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UNITED STATES OF AMERICA | |||
1HE PROPOSED A'-lrn:x 1D .-\PPEXDIX D, 10 CFR PART 5 0, APPEARS TO DEFTh""E A CLASS 9 ACCIDE:-IT AS A SEQUENCE OF FAILURES l\1UG! ARE MOR:= SEVERE TI-IA:.'i TI-IOSE l\1-UG! 11-IE SAFETI FEATURES OF 'IHE PI..fu\i! | :NUCLEAR .REGLJLA..1DRY CO~lMISSIO:N Before the Atomic Safety and Licensing Board In the Matter of Docket No. 50-272 PUBLIC SERVICE ELECTRIC & Proposed Issuance of .Amendment to GAS CO .. Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1) | ||
ARE DESIGNED 1D PREVBT. 'THE OF F.AIWRES AT 1HREE :.ITI..E ISLAi\ID PRODUCED A BREAa-I OF T.-IE | INTERVENORS' , COL:BtA..t'l, RESPONSE TO BOARD QUESTION NUMBER FOUR: WAS TivIT A CLA.SS NINE ACCIDB\JT? | ||
:tvlENf AND A RELEASE OF R<\DL\TION COULD NOT BE PREVENTED BY 1HE S...u:ETY FEA.TIJRES. | STA.1'..iLEY C. VAi~ NESS PUBLIC ADVOCATE OF .NE'i JERSEY DEPARTMENT OF 'IHE PUBLIC ADOVCATE DIVISION OF PUBLIC INTEREST ADVOCACT P. 0. BOX 141 520 EAST STATE STREET TRENTON, NEW JERSEY 08625 KEI1H A. ONSDORFF ASSISTJ'u\lT DEPlITY PUBLIC ADVOCATE Attorney for Intervenors, Coleman 7 910 l l_oz.oc_ | ||
W_t\S 'IHE OCCURRENCE AT 1HREE MILE ISI..Ai'ID . 'lliEREFORE A CLASS 9, .ACCIDE-.T? | |||
The Regulatory Cormnission in A to Appendi..x D to 10 C.F.R. Part SO has defined Class accidents as: "successive failures :more severe "t:I'.an those postulated for the design basis for protective systems a.'1:d engineered sa:fety features. | 1HE PROPOSED A'-lrn:x 1D .-\PPEXDIX D, 10 CFR PART 5 0, APPEARS TO DEFTh""E A CLASS 9 ACCIDE:-IT AS A SEQUENCE OF FAILURES l\1UG! ARE MOR:= SEVERE TI-IA:.'i TI-IOSE l\1-UG! 11-IE SAFETI FEATURES OF 'IHE PI..fu\i! ARE DESIGNED 1D PREVBT. 'THE SEQUEi~CE OF F.AIWRES AT 1HREE :.ITI..E ISLAi\ID PRODUCED A BREAa-I OF T.-IE CO~TAIN | ||
Tne:ir consequences could be severe." 36 F.R. 22852. Beyond this brief description, the Annex definition provides no qualitative | :tvlENf AND A RELEASE OF R<\DL\TION l~HIGl COULD NOT BE PREVENTED BY 1HE S...u:ETY FEA.TIJRES. W_t\S 'IHE OCCURRENCE AT 1HREE MILE ISI..Ai'ID . 'lliEREFORE A CLASS 9, .ACCIDE-.T? | ||
:measure for detennining the magnitude of environmental consequences which are deemed likely to flow from a Class Nine accident_ | The ~uclear Regulatory Cormnission in proposed~Zinnex A to Appendi..x D to 10 C.F.R. Part SO has defined Class KL.~e accidents as: | ||
It would appear, therefore, that -r:he gravamen of the Class Nine Event is the magnitude of equipment and/or human failures which exceed the re.a:tor 1 s defense in depth safety systems. :t>!ost simply put, the differem:e between a CT.ass Eight and Nine Accident is found in the proposition_ | "successive failures :more severe "t:I'.an those postulated for the design basis for protective systems a.'1:d engineered sa:fety features. Tne:ir consequences could be severe." | ||
that in all 1 credible' hypothetical accident ("Class Eight") scenarios, the plant's redundant safety systems activate as designed to ensure sufficient cooling water flow to the reactor at all times. Postulated accidents more severe than the engineered safety features in 'P\\'Rs prior to t.rarch ZS, 1979 were deened so rer::ote i.."1 probability that the !\"RC could license these plants for operations consistent | 36 F.R. 22852. | ||
\dth its statutory mandate to "provide adequate protection to the health a:.'lrl safety of the public." 42 U.S.C. 5 233Z(a). :\o more than a CJ.rosary farniliari"t;Y with the Commission's response to the Three Island accident is needed, however, to lmow that the NRC has begun a substantial upgrading of PIVR *safety features to* | Beyond this brief description, the Annex definition provides no qualitative | ||
another uncontrolled. | :measure for detennining the magnitude of environmental consequences which are deemed likely to flow from a Class Nine accident_ It would appear, therefore, that -r:he gravamen of the Class Nine Event is the magnitude of equipment and/or human failures which exceed the re.a:tor 1 s defense in depth safety systems. :t>!ost simply put, the differem:e between a CT.ass Eight and Nine Accident is found in the proposition_ that in all 1 credible' hypothetical accident ("Class Eight") scenarios, the plant's redundant safety systems activate as designed to ensure sufficient cooling water flow to the reactor at all times. Postulated accidents more severe than the engineered safety features in 'P\\'Rs prior to t.rarch ZS, 1979 were deened so rer::ote i.."1 probability that the !\"RC could license these plants for operations consistent \dth its statutory mandate to "provide adequate protection to the health a:.'lrl safety of the public." 42 U.S.C. 5 233Z(a). :\o more than a CJ.rosary farniliari"t;Y with the Commission's response to the Three ~lile Island | ||
LOCA caused by loss of the main feedwater supply. See e.g. 1\UREG-0578, 1MI-2 Lessons Learned Task Force, Status Report and Short-Tenn Recorranendations. | |||
This latter regulatory action, when coupled with* the moratorium on the issuance of operating licenses pending adoption of t:hese Lessons demonstrates quite convincingly .that the events at Three Mi.le Island constituted a Class Nine accident. | accident is needed, however, to lmow that the NRC has begun a substantial upgrading of PIVR *safety features to* pr~rent another uncontrolled. | ||
Roger Mattson' s earlier comments to the. Commission aptly summarize the Staff's conclusions rt11at the 'Jn.IT-2 accident. | LOCA caused by loss of the main feedwater supply. See e.g. 1\UREG-0578, 1MI-2 Lessons Learned Task Force, Status Report and Short-Tenn Recorranendations. | ||
surpassed the engineered safety features .at this ntl£:1.ear power reactor: ''Ke saw failure modes, the likes of i..;hich have never been analyzed. | This latter regulatory action, when coupled with* the moratorium on the issuance of operating licenses pending adoption of t:hese Lessons Learned~ | ||
demonstrates quite convincingly .that the events at Three Mi.le Island constituted a Class Nine accident. Roger Mattson' s earlier comments to the. | |||
30, 1979 CoIIIlTiission Meeting. WAS 1HE RISK TO HE.i\LTI-f .AND S.t.\FEIY A.L'ID lliE EWIRON'ilENT | Commission aptly summarize the Staff's conclusions rt11at the 'Jn.IT-2 accident. | ||
' REi\'KJTE IN PROBABILITI' OR 'EXTREMLEY LOW' AT THREE MILE ISI...Ai\m, AS 1HOSE TERMS ARE USED IN 1HE The risk was real. It was of an tmdetermined lmagnitude | surpassed the engineered safety features .at this ntl£:1.ear power reactor: | ||
:and may be continuing as efforts are initiated to unde:T.take the :most sensitive and extensive nuclear plant decontamination in history. The reality of the TMI risk to the public's heal th and safety \1;as recognized by the :Nuclear Regulatory Cormnission and the State of Pennsylvania. | ''Ke saw failure modes, the likes of i..;hich have never been analyzed. - | ||
NRC Chairman Hendrie told Governor Thornburgh that it IlEight becor.ne necessary to evacuate the general population residing as far as twenty miles from the reactor site. House of Representatives Report No. '96-413, E.:.rtergency Planning Around U.S. :Nuclear Powerplants: | Mattson, Nucleonics Week, April. | ||
Nuclear Regulatory Commission Oversight, p.2 August S, 1979. Subsequently, the Gvvernor recorrnnended that pregnant women mid families with children five years and younger in age, living within five miles of the plant leave this area. Acrai:n | 26, 197 9 p. 10; Transcript f.Iarcil'! | ||
Director, Systems Safety Division succinctly articulated. | 30, 1979 CoIIIlTiission Meeting. | ||
the s view of the 'IJ\IT danger when he reported* | WAS 1HE RISK TO HE.i\LTI-f .AND S.t.\FEIY A.L'ID lliE EWIRON'ilENT ' REi\'KJTE IN PROBABILITI' OR 'EXTREMLEY LOW' AT THREE MILE ISI...Ai\m, AS 1HOSE TERMS ARE USED IN 1HE A~? | ||
to the Conunission on the unfolding events the accident: "The latest burst didn't hurt raany people. I'm not sure why your not moving people. Got to say it. I have been saying it dmvn here. I don't know what we are protecting at this point. I think we ought to be moving people. Mattson, Nucleonics Week, April 30, 1979 p. 2 Transcript | The risk was real. It was of an tmdetermined lmagnitude :and may 1~*ell be continuing as efforts are initiated to unde:T.take the :most sensitive and extensive nuclear plant decontamination in history. The reality of the TMI risk to the public's heal th and safety \1;as recognized by the :Nuclear Regulatory Cormnission and the State of Pennsylvania. NRC Chairman Hendrie told Governor Thornburgh that it IlEight becor.ne necessary to evacuate the general population residing as far as twenty miles from the reactor site. House of Representatives Report No. '96-413, E.:.rtergency Planning Around U.S. :Nuclear Powerplants: Nuclear Regulatory Commission Oversight, p.2 August S, 1979. Subsequently, the Gvvernor recorrnnended that pregnant women mid families with children five years and younger in age, living within five miles of the plant leave this area. Acrai:n | ||
:March 30, 1979 Corrunission Meeting. However, while Mr. f.lattson sought to reassure the Commission that up to *that time few people had been injured, the needed data base to support this opinibn was non-existent. | °' , Rocrer 0 | ||
The House Committee on Government Operations, Regulatory Corrrrnission Oversight Report of .t\u.gust 8> 1979 cites the June 21, 1979 Corrrrnission meeting at which it received a "Briefing on Facts of TMI Radiological Sequence" to conclude: "Most of the radioactive material released during the accident was discharged from the plant's stack. The Radiation monitor in that stack, however, was designed to register on:iy the nonnal low level* radiation releases associated with routine operation. | Mattson > | ||
During the accident the instnunent was off-scale, or 'pegged. 1 14 Thus, emergency response officials could not be advised during the accident of how much radioactive material. | |||
Director, Systems Safety Division succinctly articulated. the Staff~ s view of the 'IJ\IT danger when he reported* to the Conunission on the unfolding events durin~, | |||
. | |||
the accident: | |||
"The latest burst didn't hurt raany people. I'm not sure why your not moving people. Got to say it. I have been saying it dmvn here. I don't know what we are protecting at this point. I think we ought to be moving people. Mattson, Nucleonics Week, April 30, 1979 p. 2 Transcript | |||
:March 30, 1979 Corrunission Meeting. | |||
However, while Mr. f.lattson sought to reassure the Commission that up to | |||
*that time few people had been injured, the needed data base to support this opinibn was non-existent. The House Committee on Government Operations, | |||
~uclear Regulatory Corrrrnission Oversight Report of .t\u.gust 8> 1979 cites the June 21, 1979 Corrrrnission meeting at which it received a "Briefing on Facts of TMI Radiological Sequence" to conclude: | |||
"Most of the radioactive material released during the accident was discharged from the plant's stack. The Radiation monitor in that stack, however, was designed to register on:iy the nonnal low level* radiation releases associated with routine operation. During the accident the instnunent was off-scale, or | |||
'pegged. 1 14 Thus, emergency response officials could not be advised during the accident of how much radioactive material. | |||
was being released into the environment. | was being released into the environment. | ||
In fact, it will never be known how much radioactive material the le around 1hree t.Iile Islan were exposed emphasis added, Report p. 22). merely \\bile Footnote 14/cites testimony presented to the Subcommittee on Environment.7-Energy and Natural Resources, Footnote 15 states .in part: ''The problem caused by the inadequate moni taring capability was compounded by the fact that the first charcoal and particulate filters . . . were lost and never analyzed. . . . TI1e stacks monitor was bv no means the only inadequate measuring For example, | In fact, it will never be known how much radioactive material the le around 1hree t.Iile Islan were exposed emphasis added, Report p. 22). | ||
the diesel generator building and the service building. | merely | ||
The radioactivity which into= the system was thus exhausted unfiil:ererl | \\bile Footnote 14/cites testimony presented to the Subcommittee on Environment.7-Energy and Natural Resources, Footnote 15 states .in part: | ||
&J.d with inadequate monitoring into the Susquehanna River. In fact.,. Al Gibson,. the NRC official who is leading the radiological effects portion of the Corrnnission investigation stated 'most of the radiation:ra()nitors in the plant were unreliable' during the e.:arly part of the accident. (Citations to hear:.ing script omitted) Previous confident assertions that the populace of Pennsylvania had been: exposed to no more than the equivalent of several x-rays were apparently based upon dose meter reading set up aI"OtaJild "the vicinity of the plant after the on-set of the accident. | ''The problem caused by the inadequate moni taring capability was compounded by the fact that the first charcoal and particulate filters . . . were lost and never analyzed. | ||
Mr. Gibson. in Iliis briefing to the Commission noted the inappropriateness of relialnce rupon such i."'lStantaneou.s dose meters which do not provide cumulative exposure me3surements,nor the . period of See June 21, 1979 transcript at p *. 75. faren more surprising in light of the health reassurances prov1dedl. | . . . TI1e stacks monitor was bv no means the only inadequate measuring devi~e. For example, j | ||
by fonner H.E.W-Secretary Califano as to the increase in cancer rate around Harrisburg,. | |||
Pennsylvania, the NRC Summary of the | unfil tereci radioactive steam was vented totally unmonitored~. Of£-gasing from water on the floor of the diesel generator building was exhausted through the building ventilation system totally unfiltered and unmonito*red-Radioacti ve water leaked into the plant's industrial waste treatment system from pumps in the turbine building.,. the diesel generator building and the service building. | ||
*** | The radioactivity which l~ked into= the system was thus exhausted unfiil:ererl &J.d with inadequate monitoring into the Susquehanna River. In fact.,. Al Gibson,. the NRC official who is leading the radiological effects portion of the Corrnnission investigation stated 'most of the radiation:ra()nitors in the plant were unreliable' during the e.:arly part of the accident. (Citations to hear:.ing tran-script omitted) | ||
These data supported the conclusion that radioactive noble gases released to the atmosphere | Previous confident assertions that the populace of Pennsylvania had been: | ||
\vere the principal cause of exposure for individuals in the plant environs." NRC News Release Volume 5, 28, August 7, 1979 p. 7-The continuing nature of the ThIT risk is demonstrated. | exposed to no more than the equivalent of several c..i~est: x-rays were apparently based upon dose meter reading set up aI"OtaJild "the vicinity of the plant after the on-set of the accident. Mr. Gibson. in Iliis briefing to the Commission noted the inappropriateness of relialnce rupon such i."'lStantaneou.s dose meters which do not provide cumulative exposure me3surements,nor the | ||
by harrowing testi...-nony recently presented to President's Kemeny Connnission. | . period of exposure~ See June 21, 1979 transcript at p *. 75. faren more surprising in light of the health reassurances prov1dedl. by fonner H.E.W-Secretary Califano as to the increase in cancer rate around Harrisburg,. | ||
by Thomas Gerush.y, | Pennsylvania, the NRC Summary of the Office of Inspect:Eon and Enforcement Report states that: | ||
1rr. Gerusky stated that there exists "an _irruninent possibility" which will continue for at least four years that an eV<:1cuation of persons living nearby the crippled reactor Kill be necessary. | "during a five and one-half hour period from 1700 hrs. to 2238 on March 23 and a two-hour period from 0340 to 0540 on ,t..Iarch 29, no offsi te surveys were perfonned in the plume. Both of tl1.ese periods of time were \...-ithin the in:t.erval when the majority of the noble gases we!fe rel eased and \...-hen a plume \...-as well defi.I2ed because of sufficient wind speed and almos~ constant direction. | ||
The Pennsylvania official cited as contributir:g factors to the continuing hazards at TMI: 11 'millions of gallons' of water to treat,. there is krypton in 'megacurie above the water in the containment and that defense in depth 'would be gone' whem the reactor vessel is opened to remove damaged fuel. " Gerus1.)' | *** | ||
further observed that: "containment and the reactor vessel must be opened for. such an operation, and that. . the last defense, fuel cladding, isn't present on much of the fuel." (Gerusk-y,. | |||
Testimony as reported in Nucleonic Week,. p. 2, August 9, 1979.) It is now believed that the radiation levels above the containment floor range from 1-5 rem/hr. and levels in the water below the floor may be as high as the hundreds of rem/hr. l\ucleonic | These data supported the conclusion that radioactive noble gases released to the atmosphere \vere the principal cause of exposure for individuals in the plant environs." NRC News Release Volume 5, ~'umber 28, August 7, 1979 p. 7-The continuing nature of the ThIT risk is demonstrated. by harrowing testi...-nony recently presented to President's Kemeny Connnission. by Thomas Gerush.y, Pennsylvariia 1 s top radiation pro tee tion official. 1rr. Gerusky stated that there exists "an _irruninent possibility" which will continue for at least four years that an eV<:1cuation of persons living nearby the crippled reactor Kill be necessary. The Pennsylvania official cited as contributir:g factors to the continuing hazards at TMI: | ||
\\'eek p. 1, July 12,.. 1979. In light of the .NRC regulations on worker exposure, the delicate decontamination procedures will entail use of relay teams working inside contairunent for extrc::iely snort tir.:e periods. The ThlI cleanup program relying upon worker substitution procedures with each person given a couple of minutes to perform highl:.* cc::iplicated tasks can only increase the risks of further radiation release during this, phase of the TI*ll accident recovery. | 11 | ||
CONCLUSION For all the foregoing reasons, it is resepctfU:U.y* | 'millions of gallons' of water to treat,. | ||
requested that the Board pursue its stated objective of thoroughly exp1orL"'lg all. relevant safety issues pertaining to the commercial use of nuclear energy at Salem One in conjunction with the operation of a spent :fuel pool. eighty feet from this reactor. Respectfully Submti.tted,. | there is krypton in 'megacurie quantities~* | ||
STA\LEY C. VAl'f NESS, PUBLIC ADVOC.i\TE BY: KEITrl A. ONSOORFF , .V .I ASSISTA'IT BEPUTI PUBLIC .AiJ""j[OC.\.".fE lliITED STATES OF .AMERICA i-i'UCLEAR REGULATORY COl'*lMISSION Before the Atomic Safety and Licensing Board II?. the Matter of PUBLIC SERVICE ELECTRIC & GAS CO. (Salem Generating Station Unit #1). | above the water in the containment and that defense in depth 'would be gone' whem the reactor vessel is opened to remove damaged fuel. " | ||
Gerus1.)' further observed that: | |||
"containment and the reactor vessel must be opened for. such an operation, and that. . | |||
the last defense, fuel cladding, isn't present on much of the fuel." (Gerusk-y,. | |||
.... -**-:-.1: | Testimony as reported in Nucleonic Week,. | ||
: p. 2, August 9, 1979.) | |||
It is now believed that the radiation levels above the containment floor range from 1-5 rem/hr. and levels in the water below the floor may be as high as the hundreds of rem/hr. l\ucleonic \\'eek p. 1, July 12,.. 1979. In light of the .NRC regulations on worker exposure, the delicate decontamination procedures will entail use of relay teams working inside contairunent for extrc::iely snort tir.:e periods. The ThlI cleanup program relying upon worker substitution procedures with each person given a couple of minutes to perform highl:.* cc::iplicated tasks can only increase the risks of further radiation release during this, phase of the TI*ll accident recovery. | |||
* | |||
CONCLUSION For all the foregoing reasons, it is resepctfU:U.y* requested that the Board pursue its stated objective of thoroughly exp1orL"'lg all. relevant safety issues pertaining to the commercial use of nuclear energy at Salem One in conjunction with the operation of a spent :fuel pool. eighty feet from this reactor. | |||
,. : | Respectfully Submti.tted,. | ||
*' | STA\LEY C. VAl'f NESS, PUBLIC ADVOC.i\TE BY: | ||
KEITrl A. ONSOORFF , .V .I ASSISTA'IT BEPUTI PUBLIC .AiJ""j[OC.\.".fE | |||
lliITED STATES OF .AMERICA i-i'UCLEAR REGULATORY COl'*lMISSION Before the Atomic Safety and Licensing Board II?. the Matter of PUBLIC SERVICE ELECTRIC Docket No. 50-272 . | |||
&GAS CO. | |||
* | (Salem Generating Station Unit #1). | ||
0:.-RTIFICATE OF SER.VICE I hereby certify that the Colemans' response to the Board Question #4 in t.lie above captioned matter have been served upon* the service list by deposit in the United States mail at the past office in Trenton> NJ,. \-.i'"i. th proper postage t~ereon, this 21th day of August, 1979. | |||
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Revision as of 15:05, 21 October 2019
| ML18079B088 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/21/1979 |
| From: | Onsdorff K NEW JERSEY, STATE OF |
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{{#Wiki_filter:-":~~-. UNITED STATES OF AMERICA
- NUCLEAR .REGLJLA..1DRY CO~lMISSIO:N Before the Atomic Safety and Licensing Board In the Matter of Docket No. 50-272 PUBLIC SERVICE ELECTRIC & Proposed Issuance of .Amendment to GAS CO .. Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1)
INTERVENORS' , COL:BtA..t'l, RESPONSE TO BOARD QUESTION NUMBER FOUR: WAS TivIT A CLA.SS NINE ACCIDB\JT? STA.1'..iLEY C. VAi~ NESS PUBLIC ADVOCATE OF .NE'i JERSEY DEPARTMENT OF 'IHE PUBLIC ADOVCATE DIVISION OF PUBLIC INTEREST ADVOCACT P. 0. BOX 141 520 EAST STATE STREET TRENTON, NEW JERSEY 08625 KEI1H A. ONSDORFF ASSISTJ'u\lT DEPlITY PUBLIC ADVOCATE Attorney for Intervenors, Coleman 7 910 l l_oz.oc_
1HE PROPOSED A'-lrn:x 1D .-\PPEXDIX D, 10 CFR PART 5 0, APPEARS TO DEFTh""E A CLASS 9 ACCIDE:-IT AS A SEQUENCE OF FAILURES l\1UG! ARE MOR:= SEVERE TI-IA:.'i TI-IOSE l\1-UG! 11-IE SAFETI FEATURES OF 'IHE PI..fu\i! ARE DESIGNED 1D PREVBT. 'THE SEQUEi~CE OF F.AIWRES AT 1HREE :.ITI..E ISLAi\ID PRODUCED A BREAa-I OF T.-IE CO~TAIN
- tvlENf AND A RELEASE OF R<\DL\TION l~HIGl COULD NOT BE PREVENTED BY 1HE S...u:ETY FEA.TIJRES. W_t\S 'IHE OCCURRENCE AT 1HREE MILE ISI..Ai'ID . 'lliEREFORE A CLASS 9, .ACCIDE-.T?
The ~uclear Regulatory Cormnission in proposed~Zinnex A to Appendi..x D to 10 C.F.R. Part SO has defined Class KL.~e accidents as:
"successive failures :more severe "t:I'.an those postulated for the design basis for protective systems a.'1:d engineered sa:fety features. Tne:ir consequences could be severe."
36 F.R. 22852. Beyond this brief description, the Annex definition provides no qualitative
- measure for detennining the magnitude of environmental consequences which are deemed likely to flow from a Class Nine accident_ It would appear, therefore, that -r:he gravamen of the Class Nine Event is the magnitude of equipment and/or human failures which exceed the re.a:tor 1 s defense in depth safety systems. :t>!ost simply put, the differem:e between a CT.ass Eight and Nine Accident is found in the proposition_ that in all 1 credible' hypothetical accident ("Class Eight") scenarios, the plant's redundant safety systems activate as designed to ensure sufficient cooling water flow to the reactor at all times. Postulated accidents more severe than the engineered safety features in 'P\\'Rs prior to t.rarch ZS, 1979 were deened so rer::ote i.."1 probability that the !\"RC could license these plants for operations consistent \dth its statutory mandate to "provide adequate protection to the health a:.'lrl safety of the public." 42 U.S.C. 5 233Z(a). :\o more than a CJ.rosary farniliari"t;Y with the Commission's response to the Three ~lile Island
accident is needed, however, to lmow that the NRC has begun a substantial upgrading of PIVR *safety features to* pr~rent another uncontrolled. LOCA caused by loss of the main feedwater supply. See e.g. 1\UREG-0578, 1MI-2 Lessons Learned Task Force, Status Report and Short-Tenn Recorranendations. This latter regulatory action, when coupled with* the moratorium on the issuance of operating licenses pending adoption of t:hese Lessons Learned~ demonstrates quite convincingly .that the events at Three Mi.le Island constituted a Class Nine accident. Roger Mattson' s earlier comments to the. Commission aptly summarize the Staff's conclusions rt11at the 'Jn.IT-2 accident. surpassed the engineered safety features .at this ntl£:1.ear power reactor:
Ke saw failure modes, the likes of i..;hich have never been analyzed. -
Mattson, Nucleonics Week, April. 26, 197 9 p. 10; Transcript f.Iarcil'! 30, 1979 CoIIIlTiission Meeting. WAS 1HE RISK TO HE.i\LTI-f .AND S.t.\FEIY A.L'ID lliE EWIRON'ilENT ' REi\'KJTE IN PROBABILITI' OR 'EXTREMLEY LOW' AT THREE MILE ISI...Ai\m, AS 1HOSE TERMS ARE USED IN 1HE A~? The risk was real. It was of an tmdetermined lmagnitude :and may 1~*ell be continuing as efforts are initiated to unde:T.take the :most sensitive and extensive nuclear plant decontamination in history. The reality of the TMI risk to the public's heal th and safety \1;as recognized by the :Nuclear Regulatory Cormnission and the State of Pennsylvania. NRC Chairman Hendrie told Governor Thornburgh that it IlEight becor.ne necessary to evacuate the general population residing as far as twenty miles from the reactor site. House of Representatives Report No. '96-413, E.:.rtergency Planning Around U.S. :Nuclear Powerplants: Nuclear Regulatory Commission Oversight, p.2 August S, 1979. Subsequently, the Gvvernor recorrnnended that pregnant women mid families with children five years and younger in age, living within five miles of the plant leave this area. Acrai:n
°' , Rocrer 0
Mattson >
Director, Systems Safety Division succinctly articulated. the Staff~ s view of the 'IJ\IT danger when he reported* to the Conunission on the unfolding events durin~,
.
the accident:
"The latest burst didn't hurt raany people. I'm not sure why your not moving people. Got to say it. I have been saying it dmvn here. I don't know what we are protecting at this point. I think we ought to be moving people. Mattson, Nucleonics Week, April 30, 1979 p. 2 Transcript
- March 30, 1979 Corrunission Meeting.
However, while Mr. f.lattson sought to reassure the Commission that up to
- that time few people had been injured, the needed data base to support this opinibn was non-existent. The House Committee on Government Operations,
~uclear Regulatory Corrrrnission Oversight Report of .t\u.gust 8> 1979 cites the June 21, 1979 Corrrrnission meeting at which it received a "Briefing on Facts of TMI Radiological Sequence" to conclude:
"Most of the radioactive material released during the accident was discharged from the plant's stack. The Radiation monitor in that stack, however, was designed to register on:iy the nonnal low level* radiation releases associated with routine operation. During the accident the instnunent was off-scale, or
'pegged. 1 14 Thus, emergency response officials could not be advised during the accident of how much radioactive material.
was being released into the environment. In fact, it will never be known how much radioactive material the le around 1hree t.Iile Islan were exposed emphasis added, Report p. 22). merely
\\bile Footnote 14/cites testimony presented to the Subcommittee on Environment.7-Energy and Natural Resources, Footnote 15 states .in part:
The problem caused by the inadequate moni taring capability was compounded by the fact that the first charcoal and particulate filters . . . were lost and never analyzed.
. . . TI1e stacks monitor was bv no means the only inadequate measuring devi~e. For example, j
unfil tereci radioactive steam was vented totally unmonitored~. Of£-gasing from water on the floor of the diesel generator building was exhausted through the building ventilation system totally unfiltered and unmonito*red-Radioacti ve water leaked into the plant's industrial waste treatment system from pumps in the turbine building.,. the diesel generator building and the service building. The radioactivity which l~ked into= the system was thus exhausted unfiil:ererl &J.d with inadequate monitoring into the Susquehanna River. In fact.,. Al Gibson,. the NRC official who is leading the radiological effects portion of the Corrnnission investigation stated 'most of the radiation:ra()nitors in the plant were unreliable' during the e.:arly part of the accident. (Citations to hear:.ing tran-script omitted) Previous confident assertions that the populace of Pennsylvania had been: exposed to no more than the equivalent of several c..i~est: x-rays were apparently based upon dose meter reading set up aI"OtaJild "the vicinity of the plant after the on-set of the accident. Mr. Gibson. in Iliis briefing to the Commission noted the inappropriateness of relialnce rupon such i."'lStantaneou.s dose meters which do not provide cumulative exposure me3surements,nor the . period of exposure~ See June 21, 1979 transcript at p *. 75. faren more surprising in light of the health reassurances prov1dedl. by fonner H.E.W-Secretary Califano as to the increase in cancer rate around Harrisburg,. Pennsylvania, the NRC Summary of the Office of Inspect:Eon and Enforcement Report states that:
"during a five and one-half hour period from 1700 hrs. to 2238 on March 23 and a two-hour period from 0340 to 0540 on ,t..Iarch 29, no offsi te surveys were perfonned in the plume. Both of tl1.ese periods of time were \...-ithin the in:t.erval when the majority of the noble gases we!fe rel eased and \...-hen a plume \...-as well defi.I2ed because of sufficient wind speed and almos~ constant direction.
***
These data supported the conclusion that radioactive noble gases released to the atmosphere \vere the principal cause of exposure for individuals in the plant environs." NRC News Release Volume 5, ~'umber 28, August 7, 1979 p. 7-The continuing nature of the ThIT risk is demonstrated. by harrowing testi...-nony recently presented to President's Kemeny Connnission. by Thomas Gerush.y, Pennsylvariia 1 s top radiation pro tee tion official. 1rr. Gerusky stated that there exists "an _irruninent possibility" which will continue for at least four years that an eV<:1cuation of persons living nearby the crippled reactor Kill be necessary. The Pennsylvania official cited as contributir:g factors to the continuing hazards at TMI: 11
'millions of gallons' of water to treat,.
there is krypton in 'megacurie quantities~* above the water in the containment and that defense in depth 'would be gone' whem the reactor vessel is opened to remove damaged fuel. " Gerus1.)' further observed that:
"containment and the reactor vessel must be opened for. such an operation, and that. .
the last defense, fuel cladding, isn't present on much of the fuel." (Gerusk-y,. Testimony as reported in Nucleonic Week,.
- p. 2, August 9, 1979.)
It is now believed that the radiation levels above the containment floor range from 1-5 rem/hr. and levels in the water below the floor may be as high as the hundreds of rem/hr. l\ucleonic \\'eek p. 1, July 12,.. 1979. In light of the .NRC regulations on worker exposure, the delicate decontamination procedures will entail use of relay teams working inside contairunent for extrc::iely snort tir.:e periods. The ThlI cleanup program relying upon worker substitution procedures with each person given a couple of minutes to perform highl:.* cc::iplicated tasks can only increase the risks of further radiation release during this, phase of the TI*ll accident recovery.
CONCLUSION For all the foregoing reasons, it is resepctfU:U.y* requested that the Board pursue its stated objective of thoroughly exp1orL"'lg all. relevant safety issues pertaining to the commercial use of nuclear energy at Salem One in conjunction with the operation of a spent :fuel pool. eighty feet from this reactor. Respectfully Submti.tted,. STA\LEY C. VAl'f NESS, PUBLIC ADVOC.i\TE BY: KEITrl A. ONSOORFF , .V .I ASSISTA'IT BEPUTI PUBLIC .AiJ""j[OC.\.".fE
lliITED STATES OF .AMERICA i-i'UCLEAR REGULATORY COl'*lMISSION Before the Atomic Safety and Licensing Board II?. the Matter of PUBLIC SERVICE ELECTRIC Docket No. 50-272 .
&GAS CO.
(Salem Generating Station Unit #1). 0:.-RTIFICATE OF SER.VICE I hereby certify that the Colemans' response to the Board Question #4 in t.lie above captioned matter have been served upon* the service list by deposit in the United States mail at the past office in Trenton> NJ,. \-.i'"i. th proper postage t~ereon, this 21th day of August, 1979.
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