ML19323A922
| ML19323A922 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/16/1979 |
| From: | Kepford C Environmental Coalition on Nuclear Power |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19323A918 | List: |
| References | |
| NUDOCS 8005070062 | |
| Download: ML19323A922 (9) | |
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80050700r,A gr o..
UNITED STATES OF AMERICA NUCIZAR REGULATORI COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANI, e_t. al.
t Docket No. 50-320
('Ihree Mile Island Nuclear Station,
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Unit 2)
SUPPLDZ1TAL PETITION TO THE DIRECTOR OF NUCIZAR P2 ACTOR REGULATION FOR D:ERGDICI ACTION IN'IRODUCTION This is a supplement to the Intervenors' Request to the Director of Nuclear Reactor Regulation for Emercency Action by the Nuclear Regulatory Commissioh, herein, " Request," docketed at 3:30 p.m., April 27, 1979 Despite the urgent need for relief requested in that emergency petition, the receipt of that petition has yet (May 15,1979) not even been acknowl-edged by the Director of Nuclear Reactor Regulation.
This supplement to the April 27, 1979 Request is now submitted because of the continuing nature of the crisis caused by the March 28, 1979, catas-trophe at Three Mile Island Nuclear Generating Station, Unit 2. (TMI-2).
Through a series of operator errors, including violations of the Technical Specifications (Tech. Specs.), instrumental failures, and basic design deficiencies, initiated by a loss of feedwater to both steam generators at 14 :00 a.m., March 28, the sequence of events over the sixteen or so following hours at THI-2 brought the residents of Central Pennsylvania much clot,er l
to a potentially uncontrolled, uncontrollable, and uncontainable con melt-down than the public had heretofon been led to believe was possible.
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~2-f Large releases of radioactive materials to the environment have already occurred. Ms Margaret Reilly, of the Commonwealth's Bureau of Radiological Protection, stated publicly on May 13, 1979, that some " dozens of curies of I131 and " millions of curies of noble gases" had already been released from the badly damaged TMI-2 facility.
(See Tech. Specs., Radiological, Limiting l
Conditions for Operation, Sec. 2 3 2.)
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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 TdI-2, when an emergency actually arose, no one was prepared to respond
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promptly and adequately to protect the health and safety of the public.
One serious consequence of this lack of preparation has been the wholly inan'e-quate radiation monitoring 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-committee of the Government 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-mental monitoring was so unconscionably deficient for so long a period of tium,
even though that minimal monitoring may have met NRC minimal standards.
It is important to observe that the information which has been and is being made available to the public concerning radiation exposure has been and is inconsistent, misleading, and inaccurate. For example, according to the "AdHoc Population Dose Assessment Group" Report, April 15, 1979, the e vi= m total dose received by any individual was estimated to be 86 millirem (mrem), throughout the course of,.a accident until April 7, 1979. However, this figure must be compared with population exposures discussed in the videly reported March 30, 1979 closed meeting of the Cowd.ssioners of the NRC.
-3 On this morning of March 30, the licensee-operator, Metropolitan Edison, permitted the escape of very large quantity of radioactive gases over a period of one or two hours. Dose 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 containment structure was not isolated, and radioactive gases were escaping.
Mr. Gerusky said the resulting projected dose rate in Golds oro, situated due west of the plant and toward which the wind was then blowing, was 10 R/hr.
According to " Preliminary Sequence of Events: TMI-2 accident of March 28, 1979," w.emo 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 average value of 0.19 ra/ day, or 0.008 nR/ hour, as the background radiation exposure in this area of Pennsylvania. This value is based on thermoluminescent dosimeter (TLD ) readings in the general vicinity of 7MI-2 for the calendar year 1977 (/dHoc report, p 12) and should be compared with the nbackground" exposure rates disseminated to the press and public after the March 28 accidente In PNO-79-67AD, dated April 23, 1979, the NRC reported offsite readings were
" consistent with normal background levels (0.02 eiR/hr)"
This value of 0.02 mR/hr is 2.5 times the 1977 average background value reported by the "Ad Hoc" group.
Furthermore, the Ad Hoc report uses an atmospheric dispersion model which dictates that doses fall off with distance according to a minus 1.5 power j
law beyond a 10 mile distance fromTHI-2.
The exposure data presented I
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in thin #4 Hoc report do not support this model.
From the NRC data in Table 3-$ 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, they increase with distance from TMI-2.
(See, for exanple, Table 3-6, Exposures in the North sector; Table 3-9, Exposures in the South Sector.) No justification is offered in the AdHoo report for the use of this patently defective distance decay model which is It han 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 THI-2.
From accident sequences released by the NRC, it seems clear that large quantities of prin.wy coolant water were vented through the electromatic relief valve (EMV) after the initial period when the core was uncovered.
l 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 approximately hO 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 would 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.
i n.s a result, it is evident that fission products which were even slightly soluble in primary coolant water under the prevailing high pressure and high temperature conditions would have been leached out of the exposed fuel, and subsequently released to the containment sump through the Df7.
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Consequently, it is probable that th4 large quantities of water released into the containment structure--reportedly over h00,000 gallons--have high fission product levels measured in tens or hundreds of microcuries per milliliter (pi/ml).
Both the volume and the probable high level of contamination of this water exceed the cleanup capabilities of the reactor coolant letdown system for an entire year's operation of that system (See ZII-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 the dumping of this high-level waste water, purified or not, into the Susque-hanna River is imminent. While conceptually it may be possible 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 consequenc'es 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 syste'm or containment basement co.1d be catastrophic to the health and the economic well-being of the many communities which obtain dri*ing water from the Susquehanna River. Additionally, since the Susquehanna River is the major fresh-water source for Chesapeake Bay, a leak of even a few hun-dred gallons of the radioactive containment water into the river could prevent the use, of this Bay as a fishery for many years to come.
g ISSUES FOR CONSIDERATION As a result of the above, the Intervenors in e,he still ongoing operating license proceeding for DII-2, now joined by their parent organiza-tion, the Environmental Coalition on Nuclear Power (ECNP), urgently request that the Director of Nuclear Reactor Regulation recognize the gravity of the In this consequences of releases of these radioactive materials from DII-2.
context, the Intervenors also urgently request that the Director order that a public evidentiary hearing with sworn testimonies and full opportunity for cross-exanination be held in Harrisburg to openly and candidly ventilate the following issues:
i The validity of the population exposure estimates made to l
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l date in whole or in part by the NRC, including an account-ing for the numerous inconsistencies and contradictions such as those discussed above.
2.
The entire scope of the proposed release into the Susquehanna River of the high-level contaninated water, purified or not, prestntly contained, or anticipated to be contaminated, at DII-2.
3 The possible range of accidents and accidental discharges to the River and the full range of consequences--economic, environmental, and health--from such discharges.
h.
The capability and intent of the licenseeoperator of Tlil-2, to prevent minor or large-scale " inadvertent" contamination of the River, in view of the events since March 28, 1979
- 5. The capability and intent of the licensesoperator of DiI-2 to obey the rules of the Commission and all applicable l
statues related to any operations at TMI-2, in view of the events since March 28, 1979 6; The capability and intent of the Commission to ensure that:
(a) the rules of the Commission will be fully obeyed, (b) the applicable statutes, including the Atomic Energy Act of 195h, as amended, the Energy Reorganization Act of 197h, and the National Environmental Policy Act of 1969 will be fully obeyed, (c) the Commission or some other Federal agency will provide for monitoring capabilities to detemine radioactive contaminai. ion levels wherever Susque-hanna River water will be withdrawn for distribution for drinking water, irrigation, industrial pro-cessing, or other purposes prior to any further releases of presently contaminated water at TMI-2, purified or not, to the River,
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continued (d) the Comission or some other Federal agency will provide for adequate monitoring capabilities to detect elevated levels of gaseous and particulate contanination from 'INI-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 much greater distances from DII-2.
7.
The need for an Environmental Statement as required by See 102 (2)(c) of the National Environmental Policy Act of 1969 The events which have i,ranspired sinco IIarch 28, 1979, including, but not limited to, the enormous releases of lodine-13 Land noble gases, the threat of an iminent core neltdown, the releases of con-taminated water which have already occurred, the threat of future release of contaminated water which are or may not be anticipated, the threat of fata"e releaces of radioactive particulates--all go far beyond the events discussed in the Final Supplenent to the Final Environmental Statemeat of December, 1976. The possible environmental impacts of future planned activities and unplanned m accidental ones at LII-2 suggest that environmental statement is required for DII-2.
8.
The method, mode, conveyance capabilities, routes, and destinations of the unusually high-level demineralizee wastes to be generated at LII-2, and the ultimate method of disposal of the wastes, including a discussion of accidents or leaks and the resulting consequences at any stage of this process.
9 The possible negligent role of the Commission in licensing TMI-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 in operating license to the licensce-operator knowing that the licenses-operator had insufficient technical experience and capabilities to operate DII-2 safely.
- 10. The question of whether or not the operating license should be temporarily or permanently withdrawn from the licensee-operator of Ti!I-2 for grosc violations of the Commission's rules and of the operating license specifications and operating conditiohs for LII-2. See Sec.186 of the Atmic EnerEy Act of 195h, ao amended, cnd the stat *s and the sections of the Comrdssion's rules cited in the Request of April 27, 1979.
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, i RQUEST FOR RELIEF 1.
The Intervenors hereby incorporate by reference paragraphs 1 through 7 from'the April 27, 1979 Request contained under the heading, Relief Requested, hnd, in addition 2.
The Intervenors request that the Comission prohibit and prevent any further releases of radioactive materials to the environment, gaseous, airborne, particulates, or 1. liquid form, until twenty (20) days af ter final action by the Com.-d.ssion 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, 1CC.F.R. 20.601.
3.
The Intervenors request that the Commission prohibit and prevent any further releases of radioactive materials to the environmeni, gaecous, airborne particulates, or in liquid fom, until twenty (20) days after final action by the Commission 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.
1s. The Intervenors request that the Commission prohibit and prevent any further releases of radioactive materials, gaseous, airborne particu-lates, or liquid, until twenty (20) days after the completion of an evidentiary hearing in Harrisburg, Pa., open to the public, with sworn testimonies and full opportunity for cross-examination to examine the issues raised in this supplemental petition and Request of April 27, 1979.
5.
The Intervenors request the Commission immediately inform the Intervenors by First Class Mail of any and all releases of: radioactive materials, l
l gaseous, particulates, or liquid, from TMI-2 which occur subsequent to the receipt of this supplemental petition.
6.
The Intervenors request that the Commission mail to the Intervenors in a timely fashion copies of all materials which are pertinent to the issues raised in this supplemental petition and the ongoing crisis at
- TMI-2, including, but not limited tos P
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(a) the past or present condition of 'IMI-2, since March 28, 1979 (b) all environmental radioactivity monitoring data pertaining to the accident.at THI-2, data already collected and additional data as it is collected in the future (c) all planned activities, procedures, or processes at TMI-2 which have the potential for releases of radioactive materials to the environment.
l (d) all planned modifications of equipment, processes, or structures at TMI-2 (e) all planned cleanup operations inside any buildings contaminated during or subsequent to the TMI-2 accident (f) all chemical and isotopic analyses of contaninated areas and volumes, including primary coolant water, water in the containment sump, and air in the contain-i ment structure, and all subsequent and related analyses.
Respectfully submitted, l
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d Chauncey Kepf.
Representative of the Intervenors 1433 Orlando Avenue State College, PA 16801 kg ((y[hf 1-6114-237-3900 P
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