ML20125A774
| ML20125A774 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/24/1992 |
| From: | Gary R PENNSYLVANIA INSTITUTE FOR CLEAN AIR |
| To: | Cooper R, Selin I, The Chairman NRC COMMISSION (OCM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20125A403 | List: |
| References | |
| NUDOCS 9212090050 | |
| Download: ML20125A774 (3) | |
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PICA The Pennsylvania Institute for Clean Air t
OFFICE OF THE PRESIDENT Under 10 CFR section 2.206 I formally request that the NRC take action as specified hereunder. This document is being mailed by first class mail on July 10, 1992 to the follewing per, sons:
Mr. Ivan Sellin Chairman, Nuclear Regulatory Commission Washington D.C.
20555 Mr. Richard Cooper NRC Director of Division of Radiation Safety and Safeguards 475 Allentown Road King of Prussia, PA 19406 Mr. Craig Gordon NRC 475 Allentown Road King of Prussia, PA 19406 The following points factual points are presented in support of the request for action.
(1) On June 30, 1992, I, Robert Gary, a resident of Dauph?.n County, went to PEMA Headquarters in Harrisburg and requaisted to see the letters of intent from private transportation companies that the Chief Counsel had told me were on file there. There was no file only a list of letters of intent that were supposedly held at the Emergency Operations Center of Dauphin County. I immediately proceeded to that location and r g ested that Director Wartz show me the file. It contained a single letter dated 1985 from Mr. Gerald Smith at Capitol Area Transit (CAT).
That letter cited a statute as the sole source of payment, which has since been repealed and superseded by another law. At that time I suspected that emergency preparedness in Dauphin County was substandard.
e P.O. BOX 1637 HA RRit **G PENNSYl,VANIA 17103 1637 TELEPHONE (717) 236 3888 g2O
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10 CFR section-2.206 Petition by R. Gary, July 10,-1992, Page 2.
(2) On July 10, 1992 (today), I returned-to the Dauphin County Emergency Operations Center (EOC) to examine the RERP which-is the book that would be-used in a radiological emergency by:the EOC staff._The first page of the book'said, "Completeli leprinted with Change 1 in 1991" or words to that effect. I then examined page E-9-5 which contained information on busses from private companies in Dauphin County. Approximately-450 buses were accounted for, but the first two listings, the one with Capitol Area Transit for approximately 70 buses, and the one with Capitol Trailways Penn Central Station for approximately 320 buses constituted the greatest proportion of the total, i.e. 390 out of 450 or about 87%. I decided to call the executives listed in the book to determine the up-to-dateness of that page of the RERP..
(3) At about 4:00 P.M.
I made the calls in the presence of the staff on duty at the Dauphin County EOC. First~I called Mr. Weeks at Capitol Area Transit (CAT). The person answering the phone informed me that hadn't been with the company since 19841 Next, I called Mr. Miller at Capitol Trailways Penn Central Station. The person answering the phone told me that Mr. Miller hadn't been with_the company since 1987.
(4) There were no "after hours" telephone numbers listed in_the RERP, which is the book that the-staff-on hand at the EOC would.
refer to in a radiological emergency._Even if there had been-after hours numbers listed, in the case of Mr. Weeks,.the number would have been non-operational for the past eight years, and in the case of Mr. Miller, for the past five years.
(5) The staff members at the Dauphin County Emergency Operations Center reported to me today, I:think truthfully, that they-have no authority to request military vehicles:from the National Guard, Mechanicksburg,-or Indiantown Gap. That would have to-be done by the state -- presumably by PENA.-PENA, over the'psat i
month, has represented-to me that their_ responsibility lies in i
communications and coordination. They have shown me Annex E to the Dauphin County. Plan which contains no reference,to the use-of military vehicles.-PEMA has no plan to. call-.for the use of J
military vehicles because they feel that their responsibility is i
in the area of communications and-coordination Dauphin County has no such plan because they feel-that the. State has exclusive jurisdiction in-that area-and that the-County cannot call for such vehicles. Therefore, although there are acres of trucks capable of carrying people within 15 miles of Harrisburg neither1 the State nor-the County has anyfreferences in the written plans they showed me to use any of them.
(6) The sua total of these f acts taken together leads nun to. the belief that the Dauphin County Emergency Evacuation Plan in the e
10 CFR section 2.206 Petition by R. Gary, July 10, 1992, Page 3.
event of a radiological emergency is essentially non-operational.
(7) The permission that the NRC extends to the power company at Three Mile Island to operate nuclear reactors there for commercial power generation is premised on the existence and the continued maintenance of an operational' radiological emergency evacuation plan for Dauphin County. When and if this plan becomes so substandard that it is for all practical purposes non-operational, it is completely appropriate for the NRC to direct the power company to power down those reactors until such time as a satisfactory plan is in place and workable.
(8) I request that the discrepancies that are mentioned in this letter be checked out by a FEMA official as soon as possible, preferably within 5 working days. If the official finds that the discrepancies are verified, then I request that the Three Mile Island licensee be ordered by the NRC to power down until the discrepancies can be corrected.
(9) Duri7g the time, after the discrepancies have been verified, and before they are corrected, while FEMA and PEMA and NRC are working to generate an operational emergency evacuation plan for Dauphin County, it is fully justified that the power reactors at Three Mile Island be in a power down mode. The license to power -
up that reactor was legally premised on a valid workable evacuation plan for Dauphin County. During times when such a plan does not exist, neither should the license to operate for power generation. Recognizing, as I do, that paperwork takes time and there are many administrative processes and considerations, I request that, once the discrepancies are officially verified, and during the pendency of the process of correcting them, the power up license be suspended.-I believe that such a suspension will cause the discrepancias in this case to be corrected fairly quickly, but in the absence of such a suspension, the corrective process might take-several years or might never occur. I believe that such a suspension would send a message to: (1) other operators, (2) other Counties in Pennsylvania, and (3) Emergency Management Agencies in other states. This message would be the precisely correct message that NRC should be sending in its fulfiljment of it legal, professional, and moral duties to the American people.
Sincerel,
Robert Ga for PICA
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