ML19029A755
| ML19029A755 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/22/1979 |
| From: | Onsdorff K, Van Ness S The Public Advocate |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML19029A755 (9) | |
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UNITED STATES OF Ai\.IERICA NUCLEAR.REQJLA'IDRY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Docket No. 50-272 PUBLIC SERVICE ELECTRIC & Proposed Issuance of .Amendment to GAS CO *. Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1)
INTERVENORS' , COLB1A.i~, RESPONSE TO BOARD QUESTION !';UMBER FOUR: \'lt..s
'Th'IT A CLt\SS NINE ACCIDB\JT?
STANLEY C* VAi'J l\'ESS PUBLIC .ADVOCATE OF l\'EW JERSEY DEPARTME.t'IT OF *1HE PUBLIC ADOVCATE DIVISION OF PUBLIC I!'-.'TEREST ADVOCACT P. 0. BOX 141 520 EAST STATE STREET TRENTON, :r-.rEW JERSEY 03625 KEI1H A. ONSDOru=F ASSISTA1'ff DEPUTY PUBLIC .Ll.DVCCATE Attorney for Intervenors, Coleman
- . e
- TI-IE PROPOSED A~Nl:X TO .-\PPENDL'{ D,.
10 CFR PART 5 0, APPE-\RS TO DEFIX-""E A CLASS 9 ACCIDENT .l!lS A SEQUENCE OF FAILURES l\1UG! ARE MO~ SEVERE "IR;\;.~
TI-IOSE 1\HIGI 11-IE SAFETI FEi\1URES OF Tr1E PLA.i'i! ARE DESIGNED TO PREVE:\T. 'TI-IE SEQUENCE OF FAILURES AT 1HREE MILE ISLAi'\10 PRODUCED A BREAGI OF 'IlfE. CO~TAIN ME!W AND A RELEASE OF R<\DL\TICN l~hl:Q-1 COULD NOT BE PREVEN!ED BY TI-IE S...u=ETY FEA1URES. WAS 1HE OCCURRENCE AT 1HREE MILE ISLfu'ID 1HEREFORE A CL:\SS 9° ACCIDEN"T?
The ~'uclear Regulatory Connnission in proposed lmne.."'< A to .Appendi..x D to 10 C. F. R. Part SO has defined Class t\L""le accidents as:
"successive failures more severe tl..an those postulated for the design basis for protective systems a.'!d engineered safety features. Tne:i.r consequences could be severe."
36 F.R. 22852.
Beyond this brief description, the Annex definition provides no qualitative measure for detennining the magnitude of environmental consequences which are deemed likely to flow from a Class Nine accident- It 1*muld appear, therefore, that -che gravamen of the Class Nine Event:. is the magnitude of equipment and/or human failures which exceed the rea::tor 1 s defense in depth safety systems. ~lost simply put, the differem::e between a crass Eight and Nine Accident is folIDd in the proposition. that in all 'credible' hypothetical accident ("Class Eight") scenarios,. the plant's redt.mdant safety systems activate as designed to ensure sufficient cooling water flow to the reactor at all times. Postulated accidents :more severe than the engineered safety features in P\\'.Rs prior to ~*!arch ZS, 1979 were deemed so re::-:ote Li probability that the !\"RC could license these plants for operations consistent Ki th its statutory marni.-:i.te to "provide ad.equate protection to the health airl safety of the public. 42 U.S.C. s 233Z(a). :\'o more tl-.;an a curosory fa..'lliliari~y with the Corrunission' s response to the Three Mile Island
e-accident is needed, however, to know that t_he NRC has begun a substantial upgrading of PWR safety features to prevFent another uncontrolled LOCA caused by loss of the main feedwater supply. See e.g. J\iUREG-0578, ThII-2 Lessons Learned Task Force, Status Report and Short-Tenn Recormnendations.
This l~tter regulatory action, when coupled with* the moratoritmt on the issuance of operating licenses pending adoption of -these Lessons Learned~
demonstrates quite convincingly that the events at Three Mile Island
- constituted a Class Nine accident. Roger :Mattson 's earlier comments t:o the.
Commission aptly stnmnarize the Staff's conclusions 1th.at the "INI-2 accident surpassed the engineered safety features at this nl'JC.lear power reactor:
"Ke saw failure modes, the likes of which have never been analyzed."'
Mattson, Nucleonics Week, April:.
26, 1979 p. 10; Transcript Maren 30, 1979 Co:rrnnission Meeting.
WAS IBE RISK TO HEALlH .fu\iTI S.l\.FE':n" Ai'ID THE EWIRONvlENT I Iffi\"K)'I'E IN PROBABILITI' OR 'EXTREMLEY LOW' AT 'TiffiEE MILE ISI.A~l), .AS TIIOSE TERivJS ARE USED IN IBE A,7\JNEX?
The risk was real. It was of an undetermined miagnitud.e and may well be continuing as efforts are initiated to unde!rtake the most sensitive and extensive nuclear plant decontamination in history. 'I1te reality of the Th!I risk to the public's heal th and safety was recognized by the Nuclear Regulatory Corrnnission and the State of Pennsy1vania. NRC Chairman Hendrie told Governor Thornburgh that it m."ight become necessary to evacuate the general population residing as far as twenty miles from the reactor site. House of Representatives Report No.96-413, E."nergen9r Plwning Around U.S. *Nuclear Powerplants: Nuclear Regulatory Commission Ov"ersight, p.2 August 8, 1979. Subsequently, the Governor recommended. that pregnant women and families with children five years and younger in age, living within five iniles of the plant leave this area. Acrai:n.
.::. , Roa-er 0 Mattson ,.
e-Director, Systems Safety Division succinctly articulated. the Staff's via-r of the DI! danger wJlen he reported* to the Conunission on the unfolding events durin,g_
the accident:
"The latest burst didn't hurt raany people. I'm not sure why your not moving people. Got to say it. I have been saying it down here. I don't know what we are protecting at this point. I think we ought to be moving people. Mattson, Nucleonics Week, April 30, 1979 p. 2 Transcript March 30, 1979 CoTTnnission :Meeting.
However, while Mr. }.lattson sought to reassure the Commission that up ta that time few people had been injured, the needed data base to support this opinion was non-existent. The House Committee on Goverrnnent Operations,.
J\uclear Regulatory Commission Oversight Report of .August 8> 1979 cites the June 21, 1979 Corranission meeting at which it received a Briefing on Facts of Th-II Radiological Sequence" to conclude:
"Most of the radioactive material released during the accident was discharged from the plant's stack. The Radiation monitor in that stack, however, was designed to register only the normal low level radiation releases associated with routine operation. During the accident the instrument was off-scale, or
'¥egged. 1 14 Thus, emergency response o f icials could not be advised during the accident of how much radioactive material was being released into the environment.
In fact, it will never be known how much radioactive material the le around Three Mile lslan were exposed emphasis added, Report p. 22).
merely
\\nile Footnote 14/cites testimony presented to the Subcommittee on Environment, Energy and Natural Resources, Footnote 15 states in part:
"The problem caused by the inadequate moni taring capability was compounded by the fact that the first charcoal and particulate filters . . . were lost and never analyzed.
. . . The stacks monitor was bv no means the only inadequate measuring devi~e. For example, unfil tereci radioactive steam was vented totally unmonitored. Of£-gasing from water on the floor of the diesel generator building was exhausted through the building ventilation system totally unfiltered and unmonito-red-Radioactive water leaked into the plant's industrial waste treatment system from pumps in the turbine building,. the. diesel generator building and the service building.
The radioactivity which leaked into. the system was thus exhausted unfiI.rered and with inadequate monitoring into the Susquehanna River. In fact,. At Gihson, the NRC official who is leading the radiological effects portion of the Cornmissi:0n investigation stated 'most of the radiation :monitors in the plant were unreliable' during the e.:arly part of the accident. (Citations to hear:ing tran-script omitted)
Previous confident assertions that the populace of Pennsylvania had been exposed to no more than the equivalent of several chest x-rays were apparently based upon dose meter reading set up arc:m:md -the vicinitY of the plant after the on-set of the accident. Mr. Gibson in hls briefing to the Connnission noted the inappropriateness of reliance uipon such instantaneous dose meters which do not provide cumulative exposure me:asurements,nor the
. period of exposure. See June 21, 1979 transcript a1: p *. 75. Even more surprising in light of the health reassurances provided!. by former H.E.W.
Secretary Califano as to the increase in cancer rate around Harrisburg>
Pennsylvania, the :NRC Swnmary of the Office of Inspect:ihon and Fnforcement Report states that:
"during a five and one-half hour period from 1700 hrs. to 2238 on ~!arch. 28 and a ti..;o-hour period from 0340 to 0540 on March 29, no offsi te surveys were performed in the plume. Both of tllese periods of time were ldthin w11.e in!:erval when the majority of the noble gases we!re released and when a plume was well defi.."':led because of sufficient wind speed and almos-n: constant direction.
These data supported the conclusion that radioactive noble gases released to the atmosphere were the principal cause of exposure for individuals in the plant environs." N"RC News Release Voltmle 5, 1\'urnber 28, August 7, 1979 p. 7.
The continuing nature of the TMI risk is demonstrated by harrowing testL11ony recently presented to President's Kerneny Commission. by 'Ib.omas Gerush.-y, Pennsylvariia' s top radiation protection official. ~-rr. GertI.Sky stated that there exists 11 an imminent possibility" which *will. continue for at least four years that an evacuation of persons living nearby the crippled.
reactor 1*;ill be necessary. The Pennsylvania official cited as contributir:g factors to the continuing hazards at ThII:
"'millions of gallons' 0£ water to treat,.
there is krypton in 'megacurie quantities 1' above the water in the containment and that defense in depth 'would be gone' when the reactor vessel is opened to remove damaged fuel."
Gerusk-y further observed that:
"containment and the reactor vessel mu.st be opened for .such an operation, and that .
the last defense, fuel cladding, isn't present on rrruch of the fuel." (Gerush.-y,.
Testimony as reported in Nucleonic Week>
- p. 2, August 9, 1979.)
It is now believed that the radiation levels above the contai:runent floor range from 1-5 rem/hr. and levels in the water below the floor may be as high as the hundreds of rem/hr. 1\ucleonic Week p. 1, July 12,. 1979. In light of the NRC regulations on worker exposure, the delicate decontamination procedures will entail use of relay teams working inside containment for extrc;-;iely short tme periods. The ThlI cleanup program relying upon worker substitution procedures with each person given a couple of In.inutes to perform.
highly cc::iplicated tasks can only increase the risks of further radiation release during this. phase of the TI-11 accident recovery.
- CONCLUSION For all the foregoing reasons, it is resepctfully requested that the Board pursue its stated objective of thoroughly exp1oriTig a11 relevant safety issues pertaining to the commercial use of nuclear energy at* Salem One in conjunction with the opera ti on of a spent fi...'el pool eighty feet from this reactor.
Respectfully Suhimitted, STA~""LEY C. VAl'f ~iiESS, PUBLIC ADVOC:.~TE KEITrt A. ONSDORFF - .V I ASSISTA'IT DEP.JTY PUBLIC i\D¥~
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e-lliITED STATES OF AMERICA
- NUCLEAR REGUU\TORY crn*NISSION Before the Atomic Safety and Licensing Board IP- the Matter of PUBLIC SERVICE EI.ECIRIC Docket ~'a. 50-272
&GAS CO.
(Salem Generating Station Unit #1) 0:--RTIFICATE OF SERVICE I hereby certify that the Colemans' response to the :Board Question #4 in t.lie above captioned matter have been senred upon the service list by deposit in the United States mail at the post office in Trenton, NJ,. ,...,-j_th proper postage t11ereon, this 21th day of August, 1979.
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KEITII A. ONSOORFF L<._..---,,
Assistant Deputy Puhlic Advocate Dated: August 21, 1979
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