ML19257A532

Mod of Contention 16.Alleges Inadequacy of Emergency Plan Due to Absence of Factual Basis for 10-mile Limit for Evacuation.Accident Effects Per WASH-1400 Should Extend to Larger Distances.W/Certificate of Svc

ML19257A532
Person / Time
Site:	Three Mile Island
Issue date:	12/18/1979
From:	Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8001040571
Download: ML19257A532 (5)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

METROPOLITAN EDISON )

COMPANY, - --et al., ) Docket No. 50-289

) (Restart)

Three Mile Island )

Nuclear Station, Unit )

No. 1) )

)

SPECIFICATION OF EMERGENCY PLANNING CONTENTION SUBMITTED BY THE UNION OF CONCERNED SCIENTISTS Based on the TMI-l Emergency Plan and at the direction of the Board, The Union of Concerned Scientists wishes to specify and modify Contention #16 in the following manner:

(The underlined material is new or altered from the original contention)

The events at TMI-2 showed the inadequacy of NRC emergency planning requirements. Emergency planning be-yond the LPZ is a recognition of the residual risk associated with major reactor accidents whose consequences could exceed those associated with so-called design basis events. The TMI-l emergency plan is inadequate because it is not based on a weather-dependent worst case analysis of the potential consequences of a core melt with breach of containment. The public health and safety requires that there be in place prior to re-start of TMI-1 a feasible plan to evacuate the public in the event of such an accident and to take other n emergency measures at distances be- 1685 27z which evacuation is impractical.

8001040

These modifications reflect the fact that the THI-l emergency plan contains no factual basis for the establishment of a ten-mile limit for evacuation planning, nor does it con-tain provisions for protective actions such as shectoring and the administration of potassium iodide at distances beyond which evacuation is impractical. UCS contends that the short and long-term health effects of major reactor accidents such as those considered in WASH-1400 would extend to distances far beyond ten miles and that rational emergency planning must ac-count for this.

Submitted by

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Ellyn R. Weiss SHELDON, HARMON & WEISS 1725 "I" Street, N.W.

Suite 506 Washington, D.C. 20006 Counsel for Union of Concerned Scientists Dated: December 18, 1979 1685 273

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY, )

et al., ) Docket No. 50-289 (Three Mile Island Nuclear )

Station, Unit No. 1 )

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CERTIFICATE OF SERVICE I hereby certify that a copy of " Specification of Emer-gency Planning Contention Submitted by the Union of Concerned Scientists" was mailed flrst class postage prepaid this 18th day of December, 1979,' to the following:

Secretary of the Commission (21)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Chief, Docketing & Service Section James A. Tourtellotte, Esquire (4)

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Steven C. Sholly 304 South Market Street Mechanics burg , PA. 17055 Jordan D. Cunningham, Esquire Fox, Farr & Cunningham 232 0 North Second Street Harrisburg, PA. 17110 Karin W. Carter, Esquire Assistant Attorney General 505 Executive House P.O. Box 2357 Harrisburg, PA. 17120 Frieda Berryhill Coalition for Nuclear Power Postponement 2610 Grendon Drive Wilmington, Delaware 19808 1685 274

Cert. of Service Docket No. 50-289 Ms. Holly S. Keck Anti-Nuclear Group Representing York 245 W. Philadelphia Street York, PA. 17404 Walter W. Cohen, Consumer Advocate Department of Justice Strawberry Square, 14th Floor Harrisburg, PA. 17127 Robert L. Knupp, Esquire Assistant Solicitor County of Dauphin P.O. Box P 407 North Front Street ~

Harrisburg, PA 17108 Chauncey Kepford Judith H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, PA. 16801 John A. Levin, Esquire Assistant Counsel Pennsylvania Public Utility Commission P.O. Box 3265 IIarrisburg, PA 17120 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218 Kathy McCaughin Authorized Representative for Three Mile Island Alert, Inc.

23 South 21st Street Harrisburg, PA 17104 Marvin I. Lewis 6504 Bradford Terrace Philadelphia, PA 19149 Ms. Marjorie Aamodt RD #5 Coatesville, PA 19320 1685 275

. Cert. of Service Docket No. 50-289

• Ivan W. Smith, Chairman Atomic Safety and Licensing Board U.S. Nuclear Begulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Dr. Linda W. Little 5000 Hermitage Drive '

Raleigh, North Carolina 27612 George F. Trowbridge, Esquire Shaw,'Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 John E. Minnich Chairman, Dauphin County Board of Commissioners Dauphin County Courthouse Front and Market Streets Harrisburg, Pennsylvania 17120

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• Hand delivered 1685 276