ML20126F442

Comments on Programmatic Des for Facility Re Decontamination.Nrc Has Not Properly Informed Public Nor Given Clear Picture of Radwaste Decontamination & Disposal

ML20126F442
Person / Time
Site:	Crane
Issue date:	11/18/1980
From:	Books P AFFILIATION NOT ASSIGNED
To:	Snyder B Office of Nuclear Reactor Regulation
Shared Package
ML20126F437	List: ML20126F439 ML20126F442
References
RTR-NUREG-0683, RTR-NUREG-683 8101118, NUDOCS 8103130736
Download: ML20126F442 (5)

Text

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1960 quarry hond Lebanon, Pennsylvania 17042 Phones 717-865-2594 November 18, 1980 Dr. I!ernard J. Snyder, Director Three Mile Island Program Office Office of Nuclear.ienetor Hegulation U.S. Nuclear negulatory Commission Nachington, D.C. 20555

Dear Dr. Snyder:

I am writing to express my comments on the "Dran Procrammatic Environmental Impact Statement (related to decontamins-T10n and disnosal of radioactive wactes resulting from barch 28, 1979 accident 'three itile Island fluelear Station, Unit 2,-NUu2C-0683)".

At this time, I wish to thank you for mailing me this craft for =y review and comment.

First, I would like to express my comments concern-ing the structure and general presentation of the report as follows:

1. One of the basic purposes of the PEIS is to inform and involve the public as well as government officials in the decision making process of the Commission. The P3IS staff has utterly failed to effectively draft a statement which would allow the public to rationally and comprehensively participate on the subject of decontamination and disposal of radioactive wastes concerned at Three rile Island or any nuIlear facility. The staff has cate-gorica11y demonstrated through this report a lack of ability to properly convey and inform the public as to a clear understand-ing of the subject. It is not that the public lacks the intelli-gence or desire to comprehend, but that the staff has failed to organize and present that naterial in an educatable manner.

2. The material presented must be placed into its correct prospect-ive of its significance to other releasco to the environment with respect to industrial, other energy producers releaces, non-industrial, and background.

3. Gince the accident, the role the NEC has assumed in involving and informin6 the public in the decision making procesc has not served the residenta in gainning greater confidence, credibility in the nuclear industry. But, rather, has consistently served thone of the nerative ninority at the expense of time, of the ?.?jority the utility, cnd the nuclear industry, clo s 130 K5(o

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Fage 2-Oonmento to PEIS-continued

3. '/he facado of neutra11t1 hac long cinee been lost throuah your lank er leadership and has become in essence a politically tax funded organization, which I feel chould be totally abolished by Congress. If you are to establish a positive rationale, then you soundly educate the public and allow those members of the majority to be representod on the same basic no thoue of the negative attitude.

L. The or6anization of the report is of ten confused and constantly interrupted with " refer back to" or "see appendix" for further reference. The arrangement and discussion of subject caterial in the precent order is not constructively set up for logical understanding. At least four or five chsptern chould be arranged as to order in the total presentation.

Next, I would like to exprecs ry views concerning =nterial in the report an follows:

1. In the first chapter, the staff stated that cornercial nuclear power plants are not desicned with cpecini consideration for largo scale decontamination operations. ? hic statement represente the total inability of the R.C to provids leaderchip in plant safety and design. Ruito frankly, I believe the conmercial inductry would have been far better to regulate itself an to denie;n.caroty, and training of its staff than to be engulf ed in bureaucratic strangulation and total inability to lead and set standards and educate those concerned with this industry.

These efforto, or lack of, have only served to undermine public confidence, severely attack the credibility of the nuclear ind-ustry and the utility in question.

2. The aajor environmental impact of the cleanup at.::I is the occu-pational doses received by the workers involved. This la not l

procented in a clear and conciso nanner to the public in relation i

to the workers and the best alternatives for then. To democtrate your f airness and neutrality, you should have a renrecentaticn t

from this work force to allow their views to be presented and l

advise considered. Yet you have consictently ignorel the workera, and the public, and tahen under advisc.ent those views from g

areasfhre the moct vocal, and threatening, and technically lacking in expertice on the natter.

3. I would like to connent on the repetitivo acntioninn of the i

failure of the HEPA filters and its possible relence of radioactive effluento to the environ ent. As of the writing of the PSIS, tuch of the Auxiliary and Fuel handling ;3u11Encs have been decon-taainated, yet, the report does not illuctrate the actuality of the failure of these filtere nnd their releases unlin2 thic operation.

I

Fase 3-Comments to PEIS-continued

3. To promote public confidence, the staff should illustrate what these filters are, their purpose, placement in the buildings involved, failure under normal operations, failure and resultant releases involved during the operation of decontamination in-volved in the Auxiliary and Fuel Handling Euildings. Then the reader can realistically place this possibility in its true prosepetive and relationship to the cleanup effort.

h. To give credence, by disclosure, of such ideas as pouring cement l

into the containment building to solidify the water in contain-m ent, only serves to anhance your lack of expertise and seriously impairs your ability to lead and regulate. I feel the public should be graterv1 that the staff could not find a way to insert a slurry into the building and give us a permanent probice.

With the additional time the staff reauired to prepare this draft, it seems to me that the staff desparately grabbed at att ideas, the core the better, to anhance the facade that YCba N.:0 IS ON THE JOB MID CAN CUTDO TH3 INDUSTiY. The licensee has demonstrated its expertise through its presentations, carefully studied and researched. This presentation of a quantity of alternatives against the licensee's presentation only serves to confuse the public and damonstrate your success in using paper not inte111-cence.

5. We simVly de not have an eternity to clean up the,lant and to delay this effort for the presentation of your struies, and reports pisces the citisen in a situation of severe financial burden and a attitude of endless frstration. In over eigateen months you have only succeeded in raising the costs, increasing the damage, and increasing the riska of safety and health to the general public.

6. If the alternatives presented will result in littic or insigni-ficant impact environmentally to the public; then you should demonstrate this in the context of other releaces or pollutants in the environment. To say that thi.s is not within your area of demonstration; then this report should have been compiled in concjunction with the proper agencies concerned with the total environment and perhaps tal:en the tohal responsibility from your agency.

7. I have far greater confide. ace in proposals presented by the licensee,such as the SDS system, especially since their proven performance in designing the v enting of Zrypton-85 gas and its successful completion.

Page h-Comments to PEIS-continued

8. The attitude of neutrality which you have trjed to relate to the public concerning decontamination at TEI is totally i

discredited through the selection of individuals to sit on the TMI ADVISOrtY PANEL. If you wish to be fair and have representation for the minority, then you must have the majority represented. By ignoring, refusing to appoint members or individuals of groups reprsenting the majority, you cannot consider this a fair and equal represantation.

The official credence of the negative attitude further corrodes public confidence in your efforts.

I hope my comments will constructively aide you and your staff in preparation of the final report. My purpose is simply to help you effect a better and fairer relationship with the public, and creating a positive atmoshpere concerning the decontamination effort at TnI and the

~1 clear industry. As a resident of Pennsyl-vania. I strongly feel that this situation must be placed into a realistic prospective, so that an expediously safe and clean effett can proceed and the unit returned to operation. If I can be of any further assistance, please do not hesitate to contact me.

1 hanking you in advance for your consideration in this matter.

Yours truly, Mrs. Patricia A. Books PAD /pab cc: Mr. Ed Helninski Fr. IMtthew Bills l'.r. Allen Ertel Dr. John F. Ahearne m

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