ML19263F013
| ML19263F013 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/13/1979 |
| From: | Wohlsen A PENNSYLVANIA, COMMONWEALTH OF |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 7910240464 | |
| Download: ML19263F013 (8) | |
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Attention: Docketing and Service Branch City of Lancaster's Comments on NRC Staff's Environmental Assessment of Use of EPICOR-II at Three Mile Island, Unit 2 Gentlemen:
The City of Lancaster believes the assessment is inadequate, and urges the Commission to reject it and order an environmental impact statement from an agency or firm not associated with the nuclear industry or the NRC staff. The assessment. is inadequate for the following reasons:
1.
The assessment sets forth bare and unsupported conclusions and does not comply with Council on Environmental Quality regulations (10 C.F.R. 51508.9).
It does not provide supporting calculations, details, data, evidence, or analysis; instead, it provides only a description of EPICOR-II, and unfounded conclusions and expectations.
It does not give facts about the environmental impacts of alter-natives, and does not list the agencies and persons consulted.
2.
The assessment fails to discuss known facts which could have significant adverse environmental impacts. The most glaring omission is the failure to report and discuss the concentrations of radioactive nuclides that would be left in water processed by EPICOR-II as com-pared to those that would be left in water processed by other systems.
It has been conceded by the licensee and the NRC staff that radioac-tive tritium will not be removed by EPICOR-II, yet nowhere is this problem mentioned or dealt with. This problem must be addressed.
3.
The assessment contradicts statements made by Met Ed and NRC officials at public briefings and under oath in depositions that occu-pational exposures to TMI workers are not a reason to rush to process the wastewater.
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Secretary of the Commission Page 2 September 13, 1979 4.
The assessment is an after-the-fact rationalization of the particular decontamination alternative which was chosen and constructed prior to the preparation of the assessment.
The NRC staff states on page 3 of the assessment that it helped develop the EPICOR-II alternative.
Now the NRC staff promotes EPICOR-II in order to pro-cess the wastewater as quickly and inexpensively as possible, rather than as safely as possible.
As a promoter, the NRC staff is incapable of restoring public trust in the safety of IHI operations.
5.
The assessment is misleading in that it argues that disposal of the processed water is a separate issue, while paragraph 6.0 acknowledges that the goal of EPICOR-II is to produce water of suf-ficient quality only for discharge to the Susquehanna.
The assessment does not discuss how the use of EPICOR-II, in comparison to the use of other processing systems, would affect the choice among alternatives for the disposal of the processed water.
The assessment fails to discuss how discharge specifications for the processing system would be affected by disposal alternatives. Will the same radioactivity standards apply if the processed water is (1) evaporated?, (2) stored on site?, (3) shipped off site?, (4) discharged to the Susquehanna?
Can EPICOR-II satisfy the standards which would apply to each of the disposal alternatives? When assessing an action, direct and indirect effects, and the cumulative impact of the action should be discussed.
Processing of the intermediate level water will result in processed water ready for disposal. How will it be disposed of ? This ultimate question must be considered before EPICOR-II can be evaluated in con-text.
The Commission's May 25 statement contemplated the preparation of a single assessment composed of three portions.
This first portion cannot be judged without knowing if the use of EPICOR-II makes one disposal alternative more likely or feasible than the others.
6.
The assessment fails to recognize that the "as low as is reasonably achievable" standard for radiation protection requires much more stringent limitations and protections for TML operations af ter the accident.
The definition in NRC regulations (10 C.F.R. 20.1(c))
of the "as low as is reasonably achievable" standard requires taking into account societal and socioeconomic considerations.
People in the geographical area of TMI have already been subjected to psychological stress and significant uncontrolled releases and exposures caused by the accident and continuing mistakes at the site.
Fear and distrust of the operations at TMI are rampant in the area around TMI.
These societal and socioeconomic considerations prevent standards and proce-dures fixed before the accident from satisfying the "as low as is reasonably achievable" standard for TMI after the accident.
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Secretary of the Commission Page 3 September 13, 1979 mistakes continue at the site, despite the presence of senior Met Ed officials, consultants, and the NRC staff.
On July 26, 4,000 gallons of water not analyzed for strontium 90 were dumped in the Susquehanna River, apparently in violation of an agreement between the NRC and Met Ed.
On August 28, six TMI workers received 10 times the allowable annual beta skin exposure because of Met Ed's errors in calculating the level of beta radiation for repairing a leaking valve.
Only much more stringent standards can improve Met Ed's performance, and the public's attitude toward TMI.
7.
The assessment conveys an illusion of safety and protection, but fails to address numerous relevant safety questions and risks.
The assessment's implications of safety and feasibility are suspi-clously similar to the assertions made several years ago about the safety and feasibility of long term nuclear waste storage. Only now are we learning from the Council on Environmental Quality and the President's Interagency Review Group on Waste Management that safe long term radioactive waste repositories may not be possible.
The decontamination of TMI's huge amounts of wastewater, and the long term storage of radioactive waste, are similar problems - they are unprece-dented and dangerous.
TMI's situation is all the more risky because hundreds of thousands of citizens live within a few miles of TMI.
Certainly, TMI's decontamination should not be rushed, or justified by such an inadequate environmental assessment, merely because the utili-ties who own TMI are eager to stop buying electricity from the power pool.
The assessment fails to address many relevant questions and risks:
2.0 only cesium-137 and iodine-131 are discussed.
The concentra-Pg. 2 tions and characteristics of every radionuclide present in the wastewater should be discussed.
For instance, Tables 2 and 3 of the assessment list several other nuclides (cesium-134, cesium-136, barium-140, and tritium), but these are not discussed.
This is particularly disturbing since their half-lives are longer than that of iodine-131. What are the direct and cumulative impacts from the release of these and other radionuclides in the wastewater?
Pg. 3 11ow can the NRC staff objectively review EPICOR-II when it admits it decided in favor of EPICOR-II prior to preparing the assessment?
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e Secretary of the Commission Page 4 September 13, 1979 2.1 Exactly how does the continued safe shutdown of IMI Unit 2 depend upon original and additional equipment in the auxil-iary building? Which original equipment must __ operated?
Which additional equipment must be operated?
3.3 What resin would be used? What are its physics and chemistry?
How would its properties change with temperature and radiation?
3.3.1 What are the " predetermined limits" to which the wastewater Pg. 8 would be processed? How will processed water be segregated from other water in the TMI liquid wasta management system, so that it can be disposed of separately?
Pg. 9 What predetermined radiation levels in the ventilation system exhaust would be allowed? What levels would cause a shutdown of the system? What types of radioactivity would be monitored? The reference to the plant radiological effluent technical specifications confirms our concerns that the NRC staff intends to allow exhausts to the atmosphere in accord-ance with specifications set before the accident and its traumatic effects.
3.4 At what preset values would automatic valves close to prevent Pg. 11 a discharge to the river? Are these the same preset values used before the accident?
If so, why? What are the poten-tial consequences of a break in the piping between the auxiliary building tanks and the pipe leading to the chemi-cal cleaning building? What are the potential consequences of a break in the pipe leading to the chemical cleaning building? How would such spills be cleaned up?
Pg. 12 Why is only iodine discussed? Why not all of the other nuclides present in the wastewater as well? What will be the radioactivity content of the demineralizer media af ter wastewater is processed?
If the media leaves the liner, how will it be retrieved? What exposures would clean-up crews receive? Since the demineralizer media would be a relatively dry material, it will be easily disbursed by the elements.
What will the exposures be if wind blows spilled deminera-lizer media into the Susquehanna, or across the river to Middletown or Lancaster?
3.5 If the exhaust ventilation system maintaining the building Pg. 13 at a negative ressure fails, nuclides in the building would AA0 USSS 2220 065
Secretary of the Commission Page 5 September 13, 1979 leak directly to the atmosphere.
In what amounts? What is the predetermined level at which radiation monitors will pro-vide alarms? What actions would be taken and notices would be given to public officials?
Pg. 13 To which releases does the staff desire to apply 10 C.F.R. 50, Appendix I? To which releases does the staff desire to apply 10 C.F.R. 207 What is the relationship between these different standards? What more stringent standards will apply because of the accident and continuing problems at TMI?
3.6 Because of the accident the public has no faith in regulatory Pg. 1, guides developed before the accident. Much stricter stan-dards should apply to TMI Unit 2 af ter the accident.
4.0 What will be the occupational exposures when filters and Pg. 15 demineralizers are transferred from the chemical cleaning building to the truck outside? What will be the exposures if the filter or demineralizer falls off the monorail, or cracks the concrete shell on the truck, or falls off the truck? How will spent. filters and liners be transferred from the transfer bell to individual cells? What will be the occupa-tional exposures if a spent filter or liner is dropped and cracks open? How will clean-up be done?
Pg. 17 Roping off the storage areas is certainly the least expensive alternative. For more safety for workers and the public, storage should be in reinforced buildings, not out in the open air behind ropes. Ropes do not stop wind, lightning, tornadoes and small planes. How will those risks be pro-tected against? How was the estimated maximum dose to an individual at the site boundary on a continuous basis calculated? What is the present dose to an individual at the site boundary on a continuous basis? How was the total integrated occupation dose of 1-5 man-rem calculated?
5.1 Once again, the NRC staff admits its significant participation Pg. 18 in the developccar. of the interim and concrete storage faci-lities on si*.e, aad then seeks to promote them.
The promo-tion of these fa. ilities cannot be unbiased.
5.2.1 What leakage vad drippagt might occur from cells stored Pg. 19 in the interf _ storage facility? When will a well be drilled in the proximity of the interim storage facility for the monitoring of ground water? Clearly, no use of the storage 2220 066 o
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Secretary of the Commission Page 6 September 13, 1979 facility should be made until several wells are drilled and background activity determined.
A grading of the area to direct rainwater away from the cells will also direct leakage away from the cells. What if the sump overflows with leakage from the cells? What will be the occupational exposure of containing it? How of ten will the cells be checked for leakage? What will be the occupational exposure of doing so?
5.5.2 Why will concrete storage modules be built only on an as-Pg. 19 needed basis? Will they be needed or will they not be needed? Will the modules, described as rectangular concrete tubes, have plugs on their ends? If no t, why not? How was this alternative chosen? What are its advantages and disadvantages? Whar other alternatives are possible?
Pg. 20 How often will liquids in the washdown and drippage sump be sampled and analyzed? How will it be determined which cells are leaking? How will they be repaired? What will determine whether the sump water will be discharged to the station drainage system? How many licensed shipping casks are available today? The licensees should be required to have all the needed casks on site prior to operation of EPICOR-II.
This would obviate the need for interim and concrete storage facilities.
6.0 Exactly what occupational exposures result from each of the Pg. 21 following actions? Making plant modificatioas? Operating the gaseous rad waste system? Taking radiation surveys?
Performing maintenance? Decontaminating the auxiliary building? What water leakage is occurring? What movements of water are required? Which components are leaking? What gaseous effluents are leaking to the environment? Why cannot the EPICOR-II tanks be used for surge capacity? What possible reasons could arise for the transfer of the highly contaminated water in the containment? Why would containment building water have to be transferred to the auxiliary building? How much leakage is occurring in the containment building? What components in the lower elevations of the building are threatened? What contingencies could arise which would require transfer of the containment building water? What components necessary for the continued safe shutdown might fail? Why might they fail?
- 6. 0.1' The reference to " producing water of sufficient quality for discharge" increase, our concerns that the NRC staff and SAO USS$
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Secretary of the Commission Page 7 September 13, 1979 licensees intend to discharge the processed water to the Susquehanna.
The reference to " satisfying release requirements" heightens our concerns that the NRC staff and the licensees still maintain their business-as-usual attitude despite the accident and the public's fears and distrust.
6.0.2 Again, the reference to " producing discharge quality water" increases our concerns.
6.0.3 The reference to a long lead time required for an evaporation Pg. 22 process directly conflicts with sworn testimony by Robert C.
Arnold, the utilities' man in charge of TMI, that an evapora-tion system was ordered in May for possible future use.
Since the assessment states toat special design provisions could reduce the occupational exposures from the use of an evaporation system to those of the use of EPICOR-II, there is no safety related reason to reject the evaporator alter-native. Clearly, the staff is recommending EPICOR-II because the staff helped create it, and because use of EPICOR-II would be quick and inexpensive, since it is alres<ly installed..
6.0.3 The assessment's conclusions are unsupported by any details Pg. 23 cr lata. The staff proposes to remove some of the radioac-tivity from the wastewater in the auxiliary building tcoke, which are inside a heavily reinforced building, and cen-centrate it in dry demineralizer resins to be stored outside.
There is no explanation given as to why this is a less likely source of public or occupational exposure.
The staff's next statement, that the earlier water processing occurs, the less the total likely exposure, occupational and public, is also totally unsupported by calculaticas or data. What exposures to the public are now occurring because of the storage of the radioactivity in the auxiliary building? How can this be more than the potential exposure when the radioactivity is stored outside?
7.0 What releases of xenon-133 and iodine-131 will be made to Pg. 23 the environment if EPICOR-II is used? Vhat other nucifdes will be released to the envircament?
It is not reassuring that "of f site exposure is expected to be
. well within
' ' applicable NRC and EPA guidelines." The pre-accident glide-c, lines sh'ould not be applicable to TMI af ter the accidenu.
37 Certainly, the operator and equipment malfunctions during and
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Secretary of the Commission Page 8 September 13, 1979 after the accident were not expected.
The public has no con-fidence in NRC staff " expectations." We have no reason to have confidence in the NRC staff's estimates of radiation releases. The NRC stated in mid-July that the xenon-133 release during the accident was more than 20 times that pre-viously estimated as the maximum credible release from such an accident.
7.0 What off-site releases in gaseous effluents are currently Pg. 24 occurring? How do these releases differ from the total possible releases which might result from the use of EPICOR-II?
8.
The assessment's conclusion that the use of EPICOR-II would not significantly affect the quality of the human environment is shocking and unjustified.
How can a major step in an unprecedented attempt to decontaminate the site of the worst commercial nuclear reactor accident in history, which caused an evacuation and widespread fear and trauma, not significantly affect the quality of the human environment?
The City of Lancaster sincerely requests the Commission to reject the assessment and order an environmental impact statement from an agency or firm not associated with the nuclear industry or the NRC staff. Only such an independent review addressing all questions and risks will be acceptable to the thousands of citizens concerned about TMI operations.
IMI wastewater should not be processed until a full environmental impact statement on decontamination and disposal is pro-duced by independent consultants and receives broad public comment.
CITY OF LANCASTER OakA.tJ4.4 _
Albert B. Wohlsen, Jr.,'
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