ML19210C291

Memorandum on Re Aircraft Crash Probability Issue.Crash May Cause Release of Large Quantities of Highly Contaminated Water to Environ.Suggests Possible Rescheduling of Third Hearing to Consider Issue.Certificate of Svc Encl

ML19210C291
Person / Time
Site:	Three Mile Island
Issue date:	10/06/1979
From:	Kepford C Environmental Coalition on Nuclear Power
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 7911140037
Download: ML19210C291 (5)

Text

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ENVIRONMENTAL COALITION ON NUCLEAR POWER Co Oracters: Mr. George Bewnsma-R.D. et, Peach Bottom, Pa. 17563 717-548 2836 '

Dr. Judith Johnsrud-433 orlando Avenue, State College, Ps.1 f4 S UNITED STATES OF AMERICA Mnetto NUCLEAR REGULATORY , COMMISSION 2 9gg?Q -

DE 001 Before the Atomic Safety and Licensing Appeal Board O g'

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In the Matter of ) gg, &

.et al. ) Docket No. 50-289 METROPOLITAN (Three Mile Island EDISON Nuclear SCOMPANY,'tatioii, Unit 1)

INTERVENORS' MEMORANDUM ON THE RESURRECTION OF THE AIRCRAFT CRASH PROBABILITY -ISSUE The Intervenors in the yet uncompleted TMI-2 Operating License o.. ...,

proceeding present herein the views of the Intervenors concerning the possible rescheduling of the third hearing concerning the probability 1

of the crash of a larger than design: basis aircraft into TMI-2. At this time the TMI-2 Intervenors take no position on the two questions offered by the Appeal Board in its September 10, 1979, Memorandum.

However, the TMI-2 Intervenors do wish to offer to the Board, and other interested parties, certain observations which we feel deserve the consideration of the Appeal Board in reaching any decision on the subject.

1. The issue of detemining the probability of a larger than design basis aircraft crash into a safety related structure is not unique to THI-2. It applies equally to TMI-1, which shares the site and certain facilities'in cannon with.TMI-2.

2. The accident suffered by TMI-2 (and suffered and still being 1

It is customary to identify abbreviations, which is a practice of which we approve. However, we feel that the abbreviation THI-2 no longer needs to be elaborated upon.

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suffered by the residents. of Central Pennsylvania) has

'"not caused the issue to beccme moot, pending an eventual, however improbable, reopening of TMI-2. Instead, the accident has, if anything, complicated the issue markedly. The Intervenors note that the severe oxidation of the fuel cladding at TMI-2

- which occurred on March 28, 1979, has severely compromised one

- of the barriers between the fission products and the environment.

Furthemore, the water, contaminated with relatively high levels of fission products, which has escaped from and leaked from and continues to this day to 1eak from the reactor coolant system,,

is currently stored in tanks located in various places around TMI-2.

Since the Staff has detennined that it was unnecessary to provide the TMI-2 Intervenors (who have been formal and active participants in the still incomplete TMI-2 Operating License proceedings since 1974) with its Draft " Environmental Assessment" for the proposed Epicor II system, we do not even know where this system is located. If it, or even components of it, are outside the safety related structures of TMI-2, the vulnerability of the system to potentially severe damage and offsite radiological consequences due to the crash of an aircraft of any size, not just larger than design basis, apoears to be greatly enhanced. Thus, while the possibility of a rapid core meltdown upon impact of the large aircraft is now largely eliminated, the possibility of a release to the environment of potentially large quantities of highly contaminated water in the event of the crash into THI-2 of any size aircraft looms much larger than before the accident began but has not yet been evaluated by the Suspended Licensee or the NRC Staff.

As a result, the entire aircraft crash issue may have been greatly complicated by the TMI-2 accident, and it may tn deserving of imediate attention. -

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3. The accident at TMI-2, which occurred while this issue and j

the radon-222 issue were yet unresolved, calls into question ~ the standard practice of the NRC of allowing nuclear power plants to operate while unresolved safety and environmental issues pend.

As the Court noted: -

No more than did the Appeal Board and the Comission itself, both of which have denied the petitioner's

. request for a stay, do we think the petitioner, in the somewhat unusual facts of this case, has made a showing of irreparable injury to himself or anyone -

else, directly attributable to the plant operation sought to be stayed, warranting our issuance of an injunction pending appeal.

(Kepford v. USNRC, D.C. Cir., March 8, 1978, unpublished order, Case No. 78-1160, pages 2-3.)

However, an accident recently conceded by the Staff to be a Class 9 2

accident occurred at TMI-2 while the appeal of another kind of Class 9 accident (the aircraft crash) at TMI-2 was underway. The Intervenors note that, had the operation of TMI-2 been stayed pend-ing resolution of all unresolved issues, the accident coninencing March 28, 1979, would not yet have taken place. Whether or not, in the interim, the management of Met Ed, or the Staff of the NRC, would have engaged in a more thorough investigation and inspection of TMI-2 equipment and perhaps discovered the problems associated with the defective "electromatic relief valve" is, of course, unknowable. Suffice it to say, the accident and the injuries and latent injuries of whatever magnitude they actudly are resultant from it could have been at the least postponed and possibly pre-vented altogether. .

2 "NRC Staff Response to L -d Question No. 4 Regarding the Occurrence of a Class 9 Accident at Tr.. as Mile Island," Docket No. 50-272, August 24, 1979.

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4. The accident at TMI-2 calls into question the Commission

practice of relying on estimated probability of occuiJrence values for some events as the basis for precluding any discussion of the consequences of the occurrence of such events in the licensing of nuclear power plants. It is now clear that Class 9 accidents can and do occur, regardless of any calculated, estimated or hoped-for low probability of occurrence. The TMI-2 Intervenors believe that it is. now appropriate for this policy of the Commission to be altered so that those persons who must face and live with the risks of a catastrophic nuclear reactor accident on a continuing basis be fully appraised of the risks of future Class 9 accidents and their attendant consequences. We ask that this Appeal Board certify this question to the Commissioners of the NRC for resolution if this Appeal Board does not have the authority to decide the question.

The Intervenors trust that the Appeal Board will give full con-sideration to these observations in reaching its decision on the dis-position of the still pending aircraft crash issue.

Respectfully submitted, o

Chauncey Kep rd Representative of the Intervenors 433 Orlando Avenue State College, Pa.,16801 814-237-3900 Dated this day of October,1979 '

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., u n.uCATE OF SERVICE I hereby certify that copies of mn.dv::.0R'S PD'ORANDUM ON THE lesvERECTION C? THE AIRCRAM CRASH D2 C?.BILITY ISSUE have been served on.the following by .

deposit in the U. S. Mail, First Class, postage paid, this day of October, 1979:

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Edward Luton, Esq., Chairman George F. Trowbridge, Esq.

Atomic Safety and licensing Board Shaw, Pittman, Potts &

U.S. Nuclear Regulatory Commission Trowbridge Washington, D.C. 20535 1?OO M Street, N.W.

Washington, D.C. 20036

. Mr. Gustave A. Linenberger Atomic Safety and Licensing Board Atomic Safet, & Licensing U.S. Nuclear Regulatory Commission Board Phnei Washington, D.C. 20555 U.S. Nuclear Reguratory Commission-Dr. Ernest O. Salo Washington, D.C. 20555 Professor. Fisheries Research Institute, WH-10 Ato?.ic Sofety and Licensing College of Fisheries Appeal' Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 98195. Commission Washington, D.C. 20555 Karin W. Carter, Asst. Attorney General Office of Enforcement Docketing and Service D'epartment of Environmental Resources Section 709 Health and Welfare Building Office of the Secretary Harrisburg, Fennsylvania 17120 U.S. Nuclear Re-ulatory

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Comminaion Alan S. Rosenthal, Esq., Chairman, Atomic Safety and Licensing Appeal Panel Washingt n, D.C. 20555 U.S. Nuclear Regulatory Commission Henry J. McGurrem

, Washington, D.C. 20555 Counsel for NRC Staff

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Dr. W. Reed Johnson, Member, Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jerome E. Sharfman, Esq., Member Toseeh Hendrie Atomic Safety and Licensing Appeal Panel

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Chairperson U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Co=ission Washington, D.C. 20555 washington, D.C. 2c555 . . _ _ ..

Richard Kennedy Co=issioner f

U.S. Nuclear Regulatory Co-4 ssion

, U.S. Nuclear He6ulatory Cc-4 ssion Washington,D_.,C. 20555 Vashington, D.C. 20555 ~ '

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Victor Gilinsky Co-4 ssioner U.S. Nuclear Re6ulatory Co-4ssion Washington, D.C. 20$$$ .

Peter Bradford

'Ce==issioner Ig/f6([/ 2 U. S. Nuclear Regulatory Co m ission Va + 4 wton, D. C . 20555_ _. _ . _ ...

rd Chmmcey Kepfo//,73 '/ ' l s

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