ML19220C729
| ML19220C729 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/23/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19220C706 | List: |
| References | |
| ACRS-SM-0087, ACRS-SM-87, NUDOCS 7905140094 | |
| Download: ML19220C729 (12) | |
Text
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s THE EARLY LESSONS OF THREE MILZ ISLAND Testimony cf Ancheny Z.
Roisman Staff Afforney Natural Resources Defense Council Before the Subccmmittee on Nuclear Regulation of the Senate Public Works Committee I.
Intreduction My name is Anthony I.
Reis.7.a.. and I am a staff atterney with the Natural Resources Defense Council.
For many years NROC has been actively involved in providing through litigation, administrative action and legislation an increased public awareness of the risks associated with the use of nuclear technology to generate electricity and of the advantages of less risky alternatives to nuclear pcwer.
Tne events at the Three Mile Island nuclear facility provide all of us with graphic evidence not cnly of some of those nuclear risks but also of hcw incc=pletely we and the experts charged with designing, building, cperating and regulating nuclear pcwer plants understand those risks.
Because even new the accident at Three Mile Island continues, because substantial dangers still remain and because the accident, its causes and consecuences are not yet fully understccd, many urge that it is tco early to draw any conclusions frcm the events at Three Mila Island.
I believe there is already sufficient evidence a railable to learn sc=e imperatant lessens frc= this continuing catastrophe, and =y testimeny tcday will fccus en those lessons.
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. II.
The Role of Nuclear Power In The Future We already obtain approximately 13% of our electric pcwer from nuclear plants.
Plants already under construction and substantially completed will nearly double that amount.
In certain areas of the United States turning off nuclear power plants or abar oning those under construction would cause substantial economic costs and could create major disruptions in the t 'cryday lives of millions of citizens.
Yet, as we learned onlv
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N_t/ v ei; ago when the NRC shut down five nuclear plants, anc hcd rea..orced at T'.ree Mile Island, the continued cperai;on c2 nuclear power plants is susceptible to discovery of previously undisclosed and poorly understocd serious safety problems which require that the plants be shut down.
Thus as we increase our reliance on nuclear power we also increase the risk that safety related shutdowns of nuclear facilities will cause major econcmic penalties and turmoil.
These serious risks will continue so long as substantial unresolved safety problems exist.
This dilemma created by increasing reliance on an as yet unproved nuclear technology is a major impetus for a renewed commitment to energy efficiency and increased use of solar technology.
If these measures can provide the level of energy savings and supply which competent government officials have concluded is achievable, we can dramatically reduce our reliance on nuclear power.
But unless the Federal, state and local governments and the private sector take these alternatives seriously we will have little choice but to increase our reliance on nuclear power as well as on coal and oil.
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. effort required will depend upon substantial government encourage-ment both in terms of penalties for failing to use energy efficiently and subsidies to enable the most rapid installation of available technologies.
For instance, government enforced penalties would penalize industries, commercial endeavors, state and local governments and individuals who did not take advantage of proven technologies to reduce energy consumption.
An industry which did not replace old and worn out equipment with the most efficient, and, from the perspective of life cycle costs, the most economical equipment could lose invest 9nt tax credits.
Appliances which had lower capital costs and lower efficiency but which over their useful life were more expensive and less efficient than other appliances could be sold but subjected to a substantial excise tax.
State and local governments which did not use the most efficient and econcmical energy systems for buildings ccnstructed with federal funds would lose a part of the federal funding.
These penalties could not be fairly imposed if the capital needed to obtain the efficient systems was unavailable or too expensive.
We would need to establish a revolving low interest credit program, perhaps like the Rural Housing Insurance Find to assure the flow of capital at affordable rates to those who want efficient energy systems and solar energy systems but can't raise the necessary capital.
Payback periods for these loans would be adjusted to coincide with the time period over which the equipment would produce efficient economic 101 227
savings to recoup the investment.
These and similar programs would need to be implemented by the Federal government getting its cwn house in order both as an incentive to increased production of the needed equipment and as an important symbol to the Nation.
There are still major areas of Federal government energy use for which more efficient systems and solar systems are clearly warranted but for which little has been done.
There is every reason to implement this kind of major program for energy efficiency and solar energy.
Even if we need to continue to rely en nuclear power it would be preferable to keep that reliance to the level clearly required and not to supply electricity frem a plant like Three Mile Island to heat a poorly insulated home or run an inefficient machine.
Energy efficiency and solar energy create far more jcbs than the same dollars invested in massive electric power plants.
And of course improving energy productivity does not mean curtailing er changing our style of living but rather making each unit of energy produced capable of doing more work for us.
Thus a truly efficient energy system improves the standard of living and permits real and not inflationary growth.
Three Mile Island gives us every reason to move ahead new, swiftly and forcefully, with an efficient and solar based energy program for the United States.
In such a program nuclear power would play an increasingly insignificant role.
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. II.
How to Handle the Nuclear Power We Will Continue to Use A.
Emergency Response Planning and Inclementation.
One of the startling lessons we have clearly learned from Three Mile Island is that in a genuine emergency the experts are totally incapable of swiftly implementing emergency planning procedures.
Inadequate early notice by the utility to state and federal officials meant that for several hours after the onset of the accident radioactivity being emitted from the plant was not being adequately monitored off site.
Inadequate communications between the NRC and the utility even into the third day of the accident seriously hampered the ability of the NRC to advise the Governor of Pennsylvania of the need for measures off site to protect the public.
An overly bureaucratic chain of decision-making permitted numerous citizens living in the vicinity of the plant, particularly those in the northeast quadrant, to be needlessly exposed to significant levels of radiation.
As early as 9:15 a.m. on Friday, March 30, an NRC official advised state authorities to evacuate people within five miles of the plant, but no evacuation occurred because of the need to await an order from the Governor who was waiting to hear from the NRC Commissioners who were waiting to find out what was happening.
Between that time and the limited evacuation order issued by the Governor at least two plumes of radioactivity apparently passed over the exposed and unknowing populace in the northeast quadrant up to five miles from the plant.
The problems exemplified by these deplorable conditions are not unique to three Mile Island or Pennsylvania.
On 101 229
numerous occasions concerned citizens have brought to the attention of the NRC in formal petitions the f act that emergency planning for nuclear plants was woefully inadequate because of the inadequacy of implementation and testing of realistic programs for coping with emergencies.
While during the morning of March 30, numerous NRC experts, including Harold Denton, urged the Commissioners to recommend to the Governor a precautionary evacuation, there was not in place a decisional process to ir<plement the recommendation of these NRC experts.
Yet the NRC response to citizen petitions regarding the evacuation issue has been to disclaim any jurisdiction or resconsibility over the implementation of state plans and to refuse to shutdown nuclear plants where inadequate state emergency plan implementation was found.
In short, although the health and safety of the public clearly depends upon adequate and effective implementation of emergency planning procedures, the NRC new contends that it does not have the jurisdiction to do anything about it.
Clearly legislatien is required to:
1)
Require ima-1; ate notice to government officials of all accidents rather than awaiting a utility assessment of the severity of the accident.
2)
Re cai. e NRC to license and regulate implementation of state and local emergency plans.
3)
Require NRC to establish authority in appropriate field personnel who are at the site of a nuclear accident to recommend emergency response actions to state officials and where n( essary to compel that 101 220 those actions be taken.
Another serious aspect of the emergency response at Three Mile Island is the apparent intrusion of extraneous factors in the decision-making process.
When on March 30 the NRC was aware that they did not fu]17 understand the accident but that it could lead to a full core meltdown or an enormous hydrogen explosion, either of which could have produced catastrophic off site consecuences, why did it not immediately order an evacuation?
As one NRC official observed, what reason was there for not taking this precaution and who was the Commission protecting?
It is conceivable as one reads the transcripts of the Commission meeting, that public relations was playing an unwarranted role in the decision-making process.
A large part of the failure of the Commission to act promptly on the recommendation of its staff may also be attributable to the absence of the kind of clear leadership role that characterizes sound decision-making in a crisis.
Without the leadership, diffuse discussions prevailed and while the Commissioners fiddled the people of Harrisburg and surrounding communities remained in grave danger.
B.
Reliable Accident Information Even today the NRC and the utility are unsure about what has happened inside the containment building and inside the reactor.
Significant data needed to analyze the accident has been unavailable from the outset because the instruments needed to record that data had never been installed.
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. Apparently other ins.ruments did not function properly particularly in the humid, hot, highly radioactive and high pressure environment that existed after the accident.
Even much of the data that reached the control roem did not reach the NRC in a timely fashion.
The existence of an appa? nt hydrogen explosion in the containment during the early stages of the accident, which would have been an early warning of significant core damage, was only discovered by accident several days later.
To correct these problems it is essential that all nuclear plants now operating be immediately required to 1) ins tall the necessary instrumentation qualified to withstand post-accident conditions, 2) install remote readouts of all the data entering the control room to which the NRC has direct access in Washington, and 3) designate one additional persen in the control room whose sole function is to act as a direcu and permanent source of information to the NRC officials.
C.
Allocating the Economic Costs Only a few months ago the insurance industry that insures nuclear reactors proudly announced that the nuclaar safety record had been so good that it was rebating part of the premiums paid by the utilities.
Yet in the wake of Three Mile Island the utility is claiming that the largest econo.nic damages caused b" this accident must be paid not by the massive insurance coverage or even by share-holders but by the ratepayers.
It is incredible that the economic losses which customers of the utilities are being 101 232
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asked to pay,to cover the cost of buying power to replace the power to have been supplied by Three Mile Island, should not be covered by the insurance scheme established by Ccagress to insure that no member of the public would suffer an economic loss in the event of a nuclear accident.
In my judgment the provisions of the Price-Anderson Act apply to this loss and if the cost of replacement power is passed on to the utility customers they should be able to recover under the Price-Anderson Act for the damage to their property--
i.e.,
their money.
If it is not covered, then Congress should move swiftly to amend the Price-Anderson Act to provide coverage for the economic costs to ratepayers for any safety related unplcnned shutdown of a nuclear plant even if it is not as the result of an accident.
In Three Mile Island if all the economic losses caused by the accident are taken into account the limits on liability in Price-Andersen will be quickly exceeded, underscoring the need to eliminate the limits en liability contained in that law.
In addition it is quite likely that t e utility has understated the real costs involved as a result of tr 2 accident.
Those costs will probably include the write-off of the reactor as a total loss.
Levels of radiation in the containment building are strongly suggestive of s'ach severe contaimination, probably from Cesium-137, that it may be years before any clean-up of the containment could even begin.
D.
The Health Consecuences of the Accident An unfortunate and misleading official lin ey s
. taken on the health consequences of this accident.
Government officials have asserted that the total health effects of the accident are in the range of 1/2 to 1 cancer.
Of course to the person who gets the cancer and his or her f amily that single health effect is completely unacceptable.
Moreover, that estimate of health effects is an overly optimistic and unwarrantedly low estimate.
First, due to the inadequate and at
.mes non-existent off site monitoring of the full range of radioactive effluents conceivably released no one knows for sure how much radiation was released or what dose the public received.
Second, the correlation between doses received and health effects used by the NRC is based upon continued acceptance of values that are being seriously questioned as the result of analyses by Drs. Mancuso, Bross and Morgan.
While these more recent studies suggest that the health effects, i.e.,
cancers, nay be as much as 10 to 50 times higher than the currently used governmental values, the point is nct that these new studies are conclusively proven as correct but that the government officials had the responsibility to disclose the existence of an honest and significant scientific disagreement.
Finally, the government estimates of health effects and exposures totally ignores the exposure to which workers will inevitably be subjected as part of the work on the plant, even if there is only a limited clean-up.
These exposures will be to a large worker population as new workers are brought in to replace workers who receive their maximum permissible exposure (exposures which the head of the National Academy of Sciences
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- Committee on the Biological Effects of Ionizing Radiation, Dr.
Edward Radford, as well as Drs. Arthur Tamplin and Thomas Cochran of the NRDC staff, believe are at least ten times too high).
These certain health effects to workers should have been included in the government assessments.
It is reprehensible that even while the Three Mile Island accident continues the apparently irresistible urge to downplay the health and safety consequences of this accident and the risks of nuclear power persists.
In a revealing exchange at one of the Commission meetings on Three N.le Island two Commissioners urged witholding frcm thc public a report prepared by one of the NRC's leading safM.y experts on the maximum consequences which might occur as the result of explosion of the large hydrogen bubble at the plant (from unedited transcript of closed Committee meeting, April 1, 1979, p. 21):
"CCMMISSIONER GILINSKY:
YOU JUST KEEP IT TO YOURSELVES.
IT SHOULD NOT GO OUT OF HERI."
"CCMMISSIONER AHEARNF-IT SHOULD NOT GO TO THE PRESS, FOR EXAMPLE."
It is too late to put a happy face on nuclear technology and it is high time that NRC and the nuclear industry begin telling it like it is.
III.
Conclusion The aftermath of Three Mile Island will include a series of autopsies of the accident each designed to find and reveal the truth about what happened, why and what to do about it.
In 101 235
, the Vermont Yankee decision the Supreme Court stated that the ultimate fate of the nuclear option rests with the Congress.
The investigation which this Subcommittee undertakes of the Three Mile Island is the crucial test of the Congressional will to accept the responsibility which he Supreme Court concluded it possesses.
Unless there is sufficient financial and staff commitments to that study the results reached will not be credible and the Congress will have shirked its crucial respcnsibility.
If the study is done prcperly, with the full and effective involvement of the public and all interested parties, it can be an important part of the data base upon which Congress carries out its duty to decide the fate of nuclear power.
Thank you for the invitation to appear here this morning, i
i 101 236