ML19209C666
| ML19209C666 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/14/1979 |
| From: | Barabas A, Sylvester S FRANKLIN & MARSHALL COLLEGE, LANCASTER, PA |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML19209C663 | List: |
| References | |
| RTR-NUREG-0591, RTR-NUREG-591 NUDOCS 7910170196 | |
| Download: ML19209C666 (6) | |
Text
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FRANKl.LN and MARSHALL COLLEGE LANCAsTER. PENNSYLVANIA 17604 DEPARTMENT of GEOLOGY September 14, 1979 Secretar; of the Ccmmissicn Nuclear Regulatory CccTaission Washingten, D. C.
20555 Attn:
Cocketing and Service Branch Cear Ccmmissioner:
Enclosed are our cements en your staff's report entitled Environmental Assessment:
Use of Eciccc-II at Three Mile Island. Uni II.
As scientists familiar witn env1renmental assessments, we are accalied ac the lack of precise data, the limitaticns of scope, and the overall poor cuality of the scientific analysis presented by your staff.
We doubt that representatives of private industry would ever consider submitting to a regulatory agency such a vague and pcorly-documented assessment of a proposed action involving dangerous materials.
If they tried, their assessment would be su=arily rejected.
It is indeed lamentable that, although the assessment was prepared by a federal regulator / agency, it dces little to protect and reassure a skeptical and frightened puolic.
in addition, the preparation of this report was a waste of the taxpayer's money.
We urge you to take a few minutes to read these cern:ents carefully.
They provide scme insignt into the peor quality of regulatory efforts of the NRC.
Yours truly, LU1.k W b J Arthur H. Sarabas, Ph.D.
Assistant :rofessor of Geology Ccordinator of Environmental Studies Fregrain
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cc:
Hon. Rcbert S. Walker Hon. Albert Wenisen, Jr.
Steven Sylvester, M.Sc.
Hon. Allen E. Ertel Specialist in Geology Hcn. Willia:n Gcedling Hen. Ricnard Thorncargh Hon. Morris Udall Jean Kchr, Esq.
Lancaster Ccunty Ccemissioners Suscuehanna Valley Alliance Dr. John G. Kemeny 1148 284 7910170lT6
FRANKLIN and MARSHALL COLLEGE LANCAsTER. PENNSYLVANIA 1*604 DEPARTMENT of CEOLO3Y The Environmental Assessment entitled Use of E icer-II at Three Mile Island, prepared by the staff of the Nuclear Regulatory Ccmmission, is a seriously flawed and inc:mplete study.
The NRC staff's rec:mmendations supporting the use of the Epicor-II system are unwarranted in light of the folicwing significant shortccmings of the published study:
1.
The scope of the present assessment is t o limited to allcw the proper evaluation of the particulac cleanup step involving Epicor-II in the larger context of the entire cleanup operation at TMI.
2.
The lack of sufficient detail in the description of the Epicar-II cleanup stage prevents a critical analysis of this step and does not support the broad conclusions drawn by the NRC staff.
3.
Detailed evaluation reveals ambiguities in the data on occupational radiation exposure levels cited in the assessment.
Thus, the estimates of 1-5 man-rems of exposure frem the use of Epicer-II are suspect.
The study neglects to consider other aspects of worker safety.
4.
The evaluatien of alternatives to the use of Epicar-II is perfunctory and a: pears to be based more en the expediency of justifying an already c:n-structed system than en c nsiderations of pcssible impacts en the public health.
E.
Procedurally, the NRC staff exceeded and c:mpr mised the NRC's regulatory authority by providing design guidance f:r the Epicer-II system before c mpleting an 'nvir:nmental assessment of this system and possible alternatives to it.
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Based on the detailed discussion which follcws, we reccmmend that the NRC Ccmissioners reject their staff's assessment.
A broader, more detailed study should be initiated innediately.
Since the NRC staff provided significant assistance in the design and construction of the Epicor-II cleanup system (page 3, section 2.0), the new assessment should be done by a grcup or agency independent of the NRC.
Detailed Discussion of Princioal Shortc mings of the Present Environmental Assessment 1.
Limited Sccce of the Present Environmental Assessment The assessment estimates dangers and exposure levels to the public based only on the use of Eoicar-II to clean a small fraction of the radicactive water at TMI.
Since the biological effects of radiation are cumulative, the public health will be affected by all radiation emissions resulting frca the c mplete cleanup of TMI.
In order to evaluate the advisability of using Epicar-II, data on resultant exposure levels frcm other cleanup activities are first needed.
In additien, Epicar-II and its alternatives should be c mpared in the context of total exposures resulting frem ccmplete cleanuo of TMI.
Until assessments covering each phase of the cleanup (up to and including removal of TMI's fuel rods) are c mpleted and published, it will not be possible to evaluate the impact Epicar-II's use will have en the public.
2.
Lack of Sufficient Cetailed Information While the assessment dces prov'de estimates of off-site exposure levels resulting frca the use of Epicor-II,no data er exclanations are provided en hew these estimates were made.
The assessment does provide an explanation of hcw on-site excesure levels were calculated, but detailed inspection of these estimates reveals sericus ambiguities (see section 3 cf this report).
The assessment leaves unanswered a numcer of critical cuestiens about the use of Epicar II and the ultimate dispositicn of the 25CO cubic feet of Ecicer-II generated radicactive waste.
It is not clear wnether Ecicor-II will be used to process water other tnan that in tne auxiliary building.
The constructicn of more en-site waste storage modules than recuired for the liners suggests that additional treatment of contaminated water, beycnd the 220,C00 gallens of interreciate-level radicactive waste water described in the assessment, is being considered by Met. Ed. cr by the NRC.
If additional trear.ent is prcjected, the added radiation to wnica the public and plant workers will be sucjected should be clearly described.
Although the ex:csure levels ex;ectec durinc the cperation of Epicar-II are discussed, the assessment dces not consider wnerner the Epicor-Il system's ccmcenents will bec:me racicactive as a result of its pr:pcsed use.
Plans for dismantling and disposing of the contaminated system are not includec D -He assessment.
The impact of the p. rosed s Orage and burial at TMI cf the 2ECO cubic feet of redicactive waste sen6 rated by Epic:r-II is only inc:=pletely assessed.
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Description of the interim storage facility (.5.2.1), which will house the radioactive waste, dces not include estimates of seismic integrity, details of the structural strength of the corrugated metal walls, calculations of the effects of freezing and thawing, and an estimate of the possibility of ficoding by groundwater infiltration.
Most significantly, the assessment dces not provide an estimate of the time scan over wnich the integrity of the interim storage facility is assumed.
The assessment states that a well will be drilled near the interim storage facility "to assure that no activity migrates from the liners to tne groundwater" (p.19).
If radicactive contamination is detected in this well, we doubt that the well could assure that migration of radioactive material had not or would not occur.
In fact, the presence of a well might even accelerate such migration.
Cescription of the concrete storage facility, which will provide longer tem storage of the same wastes, suffers frcm the same deficiencies as dces the interim storage facility (except for freeze-thaw considerations).
The assessment pmvides no estimate of hcw icng radioactive wastes wig be s:cred at TMI.
The concrete storage facility is descri5ed (5.L2) as consisting of mcdules of 60 storage cells each capable of housing cne larce or two small resin storage liners.
Epicar-II is anticipated to generate 50 liners.
To satisfy storage requirements for Epicar-II waste cnly one module is needed.
Section 5.2.2 indicates space is available to build 6 modules for storage cf radicactive wastes.
5efore the assessment is accepted, it should be clearly stated what will be stored in these other modules and the resultant exposure levels to plant personnel and the public should be detemined.
Section 5.2.2 discusses final disposal t.f the radicactive wastes and indicates that off-site shipment will occur as " licensed shipoing casks bec me available." Since on-site storage will result N release of radiation (5.2.2) the assessment should first determine if licensed 3:'ipping casks are available, as well as wnen and at wtat rate transpor to a licenced burial grcund is to take place.
The assess. Tent dces not censider the altemative of demineralizing the radioactive water a.: a rate cc.mensurate w-f th the a~ailability of licensed casks, thus eliminatin; unnecessary en-site storage and 1ssociated radicactive releases.
3.
Occucaticnal Odiation Execsure Levels and Other L:ects of Worker Safety The assessment's occucational dose estimate Of 1 to 5 man-rems as a result of using Epicar-II cannot be verified using the data cresented in the assessment.
Workers will have to change Epicer-II's prefilter/demineralizer and two demineralizers (cne caticn bed and one mixed bed deminerali er) in radiation fields of 100 milliem/hr, 30 milliem/hr, and 20 rem /hr, res::ectively (section 4.0).
Eacn change is estimated to take 20 seconds.
A.biguities in the assessment leave unclear hcw many changes perscnnel will have to perfam.
Section 4.0 states "We estimate that tnere will ce a:prcximately 50 changes of :refil:er/
deminerali:ers and ceminerali:ers.* Left unanswerec is whether there will be 50 cnanges of each of 3 units or a total of 50 changes for all 3 units.
In the case of the fcn er, the resultant occupational ex;:csure wculd be S.29 man-rems, well above the i-5 man-rems estimate for Epicor-II use.
In the latter case it is impossible to calculate the expcsure level since the number of changes of p
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each type'of filter is not specified in the assessment.
Since the exposure incurred during the change of each type of filter will vary considerably, the total exposure cannet be calc lated with the limited information given.
These ambiguities prevent verification of the estimated worker exposure levels cited in the report.
Several scenarios of possible accidents that could occur whil2 Epicer-II is in use are described in sections 3.4 and 5.2.1.
They include pipeline rupture causing radioactive water to leak into the building housing Epicar-II and dropping radioactive resin casks wnile moving them around the plant site.
For each scenario exposure levels are estimated only for pecple cutside :he plant.
No estimates of exposure levels are provided for en-site workers.
Estimates of the time needed to clean up spilled radioactive material, contingency plans for cleanups and evacuatien plans for workers in the immediate area are Tacking.
4.
Weaknesses and Flaws in the Evaluaticn of Alternatives to the precosed Use of Eo1ccr-II While section 6.0 censi'ders trans;crting the radioactive water in the auxiliary building to another site as an alternative to using Epicar-II, burial of the liquid is the only final disposal scheme which is discussed.
This possibility is rejected because there are no Burial grounds that accept liquid radioactive waste.
Transporting the radioactive licuid to an existing Epicor system for decantamination is not considered.
R. Vollmer, head, NRC Support Group at TMI, has publicly stated other Epicor systems do exist. The advantages of this alternative include reducing the cumulative public and worker expcsure levels as a result of the total clean up of TMI, transporting less concentrated radicastive mat-ial, and possibly perfor ning the deminerali:ation in a less densely pcpulated area.
If existing Epicor systems are unable or unwilling to treat TMI's waste, an Epicor system should be c:nstructed in a remote, sparsely populated area rather than at a plant undergoing conc mitant decentamination and radioactive releases.
Contrary to secticn 2.0 which states that "use of Epicar-II (at TMI) dces not preclude imolementaticn of the various dispcsal alternatives,* its use would preclude cemineralizatir at an Epicer site remote frem TMI.
The assessment deals with three alternatives for processing radicactive water or site (section 5.0): using existing racwaste systems at the plant, Epicor II, and removal by evaporati:n and c:ncensa icn.
The assessment only provi;es estimates of resulting expcsure levels to the public and piant workers for the use of Ecicar-II.
The first and :hird alternatives are dismissed f;r reascns of ex:ediency withcut considering if these alternatives wculd result in icwer expcsure levels.
5.
Procedural Shor :: mines of the Assessment Secticn 2.0 of the assessment states "the NRC staff has :revidec design guidance and criteria for the Epicar-II processing system, the building housing the system, One building's exhaust filtra icn system and :he process vessel vent system".
This partici aticn by NRC staff in the design stage of the system exceeds and c:=:r mises the ragulatcry authcrity of the NRC since the same staff was called ugen later to prepare an environmental assesemen-r Id om M D T~g s
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Based on the above informatien and our excerience as geologists familiar with environmental assessments, we believe that the NRC's Environmental Assessment dces not provide an adequate evaluation of the proposed action. Cone in a prefunctory manner, the assessment lacks sufficient scope and detail to provide assurances that the public and worker well-being would not be endangered. A broad, detailed study of the entire cleanup of TMI should be initiated immediately. To insure rigorous, independent and scientifically sound results, the new study should be done as an Environmental Imcact Statement by an agency of group independenc of the NRC. <f Me Dr. Arthur H. Sarabas Steven Sylvester, M.Sc. Assistant Frafessor of Geology Specialist in Geology Coordinator of Envir onmental Studies Program September 14, 1979 5. i148 288 -}}