ML20151G695
| ML20151G695 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/14/1988 |
| From: | NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2 |
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| NUDOCS 8807290128 | |
| Download: ML20151G695 (174) | |
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f UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of:
ADVISOR'i PANEL FOR THE
)
DECONTAMINATION OF THREE MILE
)
ISLAND, UNIT 2
)
t l
Pages:
1 through 140 Place:
Harrisburg, Pennsylvania Date:
July 14, 1988
=
===============================================o; HERITAGE REPORTING CORPORATION W A9P0Ff8P8 1220 L Strwt, N.W., Sake 400 WasMagton, D.C. 200H 8807290128 880714 (202)6 M PDR ADOCK 0500032(>
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U.S.
NUCLEAR REGULATORY COMMISSION Soc 50T&I t
In the Matter of:.
)
ADVISORY PANEL FOR THE
) Docket No.
DECONTAMINATION OF THREE MILE ISLAND )
UNIT 2
)
- Thursday, July 14, 1988 Holiday Inn Banquet Room, AB 23 South Second Street Harrisburg, Pennsylvania The above-entitled matter came on for hearing, pursuant to notice, at 7:08 p.m.
APPEARANCES:
e On behalf of the Nuclear Reculatory Commission:
DR. NEIL WALD FREDERICK RICE MICHAEL MASNIK THOMAS SMITHGALL KENNETH MILLER JOHN LEUTZELSCHWAB ANNE TRUNK ELIZABETH MARSHALL l,
Heritage Reporting Corporation (202) 628-4888
i-UNITED STATES NUCLEAR REGULATORY COMMISSION' ADVISORY PANEL FOR THE DECONTAMINATION OF.
THREE MILE ISLAND UNIT 2 Agenda for the July 14, 1988 Meeting in Harrisburg, PA Minutes 1.
Chairman's Opening Remarks - A. Morris 5
2.
Repert of Chernobyl Visit - N. Wald IS 3.
Status of Accident-Generated Water Hearing - NRC Staff 5
4 Status of Cleanup Activities - GPUN Staff 10 5.
Remarks on PCMS - GPUN Staff 50 6.
Panel working session on PDMS* - Panel members 30 7.
B rea k 10 8.
Panel working session on PCMS continued * - Panel members
-75
- Includes public participation 4
iii i
.____u___-___m_
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- 2 CONTENTS STATEMENTS OF:
PAGE i
Neil Wald 4
Frank,Standerfer 16 Ed Kinter 37 Dr. Robert Q. Marston 44 Eric Epstein 86 Frances Skolnick 104 Brian Hunt
- 112-Doris Robb 116
.i Tom Bailey 119 j
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1 PROCEEDINGS 2
MR. MORRIS:
Good evening, ladies and gentlemen.
I'd 3
3 like to call the meeting of this panel to order.
Just a couple 4
of announcements by the Chair.
~
l 1
5 One is that I've been' asked to announce the meeting i
6 with the Nuclear Regulatory Commission of this panel which will 7
be held on August the 16th, 10:30 to 12 at 1 White Flint North, 8
Corner of Rockville Pike and Nicholson Lane, Rockville, 9
10 MR. EPSTEIN:
Where's that address, again?
11 MR. MORRIS:
One White Flinh North.
That's Flint, F-12 L-I-N-T.
13 MR. EPSTEIN:
North?
14 MR. MORRIS:
North.
Which is the corner of Rockville 15 Pike and Nicholson Lane.
When you get there, Eric, please call 16 us and tell us how to get there, would you?
17 MR. MASNIK:
It's the Wnite Flint stop of the subway 18 station.
19 MR. EPSTEIN:
Is it D.C.?
20 MR. MASNIK:
It's north of D.C.,
just outside of the 21 Beltway.
22 MR. MORRIS:
It's in a place called Rockville, 23 Maryland.
24 MR. EPSTEIN:
Rockville.
25 GENERAL AUDIENCE:
It's at White Flint -- White Flint Heritage Reporting Corporation (202) 628-4888 s
o c
4 1
Mall.
(
2 MR. MORRIS:
Well, the address was 1 White Flint 3
North.
10:30 is the beginning of the meeting, and noon it will 4
end.
That's a Tuesday.
5 I receive calls from Gordon Robinson, Tom Gerusky, 6
and who else?
I'm trying to think who else had indicated they 7
could not go.
8 That's right.
Joel Roth had called me a couple of 9
weeks ago and said he could not make it tonight.
10 At the appropriate time, I will give some comments 11 that were offered by Tom Gerusky regarding the PDMS.
But in 12 order to continue at this point with the agenda, I would like 13 to turn to the next item, which is Neil Wald, and Report of 14 Chernobyl visit we had some months ago, f
15 Dr. Wald, sir, you agreed to the slide show, and i
16 you're on.
Glad to have you do it for us, i
17 GENERAL AUDIENCE:
Hope it isn't slides of your 18 vacation.
i 19 MR. WALD:
I'm not even going to show you Moscow or 20 Leningrad.
Stick to the subject.
l 21 1
22 STATEMENT OF NEIL WALD 23 MR. WALD:
The report I'm giving is about a 24 scientific Conference that was called by the U.S.S.R. Academy 25 of medicine, and the Institute of Biophysics at Moscow on Heritage Reporting Corporation (202) 628-4888
5 1
medical aspects of the Chernobyl accident.
/
2 I can't possibly review all of the information which 3
was transmitted to us in a period of three days.
But I will 4
try tc get a few of the highlights, and give you a look at the 5
Chernobyl power station.
6 The meeting was held in Kiev.
There were invitees 7
from 20 different countries.
There were nine or ten'of us from 8
the United States.
9 None of us knew exactly why we had been invited.
But 10 we showed up anyway.
The agenda, it turned out, was a review 1
11 of some of the details of the accident at the' power plant.
And 12 then more information about the exposures and the follow-up 13 studies which are being conducted.
14 Let me just give you a brief -- it's-not even a
[
15 summary.
It's my notes on what interpreters who are not V.
16 familiar with technical terms made of the presentations, all of 17 which were in Russian.
18 They were 15 minute presentations, each preventor 19 preventing about an hours worth of material in the 15 minutes.
20 If the interpreter got stuck on one word, that blew about two 21 thirds of the translation.
22 So this is sketchy.
The International Atomic Energy 23 Agency is considering publishing the proceedings of the 24 meeting.
25 But to call to your mind some of the dimensions of Heritage Reporting Corporation (202) 628-4888 i
b 6
1 the problem, the population that was involved and moved out of 2
a 30 kilometer area was 160,000 people.
3 The population itself, plus people.outside of that 30 4
kilometer' zone, have all been placed in a registry.which 5
contains 600,000 people, all of whom have had medical 6
examinations.
7 There were 3,i200 infants in utero at the time of the 8
accident.
There was a follow-up of the outcome of the 9
pregnancies.
10 And without keeping you in suspense, according to the 11 speakers, there was no increase in spontaneous abortions, or in 12 pathological births.
13 A different speaker did refer to some increase in 14 elective pregnancy terminations, and also --
(
15 (Pause) 1, 16 MR. WALD:
I think that was the only point that was 17 in addition on that subject.
18 The size of the population and the extent of the 19 follow-up were quite impressive.
The nature of the follow-up 20 includes medical examinations, and also pathological studies.
21 And the medical examinations have particular interest 22 on the thyroid.
23 There were no results really reported, other than the 24 outcome of the pregnancy.
25 Other features of the presentations had to do with Heritage Reporting Corporation (202) 628-4888 i
4 4
7 1
the acute radiation injuries, which had to be managed in a very 2
short time period.
3 And about 499 people were examined and evaluated for 4
acute radiation injury.
This population boiled down to 235 5
that were actually treated for acute radiation injury.
And 6
some were treated in Kiev, and the remainder in Moscow.
7 We've heard most about the bone marrow 8
transplantation used as a form of treatment in this population 9
that were in the Moscow center where the bone marrow 10 transplants were done, as well as some liver cell transplants.
11 There were a total of 19.
Of these, six involved
)
12 liver ce:.ls.
This is Freco (ph) liver, which is less likely to 13 react against its new host.
14 None of those were successful.
The bone marrow 3
15 transplantation -- they were up 13 patients; two of them have
'i.
16 now survived over two years since the accident took place.
17 In both cases, the bone marrow that was transfused 18 into those two patients was ultimately rejected by the 19 patients, and they are back on their own blood cell formation.
20 It also should be pointed out that these 19 patients 21 were part of the most seriously injured group, and every one of 22 these patients had serious skin burns, both radiation and 23 thermal burns from the fire which took pla'ce.
24 So from the medical standpoint, I think some of the 25 most important information relates to what is now called Heritage Reporting Corporation (202) 628-4888
8 1
combined injuries, which is radiation exposure, plus other 2
types of injuries.
s 3
I think, without going into further numbers, you 4
might be interested in seeing some of the things that we saw.
5 When we came into Kiev, we thought we saw the Statute 6
of Liberty.
We came in at night and it was lit up.
It turned 7
out to be a symbol of Kiev as one of the five hero cities of 8
the U.S.S.R. having fought and survived the great patriotic 9
war, as World War II is called in that country.
10 But the most striking thing in Kiev, especially for 11 those of us who come from Pittsburgh is that one sees the 12 churches all over the city, and they' re all in a good state of 13 repair, and in fact they will be repaired and particularly 14 renovated for the 1,000th anniversary of Christianity which f
15 began in Kiev 1,000 years ago.
S, 16 The meeting took place on a building on the right, 17 which is the Lenin Museum.
And the arch on the left is not 18 Mcdonald's, it is a Friendship Arch, representing the bond of 19 friendship between the Ukrainian and the Russian people.
20 We heard some comments about why they needed to be 21 reminded.
22 The trip to Chernobyl is about 80 kilometers away 23 from Kiev, and we made it in very good time.
Apparently, one 24 has the authority -- when someone is in front and behind, one 25 can travel very rapidly in the U.S.S.R.
Heritage Reporting Corporation (202) 628-4888
a s
9 1
This is the Chernobyl power station.
And for those 2
of you who are old enough to remember when we used to have an 3-AEC, and wondered whatever happened to it, you can see at the 4
top of the buildin, there.
Now we know.
5 This power station:-- and it stands for Atomic Energy 6
Commission.
This power station is dedicated to' Lenin, as 7
almost everything in Russia seems to be.
8 The representative of the -- I was going to say 9
company of the agency which operates this plant at least had 10 many of the characteristics that we associate with public 11 relations personnel in our country.
12 He spoke very freely, and was very forthcoming.
The 13 translator was helping him along.
14 The audience consisted of many of the scientists from p
15 other countries of the U.S.S.R.,
as well as newspaper 16 reporters.
17 They have started to open this plant to visits, and 18 according to the P.R.
man at least, he sees more Americans than 19 he sees Russians now-a-days.
20 Several of these people may be familiar to those of 21 you who know the people in the Department of Energy.
And many 22 of them are from other countries.
1 23 Some of the visitors who were a little skeptical 24 brought their own meters.
The gentleman in the middle from 25 West Germany was taking readings to assure himself and the rest Heritage Reporting Corporation (202) 628-4888
10 1
of us that things have been cleaned up.
j 4
2 You recall that the fire which followed the explosion 3
of Station Number 4, Unit Number 4, is the red in the satellite 4
- photo, l
5 You can also see the cooling canal, and'the Pripyat 6
River if'off to the right of the slide.
7 Here, you can see in the mid ground the cooling 8
canal, and behind it the Power Station Number 4, or Reactor 9
Number 4.
And the area where the explosion took place is i
10 covered by what seems to be a black covering which, on close 11 inspection, turns out to be big blocks of concrete which have 12 been lifted and deposited to cover that entire roof.
)
l 13 You can see the hooks by which helicopters carried 14 these.
And the entire right area is also cemented over the
- s existing building.
15 16 This, of course, is the quick way to close down a 17 contaminated facility, but of course is not usable for any 18 purpose, and it's just going to sit there until the authorities 19 decide what to do about it.
20 You can see a lot of construction material, and 21 cranes, all of which have not yet been fully decontaminated 22 because of the difficulties in cleaning them.
And so there's 23 restricted area.
24 On the other hand, the other three existing power 25 stations are operating fully.
This is a control room of Plant Heritage Reporting Corporation (202) 628-4888
11 1
Number 2, to which we were invited.
)
2 We never did find out exactly what the white clothing 3
does for the people in the control room.
We were given these 4
coveralls, and head covering, but no dosymeters. (ph) 5 The television display displays the top of the 6
reactor, which in this particular kind of reactor can be walked 7
on and the working crew can remove fuel elements while the 8
reactor is operating.
9 We didn't see any read-cuts that were digital.
I'm 10 an amateur at this, but it looked a little behind-the-times.
11 Here, you see the debris which is left, and also, on 12 the left-hand side, a new station which is partly constructed.
13 And here's another view.
14 Power Stations Number 5 and 6 were already under i
15 construction at the time of the accident.. And since then, Y.
16 largely because of public opinion, construction has stopped, 17 and there has been no further activity.
18 They were also constructing cool towers.
And as you 19 see, they finished one and started a second when construction 20 stopped.
So this has been sitting now for two years.
21 This is an area which contained pine forest.
You can 22 see the pines in the background.
The LD\\50 and the mid-lethal 23 dose for pine trees is very close to that of humans.
And in 24 this whole area the pines died and were bull-dozed.
25 It wasn't entirely clear to uc.
We asked where all Heritage Reporting Corporation (202).628-4888
12 1
the waste went.
And they said that they maintained it on 2
sight.
3 This 1 coked a little like a landfill.
But the little i
4 black spots that you see are the new pines which have been l
5 planted in effort to carry out reforestation of the entire 6
area.
7 And it was this dying of the pine trees which showed l
8 the direction that the fume took as it left the plant.
And 9
from satellite photos it was clear which the dead trees were 10 and which the live ones were.
g i
11 That 30 kilometer zone, as you can see, encompasses a 12 large area.
In fact, it goes from the Ukraine in Tubela, 13 Russia [ph) which was marked as sort of gray in the upper left-l 14 hand corner.
So it goes over more than one of the Soviet
- {
15 republics.
16 And they had complications with communication and 17 waive lengths, and so on.
18 Here are some scenes inside the 30 kilometer zone.
19 The Ukrainians still live largely in rural settlements like 20 this with individual housing, unlike most of the city dwellers.
21 And there are areas around the house that are always 22 immaculate in all the other parts of the Ukraine that we saw.
23 And here you can see two years' neglect.
Nobody lives there 24 anymore.
25 This is the town of Pripyat.
This was the town of Heritage Reporting Corporation (202) 628-4888 s
13 1,,
50,000 people.
A service community nearest to the plant.where 2
all of the construction crews and plant operating crews lived.
3 These are the typical apartment houses which are the 4
means of housing for people in the U.S.S.R.
And everything is 5
there except people.
6 You can see that the clean-up of the terrain around 7
the houses has taken place.
The people were allowed to take 8
their sama-bars (ph] and photo albums.
And they all left.
9 Everything that was left in the houses was dumped 10 because decontamination was too big a task.
And the houses are 11 all uninhabitable.
12 This is the fire station in Pripyat.
This ir, where 13 the firemen came from that caught the fire on top of the 14 reactor station.
g 15 You can see a lot of decontamination has taken place s
16 in that area where the trucks were coming and going.
Most of 17 the casualties, incidentally, were part of the fire-fighting 18 team.
19 The stores still have their contents.
You may not be 20 able to make it out.
But the store -- to show those on the 21 left have lamps, and on the right were television sets.
These 22 sell for about three months of work for a worker in the 23 U.S.S.R.,
but they're all just sitting the're.
24 It was the town square in Pripyat where ceremonies 25 are held.
And you can see the fair ground behind it, and the Heritage Reporting Corporation (202) 628-4888 i
14 1
ferris wheel still waiting for customers.
l 2
If you run into a sign like that in the foreground 3
that's how you stay contaminated in Russia.
Some of the areas 4
aren't quite as clean yet.
5 This is one of the apartment houses.
Many of the 6
apartment houses have signs on top of them which, I guess, is 7
the equipment of our billboards, except the commercials are all 8
for one firm.
9 And in this particular case, the sign -- let me give 10 you the exact translation.
It says, and it's rather ironic, it 11 says let the atom -- you can see the word "atom" which looks 12 like our alphabet -- let the atom be our worker, rather than 13 our soldier.
14 And unfortunately it wasn't such a good worker in
[
15 that particular instance.
16 This is the last picture that my wife took.
She was 17 shooting black and white.
And a child's ball was there in the 18 middle of the road.
19 That was the only sign of life really that we saw in 20 Pripyat.
21 So it was a very repressive sight.
But the thing to 22 remember, in spite of the dislocation of these 160,000 people 23 and the loss of the 31 lives in this worst-case accident, this 24 is what remains.
25 MR. MORRIS:
Well, thank you, Neil, for taking the Heritage Reporting Corporation (202) 628-4888
15 1
time to put the slide-show together and providing us with a 2
different side of the' story here.
3 The next item on the agenda is the status of accident 4
generated water hearing.
It's by the NRC staff.
And tonight, 5
it is important, as I've indicated, I think, to Mike Masnick on 6
the phone, and to other individuals that.we try to keep with3n 7
the time limits that are set for us because we do have a lot of 8
things to accomplish tonight.
9 So this is supposed to be very brief.
And Mike, who 10 will be providing this?
Will you be?
11 MR. SUNDICK:
I'll just speak about it.
12 I think Ken Miller had asked for an up-date.
As 13 you're aware, the licensee filed motions on May 9th and 16th 14 and moved for summary disposition of all seven contentions that
/
15 were admitted to the license proceeding.
(
16 The NRC staff, on June 23rd, responded to the 17 licensee's motions supporting the licensee's request for 18 summary disposition for all seven contentions.
19 Then on June 27th, SDA TMIA responded also to the-20 licensee's motion for summary disposition, and requesting that 21 the Board not grant summary disposition to any of the-22 contentions.
23 The Board now has these three documents -- actually, 24 they are four.
And it's up to the licensing board to determine 25 whether or not any or all of the contentions warrant dismissal Heritage Reporting Corporation (202) 628-4888 i
16 1
by summary disposition.
2 Those that they grant summary disposition to will no 3
longer be part of the proceedings.
And they will not be argued l
l 4
any further.
5 Those that they do not will be litigated.
And we 6
expect that the licensee -- I'm sorry, the licensing board will 7
give us a ruling some time in August on that issue.
8 And quite likely, when they give us the. ruling, 9
they'll also give us a schedule for the hearing.
That's where i
10 we are.
11 MR. MORRIS:
Thank you.
j 12 Unless there are any questions from the panel, I do 13 plan on moving, as I said earlier, fairly quickly.
And the 14 next item is the Item 4, Status of Clean-up Activities by the g
15 GPU staff.
s 16 17 STATEMENI OF FRANK STANDERFER, DIRECTOR, TMI-2 CLEAN-UP 19 MR. STANDERFER:
I'm Frank Standerfer, the Director 19 of the TMI-2 clean-up.
In addition to decontamination work 20 that's going on in the plant, de-fueling is the major activity.
i 21 And we are now cutting our way through, as I 22 mentioned in the last couple of meetings, through the lower 23 core support structure, is Item 4 on the diagram on the left.
24 All of the fuel's been removed from the regional core 25 zone, which is Number 2.
And the fuel that remains in the Heritage Reporting Corporation (202) 628-4888
17 1
vessel is that in the lower core support structure, Item 4, and~
2 in the bottom of the vessel, Item 5.
3 Then there's a small amount of fuel up on the sides 4
of the core support structure, Item 6.
And we've removed the 5
top layer of the core support structure a couple of months ago.
6 We've been cutting through the next layer, and that 7
was removed last weekend.
So we' re about half-way through the 8
core support structure.
And I wanted to show you what that 9
looks like.
10 The next slide, Connie.
11 The next slide is Item 4, exploded.
That's the lower 12 core support structure.
The lower grid section is the top part 13 which has been removed.
14 The grid distributor plate was removed this weekend.
15 And the next slide will show what that top ridge structure t
16 looks like today.
17 That's the structure that held the 177 fuel helmets 18 in little square egg-crate boxes.
And that's all been removed.
19 And the next plate down, Connie -- looks like this.
20 It's been cut into four pie sections, and removed.
21 And the next slide shows the first section as it was removed.
22 And then the other three sections were removed, and it looks 23 like the next slide.
24 That's the way it looks today -- on Sunday, when the 25 last plate was removed.
And this statuo is of Monday of this Heritage Reporting Corporation (202).628-4888
18 1
week.
2 With that, I've got a brief video tape showing some
+
3 of the operations on that plate.
And it always was good at the 4
island on a video screen, but when we used this machine, some i
5 of the darker portions tend to not show up too well.
6 So we'll go througn this fairly quickly.
7 This shows the cutting, lifting, cleaning of one of 8
the quarter sections.
This is kind of dark, but the bubbles 9
are nitrogen coming out of the bottom, cutting towards a lower 10 positioning to start the first cut.
11 Then a shield goes over the TV camera to be sure to 12 shield it from the light from the cutting, and that's the 13 cutting towards cutting.
They're shown there.
And we've just 14 kind of gone through this fairly quickly.
A fairly dark
[
15 section.
Now this is the light section of that plate.
n 16 And you can see where the cut is there.
It's run in 17 between the holes in the center of the piece.
And we ended up 18 with a cut all the way around the outside, and then the cross 19 separating the piece into four pie segments.
20 And this is one of those pie segments of being 21 grappled and lifted vertically inside the reactor vessel 22 underwater.
23 The next job was to brush it off.
And there's a wire 24 brush on the end of a long-handle tool.
And we're brushing the l
25 surface off to clean any fuel and other material that's Heritage Reporting Corporation (202) 628-4888 l
19 1
encrusted on this piece.
2 And you'll see as it's lifted in the vessel, it's 3
quite shiny and almost looks new.
4 MR. RICE:
Frank,'how much does one of those pieces 5
weigh?
6 MR, STANDERFER:
Oh, these are two inches thick.
And 7
that probably weighs about 1500, 2,000 pounds.
8 MR. RICE:
Just one of the pies?
9 MR. STANDERFER:
Yes.
But that's a little high.
10 Maybe 1200 pounds.
I think that's a little high for it.
Most 11 of it's holes rather than eteel.
12 These aren't the heaviest lifts.
So there are some 13 segments later that will be heavier.
But the heaviest onea 14 that we' re going to deal with are only around 3 or 4,000
{
15 pounds.
4' 16 This is that piece coming out of the de-fueling slot.
i 17 That's where the workers normally work.
You can see it's now 18 being lifted through the air by the puller crane, and will be 19 deposited in the core flood-tank.
20 It's a tank that we cut the top off of.
And 'he c
21 earlier pieces were put in it.
And now these pieces are being 22 stored underwater in this tank, on the side of the reactor de-23 rings.
24 The plasma cutting torch, of course, is operating to 25 make these cuts at 35 feet underwater.
It's computer Heritage Reporting Corporation (202) 628-4888
20 1
controlled, fairly sophisticated hardware, never intended to be 2
used for this kind of purpose.
l 3
And we' re continuing to develop and work out minor 4
bugs and problems in making it work.
That's it.
5 I'll be glad to answer any questions on progress.
6 Otherwise, I'd like to get in on the comments on the EIS.
7 MR. MORRIS:
The schedule fuel removal, Frank, called 8
for, I believe, completion at the end of this year?
9 MR, STANDERFER:
Yes.
10 MR. MORRIS:
How does that look at this point?
11 MR. STANDERFER:
Well, we're running about two months 12 behind.
This cutting -- the good news is, all of this cutting 13 equipment's working the way we would like it to work.
The bad 14 news, it's slower than we thought it was going to be.
[
15 So we have all the techniques required to get thess i
16 pieces out.
But, for example, those cutting heads -- we 17 thought we'd get ten to twelve cuts per head.
We're averaging 18 sometimes 10 or 12 and sometimes one or two.
So it's slower, 19 but it's going.
20 So we don't now expect to finish de-fueling by the 21 end of this year.
It'll be early next year some time.
22 We're looking at schedules right now.
I just don't 23 have any schedule.
24 MR. WALD:
Are you at a point yet where the 25 likelihood of any major unknowns is diminishing?
Heritage Reporting Corporation (202) 628-4888
c 21 1
MR. STANDERFER:
The only major unknown that we have 2
now-is what's on the immediate' bottom of the reactor vessel j
3' under that material down there.
And that's of course what the 4
NRC's research program is going to look at at the end of de-5 fueling.
J 6
So unless there's something I don't understand,'it's 7
what's right on the bottom of the reactor vessel underneath the 8
lose material that we see there.
9 And I guess, if it was something that was very 10 difficult to cut, or difficult to remove, then that would be 11 the problem.
i 12 On the other hand, if it's that difficult to move 13 maybe it's safe to leave it there.
So we'll have to see what 14 it looks like.
15 MR. MORRIS:
Is one of those items that could be i
(
16 difficult to remove, the silver that -- 5,000 pounds of silver i
17 that 18 MR. STANDERFER:
Yes.
It's speculated that the 19 control rod material melted earlier and flowed through the 20 water, and deposited itself on the bottom of the vessel.
And 21 then the fuel came down on top of it.
22 So that could be there.
If it then remelted, it-23 could be very difficult to remove.
If it's just granular 24 material with the fuel on top of it, then it would be easy to 25 remove.
Heritage Reporting Corporation (202) 628-4888
22 1
So we don't know whether it's there or not.
And if 2
it is there, it could be easy to remove'if it's granular, or 3
difficult to remove if it remelted.
4 MR. MORRIS:
Thank you.
Okay.
I don't see any other j
5 questions.
So maybe we can move on to the next item, which is 6
Item 5.
i 7
MR. STANDERFER:
Yes.
8 MR. MORRIS:
The remarks on the PDMS.
9 MR. STANDERFER:
What I would like to do is summarize 10 the comments that GPU Nuclear has provide to the NRC Tuesday of 11 this week on the EIS.
12 I believe we've given you a copy of that letter in 13 your package there.
I'm summarizing the general comments that 14 we made in this presentation.
And we have some copies of this.
g 15 We have people in the audience who would like to have a copy of 9*
16 the EIS letter.
17 Before I get into the comments themselves, I' d like 18 to make a little background summary.
We transmitted our 19 proposal for PDMS, the PDMS plan to the NRC in December 1986 20 about a year and a half ago.
21 We then submitted in March of 1987, about a year and 22 a quarter ago, the environmental report for this PDMS proposal.
1 23 That environmental report is the basis that the-NRC used to l
j l
24 prepare the environmental impact statement, which they issued
{
25 in April of this year -- roughly 13 months after we gave them Heritage Reporting Corporation (202) 628-4888 1
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the environmental report, g
Our environmental report addressed the environmental 2
3 issues associated with our proposal PDMS.
They have used that 4
in their EIS.
But then the EIS procedure requires them to 5
compare that with some alternatives, i
6 They put alternatives tocether.
Those were not l
i 7
submitted by GPU.
They're alternatives to assist in 8
determining whether or not our proposal has any environmental 9
issues which should be addressed.
i 10 They tend to be hypothetical in the sense that they 11 haven't been designed and detailed to the degree that our 12 proposal was.
13 The environmental impact statement comes from the 14 NEPA legislation, the intent of which is to get these kinds of i
15 issues considered as early as possible in a project like this, 16 so that if there are any environmental issues which should be 17 considered, they're considered before the project gets too far 18 along, and there's too much money invested in an option, and i
19 that sort of thing.
20 So that's why the environmental issues get addressed 1
21 at this stage.
The actual license amendment which is the item 22 that the NRC will approve PDMS on, we will be submitting later 23 this month.
24 So that license amendment actually isn't even 25 submitted yet.
So again, the EIS is to determine whether Heritage Reporting Corporation (202).628-4888
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i 24 1
there's any first order environmental issues which must be 2
addressed.
3 The issuing of the final environmental impact 4
statement is not r.
approval of the PDMS proposal.
It's one of s
5 the steps towards the eventual action on our license amendment.
6 So getting into our overall comment, the NRC has used 7
bounding values in the PDMS, many of which we'va provided.to 8
them.
9 That nieans thar. they've tended to use numbers larger 10 than we expect to end up with so that they can be sure they
11 bounded the proposal.
12 We do concur with their findings in the draft PDMS 13 that the PDMS configuration is environmentally safe.
The 14 benefits of long-term storage, the PDMS proposal, outweigh f
15 potential adverse effects.
And the dominant. issue in the. PDM 3 A
16 environmental assessment is the reduced occupational exposure 17 to TMI-2 workers.
'l 18 The first general comment dealt with preparation for i
19 PDMS.
As we included in our plan a year and a half ago,
-l 20 there's a number of prerequisites which must be achieved prior 21 to entering PDMS.
22 And they, in summary, include the reactors de-fueled, 23 and fuel shipped off the island; the potential for criticality 24 or significant radioactive release have been eliminated; and 25 that the plant is in a safe, stable, monitored condition.
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As we look forward to PDMS, there's another activity 2
which may be continuing into the first year of PDMS, or what we 3
call the transition year of PDMS.
4 We now expect to be processing and disposing of water 5
during that initial year of PDMS.
We will be decontaminating 6
some of the fuel storage systems and cubicles at that time.
7 We will still be shipping low-level waste for about a 8
year.
And we will be completing the special nuclear material 9
transfer papers with DOE associated with the shipment of the 10 fuel to Idaho.
11 So in summary, TMI-2 will be ready for entry in the 12 PDMS upon completion of the on going clean-up program.
Some 13 activities may continue for a year or so in the PDMS, But 14 those final activities don't alter the NRC assessment of the
- {'
15 environmental impacts in our judgement.
16 General comment Number 2 relates to completion of the 17 clean-up program.
A3 we have indicated in our plan, the clean-18 up program's intent was to include all actions necessary to 19 recover from the accident and place the plant in a safe and 20 stable condition that poses no risk to the public health and 21 safety.
j 22 GPU has not identified additional future clean-up 23 work to be performed separate from de-commlssioning.
Our plan 1
24 anticipates possibly storing the plant in the PDMS 25 configuration up until the time chat Unit 1 is de-commissioned, Heritage Reporting Corporation (202) 628-4888
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26 1
and then the two plants would.he de-commissioned at the same 2
time.
3 Of course, the de-commissioning activities in TMI-2 4
would include some more difficult steps than that of TMI-l 5
because the plant will not be as clean.
6 In our judgement, it !r not Alara.
That means 7
minimizing radiation exposure to workers.
Alara is the 8
shorthand that NRC uses to perform further clean-up work after 9
the end of the clean-up program as we've defined it, short of 10 starting de-commissioning.
11 To help explain this, in this EIS, the NRC has used 12 two terms for the two cases that they have used to bound all 13 the cases.
One was what they call immediate clean-up, and the 14 other is delayed clean-up.
[
15 We believe to understand these better, you might
\\
16 think of them as immediate additional decontamination, and 17 final decontamination as part of de-commissioning.
That's how 18 we would term those two.
19 The next general comment has to do with residual 20 fuel.
The draft PEIS bounding calculations are performed now 4
21 on the baeis of an assumed residual fuel inventory of one 22 percent of the original core.
23 And that's a conservative estimate.
De-fueling is to 24 continue to the extent that sub-criticality is ensured.
And we 25 expect to do better than the 99 percent removal which this Heritage Reporting Corporation (202) 628-4888
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document is based on.
So again, it's a bounding number.
2 The source term, or amount of radioactivity that 3
could be released during PDMS is insensitive to the residual 4
fuel for the most part because it will be contained within the 5
original reactor system, 6
So it's contained within a metal system'within the 7-concrete container building, and has no possibility of a 8
criticality.
9 The overall conclusions of the PEIS do not change 10 because there is some residual I'uel in the reactor vessel.
11 The next comment deals with worker exposure and, in 12 our judgement, is the principal issue with regard to what to do 13 next.
14 In response to this draft EIS,-we have recently j
15 completed an analysis of occupational exposure, and we're s.
16 providing that to the NRC.
i 17 It indicates a significant larger person rem savings 18 from PDMS than indicated in this draft.
And that, of course, 19 increases the Alara incentive to do PDMS.
20 Consistent with the original PDMS, occupational 21 exposure and savings is a dominant consideration in evaluating 22 PDMS.
23 The significant reduction in occupational exposure i
24 more than off-sets the maximum hypothetical environmental 25 impacts from PDMS.
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The NRC's numbers were simply extrapolated by saying 2
additional clean-up could be performed in four years.
And in 3
four year's time we would achieve radiation exposure at the 4
same rate that we're doing it now per year.
5 Our study actually goes in ar d takes a look at how 6
you would do tasks, where you would do them, what would be 7
removed, how many people would be required.
8 We've broken that down in reactor building work, aux 9
building work, fuel handling building work, rad waste 10 management, and then the PDMS monitoring task.
11 And our estimate -- and these are ranges -- is that 12 for the immediste clean-up case, our calculations indicate that 13 the man rem exposure for that case would be somewhere between 14 7200 and 15,500 f
15 So about 7,000 to 15,000 man rem..The red number 4
16 there is the number in the PEIS.
We would say that the'NRC 17 underestimated that by a Zactor of four or five.
18 In the PDMS case, we estimate the man rem expenditure 19 for the NRC scenario to be 2700 to 5800.
They said 45 to 1500.
20 So our estimated savings in man rem exposure by opting for the 21 PDMS proposal is somewhere between 4500 and 9700 man rem.
22 Whereas, they include in this EIS 255 to 1600 man 23 rem.
So while the immediate case, as opposed to the delayed 24 case is about a factor of two higher -- and we agree with that 25 factor, too -- but we say they understate all the values by a Heritage Reporting Corporation (202) 628-4888
29 1
factor of four to five.
2 It just strengthens the conclusion that the man rem 3
difference is the principal difference which separates the 4
cases for which the decision should be made.
5 The next comment had to do with the practicality of 6
continued near-term work.
The immediate clean-up case is a 7
satisfactory but hypothetical bounding case for environmental 8
assessment.
9 In other words, it can be used to see if there is any 10 first order environmental difference between this and the PDMS 11 case.
12 But it is not planned to the point that it is an 13 alternative which could be implemented, has not been designed 14 or detailed.
l 15 In our judgement, additional decontamination work t'
16 passed the end point that we've established for PDMS would 17 likely require the use of destructive techniques.
18 In effect, it would be a new program similar to 19 decommissioning.
Major pieces of equipment would be removed 20 from the erected building.
21 Presumably, the most efficient way to do some of 22 those is use of explosives.
And so it would be very similar to 23 de-commissioning kind of activities.
24 Large quantities of waste would be generated.
And of 25 course they do have large quantities of waste in the EIS for Heritage Reporting Corporation (202).628-4888
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1 these alternatives.
2 The current low-level waste disposal sites and 3
allocations under the low-level waste policy act are really not 4
set up yet to accept these kinds of large volumes of normal and 5
abnormal waste from TMI-2, and so there would be an 6
institutional issue that would need to be addressed in 7
connection with near-term additional work.
8 And in addition to the PDMS etorage case resulting in 9
lower exposure to workers, as radioactivity decays, the total 10 volume of future rad waste, which would have to be handled and 11 disposed of, would be similarly reduced by the decay of 12 radioactivity.
13 In the EIS, there is a table in the summary called 14 S1.
We have a number of comments On that table.
The first C
15 comment is that the two cases, the delayed case and the
(
16 immediate case, really should be compared on the same time 17 scale.
18 In other words, the PDMS cases in the NRC terms would 19 be 20 years of storage followed by four years of additional 20 clean-up, 24 years.
21 The immediate case should then be four years of 22 additional clean-up now followed by 20 years of storage.
In 23 other words, two 24 year cases.
24 I use these years because that's what they use.
Our
)
i 25 estimate for PDMS was till the end of Unit l's life, which we Heritage Reporting Corporation (202) 628-4888
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currently would estimate as 30 years from now, 2
But we believe the two cases -- when put on the same 3
time scale -- give you a better basis for evaluating them.
We
]
4 think it's worth comparing the radiological consequences in 5
these tables to that which natural background radiation 6
exhibits in this area.
7 And then we would divide the table into three tables 8
because they are three separate considerations in that one 9
table.
10 And the next three tables are how we would do it.
11 And I'm saying the NRC should exactly do it because it points 12 out our points.
I 13 The first one is radiation dose impacts -- the first 14 third of the table.
The top line has to do with radiation I
c 15 exposure to workers.
That's the mar rem estimates that I C'
16 mentioned earlier with the immediate case of being about a 17 factor of three higher than the delayed case, and the numbers 18 I've summarized earlier.
And there's no natural background to 19 compare that to.
20 The off-sight exposures to the public are essentially 21 the same numbers that the NRC used.
And we include the 22 national background over that same 24 year period.
23 And similarly, for the maximum e'xposed populations, 24 again, the two cases with regard to off-sight population 25 exposures are essentially the same.
Heritage Reporting Corporation (202) 628-4888
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The second -- or the next third of the table has to g
do with potential health impacts.
And this is the calculation 2
3 using standard techniques for converting radiation exposure to 4
potential health effects.
5 And again, the two cases have a-potential cancer 6
consequence to off-sight populations of much less than one, 7
.001 and.0004, as compared to the natural instance of cancer 8
in this population over the next 50 years, which is around 9
352,000.
10 The worker exposure are little higher numbers.
In 11 the PEIS case,
.4 to
.8, and the immediate clean-up case one to 12 two, again, the ratio roughly the same as the difference in man 13 rem, the natural instance of cancer in this thousand member 14 worker population over the next 50 years is.160.
(
15 Genetic disorder calculation is calculated roughly 16 the same way.
And again, it's basically in the worker 17 population.
They're the ones that get the major exposure.
18 And to understand what these risks are, the immediate 19 case results in a cancer risk to an individual of one in two 20 billion.
21 The immediate case is one in five billion.
The 22 natural instances is, of course, one in six.
The genetic order 23 numbers there are one in 27 million and one in 11 million, as 24 opposed to one in ten.
25 Incidentally, the genetic disorders are calculated Heritage Reporting Corporation (202) 628-4888
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for the next five generations of this population.
So it goes 2
out about 100 years.
3 And the last part of the table would be other 4
impacts.
Generally, these impacts are not major consideration 5
in EIS, but are of an informational nature.
6 The first one is what kind of cost we're talking 7
about.
And when you add 20 years of monitored storage to the 8
immediate clean-up case, you end up with the two cases costing 9
roughly the same.
10 And these are the NRC numbers.
We have not made cost 11 estimates.
But we believe they're satisfactory for EIS 12 purposes, for comparative purposes.
13 But we believe that that work would be done cheaper 14 than this.
And it's 200 to 320 million in the delayed case, y
15 the PDMS case; and 240 million to 320 million in the immediate t-16 case.
17 And then the radioactive waste volumes are the same 18 as they've used, the trap ax (ph), and so forth -- the same as t
19 they've got in their draft.
20 General Comment 7 speaks to the simultaneous de-21 commissioning of Unit 1 and Unit 2, which is our basic 22 proposal.
23 The PDMS assures continued safe and stable-TMI-2 24 plant condition until de-commissioning of Unit I where the two 25 would be de-commissioned together.
Heritage Reporting Corporation (202) 628-4888
34 1
The clear advantages are that the possibility-of de-2 commissioning activities in TMI-2 would not effect Unit 1.
And 3
recognizing that major structures are common, decontamination 4
techniques that are developed today include use of explosives, 5
and that sort of thing, which would not be practical in this 6
case.
7 So it's not too practical to try to de-commission 8
Unit 2 while Unit 1 is still running.
And then of course the 9
work force that would do the job could be more effectively used 10 if they simultaneously decommissioned both units.
11 And the NRC de-commissioning rule, which was issued 12 last month specifically recognizes this consideration when 13 there are more than one nuclear reactor at the same sight, and 14 allows for the two te be handled together as we would propose f
15 here.
E 16 And the last point is our overall conclusion, which 17 is that based on the NRC conclusions stated in the draft PEIS 18 and the results of our recently completed analysis of 19 occupational exposure for their two cases, we concluded PDMS is 20 clearly the preferred alternative.
21 And we've got a number of detailed comments in the 22 letter also.
But this is the principal issue that we've tried 23 t
frame in our letter.
24 Be glad to answer any questions.
And then we have 25 ao more presentations in our segment here.
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(Pause) 2 MR. RICE:
Frank?
3 MR. STANDERFER:
Yes.
4 MR. RICE:
Could you tell me what Alara means again?
5 MR. STANDERFER:
As low as reasonable achievable, 6
which means, with regard to radiation exposure, you plan to 7
remove this pump.
8 And you go in and measure the radiation levels.
You 9
analyze step-by-step how you're going to do that, and how many 10 workers are going to do that.
11 Then radiation engineering people look at that and 12 say, if you put some shielding over here, and if you train 13 these fellows on a mock-up, you can do this job at lower total 14 exposure than you're planning to use.
15 So then you debate that back and forth.
And you 16 attempt to arrive at a method of removing that pump which 17 reduces the radiation exposure to workers.
18 You may use shielding.
You may use long-handle 19 tools.
You may use mock-ups to practice on so you can do it 20 very rapidly.
21 There's a number of techniques.
And the NRC 22 regulations require that every job we do be done in a manner 23 which uses reasonable techniques to minimize the exposure to 24 workers.
That's Alara.
25 And we're saying here, in the big picture, it is Heritage Reporting Corporation (202).628-4888
36 1
Alara to store this plant for some period of time, 20, 30 2
years, and it results in major reduction. exposure to people, i
3 MR. MORRIS:
Thank you.
4 Ken?
5 MR. MILLER:
Frank, on Page 8 of your report-you 6
indicated that the delay alternatives would result in lower 7
volumes of rad waste.
8.
But on Page 12 it would look like, from your second 9
row of numbers, the reverse effect.
10 MR. STANDERFER:
We've used the NRC numbers.
Those 11 come directly out of the report.
We have not made any volume 12 estimates.
13 If we did make a volume estimate, we would estimate a 14 smaller rad waste volume in the PDMS case due to a number of 15 volumes of waste --
would be de minimis because of the g-16 radioactivity decay.
17 We believe the techniques of compaction will be 18 developed over the next 20 to 30. years, which would allow to i
19 compact waste more effectively.
l 20 We believe that a number of things like that could 21 result in the waste being smaller.- That's not a guarantee, but 22 it's a prediction.
But in the table we ended up using the 23 NRC's numbers.
24 MR. MORRIS:
Frank, you mentioned there'd be two 25 other presentations.
Heritage Reporting Corporation (202) 628-4888
37 1
MR. STANDERFER:
Yes.
2 MR. MORRIS:
Could you tell me who they would be and 3
how much time you think you may need?
4 MR. STANDERFER:
I think the total is another 15 to 5
20 minutes of my boss, the Executive Vice President of GPU 6
Nuclear, Ed Kinter, has a brief statement to make.
7 And then we have the chairman of one of the safety 8
review boards that he would like to introduce.
9 MR. MORRIS:
Okay.
I'd like to move right into that.
10 If we could probably stay within that 15 minute period of time 11 for both it would be helpful.
12 MR. STANDERFER:
I'd like to introduce Ed Kinter, my 13 boss, the Executive Vice President of GPU Huclear.
14 MR. MORRIS:
Good evening, Mr. Kinter.
Welcome.
/
15 MR. KINTER:
Good evening, sir.
How are you?
16 MR. MORRIS:
Fine, thank you.
17 18 STATEMENT OF ED KINTER, EXECUTIVE VICE PRESIDENT, GPU NUCLEAR 19 MR. KINTER:
I'd like to first make a statement with 20 regard to one of the issues that was raised at the last 21 meeting, end which was also discussed on the radio interview 22 with you and others this week on WITF.
23 And that has to do with funding 'for any eventual de-24 commissioning of TMI-2, 25 As you know, this company has the responsibility for Beritage Reporting Corporation (202) 628-4888
38 1
health and safety of the public.
It has exercised that 2
throughout the nine years in the aftermath of the accident, 3
including providing the funding through various means, which 4
has kept the project moving at the maximum practical rate.
5 And as of today there are something more than 1,000 6
people working seven days a week, three shifts a day, and 7
they're being paid.
8 Now we have very carefully considered this matter, 9
associated with funding for the eventual de-commissioning.
We 10 understand the issue.
We believe it's an appropriate one, and 11 we're prepared to say as follows.
12 The statutes of the United States require that a 13 licensee be responsible, financially as well as otherwise, for 14 the health and safety of the plant, any licensed reactor,
(
15 including TMI-2.
16 Recently, the NRC issued a rule on de-commissioning 17 which requires by July 1 1990 that every licensed plant, every 18 nuclear operator provide a funding plan for the eventual de-19 commissioning of this plant or plant.
20 And we propose to do that.
We'll expect under that 21 rule to set forth by July 1990 a plan to ensure that funds will 22 be available for the eventual de-commissioning of TMI-2.
23 And that plan, whatever it is, will have to be 24 acceptable to the NRC.
The rule calls for any such plan 25 providing de-commissioning funds to be kept separate from Heritage Reporting Corporation (202) 628-4888
39 1
company control, company assets, and outside the administrative 2
control of the company.
3 I believe that should adequately answer the question 4
of financial responsibility for whatever de-commissioning will 5
eventually take place whenever it takes place.
6 MR. MORRIS:
Let me understand that.
7 When you're talking about de-commissioning under the 8
PDMS format 20 years from now, or whenever, there would be some 9
required additional clean-up and de-commissioning.
10 You're talking about a funding plan that would 11 accomplish that as one of further cleaning as well as de-12 commissioning --
13 MR. KINTER:
I'm talking about all that is required 14 to go from PDMS to eventual de-commissioning of the plant --
(
15 through an eventual de-commissioning of the plant.
i 16 I'm sure that we would intend it to be on that basis, 17 and we would fully expect the NRC not to accept it,'unless it 18 was provided on that basis.
19 MR. MORRIS:
So again, to repeat, in my terms, I 20 understand that any plan that would be submitted for July 1990 21 l
22 MR. KINTER:
Yes.
23 MR. MORRIS:
-- would include a plan that would 24 include, funding-wise, PDMS requirements, as well as what would 25 be understood by the NRC to be de-commissioning.
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MR. KINTER:
That's correct.
l 2
MR. MORRIS:
The only reason I_ raise that is because 3
we, as a panel, I think have looked at two separate items.
And 4
we may be looking at it incorrectly, but I think we're looking 5
at it because of the way that PEIS was --
6 MR. KINTER:
No, that's the way the PEIS was written. -
7 I think that is an incorrect way to look at it.
It is not 8
practical in our view to move from where we are today to the 9
condition which they've used.
10 And Frank made the point that our evaluation of what 11 comes from here to de-commissioning is different from the one 12 presented in the PEIS.
13 And so I mean, and I repeat, from PDMS through de-14 commissioning.
That's what I'm talking to.
And that's what we
[
15 would intend to include in the plan.
t.
16 MR. MORRIS:
Just to be clear, and I just want to put 17 this on the record, when I was talking at the last meeting, and 18 my discussion since then has always looked at two actions that 19 the PDMS.
N 20 After the 20 year period is up there would be some 21 kind of additional clean-up required, and then de-22 commissioning.
23 And that the NRC's new action that was required would 24 be submitted in July of 1990, would only be in regard to the 25 second part of that, which would be the de-commissioning part.
Heritage Reporting Corporation (202) 628-4888 i
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I'm hearing you say that they can't really be 2
separated.
That they should be linked; you think NRC would 3
link them.
And therefore, any funding plan submitted in July 4
of 1990 would include all of the above.
5 MR. KINTER:
That's correct.
6 The NRC carrying out its responsibilities, I'm sure, 7
would view it that way.
And we would expect them to.
8 FR. MORRIS:
I may have some questions of the NRC 9
personally at some point on what a funding point is, and how 10 definitive that is, because it's an area that I really want to 11 understand better.
12 MR. KINTER:
Right.
13 MR. MORRIS:
Does anybody else have any questions for 14 the panel on that point?
15 MR. RICE:
Mr. Chairman, I have a question.
16 What is the definition of de-commissioning, and what 17 takes place?
MR. KINTER:
Well, that's 'part of the uncertainties 18 19 in all this with regard to what really is de-commissioning.
20 And when I talked to de-commissioning in this case, I talked to 21 whatever is required in de-commissioning for any other licensed 22 plant.
23 For example, TMI-1 -- any undamaged plant.
Whatever 24 would be required in that case we would expect to do for TMI-2.
25 MR. RICE:
Do we know what's required?
Heritage Reporting Corporation (202),628,4888
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MR. MASNIK:
Yes.
2 If you'd look on -- each member of the panel has been 3
provided with a copy of the de-commissioning rules.
Look on 4
Page -- if you look on Page 24, 020.
5 It states there that alternatives for de-6 commissioning provide different ways to accomplish de-7 commissioning as defined in the rule.
8 Alternative ways of reduced residual radioactivity to 9
levels permitting release of the property for unrestricted use, 10 and termination of the license.
11 So it's geared with unrestricted, or geared to 12 unrestricted use of the property -- ultimate unrestricted use 13 of the property.
14 MR. RICE:
Thank you.
15 MR. MORRIS:
Anybody else have a question on that 16 point that Mr. Kinter made?
17 If not, we --
18 MR. KINTER:
Then I would like to introduce the 19 chairman of the TMI-2 Safety Advisory Board.
Before doing so, 20 I'd like very quickly to tell you what that board is.
1 21 It was established in 1981, shortly after the l
22 accident to provide a high level appraisal of the technical 23 scientific aspects of the probe, and particularly worker and 24 public health and safety made up of eminent scientists of l
25 several disciplines.
t Heritage Reporting Corporation (202) 628-4888 l
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'43 1
They work closely with us but they maintain their i
2 independence from us.
Their conclusions are written after each 3
meeting, and the recommendations provided to me.
4' And their answers in writing, each such 5
recommendation, each time there is such a meeting.
6 Once a year they meet with the GPU, the General 7
Public Utility Board of directors and tell them how they feel 8
the clean-up is being handled from a safety point of view.
9 And once a year for the last three years they've also I
10 met with the nuclear regulatory commissioners and told them the 11 same thing.
12 They also have sub-panels, one of which has dealt 13 with PDMS, which has followed much more closely than the safety 14 advisory board as a whole, but has been going on, and Dr.
[
15 Marston is going to talk to that point.
16 I'd particularly like to call your attention to 17 qualifications of Dr. Marston.
When this board was 18 established, it was chaired by James Fletcher who was recalled I
19 to the administration of NASA after the satellite shuttle 20 accident.
21 And we had a very difficult time finding someone with l
22 the technical and managerial capability to fill shoes like 23 that.
And we were very fortunate to find Thr. Marston.
He was 4
24 willing to help us.
25 He is a graduate of Oxford an a Rhodes Scholar.
He's Heritage Report
'~ r 7orat i.o!.1 (202) e 4
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U 44 1
a graduate of the Medical College of Virginia.
He was, for 2
five years, tl.e director of the National institutes of health, 3
and was, for a number of years, the President of the University j
i 4
of Florida system.
5 He is currently President Emeritus and Professor of j
1 6
Medicine at the University of Florida.
He's a member of the 7
National Academy of Sciences Institute of Medicine.
And as a 8
mumber of that group he has recently participated in 9
preparation of a report which deals with the medical 10 implications of nuclear war.
11 He's known worldwide as a physician, and as a man who 12 understands medical effects of radiation.
So we're very 13 pleased to have Dr. Marston.
14 And I'd like to have him now tell you what he and his 15 board hhve concluded about PDMS.
Bob?
t 16 DR. MARSTON:
Thank you, Ed.
l 17 MR. KINTER:
You're welcome.
18
)
19 STATEMENT OF DR. ROBERT Q. MARSTON, CHAIRMAN, TMI-2, SAFETY l
20 ADVISORY BOARD 21 DR. MARSTON:
Mr. Chairman, members of the panel.
1
{
22 I really have three things to present.
One, an l
l 23 overview of some of the concerns the Board has had, and then a f
l 1
24 statement that I made on March 17th of this year to the Nuclear 1
25 Research Regulatory Commission, and then a summary of my Heritage Reporting Corporation (202) 628-4888 l
45 j
1 presentation.
2 As you have noted from what Ed has said, my expertise 3
is not in the nuclear field.
I am surrounded in the Safety 4
Advisory Board, though, by people of international renown in 5
nuclear scientific and essociated fields.
6 Just an example of the quality of these people, five 7
of them are elected members of their appropriate component of 8
the National Academy of Science.
9 One is a member of the National Academy of Science, 10 or members of the National Academy of Engineering, and one is a 11 member of the Institute of Medicine in the National Acedemy of 12 Science.
13 Others, of course, don't fit into the category of the 14 National Academy of Science such as those who are experts.in y
15 risk management and public policy groups.
(
16 But it is a stimulating and excellent group that I am 17 pleased to work with.
18 This board has conducted an extensive review of post 19 de-fueling monitored storage.
And Connie, if you can show, 20 we've looked at it since it was first conceived in 1985.
A 21 panel chaired by Professor Rasmussen of MIT have analyzed and 22 made a report to the full board for discussion, j
23 We've looked at the overall parameters set forth at 24 ITT*JN or PDMS.
We've looked at the implications for potential i
25 hazards to the public, or the plant workers.
l Beritage Reporting Corporation i
(202) 628-4888 i
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l 46 1-We've looked at the implications for remaining' fuel.
2 We've looked at the implications of residual radiation or 3
radioactivity levels in the plant.
4 We've looked at the radiological and environmental 5
monitoring plans, as well as operations and maintenance 6
proposed for PDMS.
7 And we've looked at the technical and safety aspects 8
of PDMS.
As a result of these studies, we have produced a 9
segment that was agreed to by every member of the safety 10 advisory board.
11 And this is what I would really like to address to 12 you tonight.
In our November 5th and 6th meeting in 1987 we 13 made the following statements.
I 14 Post de-fueling monitored storage has been analyzed s
(
15 in-depth by the Safety Advisory Board, TMI-2.
I don't need Q,
16 that yet.
17 The Board has agreed that PDMS is an acceptable TMI-2 18 plant condition that when achieved would pose no hazards to l
19 public health and safety.
20 Upon further Board review of PDMS at a subsequent SAB 21 meeting in February of 1988, it became apparent that in light 22 of the extensive SAB reviews and deliberations are the 23 technical and safety aspects of PDMS, documentation of the 24 basis of this statement was necessary, i
25 As Ed has said, the SAB's choice was oversight of the i
Heritage Reporting Corporation (202) 628-4888
j 47 l
1 actions of GPUN mana*4 F S. insure that those actions I
2 relating specificalls clean-up of the damaged plant did j
u 3
not jeopardize the health and safety of the public and workers.
\\
4 These actions sometimes require decisions which 5
involved trade-offs between health and safety, and some limited 6
low-level radiation exposure of the public and the works.
7 For example, when extremely small amounts of krypton 8
gas were released to the environment, in order to improve the i
9 ambient air quality within TMI-2 containment buildings, and 10 thus reduce the potential radiation exposure of workers who J
11 were to gain entry to begin the clean-up operations.
12 Whatever the cost of such trade-offs and personnel j
13 exposure, there has been no adverse effect on public health and 14 safety.
p' 15 Although protection of the health and safety of the
\\"
16 workers is a matter of highest priority.
The SAB must continue 17 to exercise a considerably greater responsibility in its 18 concern of the effects of the clean-up on the health and safety i
l 19 of the public.
1 l
20 The 1979 accident at TMI-2 left the interior of the i
21 reactor building so contaminated with radioactivity that entry 22 by clean-up crews were not possible without extensive 23 preparations and precautions to minimize exposure.
24 Although the radioactivity has been confined within 25 the building since the accident, except for the planned release Heritage Reporting Corporation (202) 628-4888 t
i 48 1
of small amounts of krypton soon after the accident, there was 1
2 a small but finite possibility during the first post-accident j
3 months of much lower levels of radiation exposure to nearby 4
residents.
5 A truly remarkable job has been accomplished in these 6
past nine years on the insignificant and negligible exposure of 7
the public that occurred, as well as remarkably limited 8
exposure of workers who have been carrying out the clean-up.
9 This has been achieved by judicious care, planning, 10 deliberate steps, and appropriate decision-making.
GPUNC 11 management has directed the allocation of solvable funds for 12 the protection of workers and the public.
13 Decisions were always in our view in the direction of 14 being overly safe.
Until recently, the quantity of damaged
(
15 fuel that has been present in the reactor vessel has been 16 sufficient to require precautions against any inadvertent 17 criticality occurrence, though the probability of occurrence 18 was extremely small.
19 A significant milestone will be achieved in early 20 1989, when more than 99 percent of the damaged fuel will have 21 been removed from the reactor and shipped to the U.S.
22 Department of Energy, National Engineering Laboratory in Idaho.
23 The remaining small amounts of fuel debris in the 24 reactor system represent only a small fraction of the original 25 fuel, and will pose no threat to criticality or radiation Heritage Reporting Corporation (202) 628-4888
l 49 1
1 exposure of the workers and the public.
2 At this stage there will no longer be a need for 4
3 special precautions, such as maintain borated water in the 4
reactor vessel.
5 This does not mean that the plant interior has been 6
fully decontaminated, and that no radioactivity remains.
7 During the PDMS phase, workers will have access to most of the 8
plar.t without protective clothing and with little exposure to 9
radiation.
4 10 The reactor building basement, and a few places in 11 the fuel handling building will remain radioactive to the 12 extent that workers will not be permitted access to these 13 areas.
14 Now there appears to be no reason for workers to
[
15 enter these more contaminated areas when the PDMS phase has i'
16 been reached.
17 To ensure the health and safety of the public, as 18 well as the TMI-l workers, TMI-2 plant conditions during PDMS 19 phase will be monitored continuously to preclude the 20 development of any unforeseen circumstances, j
21 Once assurance is present, that there is no potential 22 hazard for the public health, GPUNC management must decide what 23 still must be done concerning further clean-up of a small 24 amount of contamination remains.
25 Should it continue to proceed vigorously, sending 1
Heritage Reporting Corporation (202) 628-4888
4 50 1
additional tens of millions of dollars to improve the condition 2
of the reactor building basement and other areas beyond the t
3 endpoint levels rejected in the licensing documents.
4 And here, Mr. Chairman, I think sort of the heart of 5
my statement coming up in the next three sentences.
6 If it were the intention of GPU management to use the 7
containment building or any heat producing facility some time 8
in the future, then there would be valid reason to continue to 9
reduce radiation levels in the remaining more radioactive 10 areas.
11 Since the radioactivity is in an immobilized state 12 within the basement walls and structures, and since GPU has 13 announced that no plan is under consideration to rebuild and j
14 restart TMI-2, there appears to be no rational basis to j
i
/
15 continue to subject workers to unnecessary radiation exposure c
16 beyond that currently needed to remove the damaged fuel.
17 Therefore, the most responsible plan in the view of 18 the SAB would be to go into PDMS.
PDMS would be protective of 19 the health and safety of workers, as well as the public.
20 The prolonged duration of the time under PDMS would 21 allow for additional natural decay of the remaining 22 radioactivity.
23 When the time has come to de-commissioning the TMI-1 24 plant well into the future, steps can be taken to remove any
(
25 remaining radioactivity in the TM1-2 containment and associated l
Heritage Reporting Corporation a
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1 j
51 1
buildings.
2 In the intervening years, the residual activity will 3
have been further reduced by natural decay to principle 4
radioactive products.
Cesium 137, strontium 90, will have been 5
decaying at the rate of 2 1/2 percent per year.
6 The radioactivity remaining after approximately 30 l
7 years will have been reduced to the present levels.
It's also 8
anticipated that advanced robotic systems will be available to 9
further reduce potential exposure of workers expected in the 10 decontamination of the TMI-2 reactor plant in preparation to 11 de-commissioning the facility.
12 Now this represents a consensus statement of all 13 members of the TMI safety advisery board.
And you can see that 14 slide.
I'll simply repeat the four main points which we have 3
15 said to the NRC.
i 16 Post de-fueling monitored storage has been analyzed 17 in depth by the Safety Advisory Board, TMIT.
The Board has 18 agreed that PDMS is an acceptable condition, that when achieved j
19 would pose no hazard to the public health and safety.
j 20 The limitations placed on the anount of fuel that can 21 remain in the plant ensure that no conditions exist of 22 criticality.
23 The residual radiation or radioactivity levels of the 24 plant that are potentially releasable off-site during PDMS are 25 likewise believed by the Board to pose no threats to the Heritage Reporting Corporation (202) 628-4888 l
i
i0 l
52 4
1 public.
2 During the PDMS phase, workers would have access to 3
most of the plant without protective clothing, and with little 4
exposure to ra diation.
5 But t ue reactor building, and a few places in 6
auxiliary, and the basement buildings, will remain radioactive 7
to the extent that workers would not be able to enter these 8
areas.
9 There would Le no reason to enter these areas.
10 As I said at the beginning, this is not my area of 11 expertise.
But at any time in the future, Mr. Chairman, or 12 members of the panel, if you would like to have individual 13 members with such expertise to appear before you, or to make 14 reference statements backing this up, then I would be glad to 15 g
help provide that.
16 Thank you very much.
17 MR. MORRIS:
Okay.
Can I just ask one question?
s 18 I do thank you for coming here tonight, and for 19 making the presentation, but I see nothing in your presentation 20 that speaks to the likelihood of funding being in place.
21 When you make the statement that there appears to be 22 no rational basis to continue to subject workers to unnecessary
(
23 radiation exposure beyond that currently needed to remove tne 24 damaged fuel, have you looked at tha likelihood of monies being 25 in place 20 years from now, versus immediately?
Heritage Reporting Corporation (202) 628-4888 l[.
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DR. MARSTON:
Yes, sir.
We have one member of the 2
panel whose expertise is in management economics.
And he has t
3 brought, at the'last two meetings of the SAB, this question up.
4 We've had discussions of that question with Phil 5
Clark, and with Ed Kinter.
And we've received the same C
information that you heard from Ed tonight.
7 MR. MORRIS:
And you received that information prior 8
to the statement being prepared?
9 DR. MARSTON:
It was during -- actually, the 10 statement -- well, I didn't know the statement he was going to 11 make tonight until he made it.
12 But he has said to the SAB that it is the 13 responsibility which the company accepts to make the same 14 financial arrangements for eventual de-commisazoning that are 15 required in any other plants.
g t
16 MR. MORRIS:
I just am particularly interested in if 17 you have minutes of your deliberations that speak to the 18 funding question prior to this action.
This statement that j
19 you've made, there appears to be no rational basis.
20 I would be interested in seeing those minutes of i
21 those deliberations.
22 This specific recommendation includes the kind of 23 financial information we have been given tonight.
I'm 24 particularly interested in that because it's pretty strong 25 statement Heritage Reporting Corporation c
(202).628-4888
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DR. MARSTON:
Right.
I would be glad to review the 2
minutes of our February meeting, i
3 It is my memory that we did have discussions of the 4
funding issue as this was being prepared.
That was questioned 5
in the Safety Advisory Bo 3 about_ exactly where the 6
responsibilities lay in having the primary responsibility for 7
safety.
8 We did bring it up either in the February neeting, or 9
in our later meeting with Mr. Kinter..And so, I will find out i
10 whether it was in February or whether it was after March.
l 11 MR. MORRIS:
Simply, my question is based on whether 12 this statement includes the kind of consideration on funding 13 that has been outlined by Mr. Kinter, or whether it does not.
14 DR. MARSTON:
The statement does not.
15 MR. MORRIS:
It did not include a discussion to that 16 level?
)
17 DR. MARSTON:
Not in this statement.
But we have had 18 19 MR. MORRIS:
Well, p::ior to voting.on this statement, 20 the consensus decision --
21 DR. MARSTON:
Right.
22 MR. MORRIS:
-- were the members informed to the 23 level of the funding matter today or not?
That's what I 24 particularly mean.
25 DR. MARSTON:
I will be glad to look at our february Heritage Reporting Corporation (202) 628-4888
i M.
55 1
minute meetings.
2 MR. MORRIS:
Because if they were not, and it seems 3
to me their decision is based'less on funding and more on other 4
safety evaluations, and not as much-on funding.
5 DR. MARSTON:
And I think.that the real question is 6
where our responsibility lies in that.
7 MR. MORRIS:
That's all I'm trying to clear up, sir.
8 DR..MARSTON:
Right.
9 MR. MORRIS:
I just want to be clear on whether the 10 statement includes detailed concideration of future funding, or 11 whether it does not include that.
12 DR. MARSTON:
All right.
13 MR. MORRIS:
I'm not trying to give you a difficult 14 time.
I just want to be clear.
15 DR. MARSTON:
I understand because it has been a key i
16 point of discussion.
It has been for the Board.
17 MR. MORRIS:
Thank you.
Arc there any other 18 questions of Cr. Marston?
19 Thank you very much.
20 DR. MARSTON:
Thank you.
21 MR. MORRIS:
We appreciate your presence.
22 At this point in the agenda we do have panel working 23 sessions on PDMS, whatever that means.
Now-I guess what I'd 24 like to do is get comments from the panel.
25 And maybe to begin them, I would at this time try to Heritage Reporting Corporation (202) 628-4888
k 56 1
provide some coniments that were given by Tom Gerusky,
.f that 2
is okay with you, regarding his assessment of this point.
3 Now his comments, ebviously, were not based'-- were 4
based on information that he had coming prior to this evening.
5 So he didn't have the benefit of anything that was presented 6
tonight.
7 But his comments in no special order -- and I'm not 8
going to try to include all of them, but I'll include as many 9
as I can read from my notes that I took during the discussion 10 witn him today.
11 He feels that the panel should wait until the NRC has 12 received GPU's projection on worker exposure.
And we heard 13 some of that this evening, but he feels we should wait until 14 the NRC has reviewed them.
/
15 And he'd like to see or hear comments from the NRC k..
16 regarding the new information on worker exposure.
He would 17 like to see or hear that prior to our acting on this particular 18 issue.
19 He says that unless there is more substantial 20 reduction to workers as far as exposure is concerned -- and-he I
21 feels that is the main issue before us, is whether you delay 22 through PDMS the clean-up and de-commissicning, or whether you 23 proceed with it now.
24 He thinks the issue really revolves around the worker 25 exposure question.
And he feels that unless it can be 4
Heritage Reporting Corporation (202) 628-4888 3
m.
57 1
substantiated more clearly than it was in the PEIS -- and I 2
think this is fairly a statement that he gave -- unless it can i
~
3 be substantiated that there would be greater savings to workers 4
than have been in the PEIS, he doesn't really see the purpose 5
in waiting for the clean-up.
6 He was concerned about the kind of fire protection 7
systems that would be in place that weren't spoken to in the 8
PEIS.
9 He also expressed a concern about the inventory of 10 radioactive materials.
And I believe he's talking about 1
11 further documentation on that.
12 He wants to make sure that the criticality question
~
13 is not a problem.
He was concerned also on the funding, that 14 we make sure that there is mechanism for funding in place if we j
15 do go to PDMS that assures that money will be in place at the
(
16 time that it's needed.
17 And he expressly concerned that the utility has not 18 submitted its safety analysis report prior to the PEIS being 19 completed.
And that is -- I guess it's a preliminary safety 20 analysis report.
He thought that it was putting the cart 21 before the hurse doing the PEIS and not doing the preliminary 22 safety analysis report first.
23 There are just some points that he made.
He 24 indicated to me that he felt from his perspective, while he 25 can't vote this evening, if anything would come before us, he i
Heritage Reporting Corporation q
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thought that we ought not to proceed with a vote on this issue 2
because he felt more information needed to be made available to 3
us.
4 And with that input that he asked me to provide, I j
5 would be happy at this point to see if any other panel member 6
wanted to offer comment as part of where do we go from this 7
point as a panel, i
8 Obviously, we do want to receive public inputs 9
tonight.
The intent is not to leave the public out.
Yet the 10 idea right now is to have some discussion from the panel.
11 If anybody want's to make an observation, take a 12 break, come back, we'll have public comment, and then determine 13 whether we really need to take any action this evening, and if 14 so what kind of action, 15 MR. RICE:
Mr. Chairman, what is1the objective of our g
16 discussion?
Is it to prepare the NRC with an advisory 17 decision?
18 MR. MORRIS:
Well, I believe that that is one of the 19 main reasons.
Forgetting the NRC as a commission, the meeting 20 we have with them next month, forgetting that for a moment, any 21 document that's been produced as part of the clean-up -- and 22 this PEIS is one of them -- we have normally been asked to 23 review that document and give ccmments.
24 Our comments could be that we take no action on it; 25 we have no comment.
Or we could support the findings. Or we Heritage Reporting Corporation (202) 628-4888 l
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59 1
could disagree with the findings.
2 So what's really before us at'this point is the 3
document -- what do we do with the' document.
Certainly, we 4
have a meeting with'the NRC next month.
5 It would be helpful in discussing with tham a 6
position that we might have on this document if we'are 7
preferred to present them at that meeting.
But if not,.we can 8
tell them what we've decided to that point.
9 But I think the major thing before us tonight is do 10 we want to at this point take any position on this document.
11 Do we have any questions we would like to ask regarding the 12 document?
Is there more information we would like to have?
So 13 that at some point prior to the deadlines, we at least have 14 considered making some comment on the document.
15 And Mike, remind me, if you would, what, at this the 16 date is for the comment on it?
17 MR. MASNIK:
The comment cut-off date would be the 1
18 fiist of August.
So essentially, it would be comments that you 19 generate tonight, and anything in writing that you would get to 20 me between now and the end of the month.
21 MR. MORRIS:
Unless we would request a further 22 extension, and the NRC would provide it.
23 MR. MASNIK:
That's correct.
24 MR. MORRIS:
Is that right?
25 MR. SMITHGALL:
I have a question.
The fact that I Heritage Reporting Corporation (202).628-4888
h 60 1
think the workers have been exposed tremendously in this in not 2
favor of prolonging that, I still am concerned about the 3
funding, and if PDMS would be instituted.
4 Isn't it possible in the licensing amendment that 5
would be required here to put a proviso in for a sinking fund, 6
or funding for that eventual completion of what I would term 7
clean-up.
8 Is it possible to attach a rider on that amendment to 9
require that?
I'm asking the staff.
10 MR. MASNIK:
I guess that question is addressed to 11 me.
I really can't answer that at this time.
I would have to 12 check on that.
That's something that would be extraordinary.
13 To my recollection something like that has never been 14 done before.
15 MR. STOLZ:
Mike, let me --
3[.
16 MR, MASNIK:
Oh.
17 MR. STOLZ:
I'm John Stolz.
The safety of analysis 18 reports we're about to receive from the license board --
19 MR. MORRIS:
Sir, could you identify who you're with?
20 MR. STOLZ:
I'm John Stolz.
I'm with the NRC.
I'm 21 the director of the group to which TMI-2 review is assigned.
22 MR. SMITHGALL:
I think you may want to use that 23 t..ike.
24 MR. STOLZ:
As Mike said, we would not normally 25 involve the financial aspects of the SAR review with the review Heritage Reporting Corporation (202) 628-4888 s
61 1
of the SAR material that we' re about to receive.
]
2 The question of safety is the issue that we're going j
l 3
to be looking at.
The financial aspects, although it's i
4 important, is a separate action, j
5 We' re not saying we' re not going to look at it.
But 6
we propose that we would be looking at the safety aspects of 7
the PDMS, and simply review the financial aspects, j
l 8
MR. SMITHGALL:
When would that financial review 9
occur, at that outset of the SAR -- when the SAR is submitted 10 simultaneously with that analysis or 20 or 30 years hence?
11 I guess my problem is everyone has stated'that-there 12 really isn't any problem with the PDMS.
Nobody's really said 13 the funding's been talked about.
3 '.
Then they said that, yes, it has been talking about i
15 but nobody's said any numbers.
You can hear $200,000 in i'
16 today's dollars, or you could hear a billion dollars if you 17 look at 20 years from now.
18 My concern is -- when do you make that analysis and 19 how do you make it?
20 MR. STOLZ:
We'll have to get the information i
21 separately and review that as a separate matter from the PDMS 22 safety analysis review.
23 In other words, what I'm saying'is that I expected we 24 would be issuing a safety evaluation report on the PDM 3 safety 25 analysis report.
Heritage Reporting Corporation (202) 628-4888
)
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We would want to separately address the. issue of 2-financial responsibility as a' separate. matter with the l
3 licensee.
4 I don't have that.
5 MR. MORRIS:
Under what --
6 MR. MASNIK:
And I-think it would, though,.under the 7
de-commissioning rule.
The de-commissioning rule requires each 8
licensee two years from the issuance of.a rule a' plan that.
9 deals with de-commissioning funds.
10 MR. SMITHGALL:
I understand that.
That's a plan 11 that -- is it enforceable to the extent that you would require 12
--I read that, Mike, and I know where you're going to refer.
13 MR. MASNIK:
All the plan says is it provides a plan 14 for the securing of the monies required for de-commissioning.
/
15 And the Commission has presented certain guidelines as to how
'l 16 much money should be set aside.
17 And that amount presently is approximately $100 18 million for this facility, although there is an escalation 19 clause in that set aside on a yearly basis.
20 MR. SMITHGALL:
But that is for --
l 21 MR. STOLZ:
But that's two years from now.
22 MR. MORRIS:
Excuse me.
23 MR. STOLZ:
That matter is going to be given to us 24 two years from now.
25 MR. MORRIS:
Could I speak at this point?
1 i
Heritage Reporting Corporation (202) t 3-4888 l
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o 63 1
That implies a normal de-commissioning, as I 2
understand it.
3 MR. STOLZ:
That's right.
4 MR. MORRIS:
And it has not taken into consideration 5
the kind of PDMS circumstances that we're talking about here.
6 And so you talk about $100 milli ~on.
And then you talk about 2 7
or $300 million.
8 Additionally, I think what we're trying to do is 9
simplify from our perspective, and indicate that if you would 10 add that $100 million in normal de-commissioning costs in 11 today's dollars, to the 2 to $300 million additionally needed 12 for the clean-up, you have a number that varies between three 13 and four hundred million dollars, all of which we know is a 14 guesstimate in today's dollars.
[
15 And what I think Tom is asking -- what I've been 4~
16 trying to ask -- is at what point does that total cost which 17 involves what I just stated now, 3 to $400 million, when is 18 there a plan presented that both speaks to the funding of that, 19 and also guarantees the money is going to be in place, either 20 by a sinking fund that Tom Smithgall has indicated, or by some 21 other means.
22 How are we going to be assured -- just let me finish 23
-- how are we going to be assured either as a panel or a public 24 that when that mor.ey is needed it is going to be there?
25 Now we heard Mr. Kinter say that it would be required Heritage Reporting Corporation (202) 628-4888
64 1
to keep the money separate from other operating monies at GPU.
2 I don't understand really what that means.
In what fashion 3
would it be kept?
How would we be assured that the money would 4
be -- it's a moving target.
That's today's dollars.-
It's 5
going to move as interest rates change at its cost of doing 6
business changes.
7 It could be a billion dollars 20 years from now.
How 8
can we be assured that that's what the cost is going to be; 9
that there's going to be a billion dollars available to do that 10 total clean-up and de-commissioning?
11 That's really what we' re asking.
And if there's no 12 answer to it yet, say that, and maybe you can provide one at --
13 MR. STOLZ:
We don't have the answer to the financial 14 story now.
But I did want to say that notwithstanding that,
{
15 that we would still be proceeding separately with the safety 16 analysis of -- safety evaluation of the safety analysis we're 17 going to receive at the end of July.
18 MR. MORRIS:
We understand that.
. Tom is really not 19 getting into that.
I think he's getting into the money aspect.
20 MR. MASNIK:
One ot?er thing, and that is it was H
21 clear from the nice discussion -- Mr. Kinter had said that the 22 money for de-commissioning would be available.
23 Now there evidently is a problem in the definition of 24 de-commissioning.
We seem -- the NRC seems to chose to look at 25 the end of clean-up, and then a second stage of de-Heritage Reporting Corporation (202) 628-4888
65 1
commissioning.
2 And correct me if I' m wrong, ~ but Mr. Kinter seems to i
3 think that at the end of the 20 year per.4.2, 'the facility will 4
be de-commissioned.
And that'will include, to a varying 5
extent, the additional clean-up that we are supposing would 6
occur.
I l
7 And additionally, whatever is acquired during de-8 commissioning.
And if that's the case, he said that the de-9 commissioning plan, which_we submitted in two years, would 10 address both of those issues.
Then I think we have a 11 commitment that the money will be -- or the plan will be 12 evaluated, and the monies --_well, the money will reflect the 13 clean-up of the facility and de-commissioning.
14 MR. SMITHGALL:
My concern was not the definition of
/
15 de-commissioning, or clean-up, or immediate, or post.
My 16 concern was the confidence that the money will be there.
17 That's what I'm talking about.
18 I mean, I'm -- or, are we going to be,120 years from j
19 now, trying to put a funding package together that takes into 20 consideration rate pairs again, state monies again.
We're 21 going to have to be going through that whole ball wax as we did 22 a few years ago.
23 MR. MASNIK:
I think the --
24 MR. SMITHGALL:
That's my concern.
Not necessarily 25 the definition.
Is it going to be there?
What kind of --
Heritage Reporting Corporation (202).628-4888
66 1
MR. MASNIK:
The assurance that 2
MR. SMITHGALL:
-- confidence do we have that it's 3
going to be there?
4 MR. MASNIK:
.The assurance that the money will be 5
there is required by the rule.
But the amount, I think, is 6
what's in question.
7 In other words, the rule says at least $100.million.
8 MR. MORRIS:
How did --
9 MR. MASNIK:
And there is some assurance that that 10 money will be there because there are strict guidelines as to 11 how that money is to be kept separate from the operating 12 expenses of the licensee.
13 MR. MORRIS:
Where does it say that -- that it has to 14 be kept separate, and how it would be paid into that separate 15 account?
O
16 MR. MASNIK:
I think-in the section --
17 MR. STOLZ:
There are several alternatives described 18 in the rule.
19 MR. MASNIK:
Look on page 24050.
20 (Pause) 21 MR. MASNIK:
Under Item B in Column 1 there it says 22 each electric utility -- self-submitted de-commissioning 23 report.
And then it talks further on.
24 If you look at the next paragraph in the middle -- as 25 provided paragraph E(2) and (3) of his section, financial Heritage Reporting Corporation (202) 628-4888
c.
67-1 insurance is provided by the'following methods: repayment, l
2 external sinking fund, security method.
There are a number of' i
3 different ways, 4
MR. SMITHGALL:
Then when I ask you that if'there is j
5 an ability to put a proviso in their license amendment for a 6
sinking fund, you said it was an extraordinary method.
7 MR. MORRIS:
It's two different things.
8 MR. SMITHGALL:
I know that.
9 MR. MASNII;:
We're talking about the license.
And 10 when we talk about modifying the license, we're talking about 11 modifying the technical specifications which deal with 12 operation of tne facility.
13 I mean, how often you moderate -- things like that.
14 And typically, it doesn't address financial issues at some l
15 later date.
N.
16 In fact, that's one of the bases for this rule, that 17 the Commission was concerned that there would not be adequate 18 financial funds in the end for facilities to clean them up.
19 And that's why they're required now to set aside 20 certain amounts of money.
21 MR. MORRIS:
And -
go ahead.
22 MR. WALD:
I take it you're saying, then, the rule is 23 sufficient without it being mentioned in the license.
24 MR. MASNIK:
That's my understanding, yes.
25 MR. MORRIS:
Are you in agreement, or can we get some Heritage Reporting Corporation j
(202) 628-4888
68 1
kind of assurances that what was stated tonight on this record 2
is in fact going to be the interpretation of the NRC that-in 3
fact clean-up, as we've been told, and de-commissioning will be 4
considered as one at the time the financial statement is made 5
in July of 1990?
6 What kind of assurances can we get that that will be 7
the case?
8 MR. MASNIK:
I don't know if I can give you an 9
assurance of that on my own.
I would have to check on that, l
10 But it would seem to me that that plan would be reviewed.
11 And if the licensee chose to include in that plan 12 those items that would require additional clean-up or de-13 commissioning then money set aside for that would be 14 considered.
('
15 MR. MORRIS:
Well, I guess the major factor in my 16 thinking is in PDMS, if clean-up after PDMS is not contained in 17 this new order of the Commission that has to be submitted by 18 July of 1990 then we have no assurances that money will be 19 available.
20 If it is included as part of that then at least we 21 have this new action that seems to indicate that money would be 22 set aside in some form, sinking fund or whatever, to protect us 23 if we wait through PDMS.
And it's an important factor.
24 MR. MASNIK:
I agree.
I think the only assurance-we 25 have right now is Mr. Kinter's assurance that that plan will Heritage Reporting Corporation (202) 628-4888
69 1
address those items necessary to get the plant to the point 2
where it can be commissioned.
3 MR. MORRIS:
And we' re asking the NRC to look at that i
4 question, I guess, and give us some feedback, if possible, on 5
whether you agree with that interpretation.
6 And one other thing I'd like to get into a little bit 7
is what is the commissioning.
And I know that Fred asked that 8
earlier.
But as I understand it, de-commissioning can take a 9
lot of different forms.
10 There can be a request after -- as far as I l
11 understand it, TMI-1 has a 20-year life left they can request -
)
12
- they being GPU can request an additional year extension.
So 13 it can end up operating for another 30 years.
14 And then they can ask for some kind of safety 15 storage, or safe storage requirement for additional numbers of 16 years, up to, I think, maybe even 60 years.
17 MR. MASNIK:
That is correct.
There are three 18 options.
19 MR. MORRIS:
So that plant could in fact be there 20 fore 90 more years without it having to be removed or totally 21 decontamirated.
There can be a safe storage requirement for 60 22 additional years.
23 And in fact if that happens, they could allow TMI-2 24 to parallel to some degree that kind of action for Unit 1.
25 MR. MASNIK:
That's possible.
And it's also possible Heritage Reporting Corporation (202) 628-4888
j 70 1
under the rule that in the interest of public health and safety 2
it could be extended beyond 60 years.
e i
3 MR. MORRIS:
So when you look at a de-commissioning 4
financial plan with that potential scenario, it's very-5 confusing to me how it would be presented in July of 1990.
6 I'm not trying to make things more complicated, but 7
it becomes very complicated to me when you talk about it since.
8 If we knew that de-commissioning meant you removed 9
the plant 30 years from now totally from the island, and this 10 is what the cost is going to be for that, and therefore we want 11 to make sure that money's in place, that's easy to understand.
12 But when you have both the moving target as to 13 inflation and a moving target as to the actual physical removal 14 of the structure, I don't know how they put a financial plan J
15 together that really is going to hit a target 90 years from k'
16 now.
17 MR. SMITHGALL:
It's called mortgaging the future.
18 MR. MORRIS:
It's my biggest concern, and that's why 19 I continue to pursue it.
1 20 MR. SMITHGALL:
In light of that I just want to make 21 a point and then ask a question of Mike again.
22 It appears that the intent of the clean-up all along i
23 has been to ensure that clean-up be accomplished in a timely j
24 fashion, as expeditiously as possible, within the bounds of 25 public health and safety.
Heritage Reporting Corporation (202) 628-4888
71' 1
It appears that PDMS runs counter to all the NRC's 2
stated as far as not making Three Mile Island the long term 3
storage for radioactive waste.
4 I'd like to just hear how you rationalize that with 5
PDMS being environmentally acceptable.
6 MR. MASNIK:
I think we have to go back a number of 7
years when the original PEIS was issued, where we talked about 8
what the endpoint of the clean-up would be.
9 And it was nebulous at that time because we had a 10 poor understanding.
We looked at four different factors, one 11 was building and equipment decontamination.
One was fuel 12 removal and decontamination of reactor cooling system.
One was 13 treatment of radioactive liquids.
And one was packaged 14 handling and shipment of disposal of radioactive waste.
[
15 That was sort of where we were headed.
But I think i'
16 superimposed on all of this is our concern about public health 17 and safety.
18 And I think we've come a long way in satisfying those 19 four requirements.
We're certainly not at the point where 20 we've completed them.
21 But I think what has happened is that the licensee 22 has reevaluated going further in clean-up, based on their 23 calculations of those dosed workers, they felt that it is 24 advantageous to delay any further clean-up for some unspecified 25 period of time, and allow the decay of radioactive material in Heritage _ Reporting Corporation (202).628-4888
.~
72 1
the plant.
2 And they've come forward with'that request.
And the t
3 NRC has evaluated it.
And at least from an environmental point 4
of view we find it acceptable.
5 MR. SMITHGALL:
Do you feel that PDMS makes Three 6
Mile Island a long-term storage for radioactive waste?
7 MR.'MASNIK:
In a sense it does make it a storage 8
area for some additional period of time.
And.it was something 9
that we hadn't planned on earlier.
10 But I don't think anyone envisioned it being a 11 permanent long-hand term of waste storage facilities.
12 MR. SMITHGALL:
Ninety years is permanent -- not as 13 far as I'm concerned, and probably childrea, unfortunately.
14 I'll ask a question -- and if snybody else wants to ask
[
15 questions, certainly just jump right in.
Is there any other panel member that 17 wants to ask any questions at this point?
18 MR. RICE:
I have a question.
Everything we hear j
i 19 assumes that the Water evaluation process has been completed, 20 is that correct?
21 MR.-MORRIS:
Well, the water evaporation process 22 would not be part of the PDMS.
So it's expected that that 23 would be completed, I believe, prior to the.PDMS.
24 MR. RICE:
No --
25 MR. MORRIS:
Oh, you're not asking if it started yet, Heritage Reporting Corporation (202) 628-4888
73 1
are you?
2 MR. RICE:
No, no.
The assumption is that the water-i 3
solution -- the solution to that problem would be the 4
evaporation technique, is that correct?
5 MR. MORRIS:
The tactic in storage is supposed to be 6
under Lhe plan that's proposed by the operator is supposed to 7
the evaporated.
And that is presently being contested.
And 8
Mike Masnik went through that process earlier on.
9 If that is approved in a timely fashion, it's 10 expected that the evaporation of it would be completed, I 11 believe, by the time the PDMS goes in effect.
12 However, we don't know whether it's going to be 13 evaporated or not at this point.
14 MR. MASNIK:
It would be close.
There may be an
[
15 overlap of a number of months.
But for practical purposes, 16 there are two separate issues.
17 MR. MORRIS:
And they' re not really considered, were 18 they, as part of the EIS and the PDMS?
That was a separate 19 issue from the PDMS?
20 MR. MASNIK:
Yes.
21 MR. MORRIS:
That's what I had said.
22 Tom Smithgall?
23 MR. SMITHGALL:
No, I 24 MR. MORRIS:
You still have a comment?
25 MR. SMITHGALL:
No.
Heritage Reporting Corporation (202) 628-4888
74 l
1 MR. MORRIS:
Go ahead.
2 MR. WALD:
I have. comment and answer -- or comment on
\\
3 Tom's comment about the long-term storage aspect of it.
But 4
apparently it's the Commission's view that in order to get to 5
de-commissioning that has reduced residual radioactivity to a 6
level permitting release of the property for anrestricted use 7
in termination of a license, there are alternatives, one of 8
which is to permit a storage period during which radioactive 9
decay can occur prior to dismantlement of the facility.
10 In other words, there's storage in storage.
If it's i
11 deliberate delay in order to take advantage of physical decav 12 of the radioactivity, this is one of the alternative ways to i
13 get to the point of de-commissioning.
14 And I'm not sure you can turn it around simply and 15 say this is also waste storage.
.zs i
16 MR. MORRIS:
Well, I think it would really depend on 17 the level to which one would expect the radioactive storage to 18 help.
19 And when you look at the PEIS numbers, they are not, i
20 I don't think, terribly convincing.
When you look at maybe 21 what the operator is proposing tonight, that may be a different 22 story, which makes it again difficult for us this evening 23 because I'm not hearing anything from the NRC.
24 And maybe they're preferred to speak to this tonight.
25 But without some comment on the NRC on what's being presented Heritage Reporting Corporation (202) 628-4888
75-1 by GPU in the way of worker exposure, it's still hard to judge 2
how helpful that delay is to the worker, t
3 MR. MASNIK:
I think all we can say is that the new 4
numbers certainly put PEIS in a better light in the sense of 5
comparing the two.
6 But we have only had these numbers for two or three 7
days.
And I would feel a lot more comfortable if we had our 8
people check these numbers out and see what we can do with 9
their reasonable estimate.
And that's all I can say.
10 MR. MORRIS:
-- Neil.
11 MR. WALD:
I think it was mentioned that the new 12 numbers for 30 years reduces the physical activity of the 13 facility by half, I believe someone said.
14 Therefore -- am I correct on that?
[
15 MR. MORRIS:
- Yes, t'
16 MR. STANDERFER:
I made that statement -- which is 17 just 2 1/2 --
18 MR. WALD:
Yes.
19 MR, STANDERFER:
percent.
20 MR. WALD:
Which means, of course, if it ends up 90 21 years that it'll be that much greater a reduction by several 22 half lines. [ph) 23 Which may be part of the technique facilitating de-24 commissioning.
25 MR. MORRIS:
Well, that would make one wonder just Heritage Reporting Corporation (202) 628-4888
76 1
how well protected that plant would be for those 90 years, and 2
how secure it would be in all of those factors.
i 3
And I kind of hate to think what that would mean.
4 I just think there's a lot of things that go into 5
consideration other than what the level is of radioactivity, 6
when you extend something out 90 years.
7 I think one needs to look at that.
But I guess as 8
you try to take notes on the issues, one that comes forward is i
9 the money issue, and we talked about that.
i 10 The other one is worker exposure and the others 11 you' ve mentioned here.
I personally would like to see the NRC 12 at least review that and let the panel know how they feel about j
13 the numbers that have been presented tonight by GPU.
14 And maybe there are other major issues as well.
I
[
15 see them personally as the two major points -- money and 16 advantage to the worker in the way of worker exposure.
17 And just to complete the thought, if we don't get 18 information on both of those items, and particularly the later 19 one, worker exposure is definitely a PEIS matter.
i 20 how do we comment cn that until we get your 21 information, and yet we're not going to meet again.
And we 22 have an August 1 deadline?
j 23 And I still feel that as a panel we should be given 24 the opportunity to have that piece of information so that we 25 can at least decide whether we want to comment or not.
Heritage Reporting Corporation (202) 628-4888
77 1
And unless we meet again in August it seems to'me we 2
need some kind of extension so that we can discuss this.
j 1
c.
3' MR. MASNIK:
I would -- first, well, I guess I can 4
make e. comniitment that I will get that information to you as 5
soon as I can.
6 The problem we have is scheduling around the 7
Commission.
And there wouldn't probably be any days open to 8
meet with the Commissioners until unto the Fall, probably in 9
the Octcber time frame.
10 MR. MORRIS:
Well, personally, I feel --
11 MR. MASNIK:
If we could meet again prior to that, 12 that would solve the problem.
Or if my getting the information 13 to you in writing in the next couple of weeks -- then that 14 would --
g 15 MR. MORRIS:
I guess Mike thought of it.
I'm in no k~
16 rush, at this point, to meet with the Commissioners unlesc 17 we're in a position to discuss this particular document.
18 And if we're not in a position to discuss it, and I 19 don't think we're going to be, then maybe we ought to think 20 about delaying the meeting with the NRC until this Fall, and 21 asking for maybe an additional minimum of 30 days till 22 September.
23 We can meet in August, review the information that 24 you provided us, and then determine whether we want to take 25 position under PEIS or not.
Heritage Reporting Corporation i
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Then maybe the Commission isn't that far -- I realize 2
that they've took the time, and you've taken the time to 3
schedule a meeting, but it seems to me at this point we' re not 4
really going to be ready for them.
)
5 MR. MASNIK:
I believe the Chairman leaves for Russia 6
the next day.
So I'm sure he will welcome a little extra time.
7 MR. MORRIS:
We can meet him in Russia if you like.
8 (Laughter) 9 MR. MORRIS:
What's the feeling of the panel 10 regarding the discuscion that's taking place here?
I assume 11 silence is agreement, and I shouldn't do that.
l 12 MR. MILLER:
I totally agree.
13 MR. SMITHGALL:
That silence is agreement?
That you 14 agree with.
,l 15 MR. MORRIS:
Would you agree that we ask for an i
16 additional 30 days for comment and that in the meantime we ask 17 the NRC to provide comment both on the moncy aspects of it and 18 the worker exposure question.
And that we attempt to schedule 19 a meeting in August for the panel.
20 If there's agreement on that then maybe at this point 21 we could take a break, get public comment on what we've talked 22 about at this point, and then if we're still in agreement at 23 the end of the meeting we can talk about when we' re next 24 meeting.
25 Thank you.
Let's break.
Heritage Reporting Corporation (202) 628-4888
79 i
1 (Off the record.)
j 2
(Back on the recor'd.)
3 MR. MORRIS:
Hello.
Could we begin the second part, 4
please?
Otherwise we r ay be here till midnight.
5 (Pause) 6 MR. MORRIS:
The next part of the agenda is to allow 7
public comment.
And just briefly, before we go into that, I 8
would like to, if we could, have the NRC come forward and 9
explain -- and I don't know whether tl.at's Mike Masnik or 10 whoever -- but I would like somebody from the NRC to explain 11 how the PEIS license amendment and the July 1990 submittal on 12 the funding, how they fit together or how they don't fit 13 together.
14 In other words, is the funding involved in PEIS as 15 one item reviewed, or was it involved with the license 16 amendment review?
17 Because during the break I got the impression that 18 really funding is involved with neither one of those.
And I 19 just would like a little clarification on the process, maybe j
20 timing of it.
And maybe, if you could, at some point, Mike, l
21 you can talk a little bit about the funding and how it fits 22 into each one.
l 23 MR. MASNIK:
I guess this is the'first time I've been 24 on this side of the table.
25 MR. MORRIS:
You look good, Mike.
Beritage Reporting Corporation (202) 628-4888
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MR. MASNIK:
My understanding of how this would work s
2 is that the NRC would issue the draft impact statement.
It 3
comments an issue of final impact statement.
4 That impact statement would form part of the basis of 5
a future licensing action.
6 We anticipate a request from the licensee to chinge 7
the TMI-2 operating license to align it such that PDMS is 8
possible.
9 And that license change would change certain 10 surveillance requirements and certain conditions that are-11 within the license, presently, that can ensure the safety of 12 the facilities.
13 The license amendment request would be reviewed by 14
.;he staff.
And there would be a safety review.
And this 15 safety review would determine whether or not public heslth and t.
16 safety could be assured based on these changes.
17 ihe impact statement would form a part of that review 1
18 in that it would look at the environmental impacts of the s
19 storage period.
20 The impact statement is written in such a manner that 21 it is our best guess.
And it's generally a very large envelop, 22 only because we want to be certain that we anticipate all 23 possibilities in the future.
24 And that's why a lot of these numbers have big 25 ranges.
Heritage Reporting Corporation (202) 628-4888
)
h..
81 1
If the licensee at some time in the future does
-l 2
something that violates one of these envelopes -- well, let's s
3 put it this way.
The licensee cannot intentionally violate one 4
of these envelopes by any of their activities, 5
And in fact, now when there is activity on the 6
island, licensing activity, the licenses has to review that 7
activity on the basis of the PEIS up to that day.
8 So the original PEIS in supplements one and two were 9
taken into accornt.
10 Once the staff has come to the conclusion that the 1) request for the license change is acceptable from a safety and 12 environmental point of view, then there would be a change in 13 the license.
14 Now that license change -- the Commission has some 15 certain procedures.
And during that licensing, or tnat change 16 in the license, there is an opportunity for the public to 17 request a hearing.
18 It's somewhat similar to the water issue in that the 19 licensee came in with a' request for a license change.
And we 20 had a request for a hearing.
And the request was granted.
21 MR. MORRIS:
On
-hat, Mike, that is -- the license 22 amendment is a dete.rmination S; staff?
23 MR. MASNIK:
Right.
24 In this case -
the water issue is peculiar in that l
25 long ago it was decided that the Commission reserve the right Heritage Reporting Corporation (202) 628-4888 m
'G 82 1
1 to actually make the decision on the disposal of the water.
j i
2 But normally, in our licensing activities, the staff 3
makes that determination.
4 MR. MORRIS:
Okay.
But unless the Commissioners 5
would decide to make the determination, the staff would make 6
this particular license amendment determination.
7 And so far, on the final PEIS and the determination 8
in the license amendment you haven't stated any particular 9
dependence on financing.
10 I'm hearing you saying it's more of a safety 11 question?
12 MR. MASNIK:
That's correct.
13 MR. MORRIS:
The license amendment.
And therefore, 14 the whole question we've got in here on funding, at least from 15 the staff standpoint, would not be a consideration during the N.
16 license amendment.
17 MR. MASNIK:
That's correct.
That's not something 18 that the staff typically reviews when they do a license 19 amendment.
20 MR. MORRIS:
Now if the public or this panel would 21 wan that considered -- just giving you a possible circumstance 22
-- would want it considered, and requested a her.L g, would the 23 guidelines so stick that they don't allow one to look at the 24 financing end of it; that it's strictly a safety consideration?
25 And I realize this is a judgement we're asking you to Heritage Reporting Corporation g-(202) 628-4888
...e.
i 83 1
give us.. But I guess from the panel's standpoint, we want to 2
know at what point financing would be under consideration, and t
3 whether it would only really be under consideration come July i
i 4
of 1990 when the Commission deadline is required?
5 MR. MASNIK:
I would say that unless something 6
changes that that would be the case. -That finance would not be 7
the consideration in this situation, 8
Now I think the near term financial issue to some 9
extent is, but~in 30 years, that would not form the basis of 10 the determination to grant the license to allow the license to 11 enter PDMS.
12 MR. MORRIS:
Okay, Mr. Masnik.
My question on that 13 is, do you have any kind of time frame work that you. expect the 14 final draft -- forgetting any request for extension that one
[
15 would be given.
16 cut do you have any feeling that if the August 1st 17 date, say, would be met, when the final PEIS would be issued, 18 and when you would expect the licensed amendment to be 19 considered by staff -- forgetting any hearing for the licensee 20 members.
i 21 But do you have any guesstimate on that time?
l 22 MR. MASNIK:
I would gueas that -- of course it would 23 depend on the nature of the comments -- but we're shooting for 24 the end of September, beginning of October, to issue the final 25 impact statement.
Heritage Reporting Corporation
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And then depending on the licensee's submittal for 2
the license amendment -- it depends (n) when they submit it but j
3 i
l 4
MR. MORRIS:
Late this month, I believe.
Just go on 5
that basis.
l 6
MR. MASNIK:
Ckay.
Based on that, I would hope _to 1
7 complete a safety review some time next Spring -- early next 8
Spring.
9 MR. MORRIS:
So you're saying'that license agreement l
10 could be approved maybe by: staff, except any hearing by April i
11 or May of next year.
Is that a reasonable --
12 MR. MASNIK:
I would hope that it would be before 13 that.
It's a fine line because if we wait -- if 9 approve it 14 too soon there might be some changes that would mplicate g
things.
15 16 And a review of this magnitude would take some time, 17 I think.
18 MR. MORRIS:
Panel members have any question on what 19 Mike has explained here at this point?
20 If not what I'd like to do -
go ahead.
21 MR. SMITHGALL:
I just have a question, back to the j
l 22 de-coramiasioning rule.
Do you feel it was the intent of safe j
23 store to take into consideration TMI?
24 Maybe I'm not phrasing that correctly.
Do you feel 25 that TMI falls under those guidelines?
Heritage Reporting Corporation (202) 628-4888 1
1
85 1
MR. MASNIK:
I view TMI as an operating facility in 2
the sense that it has an operating license, and therefore falls 3
under the regulations that are applicable to operating --
4 MR. SMITHGALL:
So it could fall under the safe store 5
option?
6-MR.- MASNIK:
I would think.so, yes.
7 MR. SMITHGALL:
Just wanted to clarify that.
8 MR. MORRIS:
Mr. Masnik, thank you, sir, for taking 9
the table.
10 There were several requests to be put on the agenda 11 for public comment.
I must admit that the agenda had been i
12 prepared before the names were provided.
But I still would
]
I 13 like to go through and at least invite those three individuals 14 who'll give some comment first.
C 15 If I can find this I can indicate who they are.
One i
16 is Eric Epstein.
The other one is Frances Skolnick.
And I 17 guess Vera Stuchi --
18 Eric, would you like to be first, sir?
19 MR. EPSTEIN:
Yes.
20 MR. MORRIS:
Stuchinski.
I'm sorry.
21 MR. EPSTEIN:
I have copies for everybody if I may 22 give them after I speak, if that's okay.
23 MR. MORRIS:
I think we already have them.
24 MR. EPSTEIN:
No, two folks have.
Or would you 25 prefer to have them before ?
Heritage Reporting Corporation (202) 628-4888
86 1
Okay.
2 MR, SMITHGALL:
We'd like to watch.
j 3
4 STATEMENT OF ERIC EPSTEIN, DIRECTOR, THREE MILE ISLAND ALERT, 5
INC.
6 MR. EPSTEIN:
My name is Eric Epstein.
My 7
credentials are that I am a citi=en in America.
I believe I 8
have the right to speak so I'm going to do so.
9 It's been quite a parade today.
If I had known it 10 would have beer. like this I would have cancelled my plans to go 11 to Ickyburg Carnival later in the week.
12 Let me begin by saying I'm going to focus on a few 13 events from last week.
And I'm going to read through comments 14 I had.
And they basically deal with economics.
15 And another issue that the PEIS put forth as a 16 positive aspect of delayed clean-up, and that is that there 17 would be technology in the future.
18 So let me without further ado just read my comments.
19 Tonight I intend to focus on the research and 20 ecoriomic parameters of postponing the clean-up of TMI-2, i
21 referred to as the post de-fualing monitored storage option.
i 22 This discussion must necessarily encompass several i
23 generic issues associated with decontamina' tion and de-24 commissioning of nuclear power riants.
25 However, before I begin I would like to clarify Heritage Reporting Corporation (202) 628-4888 4
~k,
s.
87 1
several outstanding issues from the last meeting, and comment 2
on some recent developments.
3 First, I would like to draw the panel's attention to 4
an incident on May 13, 1988 in which GPU, and I quote, 5
"misclassified" a piece of reactor core-debris.
-6 Similar incidents occurred in August-of 1985 and 7
December of 1987.
In both incidences GPU's license to ship 8
radioactive waste was temporarily suspended.
9 Waste management is a programmatic problem at Unit 2.
10 Moreover, the NRC noted, and I quote, "We are' concerned that 11 your root cause analysis may not be affective in addressing 12 human performance problems in distinction to related technical 13 problems."
14 With these events in mind, how can the public be f
15 assured that GPU is competent to manage Unit 2 during PDMS with A.
16 a substantially scaled-down staff.
17 And perhaps GPU has sensed the public's apprehension.
18 Recentiv, they have bombarded local newspapers with ads 19 portrr'ing the merit of PDMS.
20 This is not a low-budget venture.
A full-paged ad 21 during the week in the Patriot News costs $3,553.95.
And on 22 Sunday that same ad sells for $3,760.35.
Anybody reading the 23 local newspapers have been seeing these ads consistently 24 throughout the week, and on Sundays, the last few weeks.
25 Is the public subsidizing the slick PR campaign?
How Heritage Reporting Corporation f
(202) 628-4888
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'88-1 much has this campaign cost GPU?
The cost and source.of the 2
funding should be disclosed so that the public'can make an 3
intelligent decision in this matter.
4 I would-like to clarify several issues.from the last 5
meeting relating to-de-commissioning. ~ TMI, A,
is.well aware 6
that the Public Utility. Commission factors de-commissioning 7
into the rate base, but A, there is no criteria to determine 8
dollar amounts, and B, there is no provision-for early 9
retirement.
10 In addition, there is no mechanism in place to put 11 money aside for an immediate or delayed clean-up.
This is a 12 fact.
There is simply no accounting mechanism around, or ever 13 devised to take care of what we would call an immediate clean-14 up or a delayed clean-up.
It doesn't exist.
)
15 Today, GPU has failed to detail funding plans for the i
\\
16 final phase of the clean-up, and they've failed tonight.again.
17 And I'll address this issue in more detail later.
18 Also, I'll challenge Dr. Travers' estimates ~on the j
19 generic cost of de-commissioning nuclear power plants.
To 20 begin with, Fred addressed it, and I think to some extent' Tom 21 did.
22 There is no clear definition for the term "de-23 commissioning."
Therefore, there is a wide variation in 4
l 24 published estimates.
25 Of course estimates vary depending on costs, Heritage Reporting Corporation (202) 628-4888
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operational life, activity, design, et cetera.
Dr. Travers stated it was approximately $200 million in'1988 dollars to de-2 t
3 commission the nuclear power plant.
4 Tonight Mike said -- at least 100 million?
What is 5
de-commissioning to Dr. Travers?
What is it to Dr. Masnik?
6 What were his projections bar:ed on?
7 It's interesting to note that the nuclear power 8
industry, the atomic industrial forum has estimated the cost 9
for de-commissioning from 30.1 to $129.3 million.
10 That's $29.3 million over the cost projected by the 11 NRC's most recent document.
12 Analysis and Inference, Inc. estimated 173.3 to 13
$694.9 million for a large pressurized water reactor, which is 14 what TMI is.
- {
15 And Duane Chapman, an economist at Cornell University 16 has projected the cost to be $3 billion.
17 As you can see, estimating de-commissioning costs is 18 an inexact science.
For this reason, Dr. Travers' estimate is 19 objectionable, and points to the need to closely scrutinize all 20 the NRC's and GPU's estimates and projects related to 21 decontamination and de-commissioning.
22 Let me proceed with the business at hand, 23 Many people who work with the public utility issues 24 that I've spoken to express concern over the economic aspects 25 of a delay clean-up.
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Indeed, some of you on-the panel have expressed doubt i
2 that money will somehow be available for decontamination l
3 activities in the eventual de-commissioning of TMI-2, 4
This skepticism is commendable and warranted, as 5
we've seen tonight.
The reality of that matter is that the 6
financing of an immediate or a delayed clean-up is sketchy at 7
best.
That's a fact.
8 Already -- and this is important to keep in mind --
9 already, GPU customers have shouldered a huge economic burden.
10 TMI-2 was briefly in the rate base just for months.
No clean-11 up funds accumulated, and that de-commissioning account is.
12 broken.
13 While the general consensus by experts in the field 14 is that rate payer equity should be maintained, GPU rate payers
(
15 have already assumed an inequitable status.
16 Now for your knowledge, the rate payer equity theory 17 stipulates that a person enjoyed the benefits of electrical 18 genera -- excuse me.
19 The theory stipulates that the rate payer's 20 responsible for de-commissioning cost since that person enjoyed 21 the benefits of electrical generation.
22 However, the TMI rate payer was deprived of this 23 benefit since Unit 2 was shut down prematurely.
24 While rate payer equity is a valid principle, in the 25 TMI case it doesn't work.
The TMI rate payer has been burdened Heritage Reporting Corporation (202).628-4888
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enough.
2 For example, construction cost, clean-up cost and 3
energy replacement cost.
Now I want you all to consider tnese 4
questions.
5 Should the principal of rate payer equity hold when 6
imprudent management decisions encourage huge unknown costs?
7 When management failure is responsible for the destruction of a 8
$700 million investment, when an investment was rendered 9
unusable after 1/120 of its projected life, should the next 10 generation of rate payers be liable because GPU does not want 11 to engage in timely decontamination, and de-commissioning 12 activities.
13 With such obvious inequity, it is improbable that 14 adequate funds will be forthcoming in the future.
c 15 If not, the rate payers, then who?
GPU doesn't know
(~..
16 where the funds will come from.
I talked to Gordon Tomb who's 17 in attendance tonight.
And he indicated in a phone 18 conversation to me on June 30th that the further 19 decontamination funding goes beyond the Thornburg plant.
20 In fact, Gordon said to me that'further clean-up 21 funding is -- and I quote -
"is a little fuzzy."
22 I talked to Doug Bedell and he wasn't too forthcoming 23 with information.
He told TMI, A,
on July 8th that the 24 funding, and I quote, "The funding question should be addressed 25 to the advisory panel."
I'd be very surprised if people i
Heritage Reporting Corporation (202) 628-4888
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thought that the funding question was adequately addressed this 2
evening.
3 PDMS further complicates the funding picture.
At the 4
time delayed clean-up is projected to take place, almost every 5
license for a commercial nuclear power plant will have been 6
expired.
7 By the year 2,010 almost every license in this 8
country for a nuclear power plant will have been expired.
9 That's a fact.
10 The nuclear industry will be undergoing simultaneous 11 de-commissioning.
Therefore, funding sources utilized for the 12 TMI clean-up will either be unavailable or under pressure to 13 bail out otner nuclear utilities.
14 TMI-l and Oyster Creek will also be undergoing 15 decontamination and de-commissioning.
And those projects are 16 likely to be under-funded.
i 17 In actuality, what we're dealing with here is generic i
18 economic questions related to the back end of nuclear power 19 production.
20 These are the hidden costs of decontamination and de-21 commissioning which GPU and the NRC would like to hide for 22 another 20 years -- if I understand them correctly tonight, 23 maybe 60 years; maybe 90 years.
24 This is not a site specific problem.
This is a huge 25 headache.
To date, there has been no de-commissioning of a Heritage Reporting Corporation (202) 628-4888
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large commercial nuclear power plant.
That is a fact.
2 Costs are unknown and typically undereetimated.
3 Let me give you.an example.
Battelle Pacific 4
Northwest Laboratory conducted several studies examining de-5 commissioning costs between 1979 and 1982.
6 Battelle studies provided.the basis for utility 7
estimates.
But these studies were based on the de-8 commissioning of a 22.5 megawatt Elk River plant which operated ~
9 for only four years.
10 this reactor was 1/40th of the TMI size.
11 Let me give you a quote hero.
"Many modern reactors 12 can produce 50 times more power, and will operate at some seven 13 times as long as Elk River.
That's from Cynthia Pollock.
14 Moreover, there was no peer review.
And the g
objectivity of the Battelle study is called into question due 15 16 to their heavy reliance on contracts from. DOE, the NRC, and the 17 Electrical Power Research Institute.
18 When the study was updated in 1984, and I quote, 19 "Costs had indeed risen much faster than inflation over the 20 preceding six years."
21 This is nothing new to you.
Everybody knows that 22 projecting costs are an inexact science.
23 Just quickly, other reports from DOE and the RAND 24 Corporation suggest that we can expect cost overruns.
For 25 example, and I quote, "A January 1984 report by DOE showed that Heritage Reporting Corporation (202) 628-4888 if
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out of the 47 reactors surveyed, 36 reactors cost at least-2 twice as much to complete as originally projected, and 13 cost 3
at least four times as much."
4 This demonstrates how unrealistic economic 5
projections at the front end or the back end of nuclear power 6
production are.when based on unknown variables.
7 And we'll get to the issue at hand.
Although the NRC 8
stated that they have, and I quote, they "have had considerable 9
experience with reactors that have not had a significant 10 accident before the end of their usable lives," that experience 11 is limited to small reactors.
12 In fact, many commercial reactors are not anywhere 13 close to being decontaminated or de-commissioned, primarily due 14 tc a lack of available technology.
f.
15 This is what the NRC stated that one of the 16 advantages of delaying the clean-up is.
This is from the PEIS.
17 This is one of the advantages.
18 "The monitored storage period allows time for 19 continued development of decontamination technology so that the 20 most effective and efficient techniques may be applied, 21 "Further reduction and occupational doses would be 22 achieved through the use of advanced robotic technology, 23 automatic chemical cleaning techniques, and advanced waste 24 treatment methods."
25 The NRC anticipates -- end of quote -- the NRC Heritage Reporting Corporation (202) 628-4888
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anticipates a merging technology.
'Yet, on Page 10 of this same 2
document, the staff noted, and I quote, "The NRC has no plans 3
oto develop technology for clean-up following PDMS.
4 "This task would be left to the licenses.
No 5
commitment will be obtained by the NRC from the licensee to 6
finance further development of technology."
7 Frank Standerfer said tonight the technology of 8
compassion will be developed.
And what he said, and I quote, 9
Frank said, "Not a guarantee but a prediction."
10 Gentlemen and gentlewomen, these are predictions.
11 All right?
12 Where is this new technology going to come from?
In 13 1984 Dr. Paul Woolam, a member of the Commission of the 14 European Communities Team that studied de-commissioning 15 capabilities stated, and I quote, "Design of equipment for
,e i
16 dismantling, especially remote equipment, is in its infancy."
17 In this field, GPU has portrayed itself as a pioneer, 18 but is now content to sit idly by and wait for new technologies 19 to be developed.
20 If not the NRC, if not GPU, and if not international 21 agencies, then who?
22 Well, some people suggest, what about DOE and the 23 shipping port experience.
Let's look at that.
24 Shippingport is a 72 megawatt pressurized water 25 reactor owned by the Department of Energy.
In order to cut Heritage Reporting Corporation (202) 628-4888
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costs, this is the plan.
The 800 ton 5 million curie pressurized vessel 2
i 3
reactor, and the neutron shield will be put on a barge, which i
4 will sail down the Ohio and Mississippi Rivers, across the Gulf 5
of Mexico, through the Panama Canal, up the West Coast, up the j
\\
6 Columbia River, to the Hanford Reservation.
j 7
Pretty impractical for reactors that are 1,000.
8 megawatts.
9 The federal government is avoiding a valuable de-10 commissioning experience by barging the entire reactor as a 11 unit.
12 The radioactive debris has a guaranteed burial site, 13 unlike the dilemma faced by commercial reactors which have no 14 place to go after retirement, which Frank admitted today, c
15 Therefore, the waste will be disposed of under I
16 unrealistically lax DOE waste site regulations.
17 Shippingport doesn't do us any good.
As a tootnote 18 to this -- I think you might find this interesting -- DOE's 19 funds have come under increasing pressure to clean up hazardous 20 waste sites as defense plants.
They' re not going to have funds 21 to research this technology.
22 The total costs range from 40 to 70 billion to clean 23 up hazardous waste sites.
These are just in military plants.
i 24 We're not even going to get to de-commissioning.
25 Therefore, increased research and development funding Heritage Reporting Corporation i
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for de-commissioning nuclear power plants from this agency is 2
unlikely.
j 3
Not much in the way of research is being conducted by 4
the utilities who have had to close plants prematurely.
The 5
entire industry is deferring instead of developing.
6 Take a few more minutes of your time.
TMI is not the 7
only plant that was prematurely shut down.
Let's look what 8
happened to the other plants, and I'll show you the nightmare 9
that we' re rushing into -- or we' re not rushing into, as a 10 matter of fact.
This temporary storage has become a generic 11 way of doing nothing.
12 Humboldt Bay.
It was shut down 12 years ago because 13 the cost of refurbishing it to withstand a major earthquake was 14 more than the original construction and licensing cost.
(
15 Despite appeals from local citizens groups to 16 dismantle the plant, it was put into temporary storage with no 17 de-commissioning fund set aside.
Sound familiar?
Let's look 18 at Dresden 1.
19 Shut down ten years ago due to radioactive corrosive 20 products inside the piping.
Partially decontaminated with 21 chemicals in the early '80s, the plant is in temporary storage 22 until Units 2 and 3 are ready for retirement.
23 Indian Point 1.
Shut down in compliance with the 24 Atomic Energy Commission regulations in 1974 because it lacked 25 an emergency core cooling system waiting for Indian Point 2 de-Heritage Reporting Corporation (202) 628-4888
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commissioning at 2,006.
2 Fermi 1.
Put into temporary storage in 1975 due to 3
an accident.
4 Peach Bottom 1.
Put into temporary storage 13 years 5
ago.
If Peach Bottom doesn't open -- there's no money.
6 There's not enough money right now to de-commissioning Unit 2-7 and Unit 3.
8 Uby don't we look at GPU?
They have a plant, a 9
little known plant known as the Saxton Nuclear Experimental 10 Facility, this utility that was before you this evening.
11 They've got a little plant.
12 Cwned and operated by GPU, this seven megawatt 13 reactor operated from 1962 to 1972.
Saxton was placed in --
14 you guessed it -- temporary storage in 1972, and is scheduled 15 to be dismantled in 1997.
g
\\
16 Listen to this figure.
Dismantling costs are 17 estimated to be $12 million, two hundred percent of the 18 original capital cost, okay?
Several trends are readily 19 apparent by examining these reactors.
20 In each case, deferring was prompted by inadequate 21 funding.
There is reluctance to undertake unknown tasks.
Very 22 little is being done in the way of research and development to 23 de-commissioning and decontaminate reactor's.
24 All the above reactors were shut down prematurely, 25 placing a strain on the licensee's cash flow, making research Heritage Reporting Corporation (202) 628-4888
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and development impractical.
2 And the NRC clearly accepts temporary storage as a 3
means of getting around decontamination and de-commissioning.
4 Final page.
It is clear that the. cost of postponing 5
the clean-up is immense and likely to be unfairly distributed.
6 The NRC and GPU's claims of future technologies and robotics 7
will be developed appear to be wishful thinking.
8 As was noted, every utility is playing a waiting 9
game, gambling that someone else will pioneer decontamination 10 and de-commissioning technologies.
11 I think we should listen to what this woman said.
12 Her name is Cynthia Pollock, and she describes the problems 13 with waiting 30 to 100 years to decontaminate and de-14 commission a plant.
j 15 She did an exhaustive study for the United Nations.
\\~
16 And I quote.
"Assumptions must be made about the evolution of 17 technologies and the likely increase in decommissioning costs, 18 inflation and real interest rates.
19 "Estimates must also include provisions for stricter 20 government regulations and other unforeseeable events.
The 21 staffs most familiar with the plant will have left.
22 "The company, and excellent record keeping will be 23 required to inform the future crew of the reactor's intricacies 24 and its operating history.
25 "The longer dismantlement is deferred,.the greater Heritage Reporting Corporation (202) 628-4888
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1 the margin of error, and the higher the total costs are likely 1
2 to be."
3 Let me remind you all, there's 1100 people working at 4
Unit'2.
Can you imagina the chaos if we wait 20 or 30 years 5
and we have to rehire 1100 new people who have never worked 6
there before, okay?
7 Imagine the worker exposure, and the exposure to the 8
public of people who haven't had this experience hanging out, 9
trying to figure out what to do.
10 This is what I feel -- or I should say what TMI Alert 11 feels the advisory panel should do.
We feel you should opposed 12 PDMS for the following reasons.
13 Number one, it's more costly.
Two, the cost is 14 inequitable and will be born by the next generation of fate 15 payers.
Number three, there's an underlying assumption that c
16 the technology will suddenly come forward despite a lack of 17 research and development.
18 The panel should recommend to the NRC that the clean-19 up of TMI-2 proceed immediately.
GPU should be liable for cost 20 and develop appropriate technologies.
21 In addition, GPU should develop a funding plan based 22 on acceptability and realism to be reviewed by the Public 23 Utility Commission, the consumer advocate, the Commonwealth of 24 Pennsylvania, and citizens.
25 But also, I also have something else I'd like to say.
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I'd also like to address the question of worker exposure, which 2
seems to be the fundamental issue GPU is gambling on.
3 First of all, we have to assume that these new 4
figures that just came out are accurate.
And I don't believe i
5 it.
6 I think what we need somehow is to get an independent 7
analysis to either justify the NRC's statistics, or GPU's 8
statistics because the brunt of the argument rests on the 9
worker exposure equation.
10 I'd also like to say that you can mitigate the amount 11 of worker exposure by using more workers and exposing them to 12 less radiation.
13 And I would go out on my limb to say, according to 1
14 sources that I have, that are not the word of God, that the l
15 workers that are there would like to stay there, and would like
?
16 to complete the clean-up now.
17 That's just some comments on the worker exposure 18 issue.
)
i 19 Finally, regarding the NRC's responses to TMI's 20 questions, Question 1 concerning the NRC's experience with de-21 commissioning, the staff's answer fails to alleviate our 4
22 concern regarding the federal government's lack of experience 23 de-commissioning in the nuclear reactor.
There just isn't 24 experience de-commissioning a large scale nuclear reactor.
i 25 Question 6, we still remain unconvinced that adequate Heritage Reporting Corporation (202) 628-4888 f
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safeguards are in place for the movement and location of 2
radioactive materials, and to'the best of our knowledge, 3
questions 7, 8,
9, 10, 12, 14, 15, 17, and 18 were not 4
answered.
I 5
Now, if I can just indulge you_for one more moment,_
6 the few --
7 MR. MORRIS:
Just let me say -- and I appreciate the 8
very detailed presentation -
you've been on the-agenda now for 1
9 20 minutes.
)
10 MR. EPSTEIN:
Okay.
\\
11 MR. MORRIS:
So please, if you would --
12 MR. EPSTEIN:
I'm just going to take one minute and 13 request an answer to these questions.
And then I'll sit down 14 and you won't hear from me for a little while.
15 y
Neil, a question for you -- Chernobyl.
Is it true 16 that that plant that was in the accident is in the' process of 17 being decontaminated and de-commissioned now?
18 MR. WALD:
No, the plant is entombed.
19 MR. EPSTEIN:
Okay.
So it was entombed, which is an 20 acceptable de-commissioning process to some people.
21 Okay.
I think what I heard Frank say earlier, that 22 it's not practical to de-commission one while another plant is 23 running, well I want to bring out the fact that there are 24 places like Chernobyl that would be de-comrissioned while there 25 were others running simultaneously.
Heritage Reporting Corporation (202).628-4888 T
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Quickly, I would like to -- yes.
2 MR. RICE:
But not decontaminated?
3 MR. EPSTEIN:
Okay.
Not decontaminated, but de-4 commissioning activities are taking place.
5 MR. WALD:
And entombment wasn't an acceptable 6
solution here.
7 MR. EPSTEIN:
Well, I'm going to move on.
I don't 8
want to take time.
9 I was wondering if Mr. Kinter of GPU would implement 10 an immediate clean-up if it was mandated by the NRC.
And I'll 3
11 just stop there since I'm at 20 minutes.
12 And I thank you for indulging me for 5 minutes.
I 13 would also point out that GPU is scheduled for 30 to 60.
So I 14 think I'm doing pretty good.
15 MR. MORRIS:
Eric, I appreciate your comments.
I c(
16 appreciate the detail that you went to to present it.
i 4
17 Provides, I think, some good background.
]
18 (Applause) 19 MR. MORRIS:
Frances Skolnick.
20 (Pause) j l
21 MR. MASNIK:
Tough act to follow.
22 MS. SKOLNICK:
Really.
I'm thinking of some funny 1
23 line I can make.
24 MR. MORRIS:
Just for the record, they were scheduled 25 for 30 minutes and took 50.
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MR. EPSTEIN:
That's just going to show how precise 2
estimates can be.
3 (Laughter) 4 5
STATEMENT OF FRANCES SKOLNICK, DIRECTOR, SUSQUEHANNA VALLEY 6
ALLIANCE 7
MS. SKOLNICK:
When I'm sitting here tonight I also 8
was reminded of the fact I'm really glad my children don't come 9
to these meetings because I think they would be totally 10 confused by our use of the English language.
11 I'm just totally amazed that, first of all, with PDMS 12 we were talking about the licensee didn't specify a time 13 period.
Then the NRC comes along and says 20 years.
14 Then somebody comes along and says 30, then 40, then a
15 90.
I mean, as far as I'm concerned it could be a thousand --
r 16 more than a thousand because most of the committee's clients 17 (ph) are going to be around for thousands of years anyway.
18 These are our official comments, the SBA's official 19 comments on the NRC's environmental impact statement.
I 20 We understand that the NRC staff must act upon any 21 proposal submitted by the licensee.
However, it is 22 unacceptable to us that the NRC print the draft of its 23 evaluation of this proposal in light of th'e inadequacy of the 24 data presently available.
25 Unit 2 is clearly not close to being prepared for Heritage Reporting Corporation (202) 628-4888
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PDMS.
Much work needs to be done, including the completion of 2
de-fueling.
b 3
Data, particularly that needed to determine the 4
quantity and configuration of remaining radionuclides has not 5
yet been submitted, and will not be available for evaluation 6
until de-fueling is completed.
7 The purpose of an EIS is to provide enough 8
information to both the public and all interested parties so 9
that they can carefully evaluate a proposal and determine its 10 consequences.
11 Furthermore, the information is supposedly to permit 12 public input into the decision-making process.
Clearly, if 13 inadequate information is provided, the EIS does not meet its 14 requirement as defined in the Environmental Policy Act.
l 15 There are major weaknesses in the evaluation of 16 radionuclides and their impact during PDMS.
The most serious 17 weakness is the lack of independence and objectivity in 18 evaluating this proposal.
19 And that's also very clear in the responses to SBA 20 and TMIA's questions at the last meeting.
21 The NRC uses the licensee's data rather than any of 22 its own.
In doing so, rather than evaluate the licensee's 23 proposal with an open mind, they serve only to confirm and 24 grant the licensee's desires, hardly en appropriate act for an 25 agency supposedly regulating an industry.
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Using the licensee's data, the NRC has calculated the 2
inventory of radionuclides that will remain in the reactor and 3
throughout Unit 2.
4 This inventory is presented in Table 2.4.
No 5
refefences are provided so the public might evaluate the amount l
6 of radionuclides which was. removed during clean-up and de-7 fueling.
Other references provided are for rasearch undertaken l
8 by GPU Nuclear.
9 This lack of information makes it-more difficult to 10 evaluate the impact of delaying clean-up.
11 Concerning the discussion about activation products, 12 on Page 2.27, if 90 percent of the activation products is 13 assumed to have been removed during de-fueling, the research I
14 and baais upon which this assumption is made should be i
15 referenced, j
16 This is most important in light of the NRC's 17 submission that we find methods for determining the 18 transportation of debris and radionuclides during an accident j
19 are not available.
20 Measurements of fuel and surfaces may be fraught with 21 errors, both mechanical and human.
And therefore, public
]
22 scrutiny of the radionuclide content of Unit 2 during PDMS is 23 essential.
24 Only full disclosure of information may make this l
25 evaluation possible.
Furthermore, if 90 percent o' the 1
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activation product is assumed to have left with the fuel, or to 2
have been incorporated into stainless steel of the components 3
and is inaccessible, as the NRC states, then would not part of 4
his 90 percent also be a part of the inventory at the end of 5
de-fueling, and hence be in addition to the 10 percent as 6
estimated by the NRC to remain.
7 And another question I have about manganese 54, if.it 8
has a half-life of 312 days, would there not be more than 12 9
curies left at the end of 10 years as indicated in Table 2.37 10 The claim that less than one curie of Krypton-85 will 11 remain during PDMS needs further scrutiny.
A review of 12 environmental releases of Krypton-85 during the accident and 13 subsequent clean-up does not account for the total inventory of 14 Krypton-85 present at the on-set of the accident, which I
/
15 believe was 97,000 curies.
\\
16 As late as October 1987, in a letter from the 17 licensee to the NRC, the licensee stated that it was unable to 18 account for as much as 335 curies of Krypton-85.
19 We want to know where it is.
20 The claim that less than one curie of Tritium will 21 remain during PDMS also needs further scrutiny.
There were 22 8,800 curies of Tritium present at the time of the accident.
23 The NRC claims that the accident generated water 24 contains 1,020 curies.
A review of environmental releases ano 25 additional reports shows that all of the Tritium has not yet i
J Heritage Reporting Corporation a
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1 been accounted for.
2 And therefore, there is no basis upon which to 3
conclude that only one curie remains -- will remain during 4
PDMS.
5 This issue is of particular.importance to the 6
disposal of the accident generated water, and furthermore, to 7
the dctermination of whether or not the water to be used in 8
subsequent clean-up is accident generated w: '.er as defined by 9
the Lancaster City Agreement.
10 These comments address only Manga tese-54, Krypton-85 11 and Tritium.
However, we feel that further scrutiny of the i
12 quantity and location of all radionuclides is of vital 13 importance.
14 The need for independent evaluation of the 1
l 15 radionuclide inventory is heightened by the facts that the k
16 licensee has on occasions miscalibrated waste, which has left 17 the island, and moreover, by the discovery that instrumentation 18 used fer measuring Strontium was miscalibrated for some periods 19 of years during clean-up.
20 The public's trust in the licensee's ability to 21 collect accurate data have suffered irreversible damage.
- When, 22 in 1984, the licensee was found to have maintained a policy to 23 systematically falsify critical safety data, and destroy 24 documents for monthr leading to the 1979 accident.
25 In light of this, it is incomprehensible that the NRC Heritage Reporting Corporation (202).628-4888
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should taly'so heavily on the licensee's data.
In December 1983, in NUREG 06d3 Supplement Number 1, the NRC considered 2
3 methods to reduce worker dose at TMI Unit 2.
4 One of the methods considered was that following de-5 fueling the plant would be placed in storage.
The NRC 6
indicated certain obstacles to this procedure, which. included, I
7 and I' m quoting, "Qne, uncertainties about the development of 8
robotic technology; two, lack of information about the 9
feasibility and safety of interim storage; and three, lack of 10 assurance that funds will be available for ultimate clean-up."
11 There is no evidence in the draft supplement that 12 these obstacles have been eliminated.
It is therefore 13 appropriate that the NRC notify the public prior to any 14 decision on PDMS how these three obstacles have indeed been 15 overcome to enable the NRC to conclude that the licensee's lA 16 proposal will have no significant environmental impact.
17 The public requires assurance that not only are 18 efforts being undertaken by the NRC and the licensee to develop 19 and help finrnce advanced technology for the clean-up, but also 20 that funding is put in place for PDMS subsequent cleaning and 21 de-commissioning.
22 Furthermore, a mechanism which enables the state of.
23 Pennsylvania to take ownership of these funds should be made 24 available.
25 The licensee stands to save $57 million by a Heritage Reporting Corporation g
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reduction in its work force during PDMS.
Those are their l
2 figures.
1 3
These funds.should be laid aside for the people in 4
this area who stand to lose, and who must shoulder the burden 5
of a decaying radioactive site in their backyard.
6 It's ironic that in evaluating the regulatory l
7 considerations of delayed clean-up in the EIS the NRC fails te 8
mention its policy of encouraging licensees to remove all 9
radioactive waste from the site when possible.
10 This is the policy to which the NRC so fervently 11 clung when the public esked them to consider and accept the 12 storage of accident generated water on the island until the 13 tritium had decayed.
14 It is exactly the kin" of behavior which continues to j
15 erode the public confidence i..
ne regulatory abilities of the i
A 16 NRC.
17 It is not surprising to us that the NRC concludes 18 that any of the alternatives considered in this draft will not 19 significantly affect our environment.
20 Even the lack of a firm factual basis could never 21 preclude the NRC from finding in'the licensee's favor.
22 Whether clean-up is immediate or delayed, let's make 23 no bones about it, the public must suffer the consequences of 24 millions of gallons of radioactive water going into their 25 drinking water supply, and the venting of radioactivity into Heritage Reporting Corporation (202) 628-4880
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r 1
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their air from Unit 2 for a nonspecified period of time.
2 Only those who must carry the burden of radioactive 3
exposure with no provision of electricity to off-set the cost 4
have the right to decide whether GPU Nuclear's proposal will 5
not have a significant environmental impact.
6 The NRC must provide the public with-the tools to 7
make such an evaluation.
This draft does not provide those 8
tools.
9 In conclusion, the NRC must provide more information 10 as it arises.
They must provide the basis and rcsearch for 11 their assumptions.
12 Only when the public has been given this information 13 a sufficient time to evaluate it and provide input to the NRC, 14 only then should the NRC render a decision on this issue which f
15 will e' t Sct those of us liv 3 ng here for the rest of our lives.
16 Furthormore, along with any decision on this 17 proposal,,lua NRC h&6 an obligation to us, the public,_to one, 18 establish administrative procedures which will ensure that the 19 licensee will complete clean-up; two, obtain a commitment that 20 should clean-up be delayed, the licensee will not refurbish 21 Unit 2 three, ensure that adequate funding is set aside for 22 use by those who clean up TMI; and four, ensure that both the.
23 NRC and the licensee commit money to the research and 24 development of technology to be used in clean-up.
25 Thank you.
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MR. MORRIS:
Thank you.
'2 (Applause) 3 MR. MORRIS:
Any other comments from the public?
i 4
(No response) l 5
I am at this point, in order to_ allow the panel an 6
opportunity to deliberate some more on the issue before us, I 7
am going to ask each person from the public to limit their 1
8 comments to five minutes please.
9 Yes, sir, in the back.
And I think there were two 10 other people that indicated here.
And I think that would limit 11 the comment because we needed to get into this discussion 12 ourselves.
13 14 STATEMENT OF BRIAN HUNT, CITIZEN j
15 MR. HUNT:
My name is Brian Hunt..
And I'd just like r
A 16 to point out that you all have been asking a lot of questions 17 about economics and funding.
You've been getting a lot of 18 double-talk from this side of the room.
19 Mr Epstein comes up and presents you with some data 20 which I think will be important when you jump on his case.
21 Maybe you should give them five minW.ca, and Tim -- 30 minutes, 22 and maybe you'd have more meaningful information.
23 MR. MORRIb Sir, for the record, I do want to 24 respond to that.
I didn'* jumo on Mr. Epstein's case -
please 25 let me finish.
i Heritage Reporting Corporation (202) 628-4888
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We have a standing requirement here that if you want 2
to get on the agenda for additional time beyond five minutes we t
3 will go up to ten minutes.
4 Somebody else gave Eric additional five minutes, 5
which was 15.
I was just speaking to the question.
It's a 6
long-standing ground rule that he understands.
7 I did not give him a hard time.
I just let him know i
8 that he had extended to a certain point.
For the record, 9
that's why I made the comments that I did.
10 MR. HUNT:
You heard an extensive amount of double-l 11 talk.
And you got some meaningful information --
i 12 MR. MORRIS:
I'm not speaking to the information --
13 MR. HUNT:
I'll go on at this point.
l 14 MR. MORRIS:
-- I'm speaking to your comment 15 regarding my --
16 MR. HUNT:
I want to talk to the ; -int of repair 17 equity.
And I want to clarify that that issue is important not 18 from the perspective of fairness, but frcm the perspective of 19 likelihood.
20 Will there be a willingness on the part of future 21 rate payers to pay for this?
And if there's not then your 22 funding question is once again in doubt.
23 Many of the rate pairs under GPU's proposal here, if 24 you're talking 30 year delay, are not even born yet, that will 25 be asked to bear the cost of that.
Heritage Reporting Corporation c
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And certainly, many, many more of them were not born 2
at the time of that accident.
So this issue of equity comes 3
very much to their minds when they will at some point be posed 4
with the question of paying for this de-commissioning.
5 They won't have experienced it, so they will have to 6
go back and read about it.
They will read about that pesky 7
little leaky valve.
8 They will read.about how these people falsified 9
documents, obscuring the importance of that leaky valve.
They 10 will read a)out how after only three months of electrical 11 generation these people melted that fuel, and they will know 12 that that leaky valve and that falsification of documents which 13 was a criminal act led to the masking of the loss of the 14 cooling accident, and that in fact it was that event that
/
15 caused that fuel to overheat twice to the point where it 1
VV 16 melted.
17 And those people will say -- to GPU and to the
'I 18 government, those people will say, You did what?"
Those 19 people will say, "You want us to pay how much?"
Those people 20 will say, "Bullshit."
21 Now you may take offense at my use of that word here, 22 but that's the word they will use then.
23 What if those people are not the fools that GPU 24 thinks they are.
What if they' re rational people and say this 25 is not our bill, we're not going to pay it.
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What does that mean for this claim?
Or what.if they 2
aren't the fools and they find out that they have no choice 3
because in fact we were the fools to let GPU get away with this 4
now and force a funding plan on them for acts that they were in 5
no way responsible for, for acts that they weren't even on this 6
earth when they were committed.
7 What does that mean to all of this discussion that 8
we're having here tonight?
9 GPU knows that they're making fools, either out of us 10 in this room, or that future generation of rate payers.
11 And as part of this whole mascarade they're going to 12 the NRC and saying, "Help us with this problem.
And we had 13 this little incident a few years back.
And we' re in a position 14 nobody's ever be9n in before.
Tell us what we should do."
J 15 Well, I ti: ink you should tell them.
Tell them-it's 5,
16 your problem, sucker, you pay for it.
The future generation is 17 not going to do it.
And you putting off this decision is not 18 going to make that money available in the future.
19 Just recognize that those people aren't the fools 20 that thinks they are.
And please don't be the fools that GPU 21 thinks you are.
22 Thank you for your attention.
23 (Applause) 24 MR. MORRIS:
Who is next?
Yes, Ma'am.
25 Heritage Reporting Corporation
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STATEMENT OF DORIS ROBB, CITIZEN 2
MS. ROBB:
I'm Doris Robb from Lancaster.
I have a 3
brief statement I would like to make and then two questions 4
that I would like to address to Mr. Standerfer.
5 I did not ask for time on the agenda because these 6
questions and commente came out of what'I heard this evening, l
7 First of all, this is with interest to Dr. Wald's 8
remarks about his experience in Chernobyl.
And as he was 9
talkirq I heard him say that Unit 4 is now entombed, and that's j
10 the way they handle their problem.
11 I understand that 99.5 percent of the radiation has 12 been removed from Unit 2, and the question that I will addreds 13 to Mr. Standerfer is why cannot entombment be considered, then, 14 for Unit 2.
15 Seems to me that that would solve a number of g
16 problems which we are discussing.
The major concern for GPU 17 Nuclear seems to me worker exposure.
18 Thi certainly would reduce the risk of worker 19 exposure.
It would also eliminate the expense of future clean-20 up.
21 The storage of debris which would be removed in 20 22 years would possibly eliminate the risk of that one point, or 23 the one in two billion chances of cancer which he was referring
]
l 24 to, or the ons in 27 million chances of genetic defects.
25 These statistics really do make me recall statistics 1
Heritage Reporting Corporation (202) 628-4888 i
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l 1
that I heard prior to the accident at Three Mile Island.
I 1
l 2
can't recall specifically what it was, but it doesn't make.any 3
difference at this point.
4 But I know that the public was told at that time that 5
there was one in several million chances that an accident such 6
as TMI could occur.to begin with.
7 That was information provided for us by our eminent 8
experts at that time.
9 We've talked this evening about new technology, the 10 possibility of using robotics and future technology.
I would 11 think that entombment would eliminate the necessity for having 12 to depend on new technology for which we do not know that 13 funding will be available or that the technology will be 14 forthcoming, since we have not advanced all that much.
J 15 We were told at the beginning -- I recall in the 50s s'
16 we were talking about the wonderful technology of nuclear --
17 and the problems of storage would be solved in the future.
18 Here we are in the future and those problems have not l
19 been solved as yet.
l 20 Since it is understood by Dr. Marston speaking for 21 the SAB that no plan is under co'nsideration for restart,1my 22 question remains, why not entomb the plant?
23 My second question to Mr. Standerfer is if the
)
24 tritium water is so innocuous, why can't it be stored in the 25 reactor building instead of being avaporated?
Heritage Reporting Corporation (202) 628-4888
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Thank you for your time.
2 MR. MORRIS:
Thank you.
.i 3-Mr.'Standerfer, do you prefer to respond at.this 4
' time?
5 I'm going to take your response.
I'm not going to 6
take any additional comment regarding your responses.
I'm 7
going to go to the gentleman back here next.
8
'MR.
STANDERFER:
Yes.
The NRC de-commissioning 9
regulations do provide two ultimate fates.
One is entombment; 10 the other'is removal.
11 The NRC regulations with regard to entombment would 12 require that to only apply to facilities which will decay --
13 the radioactivity will decay in roughly a hundred years.
14 So the fuel must be completely removed.
In the 15 Russian case, they entomb fuel and all.
That type of i
16 entombment would not be allowed under current NRC entombment 17 regulations.
18 And in fact, if TMI-2 were to be entombed under the 19 regulations, more of the residual fuel would have to be 20 removed.
21 But entombment is a-potential case.
Then you'look at 22 the environmental situation, and you may decide not to' entomb a
]
23 facility that's on an island in the river.
24 So while entombment might be acceptable for a 25 commercial reactor located in a different location, it may not Heritage Reporting Corporation (202) 628-4888
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)
1 be acceptable for this reactor.
We haven't evaluated that.
2 The other thing with regard to waste storage sites 3
and so forth, my understanding of the NRC regulations is if 4
waste has been removed from a facility, and is in a condition 5
which is' ready for disposal, the regulations require that it be 6
disposed of.
7 The water is ready for disposal.
And the regulations 8
would require us to dispose of it.
9 The waste that's in the facility now has not been 10 removed nor packaged nor ready for disposal.
So it's not the 11 storage of waste under the regulation.
12 MS. ROBB:
May I just ask one further question?
13 MR. MORRIS:
No, Ma ' am.
I'm going to let the 14 gentleman back here -- I indicated that he would provide the 15 response but there'd be no follow-up questions, t'
16 1
17 STATEMENT OF TOM BAILEY, CITIZEN 4
18 MR. BAILEY:
Good evening.
My name is Tom Bailey 19 from Harrisbu.ig.
20 I do not have the knowledge that a lot of people who 21 have spoken before me about nuclear events have.
I just have i
22 some reflections.
23 First would be times that I come to the Citizen's 24 Advisory Panel.
The only persons other than utility persons or 25 NRC persons that speak -- citizen that speak -- always speak Heritage Reporting Corporation (202) 628-4888
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against with the utility he's asking for.
2.
When is the last time you hears any. citizen advocate
-3
-- speak for the utility?
I've never seen it.
I ask you to 1
4 think about it.
5 Second, in my understanding of what had happened.this j
6 evening, the utility said we~are at a point now in taking care 7
of the plant that wo are considering worker contamination.
i 8
We feel it might be too dangerous to continue.
And 9
therefore we like to postpone it, and clean it up later 10 possibly.
j 11 The first question is, they've already done from the 1
12 diagram, you saw where Figure 4 was.
Figure 4 is
{
13 approximately, what, 75, 80 percent of the way down?
l 14 Why is worker contamination considered now, after the j
15 job has already been nine, ten years down the road?
Why is it 3
16 important now?
Because it's a false issue.
17 We're dealing with a business.
And when you're 1
18 dealing with business, you're dealing with money.
And that's 19 what the issue is -- is money.
20 If we were a corporate board here, and if these 21 gentlemen and women were standing as a corporation to look out 22 for the interests of the citizens of this area, you would have 23 a proposal before you.
24 You have a contractor that', done work for you.
And 25 think about it in a business sense, because they're a business.
Heritage Reporting Corporation j
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121-1 They have two units here, one, screwed up.
.They had 2
to clean it up.
The other one's still going.
Now the proposal 3
is, let us postpone cleaning up that second one until the first 4
one's done, too.
5 Well, I'm not very smart but I know that one bird in 6
the hand is worth two in the bush.
And if they want to keep 7
the other one operating they should be forced to clean up the 8
one they have now because when they're done with that Unit 1, 9
they' re going to be gone.
They' re going to be out of here.
1 10 I mean, talk business -- talk business sense.
They 11 aren't going to be here when they have no more money to make 12 here.
13 But who is going to be here?
Look around the room.
14 People that live here.
Fred Rice, this man Mr. SmithGall.
15 Smithgall raises the question, who's going to pay for it.
I
=
i 16 guess I don't understand, NRC, GPU -- who's going to pay for 17 it?
18 It'll be taken care of; it's going to be in -- it's 19 in the NRC regulations.
Yes, Mr. Mike is very interested now.
20 I don't trust the government to enforce the payment i
21 of a business debt.
It's a business debt that directly effects 22 all the citizens of this area.
23 And it's going to be there unless they're forced to 24 clean it up now.
I'm going to ask the members of the advisory 25 panel that have not spoken to speak so that we can hear what Heritage Reporting Corporation 2
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you -- especially the three members to the right -- what you 2
have to say.
We'd like to hear.
]
3 My last two comments would be, if this was a business 4
proposal submitted to this as a corporate b'oard, I have no 5
question that it would be denied.
6 It doesn't make good business sense.
The people of
)
7 this area have put up with this for a long time.
It may not 8
have been the smartest thing to do, but now we can't let it 9
continue to where we' re put to a detriment forever.
10 Twenty years down the road -- look at the people that 11 propose these things.
Where are these people going to be in 20 12 years?
The question is are they going to be?
13 We are going to be here -- my generation.
- Yes, l
14 that's one reason I'm speaking up cause I'm going to be here l
15 and I'm going to have to pay.
.g 16 I don't want to have to pay for it.
They made the 17 mess.
Let them clean it up in their lifetime.
18 Thank you.
19 MR. MORRIS:
Thank you.
20 (Applause) 21 MR. MORRIS:
Panel members.
At this point is there 22 any additional comment that anybody on the panel would like to 23 offer at this time?
24 MS. MARSHALL:
Perhaps I could just say that-the 25 comments of the last speaker do have some legitimate sense to Heritage Reporting Corporation 1
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it.
2 I don't think that any thinking person really wants 3
to put off to the next generation what should be taken care of 4
by the people today.
5 And the mention of a sinking fund was supposed to 6
provide for building up a fund which will be devoted to the 7
bench for cleaning.
8 Now whether it should be now, or whether it should be 9
90 years from now, I think is highly questionable.
10 MR. MORRIS:
Any other panel member like to make an 11 observation or a comment?
i 12 (No response) l 13 MR. MORRIS:
I would indicate that during the 14 discussion period prior to the break we were talking about l
[
15 asking for a 30 day extension on the PEIS regarding comments.
5' 16 And then we went into the break, and I talked to 17 several members on the panel.
And they indicated they thought 18 30 days was not sufficient / maybe it should be something longer 19 like 90 days.
20 And then talking to the NRC, they had their own 21 comments regarding the 90 days, and really what the comment 22 period really involves, and what the final PEIS really means.
23 And maybe they could speak to that issue 24 specifically.
25 And I guess what I'm asking them to speak to is what Heritage Reporting Corporation (202) 628-4888
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is the problem with the panel specifically asking for an 2
additional 90 days for further review of the information we i
3 would get from you, and then further discussion by the panel 4
and by the public?
i 5
MR. MASNIK:
I guess I would prefer not to change the.
i 6
date.
But I can understand the panel's position on these two 7
issues, which is the worker exposure and the future funding i
8 issues.
9 And as a proposal I would say let's not change the 10 date, but the information that's generated by the panel and 11 questioned by the panel between now and I suspect October when 12 we can meet with the Commission, those comments and questions 13 will be reflected on quietly.
14 MR. MORRIS:
Tom --
15 MR. MASNIK:
I believe I have the ability to comments t
16 even after the comment period on specific issues.
And what I 17 propose is that we don't change the comment period date on 18 these two issues.
I
{
19 MR. SMITHGALL:
How do you respond to SBA's comments 20 in reference to the configuration on the bottom of'the reactor 21 vessel, and also the inventory of radioactive nuclides in 22 relationship to deciding on PDMS now -- as issues that would go 23 along with the other two that you -just mentioned?
24 MR. MASNIK:
I don't understand the question.
25 MR. SMITHGALL:
In other words, do you feel you have Heritage Reporting Corporation (202) 628-4888
125 1
enough information in reference to the inventory question 2
brought up by SBA in configuration as it relates to PDMS?
3 M.... MASNIK:
Well, I think they've raised the point.
4 And to some extent it's a valid point.
5 MR. SMITHGALL:
Do you feel it's one that would be 6
worthwhile extending the comment period to allow that comment 7
to continue, or final EIS' position?
8 MR. MASNIK:
But I think we're missing the point of 9
what the procedure is here.
That is that the federal agency 10 puts out a draft document.
And people comment on that 21 document.
And those comments are then taken by the agency.
12 And those comments are factored into the final document.
13 Somewhere along the line here we're getting in the 14 direction of some intermediate period of question and answer.
]
15 And I'm not so certain that that's --
i 16 MR. SMITHGALL:
Maybe you missed something.
17 MR. MASNIK:
Well -- and I think they pointed 18 something out.
Anc we have to look at now our docucent and see 19 if something was missed, and if it was missed that we have the 20 obligation to incorporate it in the final.
21 And I think that's the direction I want to go.
Now 22 these other two issues that were raised -- the panel in the 23 last impact statement, we incorporated your comments based on 24 what was contained in the transcript.
25 And I suspect that we would do the same thing in this Heritage Reporting Corporation (202) 628-4888
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case.
And if we have another meeting between now and October, 2
those comments would be incorporated in the final.
L 3
MR. SMITHGALL:
How about the comments of other-4 people, other than the panel?
5 MR. MASNIK:
If they're raised at the advisory panel 6
meeting, I think we can include those.
7 MR. SMITHGALL:
Is it delay that you're_ speaking of 8
based on travel schedules and convenience, or based on other 9
things?
10 MR. MASNIK:
I think it's based primarily on the fact 11 that we've had one notice.
We had a second notice, a second --
12 and extension.
And I want to get on with the process of 13 issuing a final on this particular document, or this particular 14 issue.
15 4
And I'm willing to consider these other two issues
'e" 16 because the panel raises them.
And quite frankly, I think' i
17 they're important.
{
18 And I think that we can do that.
And the final 19 document would reflect it.
And I think we can even go so far 20 as to say that the panel will meet with the Commission before 21 the final is issued.
22 MR. SMITHGALL:
I'm just concerned here that there --
l 23 and I understand the extension.already granted and so forth.
24 I'm wanting to keep moving forward with it.
25 But we're now talking about an extension on an issue Heritage Reporting Corporation (202).628-4888
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that we' re dealing with, potentially a storage issue of 60 2
years, not on an issue as the previous EISes that may have been 3
concerning issues that take place within, say, the next five to 4
ten year period.
5 MR. MASNIK:
I'm not so sure that the final will.
j 6
reflect issues of 60 or 90 years.
And the reason is that is a 7
de-commissioning issue.
Okay?
And that de-commissioning issue 8
9 MR. SMITHGALL:
Twenty years.
10 MR. MASNIK:
-- is based on the de-commissioning rule i
11 which is something that has already been argued before the 12 Commission.
13 That's an issue that this panel -- well, that's an 14 issue that has already been decided.
And there is a final rule 15 out on that, s'
16 MR. WALD:
But the problem is the relationship 17 between the subsequent decontamination and the time of de-18 commissioning.
19 MR. MASNIK:
I understand that.
And that is an issue 20 that there's a problem in the finding between the licensee and 21 the NRC.
But I think the panel has identified that problem.
22 And I think that's one we can deal with.
23 MR. MORRIS:
Mike, if I'm understanding you 24 correctly, that you would not change the August 1st comment 25 period for the public at large, but as to this panel and the Heritage Reporting Corporation (202) 628-4888
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1 public that attends the panel meetings, that the comment period i,
on two issues that were mentioned would in fact be extended as 2
3 for those transcripts to those -- to any meetings we would have j
i 4
between now and October some. time.
5 MR. MASNIK:
Yes.
My understanding is that we have-1 6
the latitude to consider any comments provided after a certain 1
7 date.
And that date would be the end of the comment period.
8 In fact, I believe during the last environmental 9
impact statement we did receive some comments after the fact.
10 And those were incorporated.
11 MR. MORRIS:
Panel members' reaction to what Mike is 12 saying here?
13 Ken?
14 MS. MARSHALL:
Well, Mr. Chairman, isn't the date j
15 which would be three --
\\
16 MR. MORRIS:
Sorry.
Go ahead, Elizabeth.
You're 17 next.
I 18 MS. MARSHALL:
Isn't it behind a couple of months?
I 19 mean didn't we hear that tonight that the cleaning up of the 20 debris --
21 MR. MORRIS:
Yes, the fuel --
22 MS. MARSHALL:
-- is not -- yes.
23 MR. MORRIS:
The fuel removal is' I think at least two 24 months behind.
25 MS. MARSHALL:
Right, right.
So I mean I would think Heritage Reporting Corporation 3
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1 that it might follow that the comment on what's going to follow 2
after that would be delayed also.
3 MR. MORRIS:
So you're suggesting that we-ask for an
.4 extension of the August let date; at least 60 to 30 days is 5
what I think you're suggesting.
6 Ken?
7 MR. MILLER:
Yes.
1 just wanted to remind that Tom 8
Gerusky sent in a number of concerns that he had.
And I want 9
to make sure that they're going to be addressed or answered and 10 filed to EIS as well, 11 MR. MASNIK:
Yes.
I believe my understanding is the 12 state will provide -- but I. net with a member of Tom's staff 13 just last week.
And we discussed some of these concerns.
14 And my understanding is that they will provide a
/
15 formal document before the first of August that will address Y
16 the state's concerns.
17 MR. MILLER:
But if you don't get that you'll have 18 the same questions from the transcript.
19 MR. MASNIK:
Oh, yes.
Again, anything that is 20 brought up in the advisory panel meetings, we -- in fact in the 21 last statement we printed the applicable parts of the advisory 22 panel meetings verbatim in the docket.
23 MR. MORRIS:
Just for clarification, then we'll go to 24 John.
So that I don't misunderstand what you're saying, from a 25 panel and public standpoint, if we world do what you're i
l Heritage Reporting Corporation (202) 628-4888
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suggesting it would limit discussion from the panel as far as 2
impact on the PEIS to two subjects.
3 Now am I misunderstanding that 4
MR. MASNIK:
That's what I would prefer.
Yes.
5 (Laughter) 6 MR. SMITHGALL:
I don't go.along with it.
7 MR. MASNIK:
I say you go from 60 to 90 days.
8 I mean because you can shut the door anytime you want 9
on an issue.
If you want to bring up on comment period, you 10 may say you'll limit it to two, but the comment period ends 11 August 1.
If the comment period ends, it ends.
12 You could shut the door.
You may say tonight we'll 13 listen to you --
14 MR. SMITHGALL:
Tom, I'm more concerned about the
(
15 other agencies and other organizations, because when I put out
\\
16 another delay of 90 days, things tend to get lost.
And I'may i
17 not get comments from a lot of agencies.
18 MR. RICE:
T. think we hr,30 days.
19 MR. MORRIS:
Okay.
Let me ask -- I know John wanted 20 in here.
21 MR. LUETZELSCHWAB:
Somewhere along-the same line.
22 Is there a timeline when clean-up is supposed to end,-
23 when PDMS is supposed to start, and when the Commission is 24 supposed to act on this proposal?
25 MR. MASNIK:
Well, first of all, as we discussed Heritage Reporting Corporation (202) 628-4888
131 1
earlier, the Cou. mission is probably not going to act on it.
2 But PDMS I think is slated for some time next summer, late 3
summer.
4 And we have still the. safety evaluations, and the 5
license amendment process to go through which provides another 6
opportunity to revisit the subject.
7 MR. MORRIS:
Let me offer a suggestive compromise.
8 And if your attempt is to limit, make sure that everybody else 9
out there other than the panel has an August 1 date that you l
10 not try to limit us to taubject matters.
11 MR. MASNIK:
I 12 MR. MORRIS:
The panel and the public, so that at 13 least we have an opportunity to discuss on the record, and for 14 consideration until some time in October any concerns that we 15 have regarding the PEIS.
16 And I think we accomplished what we want to do.
17 We're not asking for extension of time for anybody other than 18 public and panel.
19 MR. MASNIK:
Okay.
20 MR. MORRIS:
And other people can do their own 21 dealing.
I think we get basically what we want to get by doing 22 it the way you're suggesting if we're not limited to subject 23 matter.
24 MR. MASNIK:
Okay.
I would go along with that.
25 MR. MORRIS:
And again, this is up to the panel.
If Heritage Reporting Corporation (202) 628-4888
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the panel wants to do something different, fine.
But I think 2-that this is not limited-from a public standpoint and from a 3
panel standpoint by doing this.
4 MR. WALD:
And furthermore, we're not limited when we 5
meet with the Commission which you said would be before the 6
final is discussed.
7 MR. MASNIK:
We can arrange the schedule such that 8
the impact statement would be issued at the --
9 MR. WALD:
Gi7e us the freedom to add whatever.
10 MR. MASNIK:
I'll temper all of this.
And I think I 11 probably want to talk to my legal staff.
12 But the worse case would be that I would have to 13 grant an extension.
But it's my understanding that we can do 14 this.
15 MR. MORRIS:
That would basically cover Tom's l
16 concerns that something doesn't suddenly happen that vould
'1 17 preclude us from proceeding along those lines, j
18 MR. SMITHGALL:
Yes.
That's my fear.
I would work -
19
- I'm not going to be hard-nosed about this.
But my thought j
,i 20 would be to go for the 60-day extension.
l 21 If that's going to screw anybody's vacation schedules I
22 up and travel schedules up then I'd be willing to go along with 23 what you propose as far as leaving it open for comment
.24 decisions and the panel.
25 My concern there is that it doesn't allow someone Heritage Roporting Corporation (202).628-4888 i
A 133 1
- that might not be considered a citizen to comment.
As I say, 2
my inclination right now would be to ask for a 60-day 3
extension.
4 And as I say, not trying to be hard-nosed about it, 5
I'd be willing to go along with what you propose.
6 MR. MORRIS:
I think we're getting, in this case, 7
closer to a 90-day extension cause we're talking about October 8
some day, and 90-day extension would be November 1.
9 And I think we're looking through at least October as 10 an opportunity to comment.
And I'm understanding for the 11 record that public means any person that comes before us to 12 give a comment whether they're a member of the public or 13 they're a professional from some other area that want to come 14 in and comment if that's part of the public comment.
i 15 That's what I understand, Mike.
That's the ground
\\
16 rules we've had in the past.
17 MR. MASNIK:
Yes.
18 MR. SMITHGALL:
Okay.
19 MR. MORRIS:
Any other comment on this issue?
20 (No response) 21 MR. MORRIS:
If not, can we talk about when we might 22 meet again?
How do you feel about an August meeting?
23 MR. WALD:
What's the timing on the NRC?
24 MR. MASNIK:
Well, 1 guess based on our earlier 25 discussion I will tell the Commission that we have not reached Heritage Reporting Corporation g
(202) 618-4888 1
134 l
L 1
a decision and we would like to reschedule in the October time 2
frame.
3 MR. WALD:
No.
I was asking when you can expect some 4
NRC response on.the worker exposure.
There's no point in 5
meeting before that.
6 MR. MORRIS:
That's right.
7 MR. MASNIK:
I think that that is based to some 8
extent on when we get the licensee subrittal.
Over the break I i
9 discussed with our contractor, and I was told that we do not 10 have the detailed breakdown.
l 11 Maybe Mr. Rogan can speak to that?
12 MR. ROGAN:
Our expectation now is that it will be at 13 least a couple of weeks.
14 MR. MASNIK:
All I can say is that as soon as I get 15 it we'll get it to you in a matter of weeks.
And I understand j
16 that we may have to make some allowances in the schedule if I 17 don't get it to you in a timely manner.
18 MR. MORRIS:
Well, I would hope that if we don't get l
19 it within 30 days that the whole 90-day sequence we' re talking 20 about here may have to be projected further out because it's --
21 MR; MASNIK:
I understand.
22 MR. MORRIS:
-- not going to be helpful to us if we 23 don't.
24 MR. MASNIK:
Sure.
25 MR. MORRIS:
So I think we shoot for getting that Heritage Reporting Corporation (202) 628-4888
l 135
~
-1 information from you by the 15th of next month, at least as a 2
. guideline.
3 And then we need to determine whether we try to meet 4
late August or early September.
Neil is suggesting early 5
September.
6 MR. WALD:
Yes.
7 MR. MORRIS:
Do we agree on that?
8 MR. WALD:
Yes.
9 MR. MORRIS:
Somebody want to take -- 7th or.8th?
10 MR. SMITHGALL:
That's fine.
7th or 8th, that's the 11 first week.
That's a Wednesday, Thursday.
12 MR. MORRIS:
How about Thursday the -- we normally 13 nieet 14 MR. SMITHGALL:
Usually the second..
/
15 MR. MORRIE:
We normally meet Wednesdays or
~
l 16 Thursdays?
Do we normally meet Wednesdays or Thursdays?
I 17 MR. MASNIK:
Normally, I think it's Wednesdays.
18 MR. WALD:
Wednesday.
19 MR. MORRIS:
How about the 7th?
20 MR. WALD:
Okay.
21 MR. MASNIK:
Here or in Lancaster?
22 MR. MORRIS:
Well, it would be nice if it were here 23 but it would be also nice if it would be cooler.
24 MR. SMITHGALL:
Yes.
25 MR. MORBIS:
I think we can do a better job on the Heritage Reporting Corporation (202) 628-4888
136 1
air conditioning.
2 Well, unless there's a big cry we'll probably.end up 3
holding it here.
So it'd be on the 7th, Wednesday the 7th, 4
here, provided Mike could get -- I'm sorry,-September the !th 4-5 in this room.
6 If there's a problem with this room then we would 7
attempt to move it to Lancaster.
But I assume that we'll be c
8 able to get this room.
+
9 MR. MASNIK:
All right.
10 MR. MORRIS:
Anything else to come before this group?
11 MR. RICE:
Mr. Chairman, I have two questions.
12 MR. MORRIS:
Yes, sir.
13 MR. RICE:
I'd like to ask Eric a question.
14 MR. MORRIS:
Eric, would you mind coming up here, 15 please?
16 MR. EPSTEIN:
Weren't you the same people who said 20 17 minutes?
18 MR. MORRIS:
Yes.
As part of your former comment.
19 But now that --
20 MR. EPSTEIN:
That's okay.
21 MR. MORRIS:
-- I mean,.you can refuse to comment if 22 you want.
23 MR. EPSTEIN:
I never refuse to comment.
24 I'm ntt related to Poindexter.
25 MR. RICE:
Eric, this is an easy question.
Heritage Reporting Corporation (202) 628-4888
1 137 1
Every time you come before us --
2 MR. EPSTEIN:
Yes.
3 MR. RICE:
-- and we hear from all the professionals 4
that have all kinds of degrees behind their names and so forth, 5
you infer that they don't know what they're talking about.
6 And if you tell me how you conclude that, because I 7
have always relied on credentials of people and so forth.
And 8
the Safety Advisory Board, I find --
9 MR. EPSTEIN:
3'm glad you asked that.
10 MR. RICE:
-- that I really am concerned about it.
11 MR. EPSTEIN:
Nell, you didn't see one expert here on 12 Economics this evening,.-'hich * '.hink t as very impressive.
He 13 hasn't seen one expert about extrapol4 tion, or someone who can 14 predict the future, which are cwo ersential elements of this, 15 g
You know if you look at your Safety Advisory Panel 16 there's a man there by the name of Norman -- how do you say it?
17 His Wash 1400 report has basically been discredited by the 18 nuclear industry.
And he's being paraded around as a 19 substantial expert.
20 So I think what you reed to do is take a closer look 21 at their experts.
And I think it's safe to st] that when you 22 have somebody speaking on behalf of the utility that has a 23 sense of economic investment at Three Mile Island, at Oyster 24 Creek and elsewhere that they're probably not going to be too 25 objective; that there's going to be a bias.
I think that's a Heritage Reporting Corporation (202) 628-4888
l 138.
1 given.
2 And I think I'm calling into question not the j
3 credentials but the perspective.
4 MR. RICE:
Well, are they being paid by the GPU?
5 MR. EPSTEIN:
I would think so.
Do you think Dr.
6 Marston would be here like I am as a volunteer?
Do you think' 7
that after working long hours he would spend evenings and 8
weekends doing the research that I do?
9 Do you think any of these people would be?
Ask them i
10 some time to work for free.
I'd be interested to see if they 11 would.
12 MR. RICE:
That's what you're doing.
13 MR. EPSTEIN:
Well, do you get your expenses paid?
I 14 mean, I don't want to begrudge your question.
I don't really 15 know that this is really merit worth getting into extensive 4
+
16 discussion.
17 MR. MORRIS:
I agree.
18 MR. EPSTEIN:
And I've got to get up tomorrow to 19 work.
At six.
20 MR. MORRIS:
That's why we tried to have a reasonable 21 limit on speaking arrangements.
22 I appreciate exactly what you're saying.
23 MR. RICE:
I'm one of the experts prepared, too, j
i 24 MR. MORRIS:
Eric?
25 MR. EPSTEIN:
Pardon?
l Heritage Reporting Corporation (202).628-4888
3 139
.1 I've got - _look, the bridge closed to Perry County
?.
two hours ago.
It's a long row across the river.
3 MR. RICE:
I have one other question, not of you, 4
Eric, of Frank.
5 MR. MORRIS:
Eric, thank you very much..
6' Frank, you can chose not to comment, too, if you'd 7
like to.
8 MR. STANDERFER:
Never chose not to comment.
9 MR. MORRIS:
Well, let's.try to keep it brief because.
10 it is not ten of eleven.
11 MR. RICE:
I don't want to belabor the point but if 12 immediate clean-up is started does that put Unit 1 out of 13 commission, because of the tie in?
14 MR. STANDERFER:
Well, if some option like that was
(
15 opted for, we would have to design it.
It hasn't been 16 designed.
I don't know what would be involved in the effort.
17 We're taking the plant to the stage that the 18 equipment and systems and so forth that we have on hand will 19 practically do.
20 And we have to start over with a new study and 21 design.
And it would take some time to do that.
And I don't 22 know whether it would have an impact on finit 1 or not.
23 MR. RICE:
That's all, Mr. Chairman.
24 MR. MORRIS:
Thar.k you very much.
We stand 25 adjourned.
Heritage Reporting Corporation (202) 628-4888
140 1
1 (Whereupon, at 10:52 p.m.,
the hearing was 2
adjourned.)
i 3
i i
4 5
6 7
l i
8 1
1 9
10 11 l
12 i
13 14 15 I
16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
s 1
CERTIFICATE-2 3
.This is to certify that tie attached proceedings before the
,.e-4 United States-Nuclear Regulatory Commission in the matter of:
S Name:
Advisory Panel for the Decontamination of Three Mile E
Island Unit 2 7
Docket Number:
8 Place; HARRISBURG, PENNSYLVANIA i
9 Date:
July 14 1988 10 were held as he, rein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewr'. ting by me or under the direction 14 of the court reporting company, and that the transcript.is a 15 true and accurate.ecord of the foregoing proceedings.
16
/5/Oou04bW hL&MEh s
17 (Signature typed):
ANDREW M. EMERSON 18 Officiel Reporter 19 Heritage Reporting Corporation 20 21 ll2 i
23 24 25 Heritage Reporting Corporation j
-(202) 628-4888
)
i 17/ 7 d
-i 1
1 l 1
1
-1 NRC ADVIS0l1Y PANEL MEETING l
JULY ll4,1988 PRESENTATION MATERI ALS BY F. R. STANDERFER, T (RECTOR, TMI-2 1.
DEFUELING VIEWGRAPHS 2.
PDMS ENVIRONMENTAL IMPACT STATEMENT VIEWGRAPHS 3.
GPUN COMMENT LETTER TO THE NRC ON PDMS ENVIRONMENTAL IMPACT STATEMENT l
h
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0
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- 9. *02xu ras
GPU NUCLEAR COMMENTS DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT NO. 3 PRESENTATION T0 i
THE ADVISORY PANEL FOR THE DECONTAMINATION OF THE THREE MILE ISLAND UNIT 2 F. R. STANDERFER JULY 1% 1988 1
i i
GPU NUCLEAR POSITION STATEMENT l
i NRC HAS USED BOUNDING-VALUES IN PEIS,*
GPU NUCLEAR CONCURS IN THE NRC FINDINGS THAT:
l o
PDMS CONFIGURATION IS ENVIRONMENTALLY SAFE-
[
o BENEFITS OF LONG-TERM STORAGE OUTWEIGH POTENTIAL EFFECTS o
DOMINANT ISSUE IN PDMS ENVIRONMENTAL ASSESSMENT.lS REDUCED OCCUPATIONAL RADIATION EXPOSURE TO TMI-2 WORKERS i
- ACTUAL QUANTITIES OF RESIDUAL FUEL AND CONTAMINATION ARE EXPECTED TO BE LESS THAN THOSE STATED.
I 2~
GENERAL COMMENT
NO. 1:
PREPARATION FOR PDMS e
o PREREQUISITES DESCRIBED IN THE DECEMBER 1986 PLAN, WHICH ENCOMPASSES COMPLETION OF THE TMI-2 "CLEANUP PROGRAM," WILL BE COMPLETED PRIOR TO PDMS.-
r REACTOR DEFUELED AND FUEL SHIPPED OFFSITE 4
POTENTIAL FOR CRITICALITY OR SIGNIFICANT RADI0 ACTIVE RELEASE ELIMINATED SAFE, STABLE, MONITORED PLANT CONDITION HAS BEEN ESTABLISHED I
o ACTIVITIES WHICH MAY CONTINUE INTO PDMS INCLUDE:
i WATER PROCESSING j
l DECONTAMINATION OF FUEL STORAGE AND AGW DISPOSAL SUPPORT SYSTEMS SHIPPING OF RADIDACTIVE WASTE l
COMPLETION OF SNM TRANSFER TO DOE IN
SUMMARY
, TMI-2 WILL BE READY FOR ENTRY INTO PDMS UPON COMPLETION OF THE ONG0 LNG "CLEANUP PROGRAM."
SOME ACTIVITIES MAY CONTINUE INTO PDMS BUT WILL NOT ALTER NRC ASSESSMENT OF ENVIRONMENTAL IMPACT, 4
3
.l i
GENERAL COMMENT
NO. 2:
COMPLETION OF THE CLEANUP PROGRAM
.i 1
o
.GPU NUCLEAR HAS DEFINED THE TMI-2 "CLEANUP PROGRAM" TO INCLUDE THOSE. ACTIONS NECESSARY TO REC 0VER FROM THE ACCIDENT AND PLACE THE PLANT IN A SAFE AND STABLE CONDITION THAT POSES NO RISK TO THE PUBLIC HEALTH AND
- SAFETY, o
GPU NUCLEAR HAS NOT IDENTIFIED ADDITIONAL FUTURE CLEANUP WORK TO BE PERFORMED SEPARATE FROM DECOMMISSIONING.
I o
IT IS NOT ALARA TO PERFORM FURTHER CLEANUP WORK NOW.
i o
THE NRC ALTERNATIVE CASES OF "lMMEDIATE CLEANUP" AND "DELAYED CLEANUP" WOULD BE BETTER TERMED "lMMEDIATE ADDITIONAL DECONTAMINATION" AND "FINAL DECONTAMINATION AS PART OF DECOMMISSIONING," RESPECTIVELY.'
It
A
(
GENERAL COMMENT
NO. 3:
RESIDUAL FUEL I
o THE PEls B0UNDING CALCULATIONS PERFORMED NOW BASED ON AN ASSUMED RESIDUAL FUEL INVENTORY OF 1% OF THE ORIGINAL L
CORE INVENTORY ARE CONSERVATIVE.
l o
DEFUELING IS TO CONTINUE TO THE EXTENT THAT SUBCRITICALITY CAN BE ENSURED.
WE EXPECT TO REMOVE GREATER THAN 99% OF l
THE FUEL.
(
o SOURCE TERM AVAILABLE FOR ENVIRONMENTAL RELEASES IS RELATIVELY INSENSITIVE TO THE QUANTITY OF RESIDUAL FUEL.:
l FUEL IS CONTAINED AND SUBCRITICAL, o
OVERALL CONCLUSIONS OF THE PEIS DO NOT CHANGE BECAUSE l
RESIDUAL FUEL WILL EXIST IN THE REACTOR VESSEL.
l 1
5 l
l
GENERAL COMMENT
N0, 4:
WORKER RADIATION EXPOSURE o
A RECENTLY COMPLETED GPU NUCLEAR ANALYSIS OF OCCUPATIONAL RADIATION EXPOSURE INDICATES SIGNIFICANTLY LARGER PERSON-REM SAVINGS FROM PDMS THAN INDICATED IN THE DRAFT PElS l
AND INCREASES THE ALARA INCENTIVE T0 IMPLEMENT PDMS, o
CONSISTENT WITH THE ORIGINAL PElS, NUREG-0683, 1981,
(.
OCCUPATIONAL DOSE SAVINGS IS THE DOMINANT ENVIRONMENTAL CONSIDERATION IN EVALUATING PDMS, i
j o
SIGNIFICANT REDUCTION IN OCCUPATIONAL EXPOSURE MORE THAN OFFSETS MAXIMUM HYPOTHETICAL ENVIRONMENTAL IMPACT FROM PDMS, i
6
SUMMARY
OF GPU NUCLEAR-PERSON-REM ESTIMATES i
IMMEDIATE POST-PDMS ADDIT 10NAL DECONTAMINATION-ACTIVITIES (PERSON-REM)
(PERSON-REM)
REACTOR BUILDING 6680-14690 2240-4940 AUX. AND FUEL HANDLING BUILDINGS 130 - 280-20 -
50 I
RADWASTE MANAGEMENT 360 -1550 180 - 280 c
{
PDMS TASK 0-0 230 - 490 i
1 APPR0XIMATE RANGE OF PERSON-REM EXPOSURE 7200-15500 2700-5800 APPR0XIMATE SAVINGS RESULTING FROM PDMS 4500-9700 l
7
.1j
GENERAL COMMENT
NO. 5:
PRACTICALITY OF CONTINUED NEAR-TERM WORK j
o "lMMEDIATE CLEANUP," IS A SATISFACTORY, HYP0THETICALLY BOUNDING CASE FOR ENVIRONMENTAL ASSESSMENT, BUT IS NOT-l PLANNED TO THE POINT THAT IT IS AN ALTERNATIVE WHICH COULD BE IMPLEMENTED.
o ADDITIONAL DECONTAMINATION WOULD-LIKELY REQUIRE USE OF DESTRUCTIVE TECHNIQUES.
IN EFFECT, IT WOULD BE A NEW l
PROGRAM SIMILAR TO DECOMMISSIONING-AND WOULD GENERATE LARGE QUANTITIES OF WASTE.
i o
CURRENT LOW-LEVEL WASTE DISPOSAL SITES AND ALLOCATIONS ARE NOT SET UP TO ACCEPT A LARGE VOLUME OF NORMAL AND ABNORMAL WASTES FROM TM1-2.
o THE PDMS STORAGE WILL RESULT IN THE TOTAL VOLUME OF FUTURE RADWASTE TO BE REDUCED AND/0R MORE READILY ACCOM0 DATED.
l l
l t
8
GEf1ERAL COMMENT f10, 6:
PEls
SUMMARY
TABLE S-1 o
GPU f1VCLEAR PROPOSED CHANGES TO TABLE S-1:
COMPARE ALTERNATIVES OVER 'lHE SAME TIME PERIOD COMPARE PDMS RADIOLOGICAL EXPOSURES 70 f1ATURAL
!L BACKGROUf1D RADIAT10t1 TO HIGHLIGHT If1 SIGNIFICANCE DIVIDE TABLE If1TO THREE PARTS TO COMPARE SIMILAR IMPACTS 1
I 1
9
RADIATION DOSE IMPACTS NRC - PEIS NRC - PEIS IMMEDIATE NATURAL POST-PDMS CLEANUP ALTERNATIVE BACKGROUND CLEANUP ALTERNATIVE PLUS 20-YR STORAGE RADIATION l
(24 YR)
(24 YR)
(24 YR)
UCCUPATIONAL DOSE TO TMI-2 WORKERS 2670-5760 PERSON-REM 7170-15520 PERSON-REM N/A BONE DOSE TO THE OFFSITE POPULATION 1
MAXIMALLY EXPOSED INDIVIDUAL 0.001 TO 0.03 REM 0.001 TO 0.009 REM 4.08 REM TOTAL POPULATION 9 TO 20 PERSON-REM 7 TO 9 PERSON-REM 9 MILLION PERSON-REM TOTAL BODY DOSE TO OFFSITE POPULATION WITHIN A 50-MILE RADIUS OF TMI-2 MAXIMALLY EXPOSED INDIVIDUAL 0.0005 TO 0.004 REM 0.0005 TO 0.001 REM 7.20 REM TOTAL POPULATION 2 TO 11 PERSON-REM 2 TO 3 PERSON-REM 16 MILLION PERSON-REM 10
.,VM *%
,e-POTENTIAL HEALTH IMPACT NRC - PEIS NRC - PEIS IMMEDIATE POST-PDMS CLEANUP ALTERNATIVE NATURAL CLEANUP ALTERNATIVE P_LUS 20-YR STORAGE INCIDENCE PROJECTED TOTAL NO. OF CANCER DEATHS OFFSITE POPULATION 0.001 0.0004 352,000 WORKER POPULATION 0.4 TO 0.8 1 TO 2 160 PROJECTED NO. OF GENETIC DISORDERS 0.2 TO 0.4 0.5 TO 1 1,100,000 (OFFSITE POPULATION)
INDIVIDUAL RISKS TO OFFSITE POPULATION CANCER LESS THAN LESS THAN 1/6 1/2,000,000,000 1/5,000,000,000 GENETIC DISORDER LESS THAN LESS THAN 1/10 1/27,000,000 1/11,000,000 11
~
OTHER IMPACTS NRC - PElS NRC - PEIS IMMEDIATE POST-PDMS CLEANUP ALTERNATIVE
. CLEANUP ALTERNATIVE PLUS 20-YR STORAGE
-(24 YR)
(24 YR)
COST ($ MILLION)*
200-320 240-320 RADIDACTIVE WASTE 33,000 TO 32,000 TO BURIAL GROUND VOLUME 74,000 FT3 70,000 FT3 ESTIMATED NUMBER OF 0,5 TO 1 1 TO 3 TRAFFIC ACCIDENTS ESTIMATED NUMBER OF 0.3 TO 0.6 1 TO 3 TRAFFIC INJURIES ESTIMATED NUMBER OF 0,02 TO 0,05 0.1 TO 0.2 1RAFFIC FATALITIES
- NRC COST FIGURES - VALUES ARE SATISFACTORY FOR RELATIVE EIS-COMPARIS0N ONLY.
i 12 i
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GENERAL COMMENT
NO. 7:
SIMULTANE0US DECOMMISSIONING o
PDMS ASSURES CONTINUED SAFE AND STABLE TM1-2 PLANT CONDITION UNTIL DECOMMISSIONING 0F TMI-1.
CLEAR ADVANTAGES:
P0S.clBILITY OF DECOMMISSIONING ACTIVITIES AT
i-2 AFFECTING OPERATIONS AT TMl-1 IS ELIMINATED WORKFORCE CAN BE UTILIZED MORE EFFICIENTLY IN SIMULTANEOUS DECOMMISSIONING OF TMl UNITS ii o
NRC'S fiEW DECOMMISSIONil1G RULE, 10 CFR 50,82 (s) (III),
SPECIFICALLY RECOGNIZES THE PRESENCE OF OTHER NUCLEAR FACILITIES AT THE SITE TO BE A FACTOR IN DETERMINING THE APPROPRIATE TIMEFRAME FOR COMPLETING A DECOMMISS10 Nit 4G SAFELY.
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GPU NUCLEAR CONCLUSION l
BASED ON NRC CONCLUSIONS STATED IN THE DRAFT PEIS AND 4
RESULTS OF THE RECENTLY COMPLETED GPU NUCLEAR ANALYSIS OF. OCCUPAT10NAL EXPOSilRES FOR-NRC-ALTERNATIVES, GPU
^
NUCLEAR CONCLUDES THAT:
PDMS IS CLEARLY THE PREFERRED ALTERNATIVE.
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1 14 1
M HREE MILE in!.AND ALEnr, suc.
y 315 Peffor St. Herrisburg, Penne.17101 0 17)233 7897 July 14, 1988 Tonight I intend to focus on the research and economic parameters of postponing the cleanup of TM1 2 referred to as the Post-Defueling Monitored Storage (PDMS) option. This discussico must necessarily encompass several generic issues associated with decontamination and decommissioning of nuclear power plants. However, before I begin, I would like to clarify several outstanding issues from the last meeting, and comment on some,recent developments.
I would like to draw the Panel 's attention to an incident on May 13, 1988, in which GPU "mis-classified" a piece of reactor core debris (NRC Recion I Inspection Report No. 50-320/88-08, p.5). Similar incidents occurred in August, 1985 and December 1987, and in both instances GPU's license to ship radioactive waste was temporarily suspended. Waste management is a programmatic problem at Unit 2. Moreover, the NRC noted, "we are concerned that your root cause analysis of all events may not be effective in addressing human performance problems in distinction to related technical problems" (IR No. 50-320/88-08, p.1). With these events in mind, how can the public be assured that GPU is competent to manage Unit 2 during PDMS with a substantially scaled down staff?
Perhaps GPU has sensed the public's apprehension. Recently, they have bombarded local newspapers with ads portraying the merit of PDMS. This is not a low-budget venture. A full-page ad during the week in the Patriot News cost S3,553.95, and on Sunday the same ad sells for S3,760.35. Is the public subsidizing this slick PR campaign? How much has this campaign cost GPU? The cost and source of the funding should be disclosed so that the public can make an intelligent decision in this matter.
I want to clarify several issues from the last meeting relating to decommissioning. TMIA is well aware that the Public Utility Commission (PUC) factors decommissioning into the ratebase, but a) there is no criteria to determine dollar amounts, and b) there is no provision for early retirement. in addition, there is no mechanism in place to put money aside for en immediate or delayed cleanup. To date, GPU has failed to detail funding plans for the final phase of cleanup. I'll address this issue in more detail later.
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-If not the ratepayers', then who? General Public 'Jtilities doesn't know where the funds will come from. GordonuTomb indicated to TMIA in a phone conversation on Thursday Juna 30, 1988, further decontamination. funding.goes beyond the Thornburgh Plan. According to Tomb, further cleanup funding "is a little fuzzy." Doug Bedell told TMIA on July.8,~1988, that the "funding question should be addressed at-the Advisory Panel."
Post Defueling Monitored Storage further complicates tiie
' funding picture..At the time delayed cleanup is' projected to take place, almost every license f or a commercial nuclear power plant '
.will have expired! The' nuclear industry will.be. undergoing simultaneous decommissioning. Therefore, funding sources utilized for tne TMI. cleanup will either be unavailable or under' pressure to bail out other nuclear utilities. TMI-l'and Oyster Creek will.
also be undergoing decontamination and decommissioning and those projects'are likely to be under-funded.
In actuality, we are dealing with generic economic-questic'a -
sting to the "back end" of nuclear power produc ese are the hidden costs of decontamination and decommis
.ng, which GPU and the NRC would like to hide for e
another 2e years. This is not a site-specific problem.
To date, there has been no decommissioning of a large, commercial nuclear power plant. Costs are unknown and typically underestimated. Battelle Pacific Northwest Laboratory conducted several studies exanining decommissioning costs between 1979 and 1982. Battelle Studies provided the basis for utility estimates, but these studies were based on the decommissioning of the 22.5 l
MW Elk River plant which operated for only four years.
'w This reactor was 1/40 of TMI 's size. "Many modern reactors can produca 50 times more power and will have operated some seven times as long as Elk River" (Cynthia Pollock, Decommissioning:
Nuclear Power's Missing nk, Worldwatch Paper 69, April, 1986, p.ll). Moreover, there w, no peer review, and the objectivity of P 'telle is called into question due to their heavy reliance on
. tracts from the Department of Energy (DOE),_ the NRC and the Jectrical Power Research Ipstitute (EPRI). When the study was updated in 1984 "costs had indeed risen much faster than inflation over the preceding si:: years" (Pollock, p.26).
Other reports from DOE and RAND Corporation suggest that we can expect cost overruns. For example,
'A January,.1984, report by DOE showed that of the 47 reactors surveyed, 36 reactors cost at least twice as much to complete as origi.nally projected and 13 cost at least four times ac much" (Energy Information Administration, 1983). This demonstrates how unrealistic economic projections at the "front end" or "back end" of nuclear power production are when based on unknown variables.
3
(Note: DOU 's f unds hc.ve come under increasing. pressure to clean up hazardous sites at defense plants. The total. costs range from
$40 to $79 billion [Hazardeus Waste News, June 1988]...Therefore,
. increased research and development funding for decommissioning
/.
I.uclear power plants from this agency is unlikely.)
Not inuch in the way of research is being conducted by.
utilities who hcVe had to close plants prematurely. The entire industry is deferring'instead of developing.
Humboldt Bay: shut-down 12 years ago, because the cost'of refurbishing it to withstand a major eerthquake was more than the original construction and licensing costs..Despite appeals from local citizens groups to dismantle the plant, it was put'into temporary ctorage with no decommissioning funds. set aside.
Dreseden-1: shut-down 10 years ago due to radioactive corro.ve products inside the piping. Partially decontaminated with chemicals in the early 80s. The plant is in temporary storage until Units 2 and 3 are ready for retirement.
Indian Point 1: shut-down in compliance with the Atomic Energy Commission 's regulations ir.197 4, because it. lacked an emergency core cooling system. Waiting for Indian Point 2 decommissioning in 20006.
Fermi 1: put into temporary storage in 1975 due.to an accident.
Peach Bottom 1 put into temporary storage 13-years ago. (If Units 2 and 3 are not restarted, the current decommissioning' fund r
i does not have enough money to decommission any of the units.)
- Saxton Nuclear Experimental Facility - owned and operated by GPL, this 7 MN reactor operated from 1962 to 1972. Saxton was placed in "temporary storage" in.1972 and.s scheduled to be i
dismantled in 1991. Dismantling costs are estimated to be $12 million-200 % of the original. capital costs (Burns and Roe, 1981: 1-3, Ernest Fuller, personal communications, August.15, 1983).
Several trends are readily apparent by examining these reactors: in each case deferring was prompted by inadequate funding; there is a reluctance to undertake unknown tasks; very little is being done in tree way of research and development to decommission and decontaminate reactors; all the above reactors were shut down prematurely placing a etrain on the licensee's cash flow, making research and development impractical; and the NRC clearly accepts "temporary storage" as a :7eans of getting around decontamination and decommissioning.
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Susquchann2%b Alliance p a u m.c m a g e g7ggg July 14th.1988 SUS 00ElWMA VALLEY ALLIANCE'S CObMEtES ON THE NRC'S ENVIRONMEtEAL IMPACT STATEMEIR,SUPPLEMEtE #3, APRIL 1988,CONCERNItU POST DEFUELItU MONITORED STORAGE AND SUBSEQUEtE CLEAl' UP OF TMI UNIT 2.
We understand that the NRC staff uust act upon any proposals subnitted by the Licensee. However,it is unacceptable to us that the NRC print a draft of its evaluation of this proposal in light of the inadequacy of the data presently available. Unit 2 is clearly not close to being prepared for PDMS. tiach work needs to be done, including the canpletion of defueling.
Data,particularly that needed to detennine the quantity and configuration of temaining radionuclides j
has not yet been subnitted and will not be available for evaluation until defueling is canpleted. The purpose of an EIS is to provide enough informtion to both the public and all interested parties so that they can carefully evaluate a proposal and determine its consequences.
Ebrthermore,the information
,(
ir supposedly to permit public intut into the decision making process. Clearly, if inadequate information is provided,the EIS does not met its requirenents as defined in the National Enviromental Policy Act.
There are major weaknesres in the NRC's evaluation of radionuclides and their impact during PDMS. The mst serious weakness is the lack of independence and and objectivity in evaluating this proposal. The NRC uses the Licensee's data rather than any of its own.
In doing so,rather than evaluate the Licensee's proposal with an open mind,they serve only to confinn and grant the Licensee's desires. Hardly an appropriate act for an agency supposedly regulating an industry.
Using the Licensee's data,the NRC has calculated the inventory of radionuclides which will remin in the reactor and throughout Unit 2.
This inventory is
) 'senter' in Table 2.4.
tb references are provided so tnat the public might
.he amount of radionuclides which was iemoved during clean-up and de-fuc Other references provided are fran research undertaken by GPU Nuclear.
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This lack of informtion mkes it mre difficult to evaluate the impact of delnying clean-up.
Page 1
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r-Concerning the discussion about Activation products,Pa e 2.27-if 90% of s
the activation products is assumed to have been remved during 62fueli6g,the research and basis upbh_which this assumption is made should be referen:ed.
1 his is mst important in light of the NRC's admission that refined methods for detennining the transportatiori of debris and radionuclide : d. iring an sceident are not available. M2asurenents of fuel and surfaces may b'e
& aught with errors,both mechanical and human,and therefore public scrutiny of the radionuclide content of Unit 2 during PDt4S is essential. Only with full disclosure of information may this evaluation be made.
Furthermre,if 90% of the activation products is assuned to have left with the fuel or to have been incorporated into stainless steel of the components and is inaccessible,then would not part of this 90% also bn a part of the inventory at the end of defueling,and hence be in addition to the 10% estinated to remain?
Considering Manganese-54,with a half life of 312 days, surely there would be mora than 12 curies left at the end of 10 years as indicated in Table 2.3 he claim that less than one curie of Krypton-85 will rmain during PDMS needs further scrutiny. A review of environmental releases of K-85 during the accident and subsequent clean-up does not account for the total inventory of K-85 present at the onset of the accident.
As late as October 1987,the Licensee j
was unable to account for as auch as 335 caries of K-85.
tr he claim that less than one curie of Tritium will remain during PDtiS also needs further scrutiny. An estimated 8800 curies of tritiun was present at the l
time of the accident. Be NRC claims that the AGW contains 1020 curies.
A review of enviromental releases and additional reports shows that all of the tritiun has not yet been accounted for and therefore there is no basis upon which to conclude that only ane curie will remain in Unit 2.
%is issue is of particular importance to the disposal of the accident generated water and th'.
determination of whether or not. the water to be used in the subsequent clean-up l
is "accident generated water" as defined by the lancaster City Agreement.
j
%ese cmunnts address only Manganese-54, Krypton-85,and tritium, ikwaver, we feel that further scrutiny of the quantity and location of all radionuclides is of vital importance.
%e need for independent evalua' ion of the radionuclide inventory is heightened by the facts that the Licensee has on occasions miscalibrated waste which has lef t i
the island,and wreover by the discovery that instrunentation used for measuring
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strontium was miscalibrated for sonn period of years during clean-up.
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s Be public's' trust in the Licensee's ability to collect accurate dhta has suffered irreversible damage when in 1984,the Licensee was found to have maintained a policy to' systematically falsify critical safety data and destroy.
documents for months leading to the 1979 accident. In light of this.it is incanprehensible that the tEC should rely so heavily on the Licensee's data.
.In December 1983,in Nureg 0683, Supplement.#1,the NRC considered methods'to reduce worker dose at %I Unit 2.
One of the mthods considered was that following defueling,the plant would be placed in storage. he NRC indicated certain obstacles to this procedure which included:
- 1) uncertainties about the developmnt of robotic technology
- 2) Lack of information about the feasibility and safety of interim storage
- 3) lack of assurance that funds will be available for u ltimate clean up here is no evidence in the draft supplement that these obstacles have been eliminated. It is therefore approprate that the NRC notify the public prior to-any decision on PDMS how these 3 obstacles have been overcam to enable the NRC i
to conclude that the Licensee's proposal will have no significant enviromental impact.
j he public requires assurance that not only are efforts being undertaken by the NRC and the Licensee to develop and help finance advanced technology for-the
[
clean-up.but also that funding is put in place for PDMS, subsequent clean-up
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and deew m b ning.
Fbrthermom,a mchanism which enables the State of Pa.
to take mnership of these funds should be made available. Be Licensee stands to save $57million dollars by a reduction in its work force during PDMS..%ese funds should be laid aside for the people in this area who stand to loose,and who nust shoulder the burden of a decaying radioactive site in their back yard..
j It is ironic that in evaluating the regulatory considerations of delayed clean-up,the NRC fails to mntion its policy of encouraging Licensees to remove all radioactive waste from the site when pssible. B is is the policy to which the 4
NRC so fervently clung when the public asked-them to consider and accept the storage of accident generated water on the island until the tritiun had decayed.
It is exactly this kind of behavior thich continues to erode the public confidence in the regulatory abilities of the IEC.
It is not surprising to us that the NRC concludes that any of the alternatives considered in this draft will not significantly affect our environmnt. 'Even the lack of a f.rm factual basis could never preclude the NRC from a finding g'
in the Licensee's favor.
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.m Whether clean-up is imnediate or ' delayed,the public nust suffer the consequences of millions of gallons of radioactive water going into their drinking water supply and the ventiing of radioactivity into their air fran Unit 2 for an unspecified i
pelod of tine.(The Licensee was careful not to designate a time period for PDMS,~
whereas the NRC suggested 20 years,which is mcaningless since there-is no means of enforcenent). Only those who nust carry the burden of radioactive exposure (with., provision of electricity to off-set the cost) have the. right.to decide whether GNN's proposal will not have a significant environnental impact. : The NRC must provide the public with the tools to make such an evaluation. This draft i
does not provi-those tools.
In conclusion,the GC nust provide more information as it arises. They nust-provide the basis and research for their assdmptions. Only when the public has been given this infonnation and sufficient tiinn to evaluate it and provide input to the NRC,only then should the NRC render a decision on this issue which will affect those of us living here for the rest of our lives.
R1rthernere,along with any decision on this proposal the NRC has an obligation to us,the public to:
- 1) Establish administrative procedures which will ensure that the Licensee will t
complete clean-up f
- 2) Obtain a camtitnent that should clean-up be delayed,the Licensee will not refurbish Unit 2
- 3) Ensure that adequate funding is set aside for use by those who clean-up TNI
- 4) Ensure that both the NRC and the Licensee cannit noney to the research and l
develognent of technology to be used in clean-up 1
f%m 6
q Frances Skolnick Page 4 t-e
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DISTRIBUTION LIST FOR MATERIAL TO THE ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND UNIT 2 Chairman Zech 16 H 3 Commissioner Roberts 16 H 3 Rogers if H 3 Corraissioner Bernthal 16 H 3 Commissioner Carr 16 H 3 H. R. Denton, 17 f 2 PANE T. E. Murley 12 G 18 P.O. Box 268 M. Masnik 13 D 16 Middletown, PA 17057 F. Congel 10 E 4 J. Zerbe 2100 Mr. Frank D. Davis M. Libarkin, ACRS H-1016 200 Gettyburg Pike T. Major H-1016 Mechanicsburg, PA 17055 J. Fouchard 2G5 R. Browing, MNSS 4H3 Ms. Beverely Hess, TMI-PIRC Docket File 50-320 016 1037 Maclay Street PDR 016 Harrisburg, PA 17103 LPDR 016 DCS 016 Mr. Edward Charles F. Miraglia 12 G 18 90 Nittany Drive S. Varga 14 E 4 Nechanicsburg, PA 17055 B. Boger 14 A 2 J. Stolz 13 H 3 Mr. John H. Murdoch L. Thonus TMI Site Mail Pouch 44 Kensington Drive R. Conte TMI Site Mail Pouch Camp Hill, PA 17011 L. H. Bettenhausen PCN-1 Director THI Alert c/o Kay Pickering Power Plant Research Program 315 Peffer Street Department of Natural Recources Harrisburg, PA 17102 Tawes Building B-3 Annaplois, MD 21401 Dr. Frank Parker School of Engineering Ms. Ruth Gentle Nashville, TN 37203 1 Virginia Circle Mechanicsburg, PA 17055 Ms. Michelle Voso Society of Nuclear Medicine Susquehanna Valley Alliance 475 Park Avenue, South P.O. Box 1012 New York, NY 10016 Lancaster, PA 17604 Mr. Dave Janes Dr. Sid Langer Analysis and Support Division P.O. Box 1625 U.S. Environmental Protection Angency Idaho falls, ID 83415 Washington, D.C.
20640 Mr. Kenneth L. Miller, Director Mr. E.E. Kintner Division of Health Physics and Executive Vice President Associate Professor of Radiology General Public Utilities Milton S. Hershey Medical Center Nuclear Corp.
Pennsylvania State University 100 Interpace Parkway Hershey, PA 17033 Parsippany, NJ 07054
.h4
r Mr. Bob Leyse Dr. John luetzelschwab EPRI-NSAC Professor Physics 3412 Hillview Avenue Dickinson College Palo Alto, CA 94303 Carlisle, PA 17013-2896 Mr. David J. McGoff Mr. Thomas Gerusky, Director U.S. Department of Energy Bureau of Radiation Protection A-439GTf.
Dept. of Environmental Resources Washingten, D.C. 20585 P.O. Box 2063 Harrisburg, PA 17120 F.R. Standerfer, Director Three Mile Island Unit 1 Elizabeth Marshall GPU Nuclear Corporation 736 Florida Avenue P.O. Cox 480 York, PA 17404 Middletown, PA 17057 Niel Wald, M.D.
The Honorable Arthur E. Morris Professor and Chairman Mayor of Lancaster Department of Radiation Health P.O. Box 1559 University of Pittsburg 120 N. Duke Street A512 Crabtree Hall Lancaster, PA 17605 Pittsburg, PA 15561 Dr. Gordon Robinsor.
Fr. Ford Knight Associate Professor of Westinghouse Electric Corp.
Nuclear Engineering P.O. Box 286 231 Sackett Building Madison, PA 15663 Unversity Park, PA 16802 Jim Detje.1 Dr. Henry Wagner Philadiphia Inquirer Johns Hopkins School of Hygiene 400 N. Broad Street 615 N. Wolfe Street Philiadelphi, PA 19101 Room 2001 Baltimore, MD 21205 Ms. Becky Harty Pacific Northwest Laboratory Frederick S. Rice P.O. Box 999 Personnel Financial Management Inc.
Richland, WA 99352 2 Crums Lane Harrisburg, PA 17112 Mr. Joseph DiNunno 44 Carriage Lane Mr. Joel Roth Annapolis, Md 21401 RD 1, Box 411 Halifax, PA 17032 Ms. Leslie Klein Intelligencer Journal Pro-Women 8 West King Street c/o Judy Branett Lancaster, PA 17603 320 Elm Court Middletown, PA 17057 Sally S. Klein, Chairperson Dauphin County Board of Comission Dauphin County Courthouse Front and Market Streets Harrisburg, PA 17101
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Joyce Corradi Marjorie and Norman Aamodt Concerned Mothers and Wcmen on TMI 180 Bear Cub Road 2 South Nissley Drive P.O. Box 652 Middletown, PA 17057 lake Placid, NY 12946 Francine Taylor Jane Lee 151 Hamilton Rd.
193 Valley Rd.
Lancaster, PA 17603 Etters, PA 17319 Mr. Ad Crable Pepper, Hamilton and Sheets Lancaster New Era P.O. Box 1181 8 W. King Street Harrisburg, PA 17108 Lancaster, PA 17603 c/o Debbie June Dr. Frederick J. Shon John Kabler, Director Administrative Judge Chesapeake Division Atomic Safety and Licensing Board Pane Clean Water Action Project U.S. Nuclear Regulatory Comrission 2500 N. Charles Street Washington, D.C. 20555 Baltimore, MD 21218 i
US Environmental Prot. Agency Debra Davenport Region III Office 1802 Market Street ATTIN: EIS Coordinator Camp Hill, PA 17011 Curtis Building (Sixth Floor) 6th and Walnut Streets Robert L. Vree Philadelphia, PA 19106 Box 72 Middletown, PA 17057 i
Rep. Alan Kukovich House of Representatives Mrs. Ann Trunk Harrisburg, PA 17101 143 Race Street Middletown, PA 17057 Ms. Mary Osborn 4951 Highland Mr. Thomas D. Smithgall Swatara, PA 17111 422 N. Charlotte St.
Lancaster, PA 17603 Dr. B. J. Snyder Mr. John W. Crawford, Jr.
EPC2 11405 Farmland DR.
11005 Hunt Club Dr.