ML19308E142
| ML19308E142 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/20/1980 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 8003240453 | |
| Download: ML19308E142 (3) | |
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h/laryland Ad Hoc Committee on Three Mile Island
Contact:
John Kabler (301) 647-2273 Annapolis Maryland Ad Hoc Comm.
David Zwick (202) 638-1196 or (301) 325-8803 Clean Water Action Project STATEMENT OF THE MARYLAND AD HOC COMMITTEE ON THREE MILE ISLAND AND CLEAN WATER ACTION PROJECT TO THE NUCLEAR REGULATORY COMMISSION March 20, 1980 The Maryland Ad Hoc Committee and Clean Water Action Project are pleased with the NRC's response to our request that this second meeting be held in Baltimore to hear public comments on the proposed plans for an Environmental Impact Statement on the TMI Unit 2 decontamination.
We are also encouraged by the NRC's stated intention to complete the EIS before considering any dumping of radioactive water. The fact that you are considering dumping water from the accident at all, even after the EIS, is troubling, but we believe your doing the Impact Statement is moving in the right direction.
We hope and urge that the NRC will extend this same wise principle to its choosing a method for handling the high-level radioactive water in the containment building.InourresolutionpresentedtoGoverng.rHughesinDecember,we NRC not permit "any other new step in decontamin,by emergency situations, the recommended that, except as might be necessitate, ating TMI which could result in contamination of ground or surface waters, including accidental contamination, or which could prejudice the choice among the full range of decontamination strategies" without prior preparation of an EIS and full public hearings.
Developments since that time make it even more imperative that you follow that approach.
You should not approve or choose a method for handling tha'.
high-level water until your EIS is completed.
If you do not follow this approach, if instead you start croping your way through some kind M cleanup process one step at a time without a clear sense of where you will end up, you are likely to f
foreclose the safest options and possibly even add to the dangers. It would be a terrible mistake to enter into a decontaminatior. process without an overall plan -- a blueprint. The EIS will be your blueprint and, except to avoid a real emergency, you should not proceed without it.
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We have several concerns about the scope of the EIS.
Your study should not assume the safety of current operating ~ license conditions or discharge standards for radionuclides, since recent studies have raised so many questions about their adequac3 You should analyze not only the likely impact of any l
release on the average Marylander but also on those persons most susceptible to harm.
You should not assume an even or average dispersion but rather that any wastes released might travel or settle somewhere in a more concentrated form.
l Your study should give a special focus to tritium, the contaminant less likely to be removed by many of the treatment techniques that have been discussed so
\\k far.
Your overall perspective should be that any uncertainties should be O
resolved in favor of safety, in favor of not dumping anything at all.
k 80032404 9
- Post Office Box 473
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Severna Park, Maryland 21146 -
2/ Ad Hoc Committee / Clean Water Action statement The EIS should consider not only the likely technical or physical impact of any radioactive releases, accidental or intended, but also the psycholegical impact on a public buffeted by revelations of dangers at TMI.
You should recognize the severe erosion of public trust in the Nuclear Regulatory Commission, and in its standards, procedures, and calcul.tions and take care to build that trust back.
You should t;ke account, as well, of the heightened focus of public attention on TMI and its aftermath.
Large numbers of people are likely to consider the drinking watar unsafe or fear for the safety of the seafood if radioactivity from the accident is dumped into the river, even if given assurances that your calculations snow there will be little harm. Therefore, your Environmental Impact Statement should strongly consider the social and economic impact, especially the impact on the seafood industry if its reputation is damaged.
Because of this great danger, the Ad Hoc Committee and Clean Water Action Project urge that you take every possible precaution to avoid dumping any radioactivity from the accident into the Susquehanna River.
We believe that a principle focus of the Environmental :mpact Statement should be to find the best way of keeping all radioactive wastes out of our drinking water supplies and the Bay. The study should give its greatest emphasis to developing alternatives that preclude any dumping.
Solidification of the radioactive wastewater in cement or some other medium must be seriously considered.
A real emphasis must be placed in your study on every oossible scenario for a mistake or leak during any decontamination attempted, especially with the high-level radioactive water in the containment.
Even a still spill or leak of highly radioactive waste could ruin the reputation of the Bay fishery if not the fishery itself.
We have the following additional concerns' about the EIS procedures.
Argonne National Laboratory has been chosen by the Nuclear Regulatory Commission to perform the EIS. Argonne has been working cl.,sely with the nuclear power program for many years and is likely to be sy ' pathetic to industry assumptions, needs, and goals. Because the object!vity of this study must be beyond question, we feel it should be performed by the best-qualified independent scientists or that independent scient;sts should be an integral part of this EIS process. At the very le st, independent scientists should be asked to review the EIS and their comments included in the draft and final statement.
The independent scientists should be selected by a citizen advisory committee and sufficient funds must be available to the carnittee and to the scientists to ensure thorough participation and a well-done critique of the EIS. We urge the NRC to find a way to' ensure that these recources are provided.
l This is another essential way to build the public trust tht-has been so l
shredded by events up to now.
Due to the controversial nature of this situation, we elieve it to be essential that the NRC return to Baltimore when the draft ~ S is completed, so that the public may have an opportunity to comment on i-findings and conclusions.
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3/Ad Hoc Committee / Clean Water Action statement Finally, we are aware that Met Ed is pressing you for speedy decisions granting permission to get on with some of the quickest and cheapest methods of attempting to clean the damaged plant and put it back into operation. We urge you to resist these pressures.
The safety of the people -- of our drinking water, of our Bay, of the seafood and the seafood industry -- keeping all of these safe from harm must be your only consideration.
We believe safety is best achieved by your continuing in the direction you have now begun with this EIS, by completing a thorough analysis of alternative approaches to find the safest one and by making a blueprint for what you will do.
The Ad Hoc Committee and Clean Water Action Project urge you to take the safest and most prudent course for the citizens and economy of Maryland: Work to keep radioactive water from the TMI accident out of the Susquehanna River and the Chesapeake Bay.
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