ML20215N245

Second Supplemental Memorandum in Support of Motion to Intervene & Request That Commission Postpone Action on Full Power Operation.State Emergency Evacuation Review Team Not Convinced Plan Adequate.Certificate of Svc Encl

ML20215N245
Person / Time
Site:	Perry
Issue date:	10/29/1986
From:	Northrop D OHIO, STATE OF
To:	NRC COMMISSION (OCM)
References
CON-#486-1344 OL, NUDOCS 8611050098
Download: ML20215N245 (28)

Text

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U1 \ \D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

,/ BEFORE THE COMMISSION IN THE MATTER OF:  : Docket Nos. 50-4400L

50-4410L THE CLEVELAND ELECTRIC  :

' ILLUMINATING COMPANY, et al.  :

(PERRY NUCLEAR POWER PLANT,  :

UNITS 1 AND 2)  :

s STATE OF OHIO'S SECOND SUPPLEMENTAL MEMORANDUM IN SUPPORT OF ITS MOTION TO INTERVENE, AND A REQUEST THAT THE COMMISSION POSTPONE ACTION ON FULL POWER OPERATION

/ On October 21, 1986 the State of Ohio-filed a Sup'plemental Memorandum in Support of its Motion to Intervene

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with this C6 Emission. In that pleading the State listed numerous issues of vital importance to the public safety which the Ohio Emergency Evacuation Review Team (EERT) was investigating in regard to the off-site emergency plan for the Perry Nuclear Power Plant.- This Task Force has now made s veral preliminary findings in the course of this on-going investigation which have 'only increased the State's concern i

l as to the adequacy of the plan. For those reasons which t

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follow, Ohio reaff'irms its request that.the Commission postpone action on full power authorization of the Perry Plant. -

1. Nuclear Accident Scenarios: Ohio's emergency response plan is not intended to address sudden or large releases of radiation. A basic premise of the plan is that-there will be sufficient warning of an impending nuclear accident enabling responders to carry out an orderly evacuation. Additionally, another fundamental assumption of ^

the plan is that only relatively small amounts of radiation will be released in the event of a radiological accident. .

Many recognized experts'in the field of nuclear power have addressed the EERT.and have discussed the possibilities and probabilities of an explosion or other accident which would lead to an immediate, massive release of radiation from a nuclear power plant. The. determination of whether or not a large, sudden release of radiation is possible during a radiological accident is central to any final judgment as to:

I the adequacy of the emergency response plan.

This fundamental question has sparked a serious 4

re-evaluation of nuclear power accident scenarios and

emergency response planning in the scientific community.

(New York Times, October 28, 1986.) Indeed, the Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA) have also recognized that the accident at Chernobyl raised serious questions concerning severe nuclear accidents as well as emergency planning.

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The EERT met with NRC and FEMA staff, on October 28, 1986. These agencies conceded they are preparing a report for the Commission.which will include many of the same issues that the EERT is evaluating. The NRC and FEMA are evaluating severe accident scenarios as well as a range of other emergency planning issues including the adequacy of zone distances; the long-term relocation and decontamination of affected areas; the use of KI pills; data acquisition and reporting; ingestion pathway monitoring and ingestion of contaminated foodstuffs; emergency medical services, and; onsite response. The NRC staff will present their report to the Commission in December.

2. Scope of Emergency Planning: The geographical scope of emergency planning involved in the pla'n is inadequate. A large release of radiation could make evacuation, sheltering, and other emergency measures necessary in counties where emergency response plans do not exist, e.g. Cuyahoga and Summit. Even if these counties were not directly affected by dangerous levels of radiation, they and others could receive influxes of evacuees. No plan exists for coping with large i

numbers of displaced people for.potentially long periods of time.. (NUREG-0654, p. 31, Assignment of Responsibility (Organization Control), Item One.)

l 3. Decision-Making Responsibilities: The plan's framework for making emergency response decisions is l unrealistic. A serious nuclear accident could affect many

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counties, and a response would necessarily require taking i

immediate action to protect public health and safety in all the counties that could be affected. The current plan fragments decision-making responsibility among local and state officials, creating the potential for delayed responses and leaving the fate of the citizens in one county in the hands of another county's officials,. (NUREG-0654, p. 31, Assignment of Responsibility (Organization Control), Item One.)

4. Notification of Governmental Authorities: Executing timely emergency response measures depends on the immediate notificat' ion of government officials. Yet during previous incidents at Davis-Besse many hours elapsed before state officials were notified. These delays are unacceptable and, if a serious accident occurred, .such delays could prevent the i quick responses necessary to save lives. Ohio's experiences

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demonstrate that this aspect of the plan is seriously flawed; it has lost the confidence of the public and of the State'.

(NUREG-0654, p. 43-44, Notification Methods and Procedures.)

5. Notification of the Public in Case of Emergency:

The EERT is not satisfied with the current plan's provisions for notifying the public. Many citizens have complained that they have not been able to hear the sirens during tests, and the sirens have not been tested under the worst possible weather conditions. Indeed, current plans do not provide an adequate level of protection for hearing-impaired individuals. (NUREG-0654, p. 61, Protective Response, Item 10, c.)

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6. Capability of Area Hospitals to Treat Victims of Radiation Poisoning: Area hospitals do not have the necessary equipment or sufficient numbers of properly trained personnel to treat large numbers of radiation victims.

Hospitals' capabilities have not been subjected to on-site evaluations, and their radiological emergency plans have not been adequately tested. In this respect, the emergency plan

.is based only on theoretical information. (NUREG-0654, p.

69, Medical and Public Health Support, Item 3.)

7. Monitoring Radiation Releases: The EERT has concluded that the methods proposed for monitoring radiation releases are inadequate to provide-the State with timely, independent information. (NUREG-0654, pp. 53-54, Emergency Pacilities and Equipment, Items 5-7.)

8. . Ingestion Zone Planning: Ohio has not completed planning for ingestion zone activities. The EERT considers the plan inadequate until this task has,been completed.

(NUREG-0654, p. 64, Protective Response, Item 11.)

9. Radioprotective Drugs: The emergency response plan's discussion of radioprotective drugs does not meet the minimal preparedness requirements of FEMA's policy guide.

There is no method by which the Ohio Department of Health l

could coordinate the administering of these drugs to the general population or off-site emergency workers. No provision has been made for administering these drugs to l

those individuals whose immediate evacuation may be

-infeasible or extremely difficult. (NUREG-0654, p. 63, Protective Response, Item 10, e and f.)

10. Re-entry, Recovery, Relocation: The emergency response plan assumes that contaminated areas could be re-occupied safely within a matter of days and therefore addresses re-entry, recovery and relocation issues in a summary manner. These elements of the plan are clearly inadequate to address a significant release of radiation.

They have not been exercised, and recent draft U.S. EPA guidance on these issues has not been incorporated.

'(NUREG-0654, p. 70, Recovery and Reentry Planning and Postaccident Operations, Items 1-4.)

-11. The Willingness and Ability of Bus Drivers to Perform Assigned Functions: The union representing. bus drivers has voted overwhelmingly not to participate in evacuation procedures. . Individual bus drivers and their representatives have complained of a lack of training.

Until their concerns are resolved, or other reliable means for transporting school children and others requiring transportation can be devised, this element of the plan is wholly deficient. (NUREG-0654, p. 63, Protective Response, Item 10, g.)

12. Availability of Emergency Response'Information to School Administrators: Evacuation procedures are not in place for all schools within the Emergency Planning Zone for the Perry Nuclear Power Plant, and no completion date for

E that task has been set. The plan cannot be considered adequate until appropriate procedures are in place for all affected schools. -(NUREG-06554, p. 61, Protective Response, Item 10, c.)

13. Evacuating Special Populations: Additional time, specillly trained personnel and specialized equipment would be needed to evacuate hospital patients, nursing home residents, a'nd physically and mentally handicapped individuals. The EERT has concluded that sufficient resources are unavailable within_the immediate area to perform this task. (NUREG-0654, p. 61, Protective Response, Item 10, d.)

14. Evacuation During Adverse Weather Conditions: The emergency response plan fails to provide adequate protection-to the population under abnormal conditions. Severe snowstorms, flooding and earthquakes are among the events that could create conditions that would greatly hinder rapid, orderly evacuation. The potential for some of these events

occurring in areas where Ohio's nuclear power plants are located is significant and did not receive adequate attention by the planners in the plan's formulation. (NUREG-0654,.p.

63, Protective Response, Item 10, k.)

15. Decontamination and Waste Disposal: These issues are summarily addressed in the plan. If a serious nuclear accident occurred, it is unlikely that the procedures outlined in the plan would be adequate to decontaminate'large numbers of people or to dispose safely of large amounts of l

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radioactive waste. (NUREG-0654, p. 64, Protective Response, Item 11.)

The above conc' erns have surfaced in the course of EERT's ongoing investigations. These investigations have been comprehensive'and thorough. On August.15, 1986, Governor Celeste created the Ohio Emergency Evacuation Review Team (EERT) appointing William Denihan, Director of the Department of Highway Safety, Thomas Chema, Chairman of the Public Utilities Commission of Ohio, and Raymond Galloway, Adjutant General (National Guard) to spearhead the reevaluation of the evacuation plans.

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This team began' work immediately. Between August 15, 1986 and September 1, 1986, EERT met with the County Commissioners from the six affected~ counties. EERT continues

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to meet with the commissioners on an-individual basis. Two public meetings have been held, the first on September 3, 1986 at Lakeland Community College near the Perry facility and the second on September 9,- 1986 at Oak Harbor, Ohio, only nine miles from the Davis Besse facility. Community input

.from these~well-attended public meetings was extensive as well as extremely helpful in directing the focus of the reevaluation.

On September 24, 1986, EERT memebers toured the Perry facility. On September 26, 1986, they met with

.respresentatives from the disaster services of the six

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affected counties, representatives of the Ohio Disaster Services Agency and representatives of the Ohio Department of Health.

In a continuing effort to afford all interested parties a hearing and to accumulate and evaluate all available information, EERT met on October 6, 1986 with representatives from the Sunflower Alliance (an intervenor in the Perry

• Licensing proceedings), attorney Terry. Lodge and nuclear engineer John Kiely. On October 9, 1986, EERT. met with representatives from the Cleveland Electric Illuminating Company (CEI) and Toledo Edison Company-(TECO).

On October 15, 1986, EERT met with representatives of the American Nuclear Society,-Northern Ohio Section. Dr.

Herbert Kouts, Director of Nuclear activities at Brookhaven Institute, Don Miller, Chairman of the Nuclear Engineering Program at Ohio State University, Richard Christensen, Assistant Professor of Nuclear and Mechanical Engineering at Ohio State University, and Sheldon Thorpe, a nuclear consultant.

On October 28, 1986 the EERT met with representatives of FEMA and the NRC. Many issues were discussed in the area of emergency preparedness but nothing discussed at this meeting h'as convinced EERT that the plan can adequately protect Ohioans in the event of a radiological emergency. EERT is continuing to meet with various groups and individuals, as well as to examine numerous outstanding issues.

It 1:s evident from the above that EERT is making a good f aith and comprehensive attempt .tx) review and reevaluate the emergency preparedness plans. _This' review will be completed on December 31, 1986. This is matter of grave concern to the State and its c'itizens. .( See Appendix A).

. Granting the State intervention and postponing the grant of full power to the Perry Plant can only enhance the Commission's effectivness review. The advice of the State will enable the Commission's decision to reflect the expertise and counsel of the State. Indeed the NRC's and FEMA's study of emergency plans expected in December of this year will also aid this review. If the Commission were to grant full power authorization to the Perry plant on October 30, 1986, it will deny itself wise and' reasoned counsel. It will deny the State the opportunity to bring its serious concerns-to the attention of the Commission. Because these are matters of critical importance to the Commission's obligation to assure public safety, the Commission chould postpone a decision on a full power operation until the Commission has had an opportunity to review Ohio's evaluation of the plan, and make necessary changes in the' plan.

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Respectfully submitted, ANTHONY J. CELEBREZZE, JR.

ATTORNEY GENERAL-OF OHIO 7

BY: s /

DAVID'E. NORTHROP /

SHARON SIGLl3R

• Assistant Attorneys General 30 E. Broad St., 17th Floor Columbus, Ohio 43266-0410 (614) 466-2766 6

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CERTIFICATE OF SERVICE OCT 3 0 886c-$$

' C2 . . TGd I hereby certify that a copy of the foregoi g St'aEdk5ff J Ohio's Supplemental Memorandum ~in Support of its b"O g CP Intervene, and a Request that the Commission Postpone Action on Full Power Operation has been served by regular U.S. Mail, postage prepaid, this 27' day of October, 1986, upon the -

following:

Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street Washington, D.C. 20037 Lando W. Zech, Jr., Chairman U.S. Nuclear Regulatory Commission

" Washington, D.C. 20555 Thomas M. Roberts, Commissioner U.S Nuclear Regulatory Commission Washington, D.C. 20555 James K. Asselstine, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Kenneth M. Carr, Commissioner U.S. Nuclear Regulatory Commission Washington', D.C. 20555 William L. Clements, Chief I Docketing & Service Section l Office of'the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1

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Dr'. W. Reed Johnson Atomic Safety and Licensing

. Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Gleason, Chairman 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Jerry R. Kline Atomic Safety an'd Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 John G. Cardinal. Esq.

Prosecuting Attorney Ashtabula County Courthouse Jefferson, OH 44047 Colleen W'oodhead,'Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Terry Lodge, Esq.

Suite 105 618 North Michigan Street Toledo, OH 43624 Ms. Sucan L. Hiatt 8275 Munson Avenue Mentor, OH' 44060 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 LI I

Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney Lake County Administration Center 105 Center Street Painesville, OH 44077 William C. Parler General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 husf David E. Northrop a

U Assistant Attorney General M

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Appendix A

SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT Lake County City of Eastlake 10/14/86 ...the Council and Administration Population: 22,131 of the City of Eastlake hereby.

appeal to the Governor of the State of Ohio to increase the Emergency Planning Zone for the Perry Nuclear Power Plant and the Davis-Besse Po"er Plant in Port Clinton so that such zone.will have a fifty (50) mile radius to include the counties of Lake, Geauga, Ashtabula and Cuyahoga in order to protect the lives, safety and well-being of.the residents; and further, request that the plant not be placed into full operation until the boundaries are extended to include those counties."

Lake County 6/23/86 According to the Lake County News Population: 215,518 Herald, October 24, 1986, the Lake County-Commissioners issued a two-page , six-point, policy statement on October 23, 1986. The statement reportedly does not rescind Commission approval for'the emergency evacuation plan.

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" ...until time when all questions Madison Twp. 9/9/86 Population: 15,558 regarding the safety and operations

! of the Perry Nuclear Power Plant have been addressed by the above l agencies [ Nuclear Regulatory Commission, the State of Ohio, and Governor Celeste's Special Committee appointed to investigate the safety i

' of the Perry Nuclear Power Plant, l and the. Lake County Emergency Management Agency], and that independent radiological monitoring i

be installed in the Madison Community, and that the present evacuation plan be reviewed and I

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SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER '

STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT Madison Twp (cont.) improved, the Madison Township Board of Trustees, Lake County, Ohio, will not support the start up of the Perry Nuclear Power Plant.

Furthermore, the Board-also urges all regulatory agencies to delay the start up of the Perry Nuclear Power Plant until all issues regarding the safety of the plant are addressed."

Painesville Twp 5/22/86 "

...We, the Painesville Township Population: 12,718 Trustees, oppose the start-up of the Perry Nuclear Plant in Lake County until evacuation plans are revised to provide safe exit in event of a nuclear plant accident, and...We, the Painesville Township Trustees, recommend to and urge the Lake county Commissioners to completely revise their evacuation plan, taking into account all existing and planned construction affecting major evacuation routes, including State Route 2, U.S. Route 20, Vrooman Road, and all bridge construction on noutes important to these highways, including the Route 20 bridge near Casement Avenue and the Main Street Bridge in Painesville City, and

...the Trustees recommend to and urge all public officials, both local, state, and federal, to employ all means to delay the start of operations at the Perry Nuclear Plant until evacuation plans are in effect which will employ routes capable of handling evacuations arising from accident at the Perry Nuclear Power Plant."

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SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT City of Willowick 9/16/86 ...the Governor of the State of Population: 16,793 Ohio is hereby memorialized to increase the emergency planning zone for the Perry Nuclear Power Plant and the Davis-Besse Power Plant at Port Clinton, Ohio ~so that such zones will have a 50-mile radius in order that same will not be a threat to the health, safety, welfare and economy of the Northeastern Ohio area."

Ashtabula County City of Ashtabula 10/6/86 " . . . this Council supports Governor-Population: 22,622 Richard Celeste's stand against the opening of the Perry Nuclear Power Plant."

Township of 10/2/86 " ...those trustees of the Township Ashtabula of Ashtabula, do hereby call on Population: 25,126 Governor Richrad F. Celeste to take all necessary steps to halt the operation of the Perry Nuclear Power Plant by withholding approval of the

. emergency plans for the plant until such time as the safety of the citizens of Ashtabula Township has been assured thereby guaranteeing Ashtabula Township residents their natural, inherent and inalienable rights to happiness and safety and the protection of property guaranteed in Article 8, Section 1, Bill of. Rights, Ohio State

Constitution."

l City of Conneaut' 10/27/86 ...this Council hereby calls upon

~ Population: 13,368 Governor Richard F. Celeste, the Nuclear Regulatory Commission, and all regulatory and licensing bodies to close the Perry Nuclear Power Plant, and ban all further nuclear l

power plants in the State of Ohio."

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SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT Hartsgrove Township 10/15/86 ...these Trustees of the township Population: 1,167 of Hartsgrove does hereby call on Governor Richard Celeste to take all necessary steps to permenently close the Perry and Davis-Besse nuclear power plants and ban all future power plants in the State of Ohio, thereby assuring the residents of Hartsgrove their natural, inherent, and inalienable rights to happiness and safety and the protection of property guaranteed in Article 8, Section 1, Bill of Rights, Ohio

. State Constitution...the trustees of Hartsgrove Township would allow the Perry Power Plant to operate with

. non-nuclear materials, that a monitoring system be operated by someone other than the Illuminating Company...the trustees of Hartsgrove Township are not satisfied with the evacuation plan set up by the Disaster Service, in the event of a disaster at the Perry Nuclear Plant.

No plan has been shown to the Fire Chief of Hartsgrove Township at the present time, and he was told that it was.none of his business what the

, plan was, yet the evacueos are to traverse through the township."

! Harpersfield Twp 10/20/86 "The Harpersfield Township Trustees Population: 2,425 want to go on record that the Nuclear Regulatory C^mmission delay the issuing of a full power license to the Perry Nuclear Power Plant till such time as an adequate and acceptable emergency evacuation plan is developed."

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SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR FOWER PLANT JURISDICTION DATE CONTENT Jsfferson Twp 10/1/86 "...we the Board of Trustees of Population: 5,040 Jefferson Township, Ashtabula County, Ohio do support Governor Celeste's position to suspend further consideration on the licensing of the Perry Nuclear Power Plant pending review of the ,

emergency evacuation plan and further request our county commissioners and Governor Celeste call for a regional (Cuyahoga, Lake, Geauga, & Ashtabula Counties) referendum on the licensing and (

future oeprations at the facility to ]

be decided by the residents of I northeast Ohio."

Morgan Twp 10/15/86 "...these Trustees of the township Population: 1,367 of' Morgan does hereby call on.

Governor Richard F. Celeste to take all necessary steps to permanently )

close the Perry and Davis-Besse nuclear power plants and ban all future nuclear power plants in the State of Ohio, thereby assuring the residents of Morgan their natural, inherent and inalienable rights to happiness and safety and the s_

protection of property guaranteed in Article 8, Section 1, Bill of

- Rights, Ohio State Constitution."

Windsor Twp 10/14/86 " ...these Trustees of the township Population: 1,544 of Windsor do hereby call on Governor Richard P. Celeste to take all necessary. steps to permanently close the Perry and Davis- Besse nuclear power plants and ban all future nuclear power plants in the state of Ohio, thereby assuring the residents of Windsor Township their natural, inherent, and inalienable rights to happiness and safety and the protection of property guaranteed in Article 8, Section 1, Bill of Rights, Ohio State Constitution."

SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT Ashtabula County 10/2/86 See attached letter.

Population: 101,650 Geauga County Goauga County 10/6/86 See attached letter. ,

Population: 74,922 Cuyahoga County City of Broadview Hts 7/21/86 ...this Council of the City of Population: 10,844 Broadview Heights does hereby urge Governor Richard F. Celeste to halt the operation of the Perry Nuclear Power Plant by withholding his approval of emergency plans for the plant until such time as the safety of the citizens of Broadview Heights has been assured under such emergency plan."

City of Brooklyn 9/22/86 ...this council of the City of Population: 12,126 Brooklyn does hereby call'on Governor Richard F. Celeste to take all necessary steps to permanently close the Perry nuclear power plant and the Davis-Besse power plant and ban all future. power plants in the State of Ohio, thereby assuring the residents of Ohio their natural, inherent,.and inalienable rights to happiness and safety and the protection of property guaranteed in Article B, Section 1, Bill of L

Rights, Ohio State Consitution."

l Village of Brooklyn 9/16/86 "This Council of the Village of Hoights Brooklyn Heights does hereby urge Population: 1,629 Governor Richard F. Celeste to halt the operation of the Perry Nuclear power Plant by withholding his approval of emergency plans for the plant until such time as the safety of the citizens of the Village of Brooklyn Heights has been assured under such emergency plans."

SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT JURISDICTION DATE CONTENT City of Cleveland 9/15/86 ...the Council of the City of Population: 546,543 Cleveland does hereby urge Governor Richard P. Celeste, the Nuclear Regulatory Commission and the Public Utilities Commission of Ohio to take all necessary steps to prevent the licensing of the Perry Nuclear Power Plant, thereby protecting the lives and property of the residents of Cleveland and surrounding communities from the dangers posed by the operation of the Perry Nuclear Power Plant."

City of Cleveland Hts 10/6/86 "This Council of the City of Population: 56,937 Cleveland Heights does hereby urge-Governor Richard F. Celeste to hal,t the operation of the Perry Nuclear Power Plant and the Davis-Besse Nuclear Power Plant by withholding his approval of the emergency plans for the plants until such time as the. safety of the citizens of Greater Cleveland has been assured under such emergency plans."

Cuyahoga County . 6/5/86 "We will ask the Governor to

. - nPopula tion : 1,460,561 petition the Nuclear Regulatory

• Commission to delay putting the Perry Plant on line until we have an effective plan for evacuation.

~Cuyahoga County 9/24/86 "In light of the study by the Population:. 1,460,561 Lawerence Livermore National Laboratory that the nuclear disaster j of Chernobyl may have emitted 50 l percent more radioactive cesium than all of the atmospheric tests and bombs combined and in light of the call by the Catholic Diocese of Cleveland for a referendum on the nuclear power issue in our state,

' Commissioner [ Virgil] Brown and I

[ Commission President Timothy Hagan]

urge Governor Richard Celeste to take a leadership role on this referendum and on the public debate of the use of nuclear power in our state.

SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT  !

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l JURISDICTION DATE CONTENT l City of Lakewood 7/7/86 ...This Council of the City of ,

Population: 60,531 Lakewood does hereby urge Governor Richard F. Celeste to halt the operation of the Perry Nuclear Power l Plant by withholding his approval of the Emergency Plan for the plant until such time as the safety of.the citizens of Lakewood has been ,

assured under such emergency plan."

Middleburg Hts 8/26/86 "...this Council of the City of Population: 15,395 Middleburg Heights does hereby urge Governor Richard P. Celeste to halt ~

the operation of the Perry Nuclear Power Plant by withholding his approval of the emergency plans for the plant until such time as the safety of the citizens of Middleburg Heights has been assured under such emergency plan."'

City of Parma 9/2/86 ...the Council of the City of Parma Population: 90,225 does hereby urge Richard F. Celeste to halt the operation of the Perry Nuclear Power Plant by withholding his approval of the emergency plan for the plant until such time as the safety of the citizens'of Parma and surrounding communities has been assured under such emergency plan."

Summit County Summit County 10/20/86 ...the Council of the County of Population: 512,610 Summit commends the Governor of the

.,_ State of Ohio (1) for his decision to withdraw support of the evacuation plan for the Perry Plant until a review by.a safety committee appointed by him has been completed, and (2) for his expressed intent to provide a full hearing for the concerns of local public officials

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SUMMARY

OF LOCAL GOVERNMENT RESOLUTIONS AND OTHER STATEMENTS CONCERNING PERRY NUCLEAR POWER PLANT l

l JURISDICTION DATE CONTENT Summit County (cont.) and the general ~public. The Council of the County of Summit further requests the Governor to specifically consider the opinions of Summit County Officials and the citizens of Summit County in regar,d to the safety of the Plant. The Governor is hereby requested: (1)

To withhold State approval of the evacuation plan until he, or his safety committee, and the citizens of Summit County are satisfied that Planning for evacuation and other emergency procedures is adequate.

(2) To ask the team conducting the safety review hold a hearing and/or meeting in Summit County to allow our cit.izens as well as local

~ officials to express their concerns; and (3) . Recognizing our proximity to the plant, to include Summit County Disaster Management Officials in planning for an area-wide response to any emergency at the Perry Nuclear Plant."

Attachments: 10/2/86 Ashtabula County Letter --

10/6/86 Geauga County Letter l

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Ny Ashtabula County Enmmisstoners 4

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{l 25 West Jefferson Street Jefferson, Ohio 44047-1092 216/576-9090 Alfred W. Mackey l - Peter A. larocci

" Jeanne Bento

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" Betty Johns. Administrator /Gerk N-October 2, 1986 .

Department of Highway Safety Att: William M. Denihan, Director 240 Parsons Avenue Columbus, Ohio 43205

Dear Mr. Denihan:

Following Governor Celeste's letter of August 16, 1986 to the Chairman of the Nuclear Regulatory Commission regarding the State's position concerning the Perry Nuclear Power Plant evacuation plan, we have been seriously reviewing our plan. We feel that the State of Ohio has acted properly in making a review of the State's policy concerning evacuation planning for nuclear power plants,

, and we have seriously considered the need for policy changes at the State level and have several suggestions to make. However, we first must deal with the issues now presented by the evacuation plan and how it currently affects Ashtabula County.

First, we are asking the State to reassess the role of volunteers in the event of evacuation. If volunteers, such as bus drivers, who were scheduled to evacuate school children, and upon whose action much of the plan is predicated, are unwilling to enter the evacuation area, we have no legal or moral means to compel them to participate.

Secondly, we are seriously concerned about Ashtabula County Medical Center's ability to deal with contaminated persons who are also suffering other injuries.

Presently ACMC can treat only one radiologically contaminated injured person at any one time. Since the treatment of 'one patient at a time'.is severely inadequate, we ask that the State Department of Health consider a realistic reassessment of the capacity of the hospitals in the three counties to determine their ability to properly treat a number of radiologically contaminatadu jured persons. < -

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s Department of Highway Safety. Page Two

-October 2, 1986 Regarding the issue of ' independent monitoring, we currently have in our Emergency Operations Center the "Meteorologicial Information and Dose Assessment System" commonly known as ' MIDAS'. The MIDAS system monitors noble gasses, iodine and particulate releases at strategically placed vents at the Perry Nuclear Power Plant. While the MIDAS system itself may be adequate, we doubt that at this time there is a sufficient number of trained personnel to monitor it on a twenty-four hour basis. .We. feel that we need five (5) trained personnel to monitor th'e MIDAS system - making allowances for vacation and normal attrition.

Further, we are concerned over the adequacy of the State's field monitoring. .

Because the State of Ohio has only one person to monitor the approximately -

seventy (70) field monitoring sites surrounding the Perry Nuclear Power Plant,

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we feel that the State need to provide additional. manpower for the field monitoring operations. ,

The State of Ohio has not provided adequate guidance concerning the 50 mile ingested pathway. This refers to the precautions that need to be taken to protect the food supplies in the area. This is clearly a State responsibility and the State has been lax in developing its plan, there has been little or no guidance given the local governments.

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Furthermore, in 1985 the Ohio Department of Health issued its ruling concerning the uses of' potassium iodide (KI). KI is an effective blocking agent to protect ,

individuals exposed to radiation from liver damage. The Ohio Department of Health recommended that KI be provided to the emergency workers. Over a year i later the State Disaster Services Agency incorporated the Ohio Department of

Health's recommendation into its plan. However, this does not address the issue of the availability of KI for the average citizen. We are advised that KI cannot be sold without a prescription and feel that the State needs to address this issue as it is clearly a State matter.

r The State needs to revamp its policy and provide additional competent staffing at the local level in dealing with the issues of evacuation planning.- We have no confidence in the State's' ability to properly respond to a crisis from-Columbus. There needs to be enough personnel on site to provide the necessary assistance.

The matter of financial support for the local communities for the evacuation plan is currently provided by the utility companies. We feel that this policy needs,to be revised and'that the funding required to plan and implement evacuation' planning should come from the State of Ohio. The role of the local governments and the utilities concerning the evacuation plan should be at arms' length.

Finally, there is the issue of public awareness. Only the State of Ohio and the utilities have the financial resources to adequately address the many concerns of the citizens, both within and without the ten mile zone. There are numerous questions upon which we have no qualifications and cannot respond, and the public has a right to know.

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Page Three Dapartment of Highway -Safety October 2, 1986 l

We require the assistance of the State in addressing dthe issues of the ro e y cf of volunteers, independent montioring, the issuance of Kl.We the doanot equac want the hospitals in the three county area, and 50 mile pathway.fforts countermanded' '

to proceed on these issues ourselves only to have our ewe feel it is essentia by the State.

before the plant enters a full power status._

i d We recognize that the plan is a living document and that it has been rev seAshtabula ,

in the past and will be revised in the future. from the .

to respond to constructive criticism of the plan whether it comes i general public or the State as it carries out the review of the evacuat on plan. '

We have been charged with the Our concern, as yours, is the public safety.. This duty has been imposed duty of developing an emergency evacuation plan.We have put forth.the effort to develop t have'your by State and Federal regulations.the best possible plan and we will continue 4 assistance.

Very truly yours, .

SIONE S HTABULA CQUNTY 1

C0 M _

(0L 1]h QC i 4

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COUNTY .OF GEAUGA- ~

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DGAk C' O W ?/) $ f 6 5 0 fl8 4 6-Edno L. Davis C urthouse Annex t

Tony colt 4 219 McIn Street James weller ,

Chcedon, Ohio 44024 Tim Taylor i Administrator Telephone: (216) 285-2222 October 6, 1986 Janice A. Studly < -

834-1856 clerk ,

564-7131

. . . - x-William M. Denihan, Chairman Emergency Evacuation Review Team Department of, Highway Snfety 240 Parsons Avenue' Co' lumbus, Ohio '43205' i m

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Dear Mr. Denihan:

ss The Board of Commissioners of Geauga County would like to take this t , opportunity to endorse the position of the Board of Ashtabula County-i Commissioners .in reque' sting some further. consideration..of the current i emergency response plan. While there are some changes ~ in the content j l .hf the letter due to our'particular concerns, the essence of their i ' concerns still remains close to our own views.

i We strongly urge the Review Team carefully consider the implications of any findings and determine wheth'er inadequate planning in 'any area is due to lack of State participation in' the local funding. process. We .

recognizq. our extreme limitations when it comes to expanding any ph'ase

, of the current emergency response plan beyond the ten mile limit.

L We are asking the State of Ohio to reassess the role of volunteers in the event of evacuation. While we recognize that the many individual emergency and safety departments in the county are unpaid volunteers

. who have developed their emergency response procedures with long and careful planning, we also recognize the limitations to implementation of the County's Emergency Response Plan with those individuals who

, woul'd in' frequently respond to any emergency. We agree that in the event of an incident of major proportions at the Perry Plant, we could not compel

. - any volunteer to enter the evacuation area.

We ask that a review and reassessment by the State Department of Health be made of the procedures and ability of all hospitals in the three county s area be undertaken to determine the adequacy of treatment for contaminated persons who are also suffering other injuries. Geauga Hospital has capacity to treat one radiologically contaminated injured person at one time and although the staff at the hospital is highly skilled in their emergency response to any incident at the plant, we also feel that the procedure of

'one patient at a time' severely limits the hospital's ability to treat a number of radiologically contaminated, injured persons.

We do net at this time have the " Meterological Information and Dose' Assess-ment System" nt our Emergency Operations Center, but we echo Ashtabula County's feeling for increased nucbers of trained personnel to monitor their MlDAs system and again emphasize the need for State intervention in the funding process.

Further, we are concerned over the adequacy of the S tate's f ield monitorir.g.

Because the State of Ohio has only one persen to monitor the approximately swbnty (70) f ield monitorin~, sites surrounding the Perry Suelear Power Planc, we feel that the state needs to provide additional manpower tor the fictd monitoring operationq. I

N' f . > .

• _, The State 'of.0hio has not provided adequate guidance concerning the 50- mile g Prye '2 ingestion pathway. This refers to the precautions that need to be taken to protect the food supplies in the area. We also express our concern for the adequate care of farm animals in the area and request the Ohio Department of Natural Resources review their procedures in housing and feeding of livestock which are the economic lifeline of many residents of our county.

Fu thermore, in 1985 the Ohio Dt.partment of Health issued its ruling con-cerning uses of Potassium Iodide (KI). KI is an effective blocking agenc

. to protect individuals exposed to radiation from thyroid damage. The Ohio Department of Health re. commended that KI be provided to the emergency workers.

Over a year later the State Disaster Services Agency incorporated the Ohio Department of Health's recommendation into its plan. However, this does not address the issue of the availability of KI for the average cit'izen. We understand that.KI can ,be purchased as an over the counter medication but in a cursory review of local drug stores, we found the supply of KI to be woefully inadequate. We therefore, request the Ohio Department of Health provide some means of providin'g adequate supplies of KI for distribution '

• in-a. time.ly manner during the event of a radiological incident.

The State needs to revamp its policy and provide additional competent staffing at the local' level in dealing with the issues of evscuation planning. -We have.no confidence in the State's ability to properly respond to a crisis from Columbus. There needs to be enodgh personnel on site to provide the necessary assistance.

The matter of financial support for the local communities for the evacuation plan' is currently provided by the utility companies. We feel that this policy needs to be revised and that the fundihg required to plan and implement evacuation planning should come from the . State of Ohio. The role of the local governments and the utilities concerning the evacuat'on plan should be at arms' length. .

Finally, there is the issue of public awareness. Only the' State of.0hio and the utilities have the financial resources to adequately address the many concerns o'f the citizens, 'both within and without the ten mile zone. There-are numerous questions upon which we have no' qualifications and cannot respond, and the public has Mright to know.

We require -the assistance of the State in addressing _ the issues of the role of volunteers, i'ndependent monitoring, the issueance of'KI, the adequacy ,of the hospitals in the three county area, and 50 mile pathway. We do not want to proceed on these issues ourselves only to have our efforts countermanded by the State. We feel it is essential that the State deals with these issues

'before the_. plant enters a full power status.

We recognize that the plan. is a living docynent and that it' has been revised in the' past and will be revised in the future. Geauga County will continue to respond to constructive criticism of the plan whether it comes. f rom the general public or the State as it carries out the review of the evacuation plan.

Our concern, as,yours, is the public safety. We have been charged with the duty of developing an emergency evacuation plan. This duty has been imposed by State and Federal regulations. We have put f. orth the effort to develop the best possible plan. and we will continue to do so but we must have your assistance.

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' e Sincerely,

-- SD GEAUGA COUNTY BOARD OF COMMISSIONERS

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