ML20052A231
| ML20052A231 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1982 |
| From: | Minnich J NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2 |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20052A219 | List: |
| References | |
| NUDOCS 8204280029 | |
| Download: ML20052A231 (3) | |
Text
f THE ADVISOhDECONT AMIN A 4 (UN Ut-ATTACHMENT 3 ri i THREE MILE ISLAND UNIT 2 o,,*
s March 17, 1982 Chair =an Nun =io Palladino Nuclear Regulatory Co==ission 1717 H Street, N.W.-
lith Floor Washington, D.C.
20006
Dear Chair =an Palladino:
The Advisory Cv ittee on the Deconta=ination of Three Mile Island Unit 2 sub=its the following report, our second to date, on our efforts and the findings that we have =ade based on our investigations.
We e=phasize at the outset our =ost i=portant and =ost troubling conclusions:
1.
The crippled reactor at Three Mile Island Unit 2 constitutes a threat to the health and' safety of the public until it is deconta=inated.
The rate of progress
,- on the clean-up at this ti=e is inadequate to protect the public health and safety.
2.
In the absence of an expeditious clean-up, Unit 2 is becoming a g facto, long-ter= storage facility for high-level radioactive vastes which also constitutes a threat to the public health and safety.
Our conclusion that Unit 2 constitutes a threat to the public health and safet'y derives pri=arily fro = the fact that little is known about conditions inside the reactor, and no thorough evaluation has-been perfor=ed to deter =ine whether and how long conditions vill re=ain stable.
Although the reactor facil ity was presu= ably designed to withstand an accident as severe as this one,
~
we know of no basis for believing that it was intended to re=ain in a da= aged state -for many years after the accident occurred.
You vill understand that the public concerns in this regard are heightened by the recent revelation of reactor vessel e= brittle =ent and tube corrosion problems.
If these conditicl are arising in reactors that have not undergone the stresses that THI-2 has faced during and since th'e accident, we fear that serious deficiencies will develop at DCI-2.
For exa=ple, there have been technical concerns expressed about the proper functioning and long-ter= reliability of the instru=ents within the containment building.
The ability to re=ove this threat to the public health and safety depends upon a co==it=ent of sufficient funds and other resources. We have reviewed and analyzed all of the funding proposals in detail, including proposed legislation.
We have spent =any hours obtaining infor=ation fro = Governor Thornb'urgh's office, Congress =an Allen Ertel, U.S. Senate staff personnel, the utility industry, and citicens of South Central Pennsylvania.
The transcr:
of our hearings contain the supporting docu=entation and the content of =any presentations.
82 04 2 8 00M
En9EML@OJ March 28, 1982, vill = ark the third anniversary of the TMI-2 accident,
)
yet there has been insufficient progress in cleaning up the facility.
Although GPU sub=itted a budget on October 5,1981, calling for a six-year clean-up schedule, GPU's Robert Arnold has stated that the schedule cannot be =ec due to the lack of funding, and that citan-up at the present rate =ay take 20 years or longer.
GPU is currently spending approximately.
SS =illion =enthly on IMI-2, which represents a significant reduction in clean-up funding.
Should this rate of expenditure be further reduced, GPU can only undertake a housekeeping effort, with no progress in. the clean-up.
None of the funding pr'oposals that have surfaced thus far has provided any significant =oney for the clean-up, and none provides a real co=mitment,for:
sufficient funding in the future.
DOE funding is restricted to R&D activities
'and offsite disposal of SDS and EPICORE II radioactive resins.
The Edison Electric Institute proposal has been called a " dead issue" by an Institute spokeswo=an, and the Pennsylvasia Public Utility Co=nission proposal cannot,
provide the necessary support because it depends upon the restart of IMI-1,'
which is months, if not years away given the growing inventory of serious deficiencies being discovered in that reactor.
Furthermore, proposals tied to TMI-1 restart have two unfortunate and potentially dangerous consequence First, they sanction an open-ended and indefinite delay of serious clean-up efforts.
Second, they result in presruris to restart Unit 1 'that may be inconsistent with safety considerations.
At this point, there si= ply is no significant financial co-4 =ent to fund the clean-up.
t This cw__.ittee. adopted the following position on Nove=ber 16, 1981, concerning M -1:
"The restart of the Unit I reactor should be based solely on the basis of technological and safety considerations, and not economic considerations with respect to the clean-up of Unit 2."
Based on the infor=ation available today, it is clear that $fI-2 has become a de facto long-term high-level waste storage facility.
Should funding levels be7urther reduced, storage can be expected to last for approxi=ately 20 years.
As.a result, GPU it in effect operating DfI-2 as a long-term vaste storage facility.
However, TMI-2 is not a licensed high level vaste storage facility; it' does not ce= ply with the NRC's proposed criteria for the siting, design, or construction of such a facility; and the Cc
- ssion has not instituted licensing proceedings to detersine whether TMI-2 co= plies with standards to assure the safety of vaste storage and disposal facilities.
This comittee, and the public, endorse the NRC objectives in NUREG-0698 Rev 1, page 1-1.
In conclusion, given the long-term serious hazards posed by TMI-2, the lack of funding from any source to under,take a serious.and expeditious clean-up effort, and the ~. lack of an effective co==it=ent on the part of the NRC, we are forced to conclude that the failure to =ake sufficient and timely progress toward deconta=ination constitute threats to the public health and safety.
l The Co==ission's action, or lack of action, in per=itting this condition i:o exist and to continue constitutes a violation of the fundamental requirement.
of the Ato=ic Energy Act prcrtection of the public health and safety.
We believe the Co==ission has both a = oral and a legal duty to act i=nediately to insure that the clean-up of TMI-2 proceeds expeditiously in order to eli=inate this threat to the public.
As a final note, for your infor=ation,.I am e6 closing a copy of a su==ary of tha various TMI-2 clean-up proposnis.
Tnis su==apy doss not include those submitted to us by individuals.
Sincerely yours, O
q,.
hn E. Minnich
. airman, Advisory Panel for the' Decodtamination of Three Mile Island, Unit 2
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