ML20095H310
| ML20095H310 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/20/1984 |
| From: | Lodge T SUNFLOWER ALLIANCE |
| To: | |
| References | |
| OL, NUDOCS 8408280437 | |
| Download: ML20095H310 (30) | |
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August 20, 1984 I ,-
UITITED STATES OF ATRICA NUCLEAR REGULA'IORY CCI. MISSION Before the Atanic Safety and Licensing Board In the Matter of )
)
THE CLEVEIAND ELECTRIC )
ILLUMINATING COMPANY, ET AL. )
~~
) Docket Nos. 50-440 Ob (Perry Nuclear Power Plant, ) 50-441 O L.-
Units 1 and 2) )
)
SUNFLOWER ALLIANCE'S PARTICULARIZED OBJECTIONS 'ID PROPOSED EMERGEICY PLANS'IN SUPPOfU OF ISSUE NO. I Terry Jonathan 1.odge, Esq.
618 N. Michigan St. , Suite 105 Toledo, Ohio 43624 (419) 255-7552
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, Counsel for Sunflower Alliance,
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, s, I. IITTRODUCTION By its July 26,1984 "MemorandLm and Ordert," the Board directed Sunflower Alliance, Inc., Intervenor herein, to:
[S]pecify in a written filing the specific inadequacies alleged to exist in the draft w local and state energency plans and . . .
[to] provide a reasoned basis for believing that the allegations ccnceming inadequacies
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are true.
Sunflower herewith submits its specific, particularizdd objections. By so doing, Sunflower expressly reserves the right to specify further objections concerning imdequacies in state, local, and on site emergency plans, and to object further to planning bases or other linkages between onsite and offsite plans.
II. OBJECTIOtB A. Evacuation Tirre Estimate Defects By IUREG-0654, Applicant is constrained to afford opportunity to " organizations (State and local) involved in energency response for the site" to review and ccmrent upon Applicant's estimated time require- ,
ments for ccnfinnation of evacuation. Id. at 61, 4-10. This procedure is apparently designed to allow "[s]pecific reccnmendations for actions that could be taken to significantly improve evacuation time" to be made.
Id. at 4-10. Regulatory guidance frposes the additional obligaticn that where significant costs nay be involved, pre-liminary estimates of the cost of inplementing
- these revuue-daticns shall be given. .
n Id.
' Nowhere in the draft state and local organizaticns' plans was .
any note made of having afforded the latter any opportunities to ccmnent or review, nuch less to propose i-(cumadations for inprovenent or quanti-fications of the costs of those inprovem:nt.;. All of these probleus have previously come to the rotice of the NRC Staff. t0 REG-0887 Supp. 4 at 13-16.
Applicant also has failed credibly to address the effects of adverse weather (1. e. a thunderstorm) on a surmur Sunday evacuation.
Id. "[ A] northem site with a high sumer tourist population should 4 ,
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- consider rain, flooding, or fog as the adverse condition as well as snow with winter population estimates." IUREG-0654 at 4-6,7.
B. Lack of Identification of Route Impediments Draft state and local plans neither identify, nor propose options for dealing with, potential inpediments to use of evacuation routes, required by NUREG-0654 at 63. For instance, no discussion of a e . I g snow emergerry appears. Ib discussion of the logistics of evacuating the supposed thousands of ccristruction workers who will be laboring to ccm-plete Unit 2 at Perry appears to have been considered.1/ See also IUREG-0887 Supp. 4 at 13-16.
State and local goveninents have to maintain considerable hardware and road-clearing equipnent at quite a large cost for snow removal purposes - resources which are quite strained perhaps a dozen times in any given winter in the highland " snowbelt" east of Cleveland.
Were the Board to take official notice that the snow season is nearly five (5) nonths in length, it would be obvious that a major deficiency in perspective exists. For that matter, the plans should include considera-tion of low or no-power operations at PNPP through the duration of an
~ innobilizing period of inclenent weather (viz. ,the " Blizzard of "78").
C. Uncertain Chain of Carmand In the event of a radiological energency at PNPP, CEI staff are responsible for classifying the incident, activating the onsite energency organization, and notifying offsite authorities. IUREG-0887 Supp. 4 at 13-2.
'Ihe State of Ohio Disaster Services Agency (DSA), Adjutant -
.; General's office is the lead support agency to affected county govem-ments, and it falls to DSA to notify other state officials and locally-involved entities. Id.
l Ashtabula's County Conmissicriers will " control" Ections to be taken. See State Plan, Rev. 3 at 5-31. Lake County's Ccmnissioners
.-. did.not even ra.,te a mention as to their roles in the State Plan. Id.
at 5-25. In the event of a " general anergency," where protective steps must be taken for the public within a lO-mile radius of PIPP in as little 1/ This nay be a self-correcting mutation, however.
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- as 15 minutes, Ashtabula County's " Radiological Emergency Response Plan" (RERP) states that its County Cmmissioners will " order" shelter or even evacuation, based on advice of County staff and "reemmendations" of the Govemor's office. Id. at 4. See also Lake County RERP at 1. See also State Plan, Rev. 3 at 5-27, wherein the Lake County Prosecutor c,. . advises on mergency authorities ,and proclamaticns. In sum, there is ,
no consistently-defined role in a major or minor mergency for County Ca missioners, especially in conjunction with any leadership which would be forthcoming frcm the State.
Sadly, the plans are deficient in a major technical respect.
Worse, in a major evacuation, they conpletely sidestep the logic and mandates of Ohio law.
NUREG-0654 obliges Applicant's plans to "contain (by reference to specific acts, codes or statutes) the legal basis for such authorities" of various component entities in emercy_ncy activities. T h here does any such documentation or discourse appear. Iereover, the tenor of the state and local plans ignores the overwhelming fact of Ohio law that only the Govemor may declare an emergency. O.R.C. 5915.Ol(D) defines "energency" as:
[A]ny period during which the president or the con-gress of the United States or the covemor has pro-claimed that an mernency exists.
(sphasis dupplied)
'Ihere are legal and policy reascns for the requirement that the Govemor-declare an emergency. Ohio has a " good Samaritan" statute -
for persons assisting during a civil defense emergency, which only pro-vides coverage and irmunity frun civil liability upon declaration of an '
mergency by the Govemor. R.C. 5915.10. 'Ihat section of the Ohio Revised Code states as follows: .
(A) 'lhe state, any political subdivision, 4 ' municipal agency, civil defense volunteer, or another state or a civil defcnse force thereof or of the federal govermont or of another country or prevince or subdivisico thereof performing civil defense services in this
-state pursuant to an arrangement, agrement
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or cmpact for nutual aid and assistance, or any agency, me::ber, agent or representative
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of any of them, or any individual, partnership, corporation, association, trustee, receiver or any of the agents thereof, in cood faith carr'/-
ing cu". ccuplying with or attempting to carply with any law, any rule, reculation or order duly pretulgated or issued pursuant to sections 5915.01 to 5915.143 inclusive, of the Revised Code,. any federal law, or any arrangenent, agree-
"* ment or conpact for nuhm1 aid and assistance or any order issued by federal or state military authorities m1ating to civil defense, shall not be liable for any injury or death to persons or damage to property as the result thereof during training periods, test periods, practice periods or other civil defense operations, or false alerts, as well as during eneny attack, actual or inminent, and subsequent to the same except in cases of willful misconduct.
(ertphasis supplied)
In the past two years, perhaps a dozen different decisions of the Ohio Suprene Court have virtually destroyed the doctrine of
" sovereign innunity" which has traditionally protected govermental
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units from civil liability for mistakes of its officials. However, there
- has not been a civil disaster the magnitude of an extraordinary ruclear -
occurrence to test what may remain of local goverTTnent inttunity under this faded doctrine and R.C. 5915.10. Under the draft plans, local officials such as Ashtabula County Ccmnissioners might expose them-
- selves and the numerous civil " volunteers" cortprising the backbone of goverrrnental respmse to the potential of civil nonetary damages by
% " proclaiming'_' an energerry absent an official pronouncement frun EJ * ',,g ****. -gr s. { ,,
Ohio's Governor. One can imagine Ashtabula's County Cortmissioners
- " proclaiming" an erterN and orderirx[rherely shelter, as opposed 4 C ~ to evacuation, to avoid liability for such problems as a dru1 ken or
, .. drugged or exhausted volunteer bus driver's antics, while all the while am .
~ the Lake County Carmissioners " proclaim". an evacuation and direct all' emergency personnel to cut and run. Besides the enontous inconsis-h -
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gg- d and safety, Sunflower wonders if local officials really want to roll the dice of nultimillion dollar liability by ordering all in the EPZ not to evacuate. What are the liabilities of a county catmissioner who votes to " proclaim" an ,
eregency in the absence of the Govemor's proclamaticn, but instead v u .,
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- of ordering evacuation, orders shelter only, thereby comnitting hundreds or thousands in the p1trne exposure pathway to toxic radia-tien poisonirxp Cmplicating these issues is the official guidance for decision-making. NUREG-0654 at 1-3 states that:
Prutpt notification of offsite authorities is~ intended to'irvlicate within about 15 minutes for the unusual event class aM sooner (consistent with the need for other eneroency actions) for other classes. The time is measured frun the time at which operators recoanize that events have occurred which make declaration of an energency class appropriate.
(erphasis supplied)
See also 10 CFR 50 App. E (IV)(D)(3).
Finally, all of the legal and liability considerations riust be' set against the unforgiving backdrop of the federal Price-Anderson Act. Under that Act, be it renembered, CEI and the remainder of the utility industry are absolutely irinune frun liability above $585 million for damages accruing frun an extraordinary nuclear occurrence. .
Ohio's public officials will have little or no recourse against Perry's
- owners in the event of leakage of fission matter frun a ruptured contairrnent for a penny ricre. 'lhe State and its ocunties will have to withstand challenges to the " privileged" or "irmune" acts or omissions of their officials alcne. In effect, the draft plans shift the liability burdens for ernneous decision-making to public officials m .. '
w5 in a manner quiteretniscent'of Price-Anderson's burden-shifting of n.
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m civil liability.
'Ihe fractured and fragmented web of decision-rroking on
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emergency declaratier_s is unworkable and illegal. Either the State
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c nust~be ab1'e to cannit unequivocally to declaration of an emergency
, within the gdideline prescriptions as to time, or the offsite plans ,
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D. Protective Actions Decision-Making At Table 6-1 in the State Plan, Rev. 3 (appearing at 6-16),
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the option of renaining indoorss is desned to be adequate protecticn of the public when shelter affortis less than 5 rems of whole body a y . -.
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- ganma dose exposure. Shelter ccntinues to be prestned adequate when the " shelter dose" of radiation equals or exceeds 5 rems, but the
" evacuation dose" equals or exceeds the " shelter dose." Only when the " shelter dose" exceeds the " evacuation dose" is evacuation indi-cated, so says the State Plan, Rev. 3.
These proposed acticn $pdicators are faulty in several ways.
First, Table 6-l's footnote irviicates that "[s]helter is to be with ventilaticn ccntrol," the latter term treaning that air conditioners and fans are to be tumed off, doors arxi windows closed, and mfuge sought in baserents. 'this guidance is unhelpful and potentially disastrous if hundreds are trapped in a rest home, shopping center, or school in the plume exposure pathway, on a 95 degree August aftemocn -
or a 5 degree January one. Many rtodem buildings have unclosable venti-lation required by law - another ponderance.
FurthdrTrore, Applicant has ignored the plain intentions expressed in guidance frrm the U.S. Envin. ment,al Protection Agerry.
In its " Manual of Protective Acticn Guides for Ibclear Incidents,"
EPA 520/1-75-001 (Sept. 1975) (Rev. June 1980), the EPA has stated at Table 2.1 that whole-body exposures to airbome radioactive materials
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for the general public should not exceed 1-5 rems. In the footnote to the table, EPA asserts:
i When ranges are shown, the lowest values should be used if there are no major local constraints in providing protection at that level, especially to sensitive populations.
- " local, ccnstraints may make lower values '
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impractical to use, but in no case should the higher value be exceeded in determining the ,
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need for protective action.
Id. (estphasis supplied)'
CEI and involved local and state govertirents have no apparent .
corpunction about refusing to follow this authoritative guidance. It is h.anily unimaginable that blind adherence to a set of standanis that flies in the face of better sense and authority will ccxrpound public panic. There are no proposals in state and local plans to evaluate the relative degrees of " ventilation control" within each and every
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structure in the EPZ; hence there is no possibility at all that even
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the best-doctxnented analysis of plume pathway exposure will suffice to back up public officials' reccmnendaticns of shelter, because of the wide range of variability in ventilation contruls.
E. Authority Lackino for School Bus Usage Under Ohio law, it is quite clear that school buses may not be put into service as a cortpcnent of any offsite evacuation .
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precedure.
De Federal Emergency f/anaganent Agency (FDR) has previously noted this. FEMA Interim Report at 13. Sunflower is aware of the May 27, 1983 letter to the Ohio Disaster Services Agency (ODSA) frun Hennan L. Massie, Chief of Pupil Transportation for the state Department of Education. See FD% Interim Report, App. B. W at letter, in ipse dixit fashion, concludes that the code of state adninistrative regulations, the Ohio Administrative Code, authorizes the use of school buses in the event of a civil energency. 2 OAC %33Ol-83-12(L). Scrutiny and analysis is nonetheless in order.
Ohio statutory law clearly and flatly prohibits the use of school buses for nonschool purposes. R.C. 3313.172 states:
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We board of education of any city, exertpted village, local, county, or joint vocational school district may expend district funds to obtain one or trore motor vehicles, as defined in section 4501.01 of the Revised Code. Except as pro-vided in section 3327.14 of the Revised Code any motor vehicle so obtained shall be used solely for school purposes.
(arphasis supplied) <r -
Ib exception appears in the statute. ,
R.C.'3327.14 states, pertinently:
Ee board of education of any school district that owns and operates buses for transporting pupils may contract under a lease agreencnt with a trunicipal corporation or a public or rrnprofit agency or organization delivering services to the aged, to make available one or trore of the dis-trict's buses or other vehicles to be used for transporting persons sixty years of age or older.
We board of education of any school district may als: contract under a similar agreement with any group, organization or other entity engaged in adult education activities.
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. Again, there is no recitation of any legislated right for school buses to be utilized in a civil emergency.
'Ihe State Board of Education in 1970 prurulgated 2 OAC 3301-83-12 allowing "nonroutine" use of school buses, subsection (L) of which appears as follows:
School busesunay be used by Chio governnental
agencies during time of civil emertjencies. Ques-tionable use should be clarified with assistance of the department of educaticn (Exmple of a civil energerry - Ohio national guarx1 resergs require transporta:1cn to a threatened area).-
'The problen is sinple: assuning that on questions of substarx:e, statutory law govems over adninistrative regulation, there is no proper legal fundament for the Ohio Department of Mration to have short-circuited facially obvious legislative mandates. With all (be respect to the Deparbnent of Education, this conflict at a mininun might benefit frun input frun the Department's lawyer, the Attomey-General, and not sinply lay interpretaticns.
'Ihis is not merely a lesson in jurisprudential obscurity.
R.C. 3327.14 obligates a board of edv'nticn lending bus equipnent to maintain liability insurance cberage in'accorxbrx:e with R.C.
3327.09. 'Ihe latter mandates liability coverage of $100,000 per person / $300,000 per occurrence / $50,000 property damage coverage /
$3,000 medical payments coverage. Besides the conflict between statutes and regulation, there is also the previously-discussed difficulty.
which any board of education would have in obtaining liability w ~~
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j, : negligence chring a nuclear emergency. iR.C. 5915.10 provides innonity _ _ ,
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frun. liability to persons perfonning during a civil defense emergency with an exception: "[E]xcept in cases of willful misconduct." R.C.
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Iri practical tenns, the boards of educaticn in Lake, Geauga
- and Ashtabula counties"which have been approached by CEI$r respective county officials would do well to contarplate realities. 'Ihose reali , * '
. ties.are that in case of a major nuclear accident, panic will predominate; 1 .,,
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2/ 'Ihe regulation was doubtless established in response to the
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use of Chio National Guard perscmnel at Kent State thiversity,
. where on May,4,1970 a ch'a pter in American ignominy was' written. _ , , . ,, [. .
At' any rate, citizen evacuaticn by bus was evidently not contem-plated at that moment.
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~ that boards of education ertployees may refuse to " volunteer" to drive into or near the plume exposure pathway to evacuate citizens of any age, necessitating substitute, possibly less apt, drivers to take the wheels; and that any drivers may well take incredible chances in excessive traffic, causing une almAable physical harm to passengers.
leio wi5hes tio be first titest a ipo,orly-masoned regulaticn " authority" in defense of nultimillion dollar damage actims brought by angry plaintif5Ei who camot successfully sue CEI because of the Price-Anderscn Act?
Once again, the overall uncertainty of "who pays" - when the friendly utility ccrtpany will not - should be an inestimably major factor in local ee n tion officials' thinking.
F. Insufficient Proofs of Volunteer Aid 10 CFR $50.47(b)(2) requires etertymcy plans to specify .
" interfaces among various ensite response activities and offsite support and response activities. . ." 'Ihe state and local plans are deficient because they fail to fix in unequivocal fashicn the availa-bility of, volunteers - medics, police auxiliary people, bus drivers, civildefenseworkers[etc. IUREG-0654 requires (at 41) that:
Each [eTergency] organization shall identify. . .
individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified and stypc,rted by appropriate letters of agreement.
The plans contain no such estimates. 'the parties were
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., , ~ . 7at on notice 1cng ago of-this inadequacy,by a study cortmissioned by the Perry Imgal. Defense Fund, "Stata.ss Report: ..Plaming for an .
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~ Accident at the Perry Nuclear Fower Plant!' (1983)', provided to all
, through seasonable discovery update. 'The PLDF Status Report surveyed 4
- ^ the circumstances of notic'e to emergency and volunteer personnel and lacking formal arraagnents extant betwem public and private emer-g .
h gency response agencies and CEI. . *1he stirly revealed considerable superficiality of knowledge of radiation hazards anong this grouping of personnel, stenming possibly frtm the failure by Applicant to
[ndividually fix each person's volunteer status. Obviously, the insti-tutional' response organizations - fire departments, police auxiliaries, boards of educaticn - are not in a legal or, moral -
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' individuals who would be placing their personal health on the line in the event of a general emergency. Quite arguably, individual would-be volunteers who are asked to sign their names to broad form waivers or releases from liability might determine not to volunteer so readily.
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G. -Failure to Stockpile'KI fqr Public and Emergency Personnel Glaringly cynitted from the plans is any cmmitment to the use of potassiun iodide for emergency workers and the public as a thryroid radiation blocking agent. See FD1A Interim Report, App. A, where Ohio's Director of Health rejects the idea.
10 CFR $50.47(b)(lO) requires offsite plans to denonstrate:
A range of protective actions have been developed for the plune exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emeroency, consis-tent with Federal cuidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the local have been developed.
(erphasis supplied) . ,
'Ihe use of stable iodine as a protective action for emergency workers has been the retumcadation of the U.S. Envirersnental Protection Agency for four (4) years. EPA Manual of Protective Action Guides, supra at 1.42. Furthentore, CEI reconmends it for its own workers, in concurrence with U.S. Food and Drug Administration regulations. .
Finally, bUREG-0654 requires (at 63) that plans show "[p]rovisions for
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State officials announced in May,1984 that the Department ms
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of Health is forming an advisory group to research the use of KI tablets. " .
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Sunflower urges that the offsite plans will not be approvable unless
. KI supplies are maintaineci for workers and the general public.
H. Inadequate Assurancb of Worker Protection- -
., ,; 'Ihe offsite plans are inconsistent one-the subject of allow- .
ird~ emergency workers to receive whole-body and thr9/roid dosages of ,
radiaticn. TUREG-065'4 obligates planners (at 60) to correspond
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Emergency Action Ihdels (EALs) to projected doses to the population, .
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and its' rs.umutlations in the EPA Manual of Protective Action Guides.
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The Manual sets limits for mergency workers of 25 rem whole-body and 125 run thyroid; for workers performing lifesaving duties, 75 rem whole-body and "rn limit" thyroid. Id. at 2.3 and 2.5. The EPA mitigates its "rn limit" reccmnendation in footnote (b) to the table cn p. 2.5 in the follcuing manner:
No specific upperslipit is given for thyroid exposure 'since in the extrune case complete thyroid loss might be an acceptable penalty for a life saved. 'However, this should not be necessary if respirators and/or thyroid protection for rescue persconel are available as the result of adequate planning.
The inplications for the local governnents' refusals to use potassiun iodide are obvious as well as cxninous. Additionally, Sunficwer repre-sents that at least one emergency service, Ashtabula's fire department, neither has purchased nor will it be purchasing, equipnent such as respirators, because that is Ashtabula County's decision. What do other jurisdictions intend to do?
Lake County proposes the fantasy that it will rot establish
- any decision chain authorizing any perscn, mergency or otherwise, to exceed 25 rems whole-body exposure. FD M Interim Report at 15.
This is inconsistent with pre-existing State conmitments. Geauga County does rot prescribe any decisional dain for authorizing excessive exposures of over 25 whole-body runs.
All thme of the counties' plans are unacceptable in that, while each may be forced ,to delineate a decision-making chain to
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determine whether exposure limits may be exceeded, there is no "
relevant diccussion explaining how the Qtio Department of Health, i CEI Department heads, and county officials will be able to rmder dozens, hundreds or thousands of such decisions allowing excess exposures 'in~the cataclysmic nonents following a breach of contain-ment or other ccnsequential pluning radiation. In this and other
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respects, the critical noments after major radiaticn leakage are viewed by planners with severe roseate ocular distorticns.
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'Ihe PfFP Plan, Rev. 3, cl6arly indicates that CEI never intends to sound a general cxnergn:y t.hich watild necessitate prutective actions beycnl a 5-mile radius of Perry.
/
'the plan contains a Figitre 4-1, which has no page number, headed " Dose Rate at Contairum*. /4xrttor." Fcur (4) curves appear on that graph, representing theomt' cal curves of gross gamm dose rate versus -tirre. 'Ihe plots concerr. these possible reactor statuses in the event of realfunction:
- 1) 100% coolant release with no fuel damage; 2). 10% gap activity release with 1% fuel inventory
, release;
, , '5 ) 100% fuel damage with potential core melt.
'Ihe four curve.; ccnprise the basis for plant status protective acticn guides. At p. 6-11, the PtFP Plan states the follcwing protective actions:
i Indica.
.- -tie.n_ Prutective Actions. .
- 1. Above Curve . - 360 degree shalter to 2 miles
_ , . - Precautionay shel ter 22.5 degrees on both sides of the plune center line to 5 miles
- 2. Above Curve 3 - 360 degree evacuation to 2 miles
- 300 degree shelter between 2 and 3 miles
- shelter 22.5 degrees on both sides of the plune center line between 3 and 5 miles
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- 3. Above Curve 2 - 360 degree evacution to 2 miles
. - evacuatic.n 22.5 degrees on both c.,
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- shelter tetween 2 and 3 miles in l unaffected areas
- 4. Above Curve 1 i
- 360 degree evacuaticn to 3 miles
- evacuation 22.5 degrees on both g'
sides of the pluae center line
, between 3 and 5 miles
- shelter between 3 and 4 miles in 9 unaffected areas I '
In the worst possible scerurio, the 100% damage of the fuel with poten-tial coru ric1t - the Cid.1a Sy'i drure" -*Cleveland Electric Illuninating t
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' reewmuds a ccrrplete evacuation out to three miles frun Perry; supplemental vector evacuations out to 5 miles; and shelter in
" unaffected amas" between 3 and 4 miles frcm Perry.
The IEC Staff has expressed strong misgivings about CEI's cavalier approach to setting out its respcnses to varying levels of emergency plant malfunction.\ Seq 1,etter of B.J. Yomgblood, Chief, IIRC Licensirg Branch No.1, dated January ll,1984, with its "Ccrrments on Perry Nuclear Power Plant Drergency Action Levels."
10 CFR $50.47(c)(2) states in part as follows:
Generally, the plune exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles (16 kn) in radius and the inges-ticn pathway EPZ shall consist of an area about 50 miles (80 km) in radius. The exact size and con-1iguraticn of the EPZs surrounding a particular y nuclear power reactor shall be determined in rela-ticn to local atergency msponse needs and capabili-ties as they are affected by such conditions as
- demography, topography, land characteristics, access routes, and jurisdictional boundaries. The size of the EPZs also may be determined on a case-by-case o basis for, gas-cooled nuclear reactors and for reactors with an authorized power level less than 250 FM thermal.
(atphasis supplied) tereover, the standards run directly counter to the EPA's recmmendations whicn appear in its Manual of Protective Action Guides, supra at 2.5:
When ranges are shown [of projected tnyrmid radia-
- ticn dosage ~ frun inhalation of a passing plumel, the lowest value should be used if there are no major local constraints in providity; protection _
$ - , . at that level, especially to sensitive populations.
Worse still, Cleveland Electric Illtrninating ignorts the rather bltnt guidance found at IJUREG-0654, App.1,1-17, "Exartple Initiating Conditions; dencral Dicryency," where drastic actions are g.m to be taken when EPA protective acticn guideline levels as measured at the PtIPP site boundary are " exceeded by a factor of 10 of projected I
to continue for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />." 1hc same secticn advises further:
For core rtelt sequences Where significant releases frun contairrtent are not yet taking place and con-tairnent failuru Icading to a direct atriospheric rulcase is likely in the sequence but not inminent and large triounts of fissicn prufacts in addition to nobic gases are in the contairvrnt atmosphere, E b k S [ M N. %
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cmsider precautionary evacuation to 5 miles and 10 mile downwind evacuation (45* to 90' sector).
Id.
Mere staff skepticism over CEI's poorly ,.useptualized e:rergency action levels is not an adequate remedy here. On March 10, 1982, D.R.-Davidson, CEI's Vice-President, System Engineering and Cmstruction, wrote to the TEC's Robert L. Tedesco:
As you are aware, emergency plaming activities are a burden on both the utility and local cormunity in terms of both financial and hnan resources.
If the basic arergency plaming zone were reduced by NRC from. ten to five miles, for exanple, the planning area would be reduced by a factor of four. In our specific case, a five mile plarrnng zone would encompass only me cconty instead of three and contain significantly fewer people.
a.
Effective planning and development of a prurpt notificatim system depends upon an- accurate esti-mate of exactly where the public-st-risk resides.
'Ihug, IRC should direct proTpt attention to the task of reevaluating the basic emergency planning
] assutptions to assure that the scope of energency planning efforts is accurately defined.
'Ihe Staff prenptly scotched that suggestion in an April 13, 1982 letter from A. Schwencer to Vice-President Davidson, noting that the underlying source terTns were considered ~now to be " conservative."
Nevertheless, Applicant is row trying unilaterally to get away with that which the Nuclear Regulatory Ca: mission has forbidden, sinply _
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F - ~' by postulating no plant accident scenarios which might require '- _. y .
R- 1. . . . evacuation .beyond an .5-mile ~ radius of Perry . Nuclear Power Plant. - -
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.m p .t'lhe Atomic Safety and Licensing Board in its July 26, 19842 "Mmorandan and Order" to Sunficwer to particularize its emergency
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pla'nnibngobjections,'churlishlychidedthisIntervenorinthefollowing
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- emer1gency plans are not finished. Yes, there are additicnal steps being taken to nodify and further
%r inprove those plans. However, the plans have reached a mature stage of developtent and it is time. _*'
. ~. .L 1. fob 2intervenors to state their objections so that
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Id. at 3-4.
Unfortunately, it tis Applicmt, not Sunflower, which is
. ,, , i ,
approachirg emergency preparations as a game. The core assmption -
perhaps CEI's assmptions about the PNPP oort is nore accurate - that no credible accident scenario will necessitate evacuaticn beymd 5 miles is counter to the regulations, the philosophy, and the rational basis underlying the entire offsite plaming process. The State of Ohio and the three affected counties evidmtly have adopted these fallacious fundamentals lock, stock and syndmne, which of necessity corrupts and casts doubt over every assmption conceming protective
~ -
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actions contained in the plans.
Sunflower submits that it is far nore appropriate to " lie in wait" than to wait and lie.
J. The EALs are Incmplete
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function status scenarios at Perry, with detailed tell tale signs of operation or failures of operation which would dictate the type of eTergency actions to be taken. Besides the earlier points raised, the EALs thouselves are not technically a3Tplete.
Time and again as one reads Table 4-1, one sees critical 3 : .measurunents.or standards c - .- left inccuplete, marked "later." ,
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Atomic Safety and Licensing Board has ordered Sunflower to go forward
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based upon plans which, albeit constantly evolv'ing, are at this"juncturW '
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+ rather prehensile,1 respecti'ng the neans by which Applicant proposes
-to initiate energency responses. , ,
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PerhadbApplicantcansupplythemissingcriteriasothat -
_ this proceeding might go forward based tpon due andproper notice, .a -
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., < lang-recognized prerequisite for litigaticn outside of administrative l
Cases.
K. Inp ement5ticn of Staff Recamnendations on EALs
...e i The Staff provided ccaments to Applicant by letter dated l
- e January 11, 1984 correrning the eTergency action levels. (letter frun -
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L. Radius of the EPZ
~
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'Ibe emergency plaming'zcm (EPZ) to which evacuation responses nust be directed nust have a ten (10) mile radius, a fact quite well established, why, then, does the Final Envirormental State-ment (FES) prrpose a radius of effectively fifteen (15) miles?
At F-2 of the RES (IUREG-0884), the Staff discussion of evacuation modeling for Perry states:
'Ibe evacuaticn distance is selected to be 15 miles (which is 5 miles nore than the 10-mile plune exposure pathway EPZ radius). After maching
. _ the end of the travel distance the evacuees is asstrned to receive no further radiation exposure.
'Ihe inescapable assutption inplicit in this statement is that one might sustain radiation exposures within a 15, not lo-mile radius , :. . before reaching safety.
~
Sunflower demands that the EPZ radius be increased to 15 miles or nere to confonn to this cminous asstxrption in the Final EIS.
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M. Independent tenitoring
. Lake County proposes to install and operate an independent I. -
, alert nonitoring system ccxtprised of stations throughout the County
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CX1 L!m-. monitors. Data fran this . equipment is to be telemetered to a central .
t location, with noney for its -
purchase to ccme frcm CEI. "(Second Set) 1 ..
- - .- A Responses to Interrogatori,es Filed by Sunflower Alliance, etc."
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9 Sunflower wishes to know to what location this data is to be v- ~::
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telemetered; how'it 'is to 15e digested; and what use is to be made of- -
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it'.' 'Ihese questions are not readily ansered by existing draft plans.
- Ir> fact, there are no listed functional purposes for installation or 4 use'of the equipnent, other than its obvious public relations utility. ,
Sunflower applauds the proposed installations, especially u . . .
.p g . since NUREG-065{ appears to require the use of. Independent da,ta sources,, . , ,
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and that state and local organizations have equipment and expertise to rapidly assess " actual or potential magnitude and locations of any radiological hazards." Id. at 54, 58. Why is there not corparable equipnent afforded Geauga and Ashtabula counties at Applicant's expense? For that matter, why should not CEI be directed to install ncnitoring equipment and related coordination throughout the area with-in a 50 mile radius of PNPP?
On July 18, 1984, the -trustees of Jefferson Township, Ashtabula County, Ohio, fonnally filed with the NRC their resolution to:
[R]egaest and support the installation and maintenance of independent monitoring facilities and procedures at and around the Perry Nuclear Power facility.
Noting Jefferson Township's location within about 20 miles of PNPP, it is obvious that if CEI is not willing to make unifonn an independent means of nonitoring and measuring radiation emissions near
~ ' ~ ~
PNPP, then it will be forced upon Applicant.
N. Ingestion Pathway Monitoring 1he plan enumerates steps that the State of Ohio is to take to nonitor and implenent pmtective measures throughout the ingestion pathway. Anong them, the Ohio Department of Health (ODH) is to provide technical input in these respects, incitriing the measurement, via
, 7- radiochenistry analyses,.of ganma ray enitting nuclides and alpha and beta emitting nuclides which may be present in soil, vegetation and other solid or particulate substances.
. A nujor obstacle to ODH's execution of its responsibilities in this vital capacity is that the Department does not have the equipnent capability to perform radioactivity analyses upon " hot" samples - those exceeding theshold limit values established by the National Ccmnittee on Radiation Protecticn. In an October 24, 1980 letter to the Stath Adjutant General's office Charles Cmft, Chief of the Division of Public Health Laboratories of ODH, noted that all sanples selected for testing must be "prescreened' in the field, and that ODH does not have container equipnent with lead linings for ship-
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An ingestion pathway could enccupass literally hundreds of square miles of agricultural countryside, with crops, livestock, ground-s water, firm equipment, trees, stored crops, seed, and such all in need smpling and nonitoring. It is' fatuous to assune that the State can j perform this very critical function, absent hard and extensive evidence of new equipnent and personnel resources. 'Ihe State clearly does not ccmply with the criteria in NUREG-0654 at 64 pertinent to protec- l tion of the public frcm contaminated foodstuffs.
O. Evacuated Area Re-Entry
'Ihe PNPP emergmcy plan does not adequately set forth plans
. and procedures for reentry and recovery of property within the 10 and 50-mile zones, nor does it set forth means by which protective measures are to be relaxed, all in violation of IUREG-0654 at 70.
P. Hospitals
-~ Hospital designaticns and medically-related decudominaticn procedures are inccuplete or absent frun draft plans. For instance, while Ashtabula County's Radiological Emergency Response Plan makes reference to the use of Ashtabula General Hospital to receive patients evacuated frun hospitals within the lo-mile EPZ, there are no studies of potential patient populations docunenting anticipated uses of the Hospital.,,Further,,there ;is rot a conplete inventorying of available i.
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resourres for deccntaminaticn of personnel or patients at hospitals G n ' r
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radiation injuries cn each shift; nor is'there any overview of what -
medical personnel might be available for other, not-primarily-radiolo-
'gical, ' injuries: looters / police / National Guard shooting victims; fire victim [; vehicular accident victi$1s; exhausticn, stroke or heart attack Y
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m victims, etc. Performing double duties for evacuated hospitals neans "
double duties in all other medical aspects of hospital services.
what procedures and resomces are available to minimize and record radiological contaminaticn of vital medical perscnnel? -
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rocms to be lead-lined? Will surgical gloves, masks, .
- **" Waprens, respirators be' radiaticn-resistant? -What' becomes of contaninated
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hospital materials, such as food trays, robes, sheets, medical supplies and unifonus, mattresses, pillows, etc.? How will radiation-sensitive measuring and. body-function maintenance equipment be protected? From whence will replacenent ' supplies, food, equipnent, personnel, etc. ccr:e?
-Q. Fallacioud Transportation Assunptions In Appendix 3 of the PNPP plan, at Table A3-7, the inplicit planning assunpticn is that .<wtool bus drivers would be able to make a single evacuaticn run to a reception center, and then would reenter:
the lO-mile radius EPZ for further services. 'Ihis assmption shows little conprehension of rural and small-town busing practice. Many children walk to schcol; many ride with parents; and the buses then- l l
selves frequently make two or more trips to and from schools. 'Ihe
. assmption fails if nore than a single trip occurs, with a ccnsequent ,
doubling of the needed time, merely to acconplish a primary .evacua-tien measure. A total of 21,393 children would presumably be evacuated.
At the assuned basis of 40 students per bus, 535 buses would be needed to effectuate a single-run evacuation of school children. 'nds far-exceeds the inventory of operating equiprent which is extant in EPZ-schools. Perhaps an equally great error is to assuie that 535 volunteer drivers will reenter the EPZ after making that single run. Where is the documentation of volunteer availability?
Prevailing school policies will allcn a parent to pick
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an emergency if a release form is signed
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,(might there be scme liability consideraticns after all?). Foreseeably
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within and without.the' lO-mile radius from PNPP (it would be naive to assme otherwise), janming traffic arteries and bottlenecking already-
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schoolyards... 'Ihe existing plans neither envision nor reredy the great potential for redundant bedlan of this cort. '
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% fog < L R. Insufficient Backaround Data Backgmund radiaticn readings nust be taken befom PNPP becmes operaticnal of the entim 50-mile EPZ. Radiation meters only
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measure " relative contamination- meaning that after an accidental i ,
release, radiation on an indivia ml will be indicated by equipment only in conparison with a then-elevated backgmund count. Under such circumstances, the reading on the person will be "lowballed" or understated, when by ccuparing it with pre-Perry backgmund levels, that reading might otherwise be severely high.
'lhe plans do not contain the necessary baseline data to have a systenatic set of pre-Perry levels. It is obviously of great inportance that readings be taken and logged now of virtually every inhabitable space within the 50-mile zone.
Utility ccmpanies have frequently claimed that the amount of radiation enitted from a nuclear facility during nonnal operations is equivalent to.a stroll through the mostly-granite Grand Central Station in New York City. To plan for the time when that claim may not be tme, and to confonn with NUREG-0654 at 67, it is inperative that this data ,be obtained, because an accident scenario will not give the opportunity to Applicant to leam the levels at which people
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nust be decuianinated.
S. Unavailable Extension Agent
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(RERP) requires that county's Cooperative Extensicn Service agent .
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to ' advise on food and livestock protection. McNever, in reality
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that perscn has received no equipment or training, and intemal Ser-4 c. vice; regulations require.h'im to take whatever steps are needed for 4 him to secure himself and'his family in ' time of accident. 'Ihis ccn-se t-
. flic,t_must be - formally -
-and clearly,, resolved.
. s. .
T. . Shelter and loading Buses
'Ihe EPA Prttective Action Guides docunent states at 1.38 as follows: .
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Generally, shelter provided by dwellings with
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g. off would pruride gaod protection from inhala-ticn of gases and vapors for a short time (i.e. , cne hour or less) but would be generally ineffec-tive after about two hours due to natural venti-lation of the shelter.- Sunflower objects'to mere, n. shelter precautions for any sus-
- tained release of any raagnitude for,the reason that in relatively still
~ meteorological conditions, it sinply 'is unrealistic to expect a plane of hundreds or thcusands of meters' length to " blow over" in as hour or less. The situation is worse still if the emissions in any one direction would be continuous for many hours, of course.
hhat if the auth6rities at first r&.umend shelter, but shortly afterward move to a full-scale evacuation? The PIPP plan at 5.5 indicates that school children could be loaded onto buses within the 30 to 90 minute range after the word is given. Apart frun the fact that no notor vehicle will afford even the shelter capabilities of a house, it is evident that the plans effectively could cause school children to evacuate outside under or into a plume.
. is lhe plans do not adequately address the problems which might befall the populations without individual transportation who are caught by the changing of gears frun less severe to nore severe protective actions.
U. Disposing of Contaninated Personal Property The proposed reception centers for the public do not
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, -ing or isolating personal.,property found to be excessively ccntaminated.
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for instance, is done with dozens of buses and other vehicles once evacuation is coupleted, if >they am found to be severely contaminated?
~
V. , Manitoring ContaminatSd Consunables 1here is little more than a lip service description of
- the role of the State and county p&lic health departnents in monitor-ing _the agricultural food chain. If a PNPP accident were to occur during a period of .significant harvest, hcw would officials ensure that all ccntaminated ' fan [ products were interrepted? tb crop insur-ance would exist. .to. ~,indennify farTners frun~ radiation losses. - It would
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not be difficult to envision desperate farmers, particularly at the far ranges of the ingestion exposure pathaay, rushing in a day or so after the accident, specifically to harvest and sell their crops quickly, . just to avoid public health scrutiny. To a desperate small
. businesperson in these cirumstances, the threat of sancticos after the fact may not deter such acticos. Once again, the existence of the Price-Anderson Act may actually: motivate private acticos out of economic considerations which are against the public interest.
We PIPP plan neither offers guidance, nor clearly specifies the nunbers of personnel and equipnent nor the types of steps to cut off this problen. W. Phantom Reimbursements h e state plan at I-4 indicates that relevant state and local officials will maintain acccunting records of public funds expended in a PNPP emenjency for purposes of seeking reimbursenent. From whcm reimbursement is to be obtained is not clear.
+ r Is it CEI? FD%? Congress?- ,
u Either this plan conponent nust be clarified or be discartled .
~
because of the vicious falsehood it represents. W e federal Price-Anderson Act limits a nuclear utility to a ceiling of liability, beyond which the cnly recourse for damages is the U.S. Congress, from which supplenental appropriations need be sought. he public sector y*y ' 3 _ has y.m .no particular prio,rity, 7 , . , in , tenus of claims for reimbursenent it .ax
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might press ~, over other claimants. Either,the plans nust reflect'. . _ "
- fully the means by whichirecolpnent is to. occur, . if at.all,[ including '
1 m ., % y 'a sensible discussion of Price-Anderson, or this section nust.be _ discarxied. Any and all agreements with CEI for reimbursement nust
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" also be included. It is ' absurd to use the emergency plans as a public relations docunent to give the public assurances that the ecotiomic aspects of-inplenentation will not be burdensene to tavayersi
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X. Source Term .
~ No-part of the plans can be approved until the internal NRC re-evaluation of so-called " source tenns" is ccupleted. h e very A
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basis for the plans is shaky at present, and revisior.s to source terms could mean speculations of gmater radiation dangers to the populace around Perry than presently pertain. Therefore, until the revisions occur to this fundamental assa:ption, Sunflower urges that no plan approval is substantively possible, nor practically meaning-ful. 7 Y. Incohemnt Ambularre Usage
. Lake County proposes to use antulance services to nove persons with health limitations who cannot be moved by bus. Lake County proposes to draw upon ambulances frcm Ashtabula and Geauga counties to acccmplish this end in the event of emergency. 'Ihis underscores the possibilities of conflicting responses at the county level.
Z. Bus Driver Protection Proposed arrumpicnts for measuring radiation exposures of bus drivers are fairly limited to use of dosimeters, which cnly will generally indicate how noch exposure has occurred, after the fact.
, Dosimeters do not indicate differing exposures to different parts of the body, and are not protective in the way that respirators, goggles and other protective equipnent would be. Inasmuch as in-bus and out-
. of-bus exposure potentials are pretty close to equivalence, protective gear is a nust for bus drivers, who are expected to play a crucial
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AA. Mower's " Stat $s Report" '
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p..j;-- 1; Sunflower Alliance hereby incorporates by reference and - m --
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,.c.realleges .herein all objections to state and local energency plans which appear in the " Status Report: Plaming for an Accident at the v s ,, . o -
Perry Nuclear Power Plant,'" Perry Legal Defense Fbnd (1983). BB. FBWs Interim Report - i #.~ -s.
- C Sunflower 'A111arice hereby irm v1purates by reference and
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realleges herein ach and every "planrnng deficiency" set forth in
. the March 1,1984 " Interim Report on Offsite Radiological Dnergency Planning for the Perry Nuc$ ear Power Station," Federal Dnergency
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x m y. g g m'.A,wn;-, m .e y%g . - ;:x~ : , L,= &=D =-a - a- ~ Management Agency, as particularized objections in this proceeding. CC. 'Ihe SER Sunflower Alliance hereby incorporates by reference and realleges herein each and every "resoluticn iten" set forth by the NRC staff in the " Safety Evdluataart Report," NUREG-0887, Supp. 4 (February,1984), at 13-1 thrt: ugh 13-22 inclusive as its particularized objections in this proceeding. DD .' location of the EOF Sunflower objects to the locaticn of the energency operaticos facility (EOF), presently located at the PNPP site. 'Ihis location is contrary to the reccmnendations ccntained in IUREG-0814 and NUREG-0696. Input which state and local officials niight have had into the decision is unclear, also. In essence, CEI would be asking decisicn-making e, ...
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officials to come to the nuisance in the event of a severe accident. Besides personally jeoparxiizing them, it would have the effect of removing decisional authorities frcm Ashtabula and Geauga Counties, and might ,further have the effect of rendering decisions in those counties 2
. . . . , . _ . m.uch.nore difficult..
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;EE. Reception Center Locations y, ,
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Sunflower. objects to locating;the reception centers within
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20 miles of 1NPP. Many are dowruind under normal meterological ccnditicos,
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- 'and at least one expert on radiological dispersien (Jan Beyea, who par -
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ticipated,in the Indian Point evacuaticn planrung case) believes that ' prutpt fatalities might occur as far away from $ leaking plant as 20 or l more miles. 'Ihe undecided'sourre tenns and the design and possible - [ accident sequences of the Perry plant suggest strcngly that a greater
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evacuation radius is needed.
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FF. Remote-Control Sirens IUREG-06S4 requires (at 45) that CEI install and maintain sirens, yet it is the responsibility of state and local goverrrnents c to activate such a systen. Sunflower objects to the setup as described
'in relevant plarrs unless it is delineated how Yederal Comunicaticns Cmmission approvals will or have been granted for the radio--activaticn systen. It would appear that CEI nust be the licensee, and thereby nust actually put into motion the activaticn of the sirens.
GG. Persons Without Technology Ibwhem in docunentary justification for the various media-notification: steps is there any discussion of a potentially sizeable
. population which may not utilize radios or televisions. As CEI well knows by now, there is a rather large Amish population in northeastem
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'. Ohio,"many of wh7n adhere to traditional religious beliefs rejecting T ~.
much twentieth-century technology. There must be documentation of the dimension of this population group, together with altemate means of notification, before any approval of offsite plans might ensue. HH. Evacuees Ibt Going to Centers
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', ; Had CEI'botherefto analyze the reacticns'of evacuees in ' "
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P ccnparable evacuasicn scenariod[ 'it mightifind that a majority, or?" at least a significant minority, of people go to friends' and relatives'
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. hones during a crisis, not' to evacuaticn centers. Ibw will these people
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be identified
. .e and checked and if need be, dacontaminated?
The plans ~. - .
. do not addmss this potential in any noteworthy way.
0 - II. Evacuaticn Ccnter Resources Other -than identifying the centers,' data on available resources there is nil.; 'It'is gnot
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covdred in t.he m plans that food, drugs., beds, -- 1
- s pr6tective gears, potassion iodide, and runereus other things suchc i
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, as telephones would be available. There is no doctxnentation of the po-tential lengths of stays which might be necessitated by a severe ac-cident. 'Ihere is no mention of the need for psychological services to assist those who camot accept the possible facts that they may never be able to retum to hanes, pets, etc. , or might not be able to cope with the loss of friends or relatives to a nuclear accident.
JJ. Emeryezs y System Equipnent None of the plans address the availability of electrical power, or altemate enerxjy for generation of electricity, to conpensate for'the loss of power frun PNPP that would accarpany an accident. Specifically, can Applicant or state and local govemments categorical-ly state that there will be sufficient supplies arxl availability of energy to operate sirens, emergency-set traffic 1ights, independent , radiation monitoring equipnent, gasoline punps, and the like? The , plans offer no guidance. KK. Retuming to the EPZ , Other than general refermces to cordming off all or parts 7f . . . of the EPZ, the plan,s'.do not tell hcw persons re-entering the EPZ will
. , be handled if an accident is in progress. It is rut too harti to en- ,
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. vision worried parents (particularly single parents) who work outside .n, m- the EPZ racing belatedly back into it to get school children, retrieve .
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pets or valuables, feed livestock, etc. 'Ihe issues of securing the , , a ^
' ' cordoned area 'while adowing access to bma fide residents is ' difficult to manage. In conjuncticn with the issue would be the question of how '
to limit radiaticn sures to people venturing back into the zone, as well as docunenting and measuring exposures when they once again depart. - 1 e. i-
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- LL. '1he Plans Will Ibt Work
'Ihe Conmission is bound by 10 CFR $50.47(a)(1) to find that them is " reasonable assurance that adequate protective measures can
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and will be taker 1'in the event of ruclear emergency at Perry. None of the plans have been subjected sto, anything but, at best, tabletop drills. 'Ihere has been no full-scale drill of any sort, and none is contenplatted for some months. Even after a full-scale drill occurs, e>:perience at other plants indicates that nuch reworking and fine-tuning will be necessary. Sunflower objects to the plans as being unworkable because they have not been sutmitted to these myriad acid tests which inplem-t entation would impose. Conclusion
~^ ' "
Applicant must carry the bueden of proof in denonstrating that the offsite emergh plans comply with IEC guidance and regulaticns, even though Applicant may not primarily responsible for carrying out the operaticns described in the plans. Consaters Power Company (Big Rock Point) LBP-82-77, 16 NRC 1096 (1982)." As the foregoing discussion
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indicates, there are many ccnsideraticns which have not been addressed
#~ " by existing draft plans, or which have not been resolved within the )-
ccntext of existing plans. Sunflower Alliance urges the Boarx! to waylay action on emergenc[ preparations as a ccntenticn until such time as each of these deficiencies can be rectified. Alternatively,
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. Smflower drays the Board to dismiss' the application for an operating license for Perry Units 1, and 2, for the reason that emergency plans
- are serious and critically insufficient. " -
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m- m sa w - _g. c . , n-m ..v m - -- .- - - > - ;g. . . % .; '- - ~ o Cs - r b + . Inescapably, the PIFP plans are far from having reached what this Board characterizes as a " mature state of developrnent." Perry emergency preparaticos have.to be stalked like " prey in the jungle," for the precise reason that they are very, very primitive, indeed. t . Respectfully, f) I- .
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/L i Cotnsel r Sunflower A'd ance 618 N. igan St. , Suite 105 Toledo, Ohio 43624 (419) 255-7552 Utm n1 CATION I hereby certify that a copy of the forecping " Particularized Objecticos to Proposed Emergency Plans in Support of Issue No.1" was sent by me this 21st day of August,1984 via regular U.S. Mail, postage prepaid, to each of the persons or parties appearing on the attached
" Service Li't." s
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SERVICE LIST
- 2Cice U:itNE Peter B. Bloch, Chairman Atcmic Safety & Licensing Board i U.S. tbclear Regulatory Conm.
N . fg $ll47 Washington, D.C. 20555 . , gj , , . ,
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~5 Dr. Jerry R. Kline 00CdCy&~fg=CK,Q(.
gg , Atcmic Safety & Licensing Board - U.S. Ibclear Regulatory Ccmmission Washington, D.C. 20555 Mr. Glen O. Bright . Atcmic Safety & Licensing Board U.S. Ib.: lear Regulatory Ccmmission Washingtcri, D.C. 20555 Colleen P. Wocxfhead, Esq. Office of the Executive Legal Director U.S. Ibclear Regulatory rarmission Washington, D.C. 20555 Jay Silberg, 'Esq. Shaw, Pittman, Potts, & Trobridge 1800 M Street, NW Washington, D.C. 20036 Docketing & Service Branch Office of the Secretary U.S. tbclear Regulatory Conmission Ws M , D.C. 20555 ., Atcmic Safety & Licensing Appeal Board Panel
- U.S. tbclear Regulatory Ccrimission Washington, D.C. 20555 Susan L. Hiatt 8275 Fonscri Road Mentor, Ohio 44C60 9
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