ML19248D274
| ML19248D274 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/26/1979 |
| From: | Kepford C AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML19248D268 | List: |
| References | |
| NUDOCS 7908150485 | |
| Download: ML19248D274 (9) | |
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DiCLOSUkd 2 UNITD STATE OF AERICA h7CIIAR REULATCT.C COMMISSICH a
.h, S b l 6 In the Matter of gg E"RCPCL; TAN DISCN CCMPANT, et. al.
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Docket No. 50-320
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SUT?LD*LTAL FCITION TO T"/E DIEICTCR CF NUCIZAR"?2AC*CR RIIRTIATICI FCR DG2GE'CT ACTICN IN~EOLU( ".01 This is a supplenent to the Inter-teners' Request to the Directer of Nuclear Reactor Regulatien for E.mercennf Action by the Noelear Reculatorr C r issich, herein, "Recuest,"
do',keted at 32.V p.n., April 27, 1979 Despite the crgent need fer rel'.ef requested in that e=ergency petitien, the receipt of that petition Ms yet (May 15,1979) not even been acknowl-edged by the Directer of Nuclear Reactor Regulatien.
This suppler 2nt to the April 27, 1979 Recuest is new schnitted because of the ecctinuing nature of the crisis cauted by the March 2S,197o, catas-trephe at Three Mile Island Ncclear Jenerating S tp%ca, 'Tnit 2. (~MI-2).
Threagh a series of m zrater er crs, including violatiens of the Technical Specifications (Tech. f cecs.), instrunental fail rcs, and basic design deficiencies, initiated by a loss of feedwater to both stean generators at 1::00 a.n., Maren 28, the sequence of events over the sixteen er so followint hours at ~':C-2 brcught the residents of Central Pennsylmh nuch cicser to a pctentially :.ncontrelled, urcentrol'able, and uncontainable ecre nelt-dcwn than the public had he stofore been led to believe was possible.
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occe red. Ms Margaret Reilly, of the Cc=.onwealth's Seean of Radiological Protection, stated publicly on May 13, 1979, that sc=e " dozens of curies of
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131 and "=1111ons of curies of noble gases" had already been released fran I
the badly demaged TMI-2 facility. (See Tech. Specs., Radiological, Limiting Ccnditions for Operation, Sec. 2.3 2.)
Contrary to the soothing asseances of NRC Staff and Applicant in their prepared testimonies during *he evidentiary hearings which led to the licens-ing of '::C-2, when an emergency actually arose, no one was prepared to respond prc=ptly' and adequately to protect the health and safety of the public.
One serious consequence of this lack of preparation has been the wholly inade-quate radiation =enitoring in the early days of the accident, a deficiency which remains tcday largely unchanged.
(See Tes*i-acy of Robert 3. Minogue, Director cf the EC Cffice of Standards Develop =ent, before the Energy Sub-cc=ittee of the Gove:-. ment Affairs Ca.lttee of the U.S. Senate, May 8,1979.)
In addition, there has been no objective attempt to estimate exposres to the public which occurred dcring those early days of the accident when environ-mental monitcring was se encenscicnahly deficient for so long a period of time, even thecgh that =ir -=' =cnitcring =ay have =et NRC minimal str.dards.
i It is importa=t to observe that the i=fer=ation which has been and is being =ade available to the public cence. ing radiatien exposure has been and is incensistent, nisleading, and inacer ate. For exanple, acccrding to the "Ad'ioc Popclation Dose Assessment Grocp" Report, April 15, 1979, the
axinc= total dose received by any individcal was F '.atd to be 86 d e
(= e=), thrcughout the course of the accident until Ap u T, 1979
- Hcwever, this fi;c e must be ec= cared with pepciatica e=cesces discussed in the widely repcried March 30, 1979 closed =eeti.; of the Cer:.issicners of the N20.
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J' On this =orning of March 30, the licensee-operator, Metropolitan Edison, per=itted the escape of very large quantity of radioactive gases over a period of one or two hours.,1)ose rates on the grcund were estimated to be about 120 mre=/hocr, for more than an hour.
In addition, in a public meeting en May 3,1979, Mr. Themas M. Gerusky, Director of the Screza cf Radiological Protectica of Pennsyhnia, reported that at 7:30 a. i., March 28, 1979, the dose rate in the dcme of the centain-ment structure was 600 reentgens per hour (R/hr). At that time, the containment stncture was not isolated, and radioactive gases were escaping.
Mr. Gerusky said the resulting projected dose rate in Goldsbcro, situa+ad due vest of the plant and tcvard which the wind was then bleving, was 10 P./hr.
Acccrding to " Preliminary Sequence of Events: M -2 accident of March 28, 1979," =e=o frc= R.L. Long to R.C. Arnold,'the containment structure was not isolated until 7:56 a.m., March 28, 1979.
It shecid also be noted that the "Ad Hoc" report con'ains an average value of 0.19 nR/ day, or 0.0C8 a/hcar, as the background rad.iation expos =e in this area of Pennsylvania. This valce is based en thermolu inescent desineter (T1D ) readings in the general vicinity of M-2 fer the calendar year 1977 (idHoe report, p 12) and shculd be ec= pared with the " background" e=posure rates disseminated to the press and public after the March 28 accident.
In F30-79-67AD, dated April 23, 1979, the NRC reported offsite readings were
" consistent with ac=al back;;rcund levels (0.02 2/hrl" This value of 0.02 m;tj}ir is 2.$ times the 1977 average backg cund value reported by the aid Hee" grcup.
Furthe=cr e, the Ad Hec report uses an atmospheric dispersien medel vnich dicta.es tnat deses fall off with disunce acccrding to a =inus 1.5 pcwer law heyend a 10 =ile discance fren M -.2.
The excesure data presented s
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in this Ad. Hoc report do net support this model.
Pro = the NP.C data in Table 3-5 through 3-10, = eager and wholly insufficient though they are, it is obvious that in many directions exposures do not decraase according to the =inus 1.5 power law. In numerous directions, the data shcv that exporures not only do not decrease with distance, they increase with distance f c= M-2.
(See, for exa. ple, Table 3-6, T.xposures in the North sector; Table 3-9, F.xposures in the South Secter.) No justification is offered in the Ad9ec report for the use of this patently defective distance decay model which is It can not supported by even the shallow data base revealed in this report.
only be cencluded that the obvious purpose of this inappropriate model is to cenceal the =agnitude of population exposures beyond 10 =iles frc= M -2.
Frc= accident sequences released by the NRC, it seems clear dut largo quantities of pri=a:y coolant water were vented through the elect -atic relief valve (W) af ter the initial period when the core was uncovered.
In this initial period of up to two hours, when decay beat was higher than in later periods, fuel cladding and steam reaction are believed to have occurred.
It has been sur;;ested that tt.e reaction censu=ed approximately hO percent of the total quantity of fuel cladding in the core (See "Cere Dz= age Assessment for CC-2," NEC Mencrandum frc= R.O. Meyer to Roger J.
M.attsen, April 13, 1979, page 3). This wou'.d tend to suggest that in the upper regicn of the core, which was uncovered for the longest time, ce=-
plete oxidation of at least sc=e fuel cladding occurred, exposing the fuel material to the cooling water.
As a result, it is evident that fission products which were even slightly scluble in pri=a:7 coolant water under the prevailing high pressu-e and hign te. peratu e conditions veuld have been leached cut of the expcsed fuel, and subsequently released to the cen*-ant sump th cugh the E.'7.
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Consequently, it is probable that the large quantities of water released into the contain:nent structure-reportedly over LOO,000 gallcas--have high fission prednet levels measured in tens or hundreds of microcuries per (pi/=1).
" m M ter 3oth the vola =4 and the probable high level of conta=ination of this water exceed the cleanup capabilities of the reacter coolant letdown system for an entire year's operation of +2at system (See OC-2 Final Safety Analysis
?.eport, Tables 11.2-5, 11.2-6a, and Figure 11.2-3). The Interrenors are particularly distcrbed by the n"-a cas announcements and rc= ors ' hat *2e dc= ping of this high-level waste water, purified or not, isto the Sasque-hanna Flver is i=.inent. Wile conceptaally it ng be possible for the licensee-cperater to upgrade this letdewn system to treat at least superficially the conta inated water, there has been no puhlicly-disclosed disecssion er evalaation of that capability cr of the prcbabilities and consequences of at:y accidents, spills, or leaks which might take place during the proposed release of this water to the river. Si=ilarly, there has been ro publicly-disclosed justification for the licensee-operatcr's scdden rash to process and dunp this high-level waste water as quickly as possible into the ?dver and into the lesapeake ?,ay.
Furthe::: ore, there has been no cention or evalca-tien of alternative methods of re=oring, storing, or disposing of this conta=inated water.
The consequences of de ping any of the vaste water in the priman coolant system er cen W nt basement co 1d be catastrophic to the health and the ecenc=ic well-beinE of the many ce=.anities which obtain drinking water frc the Scsquenanna F.iver. Additionally, since the Susquehanna Flver is the =ajcr fresn-watar scurce fer Chesapeake 3ay, a leak cf even a few hun-dred gallens cf ne radicactive cen* # _ent water intc the river cculd prevent the use of this 3.g as a fisten fer any yea s to ec=e.
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ISSUIS FCR CONSIDERATICN is a result of the above, the Interveners in the still ongoing operating license proceeding for DC-2, new joined by their parent organi.;a-tion, the Invironnental Coalition on Nuclear Power (IC'NP), urgently request that the Director of Nuclear Reactor Regulation recognise the gravity of the consequences of releases of these radioactive materials frem SII-2.
In this context, the Intervencrs also urgently request that the Direetcr order that a public evidentiary hearing with swcrn testinonies and full opportunity for cross-exanina.ica be held in Harrisburg to openly and candidly ventilate the following issues:
1.
The validity of the population exposure esti=ates =ade to date in whole or in part by the NRC, including an account-ing for the numerous inconsistencies and contradictions such as those discussed abcve.
2.
The entire secpe of the proposed release into the Susquehanna River of the high-level conta:.inated water, purified or not, presently contained, or anticipated to be conta=inated, at SC-2.
3 The possible range of accidents and accidental discharges to the ?.iver and the full range of consequences--ecenc=ic, environ.e.ml, and health--frem such discharges.
h.
The capability and intent of the licensesoperatcr of Si!-2, to prevent r.iner or large-scale " inadvertent" contaminatica cf the ?.iver, in view of the events since March 28, 1979 5
The capability and intent of the licenseeoperatcr of DC-2 to chey the rules of ';he Cc=.issien and all acplicable statues related to any operations at 2C-2, in view of the events since March 23, 1979 61 The capability and intent of the Cc==ission to ensure that:
(a) the rules of the Cc=missica will be fully obeyed, (b) the applicable statuns, including the Atcnic Inergy Act of 19$h, as a:. ended, the Inergy Recrganization Act of 197h, and the National Inv ren= ental ?clicy Act of 1969 will be f2117 obeyed, (c) he Oc nissica er scne other Federal agency will pre-ide for nenitcring cacabilities to deze:--ine adicactive centa:-i-cica levels wherever Susque-na_na River water v_'l be witndrawn fer distributien f c-drinuing water, ir-igt.tien, industr:.21 pre-cessing, er c.her prposes prior to any f ner releases of pr sen~.ly cenza inated va;er 1*. DC-2, n? v pc-ified er net, to the River, mWM R 8 h
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continued (d) the Cc=ission or scue other Federal agency will provide for adequate nenitoring capabilities to detect elevated levels of gaseous and particulate contamination frem ':KI-2, prior to any subsequent releases of airborne radioactive materials.
The results tabulated in the AdHoc report empha+dcally denonst. rate the need for a much more extensive and versatile envircre.onitoring capability to much greater distances frem*22-2.
7.
'Ine need for an hvironmental Statement as required by See 102 (2)(c) of the National hviren= ental Policy Act of 1969 The events which have :.ranspired since March 23, 1979, including, but not linited to, 'he encrnous releases of Iodine-131.and noble gases, the threat of an t.:d.nent core meltdown, the releases of con-tardnated water which have already occurred, the threat cf future releases of centaninated water which ere er =ay act be anticipated, the threat of future releases of radioactive particulates-all go far beyond the events discussed in the Final Supplement to the Final k n rennental Statement cf Dece=ber, 1976. The possible environmental impacts of future planned activities an' unplanned or accidental ones at 32-2 suggest that environmental statement is required for 22-2.
S.
The methc4 mode, conveyance capabilities, routes, and des *dnations of the unusually high-level decineralicec wastes to be generated at L2-2, and the ultimate method of disposal of the vastes, including a discussien of accidents or leaks and the resulting consequences at any stage of this process.
9 The possible negligent role of the Cc=ission in licensing 22-2 te operate, including the approni of the reactor design as being acceptable to protect the health and safety of the public, and the granti.g of an operating license to the license e-operater knowing that the licensewcperatcr.had insufficient technical experience and canabilities to operate ZC-2 safely.
- 10. The question of whether er net the operating license should be te=cerarily or pe: anently withdrawn fren the licensee-cperatcr of 22-2 fer gross viclations of the Cc= ission's rules and of the operating license specifications and operating cenditichs fer IC-2.
See Sec.186 cf the At=-le Inergy Act of 195h, as amended, and the statt2!s and the secticns of *ce Cc. issien's rules cited in the F.ecuest of April 27, 1979 pOf?.y pm,n,,
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REUI.ST FOR R h 1.
The' Interveners hereby incorporate by reference paragrarAs 1 through 7 frca' the April 2% SS79 Reccest contained under the heading, ?.elief Recuested, and, in addition 2.
The Intervencrs request that the Cc==ission prohibit and prevent any further releases of radioactive =aterials to the environment, gaseous, airbome, particulates, or in liqui fc=, until twentf (20) days after fhal action by the Cc= ission en this supple ental petitien, to enable the Intervencrs and other affected me=bers of the public to seek injunc-tive relief in the courts See, for example, 10C.F.R. 20.601.
3 he Inteneners requ=st that the C.
'ssion prohibit and prevent any further releases of radioactive =aterials to the environment, gaseous, airbcrae particulates, er in liquid fc=, until twenty (20) days after final action by the Co--4 ssion on the Request o' April 27, 1979, 'a enable the Intervenors to seek injunctive relief in the Ccurts.
See 10 C.F.R. 20.601.
14 The Intervencrs request that the Cc::.issica prchibit and prevent any further releases of radioactive =aterials, gasecus, airbeme partica-lates, or liquid, until twenty (20) days af ter the ecmpletion of an evidentia:f hearkg in Har-isburg, Pa., open to the public, with svern testi=cnies and full oppertunity for cross.xacination to e=a=ine the issues raised in this supplemental peturcn and Recuest of April 27, 1979.
5.
The Intervenors request the Comissica 1. mediately infc= the Inte-vencrs by First Class Mail of any and all releases of radicactive =aterials, gasecus, particulates, or liquid, fr== LC-2 wtich occur subsequent to the receipt of this supple = ental petition.
6.
ne Inter 7e. ors reque st that the Ccr. ission =2i'..o the Intervencrs in a tinely fasnien ::;ies of al' =ateria'.s which are per.inent to -he issues raised in.his sup lemen-4 pe ition and tne engeing crisis at O~.-2, including, but net ' ted ic :
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(a) the past or present condition of M -2, since March 28, 1979 (b) all envircinental radicactivity ronitoring data per+2'ndaf to the accident at 32-2, data already collected and additional data as it is collected in the future (c) all planned activities, procedures, or processes at M -2 which have the potential for releases of radioactive materials to the environ =ent.
(d) all planned e.odifications of equipment, procasses, or structures at M-2 (e) all planned cleanup operations inside any buildings centaninated during or subsequent to the DC-2 accident (f) all chemical and isotopic analyses of conta.inated areas ed volumes, including primary coolant water, water in the cen** *nt s =p, and air in the centain-
=ent structare, and all subsequent and related analyses.
Respectfully sub=it+ d,
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Chauncey Kepford Representative of the Intervencrs h33 Criando Avenue State College, PA 168C1 g,y /4 M7f 1-c15-237-39co i L M bjllWijj;!,,,
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