ML20054E033
| ML20054E033 | |
| 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 | |
| ML20054E030 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8204260034 | |
| Download: ML20054E033 (3) | |
Text
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'a THE ADVISORY PANEL FOR THE DECONTAMINATION OF E
-l THREE MILE ISLAND UNIT 2
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March 17, 1982 i
Chairman Nunzio Palladino Nuclear Regulatory Conunission 1717 H Street, N.W.
lith Floor Washington, D.C.
20006
Dear Chairman Palladino:
The Advisory Committee on the Decontamination of Three Mile Island Unit 2 submits the following report, our second to date, on our efforts and the findings that we have made based on our investigations.
We emphasize at the outset our most important and most 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 decontaminated. The rate of progress on the clean-up at this time is inadequate to protect the public health and safety.
2.
In the absence of an expeditious clean-up, Unit 2 is becoming a de facto, long-term storage facility for high-level radioactive wastes which also constitutes a threat to the public health and safety.
Our c,onclusion that Unit'2 constitutes a threat to the public health and safety derives primarily from the fact that little is known about: conditions inside the reactor, and_no thorough evaluation has been performed (to determine whether and how long conditions will remain stable. Although the reactor facil-icy was presumably designed to withstand an accident as severe as this one, we know of no basis for believing that it was intended to remain in a damaged state for.many years after the accident occurred. You will understand that the public concerns in this regard are heightened by the recent revelation of reactor vessel embrittlement and tube corrosion problems.
If these conditions are arising in reactors that have not undergone the stresses that TMI-2 has faced during and since the accident, we fear that serious deficiencies will develop at TMI-2.
For example, there have been technical concerns expressed about the proper functioning and long-term reliability of the instruments l
within the containment building.
l The ability to remove this threat to the public health and safety depends upon a conunitment of sufficient funds and other resources. We have reviewed and analyzed all of the funding proposals in detail, including proposed legislation. We have spent many hours obtaining information from Governor Thornburgh's office, Congressman Allen Ertel, U.S. Senate staff personnel, the utility industry, and citizens of South Central Pennsylvania. The transcripts; of our hearings contain the supporting documentation and the content of many presentations.
I 8204260034
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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 October 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
$5 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 :
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 Pennsylvadia-Public Utility Commission proposal cannot provide the necessary support b'ecause it depends upon the restart of TMI-1, l
which is months, if not years away given the growing inventory of serious l
deficiencies being discovered in that reactor. Furthermore, proposals tied to TMI-l restart have two unfortunate and potentially dangerous consequences.,
First, they sanction an open-ended and indefinite delay of serious clean-up l
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 conunitment to fund the clean-up.
This committee. adopted the following position on November 16, 1981, concerning 3
TMI-1 d
"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 information available today, it is clear that TMI-2 has become a de facto long-term high-level waste storage facility.
Should funding levels be further reduced, otorage can be expected to last for approximately 20 years.
As a result, GPU is in effect operating TMI-2 as a lon6-term waste storage facility. However, TMI-2 is not a licensed high level waste storage facility; i
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 licensing proceedings to determine whether TMI-2 complies with standards to assure the safety of waste storage and disposal facilities. This conunittee, I
and the public, endorse the NRC objectives in NUREG-0698 Rev 1, page 1-1.
l 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 l
effort, and the:. lack of an effective constitment on the part of the NRC, we l
are forced to conclude that the failure to make sufficient and timely progress i
toward decontamination constitute threats to the public health and safety.
The Commission's action, or lack of action, in permitting this condition to exist and to continue constitutes a violation of the fundamental requirement of the Atomic Energy Act protection of,the public health and safety. We believe the Conunission 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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3-As a final note, for your information, I am enclosing a copy of a i
suanary of the various TMI-2 clean-up proposals.
This summary does not include those submitted to us by individuals.
Sincerely yours, T. M hn E. Minnich
- airman, Advisory Panel for.the Decontamination of Three Mile Island, Unit 2 JEM: mss Enclosure 9
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