ML20052G379
| ML20052G379 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/12/1982 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Minnich J NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2 |
| References | |
| NUDOCS 8205180311 | |
| Download: ML20052G379 (3) | |
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'o, UNITED STATES U7h.D
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May 12, 1982 CHAl N
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DOCKET NUMBER 5 PROD. & UTIL FAC. 5,, _,
Mr. John E. Minnich Chairman, Dauphin County Commission P.
O. Box 1295 Harrisburg, Pennsylvania 17108
Dear Mr. Minnich:
The Commission is grateful for the efforts of the Advisory Panel for the Decontamination of Three Mile Island Unit 2 in providing recommendations both in your March 17, 1982 letter and at our meeting on March 23, 1982.
We found the Panel's presentation at our recent meeting both informative and a sound basis for believing that the Panel's worthwhile contribution to this Commission should continue.
I trust you will find our specific comments on each of your recommendations (enclosure) responsive to your suggestions.
Most importantly the Commission is in agreement with the Panel's assessment of the need to accelerate the pace of the cleanup.
Delays in completing the cleanup inevitably increase the potential for unexpected threats to public and worker health and safety as well as the environment.
In order to spur resolution of the cleanup's financial restrictions, the Commission remains dedicated to emphasizing its public health and safety concerns about lingering conditions at TMI.
Again, thank you for your continuing assistance to this Commission.
I will look forward to hearing from you in the near future.
Sincerely,
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Nunzio J.
Palladino
Enclosure:
Comments to Recommendations
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i ADVISORY PANEL RECOMMENDATION #1: 'The Commission should urge the White House to assign a liaison who would be responsible for providing high-level attention to the resolution of TMI-2 cleanup problems.
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The Commission agrees that White House attention could prove We shall to be an effective catalyst for cleanup action.
continue to use our various channels to the Administration to encourage its consideration of ways to expedite cleanup, including the Panel's suggestion of a formal liaison.
ADVISORY PANEL RECOMMENDATION #2:
The Commission should clarify the Edison Electric Institute's position regarding a possible
$192 million TMI-2 funding commitment.
The Board of the Edison Electric Institute has recommended to its members that the electric utility industry contribute a total of The recommenda-
$192 million over six years to the TMI-2 cleanup.
is not binding and will require subsequent action tion, however, Our staff has contacted EEI, has reported to_the to implement.
Panel on the current status of the EEI Board's recommendation and will continue to keep the Panel advised on this matter.
ADVISORY PANEL RECOMMENDATION #3:
The Commission should make a stronger effort to stress the serious nature of conditions at TMI-2 in order to encourage more federal resources to finance the i
cleanup.
The Commission agrees with the Panel's assessment of the serious As noted in nature of lingering conditions at the TMI-2 site.
1982 meeting, the Commission is currently involved
.our March 23, in an effort to emphasize, even more strongly than it has in the the need for a more aggressive Federal role in assuring
- past, A letter, recently sent to Congressional cleanup resources.
leaders setting out our position is attached for your information.
We intend to continue this type of effort until all cleanup impediments have been removed.
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l ADVISORY PANEL RECOMMENDATION #4':
The Commission should decide if the Panel should continue, and'if so, provide guidance on i
future Panel topics.
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. The Commission is very interested in continuing to receive assistance from its Advisory Panel.
The Panel's recommenda-tions to date have proven to be useful and constructive.
We hope to continue to draw upon information gathered from the Panel's unique perspective as major cleanup issues arise.
Specifically we would ask the Panel to identify and focus on issues relevant to the major steps necessary to complete the cleanup.
While this covers a broad area, we view your previous efforts on issues including water processing, waste management and concern over the cleanup's slow pace as examples of topics where Panel involvement has been effective.
The Commission remains interested in how cleanup issues affect and are viewed by the local community.
We hope that the Panel will continue to provide a forum for public discussion of cleanup issues.
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One specific issue which we request the Panel address is what should be done with the water after final treatment.
The Commission has several studies under way and requests the Panel provide advice at appropriate times on these efforts as well as make recommendations after their completion.
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y March 26, 1982 C>
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'The Honorable Morris K. Udall, Chai'rman Subcommitte on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D. C.
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Dear Mr. Chairman:
We have been informed that the Subcommittee on Energy and the Environment, will shortly hold hearings on financial problems af,fecting the cleanup of the Three Mile Island,We wou Unit 2 (TMI-2) nuclear power plantc our views on this issue with you.
It i's now three years since the TMI-2 accident and the financial problems, if anything, appear f urther f rom solu-tion than they did last October, when we provided the enclosed testimony on nuclear accident cleanup insuranceMy fellow legislation (S-1606) introduced by Senator Heinz. C The poten-that the cleanup of TMI-2 must be accelerated.tial f capability plus the increasing concern for an unexpected release of radioactive material argue that, equipment last resort, A more detailed explanation of our more aggressive role.
concerns is encicsed.
Our purpose in pointing this out to you is to ask that you (1) establishing some form of funding that will guarantee a rap'id cleanup; and (2) DOE plans to take posses-support:
sion and dispos,e of the entire damaged reactor core as soon as technically feasible.
We believe greater Federal participation in assuring finan-cial viability is a prerequisite to an acceptably rap program.
still have to be done and the entire job the cleanup willand associated costs may f all upon the Federal G Restart That possibility has recently become more likely. reactor at Th of the undamaged Unit iin the owner's p1an to finance the cleanup
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principal element Serious new technical problems, however,.now indicate a 6-12 month or longer delay before Unit.1 could be of Unit 2.
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This setback add's a in a position to generate any' revenue.
new degree of, urgency to the increased Federal involvement we are recommending for clean up of TMI-2.
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The' honorable Morris K. Udall 2 We s'upport DOE's decision to accept and ma'nage all the high-level waste, including taking possession of the entire core of the damaged reactor for research and eventual disposal.
For our part; we in the Nuclear Regulatory Commission are committed to a timely as well as thorough execution of 'our
. responsibility to regu. late the cleanup of THI-2 in the interests of public health and safety.
Commissioner Gil,insky adds that he agrees with the Commis-sion's statement regarding the pressing need to assure adequate financing for a prompt cleanup of TMI-2.
- However, he thinks the Commission should limit its advice to health and safety questions and leave it to the President and the Congress to strike.a balance among the competing equities of the licensee, the affected States, and the Federal Govern-ment.
I would be pleased to meet with you to discuss this matter further.
Sincerely, g
h Hunzio s P a?1 a di no
Enclosures:
As stated cc:
The Honorable Manuel Lujan e
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ENCLO.SURE The THI-2 reactor and related f acilities have remained in a condition for which they were not designed f or three years.
Only limited prog.ress has-been made in the cleanup,1/ and uncertaihties about long-term plant capabilities persist.
Even though TMI-2 is presently in a safe. shutdown condition and public health, safety and the environment are being adequately protected, this situation is not certain to remain stabl e.
If TMI-2 is allowed to remain in its present condition over the long term, accidents involving radiation leakage and
' subsequent exposure to workers and'the public have a greater The potential f or these adverse probability for. occurrence.
events 2/, although small now, will increase with time as Such deterioration will be TMI-2 equipment deteriorates.
the inevitable result of maintenance limitations in areas of
- he THI-2 facility shere high radiation fields persist.
Since the radioactive fission products and the damaged fuel presently contained in the reactor and the containment building will remain radioactive for an extremely long time, potential leakage of radioactive materials to the environ-
. ment will continue to pose a serious threat until the' fuel is removed, the f acilities are decontaminated and all radioactive wastes are disposed of safely.
In combination with mechanical deterioration over time, natural phenomena (e.g., unexpectedly severe weather) and other adverse scenarios (e.g., fire) pose a potential threat to continued successful containment of TMI-2 contamination Although the likelihood of severe weath'er and stored waste.
or a fire resulting in a radiation release to the environ-is small, the possibility does exist, and the proba-ment Only bility f or such events occurring increases with time.
the completion of all leanup and radioactive. waste disposal activities at the THI,( site will eliminate all possibility of ina'dvertent radioactive releases.
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i Footnotes 1/
March 1982 Status of TMI-2 C.leanue:
Within several weeks of tne accicent, Ine cecontamina' tion of contami-
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nated areas in the auxfliary and fuel handling
' bu.ildings was initiated and approximately 70 percent of the. area has been. decontaminated.
However, some of the more difficult areas to clean up were bypassed.
Other significant cleanup accomplishments include the purging of th,e co.ntaminated atmosphere from the reactor building, the processing of accident-related water which collected in the auxiliary and reactor buildings, and the shipment of some of the radioactive solid waste generated as a result of clean ~up activities.
Approxi-mately 750,000- gallons of ~ mode ately contaminated water from the auxiliary building and 600,000 gallons of highly contaminated ~ water from the reactor building have been processed.
The reactor building has been purged of the 45,000 curie inventory of Kr-85 which collected during the accident.
Lastly, 22 low-level waste resin liners generated as a result of accident water processing, and large quantities of other low radiation level waste, have been shipped to a
.commer.cial burial site for disposal;
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While the cleanup completed to date represents a degree of progress toward total plant cleanup,'a great deal of difficult work remains to be done.
About 5% of the highly contaminated water remains in the reactor building (approximately 30,000 gallons) and 90,000 gallons in the reactor coolant system require proces-sing.
The balance of the most contaminated floors and surfaces in the auxiliary building remain to be decon-taminated.
Although a large-scale. experiment for gross decontamination is in progress in portions of the reactor building, the entire reactor building will have to undergo detailed decontamination.
Th.e most diffi-cult task ahead, defueling of the damaged core, is not anticipated to be completed for at least several years.
Following defueling, the reactor coolant system sur-f aces will require ' decontamination.
The processed accident-generated water will require ultimate dispo.
sition and the higher. level solid waste resulting f rom l water processing and other decontamination activities will require of f site sh'ipment to a commercial or Federal facility for disposal or rese' arch, as appro-
'priate.
Finally, the damaged f uel. assemblies and -
reactor vessel internals will require offsite disposition.
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6 Potential Health and Safety Events:
Specifically, 2/
potentially a'cVerse puolic nealtn and safety events
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f all in two general categories:
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Accidents resulting in ' worker exposures -- 1eakage (a) from valves, pipes or tanks which does not reach the environment but which does expose workers either accidentally or while attending to the problem.
Accidents resulting in radioactive releases to the (b) envir6nmsnt -- leakage resulting f rom a breach of the reactor building or processed water storage tank integrity and airborne releases generated by a mishap inside the plant and not removed by the plant's filtration system.
There is also potential f or releases from the interim storage of
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radioactive waste materials external to the plant buildings.
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usu ihuM1 % hh v, ALuiv:hi CLd4hd? ihSdRIEE U. S. SENATE COMMITTEE ON ENERGY MiD ETUPAL RESOURCES SUBCOMMITTEE ON NUCLEAR P.EGULATION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORXS Mr. Chairman, I am pleased to be invited to testify today on the important legislation (S.160'6) i'ntrcduced by Senator Heinz.
I should begin by saying that the Comission's expertise does not lie in the area of utility financing and ratemaki$g and that the tcmmiss~ ion will therefore not ccament on the details' of the financial measures proposed.
Our principal concern is the protection of the public's health and safety.
We support taking prompt steps to overcome the financial problems which are hindering the clean-up of iMI-2 in order to ensure that the public health and safety is not threatened.
As we have all become aware, one of the rajor byproducts of. the March 28, 1979 accident at Three Mile Island has been the inability of the 1NI licensees to pro /ide the finances to reet the large costs estimated to be necessary to safely decontaminate the TMI-2 reactor.
The NRC is very concerned that a prompt resolution to this problem is required to eliminate a. potential threat to the health and safety of the pub 1'ic and the environ-ment.
The General Public Utilities Corporation and its operating subsidiaries -- Metropolitan Edison Company, Pennsylvania Electric Company, and Jersey Central Power and Light Ccapany -,have the. legal obligation to clean up the reactor site.
It has become increasingly obvibus that G?U does not have adequate financial resources to proceed expeditously
m h rate unless a larger source of funds is forthco,ing, either throug increases frcm its cust:mers or through assistan:e from outside sources, or a cccbination of both.
Clearly, the cleanup of TMI is an issue of national concern and Cong is the appropriate. forum to consider the conditions under which fun Although the Commission takes will be prcvided for the cleanup of TMI-2.
l no position on the specific methods of obtaining funds for TMI-2 c proposed in S.1606 and other legislation, we we1ccme the a li passed in the proposed legislation as a reasonable mechanism However, we would like to stress that remaining this continuing problem.
insurance funds are running out and that the proposed fund spe d
Section 6 of tne bill day not be established in sufficient time to You may thus wish to consider adequately' for near-term c'leanup costs.
interim steps to bridge any gap in time before a mechanism such provided in the bill is in place.
With respect to the broader issue addressed in the proposed le d
in the interests of promoting protection of public health and safe minimizing damages to life or property, the Ccomission supports bt tial requirement for on-site property damage insurance to provide source of funds that can be available in a short time to clean up As you may be aware, the Comission on August future reactor accidents.
18,1981 ' published in the federal Reaister.a proposed rul i
t of on-site require power reactor licensees to purchase the max mum amou Insurance property damage insurance available frcra private sources.
l currently available no'w totals $450 million, although the nuc ear.
insurance pools -- Amer can liuclear Insurers and Mutual Atomic ~nergy i
Reinsurance Pool and the electric utilities' own cutua.1 insurance organization, fluclear Nutual Limited -- are attempting to increase aggregate policy, limits to narrow the gap bhtween av'ailable insurance coverage and potential cleanup expens'e.
There is general optimism that about $1 billion can be made available by early next year for property insurance and cleanup through private insurance and utility payment of If this amount cannot be established -- perhaps retrospective premiums.
because of a reluctance of utilities to pledge he necessary retrospective t
premiums -- the Ccmmission would support a program of mandatory payment If necessary, the Commission would seek legislative changes of premiums.
It is not to mandate.the availability and purchase of such insurance.
certain that private sources of insurance will be available to cover cleanup costs cuch larger than those arising frca'the Three Mile Island Consequently, we see the legislation as a means of coqple-accident.
menting fiRC's proposed rulemaking to afford protection of public health Further', Federal and safety and minimize danger to life or property.
legislation may help to speed up the establishment of such a fund.
First, the requirement in We have several specific coments on S.1506.
Section 4(b) for shutdown of all operating reactors 180 days after enact-ment of the bill unless the licensees have paid the first insurance premium is almost certain to cause some shutdowns, in view of the time that would be needed af ter enactmentJo get the insurance scheme in place.
Until the~ system is established, licens'ebs and applicants will' be~ unable A similar problem to meet the requirements of the proposed legislation.
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would exist with respect to the requirement th51 the premium be paid before a new cperating license can be issued.
We would propose that the requirement for premium payments be keyed to some period following the date of formal publication by the Secretirt of Energy of the premium rates, as required by Section 5(a), rather than to the date of enactment of the bill.
Second, Section 7 should be expanded to authorize the Secretary of Energy to remove the core and to receive, process, and store those radioactive wastes, including the damaged fuel, from the TKi-2 cleanup that the NRC specifies as unsuitable for disposal in a commercial low level waste f acility.
Much can be learned about the safe handling and storage of material from nuclear reactors from an examination of the damaged core
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These are and also from processing ind solidification of the wastes.
' legitimate research and development tasks for the Department of Energy.
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Morec/er, if DOE and its contractors were to take responsibility for the.
core of the damaged reactor, one of the largest elements of technological uncertainty would be removed.
Thus, the other parties involved in funding the cleanup need not concentrate on this element..
We support the proposed legislation as a significant step in protecting public health and safety with respect to both cleaning up THI-2 and the.
broader issue of future accident cleanup for all licensed reactors.
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We note the following as complementary stocs to the legislati:n by involving those parties having a logical interes't in and benefit from TMI-2 cleanup:
The Electric Power Research Institute (EPRI) research and 1.
development support at TMI-2 can act as a channel for funds from utility 'and reactor manufacturers' who would gain valuable insight into the. effects of reactor accidents and the behavior of reactor ekuipment.
The recent recommendation of the Edison Electric Institute 2.
(EEI) in conjunction with Governor Thornburg's proposal that the electric utility industry provide about $190 million toward cleanup could provide an important increment in cleanup funding that should be encouraged.
While maintaining the basic independence of nuclear regulation mandated by Congress, the Commission intends to support both federal and state We view the conditions initiatives-to expedite, the cleanup of TMI-2.
Most disturbing persisting at that site since the accident as very serious.
is the uncertainty about the availability of resources 'ccmbined with the increasing potential for hazard to the public as time passes with little progress being made.
Irrespectde of the ultimate form that TMI-2 cleanup funding takes, the NRC is prepared to support expeditious actions consistent with ensuring 4
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y public h2alth and safety.
Currently, we maintain professional sitffs,
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located at both headquarters and the TMI site, who are dadicated :
The Ccmission wi,11 ensure quick reviews o' licens~ee cleanup proposals.
that this kind of liRC attention to TMI-2' cleanup efforts remains a hich priority in this agency throughout the cleanup.
This concludes our prepared testimony.
We will be glad to answer any questions you may have.
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THE ADVISORY PANEL FOR THE DECONTAMINATION OF
' E T') r!( 1 I
a THREE MILE ISLAND UNIT 2
=:; m a e March 17, 1982 Chairman Nunzio Palladino Nuclear Regulatory Co=ission 1717 F. Street, N.W.
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lith Floor Washington'; D.C.
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Dear Chairman Palladino:
The Advisory Co=ittee on the Decc taJ:ination of Three Mile Island 2 submits the following report, our second to date, on our Unit ef forts and the findings that we have made based on our investigations.
We emphasize at the outset our most important and most troubling conclusion 1.
The crippled reactor at Taree Mile Island Unit 2 constitutes a threat to the health and safety of the publi until it is decontaminated.
The rate of progress l
on tha. clean-up at this time is inadequate to protect the public health and safety.
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In the absence of an expeditious clean-up, Unit 2
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is becoming a de f acto,1:ng-term stotage f acility for high-level radioactive wastes which also constitutes a threat to the public health and safety.
Our conclusion that Unit 2 constitutes a threat to the public health and safety derives primarily from the fact that little is known about conditie inside the reactor, and no thorough evaluation has been performed to dete:
whether and how long conditions will remain stable.
Although the reactor ity was presumably designed to withstand an accident as severe as this one it was intended to re=ain in a dama we know of no basis for believing that state for many years af ter the accident occurred. 'fou will understand tha concerns in this regard are heightened by the recent revelatic the public of reactor vessel embrittlement and tube corrosion problems.
If these cor are arising in reactors that have :ot undergone the stresses that TMI-2 h4 faced during and since the accident, we fear that serious deficiencies wi:
develop at TMI-2.
For example, there have been technical concerns expres, about the proper functioning and 1:ng-term reliability of the instruments within the containment building.
The ability to remove this threat
- o. the public health and safety depends of suffit'ient fu:ds and other resources. We have revie upon a cor:aitment and analyzed all of the funding pr:posals in detail, including proposed legislation. We have spent many h:urs obtaining information frem Govern'.
Thornburgh's office, Congressman A*.len Ertel, U.S. Senate staff personne4 the utility industry, and citizens of South Central Pennsylvania.
The t of of our hearings contain the supporting documentation and the content presentations.
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i 2-March 28, 1982, will mark the third anniversary of the TMI-2 accident, yet there has been insufficient progress in cleaning up the facility.
Although GPU submitted a budget on,0ctober 5, 1981, calling for a six-year clean-up schedule, GPU's Robert Arnold has stated that the schedule cannot be met due to the lack of funding, and that clean-up at the present rate may take 20 years or longer.
GPU is currently spending approximately SS million monthly on TMI-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 proposals that have surfaced thus far has provided any significant money for the clean-up, and none provides a real commitment for 4
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 spokeswoman, and the Pennsylvania Public Utility Commission proposal cannot provide the necessary support because it depends upon the restart of TMI-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-I restart have two unfortunate and potentially dangerous consequences.
First, they sanction an open-ended and indefinite delay of serious clean-up efforts.
Second, they result in pressures to restart Unit 1 that may be inconsistent with safety considerations.
At this point, there simply is no significant financial commitment to fund the clean-up.
This co==ittee adopted the following position on November 16, 1981, concerning TMI-1:
4 "The restart of the Unit I reactor should be based solely on the basis of technological and safety considerations, and l
not economic considerations with respect to the clean-up of Unit 2."
3ased on the information available today, it is clear that TMI-2.has become j
a de facto long-term high-level waste storage facility.
Should funding levels be further reduced, storage can be expected to last for approximately 20 years.
i As a result, GPU is in effect operating TMI-2 as a long-term vaste storage
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facility.
However, TMI-2 is not a licensed high level waste storage facility; it does not comply with the NRC's proposed criteria for the siting, design, or construction of such a facility; and the Commission has not instituted i,
licensing proceedings to determine whether THI-2 complies with standards to assure the safety of waste storage and disposal facilities.
This committee, and the public, endorse the NRC objectives in NUREG-0698 Rev 1, page 1-1.
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In conclusion, given the long-term serious hazards posed by TMI-2, the lack of funding from any source to undertake a serious and expeditious clean-up effort, and the lack of an effective commitment on the part of the NRC, we i
are forced to conclude that the failure to make sufficient and timely progress toward deconta=ination constitute threats to the public health an'd safety.
1 The Co= mission's action, or lack of action, in permitting this condition to exist and to continue constitutes a violation of the fundamental requirement t
l of the Atomic Energy Act protection of the public health and safety. We believe the Co==ission has both a moral and a legal duty to act immediately to insure that the clean-up of TMI-2 proceeds expeditiously in order to eliminate this threat to the public.
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- e As a final note, for your infor=a
- ion, l'am enclosing a copy of a summary of the various TMI-2 clean-up proposals.
Tnis sum =ary does i
not include those submitted to us by individuals.
' Sincerely yours, 4-vk hn E. Minnich
- airman, Advisory Panel for the Decontamination of Three Mile., Island, Unit 2 JEM: mss Enclosure ed.
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