ML19248D426
| ML19248D426 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/16/1979 |
| From: | Kepford C Environmental Coalition on Nuclear Power |
| To: | |
| Shared Package | |
| ML19248D423 | List: |
| References | |
| NUDOCS 7908150769 | |
| Download: ML19248D426 (14) | |
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NUCLEAR REULATORY C0KHSSION stScNccunca scc n ne g
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METROPOLITAN EDISON COMPANY, et al_.
Docket No. 50-320
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(Three Mile Island Nuclear Station, Unit 2)
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R32UEST TO TES DIRECTOR OF NUCLEAR REACTOR REGIO.TIO" FOR EMERGENCY ACTION BT THE NUCLEAR REGULATORY CCt2S3IGI This is an energency recuest for innediate action by the Nuclear Regulatory Cemissien (NRC),
brought under Sec.,2.202Aa)(1) and 2.206(a) p o w.. tu of the Co=issien's Rules and under Sec.186 of the Atonic siergy Act (A2) 3 as amended. As a result of tne near catastrophe at the Three tale Island Nuclear uencrr. ting Station, Unit z GIl-2) en March 28, 1979, cItensive
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damage to the reactor core of TIH-2 has been reported (See, for example, terainony of li. Darryll 1::isenhut before the Subec=ittee on Huclear Regulation of the Senate Cc=ittee on Environment and Public "orks, April 10, 1979, and NRC IE Bulletin 79-0$A, coJ 9, April, 1979. See also Washington Post, April 8,1979.) Events which s
have been publicly repcrted sLnce about April h,1979, have suggested a stable situation..-ith fission product decay heat being slowly but adegaately renoved from the damaged core of TM1-2.
Tne purpose of this c=ergency petition is to regaest the Cc=ission to hold public hearings prior to activation of av phns to alter in av way the current (i.e., as of April 23, 1979) experimental and operational status of T12-2 not in accordance with the published fechnical Specifications of M-2 (Appendi.x A 79 0 815 07c1 c._.,
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-g-to Licent e ilo. DFR-73, February 8,1978).
The Intervenors observe that the Rules of the Co rtission contain procedures for the modificatien of a license, mMification of the technical specifications,..nd for experimental prograns at licensed facilities.
See Parts 50.5Me), (f), (h), (n); 50 59 ta), (b), (c); and 50.90, 50.91, and 50.100.
Interest The Interveners in the THI-2 Operating License proceeding, which is not yet conpleted--the Tcrk Co=ittee for a Safe E:Ivironnent and the Citi:: ens for a Safe Envirement (both of which are member groups of the Environmental Coalition on Nuclear rower (3;U?)--have members, as does ECNP, uno live in tne vicinity of TIE-2, within a distance of about 0.75 mile cf the facility.
These Intervenus, now to be joined by their p: rent organisation, 3C'IP, are fully aware of the health dengent of continuing releases of radioactive materials frem this nuclear facility and believe that any procedural or opera-tional changes from the status eno may be exceeding 4 dangerous to their health end safety, including the possibility of death by acute radiation injury, should the proposed croerimental procedures or operations fail or initiate further dana 6e to the reactor.
These Intervenors and Petitioners assert that their interest vill be affected by future experinentations at '~IH-2.
Concerns of the Intervonors 1.
-erious viol [tions of the Technical Specifications (Tech. Specs.)
by the licensee have already occurred which have led to the current degraded conditions of the T:H-2 reactor core, fary change from the current reactor core cooling re thod either to convective coolirg cr to the use of higher pu= ping
@eed, now com titutes a new experimental situation whose safety implications are unexolored md unevaluated, and any such change or changes in procedures and operations are therefore not covered by the Tech. Suecs. of the 0:eratirq License presently in effect.
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Due to the degraded conditio., of the core and uncertainty cf instrunontation accuracies, there is no >;ssurance that convective cooling can or will renove decay heat rapidly enot.gn from those regions where cool'nt water flow ranges from being restricted to 'being blocked.
Une possible consenuence of a failure of convective cooling may be the necessity of restarting the pu=p or pumps, currently in operation, or the restarting of addit *.on:1 pumps, which could lead to unevalinted consequences, such as a disrunt'.on or rearrangement of what remains of damaged fuel pellets. The potential exists for a possible rapid reactivity insertion, folloued by a catastrophic nuclear excursion or runauay; these potential results of altered procedures require full safety evaluation prior to undertaking any change in-the cooling mode.
3.
A further cor. sequence of the failure of convective cooling =ay be core overheating, acconpanied by more fuel rod cladding reaction with water anr. steam.
This reaction produces not only large cuantities of hydrogen gas, i
but also is a potential source of large..r.ounts cf energy.
There is a possibility, if the reaction begins, that this energy can be generated at a rate faster than this heat can be removed by convective cooling. Again, a need to restart pu=oing may lead to unintended, and potentially catastrophic, consecuences, yet unevaluated as required by IRC rules and the Atomic Energy Act.
h.
Due to the unusual ability of the Irg-drogen atcm and =clecule to penetrate and combine with many metals, the possibility edsts that, due to ~
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the large quantitiesof hyd-ogen present in the pressure vessel under relatively high prassures (perhaps up to 2000 p.s.i.1 and ter.ncratures in the neighbor-u8 hood of 500 to 600 degrees F. on or about Earch JEs, 1979, through April 2, 1979, considerable quantities cf hydrogen nay have penetrated, aid subsecuently embrittled, the pressure vessel. As a resul, of this posd.Lle e=brittlement, the reactor pressurevessel may now not have the structural capability of withstan:iing pressurization, should pressuri:stion become necessary due to F y. (
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Similarly, the hic:h hydrogen cressures, conbined with relatively high tenocratures, may have caused hydrogen embrittlenent of unexidised fuel cladding.
6.
As a result of the fuel chdding-steam reaction already co-@leted and associated hi;;h temperatures (1000F. to perhaps 3000 degrees F.) the internal structural cc=ponents of the top areas of the core may be seriously wea'tened due to oxidation or embrittlement. Again, should reflooding of the core prove necessary, if convective cooling faib, unnnticipated new prchlems and unevaluated results may occur, none the least of which msy be the recently announced core lift phenomenon identified in dabcock and Wilcox reactors.
Relief Renuested
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The"Intervenors recuest that a. Safety 2 valuation Report be made avaihble to the Intervenors and to the public prior to a:ry further experimentation at TIE-2 uhich may aff 2ct the health and safety of the public.
The Intervenors recuest that a public hearing be held prior to 4:.
any further experimentation at ZII-2.
3 The Intervenors recuest that they and their scecial consultant be informed prior to any further execrinentation or change of licensed procedures or other alteratien of the facility whien may affect the health and safet" of the public, b.
The Intervencrs also recuest that, prior to any further exnerimen-tation at U2-2, the public be evacuated from any areas that would be affected, shouli the emeriment fail and control of the reactor be lost.
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5 The intervenors request that an array of live, real-time radiation
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detectors be deoloyed in the vicinity of 21I-2 and out to a radius of h0 miles to measure radiation levels in areas where exposures currently take place but are not measured by the Co: mission.
6.
The Intervenors request that the ICIC order and rigidly enforce an innediate halt to the continuing unannounced releases of radioactive materials from ZIl-2, rnd that public announce=ent be recuired prior to any further planned releases of radioactive materials frea ZE-2.
7.
Lastly, in order to swe time and to excedite natters, Intervenors request that all cc: =nications be directed to the authorized representative of the Intervenors, Dr. Chauncey Kepford, h33 Orlando Avenue, State College, Pa.16301, y (81h) 237-3900, and, simultaneously, w the special consultant of the Interrenors, Dr. Richard %bb, 2858 '77 th St., Toledo, Ohio hj611 (h19) 729-232h /fND TD y
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%3.gfog Respectfully sub..itted,
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O Chauncc-/ R. Kepford h33 Orlando State Colle;;e, A.16801 (81h) 237-3900 PkMT"P: ; . i u Ll' 9'I su
.u.uu Dated this 2 day of April, 1979.
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UNITFD STATES OF AMERICA NUCIZAR REULATORI COMMISSIOT In the Matter of g g, z,* b l6 ME*a0POLITAN EDISON COMPANI, et. al.
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Docket No. 50-320
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i a'uL QGrr & 6 SUPPLDZJTAL PETITION TO THE DIS.ECTOR OF NUCIZAR..EACTOR REGULATICN FOR DERGD:CI ACTION DECDUCTION Ihis is a supplement to the Intervenors' Request to the Director of Nuclear Reacter Reculation for Emercency Action by the Nuelear Regulatog Cc.:issich, herein, "Recuest,"
docketed at 3:30 p.n., April 27, 1979 Despite the urgent need for relief requested in that e=ergency petition, the receipt of that petition has yet (May 15,1979) not even been acknowl-edged by the Directer of Nuclear Reactor Regulation.
This supplement to the April 27, 1979 Request is now submitted because of the continuing nature cf the crisis caused by the March 23, 1979, cates-trcphe at Three Mile Island Nuclear Generating S tation, Unit 2. (TMI-2).
Through a series of operator errors, including violations of the TechrJ. cal Specifications (Tech. Specs.), instrumental famres, and basic design deficiencies, initiated by a loss of feedwater to both steam generators at h:00 a.m., March 28, the sequence of events over the sixteen or so following hours at I:C-2 brought the residents of Central Penns'f vania much closer i
to a potentially uncontrolled, uncont cl'_able, and encontainable core =elt-devn than the public had heretcfore been led to believe was possible.
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' 1 Large releases of radioactive materials to the environment have already occurred. Ms Margaret Reilly, of the Co==onwealth's Bureau of Radiological Protection, stated publicly on May 13, 1979, that some " dozens of curies of 131 and " millions of curies of noble gasesa had already been released from 1
the badly damaged THI-2 facility.
(See Tech. Specs., Radiological, Limiting Conditions for Operation, Sec. 2.3 2.)
Contrary to the soothing assurances of NRC Staff and Applicant in their prepared testimonies during the evidentiary hearings which led to the licens-ing of "MI-2, when an emergency actually arose, no one was prepared to respond promptly* ad 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 nonitoring in the early days of the accident, a deficiency which remains today largely unchanged.
(See Testimony of Robert B. Minogue, Director of the NRC Office of Standards Development, before the Energy Sub-ccm.ittee of the Govemment Affairs Committee of the U.S. Senate, May 8,1979.)
In addition, there has been no objective attempt to estimate exposures to the public which occurred during those early days of the accident when environ-
= ental mor.itoring was so unconscicnably deficient for so long a period of time, even though that =ini=al monitoring may have met NRC minimal standards.
It is important to observe that the infor=ation which has been and is being =ade available to the public concerning radiation exposure has been and is inconsistent, misleading, and inaccurate. For example, according to the "AdHoc Population Dese Assessment Group" Report, April 15, 1979, the maximum total dose received by any individual was estimated to be 86 mim v.m (ren), throughout the course of the accident until April 7,1979. However, this figure must be ec= pared with population erposu es discussed in the widely reported March 30, 1979 closed =eeting of the Cc=.issioners of the :G.C.
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3 On this morning of March 30, the licensee-operator, Metropolitan Edison >
permit.ted the escape of very large quantity of racicactiva gases over a period of one or two hours.. I)ose rates on the ground were estimated to be about 120 mrem / hour, for more than an hour.
In addition, in a public meeting on May 3,1979, Mr. Thomas M. Gerusky, Director of the Bureau of Radiological Protection of Pennsylania, reported that at 7:30 a.m., March 28, 1979, the dose rate in the dome of the contain-ment structure was 600 roentgens per hour (R/hr). At that time, the centainment structure was not isolated, and radioactive gases were escaping.
Mr. Gerusky sa.id the resulting projected dose rate in Goldsboro, situated due west of the plant and tcward which the wind was then blowing, was 10 ?/nr.
According to Preliminary Sequence of Events: TMI-2 accident of March 28, 1979," memo from R.L. Long to R.C. Arnold,' 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 av.-rage value of 0.19 nR/ day, or 0.008 d/ hour, as the background radiation exposure in this area of Pennsylvania. This value is based on thermoluminescent dosimeter (T1D ) readings in the general vicinity of 'D41-2 for the calendar year 1977 (/dHoc report, p 12) and should be compared with the " background" exposure rates disseminated to the press and public after the March 23 accident.
In 5 0-79 67AD, dated April 23, 1979, the NRC reported offsite readings were h
" consistent with nomal background levels (0.02 8/hrM' This value of 0.02 mR/ r is 2.5 times the 1977 average background value reported by the "Ad Hoc" group.
Furthe:.cre, *he Ad Hoc report uses an atmospharie dispersion mcdel which dictates that doses fall off with distance according to a minus 1.5 power law beyond a 10 =ile distance from ?.L2.
The exposure data presented
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-h-in this Ad Hoc report do not support this model.
From the NRC data in Table 3-5 through 3-10, meager and wholly insufficient though they are, it is obvious that in many directions exposures do not decrease according to the minus 1.5 power law. In numerous directions, the data show that exposures not only do not decrease with distance, tht,y increase with distance from TMI-2.
(See, for eranple, Table 3-6, Exposures in the North sector; Table 3-9, Exposures in the South Sector.) No justification is offered in the AdMoc 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 concluded that the obvious purpose of this inappropriate model is to conceal the magnitude of population exposures beyond 10 miles from TMI-2.
From accident sequences released by the NRC, it seems clear that large quantities of primarr coolant water were vented through the electromatic relief valve (IMV) after the initial period when the core was uncovered.
In this initial period of up to two hours, when decay heat was higher than in later periods, fuel cladding and steam reaction are believed to have occurred.
It has been suggested that the reaction consumed appmximately h0 percent of the total quantity of fuel cladding in the core (See " Core Damage Assessment for TMI-2," NRC Memorandum from R.O. Meyer to Roger J.
Mattson, April 13, 1979, page 8). This wou'_d tend to suggest that in the upper region of the core, which was uncovered for the longest time, com-plete oxidation of at least some fuel cladding occurred, exposing the fuel material to the cooling water.
As a resalt, it is evident that fission products which were even slightly soluble in primary coolant water under the prevailing high pressure and high temperata e conditions would have been leached out of the exposed fuel, and subsequently released to the centainment sump through the I2N.
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-5 Consequenthr, it is probable that the large quantities of water reles ed into the containment structure-reportedly over h00,000 gallons--have high fission product levels measured in tens or hundreds of microcuries per milliliter (fi/ml).
Both the volume and the probable high level of contamination of this water exceed the cleanup capabilities of tne reactor coolant letdown system for an entire year's operation of that system (See UII-2 Final Safety Analysis Report, Tables 11.2-5, 11.2-6a, and Figure 11.2-3). The Intervenors are particularly disturbed by the numerous announcements and rumors that tiie' dumping of this high-level waste water, purified or not, into the Susque-hanna River is ire.inent. While conceptually it may be pousible for the licensee-operator to upgrade this letdown system to treat at least superficially the contaminated water, there has been no publicly-disclosed discussion or evaluation of that capability or of the probabilities and consequences of any accidents, spills, or leaks which might take place during the proposed release of this water to the river. Similarly, there has been no publicly-disclosed justification for the licensee-operator's sudden rush to process and dump this high-level waste water as quickly as possible into the River and into the Chesapeake Bay.
Furthermore, there has been no mention or evalua-tion of alternative methods of removing, storing, or disposing of this contaminated water.
The consequences of dumping any of the waste water in the primary coolant system or containment basement co 1d be catastrophic to the health and the econcmic well-being of the many cc=munities which ob+d drinking water frc= the Sucquehanna River. Additicnally, since the Susquehanna River is the major fresh-water scu ce fer Chesapeake Bay, a leak of even a few hun-dred gallens of the radioactive containment water into the river could prevent the use of this Bay as a fishery for many years to come.
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ISSUIS FOR CC'!SIDERATICN As a result of the above, the Intervenors in.the still ongoing operating license proceeding for THI-2, now joined by their parent organiza-tion, the Environnental Coalition on Nuclear Power (ECNP), urgently request that the Director of Nuclear Reactor Regulation recognise the gravity of the consequences of releases of these radioactive materials frem D1I-2.
In this context, the Intervenors also urgently request that the Director order that a public evidentiary hearing with sworn testimonies and full opportunity for cross-exarination be held in Harrisburg to openly and candidly ventilate the following issues:
1.
The validity of the population exposure estimates made to date in whole or in part by the NRC, i.ncluding an account-ing for the numeroas inconsistencies and contradictions such af those discussed above.
2.
The entire scope of the proposed release into the Susquehanna P.iver of the high-level conta.inated water, purified or not, presently contained, or anticipated to be contaminated, at DE-2.
3 The possible range of accidents and accidental discharges to the River and the full rance of consequences--economic, envirorr. ental, and health--from such discharges.
h.
The capability and intent of the licensesoperator of 22-2, to prevent ninor or large-scale " inadvertent" contamination of the River, in view of the events since March 28, 1979 5
The capability and intent of the licensexperator of LE-2 to obey the rules of the Com.ission and all applicable statuas related to any operations at HE-2, in view of the events since March 28, 1979 6 '. The capability and intent of the Comission to ensure that:
(a) the rules of the Cc=ission will be fully obeyed, (b) the applicable statues, including the Atomic Energy Act of 195h, as anended, the Energy Reorganization Act of 197h, and the National Envi: onnental Policy Act cf 1969 will be fully obeyed, (c) the Ccr:~issica or sene other Federal agency will provide fer nonitcring capabilities to dete d.ne radicactive contani-a ica levels wherever Susque-hanna ?.iver water will be withdrawn for distribution fcr drinking water, irrigr.tien, indust-ial pro-cessing, er o her prposes prior to any frther eleases of pr sently contaninated water at X -2, prified er not, to the River,
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continued (d) the Comission or some other Federal agency will provide for adequate moalt;., ring capabilities to detect elevated levels of gaseous and particulate conta-4. nation from TKI-2, prior to any subsequent releases of airborne radioactive materials.
The results tabulated in the AdHoc report emphatically demonstrate the need for a much more extensive and versatile environmonitoring capability to mur.h greater distances from DE-2.
7.
The need for an Environmental Statement as required by See 102 (2)(c) of the National Environments' Policy Act of 1969 The events which have ranspired sine, March 20, 1979, including, but not linited to, the enormous releases of Iodine-131.and noble gases, the threat of an irinent core meltdown, the releases of con-taninated water which have already occurred,' the threat of future rclease of ccataninated water which are or may not be anticipated, the threat of future releases of radioactive particulates-all go far beyond the events discussed in the Final Supplement to the Final Invironnental Statement of December, 1976. The possible environmental inpacts of future planned activities and unplanned or accidental ones at L2-2 suggest that environmental statement is required for EII-2.
8.
The method, code, conveyance capabilities, routes, and destinations of the unusually high-lavel decinerali::ec wastes to be genera +ad at L2-2, and the ultis. ate method of disposal of the vastes, including a discussion of accidents or leaks and the resulting consequences at any stage of this process.
9 The possible negligent role of the cc= mission in licensing EC-2 to operate, including the approval of the reactor design as being acceptable to protect the health and safety of the public, and the granting of an operating license to the licensee-
>peratcr kncwing that the license-operator had insufficient achnical experience and capabilities to operate DE-2 safely.
- 10. The question of whether or not the operating license should be te:.corarily or pe:=anently withdrawn fron the licensee-operator of M -2 for gros's violations of the Commission's rules and of the operating license specifications and operating conditichs for L 2-2.
See Sec. 186 of the At=mic Inergy Act cf 19$h, as amended, and the states and the sections of the Co.:=ission's rules cited in the Recuest of April 27, 1979 i; ]
-8 P& UEST FOR RELIFJ 1.
The Intervenors hereby incorporate by referenes paragraphs 1 through 7 from the April 27, 1979 Recuest, contained under the head'ng, P.elief Recuested, and, in addition 2.
The Intervenors request that the Cc=ission prohibit and prevent any further releases of radioactive materia ~.'.s to the envircament, gasecus, airborne, particulates, or in liquid fo:E=, until twenty (20) days af ter final action by the Comission on this supplemental petition, to enable the Intervenors and other affected members of the public to seek injunc-tive relief in the courts. See, for example, 10C.F.R. 20.601.
3.
The Intervenors request that the Cc=ission prohibit and prevent any further releases of radioactive materials to the environment, gaseous, airborne particuates, or in liquid fom, until twenty (20) days after final action by the Cen.:tssion on the Request of April 27, 1979, to enable the Intervenors to seek injunctive relief in the Courts.
See 10 C.F.R. 20.601.
h.
The Intervenors request that the Cc =issich prchibit and prevent any further releases of radioactive materials, gaseous, airborne partica-later, or liquid, until twenty (20) days af ter the completion of an evidentiary hearing in Harrisburg, Pa., open to the public, with evern testimonies and full opportunity for cross-exanination
+w examine the issr.as raised in this supplenental petition and Recuest of April 27, 1979 5.
The Intervenors request the Comission imediately inform the Intervenors by First Class Mail of any and all releases of radioactive materials, gaseous, particulates, or liquid, fren TMI-2 which occur subsequent 'A the receipt of this supple =en*al petition.
6.
The Intervenors request that the Cc=ission mail to the Intervenors in a ti.ely fasnien copies of all caterials which are pertinent 'A the issues raised in this su:plenental petition and the engoing eisis at T.C-2, including, but not limited '4:
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(a) the past or present condition of 32-2, since March 28, 1979 (b) all environnental radioactivity monitoring data per+mi 4ng to the accident at DE-2, data already collected and additional data as it is collected in tha future (c) all planned activities, procedures, or processes at TMI-2 which have the potential for releases of radioactive materials to the environment.
(d) all planned modifications of equipment, processes, or structures at TMI-2 (e) all planned cleanup operations inside any build 4Ws contarinated during or subsequent to the EE-2 accident (f) all chemical and isotopic analyses of contaninated areas and volumes, including prina7 coolant water, water in the containment sump, and air in the contain-ment structure, and all subsequent and related analyses.
Respectfully submit d,
Chauncey Kepford Representative of the Interveners h33 Orlando Avenue State College, PA 16801 J fg fhfhf 1-51h-237-3900 N
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