ML20008E348
| ML20008E348 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/30/1980 |
| From: | May K AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20008E337 | List: |
| References | |
| RTR-NUREG-0683, RTR-NUREG-683 NUDOCS 8010240609 | |
| Download: ML20008E348 (6) | |
Text
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be land Ad Hoc Committee on Three Mile Islar
Contact:
John Kabler (301) 235-8808 or 235-8810
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STATEMENT OF THE MARYLAND AD HOC COMMITTEE ON THREE MILE ISLAND AND CLEAN WATER ACTION PROJECT TO THE NUCLEAR REGULATORY COMMISSION AND THE MARYLAND DEPARTMENT OF NATURAL RESOURCES September 30, 1980 The accident at Three Mile Island left more than a million pallons of radioactive water at the plant, including 600,000 gal-fons of highly radioactive water still in the containment buildina.
Metropolitan Edison has said that its preferred plan for disposing of this water is to treat it to remove most of the radioactivitv and then discharge the water into the Susauehanna River, source of drinking water for several communities dosnstream (and a backuo source-for Baltimore) and potential polluter of the priceless Chesapeake Rav, an enclosed and very fragile ecosystem.
A year and a half after the accident the radioactive decontaminat-lon of the damaged reactor continues to threaten the health and safety of Maryland citizens while the government's handling of decontamination proceduras has seriously eroded the public trust and confidence in s' tate and federal regulatory agencies and governmental safeeuards.
The Nuclear Regulatory Commission (NRC) has consistent 1v and ef-
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fectively precluded the public from adequate carticioation in the anal-ysis,'and subsequent decision making process, concernine the radio-active clean up at TMI. Examples include the ourchase and installation of Epicor 11, time constraints imposed in the decision making for the purging of Krypton-85 and NRC's failure to follow uo on its oromise to form a citizen advisory committee with funding for independent
- sci-entific review.
On August 14, 1980, the NRC released its draft Programmatic En-vironmental Impcot Statement (D-PEIS) concerning decontamination and disposal of radioactive wastes at TMI. Under oressure from citizen's groups and Pennsylvania Governor Thornburgh, the NRC has extended.the comment period on the D-PEIS until November 20, 1980.
Although we appreciate the NRC's decision to extend the comment period, there are basic flaws in the D-PEIS which cannot be orocerly addressed through the public' comment process and must, instead, be re-l A
solved throuah further studies by the NRC, with subsecuent oublic re-view and comment.
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Independent scientists queri.ed by the Ad Hoc Conraittee have criticized the D-PEIS on numerous points. Examoles include ouest-ions raised about incorrect mixing projections, inaccurate and mi'sleading Susquehanna River flow rate figures and inadeouate and confusing data concerning quantities of radioactivity involved in various waste products. Other problems in the draft statement, according to Union of Concerned Scientists reoresentative Robert Pollard and others, bring into question the validity of the en-tire document.
So:ne basic flaws in the PEIS which might require separate environmental impact statements:
1.
The problem of how and where to disoose of the vastes resulting from the accident and cleanuo process is inadeouatelv considered.
There is no as-surance that any waste site will accept the low-1cvel vaste in the a:nount postulated by the NRC staff and ultimate disposal of high-level waste re-nains an unresolved question.
2.
The NRC staff dismisses the question of whether TMI-2 vill be deco = mis-sioned or prepared for restart by stating that it is not within the scope of the PEIS.
In reality the nethods of cleanuo are verv deoendent on the decision to restart or to decommission the unit.
Certain processes could severely damage the equipment, making the final dispositica question es-sential in selecting the proper methods to be used.
Thus the question of restart or deco =miisioning of the plant must be considered in depth within the PEIS.
3.
Tn'ere is a total lack of cost esti=ates in this evaluation chase o[ the
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PEIS.
The NRC staff has promised that the cost factors will be provided in the final PEIS (af ter the period for public coc:aent has passed).
The lack of 'opportun!ty for public cot.nent on economic aspects of the cleanup provides an example of how the public is being excluded from the decision making process.
In view of the precarious financial condition of Metro-politan Edison, the NRC's assertions that costs are not a limiting f actor can hardly be viewed as realistic.
4.
In the PEIS the NRC cakes the assu=otion that cesium and strontium from the olanned release of crocessed water (which will conta #nate Chesaceake Bav seafood as far south as the Potomac river) will not effect the market-ability of the seafood.
A separate EIS that includes market research data on radioactivity in Chesapeake Bay seafood must be perior sed prior to making any determinations as to the effe, cts of radioactive conta=ination of Bay seafood on the seafood industry.
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The controversy that exists today is not sinoly over the D-PEIS and the proposed methods ~of radioactive decontamination at TMI, It also involves serious doubt, if not susoicion, about the government's real intentions in handling the oroblem. When oublic officials or citizen organizations reauest better avenues for citizen involvement in the decontamination decision-makine, the NRC public relations staff responds with self serving ex-planations of NRC policy and procedures and, typically, no response at all to the specific request.
NRC's method of dealing with the decontamination process has been both inappropriate and irresponsible. Instead of dealing dir-ectly and effectively with the cleanuo, NRC has oreferred to let things drift until a crisis occurs and then, as in the case of Epicor ll, justify subsequent ill-considered actions by blaming the crisis.
NRC officials appeared to be responding to the credibility crisis they had created by publicly agreeing.to acooint a ' citizen advisory panel with funding for independent scientific review in Nbrch, 1980. Their refusal to follow up on this promise has further' alienated a skeptical public Whereas it may be easier to make a decision with incomolete information, it will be more difficult to live with the con-sequences. In our view, it is indefensible that NRC continuously avoids the scientific and public inout that, if-Drocerly con-sidered,- could lead to a safe, effective and politically acceot-able cleanup at TMI.
More seriously, NRC now proposes to make a complete mockery of the NEPA process by refusing to hold public hearings o,n the draft PEIS. CEQ regulations call for such hearings when there is
" substantial environmental controversy concerning the orocosed action or substantial interest in holding the hearing."
Nhat could-be more controversial than the radioactive de-contamination of the nation's most serious nuclear accident, lo-cated at the headwaters of the world's most valuable, and ecolog-ically sensitive, estuarine system -- the Chesaceake Bay.
NRC must work to restore the public's trust and confidence in their capability and objectivity in determining the best course of action in regard to the cleanuo at TMI. Failure to do so will result in increasingly effectiv'- airizen action in opposition to NRC plans.
In order to resolve $% e r,is of credibility that NRC has 7
created, and to restore the cubiic trust and confidence, NRC ehould agree to hold well publicized public hearings in Baltimore I
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and Harri sburg or Middletown, and to re-initiate its stalled agreement to appoint a citizen advisory committee with funding for independent scientific review.
No new actions concerning the decontamination of TMI should occur until NRC has redesigned their PEIS in re-sponse to the public's criticism and the findings of an independent scientific panel.
Finally, no radioactive water from TMI-2 should be
- released to the Susquehanna, until scientific controversy concerning the safety of such action has been resolved, until NRC and Metropolitan Edison can prove that such re-leases will not affect the marketability of Chesapeake Bay seafood and until citizens living downstream from the damaged reactor agree to such releases.
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First of all, I urge the ::uclee.r Eccu12 tory Gormissica to hold public herrings, both in Maryland and Pennsylvania, on the ?IIS. It seems to ce that the criteria in the Council of Environmental Quality regulatin s, 40 CFR 1500.7, the i portance of the proposcls, complexity of the issues, deyree of interect in the proposals and the entent of public -
involvenent alrec.dy achieved, would indics.te that public hearings should be held.
I'd like to cocaent on the prospect of Metropolitan Edison running thia,cleerup.
As I unders cnd it, the :iEC will not choose the method of the cleanup but only has t veto over the method.iet Ed chocses.
We Marylanders who rey drink the wrter
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possic,-y re_,eesec Iro= Tn.r e e r..,, e 2
thct lives in it, need assurances thr the NRC will recuire
- e; 2d to use the sefest method for the cleanup.
!:etropolitan Edison is in bed shepc fincncielly.
Tro veeks ago, it leif off a large num'rer of scrkers, including 500 vorhing on the clee.nup. - The : EC should devise plans tc continue the cicanup shou 3 d Xet Il 50 benkrupt and should device plent to deterni: e if {et Zi is seriaping on the cleanup to satc :.Oney in a nanner yhich conl-je;perdice the hee.ith nnd cafety of our' citisens.
The cleanup i' a unique and difficult technical probles.
cocs no h.ve c :epute,on for technical excellence.
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..s; 22 2 : rdey's ?rltincr
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I.C study fo.:nd 37 ccri ur lcficiencies
-t t;e T::I-1 c:::rci roca eni f.0 lese
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This Iceves the observer 5:ith the fear thet Met Ed vill not do ihe ~ encellent job required to nahe the cleanup safe.
The !!RC must develop plans to monitor the cleanup o see
- is being done correctly.
Finc11y, the 1:EC nust realise that the public does not have greet faith in it and Met Id.
There aust 'ce some assurance for the public that this process is being done correctly.
There must be a truly indepcndent, knowlel';eable, well financed bciy to monitor the cleanup so that ve ::crylrnders who drink Susc.uehanne River veter c - not heving their he lth jecperdized and -:c :iar landers who nahe their living from t'.e Chesapeake c
3ay ere not having their livelihoo.s jecpardired.
Eenneth IIcy O
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