ML20107G424

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Statement of PM Schmidt in Support of Contention That Radiological Emergency Plan Inadequate.Plan I Both Unofficial & Incomplete
ML20107G424
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/23/1985
From: Schmidt P
AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20107G302 List:
References
OL, NUDOCS 8502260417
Download: ML20107G424 (7)
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'llA h % ul [Jf STATEMENT SUBMITTED BY :

Phillip M. Schmidt 'h[kke 117 Centennial St.

Geneva, Ohio 44041 15 Fal25 PiO6

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To: NRC AT

SUMMARY

DISPOSITION FED. 20,1985 IN SUPPORT OF SUNFLOWER ALLIANCE / PERRY LEGAL DEFENSE CONT LTAde FWC PNPP RADIOLOGICAL EMEltGENCY PLAN IS NOT ADEQUATE AN81 PERSONAL BACKGROUND

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I, Phillip Schmidt, have been a resident of the Geneva r-Chie-area for.

approximately 20 years,am married and have 3 children, the oldest being

13. I am an active church leader and also active in my community, presently filing for candidacy f o rGeneva City Council Member. I grad'uated from Ohio State University College of Engineering and was employed as an engineer by a major nuclear submarine building shipyard for more than 5 years. I presently am the co-owner of a small manufac-turing firm in Geneva Township. In March 1983 I was appointed by the Ashtabula County Commissioners to represent Geneva Township on the Citizen's Advisory Committee established by the Commissioners to provide

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input into the development of the subject. Emergency Response Plan for the Perry Nuclear Power Plant. There were 6 citizens on this committee initially, and initially we all took our responsibilities seriously and worked hard trying to contribute to the development of the "best possible plan". At this time I-am the only one who has not quit in-

disgust. I am submitting this statement in hopes that some much needed changes in the PNPP Emergency Plan may result. The plan is presently not adequate.

OBJECTIONS 1.)'The Plan I reviewed (Control Copy #DSA-111 available in the Geneva Library) was UN0FFICIAL (because it had not been officially approved and signed by any one of the 3 Ashtabula County Commissioners -

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. the signature page was simply blank lines) and the Plan was INCOMPLETE, j (none of the 57 SOP's were available at the Geneva Library, and there were blank pages where there should have been Letters of Agreement to the SOP's by the organizations involved, and where there should have been information describing the evacuation time study. Also, there is no information relating to the PNPP Emergency Information IIandbook.)

For the entire time I have been involved in the development of this Plan, the SOP's have always been recognized as the " heart" of the Plan.

I believe the SOP's are missing because only a few of them have any real detail in them and many of the organizations they relate to have ref Ised to date to si",n and accept them. In other words, I believe, the writers of the Plan wrote out the SOP's to the extent (and only to the extent) that the S0P describes in general terms what the Plan writers want the organization to do, and how the organization will be notified if they are to do it. I believe that many of the organizdions have not developed the necessary step-by-stop procedures to actually do what is requestud, and I believe they have not stated they will,or can, do it!

2.) Every one of the members of the Citizen's Advisory Committee, the Geneva Township Trustees, at least one Geneva Area' School Board member I

and ncarly everyone I have talked to agrees the Plan is completely un-ccceptable and inadequate unless the following provisions are included:

l (a) Independent real-time monitoring of radioactive emissions - by an agency other than CEI - preferably either the Lake or Ashtabula County Disaster Services Agency. As the Plan now is written, all agencies and individuals must rely solely on information provided by the. utility.

For years utilities have repeatedly been found guilty of not promptly'or honestly reporting releases of radioactive material. independent real-time monitoring has many benefits:

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1. It can help-the utility detect a problem they honestly may

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, not.know they have, as when radiation nonitors at a nuclear submarine yard in Connecticut detected emissions coming from the Millstone Point Nuclear Plant that the power plant operators were unaware of...

2. It can detect a problem the utility may know it has, but doesn't want to admit...
3. It can verify - or bring into question - claims that normal plant operations only involve minimal emission of radio-activity...
4. It can help determine and track the path of radioactive clouds emitted by the plant so people in its path can be given warning quicker and more reliably.
5. It can help determine if an unexpected large accidental release of radiation has exposed any people to levels where l

they should take radio-protective drugs.

The need for this type of monitoring is one of very strong and universal agreement among members of the Citizens Advisory Committee and also

! local agencies and governments!

(b) The availaM11tv of Potassium Iodide - there is a specific and clear requirement in NUREG 0654 that the Plan include provisions for.

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.the use of radioprotective drugs - particularly for emergency. workers and institutionalized persons within the plume exposure EPZ. Yet' this Plan specifically states they will not be available-'nor used. The basis for this non-use is an out-of-date letter written-in Igg,Q -in which the

. writer states-that'"in the absence of FDA guidelines" he feels the drug should not be~used..However, in Iggg the FDA did' issue guidelines

!. and they specifically urge'that potassium iodide.be used!

To not make this drug available.to emergency workers, bus ~ drivers, etc.,

g is a betrayal- of their trust and -is inexcusable! They may.need this drug s

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.to protect them from' cancer of the' thyroid!

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(c) School children should be allowed to be taken out of school or called home by their parents at the " Alert" stage and evacuated at the

" Site Area" Emergency Level as a precautionary measure,since they are so much more susceptible to the effects of radioactivity, could be more easily united with their families, and because we love them so much we want to give them this extra protection. Also, evacuating the schools early would free up the buses sooner so they could be used to evacuate other people in the event a general evacuation was called for. This is a point that there is practically universal agreement, If it is not planned for, people will flood the schools in a disorganized mob scene. I will take my children out of school at the " Alert" stage because I don't have any confidence in this #1an.

f (d) Keep the EPZ at a 10. mile radius and if a General Emergency arises and conditions permit, evacuate the entire 10-mile EPZ area.

Universal agreement here also.

3.) There does not appear to be any capability in the Ohio Dept. of Health to do the determinations they are being counted on to do.

4.) The pick-up points for non-auto owning people are too far apart in Geneva Township.

5.) The public should be notified whenever an " Alert" level accident

.cccurs and reminded of what they may have to do in the event the sit-i untion becomes more serious. This will-got cause panic. Some people may-cvacuate voluntarily as a result, but this would be beneficial.

'6.) Geneva doesn't have enough firemen'to quickly do everything they l

are supposed to do.

7.) There ane not enough tow trucks available . to keep theiroads clear.

8.) There are no provisions to reimburse the County,. cities, and town-

- ships for th's considerable cost .of participating in annual drills luut lthe ongoing updates, etc. This may lead to:the refusal of-some

Ashtabula and Lake County agencies to participate, just as has already occurred in the Davis-Besse plant area. This is a very considerable yearly cost to area governments!

SUMMARY

In summary, for the preceding reasons and others not stated, but which I would be willing to sate if you are int erested, I am convinced this Plan is not, and will not be, adequate until the deficiencies I have herein objected to have been corrected.

Res ectfully submitted,

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Phillip H. Schmidt,P.E.

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@ Qq- (, \['v w SWEulMeasucci Notery PuNu

' STATE OF OHIO My esmalesion empires June 29.1980 p

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No specific upper limit is given for thyroid exposure since in the extreme case complete thyroid loss might be an acceptable penalty for a life saved. Itowever, this should not be necessary if respirators anc'/or thyroid protec-tion for rescue personnel are available as the result of adequte planning.

The implications for the local governments' refusals to use potassium iodide are obvious as well as ominous.

Lake County proposes the fantasy that it will not establish any decision chain authoriziaag any person, emergency or otherwise, to exceed 25 rems whole-body exposure. FEMA Interim Report at 15. This is inconsistent with pre-existing State commitments. . Geauga County does not prescribe any decisional chain for authorizing excessive exposures of over 25 whole-body rems.

All three of the counties' plans are unacceptable in that, while each may be forced to delineate a decision-making chain to determine whether exposure limite may be exceeded,'there-is no relevant discussion explaining 1s how the Ohio Department of Health, CEI Department heads, and county officials.

-will be able to render dozens, hundreds or thousands of .uch decisions m

! allowing excess exposures in the : cataclysmic moments following a breach' of-containment or other consequential pluming radiation...In this~and other respects, .the critical moments af ter major radiation leakage are viewed by planners with severe roseate ocular distortions.

. Ironically, the affidavit- of . John Mauro, ' accompanying ' Applicant's u ,

9 motion for summary disposition on Contention G, not'es-(at 9) that historically-overestimated radioiodine source terms "I.rovide compelling' reasons to look toward other more effective. methods for protecting offsite radiation A1

-workers." ' Applicant argues that it is'not required to have respirators- .

availabli to offsite. emergency workers;;it argues that potassium indids need

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not be stockpiled; 'all this while . posed by its own experts with evidence 4

-that some radiation exposure will occur to the offsite population.1-

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Applicant has failed to resolve these inconsistencies by motion.

Therefore, stun =mry disposition must be denied.

Respectfully submitted, By f V I te try J( Lodge

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j il B N. I chigan Street Qq1te 1 Tdledo, Ohio 43624 Phone: (419) 255-7552 Counsel for Sunflower Alliance

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