ML19241C244

Request by Environ Coalition on Nuclear Power That Director of Nuclear Reactor Regulation,Nmss & IE Permanently Revoke OL W/Prejudice

ML19241C244
Person / Time
Site:	Three Mile Island
Issue date:	06/29/1979
From:	Johnsrud J Environmental Coalition on Nuclear Power
To:
References
FOIA-79-98 NUDOCS 7907300447
Download: ML19241C244 (10)

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ENVIRONT.'. ENTAL COALITION ON NUCLE AR POWER C# D sectm. Mr. ceeg A nra-R D. si, Peach Octrom, Pa. 17563 717 548 4336 g

Dr. Jud.ta ;w v ud-4 33 Gile d s A .me, St ate Cche,*, Pa. 10501 814 237 3DO UNITED STATES OF AMERICA , l fiUCLEAR REGULATORY C0!?ilSSION e7 -

In the Matter of

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METROPOLITAN EDISON COMPA!4Y, et al. ) Docket tio. 50-289 (Tlicee !!ile Island Nuclear Station, Unit 1 )

REEUEST TO THE CIRECTOR OF :;UCLEAR REACTOR REGULATION, DIRECTOR OF NUCLEAR MATERIAL _

SAFETY /N3 SAFEGUA+JS, AND DIRECTOR OF THE OFFICE OF INSPECTIGil A'.D ENFORCEMENT

' i TORTC'INGDITE NUCLEATIGCC.RlTM5fI53 ION

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s f Pursuant to Part 2.206(a) of the Rules of the Nuclear Regulatory Cc.:. mission ("Cc clission" or "NRC"), the Environmental Coaliticn on Nuclear PC..er (EChP) requests that the Director of Nuclear Reactor Regulation (NRR),

the Director of N; clear Material Safety and Safeguards (:J SS), and the Director, Office of Inspection and Enforcement (0IE), si igly or in ccrbination, institute a proceeding pursuant to Part 2.202 of the Cox.ission's Rules to revoke per.nanently the operating license currently in effect for Three Mile Island N; clear Staticn, Unit 1 (TMI-1), Docket No. 50-289, with prejudice against the subsequent reissuance of that license.

This action is requested for a number of reasons which are detailed below, but stems largely frcm the recent accident ac Three Mile Island Nuclear Station, Unit 2 (TMI-2), as ; ell as from varicus events and circumstances which preceded that accident, and from the results and effects of that accidant--results and effects both tangible ar.d less than tangible.

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1. The design of TMI-l has a series of design defects and deficiencies such that safe, reliable operation of the reactor cannot be assured by the cursory examinaticn afforded in the constructico permit and operating license proceedings:

(a) The plant ccmputer for TMI-l is old, obsolete, and inadequate to respcod appropriately in emergency situations.

During the accident at the adjacent TMI-2, the alarm printer on the similar cceputer at T14I-2 had a delay time of over two and one half hours at one point, anj ranThismore thaa delay an hour cannot be behind events for over seven hours.

vimied as having adequctely served the needs of the operators of TMI-2, and there is no reason to believe that a similar accident situation, with as severe or worse consequences, cannot occur at TMI-l and be severely aggravated by sicw and ambiguous computer alarm printer readings.

(b) The icw volume of prinary cooling system water has the effect of reducing the time available to operators and the plant control systems to apply remedial measures in tne 4 event of a loss of coolant acciger.t (LOCA)

The lowsuch wateras the TMI-2 volume design accident is now aduitted to be .

deficiency means that possible epcrator error and mechanical, electrical, or electronic failure must be minimized so as to prevent either a repeat of the T'11-2 accident, or an even worse accident.

(c) The electronic signals sent to the ccntrol room in many cases record the wrong parameters. For instance, in the ;3;e of the Electromatic Relief Valve ("ERV"; the Metropolitan Fiison designation is RC-RV2), the signal sent to the control rot m to indicate a closure of this valve indicates only the electrical' energizing of the solenoid which closgs the valve, not the actual physical valve closing itself. This misleading signal aggravated the accident at TMI-2. There is no reascnable assurance that this same problem, or a ccaparable one, cannot arise many timas over at TMI-1.

(d) The TMI-2 accident sho<ied that many monitoring instruments were of insufficient indicating range to properly warn control-room operators of ambient conditions.0 For example, the " hot-leg" themoccuples went off-scale at 620 F and stayed of f-scale for over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for re3ctor coolant leap A and about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for reactor coolant locp B? A higher temperature limit would have provided important info .ation to the rc-actor operators. This situa tion is unchanged at T'41-1. In addition, it is reported that the radiation monite, s went off-scale during the TMI-2 accident.0 It should be noted here that this eventuality was predicted in 1974 by the T"I-2 Interv_nors, but dutifully denied by the NRC Staff and Applicant d; ring the TMI-2 licensing hearings. Needless to say, the TMI-2 Licensing Ecard accepted the anurances of adequate monitoring offered by the Staff and Applicant. Yet a similar situation s tiil exis ts > t TMI-1.

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(e) The TMI-2 accident included a series of mechanical failures, initiated by a Condensate Pump trip. This single failure caused both nain Feedwater Pumps to trip which led to a "feedwa ter transient." The f ailure of the ERV comp the situation, bringing about a "small-break" LOCA.Jicated

. This kind of an accident at TMI-1, while it has occurred in the real world, is not subject to litigation in a licensing proceeding because it goes beyond the " single-failure criterion" of the Cea. mission's Rules.8 Yet in spite of the Ccmmission's Rules, this nultiple failure accident occurred, and there is no reascn to believe that this accident or any of other corbin3tions of as bad or worse multiple failure accidents cannot occur at TMI-1. Nor is there any assurance that all serious multiple failure--or even all serious single-failure-- accidents h3ve been identified, let along analyzed and protected against at I"I-l .

(f) Many vital instruments, instrument controls, and other components in the containment building of TMI-2 lost their ability to opcrate because they were not considered " safety-related." As exarples, the pressurizer level indicators contained components which were not designcd to withstahd the hiqh radiation levels (reported to be as high as 30,000 R per lour). The failure of '

these was accelerated by the water envircr. ment in the containment building. Similar instruments and control systems apply in Unit-1.

(g) The TMI-2 accident showed the need for water level instruments inside the reactor pressure vessel, (RPV), as well as instruments to detect steam forntion. In addition, this accident demonstrated

- the need for a vent for hydrogen at the top of the RPV. These deficiencies still exis t a t TMI-1.

(h) The exemption for TMI-2 in 1975 frcm new safety requirements which would have required imediate isolation of the containment structure to prevent the leakage of radioactive gases to the atmosphere also applies to TMI-1.

(i) The interface between the operator and reactor, the control room panel, is not adequate to provide the appropriate and necessary information to the operators in the event of an accident.

2. The absence of a workable cvacuation plan for the area around TMI-l and 2 almost 5 years af ter TMI-1 was licensed to operate constitutes a disgraceful confirmation of the intent of the Commission to grant any,and all reactor applications tendered, regardless of the quality of the appli-cations or the consequences to the public of that licensing. This public-be-d2mned attitude ignores the fundamental question as to whether or r.ot it is even possible to carry out evacuations under realistic accident conditions.

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_4 The evacuation plans approved in the licensing at TMI-l and TMI-2 are acceptable based upon the assumption that the levels of radiation exposure to public officials, up to levels that the officials deem necessary to avoid through evacuation, are acceptable to those members of the public at risk.

This assumption is unjustified and is unaccepti.ble on the grounds of public health, even ignoring the psychological da=ge done to those involuntarily subjected to this new form of terrorism, as the TMI-2 accident so vividly demonstrated.

In addition, the assumptions and conclusions concerning emergency pre-9 paredness made by the TMI-2 Licensing Board now are known to be without merit. These erroneous conclusions and assumptions apply equally to TMI-1.

• The TMI-2 accident demonstrated that a radiological accident is not, and can not be treated, like any other kind of disaster which may require evacuation.

Furthermore, since any efforts at future evacuations will require the assistance of local volunteer firemen who will be just as anxious to leave as the general public, there is no assurance whatsoever that enough of these requisite individuals will stay behind, separated from their familie;, to assist in evacuation maneuvers.

3. The unconscionably lax attitude of the management of Metropolitan Edison, which led to the wholesale rush to get TMI-2 into comercial operation, in It is the same management spite of repeated serious mechanical malfunctions.

which pemitted the lax conditions in the TMI-2 control room that allcued TMI-2 to operate with both auxiliary feedwater pumps turned off, a serious violation of the Technical Specifications for TMI-2. It is this same lax management attitude which almost permitted TMI-l to begin operation on March 27,1979, with one of these same auxiliary feedwater pumps turned off.

It is this same management that has operated T'il-1 since 1974 and still has only a relatively weak engineering capability.10 57S282

4. There is yet little indication that the TMI-2 accident is even under-stood by the flRC, Metropolitan Edison, or Babcok and Wilcox. In particular, there does not seem to have been released a discussion of during what time periods after the accident the fuel was damaged. flor has there appeared an assessment of what could have been the range of consequences if (a) the reactor operators had been less skillful than they were in handling the accident (i .e., what if they had been more prone to panic, and had made even i.iore serious errors).

(b) the accident had taken place in a reactor with a full inventory of fission products.

(c) the accident had required an evacuation of the site, due to on-site contamination, at a reactor with spent fuel being stored on-site, either normally or in a compacted configuration.

(d) there had been a core meltdown on, say, March 30, 1979.

.5. According to sworn testimony by Mr. Thtcas M. Gerusky, Director of the Bureau of Radiological Protection of the Comonwealth of Pennsylvania, before the U.S. Cong essional Committee on Licensing and Technology, Subcommittee on f;atural Resources and the Environment on June 2,1979, about fif teen (15) curies of Iodine-131 were released to the environment in the first month after the TMI-2 accident. In the Final Supplement to the Final Environmental Statement for TMI-2, it was estimated that about 0.01 curies of this isotope would be leased during a year of normal operation. The fifteen curies, then, represents a release of 1500 times that for one year of normal operation, and 50 times more than the plant was expected to emit in its entire 30 year operating lifetime. As a result, any additional releases, due to even the noral operation of TMI-1, if normal operation is ever possible, would be far beyond those '..hich the residents of this area were prcaised.

Similar considerations apply to the emissions of the radioactive noble gases released during the TMI-2 accident. In addition, many of the residents of the vicinity, already severely victimized by Metropolitan Edison in the T"I-2 accident, now face the continuing threat of releases of radioactively G?S283

contaminated water- into the Susquehanna River. These residents may now be pla:ed in the position of having to drink, wash in, cook with, and being unable to prevent their children from consuming water containing radioactive contamination from TMI-2. These residents of the Susquehanna Valley (including members of EChP) will thus be ex;csed to radiation for which they receive no con:nensurate benefit, radiation that was not expected to be released.

6. Many residents of central Pernsylvania were thorcughly and coupletely terrorized by the March 28, 1979 accident at TMI-2. This terror has turned the lives of many otherwise happy people into a living nightmare, because ..

they know the accident at EiI-2 is not over, and that unannounced releases of radic 3ctive materials continue. In addition, Metropolitan tun on now proposes to rush TMI-l into operation. This rash and cruel act will have the effect of increasing the level of fear, terror, and bitter resentment among many residents of that beleaguered area. Already, threa ts of violence have been made concerning the proposed operation of TMI-1.Il Metropolitan Edison has created a climate where people know that they no longer are safe in their own homes, they are afraid to grow food in their cwn gardens, and many will soon i. ave reason to distrust the very water they drink. They have learned the utter contempt that Metropolitan Edison holds for their feelings and their health and safety.

One certain result of the reopening of TMI-l will be a substantial increase in the tension in the area surrounding TMI-1. The outwa ra mani-festation of this tension may well appear as increased suicide rates, divcrce ra tes, incidences of child beating, a general louering of the general mental health of the p ;ulace, quite probably, acts of civil disobedience against TMI-l and possible acts of violence, even sabotage against 57S284

TMI-1.I A good example of the psychological impact of the TMI-2 accident upon the residents of central Pennsylvania is afforded by the appended 13 edi to rial .

An additional dimension of the psychic and fiscal damage wreaked by the TMI-2 accident is found in its economic effects on the region. Start-up of TMI-l will only exacerbate the fears and uncertainties of persons who already avoid the purchase of agricultural and mar.ufactural products from this area. Effects on property values and saleability of land and buildings in the area is presently under investigation.

The slipshod and lackadaisical attitude of Metropolitan Edison to',!ard safety and security at TMI has turned the entire facility into a public nuisance and menace whose operation and even existence can no longer be ..

tolerated. This is especially true, since there can be no believable assurances of fered that more or even worse accidents will not happen in the future, if TMI-1 or-2 ever operates again.

Under the Atcmic Energy Act of 1954, (AEA) as amended, the purpose of the atomic energy program is to promote the use of nuclear energy for peaceful paposes to the maximum extent consistent with the commn defense and security and with the health and safety of the public. (AEA, Sec 3(d).)

This concept was recently given unanimous support by the Supreme Court (Vermont Yankee "uclear Power Corporation v. Natural Resources Defense Council, et al .,

April 3,1978, Slip opinion, p. 28)

The Ccmmission's price area of concern in the licensing context. . .[is] . . .public heal th and safety.

The intent of Congress has thus been upheld by the Supreme Court in determining that the highest duty of the NRC is to protect the health and safety of the public frca the possible misuses of atomic energy.

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There is no language in the AEA or any other legislation under which the Comission operates that authorizes the Comission to terrorize, traumatize, and otherwise substantially decrease the level of the mental health, the welfare, and well-being of a large body of individuals.

Nor does the AEA confer upon any licensee under Sec.103 any rights to a license just because a facility is built. In fact, Sec.103 specifically states that the Comission shall issue... licenses. . .to persons who are equipped to observe and who agree to observe such safety standards to protect the health and to minimize the danger to life or property as the Cair. mission may by rule establish (AEA,Sec.103(b)).

Metropolitan Edison has created an atmosphere where the actual operators of TMI-l and 2, as noted above, had little regard for the rules of the Commission ,,

or the tems of the operating license granted under Sec.103 of the AEC.

Under the AEA, the Ccmission has the legal authority to revoke the operating license of TMI-l under Sec. ISS of the 'EA.

The climate of fear, distrust, and, indeed, hatred that Metropolitan Edison has so effectively cultivated over the years, culminating with the TMI-2 accident and its resulting trau'ratic effects, has created a dangerous situation which may spur particularly angry or upset people, singly or in groups, to various kinds of sabotage against Metropolitan Edison. 'lh il e the vast majority of such acts may be of no public health consequence, the Comission must take into consideration the fact that sabotage is probably far more probable at THI-l or-2 than at any other nuclear facility in the world.

Merely upgrading police protection of the TMI facility would duck the answer. The continuing problem is not with the angry and emotionally disturbed people of Central Pennsylvania; they are respnding in perfectly nomal ways to v. hat they perceive as a threat to their lives' and properties, and that threa t is TMI, Uni ts 1 and 2. The public health and safety cannot 57S286

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be protected by permitting the operation of TMI-1. Such an act would be an insult to all who were so deeply hurt by the TMI-2 accident. The only way to restore the mental health and safety of this area is to close TMI forever. The restoration of health and safety of the public, both mental and phsyical, is far more important and valuable than any conceivable quantity of electricity or financial benefits to be derived from any operation of TMI 1 or 2.

Therefore, ECT;P requests that the Directors of I;RR, I;: 55, and 0IE, singly, or in any combination, institute immediately a shc.i-cause proceeding under Part 2.202 of the Commission's rules to revoke permanently the operating license for TMI-1.

Respectfully submitted

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Judith H. Johnsrud for Dated this .-

day Chauncey Kepford of June,1979. Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pa.16801 578287

References

1. Preliminary Annotated Sequence of Events, March 28, 1979, Rev. 0, dated May 10, 1979.

2. Final Safety Analysis Report, TMI-2, Table 1.3-1.

3. See ref.1, page 2.

4. Ref. 1, page 4.

' 5. Ref. 1, Figures 22 and 27. '

6. Stattment of Erich W. Bretthauer, Director, Monitoring Operations Division, Envirer. mental Protection Agency, Las Vegas, Nevada, before the U.S. Congressional House Subcommittee on Science and Technology, Elizabethtown, Pa., June 2,1979.

7. Ref. 1, p.2. ~

8. See Special Prehearing Conference Order, LBP-79-6, March 6,1979, Docket Nos. 50-387, 388, page 70.

9. Initial Decision, TMI-2, December 20, 1977, para . 53-67.

10. Transcript of the Closed Session of the NRC Commissioner's Meeting, Friday, March 30, 1979, page 166.

11. The Paxton Herald, c. June 12-13, 1979.

12. Ibid.

13. Paxton Herald, June,1979.

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