ML20004E838

Amended Contention of T Kenney.Facility Evacuation Plan Fatally Defective Since Applicant Definitions of Affected Persons,Contaminated Area,Dose Projection & Emergency Action Levels Are Deficient.Certificate of Svc Encl

ML20004E838
Person / Time
Site:	Perry
Issue date:	06/08/1981
From:	Kenney T AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20004E837	List: ML20004E836 ML20004E838
References
NUDOCS 8106150359
Download: ML20004E838 (7)

Text

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                                                                                                               " " 1 31981 ,

UNITED STATES OF AMERICA . NUCLEAR REGULATORY C0iGIISSION Before the Atomic Safety and Licensina Board In the Matter of

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CLEVELAND ELECTRIC ILLUMINATING CO., Docket Nos. 50-440 EI Al. ) 50-441 (Perry Nuclear Power Plant, Units 1 and 2) f s)

                                 .      .           INTERV:NOR 'S AMDDED CONTENTION-1 On March 16 th int rvenor filed a petition for leave to l              intervene and was accepted as a party on it's merits. On nd                   rd June 2          and 3                      a prehearing conference was arrani;ed. The purpose was to provide " potential intervenors a better op-potunity for meaningful participation in the hearing process."

37 Fed. Reg. 15127. 15128 (July 28, 1972). Deficiencies in l l respect to all parties were alluded to and the Board allowed that during the course of the conference that the contentions of all intervenors could be refined. On June 2 nd the Board allowed that Mr. Kenney be. allowed to adopt a contention of l another intervenor or present one hincelf by the close of the conference. This was agreed upon by all parties. On rd June 3 intervenor orally presented an elaboration of a contention stated by other intervenors and presented in in-tervenor's original brief. This was an attempt to satisfy the 9 card's Crder and the needs expressed by Applicants and 1 . . . . . . 8106150353

Staff that interveners' contentions be more specific. This document is filed in accordance with an order that inter-venor serve said contention in written form to all parties. Intervenor alleget that the evacuation plan for Ferry is fatally defective in numerous aspects and inadequatelty protects the safety of the public with respect to but not limited to various deficiencies. V.any of the concerns deal directly with new information that was not available at the time of completion of the FSAR. This therefore allows for reexamination of the evacuation plan. 10 C.F.R. 51.21 and

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51 23(e). This new information regards new research on the re-calculation of the effects of nuclear radiation on people done by Dr. Edward Radford. (Pittsburgh Post Gazette, Scientist: Radiation Risks Higher 5-16-81) . Dr Radford be-lieves that the probabilities for contracting any form of 4 cancer after irradiation will be quadrupled. This infor-mation warrants reevaluation of the evacuation plan. CONTE; TIC'; ( evacuation ula".) Intervenor alleges that the evacuation plan for Perry is fatally defective in regard to but not limited to the >

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fallcwir.g deficiencies; including the need for recalcula-tion of all radiation standards and accociated aspects of the plan.

1. Applicants ' definiti an ( 2) of'affected persons 'is Deficient. (Vol. 16, Appendix 13A, p. 1-1).

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a. It does not state a specific criteria as to what constitutes the degree at which a person requires special attention.

b. This leve: is open for recalculation due to new inforr.ation referenced :)eforehand.

c. It does not state how. personnel decontamination

! of 'affected person' will be facili.tated.

2. Applicants' definition (10) of ' Contaminated Area' is deficient. ( Vol. 16, Appendix 13A, p.1-2) .

a. Reference values regarding contamination levels must be recalibrated.

3 Applicants ' definition (14) of ' Dose Projection' is deficient. (Vol. 16, Appendix 13A, p. 1-2).

a. The dose projection is calculated from an off-site monitoring program which only includec l

I accumulative readout and is noncontinuous. A p-plicant should install off-site monitors with j continuous readout of current ionizing radiation.

4. Applicants' definition (15) of ' Emergency Action Levels' is deficient. (Vol. 16, Appendix 13A, p. 1-3).

a. The threshold at which action is to be implemented must be recalculated in light of new information.

                                                 '.      Applicants' definition ( 36 ) of ' Plume Exposure Path-way' is deficient. (vol.16, Appendix 13A, p. 1-5).

a. The pathway would have to be enlarged due to re-esiculation of radiation dose effects in light of-D h a "a 9 6 s .-- - , - . - - , _ , . - . , , , , , , , - , , - . ,, p. , ,, , , , , - , , - , - - - - -p,.., y>w--e-.-,- ,- ,

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6. Applicants' definition (42) of ' Protective Acti'on Guides' is deficient. (Vol.16, Appendix 13A, p.1-6) .

a. The protective action guides would have to be re-calculated in light of new information.

7 Applicants' ' Emergency Planning Zones' are deficient. (Vol. 16, Appendix 13A, Section 2 3, p. 2-2).

a. The first EPZ is compared with the plume exposure pathway. Since this aspect of the plan needs to be altered, the EPZ dimensions will have to be chan6ed and enlarged.

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b. The concern regarding the second EPZ is the in-gestion pathway of Iodine 131 par'.iculate fall-out. Applicants' state that a monitoring program of crops, dairy cows, and farm animals would be neccessary. Intervenor asserts that the human population should be included in the monitoring program since they will be ingesting affected food, be it ga: den vegatables or locally produced food products.

8. Applicants' ' Emergency Classifications' are defec-tive. (Vol.16, Appe: lix 13A, Sec tion 3 3, p. 3-4) .

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a. The Alert Classification 2 includes a limited release of radicactive caterial. Further descrip-tion of Alert Classificaton 2 makes no mention that the .cnitoring teans will be deployed. A p-plicants' should provide for this.

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                                                             -5 9    lhe Applicants should provide off-site read.ut of the current level of ionizing radiation with monitors _,that give instantaneous determination.

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10. Applicant should provide for stockpiling of Potassium Iodide at the receiving hospitals, Lake County Memorial Hospital, East, Paincyille, Ohio and The Radiation *.:edicine Center Hospital, Univerr'ty of ,

Pennsylvania, Philidelphia, PA.. (Vol. 16. Appendix 13A, Section 5 5, p. 5-14) .

                            . 11. Agreements with the local conmunities are not form-
                                        ' ally reached and therefore not binding so the evac-uation plans are fatally defective.

12. Applicants make no provision for payment to local communitiec for planning or maintenence ofithe evacuation plans and therefore is defective.

13 Applicants may suffer financial difficulty and would therefore be hampered in safely operating the nuclear facility. A factor whi:h would influence this would be the Muny Light anti-trust suit case.

14. Applicants' off-site radiological monitoring pro-gram is deficie.t. (Vol.16, Appendix 13A, Section 7.6.8.2, p. ?-13). "The Computer will perform cal-culations that will determine the radioactivity concentration and doce to all sectors of the envi-rament around the plant." By following the reference

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              .                                                             -6 to table 'i-4 the list of type of samples are given.

The list includes air borne, surface water, drinking water, sedi=cnt, fish, and milk. The sampling of thi human population is not indicated on the list. Since this is the ultimate concern it should be included amongst the sampling. CERTT?1CATF C? SER'ITCE I hereby certify that copies of INTER'IEiCR"S Ay. ENDED CCNTENTION have been served on the following by deposit in the United th States mail on this 8 day of June, 1981. TW K.'~,f Tod Kenney I hereby certif y that copies of KEiNEY ADDRE: 1 CF.ANGE have been served on the following by deposit in the 'Jnited States mail on this S th day of Ju e, 1981. TJ P .- f Tod Rsnney [ P00R ORIG NAL

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     .e Peter b. Bloch, Chairman Atemic Safety and Licensing Board
           ".S. Nuclear Regulatory Co==ission Washington, D.C. 20555 Dr. Jerry R. Kline Atetic Safety and Licent.'ng Board U.S. Nuclear Regulatory Jo= mission Washington, D.C. 20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Muclear Regulatory Cor. mission Washington, D.C. 20555 Jay Silberg, Esq.

Shaw, Pittman, Pot:c, Trowbridge & Madden 1500 % Street, N.W. hachington, D.C. 20036 Conald T. Szzone, Esq. Accistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Chio 44077 Daniel D. Wilt Wegman, Hesiler & Vanderberg 7301 Chippewa Road, Suite 102 3recksville, Ohio 44141 Terry Lodge, Esq. Attorney for Applicants o15 Spitzer Building Toledo, Chio 43604 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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AtomiF Safety and Licercing Appeal Board Panel

           's . E . N uc lear L.Er;ula ter*/ C cE.CiGeiOr Wa ;r.i:.g :c:. , C.;. 2:355 Docketing ar.d Service Secti:n Cffice of t..c Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 2:555 P00TORIGINAL
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