ML19206A295

NRC Responses to Environ Issues Raised in Limited Appearance Statements

ML19206A295
Person / Time
Site:	Crane
Issue date:	12/30/1977
From:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
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ML19206A294	List: ML19206A293 ML19206A295
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NUDOCS 7904190043
Download: ML19206A295 (24)

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3 UNITED STATES OF AMERICA NUCLEAR icGULATCRY CCMMISSION Before the Atomic Safet/ and Licensinc Board In the Matter of

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METT.0POLITAN EDISON CCMPANY,

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00CXET No. 50-320 et al.

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(Three Mile Island Nuclear

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Generating Station, Unit

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No. 2)

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NRC STAFF'S RESPONSES TO ENVIRONMENTAL ISSUES RAISED IN LIMITED APPEARANCE STATEMENTS The following is a list of issues raised by the limited appearance s ta tements :

Issue Person Makina Statement (Transcript pages)

Energy Conservation Not' Considered Carl Jarboe (195-214)

Mary Swann (2575-2579)

Milton Lowenthal (2533-2701)

Mary Douglas (2702-2704)

.ed Water Temperature in Carl Jarboe (195-214, 2745-2755) i

..zuehanna River Caused by Mike Jones (2550-2537)

Plant Credibility and Use o' Rasmussen Carl Jarboe (195-214, 2745-2755)

Report Larry Arnold (2704-2744)

Decommissioning Costs Are Too Carl Jarboe (195-212, 2725-2755)

High to Make Nuclear Power Bob Jenison (233-243)

Feasible, Methods Used for Mary Douglas (2702-2704)

Decommissioning are Unsafe Larry Arnold (2704-27aa)

There is no Safe Method for Oavid Levit (221-228)

Transportation of Wastes rv g-790419 0 0'/3

. Issue Person Makinc Statement (Pages) i Higher Lranium Costs Will Be Carl Jarboe (195-214, 2745-2755)

Passed Cn to Consumers.

Sob Jenison (233-243)

Applicant Has Not Considered Larry Arnold (2704-2744)

Escalating Uranium Costs Uranium Availability Insufficient Carl Jarboe (2745-2756) for Lifetime of Plant What is Plant's Proposed Carl Jarboe (195-214, 2745-2756)

Capacity Factor Full Nuclear Fuel Cycle is not Judith Johnsrud (234-237)

Considered in Plant Licensing Carl Jarboe (195-214, 2745-2756)

Proceedings Long-Term Effects of Low Level Eli:abeth Martham (216-220)

Radiation on the Area's Abigati Jarboe (237-238)

Population Power Produced by This Plant Bob Jenison (238-243) to be Sent to Other Areas

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Alternative Energy Sources are Milton Lowenthal (2SE8-2701)

Available, So Why Use Nuclear Cost-Benefit Considerations Used Larry Arnold (2704-2744) in Evaluation Ignore Too Many Important Costs Will Routine Sampling for Carl Jarboe (195-214, 2745-2756)

Radioactivity be Cone?

Constitutionality of Price-John Simon (189-195)

Anderson Act.

Carl Jarboe (195-211)

Price-Anderson Act Relieves Ecb Jenison (228-243)

Plant Cwners of Financial Milton Lowenthal (2588-2701)

. Responsibility for Accidents Larry Arnold (2704-2744)

Dangers frca Accidental Releases Carl Jarboe (195-212, 2745-2756) of Radioactivity Mike Jones (2580-2587)

Auxiliary Control Room Independence Carl Jarboe (198) from Main Control Room Consideration of Waste Dis;osal Carl Jarboe (200) in Licensing of 7his Plan:

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. Issue Person Making Statement (Pages)

Adequacz of Emergency Plans David Levit (223)

Larry Arnold (2717, 2713)

Testing of the ECCS Mike Jones (2583)

Adequacy of Fire Protection Mike Jones (2534)

Measures Larry Arnold (2729,2730)

Carl Jarboe (2750)

Adequacy of Security Measures Mike Jones (2584,2585)

Carl Jarboe (2753)

Assurance That all NRC Regulations Larry Arnold (2730, 2731)

Have Been Adhered to Radiation Effects on Employees Carl Jarboe (2749,2750)

NRC STAFF'S RESPCNSES TO ISSUES RAISED IN LIMITED APoEARANCE STATEMENTS 1.

Conservation Section 3.3.2 of the Final Supplement to the Final Envirormental Statement (FSFES) dated December 1976 discusses the impact of energy conservation as follows:

Recent energy shortages have focused the Nation's attention on the import'acce of energy conservation as well as measures to increase the supply of alternati se energy sources. The need to conserve energy and to promote substitution of other energy sources for oil and gas have been recommended by the Report to the President on the Nat'on's Enerev Future as major efforts in regaining national energy set?-sufficiency by 1980.

There was a slowdown in growth in the apolicant's service area in 1974 and 1975 as indicated by the data in Table 3.3.

Summer ceak load declined from 5450 MW in 1973 to 5C52 MW in 197a and 5157 in 1975.

Energy requirements declined from 30,350 GWh in 1973 to 29.931 GWh in 1974 and 29,727 GWh in 1975. While conservation was listed among cne factors contributing to slower grcwth, the a;plicant further ciced the econcmic recession and the impact on new home construction as other factors.

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4-Historically, utility rate structures were designed to encourage con-sumption of electricity by using the declining block rates, whic'1 reflected the declining average cost of furnishing additional kilowatt hgers of electrical energy to each customer. Until recently, the ecdncaic log 1c for declining block rates was never seriously disputed.

Today, however, under conditions of increasingly scarce fuel resources, declining bicck rates, by lowering the price of each additional kilowatt hour, tend to encourage greater use of electricity by individual consumers and also to encourage individual consumers to use more and more electricity instead of other energy sources.

The most commonly mentioned alternatives to declining block rates to demand for electricity are peak load pricing, flat rates., and increasing block rates.

According to the applicant, the Gpu System has made it a practice to design rates which are cost F' sed and include costs associated with servicing customers and costs associated with volume of energy supplied. Costs are recovered through a minimum charge for residen-tial ra _as which do not state demand charges.

In rate schedules with both energy and demand charges, rates are developed so that the smail customer's charges are stated separately. The costs are incorporated into the demand and energy charges for larger customers. The demand costs are usually spread uniformly across the energy blocks in nates where there is no stat 2d demand charge. Cemand costs are recovered by a demand charge where secarate energy and demand rates are provided.

Energy costs are designed to be recovered through base rates in the form of separate energy charges. An energy adjustment clause provides for changes in energy costs that are related to fuel costs.

The applicant provides residential customers with several experimentai time-of-day rates on an optional basis. This serves as part of the applicant's load management program througn.iich the acclicant is seeking more informa-ion on wnether to e::end time pricing techniques and seasonal differential pricing. Othec ex;eriments include peak load pricing ir conjunction with Federal Energy Administration and State of New Jersey to ascertain the demand price relationship for peak lead pricing in residential pcwer consumption.

The applicant has not conducted any elasticity studies that would deter nine the imoact of recent rate increases on the demand for electricity and has cited icw industrial activity and hign unemploy-ment following the oil embargo for the general damoened growth.

In addition to price and conservation, the demand for electricity is impacted by sucn other factors as (1) cnanges in the regional and national econcmy; (2) the substitution of electricity for scarce fuels; (3) growth in population and households; (4) tecnnological change affecting suostitute scurces of energy, efficiency in :ne use NTQ

. of energy resources, and the development of new uses of electrical energy; (5) market forces affecting the demand for censumer invest-ment or durable goods which recuire electricity to operate; and (5) chsnges in consumer values, attitudes and sucn practices as may be aff cted by laws, regulations or taxes.

In the face of such a com-plexity of causal forces it is exceedingly difficult to factor out tne extent to which price changes alone would affect the demand for electricity in the applicant's service area. The uncertainty exists in analyzing historical data and is even grcater in forecasting future developments because of the perturbations of outTook fostered by the energy crisis and decisions yet to be made by customers and induscrial and government agencies in relation to reducing demand for scarce fuels or developing additional reserves or new sources of energy to substitute for scarce fuels.

Load shedding is an emergency measure to prevent system collapse when peak demand placed upon the system is greater than the system is capable of providing. This measure is usually not taken until all other measures are exha.usted. The Federal Power Ccemissien's report on the major load shedding that occurred during the Nurtheast Power Failure of November 9 and 10,1965, indicates that reliability of service of the electrical distribution systems should be given more emphasis, even at the expense of additional, costs.

This report identified several areas that are highly impacted by loss of power, such as eJevators, traffic li~ hts, subway lignting, prison and g

communication facilities.

It's the serious impact on areas such as these that result in load shedding as only a temccrary method to overcomo a shortage of generating capacity during an emergency.

Load staggering has also been considered by the staff as a possible conservation measure. Sasically this alternative involves snifting the work hours of industrial or commercial firms to avoid diurnal or weekday peaks. However, the sta ff considers

.e interference wi th customer and worker preferences as well as productivity to be of significant impact to make such proposals of questionable feasibility.

For interruptible load contracts to be effective in system planning, the load reduction must be large enougn to be effcctive in system stability planning. Thus, this type contract is primarily related to industrial customers. At the present time the applicant nas two customers under contracts classified as curtailable service. The contracts are ecual to 24.3 megawatts and have been included in the

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applicant's forecas:s. The acceptability of interruptible lead con-tract: to industrial customers depends uoan balancing the potential economic loss resulting frcm unannounced interruptions against the SE -2E7

-S-savings resulting from the reduced price of electricity.

If the frequency or duration of interruptions increase as a result of insufficient installed capacity, the custcmers will convert to a normal industrial lead contract.

m h6ne of the above measures can be cc7sidered as a viable alternative for required additional capacity and does little to solve the energy shortage.

2.

Increased Suscuehanna River Water Temeerature The discussion below of the water quality criteria applicable to the Susquehanna River in the vicinity of the site as established by the Ccm-monwealth of Pennsylvania is taken frca Section 5.3.3 of the FSFES.

The NRC Staff's recent assessment of the environmental imoact based upon the water quality critaria established by the Commonwealth of Pennsylvania in its revised 401 certification for Three Mile Island, Unit 2, issued November 9,1977 (Attached as Appendix A) is attached as Aapendix 3.

The Commonwealth of Pennsylvania has established water quality criteria applicable to Suscuehanna River in the vicinity of the site to protect the water uses which were tabulated in Section 2.2.2.

The applicable criteria are listed below (Pennsylvania Code, Title 25, Part I, Environmental Resources, Chapter 93, Water quality Criteria):

5 93.4 General water quality criteria.

(a) Water shall not contain substances attributable to municipal, industrial or other waste discharges in concentracion or amcunts sufficient to be inimical or hannful to the water uses to be protected or to human, animal, plant or aquatic life.

(b) Specific substances to be controlled shall include, but shall not be limited to floating debris, oil, scum and other floating materials, toxic substances and substances which produce color, tastes, odors or settle to form sludge deposits.

I 93.5 Specific water cuality critaria.

pH - Not less than 6.0 and not more than 3.5.

Dissolved oxygen - Minimum daily average 5.0 mg/l', no value less than

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4.0 mg/1.

- For the epilimnion of lakes, ponds, anc inccunements,

minimum daily average of 5.0 mg/1, no value less than 4.0 mg/1.

G'd-?ES

. Iron - Total iron not more than 1.3 ag/1.

Temperature - Not more than a 5'F rise above ambient tempera *.ure of a maximum of 87*, whicnever is less; not to be changed by more than 2*F during any cne-hour period.

r$Dissolved Solids - Not more than 500 mg/l as a monthly average value; not more than 750 mg/l at any time.

Bacteria - The fecal coliform density in five consecutive samples shall not exceed a geometric mean of 200 per 100 ml.

Total Managanese - Not more than 1.0 mg/1.

Pennsylvania Industrial Regulations (Pennsylvania Code, Title 25, Environmental Resources, Part I, Article 2, Chapter 97, Industrial Wastes) place the following additional restrictions on the addition of waste heat:

i 97.82 Allowable Discharges (a) The heat content of discharges shall be limited to an snount which could not raise the temperaL're of the entire stream at the coint of discharge 5*F above ambient temperature or a maximum of 37'F, whichever is less, nor change the temperature by more than 2 F during ary one-hour seriod, assuming complete mixing, but the heat content of discharges may be~ increased. or further limited ahere local conditions *would be benefited thereby.

(b) If downstream circumstances warrant, the specific area in which the temoeraturo may be artificially raised above 37'F or greater than 5'F above ambient temperature or by more than 2'F during any one-hour period shall be prescribed.

Since ambient temoerature may exceed 37'F cccasionally, caragra:h (b) above may require the prescription of the area L wnich temperature may be elevated fur the r.

Pursuant to the Federal Water Pollution Centrol Act (RiPCA), on January 31, 1975 Pennsylvania has issued a 201 certificat'en indicating that in their evaluation these water quality criteria will not be violated by the procosed plant operation.

In accordance with terms of the Second Menorandum of Understanding Regarding Implementation of (:ertain NRC and EPA Resconsibili-ties, the staff has accepted Pennsylvania's determination.

The FWPCA calls for achievement by July 1,1977. of effluent limitations requiring the acclication of the best practicable control technology currentiv available. By July 1,1983, the act calls for the achievement of effluen:

limitations recuiring acclication of tra Ses: availabl e technoicgy econon-ically achievable. The effluent limitat.ons for these " technologies" are e-

8 defined in Title 40 CFR Part 223 - Steam Electric Power Generating c int o

Source Category. The only difference in the two technologies apolicable to nuclear stations is the recuiremer. for closed cycle cooling by the later date. Since TMINS will operat< m closed cycle cooling, the 1983 requirement regarding thermal dischergt can be met. The -equirements for the 1933 deadline are reproduced in Tab e 5.2.

r1 FWPCA (Section 302) also requires that an,< other limitations be placed on the operation of the facility which are necessary to protect and propagate a balanced indigenous population and to protect other users. Again, in accordance with the Second Memorandum of Understanding, the issuance by the State of Pennsylvania on December 30, 1974 of a permit under Section 402 of the NPDES is accepted as a determination that the requirement for effluent limitations will be met.

The effluent limitations imposed by the NPDES include a valoe for free available chlorine but do not include a value for total residual chlorine (see Table 5.2).

The toxicity of combined forms of chlorine has been recognized and limitations have been reccmcendec for total residual (Water Quality Criteria,1972. A report of the Committee on Water Cuality Criteria, National Academy of Sciences, National Academy of Engineering, Washington, DC,1972). The recccmended limitation for total residual chlorine, applica-ble to receiving water rather than to the effluent, is as follows:

"Acuatic life snculd be protected where the concentration of residual chlorine in the receiving system does not exceed 0.003 ag/l at any time ur place.

Aquatic organisms will toferate short tem exposure to Mgh levels if chlorine. Until more is known about the short term effects, it is

?cem-mendd that' total ' residual chiarine should not exceed 0.C5 mg/l fa a period up to 30 minutes in any 2t-hour period."

Based on experience with Unit 1 (see Section 3.3.2) a free % 'he concen-tration of 0.5 mg/l as allowed by the :: emit might corres::end r. total chlorine residual as high as 1.5 mg/1. However, it was not:t W.

oN i3C with Unit 1 has shown the actual total residual to exceed a ce s -qtraf.f on of 0.2 mg/l only rarely. Oilution with river flow and furcher ci.'mical reduction of chlorine residuals will reduce the concentrations prtduced at Unit 2 below the recommended value of 0.05 mg/l within a short distance of the outfall.

The apolicant has not been totally successful at meeting the objective of controlling biological growth within plant systems and is likely to change the chlorination program (see Section 3.3.2).

Therefore, staf" recermended that monitoring of total residual chlorine in the plant discharge be perfor*ed until the concentrations recuired for optimal chlorination can be established and evaluated. If it is necessary to operate at the :er-mitted level of chlorination, -hen the acclicant should monitor catal residuals in the river to determine the extent of.the region in whicn concentration exceeds the value reccmmended to protect'acuatic life.52-270

-9 pennsylvania has established a criterion for sulfate concentration of 260 mg/l for scme of their water bodies but has not made it aoply to the lower Susquehanna River. This is probably because ambient concentrations only rarely approach this level. As cevelopment of the river for steam electric power production and othar uses continues, it is likely that additional considerat. ion will be given to the discnarge of sulfate. Based on average river bonditions, station operation will increase sulfate concentration by less than 0.4 mg/1. For the conditions which prevailed when the highest ambient sulfate concentration was reported (2C4.3 mg/1, see Section 2.4.3),

operation could have increased sulfate concentration by as much as 3.3 mg/1.

These increases should not have a noticeable effect on downstream users under present conditions.

Cther proposed uses of chemicals will hava an insignificant effect on water qual i ty.

3.

Credibility and Use of Rasmussen Recort As stated in Section 11.1.7.1 of the FSFES, the staff's overall assessment of the Reactor Safety Study is that it provides an objective and meaningful estimate of the probable risks associated with the aceration of presen:-day light-water nuclur cowce plants in the U.S.

The staff believes the study's methodology as it Wies to the calculation of both accident probabilities and consecuences has received a broad and increasing endorsement by the informed scientific community.

It should be noted that the study was referenced as a source of data and did not by itself form the basis _for the

. staff's eya10ation of the'consecuences of postulated accidents in the Draft Supplement to the Final Environmental Statement or the Safety Evaluation Report.

4.

Deccccitsionina As discussed in Section 9.5 of the FSFES, the staff's position regarding decommissioning of the Three Mile Island ?!uclear Station, Unit !!o. 2, is as follows :

In the long-term, beyond the useful life of the proposed genera:ing station, this site may continue to be used for generation of electrical energy. At the termination of such use, the land areas occupied by the r.uclear facilities would be removed from oroductive use, unless de-commissioning measures included removal of all radioactive ecui;xnent are adopted. Although the details of decommissioning may not be worked out for several years, the various alternatives should not be diminished by the proposed action of licensing oceration. The range of beneficial uses of the site by future generations will not be curtailed, providec the applicant has the cactb:1;ty for removing all radicactivel / con-

• 2minated equiptent if and when that step may be desirable.

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. NRC regulations prescribe procedures whereby a license may voluntarily surrender a license and obtain authority to dismantle a facility and dispose of its component parts.

Such authorization would normally be sought near the end of the nuclear plant's useful life.

In any event, the Cc= mission requires that a qualified licensee maintain valid licenses appropriate to the type of facility and materials involved.

Under current regulations, the Oc mission generally requires that all quantities of source, special nuclear, and by-product materials not exempt frcm licensing under Parts 30, 4C an 70 of Title 10, Code of Federal Regulations, either be removed team the site or secured and kept under surveillance.

To date, experience has been gained with decommissioning of six nuclear electric generating stations wnich are operated as part of the Atcmic Energy Ccemission's power reactor development program: Hallam Nuclear Power Facility, Piqua Nuclear Power Facility, Soiling Nuclear Superheat Power Station, Elk River Reactor, Carolinas-Virginia Tuce Reactor, and Pathfinder Atomic Power Plant. The last two facilities were licensed under 10 CFR Part 50; the others were Atomic Energy Ccamission-cwned and opci cued under the provisions of the Part 115.

Several alternative andes of decc=missioning h. ave been experianced in those cases. They may be summarized generally as fcur alternative levels of restoration of the plant site, each with a distinct level of effort and cost.

In deccmmissioning at any level, ec."ncmically salvageable equi; ment and all reactor fuel elements would be, 9ved, some equipment would be decontaminated, and wastes of the type normally shipped during ooera-tion would be sent to waste repositories.

In addition, :he respective levels of restoration would involve the follcwing measures:

Lowest Level, There would be minimal dismantling and relocation o f equipment. All radioactive material would be sealed in containmen; structures (primarily existing ones), which would require perpetual, continual surveillance for security and effectiveness.

Second level. Some radiaactive equipment and materials would be moved into existing containment structures to reduce the extent of long-term contamination. Surveillance as in the lowest level would be required.

Third level. Radioactive ecuipment and materials would be placed in a contair. ment facility approaching a practically minimum volume. All unbound contamination would nave been removed. The con tai r. ment struc-ture would be designed to need minimal perpetual maintenance, surveillance, and security.

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Hichest level. All radioactive equipment and materials would be re-movec frca tne site. Structures would be dismantled and ciscosed of onsite by burial or offsite to the extent desired by the tenant. No fur;her Commission license would be required.

Estimated costs of deccr :sf oning at the lowest level are about 51 million plus an annual ma:ntanance charge on the order of $1C0,C00.

Complete restoration, 'aciuding regrading, has been estimated to cost

$70 million. Hence, there is wide variation, arising frca differing assumpticns as to level of restoration. At present land values, it is not likely that consideration of an ecor mic balance alone would justify a high level of restoration.

planning required of the apoli-cant at this stage w'.ll assure, however, that variety of choice for restoration is maintained until the end of useful plant life.

Units 1 and 2 of the Three Mile Island Nuclear Station are designed to operate for about 30 years, and the end of their useful life will be approximately in the year 2008. The a;:plicant has made no firm plans for decommissioning but assumes that the following steps would be taken as minimum precautions for maintaining 3 sa'e cor dition.

1.

All fue.1 would be removed from the facility and shipped offsite for dis;:osition..

2.

All radioactive wastes - solid, liquid, and gas - would be packaged and recoved from the site insofar as practical.

A decision as to whether the facility would be further dismantled would require an economic study involving the value of the land and scrap value versus the cost of ccmplete demolition and removal of the ccmolex.

However, no additional work would be done unless it is in accorcance with rules and regulations in effect at the time.

In addition to personnel required to guard and secure the facility, concrete and steel would be used to prevent ingress into any building, particularly the radioactive areas.

The applicant's position as stated in Section 11.1.9.1 is :

Since we do not anticipate having to decommission m!-2 until the year 2010, it is difficult to 5 : rec:dt regulatory requirements which may be imposed at tnat time. There wili be many changes in technology and sccial concerns between 1975 and 2010 which will influence plans for decommissioning. The Apolicant is convinced that wnen the time comes to decommission TM:-2, this activity will be acccmolis"ec in a socially, environemntally, and econcmically acceptable manner consistent witn the regulatory recuirements in effect at tnat time."52-273

. 1.

Title 10, " Atomic Energy,* Code of Federal Regulations, ? art 50, licensinc of Production and Utilization Facilities, Section 50.32,

" Applications for Terminations of Licenses.

• 2.0 Atomic Energy Clearing House, Congressional Information Bureau, Inc., Washington, CC,17(6):42, 17(10):4, 17(13):7, 16(35):12.

Financial aspects of decommissioning are discussed in Section 20 of Supplement No. I to the SER, pertinen parts of which are quoted below.

"In estimating the costs of permanently shutting down the facility, the applicant considered three alt rnatives: dismantling, ent;mb-ment, and mothballing. Dismantlinu the unit, whicn involves removing all fuel assemblies, radioactive fluids and waste, and other materials having radioactive activities above unrestricted activity levels [and apparently dismantling the turbine building and miscellaneous equipment], is estimated to cost approximately

$117 million. Expenditures for entombment are projected to be 345 million initially, with an annual surveillance expense of 563,000 thareafter. Entombment consists of sealing all remaining highly radioactive components witnin a biologically secure structure after having removed all fuel assemolies and radioactive fluids and waste. The estimated expense of putting the facility in a state of protective storage, or mothballing the unit, is 56.3

.million, wi.th an additi.cnal expenditure of $200,0C0 annually for radiation monitoring, environmental surveillance, and appropriate security procedures. All deccmmissioning costs are stated in.1975 dollars.

" Metropolitan Edison, Jersey Central, and Pennsylvania Electric expect to cover all operating ex;enses, including taxes, and interest payments through revenues generated frem their system-wide sales of electricity. The owners nave consistently exhibited the ability to cover all operating expenses as evidenced by the revenue to expense ratio presented in Table 20.3.

The staff assumes that shutdown and subsequent maintenance costs sill eitr.er be expensed in the year incurred or amortized over a pericd of years, depending on the rate-making policy,of the regulatory authorities.

"In accordance with the regulations cited in the Safety Evaluation Report, there must be reasonacle assurance that the owners can obtain the necessary funds to cover :ne estimated costs of the activities contemplated under the license. Based on our analysis, we have concluded that Metro:olitan Ecison Comcany, Jersey Central Power and Light Company, and Pennsylvania Electric Company satisfy this reasonable assurance standard and, tnerefore are financially qualified to operate and, if necessary, shut dcwn and safely main-tain Three Mile Island Nuclear Station Unit 2.

Cur conclusion is 5%-274 MW.

supported by the following factors as discussed abovs (1) the ability to earn revenues sufficient to cover all operating expenses, including interest payments and taxes; and (2) One projected out;ut or lower unit cost electricity from this facility, as compared with the utilities' present average price of p}ectricity."

5.

Transoortation of Wastes The 2nvironmental eff ects of the transportation of radioactive waste material are shown in Table 5.3 and discussed in Secticn 5.4.1.a of the FSFES.

Transoortation of Radicactive Material The transportation of cold fuel to a reactor, of irradiated fuel from the reactor to a fuel recrocessing plant, and of solid radioactive wastes frca the reactor to burial grounds is within the scope of the NRC report entitled,

" Environmental Survey of Transportation of Racioactive Materials to and from Nuclear Power Plants." The environmental effects of such transportation are summarized in Table 5.3.

TABLE 5.8 ENVIRONMENTAL IMPACT OF TRANSPCRTATICN OF FUEL AND WASTE TO AND FROM ONE LIGHT-WATER-CCCLED NUCLEAR POWER REACTCRa Normal conditions of transpo.rt Heat (per irradiated fuel cask in transit) 250,C00 Stu/hr Weight (governed by Federal or State restrictions) 73,000 lbs. car truck; 100 tons per cask per rail car Traffic density

<1 per day Rail

<3 per month Exposed population Estimated Range of doses Cumulative dose to number of to exposed exposed population persons individuals (man-rems per reactor yr)"

(millirems per reactor yr)

Transportation Worker 200

0. 01 to 300 4

General Public Onlookers 1,100 0.003 to 1.3 Along Route 600,000 0.CC01 to 0.C$

3 Accidents in trans; ort d

Radiological effects imali Common (nonradiological) causes I fatal injury in 1C0 reactor years; 1 nonfatal injury in 10 reactor yecrs;

$457 property damage oer reactor year r,d4 y,~' D

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. 3 Cata suoporting this table are given in the Ccmmission's Environmental Survey of Transportation of Radioactive Materials to and from Nuclear ower Plants, WASH-1238 Cecember 1372, and Supp. ~, NURE3 75/C33, April 1975.

bThe_Jederal Radiation Council has recommended that the radiation doses from'all sources of radiation other than natural background and medical exposures should be limited to 5,CC0 millirems / year for indivicuals as a result of occupational exposure and should be limited to 500 millirems / year for individuals in the general population. The dose to indivicuals due to average natural backgrcund radiation is about 102 millirems /yoar.

CMan-rem is an expression for the summation of whole-body doses to individuals in a group. Thus, if each member of a poculation group of 1,000 ceople were to receive a dose of 0.001 rem (1 mill f rem), or if 2 people were to receive a dose of 0.5 rem (500 millirems) each, the total man-rem in each case would be 1 man-rem.

dAlthough the environmental risk of radiological effects stemming from transportation 'ccicents is currantly incapable of being numeri". ally quartified. the risk remains small regardless of whether it is being applied to a single reactor or a multi-reactor si e.

Transportation accidents involving radioactive materials are covered in

.Section 7.2 as follows:

TRANSp0RTATICN ACCICENTS INVOLV!NG RADICACTIVE MATERIALS The transportation of cold fuel to the plant, of irradiated fuel from the reactor to a fuel reprucessing plant, and solid radioactive wastes from the reactor to burial grounds is within the scope of the NRC report entitled,

" Environmental Survey of Transportation of Radioactive Materials to anc from Nuclear Power Plants," Cecember 1972. The environmental risks of accidents in transportation are summarized in Table 7.3.

Table 7.3.

Environmental Risks of Accidents in Transport of ~uel and Wasta to and from a Typical Light-Water-Cooled Nuclear Power Reactor Environmental Risk Radiological effects Small*

Common (nonradiological) causes 1 fatal injury in 100 years; I nonfatal injury in 1C years

$475 procerty damage ;e yea' tAltnough the environmental risk of radiological effects stemming from transacrtati:

accidents is currently incapaole of ceing numerically cuantified, the risk remains small regardless of whether it is being a;olied to a single reactor or a multi-reactor site.

F r7 9 P;C d4 ~au

. 6.

Uranium Costs, Uranium Availaoility. and the Nuclear Fuel C'/c' ?

Section T.5.3 of the FSFES contains a discussion of these issues.

Further discussions of the environmental effects of the uranium fuel cycle is found in Section 5.a.3 and additienal discussion of the environmental costs of the uranium fuel cycle is found in Section 10.6.

These are lengthy discussions and, therefore, not repeated here. Copies of the FSFES are available at 59.75 for printed copies and $3.00 for microfiche from the National Technical Information Service, Springfied, Virginia 22161.

7.

Low Level Radiation Section 5.4 of the FSFES contains a discussion on radiological impacts.

Again, tnis is a lengthy discussion and will not be repeated here.

8.

Power Sent to Cther Areas The following discussion of the applicant's service area and regicnal relationships is found in Section 3.2 of the FSFES.

Acolicant's Service Arta The General Public Utilities Corporation' with tne subsidiaries of the

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Metropclitian Edison Ccmcany, the Pennsylvania Electric Company, anc the Jersey Central Power and Light Comoany sucalies electricity to an area of about 2a,0C0 square miles in parts of Pennsylvania, and New Jersey with a population of about 4,000,000 (s ee Figure 3.1 ).

Metropolitan Edison Ccmpany cperates in an area of 3,274 square miles in eastern Penrsylvania. ?ennsylvania Electric Company supolies an area of 17,600 squcre miles in western, northern, and ;outh central Pennsylvania with Jersey Central Power and Light Comoany operating in an area of 3,255 square miles in north central, east central, northwestern and sestern New Jersay.

Recional Relationshios The General Public Utilities (GPU) system service area is incluced in the Federal Power Commission (FFC) Northeast Power Survey Region and lccated within the FPC's oower sucoly area, PSAS.

The GPU system is a member of tne Pennsylvania-New Jersey-Maryland Interconnections (PJM) whicn is a formai power pool that serves three-cuarters of Pennsylvania, most of New Jersey, more than hal f of Marylanc, a scali part of Virginia, and all of tne 2istrict of Coltabia, and Celaware.

In adcition to coordination of planning, the rc d4.yy/

ccmpanies in PJM conduct econcaic discatch within the ;ool and share in any load curtailment or voltage reduction if conditions warrant it.

r; The applicant is a member of the Mid-Atlantic Area Coordination Council (MAAC). The ccmcanies which ccmcase PJM are also included in the memberahic of MAAC. MAAC is concerned cricarily with reviewing and evaluating plans frca the standpoint of bulk power reliability.

9.

Alternative Erecev Sources Section 9.2 of the FSFES and Section XI.A.2 of the Final Environmental Statement (FES) dated Cecenter 1972 discuss alternative energy sources.

ALTERNATI'/E ENERGY SCURCES A'1D SITES In the following section frca the FES of Decem:er 1972, the staff evaluated the alternative energy sources and sites. Alternative energy sources considered were hydrcelectric potential, fossil-fired generating plants, including oil, natural gas and coal-fired plants, and the purchase of pcwer frcm other ccmpanies. The applicant's site selection was also evaluatad.

There have been no major changes in the information relied ucon by the staff for the previcus avaluations that would materially alter the consideration of alternative energy sources and alt'ernative sites at the o,~. 3 rating license review stage. No feasible alternative ep.ergy source, repuirin.g capital investment as well as operating and fuel cost is econcmically competitive with TMINS-2.

XI. ALTERNATIVES TO THE PCOPOSED ACTION AND COST-SENEFIT ANALYSIS OF THEIR EN1!RC.< ENTAL EF:ECTS The Applicants have provided a discussion of alternatives and a cost benefit analysis in their Environmental Report.

In many cases the staff found the Apolicants' estimites adequate and thesa were used in the discussion.

In other cases the estimates were made irdependently.

A.

SUMMARY

OF ALTERNATIVES 1.

Abandonment of The Proiect Abandonment of the project is an alterrative to be considered in evaluating the imcact of both plant construction and subsecuent plant operation.

In the case of Three Mile Island Station we have concluded that abandenrant of the project is not a cracticable alternative for the following reasons:

Construction of the Station has progressed to the point wnere envrionmental impact associated with this pnase has already been absorbed.

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. The identifiable environmental costs of clant oceration are insignificant when compared with the unsalvageable cost of r*;

S350 million involved in abandonment (see 3.1. below).

2.

Alternative Power Sources a.

Purchase of Power The Applicants state that there was and is no possibility of a power purchase in an amount equivalent to the capacity and en?rgy of the TMI project.

The staff notes that while pCM pool reserves appear substantial (Table 22), such pool reserves do not generally include provisions for long term firm power transactions.

In addition, projected PCM reserves are uncertain, bec:.se of the possibility to delay in new generating capacity now under construction. The uncertainties of maintaining construction schedules and the steady exten-sien of demand on this area make decendence en this external baseload power source highly questionable.

In addition, the Applicants state that no nearby public or private utilities outside of the PCM ; col have large amounts of power for sale on a long term continuing basis.

b.

Al ternative betho'ds of Genec.atiha Power Coal Fired. Base Load Generation Economic studies performed by the Applicants ig 1965 indicated that mine mouth coa' cad generation in western Pennsylvania provided short term economic advantages over an equivalent nuclear unit located in the eastern portion of tne state. Based on these studies a decision '.a made to proceec with construction of the Homer City unit, a coal-fired mine month generating plant in western Pennsylvania.

In 1965 the Applicants re-examined the econcmics of additional nuclear generation out this time in comparision wita 4 coal-fired unit at the same site as would be selected for the nuclear unit. The Applicants state that there were two reasons for this shift in the basis of comparison:

(1 ) The particularly attractive conditions aoplicable to the Mcmer City plant were no longer available as an alternative, and (2) Coal sucoliers had suggested that fuel might be delivered to the GpU site for 20 cents per million Stu, although this was not a firm offer of sucn a supply.

$5k:

.C.?".

. Even the basis of this icw delivered fuel price, a nuclear unit installation was found to be advantegeous.

Ic Ncvember 1966, the decision was mace to proceed with a nuclear installation for service in 1971, in December 1966, the TMI s,ite was selected for this installation.

r; A ccmparison of a c:al-fired plant with the Three Mile Island Nuclear Plant is given in part B of this section.

Gil-Fired. Base Lead Generation The Applicants did not consider this al:ernative in the 1965-66 econcmic studies, because of tne relatively nigh cost vf oil fuel as compared to coal delivered in the area for wnich the unit was then plannec.

A ccmparison of an oil burning plant with the Three Mile Island Nuclear Plant is given in part B of :nis section.

Hydroelectric Generation The geography and flew the Susquehanna River are such that is is imprssible to find the com0ination of head and water quantity that can produce the capacity and energy equivalent of TMI.

Gas-Fired Generation The Applicants, stat,e and the staff agrees that this fuel can be dismissed frcm further consideration, since gas fuel is not available fer' boiler use within tne company's service terri Ory.

T'ner-al' :ea ki ne Ca caci ty The Applicants state that peaking capacity is not considere-as an alterna-tive because of the high cost and inefficient use of fuel, if such units are used for long hcurs of generation, c;m; arable to those expected of a nuclear plant. C;mbustion turbines, combined cycle units anc oil-fired cycling units are intended for a different type o# service and GPU is clanning on a long-term basis for limited use of such capacity to provide f r a balanced development of its system. Currently, however, very large ccm::ustion turbine installations are being made because of delayt in installations of other capacity.

The environmental cost of such peaking units are quite similar to those for an oil-fired base load unit.

The staff concurs with this evaluation and notes that is is essential to add to base load generating capacity at the present time if the a:Plicant is to be capable of meeting its projected leads.

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cr.9,6,0

. Other Sources The production of energy by MHD, solar heat, fuel cells, wind power or tidal power must be dismissed as not feasible in the time period and in the area that will be served by TMI.

Pumced storage is not a viable alternative since such facilities are net consumers of electrical energy.

10.

Cost Benefit There is a complete and lengthy Benefit-Cost Analysis found in Section 10 of the FSFES and Section XI.3 of the FES.

11. Routine Samaline Chapter 5 of the FSFES covers the environmental monitoring progrr s for the proposed Three Mile Island fluclear Station, Uni No. 2.

Since it is quite a lengthy chapter, it is not being repeated here.

12.

Price-Anderson Act The Price-Anderson Act is discussed in Section 11.1.3.3 of the FSFES as follows:

The comment discusses Subsection 17Cb. of the Atomic Enerhy Act of 1954, as amended. This subsection along with other subsictions of Section 170, the Pricr-Anderson Act, was modified by Public Law 94-197, enacted into law on December 31, 1975. This, legislation, which extends the present Price-Anderson lesiglation for ten years to August 1, 19 7 providcs, among other things, for the chasing out of Government incemnity through a mechanism whereby the utility industry would collectively

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share in the risk of damages frcm a nuclear incident exceecing the basic amount of private insurance available through tne cayment of a retrospective premium to the insurance pools.

The Commission must establish, before December 31, 1975, a retrosoective premium figure of between $2 million and 55 million per reactor. On September 20, 1975 the Commission published in the Federal Register (al (41 F.R.10512) a notice of proposed rule making which would, among other things, establish this premium figure at 55 million ::er reactor.

This retrospective premium of $5 million per reactor per incident would be paid in the event of a nuclear incident resulting in damages exceeding the amount of the current $125 million primary insurance layer. Thi s premium was not meant to replace the indemnity fee of 530 a ther ai

=egawatt paid by reactor operators. The premium was.estaclished to phase out Government indemnity by the mid-193Cs. There is also provision, however, in P.L.94-197 wnich authorices the Ccmmission to recuce tne.

annual indemnity fee as the financial protection layer increases anc Government indemnity is reduced.

C t]n, '.f. m

-- While the retrospective premium is not a "one-time fee," there is a maximum amount procosed by Commission in the notice or proposed rule making of $10 million per reactor that can be assess ed in any one cclhndar year. This figure was chosen, as explained in the notice of proposed rule making (al F.R. 40E12), not so much to provide fur.ds for a second nuclear incicent in a single calendar year, an occurrence which we feel is extremely renote, but to provide funds for claims arising from a nuclear incident ir in earlier year.

13. Accidental Releases A lengthy discussion of the environmental impact of postulated accidents is found in Section 7.2 of the FSFES.

In addition, Section 11 of the SER addresses routine releases from the plant, and Section 15 discusses releases due to accidents which we require to be postulated. The probability of occurrence of other more severe accidents is considered sufficiently low that they need not be Ctnsidered.

14 Auxiliary Control Room Cesien This subject is addressed in 3ection 7.4.2 of the Safety Evaluation Report,

.as follows:

Essential instrumentation and controls are provided outside of the main control room for tne purpose of achieving a shutdown concition. These con-trols and instruments are adecuate to achieve and maintain the unit in a hot shutdown condition and also provide capability for attaining a cold shutdown condition when supplemented by a;;ropriate operator actions. We have con-cluded that this design meets the applicable criteria and is acceptable.

Mr. Silver's testimony entitled "Resconse of the NRC staff to the Licensing Board Questicn about the Asclicacility cf Icens Addressed in ':UREG-0123 anc

-0153 to thi s plant," Issue No.11, following Tr 1322, also addressed this subject and is reproduced below.

Issue No. 11 Intercre'ation of GCC 19 " Control Room

• Abstrset of Staf position A serious accident resulting frca an event which both damages ecuipment in the con-ol rcom and forces the coerator to shut down the reactor fram out-side the control rccm is of such low procability as to be of negligible (34s m a,.,c o 4

- risk. The probability is considered low because the control rocm is recuired to be manned at all times and.c remain habitable under hazardous conditions, the ecuipment in the control room is redundant, the reactor is protected by automatic systems, tne other means of safely shutting down the reactor are available.

Design of Three Mile Island Unit 2 The control room is designed to remain habitable under :lazardous conditions, and the equipment in the control room is redundant. The reactor 4* orotected by 2&W automatic crottctive systems. The plant includes orovis.sns to shut down and maintain the reactor in a safe hot condition after shutdown if access to the contro! room is denied. Subsequently, the plant, can be brought to a cold shutdown condition from outside the control room.

15. Waste Discosal Aspects of this co1cern have been addressed in Section 5.2.3 of the FSFES and in the testimony of Dr. Gotchy in this pr 'ieeding following Tr 2C91.

16. Enercency plans The applicants' Radiclogical Energency Plan {' SAR Accendix 13A), Section 13.3 of the SER, and a considerable. amotnt of testimony at the hearing addressed most as.;ects of emergency olanning in ques' ion.

Section 11 of the SER and the prepared testimony on issue 2P of the '1URE3 issues" discuss radiation monitoring.

(follcwing Tr 1322)

17. ECCS Testine Early tests in the so-called semi-scale facility (really 1/200 scale) did produce some ancmolous results, but these were fully explainable by test pecul ia ri ti es. Results did not indicate any need to modify ECCS models.

A larger (1/5) scale program, designated LCFT, is well underway. The fifta non-nuclear test in this series was run in May,1977. All valid tests thus "ar have incicated that the ECCS systems perform as intended. Based on these results, it is expccted that tne nuclear test series, planned to start in 1973, will essentially confirm present models and permit verification of prediction techniques used in reactor safety analysis.

18.

Fire Protection:

Cur original review of the plant's fire protection system was recorted in Section 9.5 of the SER. As noted in item (5) of Section 13 of Sucolement No.1 to the SER, we issued to tne isolicant in late 1976 our uodated re.cuire-ments on fire protection, and recuested performance of a fire hazards analysis a r r _ r7 s;q

%.) f.n h u L-

. and a re-evaluacion of the fire protection system in accordance with these requirements. This information was furnished to "RC in June,1977. We aill review this information and identify any required changes as expeditiously as possible. We excect to ccmplete the review prior to the scheduled fuel loading, and we will of course require that all necessary modifications and procedural and administrative changes be made as early as feasible to improve the capability of the fire protection system.

19. Security Since the time of the alleged events noted in Jones' cuestions, adherence to existing security procedures at Three Mile Island has been demonstrated and is considered acceptable.

In addition, we have recuired this plant and all others to conform to tne requirements of 10 CFR 73.55, which sets forth ne requirements for physical crotection of licensed activities in nuclear power reactors against industrial sabotage.

With regard to the Acril 7,1977 GAO report on security, since that recort is a public document the soecific olants visited have not been identified for obvious security reasons.

20. Assurance of Adherence to NRC Reculations The NRC performs many functions by many different org[ nip $tions to assure that the applicant conforms witn NRC regulations.

In brief and partial summary these include:

1.

A thorougn review of the design of the plant to assure censistency with NRC criteria.

2.

A review of the cualifications of the applicant and his major sub-contractors to help assure their capability to cerform their function.

3.

A complete review of the Quality Assurance program of the applicant and his principal contractors.

4.

Field inspections by trained NRC personnel to:

a.

review the applicant's CA performance.

b.

review and witness construction practices and inspect the facility.

c.

review the qualifications and training of CA and construction personnel.

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. d.

review construction and creoperational test and ocerating procedures, witness appropriate tests, and review test records.

5.,a Continued monitoring by NRC personnel throughout the life of the

' plant.

The crux of the concern here should not focus entirely on complete conformance with the regulations, but in addition on? ant safety. The accroach followed l

in plant licensing consists essentially of conservative design to avoid cccidents, and provision of conservatively designed redundant systems to mitigate the consecuences of an accident if for some reason one does occur.

It is felt that this approach to safety coupled with the review functions briefly described above will assure the health and safety of the public.

21. Radiation Effects on Emolovees Although employee exposure records are maintained, there is no regula: cry requirement to maintain employee family health records.

ERDA is funding a study at the University of Pittsburgh (the Mancuso Study) to de'. ermine family health histories for present and former employees at Hanford and Cak Ridge.

NRC Office of Inspection and Enforcement will assure that :ualifications of maintenance workers are in accordance with Code ~and Cuality Assurance Program recu i remen ts. 10 CFR Part's 19 and 20 cover instructions and standards for protection against radiati'on.

Information in regulations, studies, etc., on allowable ecoloyee dores ar justification therefore is available to the general public although :ner-no regulatory recuirement to netify the jeneral public specifica'i/ of the matters.

There is no reculatory recuirement to inform the general :ublic is to possible increased genetic rip to offspring of plant employees.

Recorts of past family and social disructions allegedly due to contamination of an employee are available to the public, but there is no regulatory requirement to notify the general public of these mattars.

5W.?SG

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APPENDIX A g

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