ML19290A207
| ML19290A207 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/09/1979 |
| From: | Rosenbaum D ENVIRONMENTAL PROTECTION AGENCY |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| RTR-NUREG-0591, RTR-NUREG-591 NUDOCS 7910180589 | |
| Download: ML19290A207 (2) | |
Text
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The Secretary of the Commission U.S. Nuclear Regulatory Commission Ame
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Dear Sir:
In response to your notice in the Federal Register (44 F.R. 48829, August 20, 1979), we are transmitting these comments from our review of the " Environmental Assessment on the Use of EPICOR-II at Three Mile Island, Unit 2",
This Environmental Assessment expresses two pressing needs for decontamination of the radioactive water now in the Auxiliary Building.
One is that inleakage will soon cause storage capacity to be exceeded.
The other is that continued flooding of systems in the reactor containment may lead to their failure and degradation of the safe-shutdown status of the damaged reactor; freeing the Auxiliary Building systems for use will alleviate this problem somewhat.
In view of these needs, we endorse the actions of proceeding with the treatment of the contaminated water and its removal from the Auxiliary Building.
The first paragraph in this Environmental Assessment claims that the proposed action " includes the impact of te=porary storage, packaging, handling, transportation, and burial of the solid waste genera:ed from the cleanup operation using EPICOR-II." This document does not actually address activities subsequent to placing the waste into storage on site.
Although the proposed actions may be limited as in this document, the discussion of their influence on other activities should have included the potential influence of these actions on offsite transportation and disposal of the waste, and whether solidification of the waste is needed and desirable.
In addressing the offsite transportation and disposal of the wastes, comparisons should be =ade to other radioactive waste sources, and in particular to the normal waste shipments from a PWR.
An EPA study ("An Analysis of Low-Lavel Solid Radioactive Waste from LWRs through 1975", ORP-TAD-77-2) indicates that in 1976 on the average, a PWR shipped for the year about 275 cubic meters of filter sludges, resins and evaporator bottoms, containing about 430 curies of cesium-137 and about 1200 curies of other radionuclides with shorter half-lives. NUREG-0591 indicates that the resins in (uestion will contain about 30,000 curies of cesium-137, in about 70 cubic meters.
Therefore, the cleanup wastes from TMI clearly differ in magnitude and concentration from those from normal operations.
Consideration should 2226 050
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2 be given to the issue of whether the cleanup wastes from TMI merit special packaging and handling.
The waste in question is just one of the first installments of wastes from TMI, and therefore this is an issue that should be settled early.
Although the proposed system appears adequate for the actions addressed in this Environmental Assessment, there are two other matters that should be considered.
One is whether the packaging of the resins is suitable (e.g. corrosion resistant) for lengthy storage if disposal is delayed for some reason.
The second is whether the proposed packaging and storage procedures would in any way preclude, or present severe difficulty to, further processing of the wastes such as solidification.
We appreciate having this opportunity to present our views, and will be pleased to discuss these ccmments further if you wish.
Sincerely yours, af,W51-/ 0 David M. Rosenbaum Deputy Assistant Administrator for Radiation Program.* (ANR-458)
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