ML19260A215
| ML19260A215 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/22/1979 |
| From: | Kepford C Environmental Coalition on Nuclear Power |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7911080185 | |
| Download: ML19260A215 (9) | |
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.:: OcT2 NRC PUBLIC DOCUEif ROOM ye I828$ 3*
" ENVIRONMENTAL COALITION ON NUCLEAR POWER %
.O Co Directors: Mr. George Boomsma-R.D. e1. Peach Bottom, Ps. 17563 717 548 28 Dr. Judith Johnsrud-433 orianco Avenue, State coHege. Pa. 16801 814 237 3900 UNITG STATES OF AT*E?.ICA NUCLEAR '.(EGULATORY CCIT.dISEION In the ?,iatter of METROPOLITAN EDISCN COMPANY, et al_. Docket No. 50-289 (Three !!ile Island Nuclear Station, ) (License Suspension)
Unit 1) )
SUPPLEMENT TO ECNP PETITION TO INTERVENE:
FINAL CLIITENTICNS The Envir0nnental Coalition on Nuclear Power (ECU?), in accordance with the Commissioners' Order and Notice of Hearing (Federal Register, Aurat 15,1979) and 10 CFR 2, herein amends its Petition to Intervene in evidentiary hearings on the reopening or revocation of operating license of Three .'Iile Island, Unit 1 (TMI-1) and sets forth the following contentions 1.
Contention 1. ECNP contends that:
(a) The plant computer for T"I-l is old, obNlete, and inadeouate to respond appropriatelf in emergency situations. During the accident at the adjacent TMI-2, the alarm printer on the siH lar computer at Unit 2 had a delay time of over t,to and one-half hours at one point, " )ranThis for over seven hours moredelay than cannot an hou-bebehind viewed as events having adequately served the needs of the operators of CI-2, and there is no reason to believe that a similar acciient situatior , with as severe or worse consequences, cannot occur at TMI-l and be severely aggravated by slow and ambigucus computer alarm printer readings.
(b) The low volume of primary cooling system " rater (2) has the effect of reducing time available to operators and the plant control systems to apply remedial measures in the event of a loss of coolant accideg(LCCA) such as the T"I-2 accident is now admitted to be . The low water volume design deficiency means that possible operator error and =e c hanical, electrical, or electronic failure must be mininised so as to prevent either a repeat of the CI-2 accident or an even worse accident.
1 3ecause numercus studies and reviews of the Three Mile Island, Unit 2 accident have not been ecapleted at this time (including the report of the Presidential Commissi:n), ECN? reserves its rigat to expand or add to these cententions as new information becomes available (10 CF3 2.71.1 (a)(3) and (b)j.
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(c) The electronic signala sent to the control room in many cases ,
record the wrong parameters, and may, thereby, mislead the the reactor operator. For instance, in the case of the Electromatic Relief Valve ("ERV; the Metropolitan Edicen designation ic RC-RV2), the signal sent to the control room to indicate a closure of this valve indicates only the electrical energicing of the solenoid which cloces the valve, not the actual physical valve closing itself54). Thic micleading signal aggravated the accident at THI-2. There is no reasonable assurance that this same problem, or comparable one; cannot arise many times over at T"I-1. It is the obligation of the Suspended Licensee to provide sufficient Laformation on the performance capability of all pertinent componentr of the control system to reasonably ensure that electronic signals will record, accurately and in a timely manner, all necessary and correct parameters.
.(d) The TMI-2 .ccident showed that many monitoring instcuments were of insufficient indicating range to properly warn control room operators of ambient conditions. For example, the " hot-leg" ther=occuples went off-scale at 6200F and stayed off-scale for over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for reactor co about13hoursforreactorcoolantloopB{ggntloopAand . A higher temperature limit would have provided important infor=ation to the reactor operators. Thic cituation is unchanged at TMI-1.
All monitoring instruments for TMI-l must be calibrated to provide full and accurate readings of the complete range of possible conditions under both normal and worst-cace conditions.
In addition, it is reported that the "
went off-scale during the TMI-2 accident (6)adiation
. monitors It should be noted here that this eventuality was predicted in 1974 by the TMI-2 Intervenors, but dutifully denied by the NHC Staff and the Applicant during the T"I-2 licensing hearings. Needless to say, the THI-2 Licensing Board accepted the assurances of adequate monitoring offered by the Staff and Applicant. Yet a similar situation still exista at TMI-1. All radiation monitoring ecuipment =uct be capable of recording the maxi =um possible relences of radiition in the event of a worst-poccible accident (Class 9) in excess of Design Basis Accidents (e) The necident analyses performed by both the Staff and Applicant were inadequate. Over the previous few years, and even in the brief pre-operational and operational life of TMI-2, a series of feed-water transients had been observ>d in B & W reactors.
A seemingly unrelated problem with the " porter operated relief valve" (20HV), whose firct malfunction was on or about Maren 29, 1978, combined with a feed-water transient to bring abcut the Maren 28, 1979, accident at TJI-2. This sequence of cultiple failures at "MI-? could have been prevented if either the Applicant or the inspection arm of the NdC had leen diligent concerning safety matters. This kind of =ultiple failure, combined with reactor operator errore, underscores the inadequacy of the accident analysis at IMI-2 and at THI-1. There ic no assurance that other "cmall break" " loss of coolant accidents" cannot occur o TMI-1 with similar of greater consequences.
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. The Saspended Licensee should remain in suspension until a thorough and objective analysis of the accident hasard, with the compounding problem of possible operator error, and offsite conn 5quences have been co=pleted, and it is objectively shown that IMI-l is safe to operate. The " reasonable assurance" of safety casumed at TMI-2 was shown to be nonexistent through real experience.
(f) Many vital instruments, instrument controls, and other components in the containment building of TMI-2 lost their ability to operate becauce they were not considered " safety-related". As examples, the pressuriser level indicators contained components which were not desi,gned to withstand the high radiation levels (reported to be as high as 30,c00 a per hour), The failure of these was accelerated by the water environ =ent in the containment brilding. Si=ilar instruments and control sys tems apply in Unit-1. Tat these inatru=ents were not required to be safety grade p ints cut clearly the inadequacy of the safety analyses of the Staff and Applicant.
(g) The TUI ,2 accident showed the need for water level instruments inside the reactor pressure vessel (RFV), as well as instruments to detect steam for:ation. In addition,.this r.ccident demon-strated the need for a vent for hydrogen at the .op of the TFV.
These deficiencies still exist at TMI-l and must be c]rrected to provide substantially more than reasonable assurance that there will be adequate information concerning thermodynamic and all other conditions inside the reactor in the event of worst-case accidents.
(h) The exemption for TMI-2 in 1975 from new safety requirements which would have required i==ediate isolation of the centainment structure to prevent the leakage of radicactive gasds to the atmosphere.also applies to Unit 1. Inmediate isolation of containment =uat be assured at T?lI-l by requisite additions or modifications of equipment or co>tirol technology.
(i) The interface between the operator and the reactor, the control room panel, is not adequate to provide the appropriate and necessary information to the operators in the event of an accident. Control room and control panel design of T"I-l must be altered to assure that all appropriate and necessary infor ation is available to, received by, and comprenensible to cperators and that control room facilities maximise ability of operators to respond to accident conditions quickly and accurately.
Contention 2. ECMP contends that emergency response preparation anc evacuEtion planning for tne publig wao are and will be affected by operation of TMI-l and activities at TMI-2, are still, al=os t five years af ter the licensing of TMI-1, inadequate, untested, and wholly unworkable. The fundamental question is whether or not it is even possible to carry out evacuations under realistic accident conditions. Studies and proposals for evacuation of the public frca the entire area in which radiati:n exposures might be d trimental to the public's health and safety (including genetic w _l-being) are one thing; being able to carry out zuch paper plar successfully and quickly enough to pro tect the public is quite anothe .
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(Contention 2 continued) -
Emergency response and evacuation plans for TMI-l must be finalised and demonstrated to be workable for the outermost distance in which the public could experience radiation exposure in excess of 40 CFR 190 standards which will be in effect prior to the earliest possible date for reopening of TMI-1.
The evacuation plans approved in the licensing at TMI-l and THI-2 are based upon the assumption that the levels of radiation exposure acceptable 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 unaustified and is unacceptable on the grounds of public health, even ignoring the psychological damage 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 emer-gency Board (3")eparedness
' now are kncwnand toevacuation be witnoutplans madeThese merit. by the TMI-2 Licensing erroneous conclusions and asuumptions apply equally well to TMI-1. The TMI-2 accident demonstrated that e. radiological accident is not, and cannot be treated, like any other kind of disaster which may require evacuation.
Furthermore, since any efforts at future evacuations will require the assistance of emergency personnel who will be just as anxious to leave as the general public, there is no assurance whatsoever that encugh of these requisite individuals will s tay behind, separated from their families, to assist in evacuation manuvers. Nor has there been sufficiently demonstrated preparation of receiving centers and refugee care facilities or of the availa-bility at all times and for all needs of fuel suppliec to provide adequate transportation to accomplish evacuation. Neither has it been shown by the Suspended Licensee or NHC Staff that taking cover, remaining indoors, using blocking agents to minimise the thyroid dptake of radioactive iodine on a one time or continuing basis, or any other proposed seasures short of full evacuation beyond the cone of radioactive contamination in the eventuality of an enternally or internally propagated event causing breach of containment ~ rill adequately protect the public health and safety as is recuired undar the A tomic nergy Act of 1954, as anended. Therefore, the license to operate TMI-1 should remain suspended and in the absence of demonstrated proof of evacuation capability should be revoked per:cnently.
Contention 3.
ECN? centends that the Suspended Licensee'is inca:able
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of safely operating a nuclear power reactor, as has been conclu-sively de=cns trated by the TEI-2 Class 9 accident that began March 28, 1979, and is still in progress. The inabizity of this Suspended Licensee to provide the management necessary to operate a reactor is evidenced by the unconscionably lax attitude of the management of Uetropolitan Zdison, which led to the wholesale rust to c?: CMI-2 into cot:sreial operation, in spite of repeated serious secranical
=alfuncti:ns. It is the same management which permitted the lax conditions in the TMI-2 con rol roca that alioned TMI-2 to orerate with both auxiliary feedwater pumps turned off, a seric'es violation of the Technical Specifications for TMI-2. It is this same la manacement attitude which alacs: pernitted IMI-l to begin operation en March 27,1,279, with one of these ca=e auxiliary feedwater cuer37 1296 0
(Contention 3 continued) turned off.
This same management, which has since 1974 operated TEI-l with numerous safety and safeguards violations, has failed to develop an adequately strong engineering capability or plant safeguards capability to assure safe operation of TMI-1. Therefore, restoration of the operating license for TMI-1 should be denied.
Contention 4. ECN? contends that reopening of .UI-1 =ust be prohibited until Ine Ouspended Licensee and N2C Staff have fully evaluated the range of possible consequences of an accident such as the EMI-2 accident 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 more serioue errors);
(b) the accident had tuken place in a reactor with a full inventory cf fission products ;
(c) the accident had required an avacuation art the ' site, due to on-site contamination, at a reactor with spent fuel being stored on-site, either nor=clly or in a compacted configuration; (d) there had been a core meltdcen on, say, March 30, 1979; and until the Suspended Licensee haa provided reasonable assurance that the short-ters and long-tern alterations of equipment and practices required by the Commission can and will prevent the recurrence of the same or co=rarable or more serious secuences of events at T2I-1. NUREG-0600,'which catalogues the non-compliances of this Suspended licensee, forms a basis for evaluating the Licen-see's and the Staff's ability to analyse and hence to prevent euch accidents, or worse, from taking place in the future at TMI-1.
The burdens of proof that all such secuences of events and their consequences have been analysed lie with thy proponents of reopening TUI-1 and the burdens of full review fall upon the NRC Staff, not upon the ?etitioners/Intervencre (10 CF.( 2.732.).
Contention 5. ECN? centends that the cumulative inua;t of radi2 tion expecure already received from the TEI site during the pre-March 28, 1979, operations of Units 1 and 2, plus the orposures of undetermined and no." undeterminable, magnitude received during the weeks and conths of the T~ui-2 accicents o), plus future doces, fro: either nornal or unanticipated emissiens from a reopened T"I-l or additional planned or unplanned releases of radioactive gases, water, or eclid matarials frem TMI-2, will constitute an undue risk to the health and safety of our members and the entire population of the Susquehanna Valley and Southeastern Pennsylvania.
According to sworn testimony by Mr. Thomas %. Gerusky, Director of the Bureau of ladiation protection of the Occ=onwealth of Penn-sylvania, before the U. S. Congreccional Con =ittee on Science and Techn: logy, Subcocsittee on Natural desources and the Environnent on June 2, 1979, about fifteen (15) curies of Iodine-121 were released to :ne environ =e-+ da -"e firs =cntn af ter the T".I-2 accident. In the Final Supplement Oc the Final Environ = ental S t ate ent fer THI-2, it was ectiraten that abcut 0.01 curiec of this isotope would be released during a year of normal operation.
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(Contention 5 continued)
The fif teen curies,then, represents a release of 1500 times that expected 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 normal operation of TMI-1, if normal operation is ever possible, would be far beyond those which the residents of this area were promised.
Similar considerations apply to the emissions of the radioactive noble gases released during the TMI-2 accident and those expected to be released in the conting months. In addition, many of the residents of the vicinity, already victimized by Metropolitan Edison in the TMI-2 accident, now face the continuing threat of releases of radioactively contaminated water into the Susquehanna River. These residents may now be placed 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 ECNP) will thus be exposed to radiation for which they receive no commensurate benefit, radiation that was not expected to be released.
Contention 6_. Many residents of central Pennsylvania were thoroughly and completely 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 TMI-2 is not over, and that unannounced releases of radioactive materials continue. In addition, Metropolitan Edison 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. Al read made concerning the proposed operation of TMI-1 ghreats of violence have been Metropolitan Edison has created a climate where people know that they are no longer safe in their own homes, they are afraid to grow food in their own gardens, and many will scos bave reason to distrust the very water they drink. They have learnec 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 outward manifestation of this tension may well appear as increased suicide rates, divorce rates, incidences of child beating, a general lowering of the general mental health of the populace, quite probably, violence, acts of against even sabotage civil disobedgce TMI-l 1Aagainst Tiil-l and good example of possible acts of the psychological impact of the TMI-2 accides by the appended editorial.\gpon the residents of central Pennsylvania is afforde ECNP contends that, for the residents within a 90-mile radius of liiI, psychological stress and damage to mental health, which is a vital part of the whole health of a human being, will inevitably be increased by the reopening of TMI-l or by any future operation of a nuclear power reactor at Three Mile Island, and that such mental stress and damage to health constitutes an unacceptable threat to the health, safety, and lives of those so affected.
Contentien 7. ECNP contands that the license to operate TMI-l must remain in suspensioE because the safety evaluations for pressurized water reactors under which the TMI-l reactor was originally licensed to operate have been shown by tne TMI-2 accicent ccmmencing March 28, 1979, to have been inadequate to assess tne potential range of events and consecuences of those events and hence are invalid.
As required by 10 CFR 50.46, each PWR shall be equipped with an Emergency Core Ccoling System (ECCS) which shall be designec so tnat its performance shall be to respond to postulated accidents in sucn a way as to limit the
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. (Contention 7 centinued) fac1 te=nerature as cpecified in lo Ca 50.h6. Thi crecificatien uculd not pc=it the fuel to = cit. The e postulated accidents include the double-ended rupt= e of the larce:t pipe in the reacter coolant cycten. All ?;a power planto are licensed cubject to this recalation. The preced=ec uced to decenetrate this perfc-- nce are not valid.
The Three File I:l=d Unit II plcnt is licenced to operate subject to this requirement. On 23 7erch 1979 an accident cccured at thic plent. The accident was initiated by en event less severe than the double-ended =pture of the 1::cest nipe in the reactor coclant c.: sten. The consequence of thic accident was that at least some of the fuel melted. mhis consequence was cleerly in excer of the perfomance reqaired under 10 CE $0.h6. Thuc, the analysea used to predict mch perforence ere invalid. Thus, it has neu been establiched in fact by the evidence of 28 H::ch 1979 at Three Mile Island Unit II, that the basis for grcnting these licenses was invalid, end they cheuld be i=ediately cuspended, or revoked. In additien to the hazard of gaseous and liquid releases tha'.
will co=pernd the u=eacu- ed doces already received, soce of these sene people vill alco be threatened by further radiation expecure end conta-dnation cf e4ricultural land by radioactive perticulates in the fo= of cesi=-cnd strenti=-cent--'nated dust that =ay be expected to accc=pany clean-up operations at the da: aced 52-2.
Thus, eny additional dcce received frc= operatienc, including ulti=ato decc 'scienien of T!2-1, will be additive end constitute an =due burden of rish beycnd that already e perienced but not fally or properly assessed. The cost-benefit analy is
=uct be recalculated to ta':e account of these issues and reiccuance cf the operating license withheld =til the fall and cc=plete cost-tenefit cnal /sic has been finished.
Centantion}. C i? centends that the operating licence for 52-1 =ct pe- "ently be revol:ed regardless of th3 m:=ber or I-ind of reasures uhich the Staff and Suspended licensee =ay undertel:e, becance operation of either C2-1 cr T 2-2 would cubject the people of central and southeaste= pennsylvania to double jecperdy and would cenatitute cruel end u==ual puniS=ent.
Cententien 0,. lu.e centends that unbelieveably lan regalatory, inspection, =d enforcement cli= ate created, -s**tained, and defended by the I20 itself = t beer a censiderable arcunt of the respencibilit- for this accident end that the :20 is not cocpeten; to regalate the operation of 52-1. The 120 practice of "regalation by audit" and regalancn by inattentien, racer c:n regulatien 5:/ real inspection and real ccnce= fer selet7, has created en aco -here there utilitias with lan senage=mt attituties towari ca'atf related cc=ce=s end censistent 71olations of the Cc=13 icn's =les receive -'"imal, if emy e.ttentien free the 17.0.
If the major enfc-cerent action age. inst the cucpended Licensee to ecce cut of the 52-2 accident is to sirply allow Se restart of 52-1, then the rec 21atcry st=ce of the :EC will be e-:tal clear to all other Operators of =cles: pcuor plent :
no violatien of So IEC =les or even applicable ctatutus, no catter heu flarmnt, will brira abcut any cub t= tie.1 enforcene:.t action (as pe=itted under ~:ec.136 cf the ?.tetic .ner.-,/ Let of if .,, as ancnded) frc= te IEC. Cn the other cand, if the IEC were to per=anent1;* revche the cperating licence for TI2-1 of the c= ently su pended Liccnece, the cessege to the nuclec induct / ucu'd be ciscr: sericus safet/ violations trirq scricus cencequencec to the per;et= tor.
Centr.tien Z. 20:-) c =tends that public cerlidence in the ability of Se E to not on1; reg: lite the = clear indust / but clso the villing.cc: cf the IEC :: dcci D f D *D 33$
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8 (Centention10centinued) ,
fi=ly v:.th licenacec uhich de=enstrate a centi:re.ing dicreed for and villful ncclect of the Cerrd :icn rules and the applicable actatutes hinces the dicciplina: r action tc.cn by the !!'.C vith rep.rd to this cucpcnded licnasce. 3heuld the I2C continua its entraordinarily pe=iccive re721 story ctance toward the cucpended licensee in vicu of the role of the habitual rule violatiens by the licencee in cent-ibuting to this accident, the cicnal vould be clear to the public: eny violation of rules and eny th: ec.t to the public by any licen:.ee vill be imediately fordven by the IT20. As a re ult, the =enbers of the public will have coed reason to live in fear of nuclec power plants, and this fe: will centribute eno =ously to ceneral panic, should any evacuation be cc.lled for.
t In additien to the abovecententiens, the CC'TP Inte:9 tenors include end incorporate by reference all contentions uithcut chance found in Mditienal Itaft Cententions of the Eavironnental Coelition en IIuclear Pover, dated October 5,10'[5 Respectfully submitted,
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J/ :erc; k, 'l . y Qi Chauncey ::e,ft9 ,'
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'. i p Representative of the IP O M g? Int::vencrs O
h '\N h33 0:1rndo Avenne State College, ?a. Ic301 (614)237-39c0 O
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CERTIFICATE OF SERVICE I hereby certify that copies of SUPPLE:lIIT TO 2 CUP PETITION TO INTERVT.NE: FINAL CONTENTICNS have been served on the folloling by deposit ig $he United States mail, firat class, postage paid, this c day of October, 1979:
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ChaunceyK9fford, Ivan W Smith, Esquire Chairman Atomic Safety and Licensing Board U S nuclear .tegulatory Commission Washington, DC 20555 Docketing and Service Section U S Nuclear Regulatory Commission Washington DC 20555 g g f, s T*
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