ML20087P521

Partial Response & Contentions 157 & 151 Re Offsite Emergency Plan

ML20087P521
Person / Time
Site:	Harris
Issue date:	04/03/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20087P522	List: ML20087P521 ML20087P525
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8404090124
Download: ML20087P521 (3)

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G UNITED STATES OF AMERICA Anril 3, 198h DGCKpfp' NUCLEAR HEGULATOH'I COMMISSION ussa u

'84 Apg 5 p3gg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '

Glenn O. Bright 9EQC?fr sicy7 Dr. James H. Carpenter * "" M PG4sEr.  :

James L. Kelley, Chairman #'%

In the Matter of

) Docket- 50 400 OL CAB 0 LINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No . 82-h68-01

) OL Wells Eddleman's Partial Responce and Contentions re Emergency Plan (Offsite)

Due to illness and othar work in this case and etic, including my teaching job, I have not yet completed a review of the Emergency 1

Plan. However, I have sore assistance promised from a volunteer expert, and am filing what I can today. Per oral order in the

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March 8,1984 conference call (transcribed), this niending diso addresses certain site emergency plan contentionst- 157 and 151.

(see TR 778, Mar. 8 'Sh call)

Re contention 151, it is not clear the doctors will actually have training adeauate to cope with radiation-induced in.tu-ien at Harris; also it is not clear whether the doctors are bound to stay in the area near Harris or to continue to be bound by their agreements in the fugture.

1 Under an agreement with Staff counsel and Apnlicants ' counsel, orally approved by Judge Kelley, I'm to file what I can now, and the rest by April 9th. The exnert has not been ava!1able recently; Applicants' failure to conolete the Energency plan filing cs scheduled has turned out to put it in a. tine frane that the exnert hcs .less time available in. Whatever is connleted will be sent to Board, Arnlicants and Staff asa completed, and to other parties April 9, by infc,rm81 arrangement with Applicants.

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.Concerning contention 157, Apolicants argue (as they almost always

'do)- that you can't make them be one whit safed than the rules require.

But in fact, a logical connection between a nroblen and failure to protect the public health and safety is also grounds for a contention.

The TSC nust be able to perform'its functions in the tense, nanicky atmosphere of a real general energency -- nerhaps even a Class IX accident. Human factors must be adequately considered under conditions of high stress, crowding, possible panic, information overload, tiredness (e.g. an accident lasting for several days, e.g. TXMI-2),

and the ability of the equipment to reduce rates of error, provide needed information, and be used continually under such condit* cts.

Obviously, for exannle, adequate information about the heicht, sreed, direction and location of any radioective nuffs or niunes leaving the olant is vital to protecting the nublic health and safety during an accident, for setting up sheltering or ordering evacustion.

Contentions re emergency plan:

-200. The narticinating organizations 's signatures are not provided. At a public meeting in Chapel Hill NC, recently, as nart of the UNC Symnosiun 198k, Dept of Crime Control and Dublic Safety emergency nlanners stated that this was a oreliminary nlan. Thus, the clan is incomplete and not ready to be implenented. There is no assurance it will be inplemented since no one has signed it.

The NC Dept of CC&PS considers it a draft only. Without participating

. organizaticns, the nian cannot work. Mr. Leon Canno, a menber of

'the'NY governor's Shorham. task force, stated as much at the UNC meeting.

201. The nlume exoosure nathway is falsely based (unrt 1, n.1, iten. -II.A.3.c)on the assunption that in the worst- core melt sequences, immediate life threatening doses would not occurs outside the lo-mile x zone. For contradiction of this, see NUREG/CR 2230, pp. 2-hh, 2-k5

'and 2-k8 which point out how lives can be saved by sheltering out to 25 L

. u milac fxfon a nuclear plant in a severe accident. Note that conversion by the f actors in the tables on up 2-21/22 and (p. C-4 & (chart) for Harris sitepopulation{p.0-20) don'tzerotheearlyfatalities out to 25 niles. Nor does correction for 900 M'cle (Harris) vs. 1120 in NUREG/CR 2239.

202. PP. 2-h2 and 2-k3 sknx of NUFRG/C9-2239 show that in a worst case substantiel early fatalities would result out to 25 miles around a reactor accident, yet evacuation to 25 miles could reduce fatalities significantly, a factor of 5.2 in the nean case and 2.5 in the 99$-ile (near " worst") case. The plan, p.1 of nart 1, is thus wrong to set a 10 mile evacuatien distance based en the assunction of no early fatalities outside 10 miles fron the riant.

See P. C-E rc SST1 accident at Harris. Feduced effects due to Harris being 900 MWe instead of 1120 are only about 32 20%.

203 Page 4, iten 5 sayas it vill take about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to get the SERT (State Energency Response Tean) assembled. But in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the 7+ nph average wind speed around Harris, a niune can travel about 15 niles. Thus the plan is not adequate for ranidly developing accidents or unexpected radiat'on releases, e.g.

from an ATWS accident or fron a tower excursien accidert blowing the lid off the reactor vessel (American Physical Society, review of Rasmussen Report, 1975 Supplement). The plane will be over people before the plan is functioning.

204 Plan, page 13, noints out the lack of radiation erotection on National Guard helicopters. No other method of radiation;orotected evacuation for victins or natients who need life-suuport is nrovided.

This is inadequate nvotection of such va" sons, e.g. # rom Avex hospital within 7_ miles d'f Harris plant. .

205. The plan is inadequate for ovacuation under snow conditions, which would also produce 1srge radiation doses under the clume. Most Carolinians cannot drive well in snow; panic would contribute to accidents especially for evacuation at night in a snow storn. There would not be sufficient transnort to evacuate hospital and nursing home natients and prisoners anda persons w/o tronsnortation under such conditions.

Accidents would lead to bottlenecks and prevent successful evacuation.

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