ML19351D399

Direct Testimony Re Anti-Nuclear Group Representing York Contention V (D).Resume,Prof Qualifications,Supporting Documentation & Certificate of Svc Encl

ML19351D399
Person / Time
Site:	Three Mile Island
Issue date:	09/30/1980
From:	Beyea J ANTI-NUCLEAR GROUP REPRESENTING YORK
To:
References
NUDOCS 8010100067
Download: ML19351D399 (39)

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j RELATED CORRESPONDENOB l

. UNITED STATES OF AMERICA )

- NOCLEAR REGULATORY COMMISSION l

- 1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  !

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___ -- _____ __x In the Matter of  :

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METROPOLITAN EDISON COMPANY, et al., '-~

Docket No. 50-289 l (Three Mile Island =

l Nuclear Station, Unit No. 1) j 1

- - - - - - - - - - - - ==------------------x DIRECT TESM MONY OF DR. JAN BEYEA ON BEHALF OF THE ANTI NUCLEAR GROUP REPRESENTING YORK REGARDING A.N.G.R.Y. CONTENTION NO V (D)

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DR. JAN BEYEA QUALIFICATIONS

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i Dr. Beyea is a nuclear physicist who has specialized in the l consequences of nuclear accidents. He received his Doctorate fran Columbia University. As of May 1, 1980 he became the Senior Energy 1 Scientist for the National Audubon Society. Prior to that he was for four years a member of the research staff at the Center for En--

t ergy and Environmental Studies at Princeton University.

While at Princeton University he prepared a critical analysis of models of reactor accidents.

The lessons learned from this general study of nuclear accidents were applied by Beyea over and over agcin to specific problems at the request of governmental and nongovernmental bodies around the world. These requests came to Princeton because of the difficulty l

- l local governments and organizations faced in obtaining assessments '

of the seriousness of nuclear safety issues by independent scientists.

Because most scientists and engineers knowledgeable about the details of nuclear issues work for organizations which are seen as having a i

strong bias in favor of nuclear power, the nuclear policy group at Princeton found itself in great demand. Dr. Beyea prepared major reports on the safety of specific nuclear facilities for the Presi-

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dent's Council on Environment;l Quality (TMI), for the Swedish Energy Energy Commission (Barsebeck), and the state of Lower Saxony in West

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Germany (Gorleben). He examined in less detail, safety aspects of specific sites for the California Energy and Resources Commission, the Massachusects Attorney General's Office, The New York City l

l Council and, most recently, for the Governor of Pennsylvania in con-neation with the Union of Concerned Scientists krypton venting study.

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I (Dr. Bayea made the dose calculations for the U.C.S. study.)

A computer program useful for reactor emergency planning was written for the New Jersey Department of Environmental Protection.

l In addition, Dr. Beyea provided advice on nuclear facility siting l , policy and emergency planning for the Bureau of Radiation Protect'on of the Citr of New York, the Office of Congressman Theodore Weiss, j

the Environmental Law Institute, the Union of Concerned Scientists, i Friends of the Earth, the German Eco-Institute, the'Heidelberg Univer-1

city Environmental Group, the Oxford-ba.-;.ed Political Ecology Research

Group as well as numerous journalists and writers.

i His work was discussed in Harpers, Science, Spectrum and New Age i magazines, during his appearance on William Buckley's Firing Line and at a hational Academy of Sciences debate on nuclear reactor safety.

In addition to the reports written about specific nuclear facili-t.ies, which have been widely circulated, an article of Beyea's on resolving conflict at the Indian.P.lant reactor site appeared in l

The Bulletin of the Atomic Scientists and an article on Emergency i

Planning for reactor accidents will appear in the December issue. A Princeton report with Frank von Hippel on the value of improving re-actor containment systems has also been written.

A complete resume is attached as Appendix D.

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i' A N.G.R.Y. Contsntion V(D) l V. The NRC Order fails to require as conditions for ll restart the following modifications in the design of the TMI-1 reactor without which there can be no reasonable assurance that TMI-1 can be operated without endangering the public health and i

I safety:

(D) Installation in cffluent pathways of systems for f

the rapid filtration of large volumes of contam-inated gases and fluids.

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Outhne of Testimony "on A.N.*G.R.Y. Contention No. V (d)

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The accident at TMI Unit No. 2 suggests that the probability

, of a meltdown is sufficiently high that the possibility of a meltdown occurring at TMI Unit.No. 1 must be taken into account 4

in the regulatory process.

Although the containment at TMI Unit No. 1 may be strong enough to contain a meltdown, it was not specifically designed to do so. (The NRC's. Reactor Safety Styg estimated a one in five

. chance.that a PWR containment would fail during a meltdown.)

In light of these considerations, the philosophy of " defense in depth",now requires backfitting the TMI Unit No. 1~ containment with the capability to mitigate the consequences during a meltdown of a breached containment. _ The installation of a large

" filtered venting" system would substantially reduce off-site consequences should it be necessary to vent the containment building to prevent a hydrogen explosion or fire, should failure -

of the containment by overpressurization be imminent, or should a major leakage path develop.

As a first step towards this goal, the licensee should be .

required to complete a study investigating the compatibility of TMI Unit No. 1 safety systems with the filtered venting concept.

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..- 'i Dircet Tactimony of Dr. Jan EcyOc

, h 'on A.N.G.R.Y. Contention Nn.V (D).

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Q1 What is " Filtered venting"?

A A reactor containment with "Yiltered Venting" would have a filter system large enough to trap a significant fraction of the radioactivity which is projected to be released to the atmosphere in hypothetical core meltdown scenarios (such as

- those studiedL in the Reactor Safety Study ). If pressure inside the containment during the course of an accident reached dangerously high levels, or, if leaksgs were already occurring due to isolation failure, the pressure could be reduced by-venting some of the gases and aerosols in the containment through a large filtration system which would cleanse them of most radio- ,

I activity other than that carried by radioactive noble gases. l

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(A list of references on the subject is attached. )

Reactors were never designed to cont'ain a meltdown. They might, in fact, do so under certain accident ciremnstances but they

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would not'be expected to do so under all of the accident se-quences envisioned in the Reactor Safety Study. Reactor con-tainments were not designed to contain meltdowns because the assumption was made that regulatory procedures would keep the meltdown probability so low that reactors need not have the capability to handle the enormous pressure which might result from such an accident. (Table I, reprinted from Reference 2, shows the contribution to the containment pressure due to various failures which might occur in a PWR large volume containment during a meltdown. The total pressure is shown to significantly exceed the containment failure design pressure.)

In my view, and that of many others, the occurrence of l -

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'the TMI accident suggests that meltdowns can no longer be ignored. Should a meltdown occur at TMI Unit #1, without filtered venting installed, the only barrier left between ,,

the radioactivity and the public will be a containment which may not be strong enough to survive. In my opinion, the philosophy of " defense in depth," which has guided nuclear regulation in the past, now mandates the. addition of filtered venting as a backup to containment systems.

Q2 Do designs for filtered venting systems exist?

A Yes. See reference.8.

Q3 Would filtered venting handle all possible meltdown sequences?

A No. An escape path for radioactivity which bypassed the con-

.tainment building could also bypass the filtered venting system. The filtered venting system would, however, handle those meltdown accident sequences which are considered most likely--overpressurization and isolation failure.

Q4 What has the URC done about this concept?

A To answer that question, let me quote from a letter to Repre-sentative Morris Udall from Frahk von Hippel (July 22,1980) .

von Hippel was a member of the American Physical Society's 0

(APS) 1975 study group -- one of the early promoters of the filtered venting concept. The entire letter is included as Appendix A.)

"The NRC has sponsored various~ studies on the value of the

. particular containment improvement which our APS group pro-posed.(the filtered vent feature)-which incidentally has the strong merit that it can be retrofitted onto exis' Jing reactor containments. These NRC sponsored studies have generally come to cautiously stated positive conclusions. As with the case of thyroid protection, however, the agency has net shown any urgency to do anything about containment improve-ments. The one glimmer or hope I have in this case is based on the order issued by Harold.Denton on February 11, 1980

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. in response to the UCS petition that the NRC " suspend op-

- eration of (Indian Point) Units 2 and 3 pending resolution of various safety-related issues." In this order Denton states (pp. 7 and 9) that . .

"an NRC Task Force has been formed to review Indian Point Units 2 and 3 and Zion Station Units 1 and 2...

Other measures will continue to be evaluated in the next few months. Some of the design changes being considered are a vented, filtered containment atmos-pheric release system, core retention devices, and hydrogen control." .

In summary therefore, after five years the NRC is still studying these questions - in one case apparently as a substitute'for action - in the other perhaps as a prelude to some action some day. My overwhelming feeling after ob-serving the NRC in action on these matters for these five years, however, is that the staff is convinced that a seri-ous accident won't happen and that therefore there is no ,

hurry to bring these matters to some decision. Apparently,  ;

despite the NRC's finding that it "does not regard as reli- l able The Reactor Safety Study's numerical estimate of over- l all risk of reactor accident" (a major release of radio-activity only once in a thousand years from a population of one hundred reactors), the NRC staff still does.

I Q5 Why should THI unit il be the first reactor to get filtered i venting?

A Let me begin by pointing out that TMI #1 would not be the first reactor to have this f&ature. The German prototype breeder re-actor, SNR-1. has this capability.

In any case, it is my opinion that TMI unit il should become the first American commercial power reactor where the licensee is required to seriously pursue filtered venting.

. First of ' all, the Babcock and Wilcox reactor contained in

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Unit il is the type which is most sdspect. Secondly, the i

psychological gains from installing the system would be l

greatest at this site.

Q6 How should the Licensee be ordered to " seriously pursue" filtered venting?

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• g A The l'icensee should' prepara a study investigating ~ the com-patibility of filtered venting designs with the existing TMI-1 safety systems. If some potentially harmful inter-

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action should be found, modification of the standard filtered venting design should be investigated. This study' would be the basis for a decision by the licensing board as to whether or not this particular safety feature l should be required.

If it were found in the study that filtered venting was

'not compatible with TMI-l safety systems, I, for one, would l recommend against restart of. unit il on safety grounds alone.

Q7 How expensive would this system be?!

A Estimates range from 1-10 million. dollars.5,7,8 so that i

- a filtered venting system would represent an investment which is small compared to the total value of the plant.

l Q8 Why do you say that the TMI accident tells us that meltdowns

'are more likely than previously thought? -

A The TMI accident demonstrates that reactors are not the well-understood systems assumed in the regulatory process. The TMI accident suggests regulators must now deal seriously with the possibility that unknown meltdown sequences remain to be dis-1 l

covered.

Q9 Does royone really know the probability of a meltdown?

A I don't think so. Assigning a probability to a core meltdown has been controversial. The N.R.C. has recently withdrawn its previous expressions of confidence in the accuracy of the Reactor Safety Study's probability estimates for these events.12

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I Q10 Would filtered venting have been useful during the.TMI-2 accident under alternative sequences? .

. A It certainly would have been a desirable safety feature to he ve had the accident proceeded to a meltdown.

Should the containment spray or heat removal systems

. be damaged or fail to function properly, the pressure in the containment during a meltdown could rise to the point where it would be highly desirable to vent the containment. With

" filtered venting"e, venting could be carried out without releasing millions of curies of_the radioactive isotopes of tellurium, iodine and cesium. (These isotopes are predicted j to cause most of the harmful consequences from uncontrolled releases in a meltdown.)

'It would not be possible to safely vent through the existing filters in the air handling system because the existing filters

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would soon become overloaded.

Although a filtered venting system would trap most of the highly dangerous radioactivity under the hypothetical conditions described above, millions of curies of the noble gases, xenon and krypton would be released (perhaps 10 to 100 times as much as was released during the actual THI accident 1). Since release of all the noble gases could cause a certain number of delayed cancer deaths in distant populations (from 2 to 50 at the TMI site ), venting in a meltdown would not be undertaken' lightly, but only to prevent a much larger loss of life. It is possible that the operators of the reactor might wait until the con-tainment actually failed before turning on the filtered venting e

system. Even then the systemI would be useful in reducing the consequences of the accident, since a significant fraction of the radioactivity would still pass out througih, and be ..

trapped in, the.large filters.

011 How closa did the TMI-2 accident come to a meltdown?

A No one knows fr r sure how close the Three- Mile Island accident

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- came to a meltdown. The NRC Special Inquiry Group headed by Mitchell Rogovin suggests'that the accident actually was heading toward severe core melting and that the uncontrolled e

loss of coolant through the stuck pressure operated relief valve was terminated with only an hour to spare.15 (The Rogovin group commissioned an analysis of 15:: alternative event sequences. It was concluded that several of these alternative seque,nces might have resulted in substantial fuel melting. $)

Q12 What is your basis for claiming that the containment buildup at TMI-l might not be sufficient to contain a meltdown?

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Every major study of reactor safety, including the Nuclear Regulatory Commission's 1975 Reactor Safety Study (WASH-1400), 1,16,17 has concluded that there is a significant probability of a major calease of radioactivity into the atmos-phere following a core meltdown. In fact, the Reactor Safety Study estimated that about one in five PWR core melts would lead to a failure of the containment building through overpressur-ization.18 Q13 Are there other outcomes of the TMI-2 accident, short of a meltdown, for which filtered venting would have been a desir-able safety feature to have available?

, -7 A Yes.

Let me begin my r,esponse with a discussion of the seriousness of the actual accident that occurred. The Rogovin Inquiry

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Group [ Reference 14, Volume II, Page 527 has sunmarized estimates of the extent of fuel damage and the percentage releases of radioisotopes from th'e fuel rods.during the Three Mile Island accident. It a'ppears that "no significant quantity of fuel reached the melting point of U20 (5200 f)",

but that "about 50 percent of '?.a reactor core was damaged

[Enougg7 to release the most volatile fission products."

Even though complete melting of the fuel did not occur, the quantity of radioactive isotopes released from the fuel was similar bo that which would be expected in a meltdown for the volatile eleinents (noble gases, iodines, bromines, cesiums and isotopes of rubidium).

The Rogovin Group concluded, cautiously, that 40 percent to 60 percent of the core inven-

. tory of these volatile isotopes were released to the coolant.

• n particular, average estimates suggest a 46 percent release for the ncble gases, a 39 percent release for Iodine 131, a 63 percent release for cesium 137, and a 44 percent release for cesium 134 [ Reference 14, Volume II, Table II-57, Page 52I7. As for the percentage of the core inventory of these isotopes which ended up in the containment (primarily through overflow of radioactive cooling water) , the Rogovin Commission quotes 25 percent (Iodine 131) , 51 percent (cesium 137) , and 36 percent'(cesium 134).

Since radioiodine and radiocesium dominate the long-term consequences of hypothetical meltdown accidents, the TMI-2 accident had the potential for producing the 'me long-term

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consequences as a core meltd'own.

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of course, for this to

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happen,thelrIdh fity which escaped from the fuel would 3.v p i have had to becdme* airborne. ,

Q14 What would those.long-term consequences have been?

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A I will give two examples based on.a study I did for the Council on Environmental Quality.P (Excerpts from that study are l f s.

included as Appendix B.)  !

j Example 1. In this example, 5% of the core inventory i

i of radiciodine is assumed to be released into the atmosphere.

i (This represents about 20% of the radioiadine which passed-into the containment system during the TMI accident) . For this hypothetical accident, the following consequences have been calculated for the TMI site under average weather con-ditions: 2 to 325 delayed cancer deaths,20 200 to 27,000 2

delayed cases of thyroid nodules, 25,000 mi of temporary restriction on cattle grazing to prevent consumption of contaminated milk.

(Were the wind to be blowing towards the ocean, the area would be less. The range in the health effects numbers reflects differences in assumed wind directions as well as uncertainty in cancer dose coefficients.)

Example 2: In this example, 10% of the core radiocesium is assumed to be released into the ' atmosphere. This repre-sents about 20% of the radiocesium whi.ch passed into the con-tainment system during the TitI accident.) For this hypothetical accident, the following canaequences have been calculated for the TMI site under average weather conditions: 12 to 1650 t

excess cancer deaths over the following 75 years,20

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75 square miles of land requiring deccntamination or long-term restrictions

. -9a on use. (If, in the consequence calculations, the core inventory of cesium were taken to Le that of a mature reactor core, rather than that of a new reactor operating for only a few months, the calculated consequences for the same percen-tage release would increase: 62 to 8150 excess cancer deaths over-the following 75 years,20 550 mi 2 of land requiring decontamination or long-term restrictions on use.)

Q51 Are such airborne releases possible? '

A Such releases are certainly possible in a meltdown. In fact, releases of this magnitude would be considered " intermediate" ,

possible outcomes of a meltdown. However, it apparently has not been studied whether or not such releases could have been alternate . outcomes of the TMI accident short of a full meltdown. l 1

I. I Although a number of detailed alternate event analyses have been made for the TMI accident, 14 concern has been directed at event sequences which could lead to fuel melting, not sequences l which could have led to the escape to the environment of the -

1' radioactivity which actually entered the coolant water. In the absence of such studies, I have made a preliminary exam-ination of such sequences in Appendix C.

I have found at least two release pathways which are of concern.

1. An initial release into the containment building of radioactive gases and water droplets followed by a major failure of the containment building resulting in an air-borne release.

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2. Contamination of the secondary coolant loop as a result of leaks in a steam generator followed by a direct release into the atmosphere of contaminated steam and water droplets from the secondary system.

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Q16 Would filtered venting handle a leakage path through the secondary system?

A Not in the present designs.

Q 17 Assuming you are correct that radioactivity could have entered the TMI-2 contmi - nt in airborne form, how could the I , containment have failed without a subsequent meltdown? e A Reactor containments can fail or be bypassed theoretically, j even without a full core meltdown:

1) due to overpressurization following failure of the pressure-reducing spray systems (as in the PWR4 accident

- described in the Reactor Safety Study (RSS)) .

2) due to failure of the containment to properly isolate ,

l from the atmosphere (as in a PWR5 or PWR:.7 accident in the RSS) , Such an isolation failure actually occurred at TMI for the inert . radioactive gases, Xenon and Krypton.21 i 3) conceivably due to a hydrogen explosion.

It is also possible that the containment might be deliberately vented because of concern that a hydrogen explosion or fire might lead to a more catastrophic failure.

CNote that in the case of a full core meltdown, there is the additional theoretical possibility'of a violent steam explo-0 l.

sion breaching the containment (as in a PWR1 accident of the RSS)--an event which might arise from a large fraction of the molten core falling "in a lump" into a pool of water at the bottom of the pressure vessel or containment building.)

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• l Q18 . Therefore, based on an analisis of alternative outcomes of the TMI unit #2 accident, there appear to exist a number of plausible a'%-ccident sequences (including those which do and .

• do not end in meltdowns) for which a filtered venting capa-l bility would be the safety system.of last resort?

A. Yes. . .

Q10 Please summarize your testimony.

A Backfitting the containment building at TMI Unit i1 with the capability for rapid filtration of large volumes of radio-activity-contaminated gases and aerosols could strengthen the capability of the containment building to prevent the worst releases at relatively low cost. Such a filter system could substantially reduce off-site consequences should.it be nec-essary to vent the containment building to prevent a hydrogen explosion or fire, should failure of the containment by over-

. pressurization be imminent, or should a major leakage path develop.

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Tablo 1, repr:duced from Refsrcac3 2 12 .

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Table I-1: Pressurization Contributions for Typical Reactor Containments Sas11 Volume Steam Pressure Suppression Type *'

(designed to contain 4ats. overpressure )

R2 pressure from oxidation of 100 percer.i .of zirconium in core 5-11ata.

C0}inder cy of concrete 6 meters in diameter and 2.5 m. thickpressure from 4-9ata." thermal decompositi l'

Larne Volume Tvo*6 (ssch as at THI)

(designed to contain 3ata, overpressure )

Initial pressurization by steam from primary coolant 2.5ata.

Additional pressurization in subsequ'ent three hours in absence g of containment cooling 3 atm.

• Actual failure pressure could be considerably higher. Ref. 4 estimates the failure overpressure for a small volume containment at 9-12 atm. (n.

VIII-37) and for a larme volume containment at 5-7 atm. (p. VIII-22).

. (NUIE THAT REF. 4 IS THE REACTOR SAFETY STUDY.)

Notes a) Typical of containments used in most operating US Boiling Water Reactors.

Free volume = 7 9 x 10'm J (40% over the vapor suppression pool - ref. 4,

p. VIII-8). The higher pressure values apply if the noncondensible gases are swept by steam into, and are trapped in, the free volume over the vapor suppression pool as assumed in ref. 4 b) 56,000 kg Zr (ref. 5, p. E-7). At Three Mile Island app ~roximately 50 percent of the zirconium was oxidized (ref.,1, p. 30).

c) Ref. 4 (p. VIII-30) assumes this quantity of concrete decomposes.

Ref. 5 (p. D-6) assumes four times as much. The concrete has a density of 2.4 and is approximately 25 percent CO 2 he weight (in CACO , Ref. 5, p. D-2) 3 d) Typical of those used in most US Pressurized Water Reactors. Free volume = 5.1 x 10'm3 (Ref. 4, p. VIII-4).

e) Initial 0

mass of water in the primary coolant system = 1.9 x 105 kg at 300 C (ref. 4, p. VIII-4).

f) Ref. 4, Fig. VIII 2-6.

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.- , Not97 rnd Rafnrrnc7)

1. U. S. Nuclear Regulatory Co5 mission, Reactor Safety Study.

(Washington, D. C. , WASH-1400, 1975.)

2. " Nuclear Reactor Accidents: The Value of Improved Containment." J. Beyea, F. von Hippel, (Princeton University, Cancer for Energy and Environmental Studies, Princeton, N.J., PU/ CEES #94,1980) ./

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3. A detailed review of the issues involved. in this concept can be found in Allan S. Benjamin, Program Plan for the Investigation of . Vent-filtered Con-i tainment Conceptual Desiens for Light Water Reactors, (Washington, D.C.,

Nuclear Regulatory Commission, NUREG/CR-1029, 1979).

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4. Recently a U.S. Nuclear Regulatory Ccimeission task force recommended that the agency make a decis, ion within approximately a- year on whether or not to require a filtered release system on reactor containments. ENRC, TMI-2 Lessons Learned Task Force Final Report, (Washington, D.C., NUREG-0585, 1979),

p. 3-5.3

5. Evaluation of the feasibility, economic impact. and effectiveness of under-ground nuclear power plants, Aerospace Corporation, Report to the Califotnia Energy Commission, Clos Angeles, ATR-7.8 (76)2-14)-13.

Ef fect of Containment Venting on the Risk from LWR Meltdown Accidents, P.

6. Cybulskis, R. O. Wooton, R. S. Denning, (Nuclear Regulatory Commission, Washington, D.C., NUREG/CR-0138, BMI-2002, 1978). -

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7. A Value-Impact Assessment of Alternate Containment Concepts, D.

Carlson,J.Hickman (Nuclear Regulatory Commission, Washington, D.C. ,

NUREG CR-0165, 1978).

8. Post-Accident Filtration as a Means of Imorovine Containment Effectiveness, B. Gossett, M. Simpson, L. Cave, C.K. Chan, D. Okrent, I. Catton, (Los Angeles, University of California, UCLA-ENG-7775,1977).

9. " Gas clean-up system for vented containment," 14th ERDA Air Cleaning Confer-ence, J.L. Kovach, Nuclear Consulting Services, Inc., Columbus, Ohio, undated.

j 10. " Report to the American Physical Society by the Study Group on Light Water Re-actor Safety," Reviews of Modern Physics, 47, 1975, p. S110. _

11. For a discussion ~of"'the " psychic" or " anxiety" costs of an acci-dent see, e.g., U. S. Nuclear Regulatory Commission, United States, Experience in Environmental Cost Benefit Analysis for Nuclear Power Plants with Implications for Developing Countries,(Washington, D.C.,

. 1980, NUREG-0701,pp. 64 and .'.ppendix E.)

12. "NRC Statement on Risk Assessment and the Reactor Safety Study Re-d port (WASH-1400) in the Light of the Risk Assessment Review Group Report," (NRC, January 18, 1979).

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I Notes and RefCrencOc, peg 3 2 ,

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13. '

There is conflicting data on the amount of noble gases actually

, released during the accident. Reference 14 lists the range of i estimates as 1.5 to 13 million curies of xenon 133. This would I represent .9 to 8 percent of-the approximataly 170 million '

j curie inventory of xenon 133 (Ref. 1, Table VI 3-1,1,.7,.

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k Release 'of 60% of the noble gases at the TMI s;Lterhes been cal-culated to cause 1 to 25 delayed cancer deaths:.'($(ikiTable...I,.

1 I Appendix B). Release of 100% would cause lessItdha";! ~ TO'.%. 1'ayed deaths .

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14. Nuclear Regulatory Commission Special In hir'y" Group,.'M.'Rogovin, G. T. Frampton, Jr., et al., Three Mile' Island, A Report to the Commissioners and to Ee Fublic (Washington, D. C., 1980, Volume II, pages 358-360)

15. Ref. 14, Vol. I, Pages 20, 91, Vol II, pages 553-570.

16. Ergen, W. K., et al., Emergency Core Coolina - Recort of Advisor 1r Task Force on Power Reactor Emergency Cooling, TID-24226 (1966)

N.T.I.S.

17. D L. Morrison, et al., An Evaluation of the Applicability of Existing Data to the Analytical Description of a Nuclear Reactor Accident -- Core Meltdown Evaluation, BMI 1910 (1971), N.T.I.S.

i 18. The sum of the yearly probabilities given in Rgf. 1, Table VI 2-1, for PWR-1, 2 or 3 core melt accidents-(1.3x107 ) divided by the sum of the probabilities of PWR1 through PWR7 accidents (6x10 ?).

19. Jan Beyea and Frank von Hippel, "Some Long-Term Consequences of

. Hypothetical Major Releases of Radioactivity to the Atmosphere from Three Mile Island," Report to the President's Council on En-vironmental Quality, 722 Jackson Place, N.W., Washington, D.C.

20006 U.S.A. 1979, (Draf t) .

20. These numbers are obtained from Table 1, Ref. 19. (Reproduced as Appendix B).

21. Ref. 14, Vol. II, pages 352-365.

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. APPDDIX A .

Complete text of letter from Frank von Hippel of the Center for Energy and Environmental Studies of Princeton University to

_ Representative Morris Udall Subcommittee on Energy and the Environment e

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July 22, 1930 t

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l l Representative Morris Udall i

Subcomunittee on Energy and Environment c House Interior Cormittee ,

i 1626 Longworth House office Building l Washington, DC 20515 i

Dear Representative Udall:

l (n 1974 I was chairnan of the subcossaittee on reactor accident conse-quences and their mitigation of the American Physical Society's Study Croup i

on Light Water Reactor Safety. Our subgroup came up with two important i

proposals to the NRC in the area of reactor accident consequence mitigations

1) . ' thyroid Protection from Radioactive Iodine l "We believe that a national policy of stockpiling

! thyroid blocking cherticals for possible emergency

- distribution should be established."1 4

l. 2) Improved Reactor Containment Duilding Design _

f "...more emphasis should be placed on seeking improvements in containment methods and tech-nology. In particular, controlled (filtered]

4 d venting of the containannt building in case of j overpressure should be , studied.n2 j fince the APS group was disbanded in the spring of 1975, five years ago, j I undertook a personal effort so see that the HRC considered those proposals l

seriously. I am sorry to say, however, that, despite some studies, the NRC har been unable in the past 5 years to bring itself to the point of a policy decision in either case.

Now that the confusion following Three Mile Island has subsided, I would like to try to get these issues addressed with a higher priority. For the benefit of those who will have a continuing responsibility and involvement

" Report to the APS by the Study Crcup on Light Wate~ Reactor Safety," Reviews of Modern physics 47, pp. S109-S110.

2 Ibid, p. S7.

9

w.. -. . -

Appendix A-2 2.

i. .. .

!)

Representative Morria Udall July 22, 1980 l

~ in the reactor safety ares, I have theredore tried to stessarize the situation 0 ion each issue as it currently stands in the attached reports.

I Ma first report: "Why the U.S. Has No Syroid Protection Policy: An Account of Paralysis at the .Nucisar Regulatory Cosenissio2" has been submitted for publication in the October issus of the Bulletin of the Atomic Scientists.

It is a short suussary of my experiences in trying to get the NRC to develop a thyroid protection policy. I find profoundly distubbing the .!RC's inability to face this issue - not only because I think- that it is important for the

,' nation to have a strategy for protecting the thyroids of the millions of people who might be downwind in' case of a large release to the atmosphere of radiciodine from a reactor accident, but also because my experiences in this I l

case have fed my feeling that the NRC is continuing in general to follow the AEC tradition of avoiding the hard decisions in the reactor safety area.

The second report, Nuclear Reactor Accidents: The Value of Inproved Con-  !

cainment, which I have coauthored with Jan Leyes, explains why we should want improved reactor containment buildinga which will with greater confidence con-3* tain the radioactive gases which would be released by a reactor core melt-down. )

. (You only need read the first cight pages. % e rest is all tech e al backup l

~

for figure I-1 on r ga I-5 which shows the land arens which would be seriously I affected by, radioactive releases of different magnitudes.)

%e NRC has sponsored various studies on the value of the particular con-tainment improvement which our APS group proposed (the filtered vent feature)

- which incidentally has the acrong merit that it can be retrofitted onto existing reactor containments. Desa NRC sponsored studies have generally

. come to cautiously stated positive conclusions. As with the case of thyroid protection, however, the agency has not shown any urgency to do anything about containment improvements. The one glimmer of hope I have in this case is based on the order issued by Harold Dennon on February 11, 1980 in response to the UCS petition that the NRC " suspend operation of (Indian point] Units 2 and 3 pending resolution of various ' safety-related issues."3 In this order Denton states (pp. 7 and 9) that

! "an NRC Task Force has been formed to review Indian Point Units 2 and 3 and Zion Station . Units 1 and 2...

! Other measures will continue to be evaluated in the next few months. Sone of the design changes being considered are a vented, filtered containment atmos-pherde release system, core retention devices, and hydrogen control." , ,

i ..

3In the Matter of Consolidated Edison company of New York, Inc. (Indian Point Unit Nos.1 and 2) and the Power Authority of the State of New York (Indian Point Unic No. 3), Director's Decision Under 10 CFR 2.206, Feb.11,1980.

l M ^

!D T h M

D D U J\ . A s l =

. Appendix A-3

3. .

. Representative Morris Udall July 22, 1980 In summary therefore, af ter five years the NRC is still studying these .

questions - in ona case apparently as a substitute for action - in the -

other perhaps as a prelude to some action someday. Ify overwhelming fe& ling af ter observing the NRC in action on these matters for these five years, however, is that the staff is convinced that a serious accident won't happen and that theridoes there is to hurry to bring these matters to some decision.

Apparently, despite the NRC's finding that it "does not regard as reliable

. The Reactor Safety Study's assnarical estimats of overall risk of reactor i

accident'4 (a major release of radioactivity only once in a thousand years from a population. of one hundred reactors), the NRC staff still does.

t Best regards, l

l Pv5/ra Frank von Hippel l

t I ..

I i

l l

e "NRC Statement on Risk Assessment and the Reactor Safety Study Report (IIASH-1400) in the Light of the Risk Assessment Review Broup Report,"

(NRC, January 18 1979).

D**D *D 3'Y A me etn A X m

1 .

l .

J i

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i i

APPENDIX B s i

j

) Excerpts from Referenca 19, i Jan Beyes

Some Long-term Consequences of i Hypothetical Maior Releases of i Radioactivity to the Atmosphere

. from Three Mile Island (Report to the Council on Environmental Quality, September 1979 (Draft))

2 4 e I

^

4 6

t e

a

l .

h -

, -D*R D *D ~Y' h Tt Summer, Table. Sees tene-Tere Ceeeeeeeeeee of dg gk, j

Benethetical Areidente it Three stiIe Telead*

' (Bot imeloding emy early 111aese er deaths which might g be esemetated with high desee to unevesueted populattama a few tees of miles from the reacter.)

l I AREAS REQUIRDC 1

! neuTo m :0!n forceAnf seca m nisanas ACC M RELEASES TO A3NOSp WEE CamCIR DEATES*** MODULE Aca1CULTt:RAL Os LO:sc.Tutt  !

8E83EEAN Qae/haakd ) CASEsc.e RISTRICT10ms 31sTn!CT1055 os l (les/high) OCCUPAT10EI 1M1-0 108 et emble seems (ew 1== I en seemel estidens) 0/4 o e a1 LEASES CatATER TBAE ACTUALLY OCCURRID tee of emble gases 1/23 0 0 TM1-1 TM1-2 $3 te'damos pies 401 enh14 2 g) 23.000mi ,

games 3/330 200/27.J00 2 g) 75mi 2

TN1 3e 3:1-2 pies 101 et Ceetus 13/2000 200/27.000 13.000mi 3700mi !O t

SOE et Cosima 100/12.000 630mi TM1-Ae .

til-5e "7WR2" Salease with II 2 g) 2 semplete care malt 200/22.000 3500/430.000 173.000m1 1400mi l

CoussocssCzs Asstaclas Tur aEACmt Coas nas sexu is ottaanon rou is:Cs touC1m TuAs 3 runmts otATCar C0ar) 2 25.000m1 2 s) $50e1 Dti-3b TRI-2 ties 103 of Ceetae 65/0300 200/27.000 2 h) A300a1 2

440/48.00tM 18.000m1 TM1-4h 501 et Castes 2 g) 2 350/60.000 N II 3300/450.000 173.000e1 3300m1 IX1-5b *FWR2" release Feetnotes for Table f e) All accidente are assumed to take place under " typical" esteorological condittees. Vind shifts med changes le weather neglected. Details can be found to the supporting tr.bles la Appendia 5 and in the techeical_ discussies to Appendix E. Nealth effecta are tetelled for people livisd beyond 50 s11es.

b)' Cunelative total over a 75 year period after the accident. The resse of geestic defects woeld be equal. very reaghly, to the range s! delayed cancer deathe.

c) The low number is for the east favorable wied directise (Eastern Maryland). assuming Ce most optimistic coefficieet relating dose to health effsets. and evacuattee out to 50 elles. (Without evacuattee. the low ember would be a facter of 2-5 higher depending en the accident.) _

The high numbe r is for the least f avorehle wind directica (N.T.C./Sestee) and assuming the aset peseteletic -

coeffittent relating dose to health effects. (Evacuation is elee assumed out to 50 sites, but has a s=all Sepect se the high resulte.)

See Appendia E for a discemeten of the dese/ health-ef fect coefficient rense used.

d) Beduce high value by a facter of about 4 to obtate the predicties which would result using the peseter safetv-I JseLdata I Model. Multiply by A to obtste the prediction which would result esing health effecto coedlictents eased I of Maecuse. Stewart med Eneale. See Appendia E.

e) Comslative total over a 23 yest period af ter the accideet. A bleek entry taplies e emell number.

f) See Table 5-f in Apoendia 5 for details.

e

3) Mith reactietten. (see Table 517). Neh of than area would be water for a wind free the weet.

h) Fires year crop restrictione. Oterveeted feed set seitable for childres.) See Table 5-T. h eh of this ares eemld be water for a wind from the West.

1) A FUR 2 eteident as def amed in the teneter Seferv Study j) This number posainly could be reduced to half if semesve decontamisattes er relocattee efforts were undertakes la erben areas to eveld low-level radiattee deses.

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APPENDIX C r

a j A Preliminary Investigation of

~i Syne Alternative Event Sequences which Could Have Led, without i

a Meltdown, to a Significant Release t of Radiciodine and Radioce*sium

- at TMI Unit No. 2

.s

.I t

1 4

.e 4

e 1 a s

en-D e

+

4

Appendix C-2 As discussed in. the main tatstimony, the TMI Unit No. 2 accident led to the vlesse into the containamat of approximately 25 percent of the core inventory cf radiciodines and between 36 and 51 percent of the core inventory of radiocesium.

In this appentifu a preliminary analysis is muda of some event sequences which could result in the escape of these isotopes into the air outside of the reactor conesinannt buf.1 ding. .

It appear.s that a substantial fraction of the radioactivity which escaped from the fuel rods could have escaped.into the atmosphere as a result of leaks in the primary / secondary cooling system leading to either 1) a direct release into the atmosphere of steam and radioactivity from the secondary cooling system or 2) an initial release into the containment building of radioactive gases and water droplets followed by a major failure of the containment building resulting in an airborne release.

Case 1:

The most plausible pathway for an escape from the secondary loop to have taken place during the actual accident appears to be by way of a leak in one of the steam generators. (The steam generators serve as heat exchangers between the priaary and secondary cooling water.) ,

1 For such a pathway to develop, two leaks must occur. First, a leak must  !

develop in one or both of the steam generators at the interface between the " primary" coolant containing the radioactivity and the c'colant in the secondary side. This did not occur at TMI. However, steam generator

~

leaks have occurred at other reactors and the general problem remains an unre. solved cafety issue. [NuclearRegulatoryCommission,NRCProgam for the Resolution of Generic Issues Related to Nuclear Power, (Washington, D. C.,

NUREG-0410,1978, Task A3); also Task Action Plans from Unresolved Safety Issues Related to Nuclear Power Plants, (Washington, D. C., NUREG-0649, 1980, Tasks A3, A4, AS)._7

Appendix C-3 f

. 4 Second, in order to provide a path to the atmosphere, a leak must develop

~

f in the secondary side of the system--an event which actually did occur at TMI.

One steam generator did release steam to the atmosphere from the secondary side. Furthermore, the steam escaping from the top of the reactor was not i

checked for radioactivity for two hours, so that had a leak actually occurred between the primary and secondary system. there definitely would have been a release t s the atmosphere [ Reference 14, Volume II, Page 328._*/-although not necessarily of the magnituda hypothesized for the examples given in the main testimony. We have not made estimates of the probability of a leak in the steam generator developing under the actual accident conditions or during alternative sequences of events which might have stressed the steam generators to such a point that large leaks occurred. Any such estimates would be highly uncertain.

' ' 'Furthermore, we have not tried to estimate the fraction of liquid which would escape as vapor or as fine water droplets. If the cesium and iodine were carried in the liquid in solution form, the bulk of any escaping

. radioactivity would be contained in the escaping water droplets, not in the escaping vapor.

Case 2:

Accident sequences at TMI in which the containment could fail without the accident proceeding all the way to a meltdown were discussed in the main testimony. In this section, pathways for the radioactivity to enter the containment atmosphere are discussed.

Considerable quantities of radioactivity did entiir the containment building during the TMI accident, but not necessarily in airborne form.

However, a leak in the primary coolant system, such as at the seals of the main reactor cooling pumps, would have directly vented highly radioactive steam and water droplets into the containment. (A leak in such seals

Appanulx c-f .

has occurred in the past at the Arkansas Unic I reactor.) Severe l vibrations in the cooling pumpe did oc' cur during the THI accident-t vibrations capable of damaging the seals and attached piping , deference.14,

' Volume II, Page 319_7. ' These vibrations were severe enough to cause .

l the operators to shut down all of the main, coolant pumps af ter about two hours into the accident [ Raference 14, Volume II, Page 323_"7. (The pumps were actually ineffective in cooling the core at this time.)

Had' the operators felt it was necessary to leave the reactor cooling pumps on,it is possible that a seal' leak.would have developed. The fact that the operators tried to restart some of the coolant pumps on a number of subsequent occasions suggests that the initial decision to shut them down was not an inevitable decision.

Thus, there appear to be alternative event sequences which could have led to release of airborne radioactivity into the containment atmosphere.

There are other possible mechanisms for release of radioactivity to the

. containment atmosphere which we shall not discuss in detail. For example

,a steam path could be forced through vents on the pressurizer including a ,

i path through the " pilot operated relief valve" (when in an "open" state).

l into the " reactor coolant drain tank" and then into the containment I

l atmosphere.

W e

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i.

I APPENDIX D Rasune for Jan Beyea 1

l I

t 9

Recume for Jan Beyca

- May 1980 ,

EDUCATION: .

J Ph.D'. , Columbia University,1968. (Nuclear Physics)

Be A., Amherst College,1962 EMPIDYMENT HISTORY: .-

1980 to date,. Senior Energy Scientist, National Audubon Society, 950 Third Avenue, New York, New York 10022.

1976 to 1980, Research Staff, Center for Energy and Environmental Studies, Princeton University.

1970 to 1976, Assistant Professor of Physics, Holy Cross College.

_,1968 to 1970, Research Associate, Columbia University Physics

- Department.

CONSULTING WORK: _

Consultant on nuclear energy to the New Je'rsey Department of f Environmental Protection, the Office of the Attorney General, Common-l realth of Massachusetts, the state of lower Saxony in West Germany j and the Swedish Energy Commission.

PUBLICATIO.NS CONCERNING ENERGY CONSERVATION:

f

" Locating and Eliminating Obscure but. Major Energy Losses in Resi-dential Housing", Harrje, Dutt and Beyea, ASHRAE Transactions, 85, ,

l Part II (1979). (Winner of ASHRAE outstanding paper award. ) .

" Attic' Heat Loss and Conservation Policy", Dutt, Beyea, Sinden.

ASME Technology and Society Division paper 78-TS-5, Houston, Texas, November 1978. ,

l

" Comments on the proposed FTC trade regulation r.ule on labeling -

and advertising of thermal insulation", Jan Beyea and Gautam Dutt, testimony before the Federal. Trade Commission, January 1978.

" Critical Significance of Attics and Basements in the Energy Balance of Twin Rivers Townhouses", Beyea, Dutt, Woteki, Energy and Buildings, Volume I (1977), Page 261. Also Chapter 3 of Saving Energy in the Home, Ballinger, 1978.

"The Two-Resistance Model for Attic Heat Flow: Implications for

-- Conservation Policy", Woteki, Dutt, Beyea., Energy--the International Journal, 3, 657 (1978).

• " Energy Conservation in an Old 3-Story Apartment Complex", Jan Beyea, David Harrje, Frank Sinden, Energy Use Management , Fazzolare and Smith, Pergamon 1977, Volume 1, Page 373.

" Load Shifting Techniques Using Home Appliances", Jan Beyea, l

Robert Weatherwax, Energy Use Management , Fazzolare and Smith, Pergamon 1978, Volume III/IV, Page 121.

l.

m._ ., .

_g_

PUBLICATIONS CONCERNING NUCl2AR POWER SAFETY: l Articles > i "Neuorientierung der Katastrophenschutz-Planung nach den  ;

Erfahrungen von Three Mile Island"', Chapter 3 in Im Ernstfall

-hilflos?, E. R. Koch, Fritz Vahrenholt, editors, Kiepenheuer k Witsch, Cologne, 1980.

" Dispute at Indian Point", Bulletin of the Atomic Scientists,

~

36, Page 63, May 1980, -

1 Published Debates: .

The Crisis of Nuclear' Energy, Subject No. 367 on Firing Line, l P. B. S. Television. Transcript printed by Southern Educational ,

Communications Association, 928 Woodrow Street, P. O." Box 5966, j Columbia, South Carolina,1979. j 1

Nuclear Reactors: How Safe Are They?, panel discussion sponsored l by the Academy Forum of The National Academy of Sciences, 2101 Con- l stitution Avenue, Washington, D. C. 20418, May 5,1980, to be

' ~

published.

Reports:

" Decontamination of Krypton 85 from Three Mile Island Nuclear Plant", (with Kendall, et.al.), Report of the Union of Concerned Scientists to the Governor of Pennsylvania, May 15, 1980.

"Some Comments on Consequences of Hypothetical Reactor Accidents l at the Philippines Nuclear Power Plant" (with Gordon Thompson),

National Audubon Society, Environmental Policy Department Report No. 3,  ;

April, 1980. j "Nilclear Reactor Accidents: The Value of Improved Containment",

(with Frank von Hippel), Center for Energy and Environmental Studies Heport PU/ CEES 94, Princeton University, January 1980.

"Some Long-Term Consequences of Hypothe.tical Major Releases of j Radioactivity to the Atmosphere from Three Mile Island", Report to the President's Council on Environmental Quality, September 7, 1979.

"The Effects of Releases to the Atmosphere of Radioactivity from Hypothetical Large-Scale Accidents at the Proposed Gorleben Waste Treatment Facility", report to the Government of lower Saxony, Federal Republic of Germany, as part of the "Gorleben International Review",

February, 1979. )

" Reactor Safety Research at the Large Consequence End of the Risk

~

j Spectrum", presented to the Experts' Meeting on Reactor Safety Research l I

in the Federal Republic of Germany, Bonn, September 1, 1978.

A Study of Some of the Consecuences of Hypothetical Reactor Acci-dents at Barseback, report to the Swedish Energy Commission, Stockholm, DS I 1978:5, January,1978.

fd .[-

Appendix D-3 i ,,

1

- PUBLICATIONS CONCERNING NUCLEAR POWER SAFETY (Continued)

Testimony:

" Alternatives to the Indian Point Nuclear Reactors", Statement before the Environmental Protection Committee of the New York City

Council, December 14, 1979. Also before the Committee, "The Impact cn New York City of Reactor Accidents at Indian Point", June 11, 1979.

Also " Consequences of a Catastrophic Reactor Accident", statement to t,he New York City Board of Health, August 12,1976 (with Frank von Hippel). .

". Emergency Planning for a Catastrophic Reactor Accident",

Testimony before the California Energy Resources and Development Commission, Emergency Response and Evacuation Plans Hearings, November 4, 1978, Page 171.

"Short-term Effects of Catastrophic Accidents on Communities Surrounding the Sundesert Nuclear Installation", testimony before the California Energy Resources and Development Commission, December 3, 1976.

" Consequences of Catastrophic Accidents at Jamesport". Written testimony before the New York State Board on Electric Generation Siting and the Environment in the matter of Long Island Lighting Company (Jamesport Nuclear. Power Station, Units 1 and 2), May, 1977.

Miscellaneous:

" Comments on WASH-1400", Statement to the Subcommittee on Energy '

and the Environment, Oversight Hearings on Reactor Safety, June 11, 1976, Serial No. 94-61, Page 210. ,

" Upper Limit Calculations of Deaths from Nuclear Reactors",

Bull. Am. Phys. Soc. 21, III-(1976).

m

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.. 3 ku.LAn.D CutuGSPONDENCE ji LAW OFFICES oF, il ~

DANIEL M. PzLL i

~

fil l1 32 south BEAVER STREET g YORIC PENNSYLVANIA 174ot n 7 eds. east

% - s5 Norm MAIN SU EET Oc7

[ h a

DOVER. PENNSYLVANIA 1731s j

~

g *$g %, #/ October 1, 1980 q,,

m 9 ~

Robert zahler, Esquir '

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, DC 20035  ;

Re: Supplemental Answers to Licensee's Interrogatories to Intervenor, Anti-Nuclear Group Representing York, on Revision II of Licensee's Emergency Plan

Dear Bob:

As per your September 16, 1980, letter to me and as per the oral extension of time granted to ANGRY by Delissa Ridgeway, I herewith submit ANGRY's Supplemental Answers as follows:

(1) In supplementing our Answer to Interrogatory No. 4 (b) ,

ANGRY, relies upon 10 C.F.R. part 50 as amended in the Federal Register, volume 45, No. 162, Tuesday, August 19, 1980, at Page 55411, IV. Content of Emergency Plans, which states: "In addition, the emergency response plan submitted by an applicant  ;

. for nuclear power reactor operating license shall contain infor- l mation needed to demonstrate compliance with the standards described in Section 50.47 (b) , ... "

The quoted section is followed by a footnote No. 4 which incorporates the provisions of NUREG-0654; FEMA-REP-1, which in turn provides at Page 55 J 11 for protecting the public and by inference, their animals, from cont ami nation. Also NUREG-0654 at Page 60, Section M , requires the operator to develop general plans and procedures for recovery and describes the means by which decisions to relax protective measures are reached. This is contained in M-1, 2, 3 and 4. By implication, measures must be taken to protect livestock and other property of residents within the applicable emergency protection zone.

(2) In answer to Interrogatory No. 5-C, ANGRY supplements its Answers as follows:

(a) Letter to Mr. Herbein from Rescue Hose Company No. 3 and marked June 3, 1980, fails to describe legislation under which Rescue Hose Company No. 3 is operating, and fails to set forth mutually e

i . . 3 Robert zahler, Esquire ,

October 1, 1980 l .

, ( . . .. .

acceptable criteria for implenentation of its l, plan. The letter further fails to specify

exactly what actions will be taken by what men and

, , equipment and in what sequence. . -

4

. '(b) Undated letter fromF Union Hose , Company No.1 to

! Mr. Herbein, same objections aaf(a) above.

(c) Letter dated May 15; 198.0% from Londonderry Fire Company No. 1, same objections as (a) above.

l t

(d) Undated letter from Bainbridge Fire Company to

{ Mr. Herbein, same objections as (a) above.

(e) Letter dated April 23, 1980, from Borough of Middletown Police Department to Mr. Dennis i Mcciousky, totally fails to indicate exactly what j the police would do in the event of an emergency i and how many people they would commit to what i assignments. Also with respect to this item, the 4 same objections as contained in (a) above.

J (f) Letter dated May 28, 1980, from Thomas Je:usky i to John Herbein fails to set'forth what statutes j under which Bureau of Radiation Protection is j

operating and fails to set forth mutually acceptable criteria for implementation of the .

j BORP plan.

} - (g) Letter dated May 22, 1980, consisting of two pages from Daniel F. Dunn to Mr. Herbein on behalf of I the Pennsylvania State Police is particularly

. interesting in that it contains the following j statement: "Rather than commit ourselves to any

specific use of personnel or equipment at this

.i time, I merely wish to say that we would make every l effort to cooperate with you. We, of course, must

preserve the right to set our own priorities as far i as deployment of our personnel and equipment."

j This letter demonstrates, precisely the failure to 3

comply with NUREG-0654 to set.forth mutually acceptable criteria for implementation of all of the emergency plans and also demonstrates the fact that the licensee cannot, assure the public that the Pennsylvania State Police will act in a coordinated fashion with it or with any other Commonwealth department or agency in the event of a nuclear incident at Three-Mile Island.

J t

Robert Zahler, Esquire -

October 1, 1980 (h) Letter dated May 28, 1980, from Daniel F. Dunn, Commissioner of the Pennsylvania State Police to Mr. Herbein. The supplementation contained in

, this letter to the letter of Commissioner Dunn of May 22, 1980, contains nothing to satisfy the

. requirements as set forth above of NUREG-0654; and further merely states that helicopters will be used to warn motorists during an emergency. It again reiterates that the Pennsylvania State Police reserve their right to set their own priorities as far as deployment of personnel and equipment in the event of an emergency. This again demonstrates the inability of the licensee to demonstrate that the emergency plan of the licensee is coordinated with~

any Commonwealth or other agency.

(i) Letter dated May 22, 1980, from R. W. Miller,

. Captain, U. S. Cnast Guard, to Mr. Herbein, is completely deficient in setting forth exactly what the Coast Guard would do in the event of an )

emergency, what resources would be supplied, when j those resources would be supplied, and it is  :

completely devoid of any coordination with any l Commonwealth or Federal agency. It fails to state l under what statute or statutes the Coast Guard -

would be operating, and it fails to set forth

. mutually acceptable criteria for implementation,of its plan.

(j) Letter dated May 21, 1980, from Leroy F. A. Bailey, Jr., Second Lieutenant, Ordinance C, Commanding, Department of the Army to John Herbein. This letter completely falls to set forth the statute under which the Department of Army would be operating, fails to set forth what criteria would be involved in its being activated for bomb disposal, exactly how many personnel would be supplied; and in fact, contains a disclaimer that the U. S. Armey or its personnel are responsible for destruction of property during rendering safe procedures. There is no statement as to any coordination with any Commonwealth agency or Federal agency.

(k) Letter dated May 20, 1980, from Ray E. Byers, to John Herbein is completely deficient in that in the critical area of air control over Three-Mile Island and in the surrounding area there is no specific action format set forth to control said

l -

t. .

e l Robert Zahlerk Esquire . Octo'bar 1, 1980 h ~

l air traffic, nor any format set forth on coordination of the various state, Federal and local aircraft which would be in the area.

(1) Letter dated April 25, 1980, from J. G. Robbins

, to Mr. Herbein, no objection to this letter.

~

(a) Letter dated January 4, 1980, from Robert Priess to Mr Herbein, is not objectionable insofar as it merely sets forth DOE's response,but the letter clearly places responsibility back into the hands of the licensee for providing protection to the public health and safety. To that extent, it is objectionable since the rest of the letters which the licensee has attached to its EP, Revision II are inadequate as set forth above.

(n) Letter dated January 28, 1980, from Boyce H. Grier to Mr. Herbein is not objectionable, but it makes clear that the NRC's role is primarily investi-gative rather than being actively involved in supplying support services during an emergency.

(o)*

Letter from C. E. Goodall~to Mr. Herbein dated

, December 28, 1979, no objection. . .,

(p) Letter from Dr. Newman dated December 29, 1979,.

no objection.

~

(q)

Letter from Dr. William Albright, III, M.D.,

, dated December 24, 1979, no objection.

(r) Letter of algreement, Hershey Medical Center cannor be objected to since no copy of this has been provided.

(s) Letter dated November 2, 1979, from Michael S.

• D' Aries to Mr. Herbein does not set forth how many helicopters or airplan'es will be made available nor does it set forth exactly what duties these resources and personnel will pursue.

(t) Letter dated December 3, 1979, from Sydney W.

Porter, Jr. to Mr. Herbein, no objection to this letter. However, it is not admitted in any manner that the provisions set forth in this letter are adequate to meet the requirements of NUREG-0654, Table B-1, as set forth on Pages 31 and 32 of said nuclear guidance.

~[

1 j Robert zahler, Esquire October 1, 1980 j l i

) (3) ANGRY supplements its Answers to Interrogatory No.

j 25 (b) as follows: NUREG-0654, Section L-1, requires that all organizations shall describe arrangements for local and back-up hospital and medical services and the capability for evaluation 3

j of radiation exposure and update, including assurance that

! persons providing these services are adequately prepared to

! handle contaminated individuals. No'where in Annex N to the York l County Plan is there any explanation what medical personnel will be provided for de-contemination services, what resources will be made available from the hospitals; and nowhere is any training l

program for these individuals described. NUREG-0654, Section L l

(4) provides that each organization shall describe arrangements for transporting victims of radiological accidents to medical support facilities. Annex N fails to meet this requirement, since it does not provide any specific description of same.

Annex N primarily provides a means of spraying down vehicles.at 1 check points on evacuation routes, and giving showers and new  :

clothing to people at mase care centers following evacuation. l There is nothing specific provided as to training personnel with regard to de-contamination procedures or with regard to providing l medical services or emergency transport to hospitals.

(4) ANGRY stands on its present Answer to Interrogatory l

No. 31, and there are no other provisions known to ANGRY which

exist in Appendix 3, Annex A, under Health-Medical Operations which are not coordinated with the Department of Health plan for distribution of SSKI beyond those contained in its present Answer j to licensee's Interrogatory No. 31. ,

I j ,

I belive this, for the present, meets the requirements of '

1 our agreement.

! Very truly yours, l

l rr el M. Pell

.W l

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l DMP:ksm j l l l '

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" l CERTIFICATION OF SERVICE 1

I, Danici M. Poll, Esquira, certify that I served a true and accurate copy of the foregoing documenti,on the following individuals by placing a copy of same in the U. S.

Mails, postage prepaid, on the y , day of Oc ph ,

1980, and addressed as follows:

Ivan W. Smith, Esquire Karin W. Carter, Esquire Chai mma Assistant Attorney General Atomic Safety and 505 Executive House Licensing Board Panel P. O. Box 2357 U. S. Nuclear Regulatory Commission ,Harrisburg, PA 17120 Washington, DC 20555 Walter W. Cohen, Esquire Dr. Walter H. Jordan Consumer ~ Advocate Atomic Safety and Licensing Office of Consumer Advocate Board Panel 14th Floor 881 West Outer Drive Strawberry Square Oak Ridge, TN 37330 Harrisburg, PA 17127 Dr. Linda W. Little Jordan D. Cunningham, Esquire Atomic Safety and Licensing Attorney for Newberry Township Board Panel T.M.I. Steering Committee 5000. Hermitage Drive 2320 North Second Street Raleigh, NC 27612 Harrisburg', PA 17110 James R. Tourtellotte, Esquire Theodore A. Adler, Esquire Office of the Executive Widoff, Reager, Selkowitz '

Legal Director and Adler U. S. Nuclear Regulatory Commission P. O. Box 1547 Washington, DC 20555 Harrisburg, PA 17105 l

. Docketing and Service Section Ellyn R. Weiss, Esquire Office of the Secretary Attorney for the Union of U. S. Nuclear Regulatory Commission Concerned Scientists Washington, DC 20555 Harmon & Weiss 1725 Eye Street, N.W.

George F. Trowbridge, Esquire Suite 506 l

'Shaw, Pittman, Potts & Trowbridge Washington, DC 20006 1800 M Street, N.W. M e Washington, DC 2003 Mr. Steven C. Sholly J 304 South Market Street John A. Levin, Esq echanicsburg, PA 17055 Assistant Counsel O Pennsylvania Public - Oc7'%

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-Mr. Robert Q. Pollard UtilityCommissiont A 2 hesapeake Energy Alliance P. O. Box 3265 // 609 Montpelier Street Harrisburg, PA 171 Daltimore, MD 21218 l Mr. Chauncey Kepford Mt. Marvin I. Lewis Ms. Judith H. Johnsrud 6504 Bradford Terrace Environme~ntal Coalition Philadelphia, PA 19149 On Nuclear Power 433 Orlando Avenue Ms. Mar; orie M. Aamodt State College, PA 16801 R. D. 5 Coatesville, PA 19320 -

m Daniel M. Pell, Esquire

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