ML20126C920

Supplements 790427 Emergency Request for Public Hearing. Receipt of Petition Has Not Been Acknowledged by Director of Nuclear Reactor Regulation.Suppl Is Submitted Due to Continuing Crisis Caused by 790328 Accident

ML20126C920
Person / Time
Site:	Three Mile Island
Issue date:	05/16/1979
From:	Kepford C Environmental Coalition on Nuclear Power
To:	NRC COMMISSION (OCM)
Shared Package
ML20126C914	List: ML20126C911 ML20126C917 ML20126C920
References
NUDOCS 8004140076
Download: ML20126C920 (9)

Text

g y . yy ENCLDSURE 2 UNITED STATES OF AMERICA O NUCLEAR REGULATORI* .00HMISSIW

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MEIRDPO N EDISON CEPANI, e,,t. p,. Docket No. 50-320 (ThreeMileIslandNuclearStation, ) -T .  %

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&K T. q' ' d a.( QPcr SU??IDZlTAL FITITION TO TE DIP.ICTS OF NUCLTAR FIACTOR RDXTIATIN f $

'Tm 4 i 5HERGDICT ACTION -

'4 INTRODUCTIN This is a supplement to the Intervonors' Request 'to the Director (of_

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Nuclear Reactor Regulation for Emergency' Action by the Nuclear Regulatory Cw.. issich, herein, " Request,*: docketedat3:30p.m., April 27,197h Despitetheargentneedforreliefrequestedinthatemeighneypetition, the receipt of that petition has yet (May 15,1979) not even been acknowl-edged by the Director of Nuclear Re' actor Regulation.

This supplanont to the April 27, 1979 Request is now submitted because of the continuing nature of the crisis caused by the March 28, 1979, catas-trophe at Three Mile Island Nuclear Generating Station, Unit 2. (DE-2).

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Through a series of operator errors, including violations of'the Technical .

Specifications (Tech. Specs.), instrumental failures, and b'asic design deficiencies, initiated by a lois of feedvater to both steam generators at u

h:00 a.m., March 28, the sequence of events over the sixteen or so following hours at DC-2 brought the residents of Central Pennsylvania much c2mser' to a potentially uncontrolled, uncontrollable, .snd uncoM24a=hle core molt. ,

down than the public had heretofore been led to believe was possible.

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1 escurred. Ms Margaret #=411y,'af the Casumonwealth's Eurman af Radiological -"

,. Protection, stated publicly on May 13, 1979, that some "dosens of enries of

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I131 and ==4111a== of ouries of noble gases

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the badly damaged THI-2 f nity. (see Tosh. spees., Radi- N --', Limiting .

y conditionsforoperation,see.232.) y

.. : ..1 Contrazy to the soothing assurane'es of NRC Staff and Applicant in their .-.4

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. . ,.c prepared testimonies during the evidentiary hearings which led to the liese's- $' *

. ., o ing of 2MI a, when an emergency estual2y arose, no enat was prepared to respens , f' l

i prompt 1r and adequate'r to protect the health and safety of the ==hita. ,

g One serious consequence of this lack of preparation has been the who13r lande. ~l egnate radiation monitoring in the early days of the assident, a defiaitner 4 . .

l. which remains.todar larg 2y unehenged. (See Testimoer of Robert s. Minogne, Director of the NRC Office of Standards Development, before the Enerar Sub .

comunittee of the Government Affairs Committee of the U.S. Senate, Mar 8,1777.)

) In addition, there has been no object.ive attempt to estimate exposures to the public which oscarred during those ear 3y days of the accident when envizen.

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mental monitoring was so anconscia-^'y deficiant for so long a period af time,

_ even though that minimal monitoring may have met NRC minimal standavits.

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. . It is important to observe that the information which has been and is --

, being made available to the publia conearning radiation exposure has beam l

"and is inoonsistent, misleading, and insecurate. For esemple, according to the 'AdRoe Population Dese Assessment Groep* Report, April 15,1979,.the naziman *.,otal dose received by any individual was estimated to be 86 mi13& rum i

(aren),'throughout the sonroe of the accident untii April 7,1977. However, t .

this figure must be ocupared with population exposures' disonssed in the wide 3y k

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/ On this morning of March 30, the licensee operator, Metropolitan Edison, permitted the escape of very large quantity of. radioactive gases erar a

- 1 period of one or two hours. }' Dose rates on 'the ground were estimated to be

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about 120 arem/ hour, for more than an hour.

In addition, in a public~aesting on May 3,1979, Mr. Thomas M. Dersaky, Director of the'Barean of Radiological Protection of Pennsyhnia, ~~

reparted that at 7:30 a.m., March 28,19i9, the dose rate in the ~dene of the contain-ment structure was 600 roentgens per hour (R/hr). At that time, the containment structure was not' isolated, and J radioactive gases were esc @f;- - .-

Mr. Derusky said the resulting;pr$jected dose rate in Goldsboro, situated due west of the plant and toward,which  !

thVirind a,

was then blowing, was 10 R/br.

According to ' Pre 14=4 naq Sequence of Events: M -2 accident nf March 28,

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. . , z 1979,' meno from E.L. Long to R$C. Arnol'd,'the contmimaant' structure was not isolated until 7r56 a.m., March 28, 1979 ..,

It should also be noted that the 'A'd.' Hoc" report contains an average '

.-L value cf 0.19 nR/ day, , ' ' 'i . '

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or 0.008 nR/ hour, as the., .ba,ckground radiation exposare in ,

this area of Pennsylvania. This value'is based on thermd "=4 nascent 2: .

dosimeter (TLD ) readings in the general vicinity of THI-2 for the calendar year 1977 (J.dHoc report, p 12) and should be compared with the " background'

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exposure rates' disseminated to.t5s press and public after the March 28 accident.

In PNO-79-67AD, dated April 23,1979,,the NRC reported offsita readings were 1 This value of 0.02 mi%c "consistant with normal backgrouh@ievoidk(0.02

h mR/hrl" ,

is 2 5 times the 1977 average background vaine reported by 'the 'Ad Hoc" group. l Furthemore, the Ad Hoc report usesEan atmospharie dispersion model which dictates that doses fall off with-distance according to a minns 1.5 power law beyond a 10 mile distance fromTMI-G. The exposure data presented-g

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From the NRC,, data'in):q" 1 in this AdJios' report do not support this model.

Table 3-5 thmugh 3-10,' meager and whol2r insafficient +h-h they are, it is obvious that in many directions exposures do not decrease sacerding to the minns 1.5 power law. In numerous directions, the data show that exposures not only do not decrease with distanos, ther increase with distance from 954. , .

(See, for esa9 1a, Table 3-6, Exposures in the North sootor; Table ')-7, , .,,.

Espoenres in the South Sector.)' No r jastification is offered in the AdNoe ..

..m; for the use of this rmtent3r defective distanee doomy model whiah is- '

not supported by"even the shallow data base revealod in this report. Iteaa' ,

- . . .I on2r be concluded that the obvious purpose: of this inappropriate model is to' ,

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eeneoal the magnitade of population exposures beyond 10 miles from 'tMI-2. ~j !

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y From accident sequences released by the NRC, it seems clear that largs

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U quantities of primary coolant water were vented through the electromatie ,

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'. ': relief valve (EMV) after the initial period when the sore was unoovered. .

i In this initial period of up to tuo hours, when dooar heat was higher than ,

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in later periods, fuel cladding and steam reaction are believed to have occurred. It 'm been our:gested that the reaction consumed approximate 2r .'

I ho percent of the total quantity of fuel cladding in the core (see " core 'i l

l Damage Assessment for DC-2,8 NRC Memorandum from R.0. Mper to Roger J.

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Mattoon, April 13, 1779, page 8). This wos!.d tend to suggest that in the

. apper region. of the core, which as ansevered for the longest ti.ne, seen- . .:

e l piste osidation'of at least some feel eladding oodurred, exposing the feel l l

I material to the ===14== water.

As s' result, it is evident that fission products which were even

'slighth soluble in primary ooolant water under the prev =4'iat high pressure -

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, and high temperature conditions wonid have been leached out of,the azposed l

1 feet, and sabeequentar released te the .entainment sump through the nr.

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Consequent 27, it is probable that the large quantities of water released into W con +=inmant structure-reportedly over LOO,000 ga"r h=ve high fission product levels measured in tens or hundreds of microcuries per ,

O' milliliter ( g al). '

Both the volume and the,. probable high levwl of contamination of this water exceed the cleanup capabilities of tSe reactor coolan letdown system for 'an entire year's operation of that system (See DII-2 Final Safety Ana27 sis

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Report, Tables 11.2-5, 11.2-6a, and Figur, 11.2-3). The Intervonors are l

particularly disturbed by the numerous announcements and naars that h j dumping of this high-level waste vatar, purified or not, into the Susque-i hanna River is imminent. Whils conceptuaQ it may be possible for b l licensee-operator to upgrade this letdo n system to treat e,at least superfia4='iy the contaminated. vater, there has been no public27-disc 1cepd discussion or evaluation of that ca-hi'ity or of h probabilities and consequences of

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any accidents, spills, or leaks'which might take place during h proposed  !

release of this sater to the river. Simb.larly, there has N on no public27-'

disclosed justification for the licensee-operator's sudden mah ' to process and

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dump this high-level waste water as gniskly as possible into the River and i I

into the Chesapeake Bay. Furthermore, there has been no mention or evalna- (

l tion of alternative methods of remo@, storing, or disposing of this contaminated water.

h consequences of d" 71a[ day of the vaste water the primary o -

coolant system'od; containment basement soM be catastrophic to h health e . :3 and the economic.well h=4ae of the many communities which,obtain dr4aWas water fram the Susquehanna River. Additionally,'since the'Susquehanna River is the major fresh-water source for Chesapeake Bay, a leak of even a few hun-nt water into the river sould prevent dred gallons of the radioactive cont i.* g %

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the use.of this Any as a fishery for many years to come. s

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As a result of the above, the Intervonors in,the still ongoing .

l operating license proceeding for M -2, now joined by their parent organisa-tion, the Environmental Coalition on Nuclear Power (ECNP), urgently request that the Director of Nuclear Reactor Regulation rooognise the gravity of the .

oonsequences of releases of these radioactive materials from M-2. In this , , ,

context, the Interrenors also urgent 2y request that the Director order that

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a public evidentiary hearing with sworn testimonies and full ,,i baity for '

cross-examination be held in Harrisburg to openly and sandidly ventilate .

the follsving issues:

1. N validity of the population. exposure estimates made to c date in whole or in part by the NRC, inc1= Mag an account- *J

p. ing for the numerous inconsistencies and contradictions

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4' 2. h entire . scope of the. proposed rel' ease into the Sasquahmana .

. i River of the high-level contaninated water, purified or not,.

', presently contained, or anticipated to be contaminated, at M-2.

3. N possible range of accidents and. accidental discharges to the River and the full range of consequences--econond.c, environnental, and health--from such discharges.

h. m capability and intent.of the licenseeoperator of M-2, to prevent ninor or large-scale " inadvertent' contamination l

of the River, in view of the events since March 28, 1979.

y. The capability and intent. of the lic'enseseperator of M-2 i

._ to obey the rules of the Commission and all applicable -

. stataans related to any operations at 'D(I-2, in view of the "

evente since March 28, 1979 -

6; The capii4ty and intent of the CommissI.on 'to ensure that:  !

(a) the mies of the Commission will be fully obeyed, (b) the applicable statdes, including the Atomic Energy / .

Act of 195h, as amended, the Enersr Reorganisation Act of 197h, and the National Environmental Policy

> Act of 1969 will be fully obeyed, ,

(c) the Commission or some other Fedimal agency will .

i provide- for monitoring capabilities to determine radioactive contaminst. ion levels wherever Susque- .

. hanna River water will be withdrawn for distribution i for drinking water, irrigation, industrial pro-cessing, or other purposes prior!to any further .c . 2 releases af presently contaminated water at THI-2, purified or not, to the Eiver,' i 9

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.(d) the Coranission or some other. Federal agency will provide for adequate monitoring capabilities to ;

l detect elevated levels of gaseous and particulate l

contamination fram DC-2, prior to any subsequent I

releases of airborne radioactive materials.  ; .

l The results tabnin'ted..in the Adiloc report emphatically demonstrate the need for a much more extensive and.' '

versatils environmonitoring capability to much .':,' '

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.; greater distances from*D!I-2.  ; .

7. The seed for an Environmental iltatement as requiredThe by Sec 402 (2)(e) of the National Environmental Policy Act of 1969 event.s

- which have :.ranspired since !! arch 28, 1979, including, but not * '

- limited to, the'enomous; releases of Iodine-13.and noble gases, the threat of arfierd.nent oore'ineltdown, the releases of con- , '

ta,inatad water which have' already occurred,',the threat of future release of contaminated' water which'ere or may not be 3 anticipated, the itbreat of Tuture relea'ses of radioactive particulates--all.go far beyond the eventa discussed in the ;

Final Supplement'to the FinaliZnvironmental Statement of December, 1976. The possibis: environmental impacts of future, planned activities and unplanned or acci, dental ones at D2-2 suggest that environmental'stitement is required f,or 53-2.- '

8. The method, mode, conveyance gapabilities, routes, and destinations of the unusunihy..high-level domineralizac wastes to be generated at 52-2, and the ultimate method of disposal;of the wastes, *

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including a discussion of' accidents or leaks'and the resulting consequences at any stage of :this process. j ^ ?

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9 The possible negligerit role [of.the Commission..in licensing D2-2 to operate, including the approval of the reactor design as being acceptable,to protect the health and.l safety of the public, and the granting of an operating license to the licensee.

operator knowing that the licenss> operator liad insufficient technical experience.and capabilities to operate THI-2 safely.

10. The question of whether.or not the operating license should be temporarily or pemanentifyithdrawn from the licensee-operat4r of Z C-2 for gros's violitiosp of the Commission's rules and of the operating license spe61.fications and operating conditiohs for % E-2. See Soc.186.of the Atamic Energy Act of 195h, as amended, and tho' statdes and the sections of the Comuniasion's rules cited in the Roonest of April 27, 1979. ' .,

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1. The Intenenors hereby incorporate by .re*erence paragraphs 4 through 7 -

from'the April 27, 1979 Request con += "ad under the he=d4ng, Relief Requested, and, in addition

2. b Intervonors request that the Cosmtission prohibit and prevent any further releases of r=A4aertive materials to the envirst, gaseous, airbome, particulates, or in liquid form, until twenty (20) days after l 1

final action by the Commission on this supplemental petition, to enable -. j the Intervenors and other affected memberar of the public to seek indene. )

.l tive relief in the courta. See, for example, 100.F.R. 20.6C1. ' " - -

3. The Interrenors request ht the Commission prohibit and prevent any ) 1 furthar releases of radioactive materials to the environment, gasecas, '

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< airborne particulates, or in liquid tom, until tarenty (20) dgs.after l

,. final action by the th=1==4an on the Request af April 27, 1979, to - .

, enable the Intervonors to seek injunctive relist in the Courts.

See 10 C.F.R. 20.601.

1s.. N Intervecors request that the Commission prohibit and ge.at any '

further releases of radioactive materials, gaseous, airborne partien -

lates, or liquid, until twenty (20) days after the completion of an evidentiary hearing in Harrisburg, Pa., open to the public, with sworn testimonies and full opportunity for cross -

• antion to examine the-'

issues raised in this supplemental. petition pad Request of April 27, 1979. **

5. The Intenenors request the Commission imed5.ately infom the Intervonors by First Class Mail of any and all releases of radioactive materials, gaseous, particulates, or liquid, from M-2 which occur subsequent to the receipt of this supplemental petition.

6. The Interrenors request that the Commission mail, to the Intervonors in .

a tinely fashion copies of all materials which are pertinent to the issues raised in this supplemental petition and the ongoing crisis at M-2, 4a-w4ar, but not limited to ~ r 1 -

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6. (a) the past or present condition of M-2, since March 28, 1977 (b) all enviromental radioactivity monitoring data per+=4a4=g to the accident at 32-2, data already collected and additional data as it is collected in the future (c) : all planned activities, procedures, or processes at DC-2 iwhich have the potential for releases of radioactive imaterials to the environment.1 (d) ' all planned modif5. cations of equipment, processes, or .

. structures at DE-2  !,

(e) all planned cle'anup operations inside ary buildings conta=inated during or subse'quent to the DE-2 accident ,  ;

(f) all chemical and: isotopic analyses of contaninated areas and volumes, including.; primary coolant.. water, water in the cont.a4namat sump, and air in the contain-ment structure, and all subsequent  !,

and related

analyses.

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.Chauncey Kopford lr . as,resentattve of th. znt.rv.n.r.

~h33 orlando Avenna State College,:FA 16801 1-sa-2n-nx My If M19 4

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!" , .- -< ENCLOSURE 3 , :r :

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UNITED STATES OF AERICA NUCLEAR REGULATORY COMMISSION ETROPOLITAN EDISON COMPANY )

(Three Mile Island Nuclear ) Docket No. 50-320 Station. Unit No. 2) ) .

.. REQUEST FOR ACTION UNDER 10 CFR 2.206 -. . . . . - . - -

Notice is hereby given that my petitions dated April 27. and May 16 J. . "

1979. Dr. Chauncey Kepford, on behalf of the Environmental Coali. tion on Nuclear Power requested that the Director of Nuclear Reactor Regulation institute public hearings on the accident at Three Mile Island Unit No. 2.

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and grant other relief. These petitions are being treated as a request for action under 10 CFR 2.206 of 3e Commission's regulations, and .

accordingly, action will be taken on the petition within a reasonable time.

Copies of the petitions are available for inspection in the Commission's

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Public Document Room at 1717 H Street N. W. Washington, D. C. 20555 and in the local public document room at Government Publications Section. State l Library of Pennsylvania, Box 1601 (Education Building). HaYrisburg.

l Pennsylvania 17126.

FOR THE NUCLEAR REGULATORY COMMISSION , , .

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Harold R. Denton. Director Office of . Nuclear Reactor Reguleti,e ~

l I Dated at Bethesda, Maryland j this .6 day of July,1979. ,

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