ML20126C952
| ML20126C952 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/09/1980 |
| From: | Burgess D AFFILIATION NOT ASSIGNED |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0662, RTR-NUREG-662 NUDOCS 8004140368 | |
| Download: ML20126C952 (2) | |
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April 9, 1980 Arnold, Md. 21012 i
X Daniel R.. Muller - Acting Director for the Division of Site Safety and
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Environmental Analysis, Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission, Washington, D.C. 2055$
0 mments on WREG 0662, Dated March,1980 As both Kemeny and Rogovin have pointed out, massive changes will have to occur in the nuclear industry and the FRC to implement the ' Lessons Learned' of Three Mile Island, and in this past year, these changes have not been forthetsning. This agency, the !;RCr is clearly inable in it's present config-uration of adequately regulating nuclear power to pootect public health and safety. It remains %uisness as usual
- at the NRC, and this is precisely the problem. EUREO 0662, and the plan to vent 57,000 curies of Kr-85 is an example in at least 3 regards of the profound trouble in the NRC.
The selection of Argonne National IAbs for the contract for the 3 Mile Island Clean-up Environmental Impact Statement is indicative of the mindset of the NRC that has been widely criticized, Argonne receives much of it's funding from the DOS and the DCD for weapons related research, and it's char-ter mandates the development and promotion of nuclear power. It is typical of the gevernmental - military-nuclear - industrial beauracracy that led us to l
the brink of disaster at TMI. The crises in credibility and beleiveability of the itRC are seriously intensified by the choice of Argonne for this contract.
I recommend Dr. Karl Z. Morgan of Georgia Tech, and Dr. Terry Lash bf the Natural Resources Defense Council be appointed to the oversight body of this EIS. The close involvement of the citizens of Central Pennsylvania and near by areas, of the radiation protection departments of the U.S. Public Foalth Oervice and the Food and Drug Administration, and HEW are essential for this EIS to be meaningful.
The Megative Declaration of Invironmental Impact contained in WREG 0662 is a serious breakdown of the legal process in this case, and this is not acceptable. Governor Thornburgh of Pennsylvania has received agreement from the Union of Concerr.ed Scientists to review clean up plans, and submit their analyses for the Governor's use in forming his recommendation on the clean up, and the matter of the Kr-83. URO must therefore cooperate fully with this independent and non-biased assessment, and refrain from selecting the Kr-85 disposal option before publication and review by the public of the UCS findings and of the Covernor's findings.
There has been a pattern of incomplete information, misleading statements, s
abuse of power, withholding of documents and other data, incomplete review, violations of public participation, and conflict of interest by the NRC in the "'MI accidents, the clean up,and the present decesion making process.
This cannot and will not continus. The KRC will be held accountable for the effects of their decisions, and the citizens of the Nsquehannah Valley region demand a complete, fair, and legal Envir,onmental Impact Study of all aspects of the clean up at Three Mile Island.
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Part I-Decision Making Procese
--Oeverely inadequate and unbalanced consideration of other options in IURIG 0662 - 12 mos. after accidents, 230 rejects non-purge options due to cost and time problems, why were charcoal absorbtion etc. not obtained before now T
- !UREO 0662 (Purge plan) is a violation of NEPA, dec.102 A & O due to segmentation of clean up, and no examination of short and long term environ-mental and soolo-economio impacts
- Public participation process totally inadequate,. delay in availability of NUREG 0662 and Addendum, insufficient review & comment period
- Insufficient consultation with Pennsylvania and Maryland,. such as the Md.
Governor's Commission on the TMI Clean up, and the Regional Planning Osuncil
- No mechanism for publication and review of non- :30 staff recommendations, 1.e.- Epicore II process, deficient as it was, resulted in 47 comments, of which 45 were profoundly critical of 120 plan, but there was no public review of these comments, and 130 apparently did not consider these comments at time of decision i
- No independent. impartial, non-biased source of information on Unit 2 Options
- No mechanism for public and independent review of Met Ed Purge proposal, j
except at prohibitive expense for non-professionals of log /page Part II-Technical considerations Incomvlete and totally inadeountai accident analyses and risk liklihood asse sament No breakdown of relative source and levels of total Containment radiation, to enable informed analyses of Kr-85 cloud importance has been provided, relative impact of Kr-85 to other gamma & beta sources (water, chemicals on walls, etc. ) in terms of workers ability to remain in Centainment has not been provided Crucial unanswered questions about behavior of Kr-85 plume lin environment, (atmospherio dispersion, offects on farm land and animals of plume, effects on Susquehanna R., Chesapeake Bay surface environments, effects on Atlantio Ocean downwind of plume, etc.) Also long term effects on climate, as byproduct of activation of other elements in atmosphere, also questions of accuracy of IGO dose rate calculations, questions of inhalation and skin dose effects on susceptible individuals have not been addressed No quantified assessment of social / economio / psychological impacts of purge have been presented No mention was made of retro-fitting fans that will run reliably for 1 year in Unit 1 Containment, and transfering Kr-85 t6' Unit 1, until other decontamination & storage options are tested and available No building air samples have been specifically analyzed for St-89/90, Plutonium, etc. - Also decay products of traces of Kr-133 etc. were not mentioned - also saturation and failure of HEPA filters during 60 day purge was not mentioned Part III-Alternate Recommendations
-- Clean up methods selected should be the result of the review and comment process outlined in !"dPA
- An advisory board of scientists, health physicists, epidemiologists, and enginerre, and others from outside the Utility / !GC/ Argonne labs spheres of influence should conduct an investigation, thold hearings, and make published recommendations on clean up
- Nnding should be provided for informed public participation, alternate scientific and legal advice, and related costs
-- Full public disclosure should be made of Unit 2 status, exact timing of aspects of the clean up, and potential impacts
-- Unit 1 Containment should be retrofitted for long term storage of Kr-85, tending selection of ultimate disoonal ontion.
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