ML19240B752

Responds to 810220 & 23 Ltrs Re Advisory Panel Recommendations on Contaminated Water & Preshipment Solidification Requirement for Low Level EPICOR-II Spent Resin Waste.Nrc Recommended Deletion of Requirement

ML19240B752
Person / Time
Site:	Crane
Issue date:	04/09/1981
From:	Hendrie J NRC COMMISSION (OCM)
To:	Minnich J DAUPHIN COUNTY, PA
References
NUDOCS 8104150591
Download: ML19240B752 (3)

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Dear Mr. Minnich:

9 I am writing in response to your letters of February 20 and February 23, 1981 in which you forward Advisory Panel recommendations on contaminated water and request the NRC to waive its preshipment solidification requirement for low-level EPICOR-II spent resin waste. The Commission greatly appreciates the Panel's extensive and timely efforts to provide its recommendations.

The NRC staff recently completed its review of the licensee's request for relief from this requirement and on March 18, 1981 recomended that the Comis-sion approve deletion of this requirement. The staff also recomended that the licensee be authorized to dispose of 22 low-level resin liners (second and third stage liners) at a comercial shallow land burial site. The Comission unanimously approved these recommended actions on March 23, 1981.

The remaining EPICOR-II spent resin liners consist of 50 first stage liners, three of which are similar to the second and third stage liners in that their total curie content is within the normal range of reactor resin wastes. The other 47 first stage liners contain specific activities which are unique and unlike those routinely generated and disposed of by other nuclear power plants.

DOE has a program underway to examine and characterize the condition of the resins and liners for one of these units at a DOE contractor's facility. The knowledge gained from the characterization work by DOE may provide an improved basis for the handling and disposal of all first stage wastes and since solidi-fication of these wastes could foreclose options for further treatment, we believe that 1' is prudent to defer any decisions on disposal of first stage wastes until sucn information is obtained. Therefore, while we have authorized removal of the requirement for solidification of EPICOR-II wastes, we have not yet authorized a method for disposal of the first stage wastes.

The Comission agrees fully with the Panel's recomendations concerning contam-inated water forwarded in your letter and has found the staff's Final Programatic Environmental Impact Statement (PEIS) to be responsive to those recomendations.

Specifically, I would make the following coments.

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,j Mr. John E. liinnich.FW ADVISORY PANEL REC 0!NENDATION 91: That the radioactive contaminated water y

Toceted in the Reactor Building be decontamirated as rapidly as possible,

)j using the licensee's proposed Submerged Demineralizer System (SDS) currently I

being constructed. This recommendation, specific to the SDS System, is contin-gent upon approval of that system by the Nuclear Regulatory Comission.

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The Comission agrees that radioactively contaminated water located in the reactor building should be decontaminated as soon as possible. The licensee's i

SDS, proposed for processing water located in the basement of that building, is expected to be constnt..ed and operable ir.14ay 1981. Assuming timely

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receipt of a satisfactory proposal from the licensee, the HRC staff's ongoing evaluation of the SDS is alb expected to be completed during May 1981. HRC approval of the SDS, or other decontamination system option, will be consistent with the ALARA (as low as reasonably achievable) principle and appropriate technical specifications for release of radioactive effluents contained in the I

final PE75.

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ADV_ISORY PANEL RECOMf'ENDATION #2: That the approximately 1.6 million gallons of decontaminated water, expected as a result of TMI-2 decontamination activities, c

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be stored initially in on-site tanks to permit accurate assessment of its residual radioactivity content prior to a final decision regarding ultimate d

disposal of the water, ki The Comission agrees with this recomendation and supports the following con-clusion in the staff's Final PEIS (Section 12.):

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"A decision on the ultimate disposal of the processed water can 75 be deferred until after ti.e water has been processed. Then, the f4 concentration of radionuclides remaining in the water will be low ff enogh for the water to be stored safely onsite until the disposal

1. )1 decision is made. Processing the water to imobilize most of the radionuclides and storage of the processed water will not fore-

,j close any reasonable options for disposition of the water or concentrated wastes."

)g ADV.TSORY PANEL RECOMMENDATION #3: That the appropriateness of the continued Q) on-site storage of the decontaminated water be reviewed annually by this

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Advisory Panel.

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3 The NRC s Laff will, at tha request of the Panel, provide information to assist the Panel in making its annual review.

j ADVISORY PANEL REC 0F!iENDATION #4: That to the extent practicable, Metrr iltan 2

Edison Company should minimize additional on-site water requirements, by

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maximizing the use of recycled decontaminated wcter.

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The Comission agrees with this recommendation.

In his January 12, 1981 jf letter to Herman Dieckamp, ther Chairman Ahearne directed t'etropolitan Edison g

to " minimize the volume of water used in cleanup activities, maximize reuse of prccessed water, and reduce cross-ccntamination of processed water to the

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maximum pracucable excent."

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q Hr. John E. Mbnich ADVISORY PAflEL REC 0!91DiDATI0tl f 5: That the radioactive contaminants (excepting

' tritium) in the unprocessed water at TMI-2 should be reconcentrated and imobi-lized as expeditiously as possible, consistent with Regulatary requirements.

The Comission agrees with this recommendation and supports the following con-clusion in the staff's Final PEIS (Section 12.):

"Treacment of the contaminated accident water will transform the entrained radioactivity from its current mobile state to a more manageable form by concentrating and immobilizing the activitity by an appropriate process. The cleanup activity - ill eliminate the w

risks associated with leaving the contaminated accident water radio-nuclide inventory in the mobile unprocessed state."

ADVISORY PANEL PECOMMENDATION #6: That the design and operation of decontamina-tion systems for processing radioactively contaminated water should minimize, as far as practicable, the amounts of re;1 dual radioactivity in the resulting processed water. The Panel believes the following curie inventories for all processed water resulting from cleanup activities are achievable:

i Isotope Curies 3

I Sr-89, 90 0.1 Cs-134 0.2 Cs-137 0.5 The Commission agrees that a decontamination system for processing radioactively

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contaminated water should be designed and operated so as to minimize, to the extent practicable, the amounts of residual radioactivity in the product I

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water.

In the Final PEIS the staff has proposed technical specifications for releases of idioactive effluents during the cleanup. Within these technical specifications, the staff has emphasized that all cleanup operations be conducted in accordance with an ALARA (as low as reasonably achievable) philosophy as described in 10 CFR Parts 20 and 50.

The staff has informed the Commission that the listed curie inventories for all processed water resulting from the cleanup are achievable.

The Comission expects to receive continuing advice from the TMI-2 Advisory Panel on major activities required to accomplish expeditious cleanup of the THI-2 facility. This advice is expected to provide the Comission with important information throughout the cleanup process.

Again I would like to offer my thanks as well as those of my fellow Commissioners for a job well done.

C/R NOTE: This letter has been cleared with allSincerely, Cmrs.' offices.

It was retyped in C/R to incorporate comments.

Origind Signed By Orig. Off:

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mWG DAUPHIN COUNTY HARR!SBURG. PENNSYtVAN A February 20. 1981 Commissioner John F. Ahearne, Chairman United States Nuclear Regulatory Commission

-ashington, D.C.

20555

Dear Commissioner Ahtarne:

I am pleased to transmit to you the first report of the Advisory Panel for the Decontamination of Three Mile Island, Unit Two.

As you know, the Advisory Panel was established by the Nucleur Regulatory Commission on October 28, 1980, to consult with and provide advice to the Comm:ssion on clean-up activities on Three Mile Island.

The Commission requested that the Advisory Panel provide advice on the Draft Programmatic Environ-mental Impact Statement (PEIS, NUREG-0683).

In your letter of November 7, 1980, you requested that we address specifically the question of disposition of processed water.

During a later telephone conversation, you set the deadline on the water question as of February 28, 1981.

The Advisory Panel has reviewed the Draft PElS.

It has held several meetings and heard testimony by representatives of Metropolitan Edison Company / General Fublic Utilities, the Department of Energy, the Advisory Committee on Reactor Safety and Safeguards, and members of the public.

Before I detail the recommendations of the Panel concerning the proces-sing of the contaminated water at TMI, I have been asked to express a very real concern of the panel membe s in general. That concern is the inability to dispose of the low /high level radioactive waste generated as a result of processing the contaminated water.

The Panel's deep concern is that TMI is being converted into a storage area for this waste, as a result of a lack of, or the inability of, the Eegulatory agencies to allow disposal of the waste promptly and efficiently.

We, the Pancl, feel that disposal of the waste is a package item in the clean up of the water.

It makes little sense to process the water if the resulting radioactive waste is to be remo"ed from the Containment Building to other areas on the Island for indefinite storage.

I cannot emphasize enough the concern of the Panel on this matter.

I would close this paragraph by advising you that recommendations on disposal of the radioactive wastes will be forthcoming from the Panel.

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~ s Following are the recommendations of the panel concerr. fag the contami-nated water:

RECOMMENDATION #1.

That the radioactive contaminated water located in the Reactor Building be decontaminated as rapidly as possible, using the licensees proposed Submerged Demineralizer System (SDS) currently being constructed. This recorurendation, specific to the SDS System, is contingent upon approval of that system by the Nuclear Regulatory Commission.

RECOMMENDATION #2.

That the approximately 1.6 million gallons of decontaminated water expected as a result of TMI-2 decontamination activities, be stored initially in on-site tanks, to permit accurate assessment of its residual radioactivity content prior to a final decision regarding ultimate disposal of the water.

RECOMMENDATION #3.

That the appropriateness of the con-tinued on-site storage of the decontaminated water be reviewed annually by this Advisory Panel.

RECOMMENDATION #4 That to the extent practicabic, Metropolitan Edison Company should minimize additional on-site water requirements, by maximizing the use of recycled decontaminated water.

RECOMMENDATION #5. That the radioactive contaminants (excepting tritium) in the unprocessed water at TMI-2 should be reconcentrated and immobilized as expeditiously as possible, consistent with Regulatory requirements.

RECOMMENDATION #6.

That the design and operation of decontamination systems for processing radioactively contaminated water should minimize, as far as practicable, the amounts of residual radioactivity in the resulting processed water.

The Panel believes the following curie inventories for all processed water resulting from clean-up activities are achievable:

Isotope Curies Sr-89,90 0.1 Cs-134 0.2 Cs-137 0.5 Should you have any questions concerning the above recommendations, par-ticularly background information, I would be more than happy to provide the information to you.

At this time, I do not feel it appropriate to go into background discussions, since such information is already available in the transcripts provided from each meeting of the Advisory Panel.

Looking forward to your response, I am Sincerely }lours, E bTvd J6hn E. Minnich, Chairman Advisory Panel for the Decontamination of Three. Mile Island, u it Two

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.4AR R:SBURG. PENNSYLVAN.A r'bruary 23, 1981 Co r issioner John F. Ahearne Unit (d States Nuclear Regulatory Commission Washingten, D.C.

20555

Dear Com issioner Ahearne:

During the Advisory Panel for Decontamination of Three Mile Island, Unit 2 eeeting of February II, the disposal of the existing low-level waste was discussed. The discussion centered around the resins con-taining low-level radioactivity, as a result of utilization of the Epicer-2 System.

At the above referenced meeting, the Panel agreed and in fact authorized me to correspond with you concerning this matter.

We feel that the N.R.C.

should waive the requirement for solidification of the subject vaste when Metropolitan Edison has met all requirements insofar as avoidance of leakage, safe transportation, shielding and other precautions for shipping the wastes in present containers. We believe the waste shou?d be shipped to a commercial burial site as soon as possible, provided there are no dangers to the public during the transportation, Metropolitan Edison has submitted a request for such a waiver and w; urge imediate consideration of Met Ed's request.

It is our feeling that Three Mile Island has served as a storage site for an unconscionable amount of time, and urge the safe removal of the resins in the present state as soon as safety requirements have been met.

Should vou have any cuestions on the contents of this letter, please do not hesitate to contact me.

Sincerely yours, d,

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Minnich, Chairman Citizens Advisory Panel for the Decontamination of Three Mile Island, Unit 2 JEM:kds

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" A", BURG. PEN NSYLVAN A PHIN COUNTY hah e, February 23, 1981 The Honorable Jaces B. Edwar6s Secretary of Energy Department of Energy Washington, D.C.

20585

Dear Sir:

I em the Chairman of the Citizens Advisory Panel for the Decontamination of Three Mile Island, Unit 2.

As such, I have been directeo by the Panel members to correspond with you concerning the high-level radioactive waste at the Three Mile Island sic.e.

The high-level waste is currently contained in resins used in the processing of contaminated water, and stored on site.

It is our understanding that there are approxmiately 50 containers of this highly radioactive waste.

The Panel urges you to take immediate action to arrange for the prompt and safe removal of this radioactive waste, for interim storage off site pending an ultimate decision on its disposal. We are extremely concerned that Three Mile Island has become a storage site for waste.

We are all aware that Three Mile Island was never intended for such purposes.

Further, it is our feeling that the removal of the waste would grant some relief to the anguish of many citizens of the area.

We emphasize and request that cons.deration ce given to this removal as one of unique circumstance, and not as a precedent setter of policy.

It is extremely important that the public perception of the clean up be enhanced by the immediate removal of the subject waste.

It is now almost two years since the accident and much remains to be done with the clean up.

I cannot emphasize strongly enough the Panel's concern about the high-level racioactive waste and the urgency of removal of that waste from Three Mile Island.

Additionally, you will be contacted by Mr. Bill Travers of the N.R.C.

on behalf of myself.

The Panel is seeking a meeting with you and appro-priate staff to discuss our concerns about Three Mile Island and the extreme slovness of the clean-up procesr.

I would appreciate very much if you would give this request for a meeting prompt consideration.

Should you have any questions on this matter, please do not hesitate to centict me.

My telephone number is Area Code 717-235-2740.

Awaiting your respor.;?. I am Sincerely yours, kig i-Clee t

hfchnE.Minnich, Chairman Citizens Advisory Panel for the Decontamination of Three Mile Island JEM:kds s'

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