plan cites are adequate as are i
the rules cites and o654 cites. ;
The communication criteria relevant to contentionf232 (
and 231 are in NUREG-0654 II.F (ref 10 CPP $0 47(b)(6) same language): !
I provinansions (must) exist form prompt communicat! ons amone
! mzahma principal response organizations (including school's) and to emergency personnel (e.g. bus drivers ) and to the nublic. (enph. added):
The plan, pt.1 pp 74-75, identifies commercial telephone as the main communication with state & local govt agencies (e.g. schools) with l
.2 way radio as backup and state patrol cars as backup to that, but l t
there aren't enough state uolice cars to reach each school bus (if ther are 100 involved as Applicants allege), and the buses don't have radios.:
The plan, pt1 p.47, says shhool buses or other transnort will be used ,
but doesn't seem to say how this transport will be notified to begin evacuation school children.
I recommend 57-C-4 & 5,117,117A and 118 alpo
.-.enough writing, I'm tired and maybe sick again. /[t/h,. but this is9
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