ML20154D520
| ML20154D520 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 09/07/1988 |
| From: | NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2 |
| To: | |
| References | |
| NACTMI, NUDOCS 8809150306 | |
| Download: ML20154D520 (112) | |
Text
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\- tmh s UNITED STATES -
l NUCLEAR REGULATORY COMMISSION l
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In the Matter of:
) i ADVISORY PANEL FOR THE DECONTAMINATION )
OF THREE MILE ISLAND, UNIT 2 )
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9 I l
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Pages: 1 through 109 Place: Harrisburg, Pennsylvania l
- Date September 7, 1988 j
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- HERITAGE REPdRTING CORPORATION -
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- 3 122e t ser.e, N.w., sun. 6ee ;
Wasnington, D.C. 20065 i j
(242) 623 4ssa j 8809150306 080907 PDR \ 1 l ADOCK 05000320 PNU \
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UNITED STATES NUCLEAR REGULATORY COMMISSION 4
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ADVISORY PANEL FOR THE )
DECONTAMINATION OF THREE MILE ) '
ISLAND UNIT 2 ) -
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i Ballroom A&B Holiday Inn
- 23 South 2nd Street !
j Harrisburg, Pennsylvania
- Wednesday, '
I September 7, 1988 7:05 p.m. ,
c
, APPEARANCES: [
ARTHUR MORRIS, Chairman I 1 i NEIL WALD
- i t i FREDERICK RICE '
i l GORDON ROBINSON 1 l JOEL ROTH THOMAS SMITHGALL i
) KENNETH MILLER {
, ANNE TRUNK I I >
- ELI"ABETH MARSHALL i THOMAS GENUSKY !
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1 t i .
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! 2 i 1 PROCEEDINGS 2 CMAIRMAli MORR13: Good evening, ladies and
- 3 gentlemen.
4 I'd like to begin the panel meeting at this time.
5 With Neil Wald's arrival, we have really a full
, 6 panel, except for John Lukiswak, who had indicated at the i
7 last meeting that he could not attend today, and I' d like to 8 ask the panel members as a reminder from Mike Masnik if you 9 would look at the roster that has been handed out and 10 correct your addresses on it, if there are any corrections 11 to be made. Apparently there were members of the panel who 12 were not receiving transcripts and other mailings, and it 13 would be helpful if we could update that tonight.
14 Since the last meeting, I did receive several 15 letters.that I'd like to at least mention for the record.
16 Two of them were from Dr. Robert Marston, the Chairman of 17 the TMI 2 Safety Advisory Board. One of them pertained to a 18 statement that was made at the meeting regarding Professor 19 Norman C. Rasmussen, and I'd like to provide a copy for the 20 record on that, where he took exception to a comment made 21 regarding Mr. Rasmussen and his work and felt that Professor 22 Rasmussen was an outstanding individual, and he wanted to 23 set the record straight, and this letter will be provided 24 for the record, 25 There was also another letter provided by Dr.
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. o 1 Marston rcgtrding cy rcquOct ct the ccoting for ninutoa of 2 the TMI 2 Safety Advisory Board, specifically regarding any 3 discussion that took place at the board regarding providing 4 funds for TMI 2 Decommissioning.
5 He did acknowledge in his letter that there was no 6 such reference in those minutes. He said providing the ft'nds 7 for TMI 2 Decommissioning was not considered to be a safety 8 matter and, therefore, only brief recognition was given to 9 the funding requirements in the board's discussion of the 10 PDMS. As a result, there was no mention of them in the 11 minutes of the meeting.
12 And, then, the third letter that I received, I'd 13 like to mention, is from Ed Kintner, Executive Vice 14 President of GPU. There was a discussion at the last meeting 15 regarding funding for the PDMS, and I'd just like to read 16 one sentence out of this, and I believe that this letter, if 17 it's not part of today's minutes, was included in the last 18 -- in the minutes of the last neeting.
19 But the sentence I'd like to read goes ao follows:
20 "GPU Nuclear understands that the rule applies to TMI 2 and 21 would Cever all activities involved in the decommissioning 22 of the plant starting from post-defueling monitor, storage, 23 conditions", and that's the ruling involving the general 24 requirements for decommissioning of nuclear facilities that 25 was published by the NRC, which requires licensees to submit Heritage Remrting Corporation (202) 628-4888
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by July 1990 o rcport containing plano for d ccmmicoloning 1
1 2 all licensed reactor plants..
3 With those brief comments, that really concludes 4 my portion of the agenda, and we can now move along to Item l 5 2 on the agenda, which, I believe, if I can find my agenda, 1
] 6 is a status report by the GPU staff.
1 7 MR. STANDERFER: I'm Frank Standerfer, Director, l 4
8 TMI 2. ,
9 I have with me Mike Roche, and I called Chairman 10 Morris last Thursday, and I think we have a copy of an 1
11 announcement for the panel members, announcing m) decision 12 to leave the position of Director, and Mike is named the new l s
13 Director, i
j 14 He'll be assuming those duties in about a month. !
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] 15 He's going through transition activities at the office at i 16 the present time.
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- 17 When 1 came here froa Seattle, I had planned to be !
i I j 18 here four years, and it's been a little over four years, and ,
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1 19 for several personal reasons, I decided to stick with those i
) l 20 plans. I hate to not follow the project to the end, but I (
i 21 think things are pretty well under control and headi..g 1
22 towards completion.
23 I would like to introduce Mike Roche and ask him i I
i l 24 to make a few comments about his experienca and background 1
25 with GPU. I HeritageRggorgggggggporation
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5 1 MR. ROCHE: I CtortCd with tho GPU Cystem in'1974 2 as an Environmental Scientist, the first one that Jersey i >
j 3 centsti over hired.
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4 My background prior to that was that I have had a ;
5 Bachelor's Degree in Biology from Villanova University. I t
o 6 was born and raised in Philadelphia. I have a Master's j 7 Degree in Oceanography from the City University of New York, l [
l 8 and after working for about eight years in or:eanographic [
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9 research, I started working in the ensironmental field at i 10 Jersey Central. !
11 Mike Hasnik was my counterpart with the NRC. He i
i 12 and I had a number of dealings as I was doing nonitoring, ,
j 13 environmental monitoring around the Oyster Creek plant,
] 14 which is another GPU plant, in South Jersey.
! i 15 Since 1980, I have worked for GPU Nuclear in a i
- 16 series of jobs that initially began as environmental I I i 17 monitoring and as time went along, I took on other tasks, 18 leading to my current position with GPU Huclear, where I'm i 19 in charge of radiological controls at all the GPU Nuclear l 20 facilities, environmental controls, emergency preparedness, J 1 21 the medical department, and the industrial safety !
I 22 department. I 23 So, I've been in that position since mid-1987. I 24 spent a short while working in maintenance, about nine 25 months, working in the company's maintenance department as {
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- 6 1 D puty Director.
" 2 My experience with TMI 2 started just after the 3 accident, when I joined GPU Nuclear. The environmental work 4 that I was doing had TMI 2 involved in, and since then, I've 5 had, in one way or another, a support role to tha TMI 2 6 project, either strictly environmental or as, in the later, 7 more recent years, in industrial safety, medical, emergency 8 preparedness, and radiological controls, 9 You might wonder why an oceanographer would be i
10 useful in TMI 2, and I've often said to Frank that there's a '
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- 11 lot of parallele. Oceanographers typically are working on i
! 12 top of the ocean and probing through murky depths deep in '
l; 13 the bottom to try to discover some thing. Well, we know I
14 what is at the bottom of TMI 2. ,
15 A lot of the scientific principles are applicable, t
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16 and I know this job is going to be a challenging job for me. ,
17 My short-term goal is to try to understand the complexities >
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j 18 of the job. My long-term goal will be to ensure the safe :
J 19 completion of the defueling of TMI 2 reactor. ;
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- 20 I have another subsidiary job that I've been doing i l
21 since 1982, and that is the company does own a small 22 research reactor in central Pennsylvania, the Saxton plant, i
23 and I've been involved in the monitoring of that plant, 24 The plant was mothballed in the early 1970s, and I
{ 25 I've been working on that monitoring and in the next couple 1 ,
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, i 1 of yocro will bo'discantling thct picnt. So, I hevo been ;
2 involved and responsible for that as a vice president of 1
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3 that company.
I 1 4 If anyone has any questions, I'd be glad to answer 4
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! 5 them. I come to you with my training wheels on. l 4
6 CHAIRMAN MORRIS: I don't see anybody with any I 7 questions at this point.
1 8 I do certainly want to wish you well and r f i
9 congratulate you, Mr. Roche, and indicate, I'm sure for the :
I j 10 panel, that we look forwerd to working with you and to i j
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. 11 Frank, I've always personally found you an individual that l
1 12 has been very open and direct with us and an honorable i f
- 13 individual, and I will miss seeing you here. I i
14 I think we've had other directors at otbr- times l
15 that have, at least from my standpoint, not been as open and l l 16 direct with us, and I appreciated working with you, and I !
I t 17 wish you well in the future.
18 MR. STANDERFER: Well, thank you. I found these j
19 meetings stimulating, and I have appreciated the interest in !
i q 2 ') all of the regular attendees in the project.
21 I'd like to go over some of the status. On the i
j 22 16th of August, we submitted the safety analysis report for 4
23 PDMS, and the license change documents, the new technical
- 24. specifications and so forth. That's all part of the process 25 of presenting the PDMS documentation to the NRC.
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, l 1 Includ:d in thOt SAR 10 th0 Cvaluction of tho I
j 2 occupational exposure for additional work to be done either l 3 near-term or on a delayed basis. That - part of that i
4 submission is the raterial that the NRO has reviewed and 5 will be discussing review on under Topic 4 of this agenda.
1 6 We have finished flushing water through the block i 7 wall in the basement. If you remember, we drilled holes in
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8 three of the five walls as an almost experimental method to .
l 9 see if we could fluch water down through that block wall and f l
- 10 flush some of the radioactivity out of the wall.
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1 11 We're currently have to remove the material from !
j 12 the floor, but we believe that we removed at least thirty l t
) 13 percent of the material from the wall. The estimate was that i l
! 14 we could do somewhere between twenty and eighty percent, and l
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l 15 when we remove the material from the floor, we'll have a a
f i 16 better number as to how effective that flushing was, but l l '
- 17 that was an attempt to reduce the radiation levels in that t t
l 18 area of the basement.
i l 19 with regard to defueling progress, I've ahewn a 20 number of viewgraphs over the last two or three meetings
! 21 We're cutting our way through the lower support structure.
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22 We have removed the top two layers.
l 23 We're now working at the third layer of five
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24 layers. It's the forging. This one is more complicated in j 25 that, in addition to cutting the forging, we need to cut a 1
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1 numb 0r of supp;rt pacto off. Tw:nty-cight cf tho forty-cight 2 support posts have to be cut off at this location. Also, 3 thirty-four of the fifty-two end core guide tubes have to be 4 cut off.
l 5 So, there's a number of additional cutting, and 6 I've got a couple of viewgraphs to just give you an idea of l 7 what that looks like.
8 We have a new computer system that we put ir.to use l 9 this suamer, and this is 2 view using that computer system l
l 10 from the center of the r6 actor vessel looking north, and 1
l 11 it's about a 120 degrees -- I guess it's about a 60 degree 12 segment. -
13 This computer system, we can rotate this and look 14 at it from different angles and so forth, and I'm just going 15 to show you two views.
16 This was a view looking north on the 29th cf 17 Au gu st , and this is the forging here. These are the holes in 1
! 18 the forging. These blue pieces are the support posts. They 19 are support posts. That's a full length support post.
20 These are support posts that have been cut off,
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21 but the top piece hasn't been removed yet. These have been l
22 cut off and the tops have been removed. These red items are I 23 the end core guide tubes. The yellow are end core guide 24 tubes that have been cut off, and those places where forging 25 cuts have started to be made are shown here, and we keep l
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f I 10 1 thic current cvory day.
2 As you can gee, this is three days later, and l
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3 there are more cuts in the forging and these support posts 4 that have been cut but not removed and been removed, and !
5 this computer medel also has the capability to show fuel. !
6 There is fuel back in these corners back in here, and Siso !
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7 has the capability to put tools into the model to tell l
8 whether the tools interfere with any ot' the pieces or will 9 fit back into the corners.
l 10 So, it's quite a powerful tool we're using. I l 11 might say that as we make some of these cuts, there is fuel h
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12 in the vicinity of some of the cuts, and we, in August, as f 13 that fuel is heated during this cutting process, small i 14 minute quantities of Krypton have been released. '
15 We released in August a little less than one-tenth l 16 of a curie per week in this activity. That is, the tech spec j 17 limitation for release of Krypten per thousand curies leaks, t
18 so far balow the limits for release of Krypton.
19 It's of interest in that there is Krypton i
20 remaining in the ceramic fuel and in the locations and one I l
l 21 has seen that it can be released, and I mention that as an I i
22 item of interest. i 23 I have a brief video tape which again will show 24 this area and there's two basic view's. The first view is in f 25 July, after we removed the distributor plate, the second ae-anmar eu- i i
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, . i 11 1 picto down, cnd you'll sco tho fuol d:bris on tho forging '
2 and the rods in the forging holes. .
3 This is one of the support posts here. Adjacent to 4 it is, on the right hand side, is one of the end core guide 5 tubes. As you can see, there was a lot of fuel debris in 6 and on the forging when the distributor layer was removed.
7 HR. RICE: Frank, are those loose pipes?
l j 8 HR. STANDERFER Fuel rods. They are fuel rods. A }
l i l 9 short piece of fursA rods. I 10 Now, this is about two weeks later, and you can l [
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11 see that that's all been removed. The holes that we're going j 12 to cut in, we actually put the forging on those holes that 13 have been cleaned out, and we' re ready to start the plasma l 14 are cutting in this area.
15 This is a little mini-dumpster that material is (
t 16 put into and then that is dumped in one of the fuel cans. l 17 So, that's a cornponent to translocating material.
18 This is a gauging tool which we use and after i 19 cleaning out the forging holes, we've pushed this down !
20 through the forging holes to make sure that wu've cleared T 21 the forging holes completely because the plasma are cutting i
22 torch fits fairly tightly into the hole. ;
23 In the foreground here is one of the support posts 24 that we're cutting off and one of the guide tubes, and the :
25 next picture is kind of dark, but it's one of these support Heritage g g g p ration f
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12 1 ponts cut off. Tharo's fuol insida tho support poct. Thoro 2 is four and a half inch diameter of pipe, half inch wall.
3 This is one of those, and there is fuel in there whf.ch we 4 will remove before removing the piece of the forging.
5 With that, we're prepared to answer questions, if 6 you have any.
7 CHAIPJDJi MORRIS Anybody have any questions on 8 the status of the clean-up?
l l 9 MR. SMITHGALL: Frank, where's that put you on l
l 10 your chart?
l 11 MR. STANDERFER: Okay. The latest one of those 12 charts, I've got one here. Why don't I show it to you? It l
l l 13 hasn't changed that much.
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14 We are at 203,000 poundo. This material is the l
1 15 material you saw on that forging that was removed, and this 16 is the fuel shifting line. The shifting is keeping track 17 with the --
18 MR. SMITHGALL: Excuse me, Frank. 203,000 defuel?
l l 19 MR. STANDERFER: 203,000 defuel, a 191,000 shift.
20 Yours in an old one. Let me --
21 MR. SMITHGALL Sorry. That'e fine.
22 MR. STANDERFER: I only have one copy here, but 1
23 you can have that.
24 As you can see, we're running behind schedule. As 25 I said, the good news is this cutting equipment is working l
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13 1 tho way it's suppocOd to work. Th$ b0d n:ws 10 it's working 2 slower than it's supposed to work. .
3 So, one of the things that Mike is doing right now 4 is reviewing ou. schedule. We plan to have a revised 5 schedule available later on this month with resgard to our 6 estimate for completing defueling.
7 MR. SMITHGALL It appears that remains a little 8 flat from pretty much the beginning of the year.
9 MR. STANDERFER: Yes. We've been -- since the 10 beginning of the year, since January, we've been cutting our 11 way through this lower support structure, and, of course, 12 you don't see much progress with regard to removing pounds, 13 but we've made several hundred cuts.
14 We've removed two of the five layers, and we're 15 fifty percent of the cuts have been made in the forging 16 layer to remove it.
17 MR. SMITHGALLt So, in July, you reported to us 18 that you're approximately two months behind what you had 19 talked about since the beginning of the year, Is that pretty I
l 20 much where we're at r.ow?
I 21 MR. STANDERFER No. We're about three behind now. i J !
22 CHAIRMAN MORRIS Any other questions?
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23 (No response.)
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{ 24 CRAIRMAN MORRIS Thank you, Trank.
5 25 If we could move on to the status of NRC BeritageRgprgggggggporation 4
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14 1 cctivitios, NRC stoff report, and whilo tho stoff is ccoing i
2 up, I'm going to try to stay on schedule because we have a 3 fair amount of discussior. for the panel to hold, and we'd I 4~ like to allow some public comment at that time as well. ;
, 5 Und*r Item 6, Public Comment, that time should be 6 twenty-five minutes, and it's to be shared by three members r
7 of the public who have requested time on the aganda. Debra ;
6 Davenport requested five minutes. Eric Epstein requested ten i I
9 minutes, and Francis Skolnick requested ten minutes. l 10 So, their comment would appear right prior to the l l
11 break this evening for those three members. t i
12 HR. HASNIX: Mr. Chairman, I'm Mike Hasnik, and f i
13 with me I have Lee Thonus. {
14 There are thret (tems I'd like to bring to the !
15 panel's attention tonight: The first is the inattentiveness 16 issue with regard to the licensed operator at THI ..
l 17 I think you're aware that the NRC Office of i
18 Investigations is conducting an investigation into the l l
19 allegations of inattentiveness to duty on the part of a l t
20 shift supervisor and management's knowledge of and response t
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21 to those allegations.
22 The licensee conducted its own investigation into '
23 this matter and made public the results recently. The 24 results of the investigation are contained in the document 25 called The St.ter Report, which you have seen.
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15 1 ThO NRC OI invCstigCtian is currcntly undar 2 Headquarters review, a,nd I have been told that it will be 3 completed by the first of October.
4 The report will be issued to the Executive 5 Director of operations, the ranking individual below the 6 Commissioners.
7 The report may also be given to the U.S.
8 Department of Justice. The decision nhether or not to give 9 the document to the Department of Justice nas not been made 10 yet.
11 If the decision is not to give the report to the 12 Department of Justice, the report will be released. If it 13 is given to the Department of Justice, it will not be l
14 released until the Department of Justice acts on the report.
15 If they decide to pursue the issae, it will not be released, 16 and if they decline to pursue the issue, it will be 17 released.
1 18 The NBC staff may, through our Office of 19 Enforcement, take appropriate enforcement action after the 20 report has been issued to the LDO.
21 What this means is that wo are independently 22 pursuing this matter, and it will take some time before it 23 is all over.
24 The NRC technical staff will review the OI report 25 when it is issued next month and will take immediate Heritage g gg p ration
16 1 cppropricto cetion thtt 10 n0c0cacry to cncuro tho sofcty of l 2 the public. !
3 This action would be independent of any [
4 enforcement action if appropriate, which would undoubtedly j 5 take much longer.
6 Are there any questions on the flow charting of I 7 this issue?
8 HR. ROTH: Mike, if Justice does nothing, how long l
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9 will it be before you do something? ,
10 HR. MASHIKI They will either notify us that they I i
11 accept or decline. There is a memorandum agreement that is 12 in the process of being finalized between the NRC and j Justice, and they're talking about a three-month time frame.
13 14 MR. ROTH: The reason I ask is because I believe a {
15 couple of years ago, there was a problem between Justice and {
16 the NRC where Justice said they had given materials back to [
17 the NRC and nothing happened until we found out that you
- 3. 8 guys, you know, had the information and nothing was being 19 done.
20 Do you remember that episode? i q
21 MR. HASNIKI I == no, I don't.
22 MR. ROTH: Well, I think you should refresh your (
23 memory because that did occur about two years ago, three f 24 years ago, where we received a letter from somebody in 25 Washington stating that Justice did forward the information >
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17 1 back to tho NRC cnd nothing was -- you know, nothing h0d l I
been done.
1 3 People were blaming Justice for doing nothing just 4 to say we had sent it back to NRC for some type of action, !
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l 1 5 and we nad, I believe, one meeting, I think it was in l l
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6 Lancaster, you know, devoted to that, and that's the reason
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l 7 1'm askint.
- 8 It seems that that can really find a crack 1
1 9 somewhere and just become hidden.
) 10 HR. MASHIK: Well, I believe the system is bette' (
( t 11 now than it was several years ago, but there are two is' x f 12 here. !
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13 One is the safety issue and the other is the j f 14 enforcement issue, and what I've tried to explain here is ,
l 15 that the safety issue can be haadled immediately if, indeoc, ;
t 16 there is one, and the enforcement issue will take some time, i I
j 17 as enforcement issues and actions take time, if an l
1 i 18 enforcement action is appropriate in these circumstances. i i 19 HR. GENUSKY: A question. Can Justice and NRC both 20 take enforcement action? !
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i 21 HR. HASNIK They could. It's my understanding i
j 22 they could, but it would probably be a coordinated activity, i 1
j 23 if both chose to do so.
24 The next item is an update on the accident-25 generated water hearing.
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. o 18 1 On August 25th, the Atomic Safety and Licensing 2 Board issued an order ruling on the motions for summary 3 disposition of the contentions filed in May and June of this 4 year by the licensee and the NRC.
5 You have a copy of the order before you. Since 6 it's ninety-two psges long, I thought I'd spend a few 7 minutes and just summarize thu ruling.
8 The Board ruled that contentions 1, 3 in part, 9 4 (b) in part, 4 (c) , 4 (d) , 6 and 8 fail to raise genuine 10 issues of material fact. Therefore, the liaensee's motion 11 for summary disposition was granted.
12 What this means is that these issues will not be 13 considered further and are dropped from the hearing.
14 Contentions 2, 3 in part, 4 (b) in part, and 5 (b) 15 raise genuine issues of material fact and will be litigated.
16 I'll go through those that essentially will be 17 litigated.
18 Contantion 2 asserts that the lihC's environmental ,
19 impact statement fails to cceply with the requirements of 20 !! EPA because the ITRC failed to conduct a conclusive risk 21 benefit analysis of the no-action alternative.
22 Contention 3 stetes that the EIS fails to comply 23 w'th ITEPA because the EIS has not demonstrated that the 24 benefits of evaporation process will exceed the cost ano '
25 risk to the public.
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19 l 1 Specifically, the Doard's order stated that the ;
2 NRC's assumptions with regard to the concentrations of I
3 radio-nuclides in the AGW or accident-generated water may be l 4 invalid.
5 Contention 4(b) asserts- that sufficient evidence l
6 has not been provided to assure that the evaporator can !
7 filter out transorganics, other radio-nuclides as well as f 8 chemicals to protect the public health and safety. j l
9 Contention 5(b) states ths; M NRC staff and ,
in licensee has under-estimated the eff#a.s of tritium and 11 alpha-omitting nuclides on human beings. [
12 The Board suggested a schedule for the hearing 13 with testimony due the lith of October, rebuttal testimony 14 due the 24th of October, and the hearing from 31st October i
15 to 4 November. l 16 The location is tentatively in Harrisburg, but I !
I 17 understand that the joint intervenors have requested that i 18 the location be moved to Lancaster for their convenience.
19 The Board has not made a decision, a final decision on I i
i 20 either the schedule or the location of the hearing.
li 21 Any questions on the accident-generated water I 22 hearing?
23 CMAIPJ4AN HOPAIS: Just a light note on Lancaster.
24 The City Council Chambers are available providing you pay 25 your bill before October.
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- 1. MR. MASNIK: The final item is PDMS-SAR.
I 2 on August 16th, 1988, the licensee submitted a 3 safety analysis for PDMS, and Frank spoke about that earlier 4 this evening.
5 The submittal included a system-by-system analysis 1
6 of the plant in the PDMS condition. It included a revised '
7 poosession-on.'y license and a new set of PDMS technical 8 specifications.
9 Also included was the man rem estimate for 10 occupational exposure, which will be the subject of further 11 discussion in a few minutes. I 12 The PDMS-SAR submittal forms the basis of the 13 licensee's safety review. In order for the licensee to 14 enter PDMS, there has to be a change in the license. This 15 license change involves a safety review and an environmental 16 review.
17 The PEIS Supplement 3 will form the basis of the '
18 staff's environmental analysis while a tsview of the 19 licensee's recent submittal will form the basis of the 1 20 safety review.
21 We expect to be working on this review the rest of l 22 the year and probably into next spring. The licensee's l
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23 amendment will be handled just like any other license '
24 amendment, allowing for.a hearing if genuine issues in the {
l 25 eyes of the ASLB are raised.
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21 1 That's a copy of the report over there, the two-2 volume set, and I'll make it available to any panel member 3 that wishes to have a copy, but because of the size of it 4 and the number of fold-out pages, if you request it, be 5 certain that you really do need it.
6 CHAIRMAN MORRIS: Is there an executive summary to 7 that?
8 MR. MASNIK: Yes, and you have been provided that 9 in one of the mailings. It may be in the one you got today 10 as well.
11 If any panel member wants a copy, see me some time 12 this evening, and I'll make one available.
13 CHAIRMAN MORRIS: Any questions on the first part 14 of the NRC staff report? If not, we can move right on to 15 the, I guess, Number 4, which is Results of NRC Review of 16 Licensee's Occupational Exposure Estimates for PDMS.
17 MR. GENUSKY: I have a question.
18 Where would the public be able to see a copy of 19 that report?
i 20 MR. MASNIK: It would be in the local public l
21 document room.
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22 MR. GENUSKY: Which is where? In the state 23 library?
24 MR. MASHIK Yes. That's correct.
25 MR. GENUSKY: Since the NRC offices are closed now l
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22 1 down at TMI at Middletown, they won't be available in 2 Middietown any-ore.
3 - MR. MASNIK: No.
4 MR. GENUSKY: Okay. Thank you.
5 It's also availacle in our office if anybody wants 6 to see it.
7 MR. SMITHGALL: Where are you these days?
8 MR. GENUSKY: Same old place. P.O. Box 2063.
9 MR. MASNIK: Recall at the July meeting, the 10 licensee provided the comments on the PEIS Supplement 3, 11 which included the licensee's estimate of occupational 12 exposure for both immediate and delayed clean-up.
13 The NRC staff received these comments just several 14 days before.and did not have the time nor the back-up 15 information to perform a review of the licensee's submittal.
16 The licensee provided the detailed technical 17 documentation of their analysis on August 12th,'1988, and
- 18 our contractor at PNL has been working day and night to 19 complete our review by tonight's meeting.
l 20 You met our contractor during the last two 21 meetings, Ms. Becky Hardy of Pacific Northwest Labs. She was I 22 unable to attend the meeting tonight. So. I volunteered to 23 present the results of her review of the licensee submittal 24 and a re-analysis of occupational exposure.
25 She has prepared a hand-out for the panel which I I
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2 As a matter of background, there are three 3 components to an analysis such as was submitted by the 4 licensee. A task-by-task description of what needs to be 5 done, the exposure rate estimates based on the general 6 radiation levels in the area that the tssk is to be 7 performed, and the job hours or manpower and time needed to 8 perform the task.
9 The methodology superficially is quite simple. You 10 Ldentify what you need to do, you determine the general 11 radiation level in the area that you plan to do the work,
't 12 and you multiply it by the job hours required to complete 13 the task.
14 In actuality, it is not an easy task since much of 15 the data used in these calculations are estimates.
16 What the NRC staff did was first understand the 17 licensee's methodology, and this involved numerous 18 discussions with the licensee staff and some additional
~
19 documentation.
20 Next, we looked at what the licensee submitted and i 21 determined if their estimates were reasonable. I 22 This entailed an examination of their lists of 23 tasks, their estimates of general area radiation levels, and 24 their manpower requirements.
25 Finally, the NRC staff took the new information l
BeritageRe$frtinECorporation (20 628 4888 !
l l
l
24 1 provided by the licensee in their submittals and re-2 estimated the occupational exposure for both immediate 3 clean-up and delayed clean-up.
4 One asks how was the licensee's recent submittal 5 different from the analysis we performed when we wrote Draft 6 Supplement 3 to the PEIS. First, we should explain that the 7 dose estimates in the Draft Supplement 3 were developed 8 using Final Supplement Number 1 to the PEIS, which dealt 9 specifically with occupational exposure.
~
10 Tasks were added that had not been previously 11 considered and tasks were deleted that had already been 12 performed, and job hours were adjusted for tasks that were 13 partially completed.
14 The licensee, on the other hand, used a recent 15 report 'which formed the basis for the task descriptions and 16 the task job hours.
17 As we mentioned earlie'r, the three components to 18 an estimate are the list of tasks, the exposure rate 19 estimates and the job hour estimates. Let's examine each of 20 these components.
21 The task-by-task listing of the two estimates 22 differ principally due to the addition of tasks that the NRC 23 had not considered previously and, in some cases, tasks were
{
24 considered by the licensee which the Draft Supplement 3 had 25 assumed had been largely completed.
l Heritage Reprting Corporation (202) 628-4888 !
l 1
4
^ -
25 1 The second component, exposure rate estimates, I
2 were essentially similar in both the Draft Supplement 3 3 analysis and the licensee submittal.
4 The third component, job hour estimates, differed 5 significantly. The job hour estimates for task by the NRC 6 were considerably lower than those estimated by the licensee 7 in their recent submittal.
8 This difference is due in part to the assumption 9 by the NRC that decontamination methods would be employed to 10 complete the clean-up in the most expeditious manner, by 11 using largely destructive methods.
32 In some cases, we felt that the licensee's job 13 hour estimates were too high. However, we felt that they 14 were not unreasonable, and we also felt that the licensee is 15 in the best position to estimato how much time a task would 16 take.
17 Furthermore, we recognize that the 1:litial 18 estimates for the completion of the clean-up after the 19 action was given in months, and we are now rapidly 20 approaching ten years.
21 The methodology used by the NRC and the licensee 22 was found to be essentially the same. So, what can we 23 conclude?
24 Well, after reviewing the licensee's submittal, we 25 found that there is some disagreement in some of the Heritage (20 Regorting Corporation
) 628 1888 I
)
i l
26 )
1 estimates of the amount of time it would take to complete a l l
2 task. However, we find the licensee's submittal reasonable.
3 We also computed our own re-estimate of the 4 anticipated occupational exposure for immediate and delayed 5 clean-up using the licensee's new data and our own l
6 methodology, tempering some of the job hour estimates.
7 We have summari=ed our findings in the hand-out, 8 and we have a slide here that I'll get Lee to put up that 9 compares occupational dose savings.
10 What we have here is on the left-hand side the 11 various documents in which occupational dose is reported, 12 and across the top, we have either immediate clean-up or 13 what the licensee calls post phase 3 clean-up and delayed 14 clean-up or what the licensee calls post-PDMS.
15 The third is the difference between the first and 16 the second column. As you can under Draft Supplement 3, we 17 talked about an occupational dose savings, the most right-18 hand column, of only 250 to 1600 person rem. Appendix 1-A 19 of the SAR, thirty years in PDMS is the licensee's estimate, 20 based on a thirty year period of PDMS.
21 The third line, Appendix 1-A of the SAR, twenty i
22 years in PDMS is most comparable to the NRC's estimate of i
23 twenty years between the end of clean-up and the end of PDMS i i
24 and post or delayed clean-up.
{
\
25 The third line is our revised occupational dose l HeritageRegorgrg ggporation l
, o i
27 1 estimates based on the re-analysis using licensee data.
2 As you can see, our estimates of person rem for 3 immediate. clean-up and delayed clean-up are lower.than the 4 licensee's. However, the actual occupational dose savings, i
5 which is really the most important column, the right-hand 6 column, is approximately the same.
7 So, although we estinated lower doses, the savings 8 are about the same.
9 MR. ROBINSON: Mike, did you say twenty years?
10 MR. MASNIK: Yes. We assumed twenty years.
11 Obviously, if you go to thirty years, you get a greater 12 savings because of decay.
13 I'd like Lee to come back and talk a few minutes L
14 about taking this one step further, and that is what this 15 means f'om r the standpoint of cancer fatalities.
16 MR. SMITHGALL: Mike, maybe we could leave that 17 chart up there? We might be able to refer to it. Maybe not 18 necessarily blacken the room, but other people might want to 19 refer to that for the discussion.
, 20 MR. GENUSKY: Mike, to put this in perspective, 21 what total occupational dose in person rem to present time 22 mean?
23 MR. MASNIK: I'm not exactly sure. I think someone J
24 from the licensee probably could answer that.
25 VOICE: 6000.
i Heritage Rep rting Co.poration (202) 628-4888
-. - -. -- --y gy - _ _ . . _ . - _ _,. 7 _ . _- _ , . - . . ,.- .y_ _ _ _
28 1 MR. MASNIK: 6000.
2 VOICE: 6000.
3 MR. WALD: That is up to now?
4 MR. THONUS: That is correct. It's up to the 5 present.
6 If you look at the bottom line, the three numbers, 7 three ranges of numbers that we have, the immediate clean-up 8 of 4300 to 10,900 man rom, the number of expected fatalities 9 would range from .6 to 1.5. The delayed clean-up, which, on 10 the slide, has a range of 1750 to 4600 person rem, would 11 result in, again, a statistical estimate of 0.2 to 0.6 12 fatalities.
13 And the dose savings in person rem of 2600 to 6300 14 would be a savings of .3 to .8 fatalities. Again, these are 15 st acast'ic . In reality, we don't have tenths of a person, but 16 it gives you a perspective of what you're looking at.
17 MR. MASNIK: I think all of this will be set forth in greatar detail in the final version of Supplement 3, but
~
18 19 that essentially concludes our presentation, and if you have l 20 any questions, we'd be happy to try to answer them.
,' 21 CRAIRMAN MORRIS: Anybody at this point have any 22 questions?
23 MR. WALD: If I understand right, then the NRC 24 feels there's a greater savings percentage-wise than the 25 licensee has indicated because you start with a smaller Heritage I g ration
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29 1 total and your savings is equal to that of the licensee.
2 So, you are saying percentage-wise that there's a 3 greater savings than the licensee has postulated.
4 MR. MASHIK: That's correct.
5 CHAIRMAN MORRIS: Any other questions?
6 MR. SMITHGALL: I'm not an expert in this, but I 7 need to just have something clear in my mind on the job hour 8 estimates which you said is an area of those three factors-9 that in this report that showed the greatest differences.
10 And I want to know how you -- well, what the 11 methodology was to temper those job estimates, job hour 12 estimates that you used versus what the licensee used in 13 line with your comment and your statement that you were 14 initially looking at a forty-eight month or four year clean-15 up and now we're closing in on ten years.
16 How do you reconcile those things? I mean, we 17 have been told that these things are going to take so long l l
18 and they always take that long. l l
l 19 MR. MASNIK That's correct. I mean, we basically '
.0 hava to defer to a great extent the licensee on these !
i 21 estimates because they are truly the experts on it.
d 22 There are -- thore were some numbers that were 23 reported that our contractor felt that were certainly 24 extreme estimates, and essentially what she did was, based j 25 on her background and the experts that she employed at PNL, Beritageg g gf p ration j -
i 30 1 reduced some of those numbers.
2 She looked at the licensee's justification for 3 those man hours and felt that, in some cases, the 4 justification was not there.
5 All I can say is that it was essentially our best 6 estimate of hours. It was broken down by task and each task 7 was looked at in detail.
8 MR. SMITHGALL: When you're looking at this, using 9 that analysis or that theory, when you look at the
~
10 experience that you gain in this clean-up, it seems that NRC 11 should have a track record that the licensee has shown in 12 their estimates, and can you rely on them to be even close, 13 such that even tempering them a factor higher -- I guess 14 what I'm getting at is whether or not you feel you've 15 factored them appropriately, feel confident in that, because 16 that could skew your numbers, I would suspect.
17 MR. MASNIK I think you're correct in saying that !
I l
18 it could affect the numbers dramatically, but I think it's l I
19 our best estimate and I think we feel comfortable with them.
20 MR. MILLER: Mike, I think it was the EIS, there i
21 was an estimate of dose in terms of natural backg.Tound 1
22 radiation over the next twenty or thirty years. If I l 23 recall, it was to the population in the surrounding area.
24 Has there been done an estimation of the, natural 25 radiation burden of this same clean-up population that we HeritageRegor gg poration
31 1 can see around the next twenty years waiting to clean it up?
2 MR. MASNIK: In other words, the workers 3 themselves?
4 MR. MIL 2.ER : The workers. The workers, not the 5 public.
6 MR. MASNIK: Not to my knowledge.
7 MR. GENUSKY: I'm not positive of this, but in 8 looking at that just very quickly, it appeared that the 9 utility also used some dose reduction factors based upon new 10 processes and robotics as part of their total dose reduction 11 package. Is that correct, and if it is, did you also take 12 that into consideration in your review, or is it just tht 13 same work performod at a later date? I l
14 MR. MASNIK: I'm sorry, Tom, but I can't answer !
{
15 thet. .I don't know for certain.
16 MR. GENUSKY: I'm not certain that that's correct 17 in the review. I think it was in there, but I'm not sure.
18 MR. MASNIK: My understanding was that there was l
19 savings from that.
20 MR. GENUSKY: Not tremendous savings, but it was 21 taken into consideration.
22 CHAIRMAN MORRIS: Mike, I'm paging through the 23 PEIS and I can't find the chart that showed your numbers for
\'
I 24 cancer fatalities within the PEIS.
25 MR. MASHIK Look on page VII. Right at the very j HeritageRegor gggggporation
~ - __ __ _ ._
o\ *
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32 1 beginning. It's maybe four-five pages in. Three pages in 2 from the front.
3 CEAIRMAN MORRIS: Okay. I have it.
4 Cou.'.d you tell us how these revised numbers vary 5 from what was in this report, ard could you give us that in 6 the form of cancer fatalities at all, if possible?
7 MR. THONUS: I guess the audience can't see what 8 you have in your book that I have in front of me, but what 9 we had published in Draft Supplement 3 was a range of 10 estimates of .04 to .4 fatalities'b'ased on an immediate 11 clean-up over a four-year eeriod which would result in 300 12 to 3100 person rem.
13 Our revised estimates are up there on the slide,
'1 14 and that came out to be .6 to 1.5 for the immediate cleon-up 15 in fatalitier, and for the delayed clean-up, it came out to 16 be 0.2 to 0.6.
17 CHAIRMAN MORRIS: So, you significantly changed 18 your numbers since the PEIS. Is that what you're saying?
19 MR. THONUS: Yes.
20 CRAIRMAN MORRIS: Taking the lower 6nd and 21 increased it by a factor of ten, I think, or nine or 22 something like that and you' re going to just about double-l 23 it.
24 MR. THONUS: Yes. The lower end is actually a l 4
25 little more than a factor of ten. 4300 versus 300, I
Heritage Ro or gg gporation
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- 33 1 CHAIRMAN MORRIS: Okay.
2 MR. THONUS: And the --
3 CHAIRMAN MORRIS: I'm looking at your difference 4 and I shouldn't be doing that. I should be looking at the
\
5 4300. So, you've gone almost fourteenfold in the lower end 6 and over three fold in the upper end.
7 MR. THONUS: That's correct.
8 CHAIRMAN MORRIS: Okay. Does anybody else have any 9 questions at this point on what's been presented?
10 (No response.)
11 CHAIRMAN MORRIS: If not, I'd like to move along 12 to the next item on the agenda, which is a presentation by 13 GFU on the Funding Plan.
14 MR. STANDERFER: Frank Standerfer, Director of the 15 a TMI Cle'n-Up.
16 Chairman Morris, my intention at this point was to 17 introduce Ed Kintner's letter into the record, and read the 18 same passage whien you read at the beginning of the' meeting.
19 We believe that satisfies the commitment that the company 20 has made to provide funding plans in accordance with the NRC 21 regulations 2or future work in the plant, and it would 22 include all work from the PDMS condition through the end of
- 23 decommissioning. I j 24 And I simply wanted to make the point you made j 25 earlier, i
HeritageRegorggg ggporation l
\
. . l 34 l 1 CRAIRMAN MORRIS: Okay. Does anybody on the panel 2 have any questions on the letter that we now have received 3 and the one that I read an excerpt from earlier in the 4 meeting? !
\
5 MR. NALD: I may have missed it, but does the NRC I i
6 representative confirm the applicability of the rule at TMI y l
7 27 l 8 MR. MASNIK: Yes, it does. It is applicable, and l
9 I think we' re construing the letter as a commitment to 10 include in the NRC-require'd funding plar. financial planning '
11 for all activities involving the decommissioning of the ,
I 12 plant, starting with PDMS. !
l 13 The rule, as it's written, doesn't rcquire that it 14 be broken down by activity, but that it just make a 1
15 commitment to raise the money that's required by the rule.
16 We're construing this letter as a commitment to go 17 further than that and include all activities necessary'for !
18 the clean-up, for decommissioning. !
19 Since we must submit plans for TMI 1 and Oyster l I
20 Creek at the same time, I believe, as we have said in i 21 earlier statements, we would be looking at the 22 decommissioning of the two reactor sites as a one activity, 23 including all of the work requirements.
24 CRAIRMAN MORRIS: On the severe report.
i 25 MR. SMITHGALL: Let me r.sk a hypothetical in l 1
l LeritageRggorggggggporation l
' 7
, e .
\ l 35 1 roforenca to your intorpretation of tho now d:commiccioning j t
2 rules.
3 What if. thirty, sixty,. ninety years from now, the 4 decommissioning costs put the licensee in a situation where 5 they cannot ensure that public health and safety at one of 6 their operable plants by incurring the costs of 7 decommissioning at that time of plants that they want to ,
8 decommission?
9 How would the NRC interpret that then as it would 10 pertain to these new decommissioning rulen?
11 MR. MASNIK: I think the Commission has recognized 12 that this possibility may occur, and I believe in the Atomic 13 Energy Act, there is the option of the Federal Government 14 actually stepping in and taking over decommiusioning if 15 public health and safety is jeopardized by inactivity on the 16 part of the licensee.
17 That's the only thing we can commit to.
18 MR. SMITHGALL: Because I think the concern of a 19 lot of people in this area as to deferred clean-up is 1 20 whether the licensee will be around at that time, whether 21 the plumbing will be in place, and whether the NRC will 22 allow them.
23 MR. MASNIK Well, I think that's why this funding 24 plan has to be looked at carefully, to make certain that it 25 includes the activaties necessary for a complete HeritageRggorgggggggporation i
36 1 decommissioning and that there is a plan in place to raise 2 some money.
3 MR. SMITHGALL: I mean, we all make these 4 commitments daily. I guess I'll have enough money to pay off 5 my mortgage assuming I still have a job. So, it's clear tnat 6 GPU wants to make the effort. It's whether or not they can 7 make the effort that I'm concerned with thirty years hence.
8 MR. MASNIK: But the banks.still lend money for 9 mortgages, you know. It's a question of trust, I guess.
10 MR. STANDERFER: I might say, Tom, that it's more 11 than a whim. It's actually the accumulation of the funds, 12 also, as part of the whole process.
13 MR. SMITHGALL: That's right.
14 CHAIRMAN MORRIS: But we don't know, I guess, at 15 this point what would be required in order to accumulate the 16 funds. In other words, it could turn out that you submit a 17 thirty year plan to provide $10 million a year, whatever, I 18 some fictitious number like that. -
19 It might be more -- make us feel more comfortable 20 if the plan would say that in the first year, you would put l
[ 21 all of the money into a fund, and I'm sure that won't l
22 happen.
23 So, you know, it's still a mortgage situation that I
l 24 I'm sure you will outline in your plan.
25 MR. STANDERFER: That's right.
Heritage gg p ration l
e =
l . 4
'~ '
37 l' CHAIRMAN MORRIS: Which will vary your ability to 2 pay for that, will vary with time.
3 MR. STANDERFER: And depends on revenues from our 4 existing activities.
5 CHAIRMAN MORRIS: Well, I appreciate the 6 clarification tonight. I think that wra very helpful to '
7 us.
I 8 Anybody on the panel have any questions at this
. 9 point?
10 (No response.)
11 CRAIRMAN MO?RIS: If not, I'd like to move on to [
12 the three individuals from the public at this time to offer L 13 their comments. ,
l 14 I believe the first person is Debra Davenport for i 15 five minutes, if she is present.
16 Good evening, j 17 MS. DAVENPORT: I have some questions, not so much 18 comments.
19 This is sort of going back to an original oubject, 20 but it does relate to PDMS, and that would be the i'
21 evaporator. !
22 Lince that is going to be used by GPU for l ;
23 designing, will that be taken out of clean-up costs? Will
- 24 that -- could that be public in some way --
25 CHAIRMAN MORRIS: Let me ask. Are your comments '
seritageRggorgggggggporation I
)
l
t e
- y 38 1 basically related to the evaporator issue?
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2 MS. DAVENPORT: No. Really, only to PDMS and the 3 evaporator costs.
4 >
CHAIRMAN MORRISt Okay. ,
I 5 MS. DAVENPORT: I can wait until you get to that i I
6 section.
7 CHAIRMAN MORRIS: Fine. If it's strictly related
, 8 to the cost part of the.PDMS and involved with that, fine.
9 If that's what it is, fine. But if it's strictly on the
) 10 +vaporator issue itself, I feel this evening is'really not ,
11 to address that specifically. It is to address the PDMS l
4 12 issue.
13 MS. DAVENPORT: I thank PDMS because, really, I'm 14 wondering what the :ost of that will be. Will that string l
- 15 out the' cost as opposed to fueling storage, and why wasn't I 16 the design royalty issue included in the original PDMS, 17 CHAIRMAN MORRIS: Okay. Now, Frank, is it p'ossible i
18 for somebody to come forward? It may make the questioning l 1
19 and answering a little bit easier if you could. By all 4
)
20 means, if you'd prefer to sit down, because I think maybe i I
21 there are several questions that are going to be asked at f l
22 this point. !
J ;
23 The only thing I would ask is that you try to l
i l
24 adhere to the time limit. I do feel that there is need for l
- 25 discussion by the panel on the main issue at large and to seritage!jgforgggggggporation !
T ;
i t
39 1 allow other public comments.
2 MR. STANDERFER: I'm not sure I understand the
'3 question with regard to design royalties. <
4 We have contracted for the design and fabrication 5 of evaporator, and we hea contratted tith that firm to 6 operate. the evaporatoz, and there are prcvisions in the 7 contract if we dc nr.' cond the e'raporator, there are i
!) 8 cancellation charges and so a rth, 4 9
9 So, Debra, I'm not quits sure I understand'the
! i i
10 question. i 11 MS. DAVENPORT: And I think it was May's meeting 12 or June's, I had asked what they would do if the evaporator,
]
i 13 once it was done being used for PDMS, and you had said, I 14 think, for design royalties, but when the thing was printed
! 15 up, it looked like it had been corrected.
16 In other words, the unit would then be either the 17 design, for the design of it, would be used and that would ;
la bring profit back to GPU for by the rental of the machine, i 1
) 19 I'm assuming.
- 20 MR. STANDERFER
- At the end of the job, the I 4 ;
- 21 contractor that we had bought the. equipment from will own l 5
q i 22 the equipment. We will not own the equipment. Through the !
) 23 operations phase, we're essentially selling the equipment 1
24 back to him. We do not want to own an evaporator. He would I l
25 like to own an evaporator. ;
1 1
i Heritageg gg f y ration l
1
- 56 1 do. Wo bolicvo tho penol chould rccomm:nd to tho NRC that 2 the clean-up of TMI 2 proceed immediately. GPU should be 3 !
liable for the costs and develop appropriate technologies.
4 In addition, GPU should develop a funding plan r
5 based on equitability and realism to be reviewed by the PUC, 6 the consumer advocate, the Commonwealth of Pennsylvania, and 7 the citizens. I 8 As an addendum, I wrote this and I'm quite sincere
? l
- 9 about this, I really don't know what else I can say that l 10 would truly affect you people. The last time I was here, I 11 spent a lot of time researching and talking to competent 12 well-versed people in the field of economics and 13 decommissioning, which included people at the PUC and the 14 Consumer Advocate's office, that I will not name.
]
1 15 One member questioned my credentials, which is 16 your privilege, and I respect that, but let me remind you I
17 that we're all citizens with rights and responsibilities.
] t I
18 The federal, state and local governments provide public l
] 19 document rooms, libraries, research material and, if 1 20 necessary, one can also utilize the Freedom of Information l 5
21 Act to obtain information. i i '
j 22 The data our organization presents at these 1
23 meetings is documented, and I go out of my way to document 1 24 that material. In addition, I think it's worth noting, we
- 25 have no financial stake in the matters before you.
seritage g g g f p ration 1
57 1 Let me close by saying that I think the case 2 against PDMS, at least in our opinion, is clear and t 3 overwhelming. However, as I look around, I'm reminded of 4 what George Orwell once said. People can perceive the future 5 only when it coincides with their own wishes and the most 6 grossly obvious facts can be ignored when they are j 7 unwelcome.
l 8 So, what I hope you do is scrutinize the material i
9 l
, as best you can and I know you usually do, and make the i 10 'right decision, which is, in our case, to proceed with 1
l 11 immediate clean-up, and I really appreciate your indulgenew, i
12 Chairman Morris, 13 CHAIRMAN MOPRIS: Thank you.
14 I would hope that, Mike, if you would, there are 15 several~ questions at least initially in the first page or so 16 of Eric's presentation, that I would hope you would work 17 with GPU on or at least bring to their attention and ask 18 thom if they would provide answers.
l j 19 MR. MASNIK Okay. I'll coordinate it. !
1 1 l 20 MR. EPSTEIN: And there were two questions for 21 GPU. I don't know if Mike is going to be here next time. I 22 don't think so. The one concerning if they're going to 23 disclose how much advertising campaign costs and if they !
- 24 vould proceed with an immediate clean-up, if ig is mandated, l 25 and I'm not sure, I think the other questione are just for' ;
l' j
1 NeritageRggorgggggggporation
j 58 1 the NRC.
2 MR. MASNIK: You wouldn't have an extra copy, I 3 would you?
4 MR. EPSTEIN: I would have an extra copy, but I i
5 want to remind you that it's xeroxed on both sides because l 6 the last time you failed to look at the other side.
I 7 MR. MASNIK: I mentioned it to the court reporter (
8 and I'll be aware of the problem. t i r I
9 MR. EPSTE2N Okay.
1 i J
10 CRAIRMAN MORRIS: Are you asking that Frank
) 11 attempt to respond to your questions this evening? Is that i 12 what you're suggesting? I 1
i 13 MR. EPSTEIN: I doubt Frank can respond to how ,
I 14 much they are putting on the media campaign. Doug Bedell ,
i 15 probably could and I'd love to have Doug come up here and L r
i 16 address it or not address it. Just have it clarified. ;
L 1 17 CHAIRMAN MORRIS: Is Doug present and is he able
)
18 to come forward and respond?
19 Eric, do you want a copy of this letter from GPU :
I 20 on funding?
{
21 MR. EPSTEIN: Sure. I
- 22 MR. BEDELL
- Doug Bed 611, GPU. f i
) 23 We will provide that for the record, that answer. !
t i '
- 24 CHAIPNAN HORRIS
- Thank you. l l
j 25 MR. EPSTEIN: That was so simple. If everything !
1 l
] Meritagegggorgggggggporation i
4 r 1 !
) .
l .
59 1 else cottid be that simple, va probably wouldn't have to i 2 moet.
3 CHAIRMAN MORRIS: It would be nice, wouldn't it?
4 MR. EPSTEIN: How naive of me.
5 CHAIRFD6N MORRIS: Thank you, Eric.
< 6 MR. ROTH: Don't leave, Eric, please. Can I?
7 CHAIRMAN MORRIS: Sure.
8 MR. ROTH: I was not at the last meeting, and 9 nuvor received this, some other panel members did, you know, 10 a copy of the transcript, and I have to admit that my copy [
- 11 of the transcript did come from Eric.
s 12 So, I would just like to say that I found your I 13 comments a t time to be excellant and it did show a lot of i 14 research, and I certainly appreciated reading and having j 15 seen th'at. !
) 16 But I do have a question for you tonight.
17 MR. EPSTEIN: Sure. !
! l j 18 MR. ROTH: And that is, what would TMIA or SBA's l
19 definition be of the end of clean-up? In other words, what i i 20 is satisfactory to the group? t
)
21 MR. EPSTEIN: Well, I think that's a good question f
22 because I'm not really sure it's clear in our mind. I think i l
j 23 what we're aware of is that there's more that can be done l
i 24 before the unit is placed into decommissioning, and that's l l 1 25 what we're hoping is done. 1 l
) '
d Heritagegggorgggggggporation l
t
60 1 It cppocro thOt icvalo, cnd I think tha utility 2 and NRC would acknowledge that it's probably destructive 3 methods of decontamination could.take effect prior to 4 decommissioning, and that's what we would hope would happen.
5 I'm not really sure what destructive as opposed to 6 non-destructive methods of decontamination are, but it's 7 clear to us that the basin is still highly radioactive and, 8 in our opinion, poses a threat to the community, and we're 9 not -- I don't know how else to put this gently.
10 We don't take the utility's word necessarily about 11 radiation levels and locations. We feel a continued, you 12 know, decontamination of the plant would be in the best 13 interests of the community.
14 I know I'm being vague because nobody really put a 15 definition on the clean-up, and I think even tonight it's 16 even more fu :y, but it's apparent to us that more can be 17 done before the plant is decommissioned, and we'd like to 18 see that.
19 We would like to see the maximum effort applied 20 before the plant is mothballed because it's a fear of ours 21 that this plant is going to lay idle for quite some time.
22 There's five plants in Pennsylvania that are licensed and 1 1
4 23 they're all going to como up at the same time.
24 We think at this point, while THI is a unique i i
25 plant, we can get funding to continue the decontamination.
HeritageRgporgggggggporation l l
51 1 So, I don't know if that answers your question 2 because we're still grasping at what exactly the utility 3 intends to do and what the end of clean-up is.
4 MR. ROTH: Good enough. Thank you, i 5 MR. EPSTEIN: Okay. ,
f 6 I would also add that decommissioning in the NRC's 7 recent rules, I think decommissioning.is achieved when the !
i 8 site is restored back to its unrestricted use.
9 MR. SMITHGALL: Unrestricted access.
10 MR. EPSTEIN: That means you could just go around 11 and perhaps build a housing complex on Unit 2.
I 12 Theoretically. '
13 CRAIRMAN MORRIS: Thank you, Eric. I L
14 And the last person is Frances Skolnick.
I 15 MS. SKOLNICK: Good evening, everybody.
16 Frances Skolnick, Susquehanna Alliance. j I
17 First of all, I'd like to' comment on the old 18 question as well, what's SBA's position on the definition of 19 the end of clean-up.
20 I think it is a really difficult question to 21 answer, mostly because I asked a question of Mike about this 22 as well. We have not researched what tasks followed the end 23 of clean-up. So, I honestly can't evaluate what the end of 24 clean-up is.
25 I think that's one of the problems that we always Meritageg gg f p ration i
E 62 ,
1 have to grcppio with of environmental orgnnizations. We're 2 never given the full amount of information, and the 3 information that we are asked to look at, we do find holes
. 4 in it, and it never seems that we can get answers, prcper 5 answers nnd, therefore, we're stuck in a position of still 6 grappling with a lack of information.
7 And, Mike, if I could just ask, in your
]
i 8 presentation, you were telling us that you looked up 9 immediate clean-up versus delayed clean-up, and you list the ,
t 10 list of tasks, the exposure estimates and the hours per job.
11 I'm not quite sure where you got your list of l i
j 12 tasks from to be done after defueling. could you just i 13 explain that? ;
l 14 MR. MASNIK Okay. I gucas when you asked that 15 question, ar6 you talkirig about our current estimate or our
- 16 estimate that we have presented previously la Draft 17 Supplement 37 i
18 MS. SKOLNICK: This issue, the current estimats.
1 l 19 MR. MASHIKI The current was developed principally 1
20 from what the licensee submitted in these two documents i
21 here. They are post defueling monitor storage safety
}
i 22 analysis report.
I
] 23 In other words, we started with that and evaluated I 24 the tasks.
1 25 MS. SK0LHICK: That would be done following --
]
1 Meritage gggorgggg gggporation i
.I 1
63 1 MR. MASNIK That would be done following --
2 MS. SKOLNICK: -- defueling?
3 MR. MASNiK: -- defueling in what we call 4 immediate clean-up, and they had post phase 3 clean-up, and 5 then, at the end of PDMS, which we call the delayed clean-1 i 6 up. '
i 7 MS. SKOLNICK: So, whenever you list those tasks, 8 presented by GPU, did you list other alternatives to those 9 tasks? Did you evaluate ..hom? Did you evaluate the kinds 10 of machinery that might be needed?
11 MR. MASNIK: That's correct. What we did was we 12 looked back at what we had avalusted earlier and compared I
13 that to what was presented at the present time, and 1 don't 14 know if you recall, we talked about some techniques being 15 more destructive than others. !
! 16 When we did the initial Draft Supplement 3 or the i
17 Draft Supplement 3, we relied heavily on an earlier
! 18 supplement, Supplement 1, which looked at various tasks I
19 because we were evaluating specifically occupational q
20 exposure, and some of those tasks involved methods that the i i
21 licensee no longer plans to employ, and some of them, we i j 22 essentially developed ourselves based on the type of i
23 decontamination that was necessary. :
l j 24 So, the current document provided a more detailed f 25 description of how they would plan to dn this, i I
i Meritagegggorgggggggporation l l
l
)
. . . - . ~ . _ _ _ . .
). *
- 64 '
- 1 MS. SKOLNICK
- And did you consider -- I know you 3 J l
- 2 said originally that it would be a four-year period for i
3 immediate clean-up. Okay. Originally, you said four years.
l, 4 Are you still saying it would be an additional four years? :
l; 5 MR. HASNIK Yeah. The period of time didn't f l 6 change. .
7 MS. SKOLNICK: It would be the saae. Did you ;
i
, 8 consider that perhaps it would be possible to continue with l 2
9 clean-up for either more or less than four years? l l 10 MR. MASNIK Yeah. If you recall in Supplement 3, r l -
11 we looked at a number of alternatives, and one of those, for l
l 12 example, one of them was centinued clean-up at a reduced {
j 13 level of effort, which essentially would mean that instead I i
- 14 of immediate clean-up in four years, it would be immediate !
15 clean-up in eight years with a fifty percent reduction in j 16 effort.
j j 17 But we found that it really was essentially !
~
l 18 somewhat insensitive because the two alternatives we looked 19 at bounded those other alternatives, and, you know, you run 20 into some problems associated with when you draw something j 1 '
I
! 21 out like that, you have undefined problems associated with 1
l
- 22 training and continuity of programs and such.
3 J
23 So, you know, we felt that the two alternatives
- 24 we'd pick, immediate clean-up, a period of approximately i
i
{ 25 four years, and the delay clean-up, bounded these other Eeritage g ration
}
o .
65 1 alternatives.
2 MS. SKOLNICK: I noticed that you addressed 3 continuity of clean-up and problems with trend, but I don't l 4 think you addressed that in the prospect of leaving clean-up i 5 for twenty or thirty years, did you?
6 MR. MASNIK Yes, we did. We did. In fact, the
- 7 period of time for delay clean-up was extended some time, i 8 primarily because we knew that there would be significant 9 start-up activities associated with additional training and I
10 such.
11 MS. SKOLNICK: Thank you.
12 And I appreciate your answering my questions which j
! 13 brings me to the next point. I really think that there is a 14 show of discrimination at these public meetings, and the NRC 1
15 published its Draft Supplement, presents data on worker j
l 16 expo s'tre .
l j GPU can come backa 'nd say,' we disagree with these 1 17 i
18 figures. Subsequently, the NRC uses the resources and energy 19 to re-evaluate their findings, and we know the story that i 4
20 you came up with the same figures as the licensee, s I
.i 21 We come forward, as Eric pointed out we do an 22 endless amount of research, we don't get any money for doing a
23 this, there's nothing in this for us, except our concerns 24 for the community. We come up and raise genuine concerns 1
25 about estimates of the radiological content that will be l HeritageRegor ggggporation i
l _ - . _ _ _ . _ - . - - - . _ - - - - - - - - - - . - - - - - - - - - - - - - - - - - - -
O O 66 1 left in the plant.
2 Our concerns are noted in the record and we are 3 informed that it won't be discussed any further until the !
4 NRC responds in a final d,-aft. It limits furth'er 5 discussion.
t 6 I find really that's insulting because I believe 7 we are being discriminated against.
8 We brought major concerns here about the 1
9 evaporation of water, and for most of the panel, it did fall i
10 upon deaf ears, and like I said, we do do constant research, !
11 Commissioner Rice, and you know, all you need really is the ,
i 12 power of critical thinking. You don't need an endless list 2
- 13 of university degrees and a large packet from a licensee, l -
14 Unfortunately, this time, the judges at least did I
i 15 listen to some of our concerns. Some of our concerns have
,' 16 been noted, others have been drawn up, but I just want to i
i 1
17 read you one quote, which I tried to impress and permit this 18 panel to conclude some time ago as well, t
19 The judges concluded, "We are not convinced at 20 this stage of the proceeding that forced evaporation meets -
! E 71 the Commission's policy of providing expeditious [
l 22 decontamination consistent with ensuring protection of 23 public health cnd safety and the environment. Therefore, 24 there is a genuine issue of facts concerning whether the no- ;
i
! 25 action alternative may be obviously superior to forced
- t J
BeritageRegorggg gporation
67
! 1 evaporation."
i 2 I did also raise about the character of the water ,
3 and the judges have admitted that I have raised enough ,
l l 4 material facts to show that the water may have been 5 characterized incorrectly and, therefore, the dose from the !
6 people may have been incorrectly evaluated. f 4
7 I just think it's so important that -- the
- 8 important point is net that we cannot question. I think that ,
9 we should come back to question more. I 10 CHAIRMAN MORRIS: Let me just say for the record i 11 since we're all trying to make sure that the record is i
l 12 correct, and I have to say that you were quite critical of t
I
)
13 this panel on evaporation, while I was not one of'the people 14 that voted against evaporation, this panel did vote, the
{
15 majorit'y of this panel did vote against evaporation.
l 16 So, I think your criticism there when you say only 17 a few is misplaced on that issue. i
- l 18 MS. SKOLNICK: I don't know, and I'm glad that the 19 panel did vote against evaporation, but I think --
l 20 CHAIRMAN MORRIS: But I think your statements l J 21 would indicate that people reading this particular 1 i
l j 22 transcript, that this panel did not vote that way, and I
{ 23 just don't want to get into a debate with you. I just want J
) 24 to clarify the issues.
I i 25 MS. SKOLNICK: Okay. Your point is well taken.
Meritage g ration 1
68 ,
1 CHAIRMAN MORRIS: The panel did vote that 2 particular way.
3 MS. SKOLNICK: Yes, but I do think, too, there is !
1 4 a feeling that our information is not worthy of 5 consideration in many cases.
6 CHAIRMAN MORRIS: Well, I appreciate your earlier 7 comments and specifically on that issue, we did ask, so that 8 we as a panel have to, in a timely fashion, given the j 9 constraints, you were here at the last meeting, you heard us 10 discuss asking for extensions of time, we do not have the 11 luxury that a judge has. They can schedule whatever they I
12 want on their time frame, but we have a separate time frame 13 that we must meet. c i
14 We did not want to take action until we heard two 15 specific questions answered. One, the NRC's position on the I
16 submittal by GPU. So, we asked them to 'lo that evaluation 3
17 for the panel. And, secondly, on the funding question -
f, i
j 18 regarding the cost of PDMS being included in the {
) 19 decommissioning. (
1 I
i 20 We did not want to meet agaia until we got that !
21 information. So, we were the ones that asked for it to allow i
22 us to at least consider as much as we could. We've heard 23 what you've said. We thought we needed clarification.
- 24 That's all. We're not attempting to discriminate, but we ,
- 25 have a time frame that we have to try and meet as well.
BeritageRggor gg ggporation i
l
. . _ - _ - - - - . - , - - - - - - - - - - - - - - - - - - - - - ' - - - - - - ~ - - - - - - - - - - - - -
69 1 I think we've tried to do that. We extended that 2 comment period for the public, for you, to comment on this 3 this evening. We fought for that at the last meeting.
4 So, we try hard to involve the public and give you t
5 a chance to at least have some influence on what 6 determination is made. ;
7 MS. SKOLNICK: Yes. I appreciate that, but I think 1 8 particularly to my statement, too, I did direct my comments 1 (
9 to the NRC, a show of discrimination in treating GPU as a
! 10 need to re-evaluate -- ;
11 CHAIRMAN MORRIS: Yes. But all I'm saying on 12 that, Frances, is that we as a panel specifically requested 13 that information at the last meeting. I think we --
I 14 MS. SKOLNICK: Yes, but Tom also asked for the SBA i
- 15 matters to be brought up again and that was refused.
l 16 CHAIRMAN MORRIS: Okay. If that's the case, I !
j 17 apologize.
18 MS. SKOLNICK: Thank you.
19 CHAIRMAN HORRIS: Thank you, a
20 At this time, we would take a break and then I 21 would like for the panel to spend a fair amount of time
] 22 discussing what can we do with thip particular report.
23 (Recess.)
24 CRAIRMAN MORRIS: I know you may not be ready at
- 25 this point for the questions, but if you could take us back Heritage g ration
. . s.
70 1 and remind us of the schedule involving the PEIS.
2 MR. MASNIK: Essentially, there isn't much of u 3 schedule at this point. What I have planned is that after 4 the panel meets with the Commission, to essentially finalize 5 the documents, and try to get it published.
6 I suspect that at this point, we're talking 7 towards the end of the year. Certainly, not before the 8 middle or end of November, and it's probably more like the t 9 middle or end of December.
I i 10 CHAIRMAN MORRIS: Okay. As I understood the last
' 11 meeting, that we put out the meeting with the NRC with the 12 hope of probably meeting with them some time in October,
- 13 which vo21d allow us to meet here today and hopefully figure I
l
] 14 out what it was we wanted to do regarding the PDIS, then [
15 meet with the Commissioners in October, relay to them to our t-16 feelings on the PDIS and anything else we want to discuss on
! 17 the clean-up, and then, thereafter, you were -- the clock l l
)
]
18 kind of stopped ticking and you were going to be then l 19 1 finalizing the PDIS. i 20 MR. MASNIK: That's correct.
1 21 We are in the process of addressing a lot of the f 4
22 comments that we've already received, but the record 23 essentially will stay open until the panel meets with the i
24 Commissioners. .
25 CRAIRMAN HORRIS: Okay. I raise that question Beritage (20 Re$frtinE 628 4888 Corporation J
71 l
1 simply to get into this part of the agenda, which really, I 2 believe, is the time for the panel to really determine just 3 what it is we want to do at this point regarding comment on 4 the PDIS. ,
5 I guess there are several options. One is to l
- 6 offer no comment. There would have to be some type of ,
7 consensus for that. The others would be to offer comments in 1
8 support of our interest or if there are problems with it, 9 maybe state what the problems are and either offer them as
- 10 amendments or offer them in opposition to PDIS. There may be 11 other options that others will suggest this evening.
12 It is my hope, quite frankly, that the panel take 13 a position this evening and other people might have a l
, 14 different viewpoint than that, and I would hope you would i
15 express them. I would hope this evening that after we have i l
l 16 a chance to discuss our options, that we do, in fact, take !
- 17 some formal position.
I 18 I think this represents the third meeting that t
l 1 19 we've had on this particular document. We have delayed the j
] 20 meeting with the NRC to allow us to have this particular l 1
3 21 meeting.'So, I certainly hope that we are in a position to I
22 offer some comments, take a position here. l i i 23 With that, I open it up and ask the panel members 24 if they want to make any observations or ask any additional
)
i 25 questions that they felt they need to ask, seritageRggprgggggggporation
)
i
12 1 ISS. RICE: Mr. Chairman, Mr. Roche commented that '
2 when Unit 2 goes into the PDMS, that the Reuter Stokes !
)
3 system would be removed, is that correct?
4 CHAIRMAN MORRIS: He indicated that it was the l 5 plan of GPU to remove that system once, actually once it 1
6 went into PDMS or once the fuel was removed. That's what he ;
t 7 said, I think, pretty clearly this evening.
8 That at least is the plan of GPU.
9 MR. RICE: Regardless of the Unit 1 operati3n?
10 CRAIRMAN MORRIS: Well, I think he didn't include 11 Unit 1 in that comment. He just spoke specifically -- he i 12 indicated that that was in place because of TMI 2 and 13 actions at THI 2 would decide what happens to the system, t
14 That's what I thought was their plan and I think l 15 he's nodding his head at this point. I did indicate that I ,
j 16 that was an issue I thought we needed tra discuss at a future j
i l 17 meeting. But that was their position as of this evening. F f
18 MR. RICE: Thank you. I 19 CHAIRMAN HORRIS: Come on, folks. I mean, I'd be l 20 happy to offer scme comments of my own, but I don't want to 21 jump into that so quickly. I think that there's other people j 22 that may have other observations they might want to make.
i 23 MR. GENUSKY: Mr. Chairman, there's a difference 1
4 24 between commenting on the environmental impact statement and 1
- 25 commenting on the proposal, and I wonder what we're supposed Beritage gg p ration a
73 1 to do.
2 I'd like to see us comment on' the proposal, not on 3 necessarily the documents the NRC perused, but I'm not sure 4 that that's what we've been granted an extencion to do.
5 CHAIRMAN HORRIS: We11, --
6 MR. GENUSKY What is the procedure?
7 MR. MASNIX Well, there are two things at work 8 here.
9 First of all, commenting on the draft supplement.
10 I understand your problent with that in that it has changed 11 and it has changed considerably over the last couple of 12 ~ months based on primarily what has gone on here.
13 The comments that the panel has already raised on 14 the impact statement will be addressed in the impact 15 statement if they're still appropriate.
16 The other requirement that the panel has is to act 17 in its capacity as an advisory panel to the Commission,
- 18 which is to act as a conduit of public concern to the 19 Commission and provide advice, and that, in my mind , is
! 20 somewhat independent of the impact statement or it's a i
1 i 21 synthesis of the impact statement plus what has transpired 22 at these meetings.
I 23 So, I think that the panel certainly can go to the 5
- 24 Commission and provide its comments on the proposal. ,
i j 25 CHAIRMAN MORRISt So, we're saying that we can 1
Beritage g ration i
- ~ - re,*,,, .
, . - - , , , , , ,,----.m.m -e..,.+--. - - - ,- u ,m mm,,._m-m,- ,.wv., ..,.,w,,,.-e-ww-y---y- -g__ f
, i 74 1 L parate PDMS and the PDIS as a proposal or we can -- I !
l' i'
- 2 guess if we feel we have to make some -- somebody agreed we J 3 had that option.
t j 4 I think in my mind, they are somewhat mixed. I 5 felt maybe a month or two ago that you could separate them, ,
f 6 but, you know, some of the problems I had with regard -- one I
i 7 of tne problems I had with the PDIS is it doesn't deal with i ,
j 8 the likelihood of funding in each scenario. l I 9 one of the discussions we've had here is what l 4 I t
10 would be the funding plan in each scenario, and I realaze 11 the problem in dealing with that, but I think it is a flaw !
0 12 in the FDIS. I think it makes it a very difficult -- makes i
- 13 it very difficult to review the PDIS, I think, in a logical
) 14 way. ,
! 15 The other scenario that bothers me is the risk to k i i
- 16 the environment if it is -- if the plant is mothballed
! [
! 17 indefinitely,'and at the last meeting, you know, you used [
18 here in the review on PDMS a twenty-year period of time and, j 19 yet, at the last meeting, we heard that that twenty years l
20 could be sixty years, it could be a hundred years. I i
i I
J 21 I don't want to imagine things, but I think the ,
) 22 likelihood is that the PDMS will be much longer than twenty J l j 23 years. That's the sense I get, rightly or wrongly, that once 1
] 24 PDMS occurs, that it's going to be combined with 1
} 25 decommissioning at some point and the whole thing is going j
Beritage g ration 4
. e g s 4 75 1 to continuo to bo cothballed for cuch long0r th n twenty 2 years.
3 I think that's the most likely scenario, 4 personally, and that that is not really considered and what 5 then is the risk to the public with a plant that's 6 mothballed for eighty or a hundred years. I mean, who even
- 7 knows after fifty years what that plant really is and is j
8 there a threat to the public or to the environment because 9 of that.
10 That's my concern as a person going into this. I 1
11 stated early on that I felt that PDMS was a right position.
P 12 I said that publicly, but I have also said that at what
! 13 point should that PDMS begin, and I continue to have thkt i
14 se.me concern, and our discussion really has just clouded the 15 issue for me on it.
- 16 So, I think, I guess I'm saying that I see them 17 combined. I see PDIS and PDMS as very hard to rep 4 rate i i
i j 18 because one is somewhat dependent on the other. f l
19 MS. MARSHALL: Well, doesn't PD mean post i
20 defueling? I mean, wouldn't that point that when the fuel l l
J 21 has been defueled? Removed? I 22 CHAIRMAN HORRIS: Basically, that's what we're i
23 saying. Defueled. They can define this better thar I can.
{
l
, 24 Apparently it's readily eva t?.able to get to it, the. reactor, I i
't 25 but there is a lot of fuel that is throughout the system, .
l BeritageRggorggg ggporation l
l
- . . 1 1 76 1 that is not so easy to reach, that they're saying they want l
I 2 to put into a storage situation so that they can have it !
1 l 3 decay over a period of time and mayLe with new technology '
4 would be easier, more easily removed, and it will lower the ,
5 amount of radioactivity to the worker. ,
- I
! 6 So, there's two things I've heard from a period of '
i i 7 time. There's not so much the money from the operator but 1
1 :
2 8 more new technology and lower radiation exposure to workers.
1 l 9 That seems to have been the argument that they have f f]
10 presented for FDMS. !
) 11 MS. MARSKALL: There would be more exposure to i
12 workers who are involved with cleaning up Unit 2 than with !
I f
13 the ordinary nuclear facility. '
14 I guess what bothers me was that including TMI 2 15 in this rule business, that, you know, you don't have to 16 submit until July 1990, it's almost as though, well, this is [
'17 put in the same category with all the other nuclear plants. l l
18 I was under the impression that snit 2 and the l
19 accident that took place really was ar.mething pretty '
20 special, and it bothers me that a, you know, plan for 21 decommisaioning it is being postponed because it is being 22 lumped with all the others.
23 I think that, you know, something should be done
- 24. about it now, whether it is the physical thing of actually 25 restoring it to the ultimate goal that it would be restored seritageg g f p ration 1
o *
. e 77 1 to or at least, it seems to me, that the funds for dealing 2 with that should be dealt with, the plan should be submitted a
3 and not be put on hold until, you know, we follow through 4 with this rule for 1990. f i
0 1 don't know when that means that the funds would I
. l 6 be set aside, the time. I imagine that PUC would be involved !
1 !
7 in it at some point. .
i !
8 CHAIRMAN MORRISt Well, it all becomes vary I 9 complicated when you consider PUC and what they would allow
{ 10 to go into the clean-up, and it becomes very complicated 11 when we try to figure out what will the NRC accept as a 1 ,
12 funding plan.
I l 13 As you're pointing out, --
l 14 MS. MARSKALL: But why delay it until 1990? Why l 1
l 15 hasn't 'it been started already? It's einven years. {
16 CHAIRMAN MORRIS: Because what they're saying is 1 .
l 17 that that is for the decommissio'ning of any plants and this ;
J t
18 is a new order that was put out by the NRC that said the i 19 plan must be equipped to get funding for decommiwsioning, j 20 and what's happening with us here is that they are combining 21 the PDMS with the decommissioning as one funding plan to be l l, 22 presented in July of 1990, and I share the same concern you l i
q 23 have, that we have no real funding plan before us to review 1
24 as part of this PDIS.
l
- l 25 Part of the PDIS was the cost of this particular I l l
, "*'it*9*JHy'12I'4EliP*" l i
! 1
. i
- 76 >
1 pheso of the clocn-up, but thoro'o nothing to cddross os to 1 :
2 how would those funds be put in place. So, I hear what ,
t 3 you're saying. I'm just indicating there's no NRC standard t ;
j 4 and there is no requirement for that funding plan until July i !
l 5 of 1990. l I
6 MS. MARSHALL: Well, it makes you wonder if, you !
7 know, that the politics of the thing doesn't make it ,
4 . t l 8 tempting to just simply delay and delay and delay wrestling !
]; 9 with coming to grips with what are we going to do. ;
i 10 CHAIPNAN MORRIS: Let's -- i 11 MS. MARSHALL So, --
f 4
j 12 C MIPNAN HORRIS: I don't know if you followed the 1
{ 13 discussion at the last meeting, but that was precisely one i
j 14 of the points that was made, that under PDMS, under one i
o 15 option here, the twenty-year delay until they begin that
- {
16 clean-up and, yet, it was readily agreed to at the last
]
! 17 meeting by even Mr. Standerfor or Mr. Kintner that, in fact, f
18 twenty years may be a moving target way into the future, i 19 that PDMS could be combined with decommissioning, and
{ .
20 decommissioning could be put off for many, many years more J 21 than twenty. Sixty, eighty, maybe a hundred. I think 22 they're not unreasonable numbers to talk about, and as I 1
! 23 said earlier, it could be maybe more in line in reviewing l l
{ 24 the PDMS than the twenty-year period.
1 1
25 So, it is a delay, could very well be a delaying 5eritage g g g p ration 1
)'
. .- - _. . ~- . - - _ - _
o
- 79 4
1 game. t 2 MS. MARSKALLt Well, I don't think the panel
] 3 should support evasion of responsibility. I don't know what ;
i 4 we can do about it, but except to go on record.
5 CHAIRMAN MORRIS: Okay. Are there any other l l
6 observations? l
, 7 HR. GENUSKY: I have a question concerning what r 8 NRC has authority to do.
9 If -- under the decommissioning rule now, could !
i e I
10 the Commission decide that TMI 2 must be -- that clean-up
{
11 must be continued through decommissioning at this point and l
. t 12 require the utility to continue all the way through
]
]
13 decommissioning and forgetting about that rule, or can they [
2 14 -- or do they have a choice at all? Could they require some J
15 stopping between that point down to a level in which "normal i !
! 16 reactor", which was never really defined, and then
- 17 decommissioning at a later date? i 1
I 18 In other words, if there is another stopping point i
! 19 in between what is being proposed and final decommissioning, i 20 can NRC require that or can they only react to what the f i
21 utility proposes? ;
5 22 HR. MASHIKt My understanding is that the 1 i j 23 Commission has not come up with criteria for decommissioning l
\
f 24 criteria as far as, you know, what sort of clean-up levels (
k
) 25 are required before, for example, you go into a safe store l
! I i
seritageRggorgggggggporation i
\
i
[ 80 1 condition. l 2 So, obviously, we can't acquire that at the 3 present time. That's something that it's my understanding !
l 1 4 is under development at the present time. ,
I !
3 5 MR. GENUSKY: I guesa the question is what are the !
I i 6 options available to us. I don't really understand what i
! 7 they are right now. !
i l 8 HR. SMITNGALL: Excuse me, Tom. Am I missing
! E I 9 something there? When they talk about safe store and i i
10 containment in that new decommissioning rule, --
t i 11 MR. MASNIKI Right. l
-i 12 MR. SMITNGALL: -- where it -- am I missing the !
! 13 point where decon is the alternative in which equipment and :
I I
14 structures of the faci:ity containing radioactivity are [
15 removed and decontaminated to a level that permits property !
t 16 to be released from restrictive use? That being decon. Safe 17 storage is the alternative in which is in essence defer I i 18 decontamination, j
! l 1 19 MR. MASNIKI That's correct. !
f 20 MR. SMITHGALL: Aren't those criteria for --
l
) 21 MR. MASHIK What I'm saying is that there's no !
r i 22 criteria that to clean up a plant to a certain level before l l
} 23 it goes into safe store. Now, there is obviously criteria 24 for unrestricted use of an area. So, onder the I l
l 25 dismantlement option, there is an end point there.
l Beritage g g g g p ration 1
1,
, ~ _ _ .,----or ..,--r-,.-m-,-..,-,_r--.,.,,,-.m..,,---,-.,.. rom.m.- --w-,- . - - - - - - - . - , - -,r v-, -,-- ---,_- .. __ - y.,
- ._. -. _ -_. - . - . - _ _ _. . - _ ~ - _ - .
- 6 . . ,
' ' 5 81 i l 1 CRAIRMAN MORRIS: I think, though, even though it !
2 seems to be certainly an undefined situation here, I think l 3 the panel should feel' free to, if they have a sense or a 4 feeling on this particular question, they should feel free I 5 to offer that sense to the Commission.
l 6 What they can and can't do with it, I think at l 7 this point, we don't know.
8 MS. MARSKALL: Can somebody tell me is l i
9 unrestricted use the goal for the cleaning up of any --
l 10 MR. MASNIKt Any facility. }
11 l MS. MARSKALL: Any facility.
[
t 12 MR. MASHIKt That's correct. I f
't 13 MS. MARSKALL: Is it contemplated that that would i
)
i 14 be the goals of THI 2?
15 MR. MASHIKt That's correct. '
16 MS. MARSKALL By unrestricted use, does that mean !
17 that the physical plant would still be there, that people j 18 could walk in ar.d out and it could be used for a museum or l
19 something?
l L
20 MR, MASNIKt Conceivably, it could be farmed or (
L 1
21 houses built on the site, and it's to a point at which I 22 people can inhabit it and not have any restrictions due to ,
1 23 radiological considerat,ons.
24 MS. MARSKALL t Have there ever been any nuclear 1
J 25 plants anywhere in the world that have been decommissioned i
Beritage g ration l
O '
82 ,
1 and there has been that type of restoration?
2 MR. WALD: The plan for Shreveport, which is l 3 currently in the process of decommissioning, is for it to be :
4 resorted to public uses. A public park. That is the goal !
5 and the Chairman was talking about it about three or four i
6 years from now.
j l
7 But that's the objective there.
l 8 MS. MARSHALL: Where is that located? l' l
9 MR. WALD: It's near Pittsburgh. Twenty miles 10 from Pittsburgh, i 11 MR. MASHIK There has been reactors that have i i
12 been completely dismantled. One, I believe, is Elk River, 13 where they essentially leased the ground for unrestricted 14 use. !
15 MS. MARSMALL: I should think they would have a !
16 handle on costs, if it's already been done. l
(
17 CMAIPJ4AN HORRIS: Is this clarification, Neil:
l 18 because I was going around this way, but if you want to I 19 clarify something?
20 MR. WALD: No. I was going to ask you for i
21 clarification. Is this end of the table constrained not to j l
22 make any comments in the discussion?
23 CHAIPJ4AN MORRIS: No. I indicated that in' order !
1 24 to be fair and give everybody a chance, I was indicating we !
25 would come this way around and we will eventually get to meritage g g g g p ration l
s i 83 1 that end. But if that end has a clarification or a point 2 that's being raised by the others, please jump in.
3 If you want to offer observations on this n
]
4 discussion, I was trying to make order of it, we could have '
j l 5 started with either end.
l i
) 6 MR. WALD: I wanted to kind of make Tom's -- < f t
i
] 7 CMAIRMAN MORRIS: Go ahead. I'm not going to be ;
8 that -- I will switch them from you, I think Elizabeth has 9 spoken and then go to Anne unless aomeone raises a point. i j 10 HR. WALD: I can wait.
1
- 11 CRAIRMAN MORRIS
- Go ahead.
I I
12 MR. WALD: It seems to me that Tom has a very I [
) 13 interesting suggestion which has not been broached before, i 1
l 14 which is a stopping point somewhere along the line which I
) '
15 would define as an environment which it no different than
) 16 any active operating plant, and that may mahe a lot more f l I i 17 sense than all or nothing, which is what's been discussed'up l i
{ 18 to now.
j 19 MR. IU.SNIK But that's precisely what the impact i I
- 20 statement defines as the end point of our evaluation. It is 1 l t
21 conditions closely approximating the operating plant nearing !
i 1 22 the er.d of its life.
1 l 23 CRAIRMAN MORRIS: Is that the end point of PDMS?
4
) 24 MR. MASNIK: In our mind, yes.
i
]
25 CRAIRMAN HORRIS: Right. I understood that.
5eritage g g g y p ration 1
i
84 1 MR. MASNIK: That's correct.
2 Now, the next step after that would be 3 decommissioning.
4 CHAIPNAN MORRIS: I understand.
5 MR. MASNIK But the problem to understand is that 6 they're getting bloodied.
7 CRAIRMAN MORRI5: But I think if we're looking for 8 an action here and it would be one where it would be a plant i
9 equivalent to, as Neil pointed out, a normally operating I
10 plant, that is at least more of a definite position than l
11 maybe what we've been discussing at this point, and I think l
l 12 Tom was trying to say the same thing.
l 13 Anne?
14 MS. TRUNK Couldn't we put a deadline, say, 15 twenty years, you nave to have the PDMS, you know, completed 16 and start decommissioning, instead of going for thirty years 17 and sixty years?
l 18 CRAIRMAN MORRIS: Well, I guess this panel could i 1
19 make -- I think we can of fer any observation we want to at 20 this point.
l 21 MS. TRUNK But uphold it, too. Not like that l
l 22 water thing that we were going to look at every couple of 1 I
( 23 years and eventually gather up -- and have something that, L l
24 you know, you make it stick.
l l 1
l 25 Then, I also want to know, what is the safe plant. l HeritageRggor gg poration l
85 1 If they put it into storage, just what is safe for the 2 environment and for me living in Littletown?
3 CHAIRMAN MORRIS: I think there's been attempts to 4 try to define what that is, arid I think one definition has 5 been at least equivalent to radiation levels in a normally l
6 cperating plant. Whatever that means2 7 Obviously, there's a lot of technical questions 8 that we could not provide answers to, and that we will not 9 have answers to as we deliberate on this. It just isn't 10 possible. It's such a complex issue for us to take on, and 11 that's why I'm saying all I think we can offer as a panel is 12 a sense of after three meetings, full lengthy meetings, what 13 is the sense of the panel, and I don't think we ought to 14 feel that we're giving something that we can technically 15 support.
16 I think t:o have to -- we've heard public comment.
17 We've heard CPU's positiens and certain comments from the 18 NRC and these have developed a sense of the position that we 19 have, and I think that's what I'm trying to get to.
20 MR. MILLER: I think we're all expressing the same 21 frustration at not having clearly-defined end points of 1
22 things that seem to be rather generic, and I think that we l 1
23 need to express this frustration to the Commissioners. I l
24 I'm not sure it's the function of this panel to 25 define what those end points ought to be for any of those .
I Heritages Reporting Corporation (202) 626 4888 l
\
. . t 86 -
1 conditions.
I 2 CHAIRMAN MORRIS: Thank you.
3 MR. GENUSKY Just a comment on that.
4 In the SAR, there is a table indicating what the 5 levels of radiation, radioactivity, inside the plant will be i J
i 6 under PDMS versus what it would be in a normal operating f 7 plant, and you can get a comparison, but, you know, the .
2 l
8 first time I saw that table was this aftecnoon.
]
9 We haven't had an opportunity to look at it and 10 ask questions about it. So, it is in there. It's available. I
!{ t j 11 So, there is something in the SAR that can provide us with !
I i 12 the guidelines as to what at least the utility believes is a 4 ;
) 13 reference plant. I i
- 14 MR. MASNIK I also believe in the supplement, 2
i 15 there is a table on end point criteria for clean-up. l q e 16 MR. SMITHGALL Mike, could you see what you can !
17 find on that and while you're looking, if -- Ken --
18 I HR. MASHIKt It's on page 3.2 It's Licensee's ,
1 19 I j Radiological Goals for TMI 2 Facility at the end of its use. }
i 5 20 MR. GENUSKY: What was that page? Does that give :
1 t
21 a reference point, too? '
i i 22 MR. MASHIKt No.
I !
t t
23 MR. GENUSKY It's a comparison of the two, as I J
l 24 was pointing out. '
I I I
- 25 C EIRMAN MORRIS
- Mike, while you're looking, I T
( (
L i
.., l l
1 roolizo w3'ro pursuing thct eno quoction, I'o just going to ;
I l 2 see if Tom has any thoughts. !
i I j 3 Ken, did you have anything additional you wanted 1
l i
I 4 to add? i l
] 5 MR. MILLER: The only thing that I would like to [
i ;
! 6 add is in looking at the dose savings that are to be gained l 7 through PDMS, if you compare that to a clean-up population 4 l 4 ;
l 8 of about a thousand persons over the same twenty or thirty
{
3 l J 9 years, you're looking at dose savings that are comparable to ;
r 10 the same committed doses people are going to get from f
11 natural background radiation.
i 12 And if you throw in the radiation dose from radon, l l
13 you're going to get levels that reach the extremes of what i f
, 14 your projections are there.
, 15 So, I personally don't see justification for going ;
1 l l 16 into PDMS based upon the dose projections that are in the 17 impact statement. (
i 18 HR. SMITHGALL: Excuse me. To go back to Mike's f f
l I i 19 comment a little earlier that we can comment on the PDIS and !
i 20 the PDMS and be a conduit of public opinion and advice, I }
'l guess my thought there is that I don't think we're confident f
{ 22 enough in the numbers that are being used to estimate the 1 b
] 23 dose savings and that was interesting to hear Ken's comments !
I l
l 24 on it right now.
25 Secondly, and more importantly for me, I don't seritage g g g p ration l t
h
88 1 think it con bo cortcin thtt funding would bo in picco 2 despite the assurances of Mr. Kintner in his letter and us 3 making comment on that without even seeing the plan.
4 So, I'm a little dubious. I would rather comply 5 with the Commission's past stance on an expeditious clean-6 up and not leave a waste site on the Susquehanna River for 7 ninety years.
8 Again, I see no justification for PDMS based on 9 that.
10 CRAIRMAN MORRIS: Joel?
11 HR. ROTH: Yes. Try to maka some sense of this. I 12 have a feeling that to a certain er. tent, we've been caught 13 in the trap of dealing with URC rules or GPU rules that in a
~
14 time past we sort of rebelled against sometimes and said, 15 well, this is how we feel and we should go on record in 16 saying that.
l 17 For instance, the funding which we were told we 18 had no business dealing with, but, yet, far about two or 19 three years, we continued to do it and kept pressure on, and l 20 I'm glad we did.
21 I just have a sense tonight that NRC would 1
22 probably be a lot more comfortable it we would just be good l l
23 children and go along with the rules, and I just have a real l 24 strong sense that we can try to cut through all tnat and 25 just really say there's no justification for the PCMS and Heritage Remrting Corporation (202) 628-4888
. . i 89 1 for tho ciccn-up to procOOd immedictoly, cnd Act tho NRC 2 deal with what is, you know, what are the finer points, that i 3 we are representing, say, the public, the public sense is !
4 that, and stop trying to maybe, you know, complicate 5 ourselves, you know, with the issue.
6 What I hear, you know, Ken Miller make the f 7 statement, you know, no justification, as a scientist, 8 that's very meaningful to me. When I hear, and I did hear, I I I
9 read Mr. Kintner's, you know, promise of funding, it reminds 10 me of what George Bush probably meant in 1980 as "voodoo [
11 economics" has come to roost at this point. !
I 12 I just don't see any reason for us to really try j i
13 to make it maybe too complicated and just merely say this is f i
14 our feeling as a panel that PDMS is not justified at this f 15 point and we throw it back to you to deal with getting on I f
16 with the clean-up, and if, you know, someone would like to i
17 put that into a motion, I'd be very happy to accept that. i i
18 CMAIRMAN HORRIS: What I'd like to do, hopefully i 19 we can allow each person to have a comment, and then if i
l j 20 somebody would like to make a motion to at least begin de i
i 21 process, I think that would be wonderful.
l j i
l 22 Gordon? i 1
l l 23 MR. ROBINSON:
l I couldn't agree with your earlier !
I 24 connents. I have a problem distinguishing between a PDIS' l 25 and a SAR from the standpoint of the information that I got.
l 5eritage g g g g ration
i ., ,
90 i l
1 I had o chcnco to look ct tho SAR, but I d n't havo too cuch l l 2 of a problem w?.th PDMS, the two criteria, neither of 'thich l 3 show up in the PDIS. It's terrible letters. r l
! 4 One is the funding, is the funding going to be in 5 place. The second one is, and there's a statement in the [
i 6 PDIS that says, "In addition, the staff concludes that no l l
7 further clean-up following defueling or no action j i
8 alternative is not acceptable because this course would not l i
9 result in elimination of public health and safety risks i 10 associated with the damaged facility".
11 So, that inds. cates that there is some time limit I 12 that has to be satisfied as far as completion of the (
[
13 decommissioning and clean-up is concerned. -
14 Yet, I have seen no indication of why there is and l 15 what the risks are to safety. It may show up in the SAR. It l 16 may just be good common sense. I just don't know the answer f
f 17 to that. Those are the contents that are bothering me.
{
l 18 CHAIPNAN HOPAIS: Thank you, Gordon. t i
19 Fred? l
}
20 HR. RICE Thank you. !
21 Gordon asked a question, is the funding going to l 22 be in place. My question is, what is the procedure to 23 guarantee the funding. If I knew that, then I think I could i I
24 take'a better position as to whether the clean-up should be l 25 immediate or ton years or fifteen or twenty, but how do we
-m.w.una.r.u.m
~
91 1 gu0rentco tho funding. ThSt's ty qu0stion.
2 CHAIPNAN MOPRIS Neil? We finally got over to 3 your side.
4 MR. WALD: I really want to raise the same 5 concerns that some of the issues have not been quantitated l l 6 the way they say the occupational exposure is. I'm not sure 7 the quantitation of exposure at the twenty, thit *, sixty, ;
8 ninety or whatever number of years, the costs would be to 9 weigh against this occupational exposure.
10 I'm not sure that the PDIS gives that. If it does, f 11 I may have missed it or forgotten what I read.
12 So, I think there are variables here that we i 13 really don't know and certainly funding is one of the i 14 biggest. I think that is the comment from the panel that I !
15 would expect the NRC needs to know. I 16 CRAIPMAN MOPAIS Which one specifically, Neil? I 17 didn't catch the last. Funding?
s 18 MR. WALD: You finally got to me and you didn't [
19 listen, t
20 CMAIPMAN MOPAIS: I listened to the first for a i i
21 minute or so when you were talking about agreeing on the i !
i 22 funding, but I missed the last part.
23 MR. WALD: I said that there are so many variables 24 to weigh against the quantitative figure' for occupational i
)
25 exposure, say, are not in place, certainly not in any time 1 l
l 5eritage g rg g p ration l
I i
92 1 frcme, like twenty, thirty, sixty or ninety years, and the 2 funding is another area for which we don't have any l
3 quantitative information and it makes it very hard to have a 4 reasonable judgment on it.
5 I think that's a comment or a complaint or 6 frustration.
7 CHAIRMAN MORRIS: Well, I certainly share that, 8 and I think I've heard most people here share that very same 9 thing. Both the radiation exposure, moving target type of 10 thing, and the funding problem.
11 I wonder if anybody is in a pc-ition here to share 12 with us a proposed motion. Joel keeps whispering he's 13 working on something, but I don't know if he's reaty or not.
14 MR. ROTH: Well, with my luck in the voting, I' m t
i 15 gozng to be very careful, you know, on what I say.
16 But just as a start, I guess, and I'm certainly 17 open to friendly amendments or whatever to it, and it's
. 18 going to be not worded correctly, but I'd just like to see 19 us, you know, move off center like and act responsibly and I
20 quickly, is just to say that we see, the panel sees no 21 compelling reason for the PDMS and under that, we can use (
22 the worker exposure and the funding and, therefore, to
) 23 proceed with the 11esn-up expeditiously.
4 1
24 I'm certainly open t o any friendly changes.
25 Hearing silence, it's passed, right? '
i HeritageRegorggggggporation
)
93 1 CEAIRMAN MORRIS: Okay. Let's.just take it slowly 2 here. The panel sees -- the motion would be that the pane]
3 sees no compelling reason for the PDMS and then following 4 the PDMS, you're indicating express some concern regarding 5 funding and the worker exposure question.
6 I guess on the funding, you said it's the 7 uncertainty of the funding for the PDMS and on the worker i
8 exposur , it's the uncertainty of just what level of worker 9 exposure is saved due to the delay, whether it's a twenty-10 year period or forty-year period, worker exposure would 11 change. There's a great deal of uncertainty to that.
r 12 Therefore, clean-up should proceed expeditiously.
13 Neil, comment? Clarification?
14 HR. WALD: I don't entirely share Ken Miller's 15 positioin about the worker exposure. If weighed against the 16 additional worker exposure, there '.s nothing, then I can 17 wait for the worker exposure.
18 My problem is I don't know what to weigh against i 19 it and the cost issue is one reason I vote. In other words, 20 will this actually be taken care of in twenty years or not.
21 I don't know how to weigh what's in the balance against the 4
22 worker exposure, but given an improvement or reduction of l 1 23 worker exposure and no loss anywhere up and down the line, I l 24 would have to vote for the worker exposure.
1 25 MR. MILLER: Can I clarify my comments?
HeritageRegor gg ggporation i
94 1 CRAIRMAN MORRISt COrtainly.
2 MR. MILLER: I was not saying that I didn't think -
3 the worker exposure was significant. I was trying to put it 4 in to context in terms of its significance, and I was saying 5 that, just doing a quick calculation, it turns out to be 6 that the dose savings, the total dose savings amounts for 7 the amount of natural background radiation on the san.e 8 worker population you get over twenty years.
9 I didn't say that it was insignificant. However, 10 on the other hand, this population in this area has been 11 given a lot of these dose projections a.id dose estimates and 12 so on. Following the accident, an analysis was done to 13 indicate that the total population dose commitment in this 14 area or at least radioisotopes was 3300 person rom, and the 15 people of this area were told that this would be expected to l 16 produce approximately one-half of one case of fatal cancer, 17 and, therefore, this is insignificant.
18 So, if that 3300 person rem was insignificant in 19 that sense, this 3300 person rem should really be somewhat 20 insignificant in the same sense.
21 MR. WALD: Can I comment?
1 22 CHAIRMAN MORRIS: Sure. l l
23 MR. WALD: Excspt that one was already received l
1 24 and the other is being planned and that is a big difference 25 there.
Heritage (20 Ro$orting Corporation
) 628 4888 l 1
.- e e
. . o 95 1 MR. MILLER: Not in the calculation. I would also 2 like to add to that list that I think we need to convey to 3 the Commissioners our concern, our frustrations over these 4 poorly-defined end points.
5 I think that's the real problem here, and that's 6 what's got us all bogged down in trying to come to some sort 7 of deciclon and throwing out something we could all vote on.
8 MR. RICE: Mr. Chairman, let me ask another 9 question.
10 CHAIRMAN MORRIS: Yes, sir.
11 MR. RICE: The Federal Register, dated Monday, 12 June 27th, 1988, deals with the financial assurance and 13 recordkeeping for decommissioning. Paragraph F says, 14 "Financial assurance for decommissioning must be provided by
- 15 one or more of the following methods: prepayment", that 16 would be one, "or, two, a slurry method of insurance or 17 other guarantee methods", but there's an entiro section here 18 that explains exactly what the licensee must do.
19 So, has a funding plan been submitted? i 3
20 CHAIRMAN MORRIS: The answer is no. A funding 21 plan would not be submitted until July of 1990.
22 MR. RICE: That's July 19907 23 CHAIRMAN MORRIS: That's the deadline.
q 24 MR. RICE: Well, I think we ought to suggest that l
25 that be updated so that we can consider it because I just Heritage Reporg gg g poration I
96 1 think that we cannot come to a proper conclusion.
2- CRAIRMAN MORRIS: And I think that's the point of 3 the motion, that, again, if I could attempt to clarify where 4 we are at this point, the motion is the panel sees no 5 compalling reason for the PDMS and after that, I think some 6 points have been made regarding conditioning that statement 7 on PDMS, poorly-defined end points. Worker exposure savings 8 argument is not convincing when you compare it to the 9 uncertainty of the funding and uncertainty of the length of 10 time of the PDMS.
11 I mean, that -- at least I'm finding in this a 12 sense that whether you agree with the comment Ken is making 13 or Neil has been making, I think there is a sense of the 14 panel that the worker exposure savings, the argument for 15 that, l's just not convincing when you compare it to some of 16 the other open-ended things that ere just funded and the 17 moving terget when it comes to the PDMS itself.
18 Therefore, the clean-up should not proceed --
19 therefore, the clean-up should proceod expeditiously, and 20 express also in the motion that we define end points that 21 have caused the panel to feel a sense of frtistration in 22 dealing with the PDIS and the PDMS.
23 Again, I'm just throwing ou". some guidelines here l 24 that we can clean up if we se desir6.
j 25 MR. ROBINSON: I have a problem with making a 5eritage g ration i_ __ _ _ _ _
. }
97 1 decision on PDMS at this point until some of the other 2 things are defined, and it seems to me that the way the 3 motion reads now, we are making a decision against PDMS, and 4 I'm not ready to do that yet.
5 I'd like to see some more -- the other problems 6 defined and then make the decision rather than make the 7 decision and say these have been weighed against each ocher.
8 We haven't had a chance to weigh them yet because .
9 we don't know what the answers are.
i 10 CHAIRMAN MORRIS: Well, we could change the '
11 language to say that until such time as other information is 12 available, that the panel takes the position.
13 Again, I understand what you' re saying. That 14 information is not forthcoming. We've had nobody come 15 forward and say, well, we're going to give you a funding 16 plan tomorrow, and unless it's forthcoming, how can we deal 17 with it?
18 MR. WALD: I think that I would subscribe to what 19 Gordon said, is to say that there's no reason to go for 20 that. The panel is not in faver of going forward with the ,
21 PDMS until the justifications a;te made much more clearer.
22 MR. ROTH: Yes, but as the maker of the motion, 23 that is not a friendly amendment. It's not open just for 24 friendly amendments. Right. I understand that. But I 25 certainly wouldn't incorporate that in my proposal, my Heritage ration l
l
98 1 resolution, whatever you wish to call it at this point.
2 No, I could not accept that. I think it's up to 3 the --
4 CHAIRMAN MORRIS: That would be a whole new 5 motion.
6 MR. ROTH: Right.
7 CHAIRMAN MORRIS: And I guess what we should do 8 here is try to move towards a wording that maybe is a sense 9 to here and vote up and down, you can certainly -- Neil, 10 yes, I hear what you're saying.
11 I think if you have another position on this that 12 you'd like to offer, that you will vote up or down on this' 13 motion or ,vu will try to amend this motion or have a 14 substituto motion to it.
15 But at this point, before as again, the panel sees 16 no compelling reason for PDMS and because of -- again, 17 because of no convincing reasons being presented on worker 18 exposure and the uncertainty of the funding and the 19 uncertainty of length of time of the PDMS, we basically are l
20 opposing PDMS and suggesting that clean-up proceed 21 expeditiously. - l 4
22 That's the sense of that is before us at this 23 potat.
24 MR. ROTH: Can I just give one other reason for 25 that motion? As I agree with what you're saying, but I Heritage rem rting Corporation l l (202) 628-4888 !
i l
.' l
. j 99
' 1 1 think the onus is on the utility'and the NRC to step forward ;
I 2 and do that and not for us to say, well, when you do, you -
3 know, -- I mean, to ask tbsm, I don't think we should have 4 to ask them.
5 I think we should say if we agree, there is no 6 compelling reason at this time, let the utility step 7 forward, let the NRC step forward, and show us compelling 8 reasons.
9 I don't think we have to, you know, amend and 10 maybe weaken the stand. I don't think we should wait till 11 1990 to give the funding. If they wish to mov6 it up, I 12 think that we should make our stand and they then have every 13 right to come back to us and say here's what we're going to 14 do about that.
15 I would rather not see us start anew our feelings, 16 you know, at this point, and I use, for example, what we did 1 17 on funding. I use, for example, when -- I mean, God must 18 have been listening that night because a number of years 19 ago, I had made a motion that the clean-up of Ur.it 1 20 shouldn't be started until there was a funding plan for l 21 clean-up. This panel actually voted in favor of that motion, i
22 and we did bring it up before the NRC, and they were 23 startled, but at least it showed our feelings.
24 I guess that's all I'm trying to do at this point.
25 MR. GENUSKY: Could you make a minor modification J
HeritageRggorggg ggporation
. o 100 1 'in it and say, cut out the: phrase "we are opposed to PDMS" 2 and say we propose expeditious clean-up?
3 CHAIRMAN MORRIS: .I - -
4 MR. GENUSKY: And that would solve everybody's 5 problem.
6 CHAIRNAN MORRIS: I would state again for the 7 record, again, the panel sees no compelling reason for the 8 PDMS. It doesn't say we're opposed.
9 MR. ROTH: Right.
10 CRAIRMAN MORRIS: We see no compelling reason for 11 the PDMS.
12 MR. ROTH: Right.
13 CHAIRFEN MORRIS: Now, comments on something like 14 that. Worker exposure savings. Worker exposure savings 15 argument is not convincing compared to the uncertainty of 16 the funding and the uncertainty of length of time of the 17 PDMS. Therefore, clean-up should proceed expeditiously. l 18 MR. ROTH: Exactly, i
I
- 19 CRAIRMAN MORRIS
- Obviously, it needs cleaning t'p i I
20 some, but that's again the sense of what we're saying and 21 part of the motion then is the statement that poorly-defined 22 end points of clean-up caused the panel to feel a sense of l
23 frustration in dealing with the PDIS and PDMS.
24 Now, again, just to clarify items, I personally 25 agree with what Joel is saying. I think we're not closing a
Heritage (20 rep. .) 628-4888 rting Corporation l i
. . 6 101 1 off the chance to return to this issue if somebody comes 2 forward and presents information that we are l'acking.
3 So that, you know, for the record, my vote -- I'm 4 certainly open to receive information on both of those 5 arguments, but until we do, I have been expressing the 6 opinion on what we've heard, and what we've heard is that 7 there's no funding plan until 1990 and this PDIS is supposed 8 to be completed by this year some time, which is a whole 9 year and a half before the funding plan is put in place.
10 So, if that's the case and with that kind of 11 uncertainty, I personally don't feel like I've got much of a 12 choice but to vote for the motion.
13 MS. MARSHALL: Couldn't we be a little more 14 specific and request that a plan for decommissioning be 15 started at this time with the ultimate goal of unrestricted 16 use?
17 CRAIRMAN MORRIS: I think, if I could, --
tha't's a 18 separate -- in the decommissioning issue is scmewhat 19 separate from the PDMS,
) 20 MS. MARSHALL: It's the decommissioning that i
21 they're talking about An this Kintner letter.
22 CRAIRMAN MORRIS: On the funding.
23 MS. MARSHALL: And putting it with all the other 24 licensed reactor plants in the country.
25 CRAIRMAN MORRIS: That's the way it's tied into Heritage gg ration d
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102 1 decommissioning because they have agreed that the PDMS 2 funding would be included in the submission.
3 MS. MARSHALL: Did the -- TMI 2 is a licensed 4 reactor plant. It hasn't been an operating plant for eleven 5 years.
6 CHAIRMAN MORRIS: I think the point that's being 7 made is you can certainly try to make a motion to amend 8 this, and I would encourage you to do that if you have a 9 thought on it, but I think what was said in the motion is 10 again is that this panel is making a strong statement based 11 on information that's been provided to us.
12 If somebody wants to come along and try to change 13 the sense of the panel by providing information on 14 decommissioning, funding plan, or something on the PDMS or 15 some changes, by all means, feel free ta do that.
16 But given the information we have, this is the 17 sense of the panel.
18 MS. MARSHALL: That --
19 CRAIRMAN MORRIS: Which includes the sense of 20 frustration throughout.
21 MS. MARSHALL: We are just, in other words, going 22 to put simply on record that we're opposed to the monitored 23 storage, post defueling monitored storage?
24 CHAIRMAN MORRIS: But we are conditioning that en 25 the fact that we have not -- the worker exposure question Heritage ReMrting Corporation (202) 628-4888
o a 103 1 has not been compelling when you compare it to the lack of 2 information on the funding, and the lack of information on 3 the length of PDMS.
4 So, we're conditioning it.
5 MS. MARSHALL: It's a unique plant, though.
6 CRAIRMAN MORRIS: They understand that. They're 7 going to read the transcript. If somebody wants to come ,
8 along and offer something to help us, fine, but until they 9 do, t 10 Again, it's such an open ended question for us to 11 answer.
12 MS. MJ3SHALL: They have to start the plan some 13 nime.
14 CHAIRMAN MORRIS: I understand that.
15 MR. ROTH: Can I just -- Arthur has been a very '
16 fine spokesman for my motion, and I certainly don't want to 17 stop it. He's on a role at this point'.
18 But all I'm trying to say is condensing all this i
19 iato the no compelling reason and let them come with all the 20 other reasons and points they wish to. That's not for us to 21 do, you know, at this point. ,
22 We just have heard no compelling reason yet, you 23 know, at this point, and I think that's all my motion is 24 addressing, is that. It's not addressing decommissioning or 25 any of these other issues which I certainly feel strongly BeritageRegor gg ggporation 1
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2 What the people to my right, which is a great l l
3 position for you guys to be in, is just trying to get to the l 1
4 heart of the issue, where we are. That's all I'm trying to 5 do, and not bring in, you know, all these other things, i
6 which I'm agreeing with.
7 But I don't think that belongs. I think the onus, 8 the responsibility belongs on GPU and NRC, not on the public 9 that keep coming forward endlessly and not for us to try to 10 develop, you know, ideas at this point, but just to say what 11 we have heard, you know, is just not sufficient.
12 CHAIRMAN MORRIS: Neil?
13 MR. WALD: You still pointed out Neil rather than 14 him.
15 MR. ROTH: Good, Neil.
16 MR. WALD: I have to agree with the intent. I 17 think we're close in that. My concern is -- well, if you say 18 at this time, for instance, as you just did, if it's clear '
19 that at this time, there's no compelling reason, I agree I 20 with you, the burden of proof is on the NRC and GPU to be ,
21 convincing about what to weigh against the worker exposure, 22 and I agree with the question that we don't have is 23 important and needs to be built in, and I think by these ,
24 people, not by us.
l 25 So, I agree with you. I don't want it to appear '
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105 1 that we're closing out for all time consideration of this.
2 MR. ROTH: Right. At this point, there's no 3 compelling reason at this time. I would certainly accept t
4 that as a friendly addition.
5 MR. WALD: Okay.
6 MR. RICE: I have one question. What is the !
7 period for clean-up under immediate? Four years? Is that 8 correct?
9 I thought they sabmitted many reasons for post 10 defueling and one of the reasons was that they had to tear' 11 the whole thing apart and cause a lot of restructuring and 12 so forth.
13 I'm still not prepared to support your resolution.
14 CHAIRMAN MORRIS: Okay. The motion as it now 15 reads has been amendud in a friendly fashion to say at this 16 time, the panel sees no ccmpelling reason for the PDMS, 17 worker exposure savings -- the worker exposure savings 18 argument is not convincing when compared to the uncertainty 19 of funding and uncertainty of length of time of the PDMS.
20 Therefore, clean-up should proceed expeditiously.
1 21 Poorly-defined end points of clean-up caused the 22 panel to feel a sense of frustration in dealing with the 23 PDIS and PDMS. That is basically the motion before us.
24 I would ask permission that if we go forward, that 25 I am allowed to have some editorial right to clean up simply l HeritageRggor g gporation i
. s 106 1 the language, not the intent.
2 MR. ROTH: As long as I can hear that, sir.
3 CHAIRMAN MORRIS: Again, I will send copies of any '
4 thing like that to the commenters. If anybody has a problem 5 with it and want to restate it, it would only be in order 6 for people to understand it maybe a little bit better and 7 not argue about crossing the t's.
8 MR. ROTH: I would certainly accept that. Yes. , ,
9 MR. SMITHGALL: I have heard somebody ask for a 10 call of the question. I'll second it.
11 CHAIRMAN MORRIS: Okay. It's been moved by Joel 12 Roth. That motion has been moved by Joel Roth and seconded 13 by Tom Smithgall. The question has been called for, and I 14 would ask all those in favor -- if you will wait a second, I 4
15 will ask you again, I will ask you to raise your hand if 16 you're for it and raise your hand if you're against it, so 17 it's easier to figure out.
18 So, all those in favor of the motion, signify by 19 raising your hand, please. i t
20 (Show of hands.)
21 CHAIRMAN MORRIS: There are eight individuals for 3
22 it and, for '4he record, they are Genusky, Marshall, Trunk, l 23 Miller, Smithgall, Morris, Roth and Wald.
24 Those against, raise your hands, please.
25 (Show of hands.)
4 l
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107 1 CHAIRMAN MORRIS: I guess the two other 2 individuals that are present here this evening, Fred Rice 3 and Gordon Robinson.
4 No , you will not be discriminated against. I 5 didn't know whether to use the names or not. It's on the 6 record.
7 Okay. That basically completes the agendu~ items 8 for this evening.
9 We do need to discuss and I know that Neil 1
10 apparently needs to leave at this point, Neil, if you could P
11 hang in for a little bit, I know you need to leave here soon i
12 because you've got to drive to Philadelphia this evening, 1
! 13 could we talk at all about shooting for a meeting with the ,
14 NRC on a certain date or not?
15 MR. MASNIK: I don't have a specific date. What I r
16 would suggest is that you prepare a letter to the Commission 1
- 17 essentially detailing the results of tonight's vote, and 18 request at that time that you would like to meet with the 1
19 panel, with the Commission some time in October, and I'll i
20 independently begin negotiating a date.
l l 21 What would be helpful to me is if I can get some
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1 22 sense of when there might be significant conflicts with the 23 panel during the month.
j 24 CHAIRMAN MORRIS: I'd like to maybe take a minute j 25 for the panel to talk abcat maybe a couple of days that we BeritageRggorgggggggporation
108
- i. 1 can meet, and we have met'before, I think, on Tuesdays, 2 Mike, or doesn't it really matter?
, 3 MR. MASNIK: Generally, in the middle of the week, 4 and I would say that it would probably be best towards the a
5 end of the month because the Commission generally tends to 6 schedulo approximately six weeks in the future.
i 7 So, things are locked in pretty tightly at six 8 weeks.
9 CHAI!WAN HORRIS: How does Wednesday, ths 19th, 10 look to people?
11 Anybody have any -- that's --
I 12 (Discussion off the record.) i 13 CHAIRMAN MORRIS: October 19th is a Wednesday.
I 14 (Pause) 15 CRAIRMAN MORRIS: Wednesday, the 26th. Does 16 anybody have problems with that, that they know of? October 17 -- Wednesday, October 26th.
18 Okay. Why don't we at least -- let me ask -- does 19 anybody have problems with the 27th? So we can give them i j 20 two days to work with.
21 MR. ROBINSON: I'd prefer the 27th. I have two 22 classes on the 26th that are pre-arranged. l 23 tHAIM Wi MORRIS: Why don't we work with the 26th 24 and the 27th. I've heard a preference by one person for the 25 27th.
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. . 3 109 1 MR. MASNIK: And this would be prior to lunch, 2 probably 11:00, the standard time.
- 3 CHAIRMAN MORRIS
- I have heard Joel say it's y 4 probably the 26th. I think -- whatever randomly turns up 5 with the Commission members, if we can go with ona of tho'se ,
i 6 two dates, then let us know.
. 7 Anything else to come before the panel this 8 evening? ,
9 (No response.)
10 CRAIRMAN MORRISt If not, we stand adjourned.
i 11 (Whereupon, at 10:00 p.m., the hearing was 12 concluded. )
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i REPORTER'S CERTIFICATE 1
2 3 DOCKET NUMBER: N/A s.
4 CASE TITLE: ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND, UNIT 2.
$ HEARING DATE: September 7, 1988 6 , LOCATION: Harrisburg, Pennsylvar.ia ; ,
7 I hereby certify that the proceedings and evidence 8
i i are contained fully and accurately on the tapes and notes 9
reported by me at the hearing in the above case before the !
10 :!
United States Nuclear Regulatory Commissien, and that the 11 ,
transcript is a true and accurate record of the foregoing r 12 i l proceedings.
13 Date: September 7, 1988 9
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UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY PANEL FOR THE DEC0hTAMINATION OF THREE MILE ISLAND UNIT 2 Agenda for the Septeinber 7,1988 :
Meeting in Harrisburg PA Finutes
- 1. Chairun's Opening Retnarks - A. Morris 5
- 2. Status of Cleanup Activities - GPUN staff 15
- 3. Status of NRC Activities - NRC staff 10
. 4 Results of NRC Review of Licensee's Occupational
? i Exposure Estimates for PDMS - NRC staff 20 -
- 5. CPUN Funding Plan - GPUN staff 15 l
} 6. Public coinrent 20 i
- 7. Break 10
- 8. Panel working session on POMS * - Panel members 60
- Includes pubite participation 1
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O Timer MILE L;LA D ALEMr, MC, U 315 Pef for St. Herrisbury. Penne.17102 (717)23J 7337 s September 7, 1988 TMI A 's COMMENTS TO THE ADVISORY PANEL I would like to begin by taking care of some old business, including a brief review of some events that have taken place this summer at TMI-2. I would also like to take the time to thank the NRC for responding to the rest of TMIA's questions on the staf f 's 'iIS on PDMS. However, I did not receive GFU 's letter addressing the issue of funding as was indicated in the cover letter.
TMIA is resubmitting a request to GPU to reveal the full cost and source of their advertising campaign to promote PDMS.
Let me remind the Panel that several months ago GPU thought
$800,000 was a worthwhile gamble for rate payers to underwrite for the purchase of an evaporator. Moreover, it is estimated
... it will cost $10 million in the first year and S5 million in the subsequent years to keep Unit 2 in monitored storage "
(The Patriot gews, September 2, 1988, B5.) With funding in doubt for a continued cleanup, the public has a right to know how much it is spending to convince it.self that PDMS is the right course of (in) action.
Also, at the last meeting I formally 'ked Mr. Kitner if GPU would comply with an NRC order to continue an immediate cleanup, rather than place Unit-2 in PDMS. TMIA would appreciate a response.
Drawing from GPU and the NRC's actions and observations one gets the distinct impression that the plant has already been placed into post-defueling monitored storage. According to the Plant Status Report for the period of July 9 to August 6, 1988, the staff noted, "One plant ar'ea has been isolated and placed in an interim Post Defueling Monitored Storage (PDMS) status. Seven other plant areas are in the proce's s of being verified to meeting the interim PDMS isolation criteria" (p.2).
This passage facilitates several logistical questions for the NRC and GPU. What are the "interim" PDMS criteria? What are the seven areas that may be placed into "isolation?" Please define "interim" and "isolation." On the surface, this seems like a replay of GPU's decision to purchase, design, fabricate, install and test an evaporator prior to the resolution of the accident-generated, water issue.
As the summer is draw),ng to a close I thought it would be appropriate to draw the Panel's attention to some highlights of the action (or inaction) at tue Irland.
June 9, during a routine inspection "six pages of word puzzles were found in the procedures book (operations procedural manual) at the defueling platform in the RB" (Inspection 50-320/88-10.)
,'- , t July 20, Edwin H. Stier concludsd his investigation on TMI-2 sleeping allegations. "Stier 's f urther investigation into i management response to the allegations revealed inadequacies in management response to the allegations that the shift supervisor slept or was otherwise inattentive to duties. These inadequacies lead to inaccurate or distorted information reported.to higher t levels of TMI-2 and other GPU Nuclear management and to the I Nuclear Regulatory Commission, Stier said" (News Release, GPU Nuclear, Jul.y 20, 1988.)
Joly 26, 1988 "A railcar carrying a loaded shipping cask and its unmanned yard engine drifted for approximately 60 yards on the site tracks. The engine and the railcar came to a final I
rest as a result of an increase in the natural grade of the rails" (August 1988, Status Report.) i August 31, 1988 - A Unit-2 operator was fired after a 11-day j
investigation, including a medical probe, "showed the licensed l operator, who was not identified, had been drinking and taking i drugs either before he reported to work or while he was at work"
( The Patriot News, August 31, 1988, p.B3). Althougn the utility prohibits its workers from reporting to work under the influence
^
of drugs and alcohol, " ... those who have tested positive are t ,
1 not always fired" (Patriot, August 31, 1988.) Refer to June t 15, 1987, for a related incident.
Unfortunately there is Ir. ore then a thread of continuity to these problems. On July 1, 1988, the NRC, GPU nnd the 1 Commonwealth met to discuss "poor human perforirance . . . such as complacency, with respect to the changing plant status leading to post-defueling monitored storage and/or the inf:1uence or poor procedures or work schedules..." (Inspection Report 50-320/88-10, ;
p10.) At the meeting GPU "acknowledged the potential f or apathy l in light of the end of the cleanup project" (p.10) If their apathetic, sleeping, and having trouble following directions now, t
what can we expect in the next 20 to the 30 years when the plant is idle? ,
I Let me now switch to decommissioning, economics and PDMS. At l
)
this point it is clear that PDMS is analogous with l j
decommissioning. GPU recently stated in a press release on August 25, that they are " ... proposing to maintain Unit 2 in safe, 3
monitored storage until it is decommissioned along with TMI-1 l
) sometime in the next century." :
l
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1 Earlier this summer " ... the NRC issued on June 27, 1988, a l 4 final rule on decommissioning which became effective on July 27, !
1988 (Michael Masnik, August 30, 1988.) This new NRC rule has a l 1 direct impact on post-defueling monitored storage, since PDMS is j
little more than a precursor to decommissioning at best, and a j
initial phase at worst, 1
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i Under the section on Decommissioning Alternatives, the NBC noted, ""Delaying completion of decommissioning to allow short q lived nuclides to decay may be justified in some cases, however i any, extended delay would rarely be justifiable" (Federal ;
Register /Vol. 53. No. 126/ Thursday June 30, 1988/ Rules and ,
Regulations, p.24681.) l GPU is asking f or at least a 30 year delay to allow worker exposure rates to diminish. At the last meeting we j witnessed an appreciable dif f erence between the radioactive i levels projected by the NRC and GPU. This is indeed a puzzle
, since GPU supplied the majority of the data for the staff's ,
- Environmental Impact Statement. It seems as if GPU's motto for !
l this project is, "If at first you don 't succeed, lower your I i standards." '
! Who 's to say that GPU or the NRC will not revise their I figures after 20 to 30 years, and ask the community to wait i another 20, 30 or maybe 60 years before finishing the cleanup! An t
expedited cleanup will resolve the lingering questions related to ;
i radiation levels and locations, and allow GPU to make good on their promise to clean Unit-2 up. Ws agree with the NRC that " i i
case, 20 to 30 years is not justifiedt !
l Under the section on Planning, the NRC noted, "Planning for decommissioning is a critical item for ensuring that the }
decommissioning activities can be accomplished in a safe and a ,
timely manner" (p.24681.) '
i Yet for PDMS, the NRC does not stipulate any research or
] development be employed to ensures that the cleanup can precede at a later date. In fact, the NRC acknowledges "Development of l
, detailed plans at the application stage is not possible because ;
many factors (e.g., technology, regulatory requjrements, economics) will change before the license period ends" (p.24681.) ,
Thus PDMS allows GPU the luxury of cutting costs, laying off experienced workers and postponing cleanup, until.a time in the !
distant future when, in their judgement, it will be "safe and i
timely" to resume the cleanup.*To date, GPU and the NRC have l failed to provide data the demonstrates that any research j and development will take place during the layoff. It is clear !
that GPU and the NRC have adopted former NRC Chairman Hendrie 's
) infamous policy, "Don't turn over new rocks." ;
i j
i Under the section on Residual Radioactivity Levels, "The l r
i cost estimate for decommissioning can be based on current l criteria and guidance on regarding residual radioactivity levels ;
for unrestricted use...the cost of decommissioning is relatively '
1 insensitive to the radioactivity level and use of cost data based on current criteria should provide a reasonable estimate...it is
} expected that the decommissioning fund available at the end of l facility life will approximate closely the actual cost of ;
j decommissioning" (p.24681.) l i ,
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Already there ils a disparity betwecn GPU's estimato f or decommissioning and the NRC's generic projections. All one needs to do is consult GPU's latest shareholder report to be updated on the economics of decommissioning. GPU acknowledges that there is no money in the Unit-2 decommissioning f und, and the money put
' aside for TMI-1 may be inadequate. GPU 's estimate for decommissioning costs is millions 'of dollars above the NRC's generic estimate. Once again, GPU fails to supply data on how they are planning to meet this shortfall. I would suggest that the publisher of that newsletter be invited to the next Advisory Panel meeting. Perhaps then we can get some information on funding packages for the continued cleanup and decommissioning of i
Three Mile Island.
. TMIA believes that the Panel should recommend to the NRC that the the cleanup of TMI-2 proceed immediately. GPU should be liable for costs and develop appropriate technologies. In addition, GPU should develop a funding plan based on equitability and realism to be reviewed by the Public Utility Commission, the Consumer Advocate, the Commonwealth of Pennsylvania and citizens.
4 I really don't know what else I can say that would truly '
affect you people. The last time I was here I spent a lot of time i researching and talking to competent, well-versed people in the fields of economics and decommissioning. One panel member l questioned my credentials; which is your privilege. Let me remind you that we're all citizens with rights and responsibilities. The federal, state and local governments provide public document
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rooms, libraries, research material, and if necessary, one can also utilize the Freedom of Information Act to obtain information. The data our organization presents at these meetings is documented. In addition, we have no financial stake in the matters before you.
Let me close by saying that I think the case against PDMS is clear and overwhelming. However, as I look around, I 'm reminded of what George Orwell once said, "Peopic can forsee the future j
only when it coincides with their own wishes, and the most grossly obvious facts can be' ignored when they are unwelcome.,"
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' ROBERT Q. MARSTON MD f R.... ei. na #^ '
- Ai o.. . ruan l RECENEG Jti' 2 7 og ,
1 i
- July 25,1988 ;
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- Mr. Arthur E. b rrO an i
' NCR Advisorv Pruel o
- of TMI 2 l P.O. Box 15s$
120 N. Duke kru; j Lancaste PA
' t I ;
- Subjeer J_inutes of TMI.2 Safety Adviserv Board !
I Dear Mayor Mort I You made a request of me on July 14, 1988, at the NCR Advisory l l Panel meeting, to present some evidence that the TMI.2 Safety '
J Advisory Board had discussed the issue of funding for the i f, decom:sissioning of TMI.2 in the Board's review of PDMS. The SAB i had intermittently reviewed the safety of the PDMS phase for ,
i more than two years. However,'the providing of funds for TMI.2 1 decom:sissioning was not considered to be a safety matter and, i therefore, only brief recognition was given to the funding 1
requirement in the Board's discussions of PDMS. As a result, l
! the minutes of our meetings do not reflect the mentioning of i such a funding requirement but rather dwell on the safety i j aspects of PDMS. i
' l Although I cannot provide you written evidence of SAB discussions on the necessity for CPUNC to provide funds for !
, TMI.2 decommissioning, I itssure you that the SAB has been aware 1
of such a funding requiressent for some time, t
l Yours truly, !
r l
3
- M Dr. Robert Q'. Marston, Chairman / \a j TMI.2 Safety Advisory Board i l J l l
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j I I l 1 !
6
adstaf Q. MARSTON MD geen si, ses tea ,
Alacbee FL 32419 l
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i July 25, 1988 i l
2 ,
f .-
1 i l Mr. Arthur E. Morris, Chairman I i NRC Advisory Panel on Clean up of TMI.2 ]
l P.O. Box 1599 !
! 120 N. Duke Street :
j 1.ancaster PA 17603 (
i '
Dear Mayor Morris,
I appreciate your handling of the NRC Advisory Panel, permitting ;
j citizens to freely express divergent opinions, and recogniza j that you cannot-control the statements made at these meetings. .
! I must protest, however, the flagrant character defamation of a [
f member of ths TMI.2 Safety Advisory Board. Specifically, it was ,
stated that WASH.1400, Reactor Safety Study.An Assessment of l
4 Accident Risks in U.S. Commercial Nuclear Power Plants Oct.
{ 1975, the principal author of which is Prof. Norman C. !
j Rasmussen, a member of the SAS, had been completely i d
discredited. In my judgement, the statement also inferred a -
j
! similar discrediting of Prof. Rasmussen. )
l
) I must set the record straight and point out to you that Prof. j j Rasmussen received the prestigious Fermi award two years ago ;
j honoring him es one of the outstanding nuclear scientists in the l l United States and in the world. The award specifically stated: ;
I l "This award is given for exceptional and altogether i outstanding scientific and technical achievement in the development, use or control of atomic energy. More ,
l specifically, this award is in recognition of his primary l 1
contributions to nuclear energy and the development of !
probabilistic risk assessment techniques that have provided l new insights and led to new developments in nuclear power !
g plant safety." l 1 !
\
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- Mr. Arthur E. Morris, Chairman NRC Advisory Penel on Clocn up of TMI 2 Page 2
/
i Further, the statement regarding the discrediting of WASH 1400 i failed to recognize that the analytical methods presented in the !
i document have become the basis for current nuclear plant l probabilistic risk assessment calculations. Although some of 3
the assumptions made in WASH 1400 have changed with the ,
availability of additional experimental information (the ,
assumptions are now generally less conservative), the report
! prepared by Prof. Rasmussen and his co. workers remains a j valuable and useful analytical tool for the nuclear industry.
I Far from being discredited, VASH.1400 continues to be regarded j as the outstanding risk document for nuclear power plants in the
- United States. ;
il 5 f
, . l j Yours truly, l )
j r . Tob e rt-Q.
h =Q / f arston, Chairman %
1 TMI.2 Safety Advisory Board ,
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Mouis 441 South MI6dletown, Pennsylvania 17067 0191 717 S44 7821 TELEX 84 2306 Writer's Direct Dial Numtwr; (717) 948-8461 August 5, 1988 4410-88-L-0117/0402P US No: lear Regulatory Comission Attn: Docur'ent Control Desk Washington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Statien, Unit 2 (TMI-2)
Operating License No. CPR-73 Docket No. 50-320 Funding For Decovissioning of THI-2 Following Post-Defueling Monitored Storage This letter is in response to ovestions concerning funding for decomissionin; THI-2 raised Dy NRO Staf f following the meeting of the WC's Advisory Panel for the Decontamination of TMI-2 in Harrisburg, PA on Aly 14, 1989.
A -2 is a licensed reactor plant which mJst, by law, conform to Nuclear Regulatory regulations and orders. The PC has puolished a Rule, "General Reovirerrents for Decomissicaing Nuclear Facilities," which reoJires licensees to sutnit ey N1y 1990 a report containing plans for decomissioning all licensed reactor plants. Tnis re,, ort must contain licensee's plans for funding cecomissioning and certify that adeouate funds will be availaole for decomissioning, such funds to be kept separate from other comany assets ard outside the company's actinistrative control. G'u Maclear uncerstands that the Rule applies to TMI-2 and would cover all activitler inwalved in the 1kcomissioning the plant starting from Post-Defueling Monitored Storage (PCHS) corditions. CPU Nuclear will, of course, atdde by that Rule and provide the reoaired plan and certification for TKI-2 by 11y 1990.
We believe that intent is fully responsive to the reovirenents of the Decomissioning Rule. It would be helpful if the 20 representatives would confirm the applicability cf the Rule to TMI.2 during the next meeting of the Advisory Panel.
Sincerely,
- /s/ E. E. Kintner E. E. Kintner Executive Vice President t
GPU Nuclear Corporation b a subsidiary of the General Public Utilities Corporation
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' ~~ ' L . . ?) 9 GPU Nucleet Corporation y gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELF.X 84 2386 Writer's Direct Dial Nurnber:
(717) 94B-8461 August 5, 1988 4410-88-L-Oll7/0402P US Nuclear Regulatory Comission Attn: Document Control Desk tashington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. OPR-73 Docket No.53-320 Funding For Oecomissioning of TMI-2 Following Post-Defueling Monitored Storage This letter is in response to cuestions concerning funding for deccmissioning TMI-2 raised by NRC Staff following the meeting of the NRC's Advistry Panel
'or the Decontanination of TMI-2 in HarrisDurg, PA on July 14, 1985.
TMI-2 is a licensed reactor plant which must, Dy law, conform to Nuclear Tcgulatory regulations and orders. The NRC 'nas puDlished a Rule,
- General Reevirenents foi Deco rissioning Nuclear Facilities," wnich requires licensees to submit by July 1990 a report containing plans for decomissioning all licensed reactor plants. Tnis report must contain licensee's plans for funding ditcomissioning and certify that adeouate funds will be availaole for decomissioning, such funds to te kept separate from other company assets and outside tre company's administrative control. GPU Nuclear understands tnat tne Pule applies to TMI-2 and would cover all activities involved in the d:comissioning the plant starting from Post-Defueling Honitored Storage (FOv5) concitions. GPU Nuclear will, of course, abide by that Rule and provide the reovired plan and certification for THI-2 cy 11y 1990.
ke believe that intent is fully responsive to the requirements of the Decomisbioning Rule. It would be helpful if the NRO representatives would confirm the applicability of the Rule to TMI-2 during the next meeting of the Advisory Panel.
Sincerely,
/s/ E. E. Kintner E. E. Kintner Executive Vice President emf GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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', ChumentControlOesk August 5,1988
! , 4410-69-L-0117 ,
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- Senior Resj hnt Inspector, TMI - R. J. Conte !
- Regional Administrator, Region 1 - W. T. Russell '
Director, Plant Directorate IV - J. F. Stoir Systems Engineer, TMI Site - L. H. Thonus [
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News Roloase Thrce Mlle !sland Nuclear Station QQ gg Post Oftce Box 480 P' Tetown, PA 17057
. 948 8197 Public Information Services For Further informa9en Doug Bedell Contact.
Imediately September 1,1988 For Re! ease Date (28-88N ROCHE NAMED DIRECTOR OF TMI-2 Middletown, PA -- Michael E. Roche has been named Vice President and Director, Three Mile Island l'nf t 2, effective in early October, Philip R.
Clark, President and Chief Executive Office of the GPU Nuclear Corporation announced today.
Roche, who is currently Vice President and Director cf Radiological and Environmental Controls for GPU Nuclear, will succeed Franklin R. Standerfer, who resigned for personal reasons, effective in early October.
Roche, in his current capacity, is responsible for all radiological, environmental, health and safety programs, as well as emergency preparedness i throughout the. corporation. He Joined the GPU System in 1974 as an environmental scientist for Jersey Central Power a Light Company. In 1980 he came to GPU Nuclear as Manager of Environmental Controls and later served as !
1 Deputy Director of the Radiological and Envirornental Controls Division n as I Deputy Director of the Maintenance, Construction and Facilities Division. He is also Vice President of the Saxton Nuclear Experimental Corporation, responsible for decontamination, dismantlement and eventual decomissioning of a small GPU System nuclear power station in Bedford Township, Pa.
Standerfer joined GPU Nuclear in July 1984 from the U.S. Department of i Energy and assumed his duties at TN!-2 in August 1984 During his tenure, substantial progress was made in the cleanup program. Defueling began under j
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September * , t*38
. . d28-88N I
i substantial progress was made in the cleanup program. Defueling began under Standerfer and today more than two-thirds of the damaged fuel has been removed from the Unit 2 reactor vessel. More than 191,000 pounds of core debris has been shipped to the Idaho National Engineering Laboratory. Tooling development for defueling was successfully accomplished. Post Defueling Monitored Storage (PDMS) was defined and a detailed safety evaluation of PDMS was completed and submitted for NRC review. Decontaminatien of the reactor and auxiliary buildings has been brought significantly towards completion.
In submitting his resignation, Standerfer said, 'My personal plans have been based on a schedule which had the cleanup of TMI-2 completed in the fall of 1988. I am satisfied that the project is in its final stage and l1 i disappointed that my plans will not allow me to stay on until the end. I am I
particularly proud of the highly shilled and dedicated people who fonn the
- TMI-2 project team."
In accepting Standerfer's resignation, Clart expressed his appreciation I to Standerfer for his major contributions to the cleanup program. "I deeply l appreciate the effort that Frank Standerfer devoted to the TMI-2 cleanup program during his four year tenure with us. His unique expertise and '
, leadership has brought us well within reach of the end of the cleanup program," Clark said.
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DISTRIBUTION LIST FOR MATERIAL TO THE ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND UNIT 2 Chainnan Zech 16 H 3 Comissioner Roberts 16 H 3 Rogers 16 H 3 Comissioner Bernthal 16 H 3 Comissioner 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, THI-PIRC Docket File 50-320 016 1037 Maclay Street PDR 016 % rrisburg, PA 17103 LPDR 016 DCS 016 Mr. Edward Charles F. Miraglia 12 G 18 90 Nittany Drive S. Varga 14 E 4 Mechanicsburg, FA 17055 B. Boger 14 A 2 J. Stolz 13 H 3 Mr. John H. Murdoch L. Thonus TMI Site Mail Pouen 44 Kensington Drive R. Conte TMI Site Mail Pouch Camp Hill, PA 17011 L. H. Bettenhausen RGN-1 Director TM! Alert c/o Kay Pickering Power Plant Research Program 315 Peffer Street Department of Natural Recources Harrisburg, PA 17102 Tawes Building B-2 l
Annaplois, MD 21401 Dr. Frank Parker School of Engineering Ms. Ruth Gentle Nashville, TN 37203 1 Virginia Circle Mechanicsburg, PA 17055 Mr. Dave Janes Analysis and Support Division Susquehanna Valley Alliance U.S. Environmental Protection Angency P.O. Box 1012 Washington, D.C. 20640 Lancaster, PA 17604 Mr. E. E. Kintner Dr. Sid Langer Executive Vice President P.O. Box 1625 General Public Utilities Idaho Falls, ID 83415 Nuclear Corp.
100 Interpace Parkway Mr. Kenneth L. Miller, Director Parsippany, NJ 07054 Division of Health Physics and Associate Professor of Radiology Milton S. Herstey Medical Center Pennsylvania State University Ht:rshey, PA 17033 go\
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Mr. Bob Leyse Dr. John luetzelschwab ;
EPRI-NSAC Professor Physics 1 3412 Hillview Avenue Dickinson College Palo Alto, CA 94303 Carlisle, PA 17013-2896 Mr. David J. McGoff Mr. Thomas Gerusky, Director U.S. Departinent of Energy Bureau of Radiation Protection A-439GTN Dept. of Environmental Resources Washington, 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. Box 480 York, PA 17404 Middletown, PA 17057 Niel Vald, M.D.
The Honorable Arthur E. Morris Professor 3nd 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 Robinson Mr. 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 Detjen Dr. Henry Wagner Philadiphia Inquirer Johns Hopkins School of Hygiene 400 N. Broad Street 615 N. Wolfe Street Philiadelphi PA 19101 Room 2001 Baltimore, MC 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. LLslie 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 i
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Joyce Corradi Marjorie and Norman Aarrodt l Concerned Mothers and Wornen 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. 183 Valley Rd.
Lancaster, PA 17603 Etters, PA 17319 Mr. Ad Crable Pepper, Hamilton and Sheets Lancaster New Era P.O. Box 1181 8 F. 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 Comission 2500 N. Charles Street Washington. 0.C. 20555 Baltimore, MD 21218 US Environmental Prot. Agency Debra Davenport Region III Office 1802 Market Street ATTIN: EIS Coordinator Camp Hil., PA 17011 Curtis Building (Sixth Floor) 6th and Walnut Streets Robert L. Vree Philadelphia, PA 19106 80x 72 Middletown, PA 17 N Rep. Alan Kuk',vich House of Representatives Mrs. Ann inank Harrisburg, PA 17101 143 Race Street Middletown, PA 17057 Ms. Mary Osborn 4951 Highland Mr. Thomas D. Smithgall Swatara, PA 17111 1030 Woods Avenue Lancast,ir, PA 17603-3127 Dr. B. J. Snyder Mr. John W. Crawford, Jr.
EMCP 11405 Fanaland DR.
11005 Hunt Club Dr. Rockville, MD 20852 Potomac, MD 20854 l
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