ML19318B541

Testimony at MD Commission on Intergovernmental Cooperation 800603 Hearing,In Annapolis,Md Re Spent Fuel Storage.Outline of El Conner Comments Encl

ML19318B541
Person / Time
Site:	Calvert Cliffs
Issue date:	06/03/1980
From:	Long S GEORGIA, STATE OF
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ML19318B535	List: ML19318B538 ML19318B541 ML19318B547
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NUDOCS 8006270020
Download: ML19318B541 (8)

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EHCLOSURE 4 Testineny of Dr. Steven M. long before the O Maryland Ccanission on Intergovernmental Cooperation Chairman Byrnes, ChaiInun Maurer, members of the Ccmnission, my name is Steve Long. I am the Director of Maryland's Power Plant Siting and Research Program.

Mr. Easter has asked me to address five specific questicns for you today.

Each of these touches upcn one or nere very ccanplex issues in a general manner, so that conplete response to each would require volth testimony. However, in my responses to follow, I have held my renarks to brief overviews, except when there is a specific point to be made concerning intergovernmental cooperation.

1. What is the status of the Three Mile Island Clean-Up?

W e current condition of the power plant is as follows. The containrent building has about 650,000 gallons of highly contanunated water in the ficcr of the lower level. There is about 1 curie of radioactive material (mostly Cs-137) per gallon in this water. Present depth is apprcximately 7.7 feet. Due-to the centinued leakage of water frcm the reactor coolout system, the water level in the building is still rising but now at a very small rate. The water has now covered scme equignent, such as electrical value actuators, rendering them inoperable or unreliable. This situation does not appear to constitute any imnediate threat. We Metropolitan Edison Ccrapany is presently designing a Submerged Denineralizer System to decontaminate this water. The Nuclear

! Regulatory Ccmnission nust approve such a system before the Ccmpany can use it, howver, and the Ccmnission has not yet nude any decision as to the type of -

systen which should be used for this portion of the clean-up. The NBC intends to withhold this decision until their prograntratic envirccmental impact statement has been canpleted. A draft of this statenent is s:heduled, for this acnth, with the final statenent due in the fall. Th.is schedule appears optimistic to us.

The air inside the containment building is cantaminated with about 57,000 Ci of an inert radicactive gas, Kr-85. We, Metropolitan Ediscn Ccrpny wishes to vent this gas to the outside atnesphere iri a controlled :ranner so that workers may enter the building without cumberscme protective clothing and breathing apparatus. The NBC has agreed to consider the venting option prior to'its ccepletien of the progrmtunatic envi.mtal impact statement, and has been soliciting and considering public ccmnent on a separate envi.mtal assessment since March. We NRTs decision on the.Krypten-85 renoval may be forthecnung' at any time, now, but their staff does not seen to think that the venting could occur before this fall. Maryland has subnitted written ccanents favoring the venting of the Krypton gas in a manner controlled to minimize the resultant dose to the local populaticn.

Because of the 1cng delay since it requested to vent the containment

, building, the Canpany has sought permissicn frcm the NFC to have workers in j protective acparel enter the contai:rnent building through an airlock. _Permissicn l

was finally granted for this, but the attenuted entry on May 21st was thwarted when the airlock's inner door was found to be stuck, prcbably due to corrosien.

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Outside the containment building, about 470,000 gallons of radioactive water was accumlated during the accident, and the auxiliary building and fuel handling building were contaminated. By Octcber, 1979, the auxiliary building water had accumlated to a volume which threatened to exceed available tankage in Unit 2. At that time, the NBC approved the use of a decontamination system known as EPIC)R II. N NRC's decision was preceded by an environmental assessment.

At this time, the EPIOCR II systs has decontaminated about 311,000 gallons of the auxiliary building water. Our own sampling of EPICOR II output verifies that this systs is producing water of a quality similar to that in normal discharges fr m an operating nuclear power plant. Actual discharge of the decontaminated.

water is currently prohibited until 1982 or the time that the NBC's programatic envircrimental impact statment is empleted. .

Canisters of ion exchange resins, contahting the radioactivity re oved fr m the water by EPICOR II, are now being stored on the southern.end of the island in a newly constructed interim storage facility. N EPICCR II system was not designed to permit " solidification" of these resins in the filtratica syste

" liners". However, the NRC has decided nct to allow the liners to be shipped off-site cm public highways without solidification. 'Ihe liners are presently accumlating on the island and the storage area is being expanded to e- - ate the while a suitable solidification ;:rocess is designed and approved.

In the course of this status update', I have mentioned several areas of intergovernmental contact which it would be useful to describe to this Comission.

In staff level contacts and working relationshios with both the NBC and the utility cmoany, we have enjoyed an excellent degree of cocoeration frm all concerned. Beginning early in the course of the accident, Maryland has been able to arrange for exchanges of technical information and radiological sanples i on a very prmpt and informal basis thrcugh those individuals actually responsible for ccriducting the pertinent activities. More recently, a Maryland State enployee has been cleared for unescorted access to 'IMI so that he may sapple pertinent ite s, himself. This sort of contact has proven essential to our proper handling.of the situation. Early in the' accident, formal channels.of cmmunication proved too slow and ac hoc channels inwiving nontechnical people pr'uved too inaccurate. h lesson learned is clear: when the chips are down, it is

essential that information be exchanged frm one technical perscn to another, with no one in between s o doesn't understand precisely what the information ,

means and how it is to be used. Any mechanisms developed for emergency response j to future accidents will'be substanHally flawed if they fail to provide for this type of direct ccanunicaticn among the responsible individuals actually .

performing the work. .

Our one ccrmunication impasse during the accident illustrates my point.

l Herold Denton (NBC) was worried that the hydrogen bubble in the prirary, coolant

systs might am=_ Hate enough oxygen to explode, and was apparently sericusly

! considering early depressurization of the coolant system to remve the bubble. *

Fe was apparently very isolated frcm cmpetent technical advisors, many of -

l whcra were trying to give him the word that calculations shcmed the oxygen could not accumlate in the bubble. He was also seriously isolated frm us here in Maryland. Our own modelling had shown us that no public protecticn measures j would be' necessary for Maryland citizens unless' a major core-melt accident cccurred. We were satisfied that this w ts not prchable, unless the primary coolant loop was depressurized and the bubble blocked the coolant pmps. In order to be prepared, we therefore desired to get the earliest possible

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notification should Denton make the decision to depressurize, but were con-cerned that we would not be notified. This is also a lesson which riust be applied to our planning for future mergencies: local and state civil defense authorities r:ust be kept informed of ccr:rard decisions by whoever is actually in charge of the reactor operations, regardless of whether that perscn thinks any particular ccrnmand is of interest to the civil defense personnel. Subs'a tial progress has been made in our emergency planning since March,1979, as' I'm sure General Brooks will describe, later this afternoon. Although the federal govern-ment has participated in a heavy-handed manner to require this progress, it has yet to participate in the actual planning by providing the states with even an outline of an emergency plan of its own. It is still not clear what role the NBC would play or with whcm they would choose to ccrmunicate during any future accidents.

Intergovernmental liaison between Maryland and the Nuclear Regulatory Ccrimission itself has been truch less productive than ecumunication with the NPC staff. Governor Hughes' letter to Chainnan Ahearne did not succeed in cbtaining additional ccatmit:nents for liaison with Maryland beyond what.is strictly required by law 'or regulaticn, however several of the Governor's requests were '

agreed to by the Ccurmission during dealings with other entities p.rior to their written respcase to Governor Hughes. We believe that those requests which the Ccrmission did not grant are ncw adequately covered by working relationships developed at the respective staff levels. Cooperation has been very gocd with '

the NBC staff cm Ccutmission-directed activities such as preparaticn of ,the prcr-gracitatic environmental irtpact statement, the various envircrunental assessments, and related informational meetings. Maryland's technical ccanents are clearly being ccnsidered by the staff, and their responses will'.be presented to the Ccmnis.sion. Very informal working arrangements have developed in several important i areas such as the I:odelling of the radiological impact of mI releases cn Chesapeake Bay. We NRC staff group develcping this part of the envircrunental impact statment has met with our radioecology people several times to go over existing data and discuss the model as it is being developed.

On the basis, it appeIrs that our excellent working level relationships with NFC staff will ensure that Maryland's technical views are adequately considered by the Nuclear, Regulatory Ccmnssicn. However, the Ccurmissicn itself dces not appear inclined to formally reccgnize these relationships nor provide ,

any assurances that Maryland will be dealt with in any other manner than what is strictly required by law or regulatien.

2. What environmental impact has Wree Mile Islard had on Maryland to date?

During the accident, about.13,000,000 curies of radioactive inert gases and about 14 curies of radioactive iodine were released to the atznosphere.

Sampling of the atmosphere in Maryland failed to detect this gas at any time with the exception of one sample at one station between March 30 and April 1, 1979. We levels were extreely lcu, and could not' be definitely attributed to 'IMI because of the close proximity to Peach Bott:ra Atcmic Power Station.

Doses frcm the level detected would be abcut 0.000003 millirem to the whole bcdy, and about 0.003 millirem to the thyroici.glard of an infant due to the inhalation pathway, alone. Since we did not detect radioicdine in loedl = ilk,.

this pathway was not included in the dose calculaticn.

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At the time of the accident, discharges of water from the radwaste system at TAI Unit 2 were discontinued. However, because of scme leakage to normally clean systems, sczne radioactivity was discharged to the Susquehanna River. We arranged through the IGC to cbtain samples of the discharges and tabulated the totals over the period of the accident. Most of the radioactivity in the dis-charge water was dissolved inert gases (mostly Xe-133), but there was also about 0.25 Curie of I-131.

Our sanpling of the river water detected the dissolved Xe-133 as far down river as Holtwood Dam, but not below in Maryland. We were unable to detect any of the other radioactive materials frcm the discharge of any point we sampled in the river.

Since the accident, we have extensively sanpled fish, shellfish, aquatic plants and bottcm Wimarits in Holtwood Reservoir, Conowingo Reservoir, the lower Susquehanna, the Flats, and the Upper Chesapeake Bay. Based upon this

• sampling, we conclude that neither the normal operations of StI nor the accident in 1979 have had detectable radiological impact in Maryland waters. mis is not surprising,since water borne releases frcm DtI before ard during the accident were quite snall, and there have been no releases frcm Unit 2 since last su:mer.

To provide contrast, I'll mention.that the same sacpling quite clearly shows the levels of natural radioactivity, the fallout frcm nuclear explosions conducted in the atnesphere, and the influence of the releases fran the Peach Bottcm plant.

In other words, whatever level of radiological impact did occur in Maryland frcm DiI's aedident is negligible.

3. What storage facility is accepting Three Mile Island's nuclear waste?

i At present, the Hanford, Washingtcn low level radioactive waste dispsal facility is accepting DfI Unit 2 low level wastes, ard it appears Hanford will accept EPICOR II " liners", also. As I mentioned previously, the EPICOR wastes are presently being held on the island pending solidificaticn to NBC's approval. -

It is worthy of note that DII Unit 1 wastes are still being shipped to Barnwell, S.C., but Unit 2 wastes are not accepted there. This means that Unit 2 wastes will not be transported through Marylard.

W e damaged nuclear fuel in StI Unit 2 is classified as high level waste.

Presently, there is no high level waste repository because the federal government has failed to establish one yet. Ebrther, since President Carter ordered the cessation of spent fuel reprocessing in the spring of 1977, there has been no .

place to ship used fuel in good condition. It is unclear just how long the damaged fuel may be stuck on Three Mile Islard under these circumstances. The federal government's failure to make any substantial progress en nuclear waste disposal during thepast 20 years renders their current schedules noncredible.

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• What can Maryland do to expedite removal of radioactive waste frcm tree Mile Islard?

With regard to the high level wastes, the damaged fuel, there is an .

cpticn for the federal government to accept ifas soon as it can be renoved and packaged. It can be handled alcng'with similar federal wastes created in cur military weapons production facilities ard nuclear ship propulsion systers.

In ecmnenting en the scope for the NRC's progranratic envircnmental irpact e

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statcment, Maryland has requested that this option be considered. I understand that it will be addressed, but have no hint as to what the SEC staff ray recom-

, mend nor what the Ccumissien may decide.

With regard to the low level wastes, disposal is not new blocked, but could be by either the Washington State government or the Hanford operators. There is an interesting lesson to be learned frcm the difficulty with disposal of the EPICDR II " liners": the clean-up operation must be conceptually planned in a oceprehensive manner, frca start to disposal, so that the outputs of each step will be ccrnpatible with each successive step. At the tire the EPICDR II systs was designed, the NBC had not decided that the resins must be solidified before shipnent. By the time the NFC approved the use of EPICOR II and added the solidi-fication requirenent, the Ccmpany did not have enough time to rebuild the system before the water amlation rate forced the to begin using it.

In order to speed up the TMI clean-up and waste renoval, Maryland would need to make the NBC not only work faster, but also to be thorcugh. I don't know how to" force any federal agency to be fast and thorcugh at tre same time. Ecwever, I do know how to urge them and how to help then, so this is the approach that has been taken by Maryland's technical staff and executive branch ad::unistrators.

By providing data and ccoments expediticusly, assisting the NPC in setting up p:blic meetings, and by taking our own radiological data to establish an independent viewpoint add help bridge the credibility gap, I believe we have materially a W a in expediting an adequately planned clean-up.

Uhfortunately, scme others have chosen to threaten the NBC with lawsuits and to demand unreasonable criteria be applied to the clean-up process ard its planning-by the NBC. This appears to me to have resulted in considerable delay and uncer-t tainty in the process. In my opinion, the Nuclear Regulatory Ccanission's reticence to make any cc:rtmit:nent on planning procedure or clean-up rethod is .

greatly exacerbated by their recognition that almost any action on their part will be challenged cm procedural grounds. These challenges may block actions in scne cases, and in any case tend to force the NRC never to' turn back once they start scmething. Because the clean-up cannot be planned in final detail frcm start to finiih withcut information that can only be cbtained by starting scme

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parts of the process, there is no easy way for the NPC to show ccupliarce with the Naticnal Environmental Quality Act. NEPA was designed to create awareness of environmental impacts associated with new plans prior to gcvemnent cccmit- -

ments. It was not designed for speed in energencies, nor was it designed for situatienswhere events created the ccumitments, and the federal acticns censidered constitute a clean-up operaticn. This is not intended to mean that envircnmental censideraticn is uninportant in planning the 'IMI clean-up; it is intended to warn you than insistence en the NFC's ccnpliance with the most strict inter-pretations of NEPA will create a slow j.f not inpossible situation..

5. Shculd Maryland take any acticn to facilitate increased storage of spent fual frcm Calvert Cliffs Power Plant so as to safeguard its continued option beycnd 1987? .

Baltincre Gas and Electric Ccn:pany has made application to the Nuclear Regulatory Ccrru.ssicn for two license amer 4ments. The first would al16w the use of new fuel racks in the spent fuel pool, acccrtacdating enough fuel to last until 1987. The seccnd requests to change the fuel assemblies so as to have

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an 18-month fuel cycle instead of the current 12-month cycle. This, together with the new racks would allow the Company to go to April 1991 before losing the ability to unload a full core in the event of an accident, and until Octcber 1993 before the spent fuel pool is full. M1ryland does not need to take any action to facilitate these changes.

Scznetime prior to 1991, BG&E wculd have to decide if still further Ccupany action was needed to guarantee continued cperation of their Calvert Cliffs Nuclear Power Plant. One such option is to build an additioral spent fuel storage pool cn site in a separate building.

If BG&E should choose this option, it is not clear to me whether the Maryland -

Public Service Ccmnissicn would need to authorize it by issuance of a Certificate of Public Convenience and Necessity . Article 78, Section 54H(a) of the Annotated Code of Maryland requires an electric ccrpany to obtain a Certificate for any modificaticn to "the facilities at ein electric generating station or the change in the fuel used by the station, which would result in any change of air enissions fran the station". This last provision en fuels applies cnly if there would be an increase in enissions beyond the levels considered by the PSC as the basis for granting the certificate at time of constructicn.

Should the PSC hold hearings cn a ~new spent fuel storage facility, Article 43, Section 689B(b) of the Annotated Code would seen to prchibit such storage.

Ecuever, in a recent opinian (No.80-021) the Marylard Attorney Ceneral has declared this Ecrticn of the Maryland law to be preegt.ed by the federal Atcznic Energy Act. Therefore, the PSC would not appear to be required by law to deny such an application frcru BG&E.

It is worthwhile to point out to this Ccmnissicn that Maryland's position as expressed in Article 43, Section 589B is senewhat enbarrassing. Basically, Maryland desires to ccntinue to use nuclear power and gerarate radioactive wastes, but will not even consider clisposal, storage or reprocessing within its borders. In considering the various aspects of interty:n/ernmental cooperatien, the effects of this self-serving policy on cur dealings with other governments should be considered.

That ecznpletes the answers to my assigned questicns. I wxild like to thank you for the opportunity to address this n = h aicn.

If you have any questiens, I would be pleased to try to answer them, now.

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ENCLOSURE 5 COMMENTS ON NUCLEAR WASTE MANAGEMENT AND DISPOSAL BEFORE THE MARYLAND COMMISSION ON INTERGOVERNMENTAL COOPERATION By E. L. " Monte" Conner, Nuclear Regulatcry Comission June 3, 1980 OUTLINE A. Introduction B. Nuclear Regulatory Comission's Responsibility

1. Nuclea.r Reactor Regulation

a. Licensing of Facility

b. Review of Proposed Changes

c. Issuance of Technical Specifications

2. Nuclear Materials Safety and Safeguards

a. Control of Fuel Shipments

b. Safeguards Evaluation

3. Inspection and Enforcement

a. On-site Coverage

b. Ensures Compliance C. Spent Fuel Pool Design

1. Physical

2. Criticality Safety D. Past Licensing Action

1. Areas of Review

2. Amendment Package

3. Installation E. Current Licensing Action .- -

1. Borated Rack Design i

2. Review Status

3. Schedule r

SPENT FUEL CAPACITY - CALVERT CLIFFS flVCLEAR POWER PLANT TYPE OF RACK UO. OF FUEL ASSEMBLY OPERATING THROUGH ORIGIiAL LICENSE WIDE SPACE 410 1979 COMPACT RACKS , CLOSE CENTER ,

AUTHORIZED 1056 1984 JAN. 1978 INSTALLED TO DATE 728 1981 CURRENT A PPLICATION BORATED RACKS -1760 1989 I

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A cn

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