ML19220B820
| ML19220B820 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/06/1971 |
| From: | Egeberg R HEALTH & HUMAN SERVICES, DEPT. OF |
| To: | Price H US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7904270413 | |
| Download: ML19220B820 (16) | |
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Mr. Harold L. Price JAN1 19'71 > M b
Director of Regulation
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Dear Mr. Price:
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Mr. Roger S:relow has referred to me your letter of October 23, 1970, requesting cc:=ents on the Environmental Report - Operating License Stage for Three Mile Island Nuclear Station Unit 1 and Unit 2.
We are pleased to provide the enclosed report which details ou:. co==ents on the radiological effects on the environ-
=ent frem the preposed operation of the plant.
We would appreciate receiving your compilation of co=ents by other agencies when it is completed.
If this Department can assist you furtner in this matter, we would be happy to do so.
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A istant Secretay for Health and ecienti.ic Af fairs Enclosure
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PUBLIC HFX T'i FflI D TEREE y.ILE ISLA:iD :n' CLEAR S*.CION UNIT 1 and UNIT 2 A..u
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PRIFACE This report is one of a series designed to su==ari a the results of evaluations by the Public Health Service of the environmental effects of nuclear facilities. The evaluation is based on a detailed technical review of design informatica for the facility as well as the " Environ-mental Report" sub=itted to the Ato:ic Energy Cc==1ssion under the conditions of the National Environ =er.tal Policy Act of 1969. Reviews of individual tacilities are performed by the Nuclear Facilities Branch of the Division of Environmental Radiation, Eureau of Radio-logical Health. The Branch, as a part of this review process, has developed and referenced several technical dovurents to support the discursions presented.
The evaluation presented in this repctr is directly responsive to the requirements placed en Federal agencies by the National Environ-cental Policy Act and as such is in'tnded to state the position of the Depart =ent of Health, Educatien, and Welfare en the environ = ental effects of the operatica of the facility. The report is also intanded to provide information to the State involved for its use in conducting their radiolcgical health progra for the facility.
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e II.T*'.CLUCTIO:: A:;O CC: CUS::::S This report summarizes an evaluation of the potential radiolc;ical effects on the environment of the Three Mile Island !;uclear Statien Unit 1 and Unit 2.
The facility is under construction about ten miles southeast of Harrisburg, Pennsylvania. Unit 1 and Unit 2 are scheduled to begin eo:=cretal operation in yova ber of 1972 and >Sy of 1974, respectively.( ) Both units are pressuri:ed water reactors (?b'R) nanufactured by Eabcock and L'ilcox Co.
with design power ratings of 871 Z'(e) for Unit 1 and 965 Zl(e) for Unit 2.
This evaluatica is based on informacien provided by Metropolitan Edison Cc=pany and Jersey Central Power and Light Cocpany in its
" Environmental Report - Operating License Stage,"(1) Final Safety Analysis Report (FSAR)(') for Unit 1, and the Prel1=inary Safety Analysis Report (PSAR)( } for Unit 2.
This review also updates the previous evaluation of the facility made prior to the start. af construction.(4,5)
This earlier evaluation was based on infor:ation contained in the PSAR for Unit 1(
and the PSA_4 for Unit 2.
Consideration was given to radioactive waste treatment, expectad levels of radioactive waste discharges to the environment, potential population radiation dose levels, environmental surveillance, and t=ergency planning. The principal conclusions are:
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1.
The operator has available several different processing routes
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for treating liquid wastes. He should routinely u:e that processing route which will result in the lowest effluent letel.
2.
In order to =aintain gasecus radioactive discharges at the icwest practicable levei, all gaseous vaste from Thre'e 1111e Island Nuclear Station Units 1 and 2 should be stored at all rises for not less than 60 days prio; to discharge and the applicant should =ake an operational ce=nittent to do so.
3.
The liquid waste treatment capability and the estinated primary coolant radioactivity concentration for both Unit 1 and Unit 2 are si=ilar; however, the applicant's calculated discharge levels fo r the different units are significantly different. The applicant should =ake a thorough comparison of the liquid radicactive waste treatment systen decontaminatica factors for Unita l and 2 and acccunt for any differences in pertinent assumptions in order to either justify or eliminate the inconsistencies between the expected discharge levels estimated for the two units.
4.
A population dose assessment shculd be made in order to fully evaluatt the potential environr. ental impact of radioactive waste discharges from Three Mlle Island Nuclear Station - Units 1 and 2, and the results should be presented in the Environmental State =ent prepared by the Atomic Energy Cc= mission.
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The auequ:c/ 0 eneir:rr. ntal c dial.,i::: :urveillan:: f:: the facility cannot ba fully evaluated.-ithout acre detailed info rmation on radionuclides that will be =casured and the Icca:Lon of all proposed indicator and background stations in all three sampling regimes. This infortation should be made a part of the public record before Unit 1 becomes operational in order to facilitate utilization of the surveill nce data follcuing start up of the plant.
6.
More information on the content of the Three 1111e Island ;uclear Stat' ion emergency plan such as that required in the prcposed a:end:ents to 10CFR50 should bc submitted by the applicant. The plan should recognize that only the State has the authority to initiate protective action measures to protect the health and safety of the public.
WASTE TREAT'EiI Licuid: The extent of liquid waste treatment and the resulting arount of discharged liquid waste will be highly dependent on procedural controls. Operational procedures determine the tanks, pumps, denineralizers, piping route, ecc., that will be utili:ed in the treatment of liquid waste.
In bcth the environmental report (') and
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1 FSAR,(-)the applicant the Unit states that discharges of liquid waste to the cooling tcwer bicwdown line will be within 10CFR20 limits; however, no ce==it:ent was made by the applicant to maintain the liquid discharges at Onc icwcs practicable icvel as required in the recent acendments to 10CTR20.( ) The applicant should make a eo: itment to fully utilize the capability of the liquid waste design during all plant operations so that liquid discharges will bc maintained at the a l (J
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Icwest practicable level.
In specifying the operating procedures for the liquid treat =ent system, the applicant should routinely use those liquid waste processing routes which will result in the lowest effluent level. Alternate processing routes shou'd be limited to those instances where their use is absolutely necessary.
G:ses: The applicant states that " generous waste gas storage capacity coupled with the ability to recycle waste gases to the vent header s'ysten =ininize radicactive gas activity discharges to the environment by providing icag hold-up times for radioactivity decay prior to release."(
On page 11-10 of the Unit 1 FSAR,(
the applicant states that for radioactive gaseous vastes being disposed to the envi.ron=ent, "a =ini=u= of 90 days decay time =ay be utilized prior to disposal, as may be required." The applicant clso assumed that all gaseous waste is compressed and stored for 90 days prior to discharge when they esticated the annual average waste gas discharge for Three Mile Island Unit 1.
In the Unit 2
- PSAR, the applicant stated that gaseous waste would be held up for decay; however, neither the design holdup capability ner the routine holdup ti=e was specified.
Holdup for a mini =un of 60 days at all times will significantly 85 reduce the activity of all noble gases except for Kr.
Because 85Kr is predominantly a beta emitter, the dosimetric impact of 8'~Kr is much less than that of nobic gas beta-gs=ma emitters sue:. as 13Xe. (S)
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We are tharefore of the opinion that the applicant should rake an
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operational ec =itman: to holdup all gaseous wastes fro both Units 1 and 2 for a minimum period of 60 days prior to discharge.
This operational co==itment should be made part of the public record.
PADI0 ACTIVE UASTE DISCHARGE LEVELS EU EC ED Radicactive gases are discharged through a =ccitored vent and conitored liquid radwaste is discharged into the effluent Ircm the rechaniemi draft ecoling tower at a =ini=un flew rate of 5000 gym.
There are no estinctes of expected gaseous and liquid discharge levels in the environmental report,(1) but this infer:ation is presented for Three Mile Island Nuclear Station Uni I and Three Mile Island Nuclear Station _'ait 2 in the FSAR(
and PSAR, respectively. The liquid waste trestre oc capability and the estimated primary coolant radioactivity concentrations for both unita dre similar; hcVever, the applicant's calculated discharge levels for the different units are significantly different. Liquid discharges (excluding H) for Unit 2 are much higher than those for Unit 1 and the difference say be due to differing assumptions regarding dccentamination factors for waste treat:ent systen equipcent.
The applicant should make a thorcu;h co=parison of the liquid radio-active waste treatment system decontamination factors foc the two units and account for any differences in assumptions l atween the two units made in the analysis.
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6 One of the major differences in :he applicant's discii:13e estimates for Units 1 and 2 is in the radienuclide cc pcsition of the liquid waste. The applicant's estimated liquid discharge for Unit 1 (FSAR, Table 11-7) did not include many i=portant ina: W 's 0
59 95 activated corrosien prcducts such as Co, Co, Fe, Zr, Mn, Sl Fe, and cr which constituted almost the entire liquid discharge that was =easured in the liquid waste at Yankee Nuclear Pcwer Station. ('}
The applicant's liquid discharge estimates for Unit 2 included the
=ajority of the activated corrosion p cducts that were omitted in the cnalysis for Unit 1.
Primarv to Secondarr Leak in a Steam Generator Current cpo. rating experience at PWR nuclear power plants indicates that a considerable por;tvu.
LL. su al liquid radiocctive discharge may be attributed to leakage of radicactivity frc= the primary into the secondary syste= through leaking tubes in the steam generators.
Depending on the size of the stea= generator tube leak and the percentage of defective fuel elements in the core at the ti=e the leak occurs, serious radioactive vaste =anagement problems can result due to relatively large volumes of liquid radioactive vaste hav4 ng a high solid content. The presence of high solids prceludes use of ion-exchange purification and the liquid waste volume is usually too large to be readily processed by evaporation.
Radiological waste
=anagement procedures s hould thereby be designed to enable rapid action ta be taken upon detect. ion of a primary to secondary leak in order r.o li=it the amount of liquid radicactive waste discharges.
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7 Cn page 11-11 cf tac Un.
2 22.'., "u the applicant ;tates that an aluation will be made to examine the consequences of reactor operatica with steam generator tube leakage and 1 per cent failed fuel rods."
The applicant is therefore aware of the problem and has initiated but not completed their evaluation.
The results of this evaluation should be made available before Unit 1 becomes operational and it shculd show that adequate radiological waste manage cat capability exists to handle a primary to secondary leak.
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In this regard, we are interested in the amount of gaseous waste that may be.centinuously vented to the atrosphete wi:hout being processed through the gaseous waste holdup system. Recent studies (C) indicate that this route of dischtrge may be significant for PUR's operating vith primary to secondary leaks.
E:NIRO: ENTAL I'GACT The potential environmental impact due to radioactive waste discharges to the environment from the Three. Mile Island Nucicar Station Units 1 and 2 is the population doses which will cccur. An estimate of the radiation doses to the population during normal operatica of the plant is essential for evaluating the potential radioicgical effects on the population.
A population dose assessment should be f r '.ded for review which includes the calculations of potential total doses from all critical pathways for 1) individuals residing in the plant 's i= ediate environs; and 2) the exposed populatior within 50 miles of the plant c:cp res s ed
'as'=an-re /yr, taking into consideratica environ = ental and demographic factors.
The results of such an assessment shculd be expressed in the 4 3,n, et La_ I k
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contc.xt of c..e recm.:.:en ation; of th2 Fed 2:al Pha:i ca Council
' hat the bene"'
pected should outucigh he risx that cust be assuced.0)
The cri. trion that should be sati fied is that the risk so Icw that it is obvious the benefit far cutweighs it, theren _e, a dose assessment should be presented and analyzed in this context by the Ato=ic Energy Cor=ission in its Environmental State =ent for Three Mi7 e Island Nuclear Station Units 1 and 2.
ENVIRC:CC;TAL SL'R'/ELLANCE The Three Mile Island Nuclear Station monitoring progran is being conducted in cooperation with the Pennsylvania Department of Health.
Our evaluation of this progras is based on information submitted by the applicant in the environ = ental report,(1) Unit 1 FSAR,('~) and Unit 2 ?SAR.(3)
The applicant has divided the environ antal surveillance progran into three regimes. (')
For the first year after criticality, th e program will be conducted in regime III which is the regime of highest sampling frequency. The applicant also states that, if "no significant differences between indicator and background levels are observed during this period and if calculaticas and pre-opera tional
=casurements indicate that no significant differences shculd be observed, the survey will then be cperated under regime 1.
Regi=c I is of the icwest sampling frequency. We believe that if the results of the first year of operation show sufficiently low levels of environ = ental radiation, the sampling frequencies could be icwered
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. to those of regime II, but no lower than this, c least to the end of the first full fuel cycle.
Following the fir;t fuel cycle, an environ = ental surveillance progra may be employed in which the sampling frequency is dictated by the discharge icvels. This recocrendation is in keeping with our previous conclusion regarding sa=pling regimes as was stated in cur review of Forked River Nuclear Station Unit 1. (11 )
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The applicant has tentatively specified the number of indicator and background stations, sample types, the reasurement intervals associated with each sa:pling regime, and the proposed =ethod of sample analysis for some of the sa:P e media.
'Je are unable, l
however, to fully evalusta the adequacy of environ:2ntal radiological surveillance for the facility without infor:ation on the radienuclides that will be =casured in key =edia and the locations of sampling s tatio ns. This information shculd be specified fer all three sa=pling regi=es especially for Unit 1 before it b9 gins operation.
Tritius in river water sa:ples is of special interest.
NGENC" PLA'i Because of the absence of additional informacien, the reco==endaticas made in our public health evaluation of Three Mile Island Unit No. 1 dated February 21, 1968('} regarding crergency planning are still applicable. Again, we emphasize the fact that only the State has the authority to initiate protective action =casures to protect the health and safety of the public. The applicant should i=:ediately notify the State of all incidents, provide source ncnitoring data, e
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t 10 and ctherrise assist the State in designing and carrying cut procedures - to assecs the ensui.; environ cntal levels and public health effects. Before we cceplete eur evaluation of the adequccy of e=argency planning, core information on the content of the plan such as that required in the proposed a end=ents to 10CFR50(l)
should be sub=itted by the applicant.
WAIER USE The >ktropolitan Edison Cc:pany has filed an application with the Federal Pcwer Co==ission for approval of utilization of water frc=
the Ycrk Haven Reservoir for cooling water and other purposes for the Three Mile Island Generating Station Unit 2. (
At the request of the Bureau of Cater Hygeine, this application has been reviewed in conjunction with cur review of the applicant's environmental report and PSAR.
As discussed in the previcus section, although the applicant's expected discharge levels are inconsistent, it is concluded that operation of the Three Mile Island Nuclear Statica will not result in radioactivity levels in the York Eaven Reservoir of sufficient
=agnitude to restrict utilizatien of the reservoir as a source of potable water. This conclusion is principally based on experience at operating pressurized water reactors similar in design to Three Mile Island Nuclear Station and our environmental surveillance studies at two operating PWR plants, Yankee at Rowe, bssachusetts, and Connecticut Yankee at Haddau Neck, Connecticut.
This experience 83 D10 s
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, leads us to believe that radicactivity ecacentrations in the York Haven Rescr/cir resulting from liquid radioactiic caste dicchcrges from the Three Mile Island Nuclear Station vill not be above detectable levels.
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1.
Mctrep;11'an 21 c a Oc paq and Jeracy C: urci ?cicer and Ligh:
' Company, "E.virannental Repor Cpcratin; License Stage - Threc.221u Island.,aclear Scation Uni 1 and Uni: 2," A2C Fuolic Dccuran: Room, AEC Docka: No.59-239 and A:C Docket No. 50-220, October 1, 1970.
2.
Metropolitan Edison Company and Jersey Central Pcwer and Light Co:pany, "Threc } Ele Island Nuclear Station - Unit 1 Final Safety Analysis Report," AIC Public Docu cat Rocc, AEC Decket No. 50-259, Maren 19, 1970.
3.
Metropolitan Edison Ccepany and Jersey Central Power and Light Company, "Three Mile Island Nuclear Station - Uni: 2 Preliminary Safety Ana:ysis Report," AEC Public Docucent Roo=, AIC Decket No.
50-320, Sh: ch 10, 1969.
4.
Peterson, Harold I., Jr., '"Public Health Evaluation Three Mile Island "uclear Station Unit No.1," Department of Health, Ilucation and Welfare, Public Health Service, National Center for R2dioicgical Health, Environmental Surveillance and Centrol Prograc, Nuclear Facilities Section, NF-63-2, February 21, 1963.
5.
Peterson, Harold T. Jr., "Public Health Evaluation Three Mile Island Nuclear Station - Uni: 92 - Addendu: No. I to the Public Health Evaluatica of the Ihree Mile Island Nuclear Station,"
Department of Health, Education, and Welfara, Public H2alth Service, Eureau of Radiolcgical Health, Divisica of Environmental Radiation, Nuclear Facilities Iranch, NF-68-2a, July 30, 1969.
6.
Metropolitan Edisen Company, "Three Mile Island Nuclear Sta:icn Unit 1 Preliminary Safety Analysis Raport," AEC Public Docu=ent Race, AIC Decket No. 50-239, October 2, 1967.
7.
Atocic Energy Co==issien, "Centrol of Releasts of Radicactivi:7 to the Environment," Title 10, Par: 20 - Standards for ?ratection Against Radiation, Par 50 - Licensing of Production and Utilization Tacilities, Federal Register, Vol. 35, No. 234 - Thursday, Dece=ber 3, 1970.
8.
Fowler, Ted U. and David E. Voit, "A Review of the Radiological and Environmental Aspects cf Krypton-85," U.S. Department of Health, Educatica, and Welfare, ?ublic Health Service, Consumer Frc:2ccion and Envirot= ental Health Servic e, Environmental Centrol Ad=inistratien, Bureau of Radiological Health, Divisica of Envirenzantal Radiation.
Nuclear Facilities 3 ranch, NF-69-16 Revision 6/ 70, September,1969.
9.
Kahn, Bernd et al., " Radiological Surveillance Studies at a Pressuri:ed Uatar Nuclear ?cuer Reac:cr," U.S. Department o f Health, Education, and Welfare, U.S. Public Health Service, Environmental Health Service, Sureau of Radiological Health, Division of Environ-cental Radiation, Radiological En;ineering Laboratories, 3RH/ 2ER 70-3, Draft (To be published early 1971).
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s 10.
Federal Radiation Council, Report No. 1. 3,c:: rcund
.2 erial j[or_ the C:<ccicorant of Radiation Procecrien Stand:rds, v.5.
Gcvarn=cn: 2rinting 0:fice, Washin; con, D. C.,
May 13, 1960.
11.
"Public Health Review, Forked River : uclear Station Unit 1,"
U.S. Department of Health, Education, and k'elfare, Public Health Service, Environmental Healt h Service, Eureau of Radiological Health, Division of Environmental Radiation, Nuclear Facilities Branch, DEPJNF3 70-12, October, 1970.
12.
Accaic Energy Commission, " Licensing of ? reduction and Utiliza-tion Facilities, 10 CFR Part 50, Plans for Coping with Energ encies,"
Federal Regis ter, "cl. 35, No. 9c - Thursday, May 21, 1970.
13.
Metropolitan Edison Company 2nd York Haven Power Company,
" Application for Approval to Permit Joint Use of Project :iat ers for Additional Unit of Nuclear Generating Station," ?:oject No. 1838, Federal Power Cc==ission, July,1970.
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2020s Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Cc=sission Washington, D.C. 20545
Dear Mr. Price:
Mr. Roger Strelow has referred to =e your letter of October 28, 1970, requesting co=ents on the Environ = ental Report - Operating License Stage for Three Mile Island N'ucicar Station Unit 1 and Unit 2.
We are pleased to provide the enclosed report which details our co=ents on the radiological effects on the environ-
=ent from the proposed operation of the plant.
We would appreciate receiving your co=pilation of co=ents by other agencies when it is co=pleted. If this Papart=ent can assist you further in this catter, we would be nappy to do so.
h Since #,,,rj Ro _r O. E
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As istant Secretary for Health and 4cienti.ic Affairs Enclosure "O90 N CN
DER /N73 70-19
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PUBLIC HEALTH FflII'1 THREE MILE ISL'.cTD NUCLEAR SZ" ION UNIT 1 and L"iIT 2 U.S.
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PREFACE This report is one of a series designed to summarice the results of evaluations by the Public Health Service of tha environ = ental effects of nuclear facilities. The evaluation is based on a detailed technical review of design information for the facility as well as the " Environ-
= ental Report" submitted to the Atomic Energy Co= ission under the conditions of the National Environ = ental Policy Act of 1969. Reviews of individual facilities are perfor ed by the Nuclear Facilities 3 ranch of the Division of Environmental Radiation, Bureau of Radio-logical Health. The Branch, as a part of this review process, has developed and referenced several technical docu=ents to support the discussions presented.
The evaluation presented in this report is directly responsive to the requirements placed on Federal agencies by the National Environ-
= ental Policy Act and as such is intended to state the position of the Depart ent of Health, Education, and Welfare on the environ = ental effects of the operation of the facility. The report is also intended to provide information to the State involved for its use in conducting their radiological health program for the facility.
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IhTRODUC* ION AND CONCLUSIONS This report su-arizes an evaluation of the potencial radiological effects on the environ =ent of the Three Mile Island Nuclear Station Unit 1 and Unit 2.
The facility is under construction about ten miles southeast of Harrisburg, Pennsylvania. Unit 1 and Unit 2 are scheduled to begin concercial operation in November of 1972 and May of 1974, respectively.
Both units are pressurized water reactors (PWR) =anufactured by Babcock and Wilco):
Co.
with design power ratings of 8713"J(e) for Unit 1 and 9651"J(e) for Unit 2.
This evaluation is based on information provided by Metropolitan Edison Company and Jersey Central Pcwer and Light Co:pany in its
" Environmental Report - Operating License Stage,"
Final Safety Analysis Report (FSAR)(
for Unit 1, and the Preliminary Safety Analysis Report (PSAR) (
for Unit 2.
This review also updates the previous evaluation of the facility made prior to the start.of construction.(?,5) g g
g contained in the PSAR for Unit 1(6) and the PSAR for Unit 2. (3)
Consideration was given to radioactive waste treatment, exp ec t ed levels of radioactive waste discharges to the enviroament, potential popul2 tion radiation dose levels, enviren= ental surveillance, and e=ergency planning. The principal conclusions are:
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2 1.
The operator has available several different processing routes for treating liquid wastes. He should routinely use that p roces sing route which will result in the lowest effluent level.
2.
In order to =aintain gasecus radioactive discharges at the icwest practicable level, all gaseous waste from Three Mile Island Nuclear Station Units 1 and 2 should be stored at all times for not less than 60 days prio to discharge and the applicant should =ake an operational co==itment to do so.
3.
The liquid waste treatment capability and the esti=ated primary coolant radioactivity concentration for both Unit 1 and Unit 2 are si=ilar; however, the applicant's calculated discharge levels for the different units are significantly different. The applicant should =ake a thorough comparison of the liquid radioactive waste treatment systes decontamination factors for Unit 31 and 2 and account for any differences in pertinent assu=ptions in order to either justify or eliminate the inconsistencies between the expected discharge levels estimated for the two units.
4.
A pcpulation dose assessment should he made in order to fully evaluate the pctential environmental impact of radioactive waste discharges frc= Three Mile Island Nuclear Station - Units 1 and 2, and the results should be presented in the Environmental Statement prepared by the Atomic Energy Commission.
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3 5.
The adequacy of environmental radiological surveillance for the facility cannot be fully evaluated without more detailed information on radionuclides that will be ceasured and the location of all proposed indicator and background stations in all three sa=pling regimes. This infor=ation should be =ade a part of the public record before Unit 1 becomes operational in order to facilitate utilization of the surveillance data following start up of the plant.
6.
More information on the content of the Three Mile Island Nuclear Stat' ion emergency plan such as that required in the proposed amendments to 10CFR50 should be submitted by the applicauc. The plan sbould recognize that only the Sta:e has the authority to initiate protective action measures to protect the health and safety of the public.
WASTE TRE.CE'C Licuid: The extent of liquid waste treatment and the resulting amount of discharged liquid waste will be highly dependent on procedural controls. Operational procedures determine the tanks, pumps, denineralizers, piping route, etc., that will be utilized in the treatment of liquid waste. In both the environmental report (
and 1 FSAR,( the applicant states that discharges of liquid the Unit waste to the cooling tower blowdown line will ae within 10CFR20 limits; however, no co==itzent was made by the applicant to maintain the liquid discharges at ena lowest practicable icvel as required in the recen amendments to 10CFR20. ( ) The applicant should nake a co==itment to fully utilize the capability of the liquid waste design during all plant operations so that liquid discharges will be naintained at the 83 C 'M
4 1cwest practicable level.
In specifying the operating procedures for the liquid treatment system, the applicant.should routinely use those liquid waste processing routes which will result in the icwest effluent level. Alternate processing routes should be limited to those instances where their use is absolutely necessary.
Cases: The applicant states that " generous waste gas storage capacity coupled with the ability to recycle waste gases to the vent header systes minimize radioactive gas activity discharges to the environment by providing long hold-up times for radioactivity decay priot to release."(
On page 11-10 of the Unit 1 FSAR,(
the applicant states that for radioactive gaseous wastes being disposed to the environ =ent, "a ninimum of 90 days decay tire =ay be utilized prior to disposal, as may be required." The applicant also assu=ed that all gaseous waste is co= pressed and stored for 90 days prior to discharge when they estirated the annual average waste gas discharge for Three :411e Island Unit 1.
In the Unit 2
- PSAR, the applicant stated that gaseous waste would be held up for decay; however, neither the design holdup capability nor the routine holdup time was specified.
Holdup for a mini =um of 60 days at all tires will significantly S
reduce the activity of all noble gases except fc r Kr.
Because 85Kr is predo=inantly a beta enitter, the dosimetric impact of 85':r 13'1::e.(8) is much less thao that of nobic gas beta-gamma emitters such as O
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We are therefore of the opinion that the applicant should =ake an operational co==itzent to holdup all gaseous wastes from both Units 1 and 2 for a =ini=um period of 60 days prior to discharge.
This operational co==itment should be =ade part of the public record.
PADICACTIVE WAS"'E DISCHARGE LEVELS EXPECTED Radioactive gases are dischargcd through a =enitored vent and
=onitored liquid radwaste is discharged into the effluent from the =echanical draft ecoling tower at a minicun flow rate of 3000 gps.
There Ira no estinates of expected gaseous and liqrid discharge levels in the environnental report,(1) but this information is presented for Three Mile Island Nuclear Station Unit 1 and Three Mile Island Nuclear Station Unit 2 in the FSAR and PSAR, respectively., The liquid waste treatment capability and the esti=ated primacy coolant radioactivity concentratiors for both units are similar; however, the applicant's calculated discharge levels for the dif ferent units are significantly different. Liquid dis charges (excluding H} for Unit 2 are =uch higher than those for Unit 1 and the difference =ay be due to differing assumptions regarding decontamination factors for waste treat =ent system equipment.
The applicant should =ake a thorough comparisen of the liquid radio-active waste treat =ent system decontamination factors for the two units and account for any differences in assumptions between the two units made in the analysis.
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6 One of the =ajor differences in the applicant's discharge esti=ates for Units 1 and 2 is in the radionuclide co=positica of the liquid waste. The applicant's estimated liquid discharge for Unit 1 (FSAR, Table 11-7) did not include =any i=portant insoluble activated corrosion products such as Co, 60Co, '9Fe, Zr, 54Mm,
58 5
95 55 51 Fe, and Cr which constituted almost the entire liquid discharge that was =easured in the liquid waste at Yankee Nuclear Power Station.(
The applicant's liquid discharge estimates for Unit 2 included the majority of the activated corrosion products that were ositted in the analysis for Unit 1.
Primarv to Seccedart Leak in a Steam Generstar Current operating experience at FWR nuclear pcwer plants indicates that a considerable portion of the total liquid radioactive discharge
=ay be attributed to leakage of radioactivity from the primary into the secondary systea thrcugh leaking tubes in the steam generators.
Depending on the size of the steam generator tube leak and the percentage of defective fuel ele =ents in the core at the time the leak occurs, serious radioactive waste management problems can result due to relatively large volu=es of liquid radioactive waste having a high solid content. The presence of high solids precludes use of ion-exchange purification and the liquid waste volume is usually too large to be readily processed by evaporation.
Radiological waste
=anagement procedures should thereby be designed to enable rapid action to be taken upon detection of a pri=ary tu secondary leak in order to limit the amount of liquid radioactive waste dischar;es.
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7 On page 11-12 of the Unit 2 PSAR, 3) the applice.nt states that an
" evaluation will be =ade to examine the consequences of reactor operation with steam generatcr tube leakage and 1 i,er cent failed fuel rods."
The applicant is therefore aware of the problem and has initiated but not co=pleted their evaluation. The results of this evaluation shetid be =ade available before Unie 1 becomes operational and it should show that adequate radiological waste ca tage cat capability exists to handle a prinary to secondary leak.
In this regard, we are interested in the amount of gaseous waste enat nay be. continuously vented to the atmosphere without being processed through. the gaseous vaste holdup systen. Recent studies indicate tha*. this route of discharge may be significant for PUR's operating with pri=ary to secondary leaks.
DiVIROFEIAL I'!?ACT The potential environ = ental 1: pact due to radioactive waste discharges to the environment from the Three Mile Island Nuclear Station Units 1 and 2 is the population doses which will occur. An estimate of the radiation doses to the population during normal operation of the plant is essential for evaluating the potential radiological effects on the population.
A population dose assessment should be included for review which includes the calculations of potential total doses from all critical pathways for 1) individuals residing in the plant's i=cediate environs; and 2) the exposed population within 50 miles of the plant erpressed as' nan-rem /yr, taking into consideration environmental and demographic factors. The results of such an ascessment should be expressed in the c ry im r ar C,a, o
a,
8 context of the reco==endations of the Federal Radiation Council that the benefit expected shculd outweigh the risk that rust be assu=cd.(
The criterion that should be satisfied is that the risk is so low that it is obvicus the benefit far cutweighs it.
Therefore, a dose assess-c7t should be presented and analyzed in this context by the Atomic Energy Co= mission in its Environrantal Statement for Three Mile Island liuclear Statica Units 1 and 2.
E:NIRORE'C/1 SURVEIIIA'!CE The Three Mile Island Nuclear Station monitoring program is being conducted in cooperation with the Pennsylvania Department of Health.
Our evaluation of this progran is based on information submitted by the applicant in the environmental report,(
The applicant has divided the environmental surveillance progran into three regl=es.( ) For the first year after criticality, the progra: will be conducted in regime III which is the regime if highest sampling frequency. The applicant also states that, if "no significant differences between indicator and background levels are observed during this period and if calculatir :s and pre-opera tienal
~
seasurements indicate that no significant differences should be observed, the survey will then be operated under regine I.
Regime I is of the icwest sa=pling frequency. We believe that if the resui:s of the first year of operation show suf ficiently low levels of environ = ental radiation, the sampling frequencies could be icwered 83 CTM
9 to chose of regime II, but no lower than this, at least to the end of the first full fuel cycle.
Following the firs t fuel cyct2, an environmental surveillance progra
=ay be e= ployed in which the sa=pling frequency is dictated by the discharge levels. This recocnendation is in keeping with our previous conclusion regarding sa=pling regimes as was stated in our review of Forked River Nuclear Station Unit 1.(
}
The applicant has tentatively specified the nu ber of indicator and background stations, sa=ple types, the reasurc=ent intervals associated with each sa=pling regime, and the proposed =ethod of sample analysis for so=e of the sarple media. We are unable, however, to fully evaluate the adequacy of envirennental radiolo ;ical surveillance for the facility without
$for=ation on the radionuclides that will be reasured in key =edia and the locations of sampling stations. This information should be specified for all three sacpling regimes especially for Unit 1 before it begins operation.
Tritius in river water samples is of special interest.
D1RGE;CY PIXi Because of the ebsence of additional information, the reco cendations
=ade in cur public health evaluation of Three."lle Island Unit No. I dated February 21, 1963( ) regarding emergency planning are still applicable. Again, we emphasize the fact that only the State has the authority to initiate protective actica =casures to protect the health and safety of the public. The applicant should ir=ediately notify the State of all i ncidents, provide source monitoring data, pg <y est --
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10 and otherwise assist the State in designing and carrying cut procedures to assess th; ensuing environ =antal levels and public health effects. Before we cc=plete our evaluation of the adequacy of e=ergency planning, = ore information on the content of th; plan such as that required in the proposed a:end:ents to 10CFR50(12) should be submitted by the applicant.
WATER USE The Metropolitan Edison Company has filed an application with the Federal ?cwer Co= mission fcr approval of utili:ation of water from the York Haven Reservoir for cooling water and other purposes for the Three 'ile Island Generating Station Unit 2.(
)
- At the regrest of the 3ureau of Water Hygeine, this application has been reviewed in conjunction with our review of the applicant's environmental report and PSAR.
As discussed in the previous sect.aa, although the applicant's expected discharge levels are inconsistent, it is concludad that operation of the Three Mile Island Nuclear Station will not result in radioactivity levels in the York Haven Reservoir of sufficient
=agnitude to restrict utilization of the reservoir as a source of potable vater. This conclusion is principally based on experience at operating pressurized water reactors similar in design to Three Mile Island Nuclear Station and cur environmental s"rveillance studies at two operating FWR plants, Yankee at Rowe, !bssachusetts, and Connecticut Yankee at Had da Neck, Connecticut. This experience gm e -
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11 leads us to balteve that radioactivity concentrations in the York Haven Reservoir resulting from liquid radioactive waste discharges from the Three 1111e Island Nuclear Station will not be above detectable levels.
O S3
a REFERENCES 1.
Metropolitan Edison Company and Jersey Central Power and Light Co=pany, " Environ ental Report Operating License Stage - Three Mile Island Nuclear Station Unit 1 and Unit 2," AEC Public Document Room, AEC Docket No.59-289 and AEC Decket No. 50-320, October 1,1970.
2.
Metropolitan Edison Company and Jersey Central Power and Light Cocpany, "Three Mile Island Nuclear Station - Unit 1 Final Safety Analysis Report," AEC Public Document Room, AEC Docket No. 50-289, March 19, 1970.
3.
Metropolitan Edison Company and Jersey Central Power and Light Co=pany, 'Three Mile Island Nuclear Station - Unit 2 Preliminary Safety Analysis Report," AEC Public Document Room, AEC Dccket No.
50-320, March 10, 1969.
4.
Peterson, Harold T., Jr., '"Public Health Evaluation Three Mile Island :helear Station Unit No.
1," Deparr=ent of Health, Education and Welfare, Public Health Service, National Center for Radiological Health, Environmental Surveillance and Control Program, Nuclear Facilities Section, NF-68-2, February 21, 1968.
5.
Peterson, Harold T. Jr., "Public Health Evaluation Threa Mile Island Nuclear Station - Unit #2 - Addendu: No. I to the Public Health Evaluation of the Three Mile Island Nuclear Station,"
Department of Health, Education, and Welfare, Public Health Service, Bureau of Radiological Health, Division of Environ ental Radiation, iclear Facilities 3 ranch, NF-68-2a, July 30,1969.
6.
Metropolitan Edison Company, "Three Mile Island Nuclear Station Unit 1 Preliainary Safety Analysis Report," AEC Public Document Roo=,
AEC Docket No. 50-289, October 2,1967.
7.
Atomic Energy Co==ission, " Control of Releases of Radioactivity to the Environment," Title 10, Part 20 - Standards for Protection Agains t Radiation, Part 50 - Licensing of Production and Utilization Facilities, Federal Re2ister, Vol. 35, No. 234 - Itursday, December 3, 1970.
8.
Fowler, Ted W. and David E. Voit, "A Review of the Radiological and Environmental Aspects of Krypton-35," U.S. Department of Health, Education, and Welfare, Public Health Service, Consumer Protection and Envirottental Health Service, Environmental Control Administration, Bureau of Radiological Health, Division of Environ = ental Radiation, Nucle Facilities Branch, 22-69-16 Revision 6/ 70, September,1969.
9.
Kahn, Bernd et al., " Radiological Surveillance Studies at a Pressuri:ed Water Nuclear Power Reactor," ".S.
Department o f Health, Education, and Welfare, U.S. Public Health Service, Environ ental Health Service, 3ureau of Radiological Health, Division of Environ-cental Radiation, Radiological Engineering Laboratories, 3RH/ DER 70-3, Draft (To be published early 1971).
N N.O
10.
Federal Radiation Council, Report No.1, Background at erial for the Develoo ent of Radiation Protection Standards, U.S.
Governnent Printing Of fice, Washington, D. C., May 13, 196 0.
11.
"?ublic Health Review, Forked River Nuclear Station Unit 1,"
U.S. Department of Health, Education, and 'a'elfare, Public Health Service, Environ = ental Health Service, Eureau of Radiological Health, Division of Environmental Radiation, Nuclear Facilities Branch, DER /NF3 70-12, October,1970.
12.
Ato ic Energy Cc= mission, "I.icensing of Production and Utiliza-tion Facilities, 10 CIR Part 50, Plans for Coping with Energencies,"
Federal Regis ter, Vol. 35, No. 99 - Thursday, May 21, 1970.
13.
Metropolitan Edison Company and York Haven Power Company,
" Application for Approval to Permit Joint Use of Project '4aters for Additional Unit of Nuclear Generating Station," Project Mo. 1888, Federal Power Co::ission, July,1970.
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