ML19224C156
| ML19224C156 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/24/1979 |
| From: | Kepford C CITIZENS FOR SAFE ENVIRONMENT |
| To: | |
| References | |
| NUDOCS 7906290206 | |
| Download: ML19224C156 (6) | |
Text
N t'T hkC m.
' STATE OF PENUSYLVANIA
'. =
ss:
T COUNTY OF LANCASTER g,
un.
sw
~.
]_
s
^
I,DaunceyKepford reside at 433 Orlando Avenue, State College, Pennsylvania, 16801.
I have a Ph.D. in chemistry from the University of Calgary in Alberta, Canada.
I worked for two years as a radiation chemist for the United Aircraf t Research Laboratory in East Hartford, Connecticut.
For tuo years I uas an assistant professor of chem-istry at the York campus of the Pennsylvania State University.
I have tes tified before numerous state and federal legislative and ad-
-o.nis trative bodie s.
I testified before the Atomic Safety and Licensing Boards of the United States Nuclear Regulatory Corr ission as an expert witness on the environmental and health affects of radioactive aef-fluents from the nuclear fuel cycle.
The first of these tes timonies was of fered during licensing pro-ceedings for TMI urat number tuo on July 6, 1977.
My testimony caused the Nuclear Regulatory Commission to void the stated number of curies of Radon-222 in the Nuclear Regulatory Commission's Table S-3.
De-termination of the amounts of Radon-222 to be released in'to the en-vironment as the result of mining and milling of uranium ore for one year's reactor operation is still to be established for purposes of Table S-3 of ten CFR51.20(e) of URC regulations.
My tests have shown that Sadon-222 is the largest single source of radioactive emission in the entire nuclear fuel cycle.
Through a series of operator errors, including violations of p - 3 p ()
t rr
,906sg0;Aob EXHI B1 i B
256 267
- />-
,j c
the Technical Specifications (Tech. Specs.), instrumental failures, and basic design deficiencies, initiated by a loss of feedwater to both s team generators at 4:00 a.m., March 28, the sequence of events over the sixteen or so following hours at TMI-2 brought the residents of Central Pennsylvania much closer to a potentially uncontrolled, un-controllable, and uncontainable core meltdown than the public had heretofore been led to believe was possible.
Large releases of radioactive acterials to the environment have already occurred.
Ms. Margaret Reilly, of the Commonwealth's Bureau o f Radiological Protection, stated publicly on May 13, 1979, that some
" dozens of curies of Il 1" and " millions of curies of noble gases" had already been released from the badly damaged TMI-2 facility.
Contrary to the assurances of NRC Staff and Applicant in their prepared testimonies during the evidentiary hearings which led to the licensing of TMI-2, when an emergency actually arose, no one was pre-pared to respond promptly and adequately to protect the health and safety of the public.
One serious consequence of this lack of pre-paration has 'ocen the wholly inadequate radiation monitoring in the r
early days of the accident, a deficiency which remains today largely unchanged.
(See Testimony of Robert B. Minogue, Director of the NRC 01 fice of S tandards Development, before the Energy Sub-committee of the Government Af f airs Commit tee o f the U.S.
Senate, May 8, 1979.)
Ir. addi tion, there has been no objective attempt to estimate exposures to the p ablic which occurred during those early days of the accident when environmental monitoring was so unconscionably deficient for so though that minimal monitoring may have long a period of time, even met NRC minimal standards.
It is important to observe that the information which has been 256 268 4
and is being made available to the public concerning radiation exposure '
has been and is inconsistent, misleading, and inaccurate.
For example, according to the "Ad Hoc Population Dose Assessment Group" Report, May 10, 1979, the maximum total dose received by any individual was estim-ated to be 86 millirem (mrem), throughout the course of the accident until April 7, 1979.
However, this figure must be compared with popu-lation exposures discussed in the widely reported March 30, 1979 closed meeting of the Commissioners of the NRC.
On this morning of March 30, the li censee-operator, Me tropolitan Edison, permitted the escape of very large quancity of radioactive gases over a period of one or two hours.
Dose rates on the ground were estimated to be about 120 mrem / hour, for
'4 s, E k ' M'-
s more than an hour.
In addition, in a public mee ting on May 3,19 79, Mr. Thomas M.
Gerusky, Director of the Bureau of Radiological Protection of Pennsyl-vania, reported that at 7:30 a.m., March 28, 1979, the dose rate in the dome of the containment structure was 600 roentgens per hour (R/hr).
At that time, the containment structure was not isolated, and radioactive gases were escaping.
Mr. Gerusky said the resulting projected dose rate in Goldsboro, situated due west of the plant and toward which the wind was then blowing, was 10 R/hr.
According to
" Preliminary Sequence of Events:
TMI-2 accident of March 28, 19 79,"
memo f rom R.L. Long to R.C. Art.-;1d, the containment structure was not isolated until 7:56 a.m.,
March 28, 1979.
It should also be noted that the "Ad Hoc" report contains an average value of 0.19 mR/ day, the background radi-or 0.008 mR/ hour, as ation exposure in this area of Pennsylvania.
This value is based on thermoluminescent dosime ter (TLD) readings in the general vicinity of 256 269
~
,2
TMI-2 for the calendar year 1977 (Ad Hoc report, p. 12) and should be compared with the " background" exposure rates disseminated to the press and public after the March 23 accident.
In PNO-79-5 7AD, dated April 23, 1979, the NRC reported of fsite readings were " consistent with normal background levels (0.02 mR/hr)."
This value of G.02 mR/hr is 2.5 times the 1977 average backgradnd value reported by the "Ad Hoc" ju v & M w h b W l A 'A k group.
the Ad Hoc report uses an atmospheric dispersion &
PT t
cb Furthermore, model which dictates that doses fall off with distance according to a minus 1.5 power law beyond a 10 mile distance from TMI-2.
The exposure data presented in this Ad Hoc report do not support this model.
From
/
the NRC data in Table 3-4, meager and wholly insufficient though they M
[Qq are, it is obvious that in many directions exposures do not decrease ph according to the minus 1.5 power law.
In numerous directions, the data show that exposures not only do not decrease with distance, they increase with distance from 'IMI-2.
(See, for example, Table 3-4, Exposures in the North Sector and Exposures in the South Sector.)
No justification is offered in the Ad Hoc report for the use of this pat-ently defective distance decay model which is not supported by even the shallow data base revealed in this report.
It can only be con-cluded that the obvious purpose of this inappropriate model is to con-ceal the magnitude of population exposures beyond 10 miles from TMI-2.
The "Ad Hoc Group" implied that people remaining indoors would be " shielded" from xenon gases.
However, taking cover would protect persons only from a very short (a few minutes) passage of a radio-active plume containing xenon gases.
Air circulates through buildings and brings the radioactive gases indoors with it.
From accident sequences released by the NRC, it seems clear that large quantities of primary coolant water were vented through the
?,. R A. 7.70 i
~
,4
~
electromatic relie f valve (EMV) after the initial period when the core was uncovered.
In this initial period of up to two hours, when decay heat uas higher than in later periods, fuel cladding and steam reaction are believed to have occurred.
It has been suggested that the reaction consumed approximately 40 percent of the total quantity of fuel cladding in the core (See " Core Damage Assessment for TMI-2,"
NRC Memorand a from R.O. Meyer to Roger J. Mattson, April 13, 19 79, page 8).
T is would tend to suggest that in the upper region of the core, which was uncovered for the longest time, complete oxidation of at least some fuel cladding occurred, exposing the fuel material to the cooling water.
As a result, it i2 evident that fission products which were even slightly soluble in primary coolant water under the prevailing high pressure and high temperature conditions would have been leached out of the exposed fuel, and subsequently released to the containment sump thrcugh the ENV (Electromatic Relief Valve).
Consequently, it is probable that the large quantities of water released into the contain-ment structure -- reportedly over 400,000 gallons -- have high fission product levels measured in tens or hundreds of microcuries per mil-Liliter (mci /ml).
Both the volume and the probable high level of contamination of this water exceed the cleanup capabilities of the reactor, coolant le tdown system for an entire year's operation of that system (See TMI-2 Final Safety Analysis Report, Tables 11.2-5, ll.2-6a, and Figure 11.2-3).
I am particularly disturbed by the numerous announcements and rumors that the dumping of this high-level waste water, purified or not into the Susquehanna River is imminent.
Llhile conceptually it may be possible for the licensee-operator to upgrade this letdown system to treat at least superficially the contaminated water, there has been no 2R6 27I
,i publicly-disclosed discussion or evaluation of that capability or of the probabilities and consequences of any accidenta, spills, or leaks which night take place during the proposed release of this water.
The consequences of dumping any of the waste water in the primary -
coolant system or containment basement could be catastrophic to the health and economic well-being of many communities which obtain drinking water from the Susquehanna River.
Additionally, since the Susquehanna River is the major fresh-water source for Chesapeake Bay, a leak of even a few hundred gallons of the radioactive contain-ment water into the river could prevent the use of the Bay as a fishety Z,r years to come.
?
I J
Sworn to and subscribed before me this 24th day l
[
o f diay, 1979.
Chauncey Kepford dEWU NW Notary.[dlic Bly Commission expires:
texy c. stest sceuy Pese torewer, tacewer ca., Ps My Currtslen Epitse AL-y 119CC 256 272 b
,