ML19254F304: Difference between revisions

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co    os NRC PUBLIC DOCIDIENT ROOM                                            4 S
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NRC PUBLIC DOCIDIENT ROOM                                            4 S
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         ]D                #T Lb UNITED STATES OF AMERICA mNUCLEAR REGULATORY CCMMISSION 4      M+        /!
         ]D                #T Lb UNITED STATES OF AMERICA mNUCLEAR REGULATORY CCMMISSION 4      M+        /!
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In the Matter cf                                )
In the Matter cf                                )
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REVISED CONTENTIONS OF THREE MILE ISLAND ALERT INC .
REVISED CONTENTIONS OF THREE MILE ISLAND ALERT INC .
Pursuant to the Board's Memorandum and Order dated September 21, 1979, intervenors were directed to file revised contentions by October 22,1979.
Pursuant to the Board's Memorandum and Order dated September 21, 1979, intervenors were directed to file revised contentions by October 22,1979.
        .
Accordingly, Three Mile Island Alert Inc. (TMIA) files the following contentions.
Accordingly, Three Mile Island Alert Inc. (TMIA) files the following contentions.
REVISED CONTENTION 1.
REVISED CONTENTION 1.
It is contended that the short ters actions proposed by the licensee wG nct adequately protect the members of TMIA, whose tambers live within twenty (20) miles of the Mant, from abnormal and unhealthy additional releases cf radiation.
It is contended that the short ters actions proposed by the licensee wG nct adequately protect the members of TMIA, whose tambers live within twenty (20) miles of the Mant, from abnormal and unhealthy additional releases cf radiation.
As a result cf the accident at TMIUnit #2,      radicactive gases in excess of permissible limits were released into the atmosphere. These releases incitt.ed:
As a result cf the accident at TMIUnit #2,      radicactive gases in excess of permissible limits were released into the atmosphere. These releases incitt.ed:
(a) I-133, which was released cver a thirty-fcur (34) day period following the accident in a*.aounts in excess cf 26.84 Ci; (b) Krypton-88, which, during the first day cf the accident alone, was discharged into the atmosphere in an amount cf 6.lE + 4 Curies; 1302 ?21
(a) I-133, which was released cver a thirty-fcur (34) day period following the accident in a*.aounts in excess cf 26.84 Ci; (b) Krypton-88, which, during the first day cf the accident alone, was discharged into the atmosphere in an amount cf 6.lE + 4 Curies; 1302 ?21 7911000C
                  .
7911000C
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                                                                                              .
(c) Xenon releases cf at least 10 million Curies, far in excess of NRC regulations. For mple:                                          0                        r D    g[D9  P  l i      y    LU ij (1) Xenon 133M: 170,000 Curies over a ten day period                  ul  t  L, (ii) Xenon 135: 1.5 million Curies over a seven (7) day pericd (iii) Xenon 135M: 140,000 Curdes over a three (3) day period Other radioactive gases released as a result cf the accident at Unit #2 include Rutheniuim - 103, - 106; Tritium; and Bremine -82, -83, -84, -85.
:
                                                                                                ,
(c) Xenon releases cf at least 10 million Curies, far in excess of NRC regulations. For mple:                                          0                        r
                                                                    ''
D    g[D9  P  l i      y    LU ij (1) Xenon 133M: 170,000 Curies over a ten day period                  ul  t  L, (ii) Xenon 135: 1.5 million Curies over a seven (7) day pericd (iii) Xenon 135M: 140,000 Curdes over a three (3) day period Other radioactive gases released as a result cf the accident at Unit #2 include Rutheniuim - 103, - 106; Tritium; and Bremine -82, -83, -84, -85.
These releases will have Icnq term health effects on ther members of TMIA.
These releases will have Icnq term health effects on ther members of TMIA.
If TMI Unit #1 were to be recpened, the adverse health effects to the members of TMIA would be magnified since Unit #1 will release additional amcunts cf radiation into the environment. Since radiation affects the bcdy in a cumulative manner, the additional releases frem Unit #1 will have a direct adverse health effect on
If TMI Unit #1 were to be recpened, the adverse health effects to the members of TMIA would be magnified since Unit #1 will release additional amcunts cf radiation into the environment. Since radiation affects the bcdy in a cumulative manner, the additional releases frem Unit #1 will have a direct adverse health effect on the members cf TMIA.
                              -
the members cf TMIA.
In addition,' the cleanup cf Unit #2 will undcubtedly result in both planned and unplanned discharges of radiation into the environment. Since the members cf TMIA have already received desages cf radiation far in excess cf that which would have been received had there been no accident,the cumulative effect as described above may ultimately cause sickness ar d death to scme members of TMIA.
In addition,' the cleanup cf Unit #2 will undcubtedly result in both planned and unplanned discharges of radiation into the environment. Since the members cf TMIA have already received desages cf radiation far in excess cf that which would have been received had there been no accident,the cumulative effect as described above may ultimately cause sickness ar d death to scme members of TMIA.
It is contended that the short term acticns proposed by licensee do not adequately deal with this problem.
It is contended that the short term acticns proposed by licensee do not adequately deal with this problem.
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                                                                                      .
b REVISED CONTENTION 2.
                      -
TMIA contends that the additional low-level radiological discharges from Unit #1, in addition to these high-level discharges that have and will be discharged as a result of the TML accident, will have a sigr* ant adverse effect on the water quality in the Susquehanna. During decontaminatien, there exists the real possibility of discharges of radicactive wastewater into the Susquehanna. Even if decontamination is done acccrding to present plan, the system, Epicere II, cannet recove radicactive tritium frem the decentaminated water. This tritium will be discharged into the Susquehanna River. If Unit #1 were to reopen while decentamination cf Unit #2 was continuing, additional discharges of radiation into the Susquehanna will occur. Radioactive releases into the river as a result of the accident at TMI #2, have resulted in presently ascertainable damage to the fish and wildlife in and around the river, thereby increasing the probability of radiation in the feed chain. Therefore, it is contended that no consideration be given to reopening Unit #1 until 'I?.fI Unit #2 is decontaminated to pre-March 23, 1979, levels, and the effects cf the accident and subsequent decontaminaticn on the water quality in the river have been thoroughly analy::ed.
b
                                                  ,
REVISED CONTENTION 2.
TMIA contends that the additional low-level radiological discharges from Unit #1, in addition to these high-level discharges that have and will be discharged as a result of the TML accident, will have a sigr* ant adverse effect on the water quality in the Susquehanna. During decontaminatien, there exists the real possibility of discharges of radicactive wastewater into the Susquehanna. Even if decontamination is done acccrding to present plan, the system, Epicere II, cannet recove radicactive tritium frem the decentaminated water. This tritium will be discharged into the Susquehanna River. If Unit #1 were to reopen while decentamination cf Unit #2 was continuing, additional discharges of radiation into the Susquehanna will occur. Radioactive releases into the river as a result of the accident at TMI #2, have resulted in presently
                              .
ascertainable damage to the fish and wildlife in and around the river, thereby increasing the probability of radiation in the feed chain. Therefore, it is contended that no consideration be given to reopening Unit #1 until 'I?.fI Unit #2 is decontaminated to pre-March 23, 1979, levels, and the effects cf the accident and subsequent decontaminaticn on the water quality in the river have been thoroughly analy::ed.
REVISED CONTENTION 3.
REVISED CONTENTION 3.
It is contended that if Unit #1 is reopened, fear cf another Unit #2 type accident will cause mental health problems, in varying degrees, to many pecple living near the plant. This fear will also adversely affect the ecenemy cf the region because empicyees will be absent from work due to mental anxiety, pecple
It is contended that if Unit #1 is reopened, fear cf another Unit #2 type accident will cause mental health problems, in varying degrees, to many pecple living near the plant. This fear will also adversely affect the ecenemy cf the region because empicyees will be absent from work due to mental anxiety, pecple 1302 526
.
1302 526


                                                                                      ,
willleave thee jobs and =cve from the area, and new businesses will refuse to locate in the area. It is contended, therefore that the health and economic consequences brought about by the fear and anxiety which wi!!
willleave thee jobs and =cve from the area, and new businesses will refuse to locate in the area. It is contended, therefore that the health and economic consequences brought about by the fear and anxiety which wi!!
cccur, and increase, if Unit #1 is reopened, cutweigh the benefits that will be obtained thereby.
cccur, and increase, if Unit #1 is reopened, cutweigh the benefits that will be obtained thereby.
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797 002      e 1
797 002      e 1
m
m
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w      b..        .=a
w      b..        .=a REVISED CONTENTION 5.
,
REVISED CONTENTION 5.
It is contended that Met-Ed has negligently. and on occasion, willfully viciated NRC regulations concerning the safe operaticn cf both Units #1 and #2, in that it has deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment cf the integrity of the nuchar facility itself. The licensee has, in the past, allowed work orders to go undene in order to avoid shutting Unit A down to perform necessary maintenance. The licensee would allcw werk crders to pile up unul refueling, at which time Se licensee wculd attempt to do all the work required.          Just to ccmplete essential maintenance in the short time available, employees were worked to a point where they were no longer effective because cf fatigue. These actions, and actions cf this t'ipe, reflect negatively upon the ability of the licensee to safely operate c nuclear facility.
It is contended that Met-Ed has negligently. and on occasion, willfully viciated NRC regulations concerning the safe operaticn cf both Units #1 and #2, in that it has deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment cf the integrity of the nuchar facility itself. The licensee has, in the past, allowed work orders to go undene in order to avoid shutting Unit A down to perform necessary maintenance. The licensee would allcw werk crders to pile up unul refueling, at which time Se licensee wculd attempt to do all the work required.          Just to ccmplete essential maintenance in the short time available, employees were worked to a point where they were no longer effective because cf fatigue. These actions, and actions cf this t'ipe, reflect negatively upon the ability of the licensee to safely operate c nuclear facility.
Ccnsequently, it is centended that Met-Ed is incapable of safely operating TMI A and that its operating license should be reveked permanently.
Ccnsequently, it is centended that Met-Ed is incapable of safely operating TMI A and that its operating license should be reveked permanently.
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(1) comply with technical changes that may be demanded as a result cf the accident at Unit 42, and (2) comply with requiations cf the NRC requiring the expenditure of additional sums cf =cney either fcr mandated design changes or changes in the financial protecticn requirements of ICCFR Part 140.
(1) comply with technical changes that may be demanded as a result cf the accident at Unit 42, and (2) comply with requiations cf the NRC requiring the expenditure of additional sums cf =cney either fcr mandated design changes or changes in the financial protecticn requirements of ICCFR Part 140.
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1302 52'i
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D D^]f oo          %]N@h_$~
D D^]f oo          %]N@h_$~
6th          nk, Because cf the I!censee's problems with Unit #2, it has been unable to meet its energy obligations to the PD1 interconnect. As a consequence, the licensee's deferred energy balance owed PIM may very well exceed its t'ert term debt by February,1980. If this occurs, the licensee's ability to borrow money will cease, and thereis the real possibility cf the licensee going bankrupt. It is centended, therefore, that the licensee does not presently, or for the foreseeable future, have the financial requirements necessary to operate a nucicar facility.
6th          nk, Because cf the I!censee's problems with Unit #2, it has been unable to meet its energy obligations to the PD1 interconnect. As a consequence, the licensee's deferred energy balance owed PIM may very well exceed its t'ert term debt by February,1980. If this occurs, the licensee's ability to borrow money will cease, and thereis the real possibility cf the licensee going bankrupt. It is centended, therefore, that the licensee does not presently, or for the foreseeable future, have the financial requirements necessary to operate a nucicar facility.
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It is contended that the licensee will be unable to adequately deal with a design basis accident cf class one through eight if one should cccur at Unit # 1      while decentamination continues at Unit #2.        The Unit #2 containment building and vessel today hcuse in excess cf half a million gallens of highly contaminated wastewatir, and another 250,000 gallons are stored in auxiliary storage buildings on the island. Presently, there is no approved timetable for the safe decontamination of Unit #2.      It is centended that the wastewater storage capability cf Unit 4          if an accident were to occur, wculd be insufficient ,  since a large portion cf this capacity may ult' anately be ccmmitted to the safe decontaminaticn cf U:3t #2.        Furthermore, even if no accident should cccur at Unit #1      there is a possibility of an accident cccurring at Unit
It is contended that the licensee will be unable to adequately deal with a design basis accident cf class one through eight if one should cccur at Unit # 1      while decentamination continues at Unit #2.        The Unit #2 containment building and vessel today hcuse in excess cf half a million gallens of highly contaminated wastewatir, and another 250,000 gallons are stored in auxiliary storage buildings on the island. Presently, there is no approved timetable for the safe decontamination of Unit #2.      It is centended that the wastewater storage capability cf Unit 4          if an accident were to occur, wculd be insufficient ,  since a large portion cf this capacity may ult' anately be ccmmitted to the safe decontaminaticn cf U:3t #2.        Furthermore, even if no accident should cccur at Unit #1      there is a possibility of an accident cccurring at Unit
     #2      during decontamination which wculd result in the diversicn of all Unit #1 storage capacity to U-it #2,    thereby leaving Unit a        unable to cope with any 1302 329
     #2      during decontamination which wculd result in the diversicn of all Unit #1 storage capacity to U-it #2,    thereby leaving Unit a        unable to cope with any 1302 329
                                        .


                                                                                          .
  ..
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type of accident that would produce abnormal an.mnts cf radicactive wastewater.
type of accident that would produce abnormal an.mnts cf radicactive wastewater.
If an accident of the magninide of that which occurred at Unit #2 were to occur at Unit #1, wastewater stcrage facilities at Unit #2 wculd have to be borrowed, just as Unit #1 facilities have been borrowed to deal with the accident at Unit #2. Since there is presently insufficient storage capacity on the island to deal with a Unit #2 accident at Unit #1 it is an unreasonable and unacceptable risk to the public health and safety to reopen Unit #1 until Unit #2 has been safely deconta=1:ated. The short term acticns preposed by the licensee do not adequately deal with the scanaries described herein.
If an accident of the magninide of that which occurred at Unit #2 were to occur at Unit #1, wastewater stcrage facilities at Unit #2 wculd have to be borrowed, just as Unit #1 facilities have been borrowed to deal with the accident at Unit #2. Since there is presently insufficient storage capacity on the island to deal with a Unit #2 accident at Unit #1 it is an unreasonable and unacceptable risk to the public health and safety to reopen Unit #1 until Unit #2 has been safely deconta=1:ated. The short term acticns preposed by the licensee do not adequately deal with the scanaries described herein.
                                  .
REVISED CONTENTION 8.
REVISED CONTENTION 8.
The invcivement cf the NRC in any decision to restart Unit #1 is critical.
The invcivement cf the NRC in any decision to restart Unit #1 is critical.
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Accordingly, it is contended that an environmental impact statement must be filed prior to restarting Unit #1.
Accordingly, it is contended that an environmental impact statement must be filed prior to restarting Unit #1.
The FES must consider, among other things, the socio-ecencmic ccsts of 1302 330
The FES must consider, among other things, the socio-ecencmic ccsts of 1302 330
                                              -
                                    . - . .


                                                                                    .
                                                                                      .
reopening the plant versus the benefits; whether the plant is necessary to the energy needs of the licensee's customers; and, finally, the costs of converting Unit No. I to a coal-fired plant.
reopening the plant versus the benefits; whether the plant is necessary to the energy needs of the licensee's customers; and, finally, the costs of converting Unit No. I to a coal-fired plant.
Respectfully submitted, Three Mile Island Alert Inc.
Respectfully submitted, Three Mile Island Alert Inc.
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Thecdore A. Adler, Esquire Wideff Reager Selkcwit:: & Adler Post Office Box 1547 Harrisburg, Pa.17105
Thecdore A. Adler, Esquire Wideff Reager Selkcwit:: & Adler Post Office Box 1547 Harrisburg, Pa.17105
                                     -            Telephone: (717) 763-1383 1302 ';31
                                     -            Telephone: (717) 763-1383 1302 ';31
                          .
                                      -


        .
          -
. .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
                                                   )
                                                   )
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dated 22 Cctober 1979 have been served upon the fc11owing by deposit in the United States mail, postage prepaid, this 22nd day cf October,1979:
dated 22 Cctober 1979 have been served upon the fc11owing by deposit in the United States mail, postage prepaid, this 22nd day cf October,1979:
Ivan W. Smith, Esquire                      C hief, Chairman                                      Docketing and Service                      m Atcmic Safety and Licensing                      Section Board Panel                            Office cf the Secritary              p    ,pg        g U.S. Nuclear Regulatory          -
Ivan W. Smith, Esquire                      C hief, Chairman                                      Docketing and Service                      m Atcmic Safety and Licensing                      Section Board Panel                            Office cf the Secritary              p    ,pg        g U.S. Nuclear Regulatory          -
U.S. Nuclear Regulatory            %    T#        y,
U.S. Nuclear Regulatory            %    T#        y, Commission                                Commission                  ,
                                                                                      '                  -
Commission                                Commission                  ,
Washington, D.C. 20555                      Washington, D.C . 20555                gg %g$1g$
Washington, D.C. 20555                      Washington, D.C . 20555                gg %g$1g$
Marcia E. Mulkey                            George F. Trowbridge, Esquire 9          @
Marcia E. Mulkey                            George F. Trowbridge, Esquire 9          @
D Office of the Executive                      Shaw, Pit: nan, Pctts & Trowbridg Legal Directer                        1800 M Street, N.W.                    c, / 4  Ij U.S. Nuclear Regulatory                      Washington, D.C. 20006 Commission                              (hand delivered to representative Washington, D.C. 20555                          of licensee)
D Office of the Executive                      Shaw, Pit: nan, Pctts & Trowbridg Legal Directer                        1800 M Street, N.W.                    c, / 4  Ij U.S. Nuclear Regulatory                      Washington, D.C. 20006 Commission                              (hand delivered to representative Washington, D.C. 20555                          of licensee)
                                                                           /, /,j
                                                                           /, /,j
                                                                            .
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Thecdore A. Adler ID r    D        l@'
Thecdore A. Adler ID r    D        l@'
                     $iu IP}D MJudk j 1302    1p
                     $iu IP}D MJudk j 1302    1p
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                             *                              -ow=}}

Latest revision as of 00:57, 2 February 2020

Revised Contentions of TMI Alert,Inc.Licensee Proposed short-term Actions Inadequate.Addl Low Level Radiological Discharges Will Have Significant Adverse Effect on Water Quality of Susquehanna River.Certificate of Svc Encl
ML19254F304
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/22/1979
From: Adler T, Adler T A
THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 7911090005
Download: ML19254F304 (9)
v • d • e


Text

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co os NRC PUBLIC DOCIDIENT ROOM 4 S

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]D #T Lb UNITED STATES OF AMERICA mNUCLEAR REGULATORY CCMMISSION 4 M+ /!

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In the Matter cf )

)

METROPOLITAN EDISON COMPANY ) Dceket No. 50-289

) (Restart)

(Three Mile Island Nuclear Station, )

Unit No.1) )

REVISED CONTENTIONS OF THREE MILE ISLAND ALERT INC .

Pursuant to the Board's Memorandum and Order dated September 21, 1979, intervenors were directed to file revised contentions by October 22,1979.

Accordingly, Three Mile Island Alert Inc. (TMIA) files the following contentions.

REVISED CONTENTION 1.

It is contended that the short ters actions proposed by the licensee wG nct adequately protect the members of TMIA, whose tambers live within twenty (20) miles of the Mant, from abnormal and unhealthy additional releases cf radiation.

As a result cf the accident at TMIUnit #2, radicactive gases in excess of permissible limits were released into the atmosphere. These releases incitt.ed:

(a) I-133, which was released cver a thirty-fcur (34) day period following the accident in a*.aounts in excess cf 26.84 Ci; (b) Krypton-88, which, during the first day cf the accident alone, was discharged into the atmosphere in an amount cf 6.lE + 4 Curies; 1302 ?21 7911000C

(c) Xenon releases cf at least 10 million Curies, far in excess of NRC regulations. For mple: 0 r D g[D9 P l i y LU ij (1) Xenon 133M: 170,000 Curies over a ten day period ul t L, (ii) Xenon 135: 1.5 million Curies over a seven (7) day pericd (iii) Xenon 135M: 140,000 Curdes over a three (3) day period Other radioactive gases released as a result cf the accident at Unit #2 include Rutheniuim - 103, - 106; Tritium; and Bremine -82, -83, -84, -85.

These releases will have Icnq term health effects on ther members of TMIA.

If TMI Unit #1 were to be recpened, the adverse health effects to the members of TMIA would be magnified since Unit #1 will release additional amcunts cf radiation into the environment. Since radiation affects the bcdy in a cumulative manner, the additional releases frem Unit #1 will have a direct adverse health effect on the members cf TMIA.

In addition,' the cleanup cf Unit #2 will undcubtedly result in both planned and unplanned discharges of radiation into the environment. Since the members cf TMIA have already received desages cf radiation far in excess cf that which would have been received had there been no accident,the cumulative effect as described above may ultimately cause sickness ar d death to scme members of TMIA.

It is contended that the short term acticns proposed by licensee do not adequately deal with this problem.

1302 325

-1

b REVISED CONTENTION 2.

TMIA contends that the additional low-level radiological discharges from Unit #1, in addition to these high-level discharges that have and will be discharged as a result of the TML accident, will have a sigr* ant adverse effect on the water quality in the Susquehanna. During decontaminatien, there exists the real possibility of discharges of radicactive wastewater into the Susquehanna. Even if decontamination is done acccrding to present plan, the system, Epicere II, cannet recove radicactive tritium frem the decentaminated water. This tritium will be discharged into the Susquehanna River. If Unit #1 were to reopen while decentamination cf Unit #2 was continuing, additional discharges of radiation into the Susquehanna will occur. Radioactive releases into the river as a result of the accident at TMI #2, have resulted in presently ascertainable damage to the fish and wildlife in and around the river, thereby increasing the probability of radiation in the feed chain. Therefore, it is contended that no consideration be given to reopening Unit #1 until 'I?.fI Unit #2 is decontaminated to pre-March 23, 1979, levels, and the effects cf the accident and subsequent decontaminaticn on the water quality in the river have been thoroughly analy::ed.

REVISED CONTENTION 3.

It is contended that if Unit #1 is reopened, fear cf another Unit #2 type accident will cause mental health problems, in varying degrees, to many pecple living near the plant. This fear will also adversely affect the ecenemy cf the region because empicyees will be absent from work due to mental anxiety, pecple 1302 526

willleave thee jobs and =cve from the area, and new businesses will refuse to locate in the area. It is contended, therefore that the health and economic consequences brought about by the fear and anxiety which wi!!

cccur, and increase, if Unit #1 is reopened, cutweigh the benefits that will be obtained thereby.

REVISED CONTENTION 4.

It is contended that if Unit # 1 is reopened many people from all over the country will be fearful and angry. Many cf these people will ccme to Middletown and attempt to keep Unit #1 closed by using both vicJent and non-violent means. As a result, censiderable civil disruption will occur in the area surrounding the plant. Lccal and State authorities are not presently equipped to deal with the types of civil disruptions that may very well occur.

it is contended that the additional costs which will have to be incurred by the State and the local municipalities involved, in order *a deal with the civil disruptions, have not been evaluated at all. Furthermorez it is contended that this disruption, added to a crippled #2 reactor that will be contaminated with highly radicactive matcrial for years to come, is an unreascnable and unacceptable cost nct outweighed by the benefits of reopening Unit #1. The short term actions proposed by the licensee do not deal with this eventuality.

797 002 e 1

m

w b.. .=a REVISED CONTENTION 5.

It is contended that Met-Ed has negligently. and on occasion, willfully viciated NRC regulations concerning the safe operaticn cf both Units #1 and #2, in that it has deferred necessary maintenance and repairs in order to minimize reactor downtime, to the detriment cf the integrity of the nuchar facility itself. The licensee has, in the past, allowed work orders to go undene in order to avoid shutting Unit A down to perform necessary maintenance. The licensee would allcw werk crders to pile up unul refueling, at which time Se licensee wculd attempt to do all the work required. Just to ccmplete essential maintenance in the short time available, employees were worked to a point where they were no longer effective because cf fatigue. These actions, and actions cf this t'ipe, reflect negatively upon the ability of the licensee to safely operate c nuclear facility.

Ccnsequently, it is centended that Met-Ed is incapable of safely operating TMI A and that its operating license should be reveked permanently.

REVISED CONTENTION 6 It is contended that Met-Ed dces not have the financial capability to:

(1) comply with technical changes that may be demanded as a result cf the accident at Unit 42, and (2) comply with requiations cf the NRC requiring the expenditure of additional sums cf =cney either fcr mandated design changes or changes in the financial protecticn requirements of ICCFR Part 140.

1302 52'i

D D^]f oo  %]N@h_$~

6th nk, Because cf the I!censee's problems with Unit #2, it has been unable to meet its energy obligations to the PD1 interconnect. As a consequence, the licensee's deferred energy balance owed PIM may very well exceed its t'ert term debt by February,1980. If this occurs, the licensee's ability to borrow money will cease, and thereis the real possibility cf the licensee going bankrupt. It is centended, therefore, that the licensee does not presently, or for the foreseeable future, have the financial requirements necessary to operate a nucicar facility.

REVISED CONTENTION 7.

It is contended that the licensee will be unable to adequately deal with a design basis accident cf class one through eight if one should cccur at Unit # 1 while decentamination continues at Unit #2. The Unit #2 containment building and vessel today hcuse in excess cf half a million gallens of highly contaminated wastewatir, and another 250,000 gallons are stored in auxiliary storage buildings on the island. Presently, there is no approved timetable for the safe decontamination of Unit #2. It is centended that the wastewater storage capability cf Unit 4 if an accident were to occur, wculd be insufficient , since a large portion cf this capacity may ult' anately be ccmmitted to the safe decontaminaticn cf U:3t #2. Furthermore, even if no accident should cccur at Unit #1 there is a possibility of an accident cccurring at Unit

  1. 2 during decontamination which wculd result in the diversicn of all Unit #1 storage capacity to U-it #2, thereby leaving Unit a unable to cope with any 1302 329

type of accident that would produce abnormal an.mnts cf radicactive wastewater.

If an accident of the magninide of that which occurred at Unit #2 were to occur at Unit #1, wastewater stcrage facilities at Unit #2 wculd have to be borrowed, just as Unit #1 facilities have been borrowed to deal with the accident at Unit #2. Since there is presently insufficient storage capacity on the island to deal with a Unit #2 accident at Unit #1 it is an unreasonable and unacceptable risk to the public health and safety to reopen Unit #1 until Unit #2 has been safely deconta=1:ated. The short term acticns preposed by the licensee do not adequately deal with the scanaries described herein.

REVISED CONTENTION 8.

The invcivement cf the NRC in any decision to restart Unit #1 is critical.

The plant cannot recped without NRC approval. There can be no reasonable basis to deny that sucn wtions are covered by the National Environmental Policy and it is centended therefore, that a decision to reopen Unit #1 is a major federal action significantly affecting the quality of the human environment.

Accordingly, it is contended that an environmental impact statement must be filed prior to restarting Unit #1.

The FES must consider, among other things, the socio-ecencmic ccsts of 1302 330

reopening the plant versus the benefits; whether the plant is necessary to the energy needs of the licensee's customers; and, finally, the costs of converting Unit No. I to a coal-fired plant.

Respectfully submitted, Three Mile Island Alert Inc.

By: Me c /

Thecdore A. Adler, Esquire Wideff Reager Selkcwit:: & Adler Post Office Box 1547 Harrisburg, Pa.17105

- Telephone: (717) 763-1383 1302 ';31

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Decket No. 50-289

) (Restart)

(Three MileIsland Nuclear )

Station, Unit No.1) )

)

CER"'IFICATE OF SERVICE I hereby certify that ccpies of Revised Contentions of TMIA, 20.

dated 22 Cctober 1979 have been served upon the fc11owing by deposit in the United States mail, postage prepaid, this 22nd day cf October,1979:

Ivan W. Smith, Esquire C hief, Chairman Docketing and Service m Atcmic Safety and Licensing Section Board Panel Office cf the Secritary p ,pg g U.S. Nuclear Regulatory -

U.S. Nuclear Regulatory  % T# y, Commission Commission ,

Washington, D.C. 20555 Washington, D.C . 20555 gg %g$1g$

Marcia E. Mulkey George F. Trowbridge, Esquire 9 @

D Office of the Executive Shaw, Pit: nan, Pctts & Trowbridg Legal Directer 1800 M Street, N.W. c, / 4 Ij U.S. Nuclear Regulatory Washington, D.C. 20006 Commission (hand delivered to representative Washington, D.C. 20555 of licensee)

/, /,j

[ <. -

Thecdore A. Adler ID r D l@'

$iu IP}D MJudk j 1302 1p

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