ML20235A861

Amends to Suppl to Petition for Leave to Intervene for Susquehanna Valley Alliance (Sva) & TMI Alert (Tmia).* Contentions Listed

ML20235A861
Person / Time
Site:	Three Mile Island
Issue date:	11/20/1987
From:	Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20235A860	List: ML20235A857 ML20235A861
References
87-554-04-OLA, 87-554-4-OLA, OLA, NUDOCS 8801130193
Download: ML20235A861 (7)

Text

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5 Order, the Board will set forth the due dates for the filing of summary disposition motions and answers, or will schedule a hearing.

THE ATOMIC SAFETY AND LICENSING BOARD

\

Sheldon J. Wo}4fe, Chairnian M

ADMINISTRATIVE' JUDGE l

M '

W\

l Oscar H. Paris l ADMINISTRATIVE JUDGE i

m 0, I u

r C Glenn O. Bright ADMINISTRATIVE JUDGE Dated at Bethesda, Maryland this 5th day of January, 1988.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COtti!SSION ATOMIC SAFETY AND LICENSING BOARD i

Bef ore Admi n i stra t i ve Judoes Sheldon J. Wolfe, Chairman Oscar H. Paris Glenn D. Bright f

In the Matter of Docket Nos. 50-320-OLA (Disposal of Accident-GENERAL PUBLIC UTILITIES NUCLEAR Generated Water)

CORPORATION, d d.

(Three Unit 2)

Mile Island Nuclear Station, (ASLBP No. 87-554-04-OLA)

November 20, 1987 Amendments to Sucolement to the Petition l for Leave to Intervene for Susouthanna Valley Alliance (SVA) and Three Mile Island Alert (TMIA)

Fol l owi ng i s a l i s t of Con t en t i on s:

k 1. Neither the Licensee nor the Nuclear l

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I Regulatory Commission has shown that the disposal of the '

accident generated water by an evaporation method complies g

with the A.L.A.R.A. principle (as low as reasonably

' achievable). Other methods of water disposal discussed in

! the Environmental Impact Statement (EIS) (NUREG 0603 l

Supplement N2, June 1987) would not release all the tritium and a quantity of radionuclides into the environment as the evaporation method would. g NDY 2 4 St

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2. The EIS f alls to comply wi th the requirements {

4332, n of the National Environmental Policy Ac t (42 USCS 29). The NRC and GPU failed to conduct conclusive

• ri sk/benef i t analysis of the 'No Ac t i on Al ternat ive." The EIS has not clearly demonstrated that any adverse impact I

from the disposal program are outweighed by its benefits to  :

i the public. The benefits have not been clarified except the NRC says disposal is a fundamental element of the clean-up.

This would appear to be a benefi t to the Licensee and the ,

i t

-s NRC, but not to the public. The benefits of whether or not 1 i

j to dispose the water can only be analysed f ollowing the I evaluation of the Licensee's plan for " Post Defueling i

Monitored Storage."

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3. The EIS f ails to comply wi th the requirements l t of the National Environmental Policy Act. The EIS has not demonstrated that the benefits of the evaporation process 1 t

will exceed the costs and risks to the public. The benefi ts  ;

are unclear whereas the risks include the followings  :

a. The release of radioactivity into the air will enter the water, food chain, human organisms and the entire ecosystem.

b. A solidified waste of possibly 88,000 cubic feet will be created. This waste will have to be trucked to a low level waste site.

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4. No credible scientific evidence has been presented to demonstrate that the evaporator, operating in an open cycle mode, can te assured not ,+,o break dowa more then 25% of the time, as guaranteed by the vendor. There is no assurance that the 2.3 million gallons of radioactive a

water can be evaporated eff ectively and efficiently within a

_g time period which will provide reasonable protection to the p

pubile.

I Sufficient evidence has not been provided to i ensure that the evaporator can filter out transuranic, other radionuclides as well as chemicals to protect the h pubile heal th and saf ety.

The evaporator's monitoring and safety i systems have not been shown to provide the safeguards needed i

to protect the public health'and safety when the evaporator

$ operates in an open cycle mode.

It has not been demonstrated that the

> influent to the evaporator may be varied from 3 gallon / minute to 20 gallon / minute wi thout the heal th and saftey of the public being Jeopardized.

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' Page four l 5. The National Environmental Policy Act (42 USCS Section 4332, n 29) states

" Purposes intended to be served by detailed env iccnmen t al impact statement is to provide decision-makers wi th environmental disclosures suf ficiently detailed to aid in substantive decision whether to proceed with projects in l light of its environmental consequences....

The NRC staf f has violated Section 4332 of NEPA by not sufficiently inf orming the public as required by law.

I NEPA states: " Purposes served by environmental impact I

statement include...(2) tool of environmental fuit

! disclosure by providing information to public about environmental costs i nvolved in par t i cul ar proj ec t . . ."

Neither the Licensee nor. the NRC have provided detailed nor accurate information to demonstrate that i evaporation will protect the public heal th and safety in j j i compliance with the Atomic Energy Act, or the National Environmental Pol i cy Act f or the f ollowing reasons:

a. Dr. Karl Z. Morgan chairman of the Internal i

j Dose Committees of both ICRP and NCRP for two decades and who has researched ionizing radiation and health physics for over 50 years has shown that the calculations done by the NRC and GPU are not correct. On commenting on GPU Nuclear's

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Page five oroposal of July, 1996 to dispose of the water, and the NRC staff's EIS (June 1987), Dr. Morgan has stated for the record, "the studies made by GPU and the NRC staff are woefully inadequate and much more data should be provided i

before deciding the best way to be rid 4f this problem."

F (Comment on the EIS, June, 1987.)

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! b. They have ignored the cumulative effects of the acc i den t and the cl ean-up . For instance, there is a great 6

controversy as to how much radiation escaped during the t accident and the subsequent eight and one half year I clean-up.

c. They have grossly s,impilfled the radi ol ogi c al and chemical content of the water and 1

underestimated the ef fects upon the population. This very water has covered the mel ted fuel rods during and af ter the -

j core had reached 5,100 degrees Fahrenheit. Neither the I

Licensee nor the NRC have analyzed the health effects of the e

i synergistic effect of all the radioisotopes and All the chemicals present in the water.

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d. They have underestimated the ef f ects of tritium and alpha emitting radionuclides on human beings.

The alpha emitters such as plutonium 238 and other I transuranic elements which are present in the water wers i

a virtually ignored in the 1987 EIS. They were not examined f or their chemical and biological characteristics in spite of their well-known toxicity.

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' 4. An amendment to the license is premature because this water is presently covering the melted fuel, L

which mel ted at 5,100 degrees Fahrenhei t, and will be cased g

In decontamination activities with the potential f or the j addition of more chemicals. The Licensee has added more chemicals since the submi ttat e ! its proposal in July, 1986.

The effects of these chemicals on the capabili ties of the I

Epicor !!, SDS and evaporator systems must be evaluated.

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7. The off-site monitoring studies which have g

been undertaken by Dr. Ruth Patrick and Bernd Franke could prove valuable in determining the adequacy of the monitoring for the disposal of the radioactive water. It is prudent, therefore, to await this additional information for the sake of the public's health and safety.

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I-Page seven a

f W. The NRC failed to give reasonable and due the I consideration to evaporation in a closed cycle with L

bottoses and condensate being solidified and shipped to a Low Level Waste Site. They also f ailed to give reasonable consideration to disposing the water in tanks and storing it

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r inside Unit Two.

5 Frances Skolnick Repr esen tat ive f or SVA and TMI A r

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