ML19291B271

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Responds to Hart Re TMI-2 Recovery Operations. Forwards Info Re Current Status of Contaminated Water & Options for Processing & Storage
ML19291B271
Person / Time
Site: Crane 
Issue date: 10/01/1979
From: Kennedy R
NRC COMMISSION (OCM)
To: Hart G
SENATE, ENVIRONMENT & PUBLIC WORKS
Shared Package
ML19291B270 List:
References
NUDOCS 7911060024
Download: ML19291B271 (23)


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[c b y O NUCLEAR REGULATORY COMMISS!ON u

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October 1, 1979 oPFmE oF D4E comossicura -

The Honorable Gary Hart,. Chairman Subcodmittee on Nuclear

  • Begulation Committee on Environment and Public Works United States Senate Washington, D. C.

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Dear Mr. Chairman:

This responds to a letter dated September 27, 1979 from you and a number of your colleagues on the Senate Committee on Environment and Public Works concerning Three Mile Island Unit 2 recovery coerations.

Your letter dealt with two important aspects of these operations - the contaminated water now stored at the site and the licensee's radiation protection program.

Shortly af ter receipt of your letter, the Commission requested and received a staff briefing on these issues at a public meeting of the Commission held on September 28.

Inclosure 1 to this letter discusses in some detail the current status of the contacinated water at the site and the options for processing and storage now under active consideration.

Of principal importance-in this connection is the fact that under no f o res eeable circu= stances do we plan r.or will it become necessary to put unprocessed contaminated water into the Susquehanna River.

There centinues to be sufficient waste storage capacity at the Three Mile Island site (including that currently available at both Units 1 and 2) for about 9 more conths, assuming the amount of contaminated water continues to increase at the present rate.

Notwithstanding this extensive storage capacity, th ere is a need to begin processing of the contaminated water in order to remove and im=obilize the contained radioactivity as soon as a careful consideration of the related saf ety and environ = ental considerations by the staff and the Commission will permit.

The staff -has already prepared and issued an environmental assessment of the use of "EPICOR II" to process the contaminated water now contained in tanks in the auxiliary building.

The period for public comment on these staff reports has recently expired and the staff currently plans to =ake its final recommenda-tions to the Com=ission later this week concerning the use of this system.

It is important to note that while the potential risk to the public offsite from continued storage of the conta=i-ncted water cannot be completely discounted, the principal safety concern pending processing of this watcr involves the increased likelihood of worker o'verexposure.

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T$e Honorable Gary Sart October 1, 1979

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With' regard to a related matter, your letter of September 27 correctly points out that the: staff.has in.t.be past identified a number of deficiencies..in the. licensee's radiation protection

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program which, as yet,'have not'been' corrected.. As discussed inf more detail in enclosure 2,'the staff has been pursuing these:..

., J, catters over the past several months and will continue to do.so'.

Neither they nor the Commissioners will permit expansion of the recovery program until these important issues are suitably resolved.

Again, the principal concern related to these deficiencies is in providing adequate protection for the workers on the site.-;.

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.r-Please be assured that my fellow Co=missioners and I have been actively following and will continue to follow these and other Issues related to management of the radioactive water at th e.

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Three Mile Island site, and are being periodically briefed by the staff, both orally and in writing, i.*e _will intervene at any time we or the staff believe such action is necessary to caintain. -

adequate protection for ~the workers at the facility.

You may also be assured o.f prompt NRC action if needed to protect the ~

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health and safety of the general public in the vicinity of the Three Mile Island site.

Sincercly, Lf LZ 2M Richard T. Kunnedy Acting Chait. san

Enclosures:

1.

Staff Report on Centaminated D

3 Water at Three Mile Island

'J" Site dated Septe=ber 30, 1979

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  • 2.

Staff Report on Licensee's

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Radiation Protection Program at Three td.ile Island dated September 30, 1979 Distribution Note:

Identical [etters sent to Central Files VStello J3andolph, DPMoynihan, PVDomenici NRR Rdg JSnie::ak RTStafford, AKSimpson, and H3akel EDO Rdq, OPE Jr.

SEP/TMI Rdg SECY PSS/TMI Rdg OGC RETYPED IN OFFICE OF C010iISSION HRDenton MGroff LVGossick GErtter (EDO-7450)

TRehm Attorney, OELD z009 0/3 EGCase JMullin m

onnic[5b11N$r m i ma A/ Chair =an R. T. Kennedy suasmuc >

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September 30, 1979 CONTAMINATED WATER AT THREE MILE ISLAND SITE Currently there are three major volumes of contaminated waste water resulting from the accident at the TMI-2 facility. They are:

1.

water contained in the lower level of the reactor building, 2.

water contained in the reactor coolant system, 3.

contaminated water contained in the auxiliary building tanks.

This water inventory is summarized in Table 1 and depicted in Figure 1.

The water in the reactur building is a result o# water discharged to the lower levels of the building during the accident, as well as the accumula-tion of normal leakage from the reactor coolant system following the accident and sources of uncontaminated secondary watt;r that have mixed with the contaminated water. The volume of water in the reactor building is about 630,000 callons, which i+.a level of about 7-1/2 feet above the basement floor in the reactor buildinc. The current leakace rate, principally of water from the orir.ary reactor coolant system, results in an increase in volume of about 430 callons per day and a level increase of about 2 inches per month as shown in Table 2.

Since this amount of leakage is to be expected, this source of inleakace will continue. The princioal isotopes and activity level in this water is presented in Table 3.

The reactor coolant system is another volume of contaminated water. The fixed system is comoosed of the reactor vessel, steam oenerators and associated cumos, cicing, and valves, and has a volume of about 85,000 gallons. The 2009 074

principal isotopes and activity level in this water is presented in Table 3.

Since it is a fixed system its volume does not increase but there is leakage out of the reactor coolant system into both the reactor building and the auxiliary building. As leakage occurs from the primary cooling system, replacement water is added to keep it full at all times.

The contaminated water in the auxiliary building is contained in tanks having a total capacity of about 415,000 gallons.

Currently 387,000 gallons of contaminated water is stored in these tanks; thus, the remaining capacity is about 29,000 gallons. With the current inleakage rate of about 800-1000 gallons per day, a margin of about 30 days (from September 29, 1979) remains until these tanks are filled. The details on the tank volumes and remaining capacities as well as the radioactivity levels in these tanks are given in

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Tables 4 and 5.

The dominant sources of leakage in the auxiliary building are frcm the component cooling system, demineralized water system, reactor building evaporator cooling system and from the recirculation of tanks prior to samoling. Most of this leakage is non-contaminated wate. but it becomes contaminated while passing through floor drains and sumos which are provided to collect the leakage.

Another source of water, althouch minor in volume (acoroximately 10t) is from leakace in the reactor curification and makeuo system which is also 'ocated in the auxiliary buildinQ and Contains crimary coolant water. This leakace is likewise to be expected and is from cumos and valves.

In summary the leakace of water ' rom various sources which results in an increase in the amount of ccntaminated water is from normal leakace paths. The current 2009 075

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inleakage rate to the reactor building poses no threat to the public health and safety. Although the inleakage rate to the auxiliary building is contained in tanks, it does contribute to occupational exposure. However, since the tank volumes remaining at TMI-2 are limited, a decision regarding which option to be exercised to accommodate water about 30 days hence needs to be made. These options are addressed in the following pages.

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Ootions for Accommodating Leakage of Contaminated Water The options available for accommodating the increase in the amount of contam-inated liquids at the Three Mile Island site are basically as follows:

1.

The use of EPICOR-II to decontaminate the water so that it can be placed in available tanks; 2.

The transfer of contaminated water from TMI-2 into the TMI-1 facility where tank capacity is available in the auxiliary building; 3.

Placement of contaminated water into the reactor building; and 4.

Construction of new tanks onsite which weuld be capable of storing highly contaminated liquids.

EPICOR-II The use of EPICOR-II for the processing of auxiliary building water has been

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evaluated in detail in the staff's environmental assessment, a copy of which is enclosed. The EPICOR-II system is a demineralization process which removes radioactive ions frca the water stream as it is passed over filters and resins.

This technique is well-proven through many years of use in commercial and military nuclear applications. The EPICOR-II system was designed and built following the TMI-2 accident for the purpose of processing the contaminated water generated by the accident currently being stored in the auxiliary buf1 ding.

This design and construction activity received close review and evaluation by the NRC staff, onsite as did the training of operating personnel and in the preparation of operating procedures. The actual use of the system, however, has been deferred pending resolution of objections to use of the EPICOR-II system by the City of Lancaster and the Susquehanna Valley Alliance. As a result of these objections and court actions the Commission directed the staff on May 25, 1979 to prepare an environmental assessment and allow a period for.

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for public coments. An approved draft of the environmental assessment was released for public coment on August 20,1979 and 38 public coments were received by the close of the 30-day coment period on September 19, 1979.

Of these 38 coments only three were substantive in nature. The City of Lancaster and the Susquehanna Valley Alliance were opposed to the use of EPICOR-II based on extensive technical and legal coments, which the staff currently has under consideration. The staff does not believe that any of these will alter its previous conclusion concerning the acceptability of using EPI (.0R-II.

The Comonwealth of Pennsylvania had comments which are being incorporated into the environmental assessment by the staff, the Comonwealth is in agreement with the staff that the EPICOR-II system should be used to decontaminate the auxiliary building water. A summary of these comments, along wi_th a revised environmental assessment and the staff's recomendation, will be presented to the Comission on October 4,1979.

It is important to note that the use of EPICOR-II does not involve the discharge of any processed water into the' Susquehanna River. The use of EPICOR-II, as described in the environmental assessment, is only for the decontamination of the water.and does not consider or pernit disposal of the cleaned up water.

The cleaned' up water will be such that it could be discharged under existing Federal and state regulations, but since various options exist for the water disposal, approval is being withheld until the disposal alternatives can be evaluated. Among the disposal alternatives are evaporation at the site, transport of the decontaminated water off-site, discharge at another location, re-use at the facility, and discharge into the river. As was indicated above, if the alternative of discharge into the river were to be used, this option would meet all standards, including the confomance at public drinking intakes to the EPA Safe Drinking Water Act. To date since the accident, the activity 2009 078

in the Susquehanna River at drinking water inlets has been indistinguishable from normal background levels as measured by a number of Federal and state

' agencies.

Storace in THI-l Tanks A second option for handling the increase in the amount of contaminated water is the placement of such water in TMI-1 tankage which has been available for can'tingency purposes. The tanks for storage of liquid in TMI-l are in the TMI-1 auxiliary building and have generally the same capability and safeguards as the current storage of liquid in TMI-2. Currently available storage in TMI-l is about 225,000 gallons. However, there are several reasons why the placement of water in TMI-l is not considered as the best alternative. First, putting contaminated water into additional tanks extends the scope of the

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potential problem of exposures of operators and does not reduce the mobility of.the contamination.

Further, the placement of contaminated TMI-2 water into TMI-1 tanks may require clarification of the Commission's May 25, 1979 statement which allows continued processing and discharge of TMI-l water put prohibits processing and discharge of TMI-2 water.

If TMI-2 water were to be transferred to the TMI-l tanks through existing piping interconnections between the two units, it is likely that trace ar.unts of TMI-2 contamination would be deposited on some of the piping used for processing or discharge of TMI-l water.

Consequently, subsequent processing and discharge of TMI-l water under these circumstances could be inconsistent with the Commission's May 25 statement.

In addition, public perception might be that TMI-2 water was being processed through the TMI-l facility.

In summary, although the placement of TMI-2 water into TMI-l tanks affords substantial additional capacity and protects the public health and safety, it does not appear to offer a suitable permanent solution to the problem.

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Storag4 of Water in the Reactor Building Storage of water in the reactor building is another option for alleviating the storage' problem. The reactor building currently contains about b 3,000 gallons of contaminated water and could accommodate additional water. However, the reactor building contains equipment which is vital to the continued safe shutdown of the damaged TMI-2 reactor and the addition of water into the reactor building would place some of this equipment into a situation whereby non-operability would be made more likely. Storage of wa,ter in the reactor building presents no undue risk to public health and safety since no paths of leakage to the outside have been identified. Notwithstanding this, the licensee has been asked to develop and implement a program whereby groundwater under the TMI-2 reactor building will be sampled for potential radioactive contaminants. We expect,this program would heighten assurance that none of the reactor building water is escaping.

In summary, the storage of TMI-2 water which is leaking into the auxiliary building, in the basement of the reactor building does not permanently solve the contaminated water problem and would also lessen the contingency available in the reactor building for the protection of vital equipment which might fail if submersed in water.

Con *ruction of Additional Tanks A third option is the construction af additional tanks. Tanks for storage of radioactive liquids would be required to meet regulatory requirementIs that provide substantial assurance of long term integrity, as well as for the detection of possible leakage. The construction of new tanks at the facility would pose a problem of time as well as location. As previously discussed, contingency tankage of 110,000 gallons was built after the accident in the 2009 080

8-spent f*uel pool where space was available by removal of the spent fuel storage rack. However, at this time it would be difficult to find another plant location where tanks would be constructed that would provide that same degree of public environmental protection of the current tanks that are installed in a seismically qualified auxiliary building.

In addition the same drawbacks exist as were discussed for options 2 and 3 that the creation of additional storage capacity extends the scope of the potential operator exp'osure problem and does not immobilize the contained radioactivity. There-fore, although this option could provide adequate public health and safety protection, it would not provide a permanent solution to the problem.

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UNIT 1 UNIT 2 i

Reactor Building Auxiliary Bailding.

Auxiliary Building Reactor Building f

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( 001 ant Make sp Makeup Coolar t Sys ten Syste:m tystep Systen I

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TABLE 1 THI-2 RADI0 ACTIVE WASTE WATER INVENTORY Usable Waste Water Remaining Inleakage Rate l

Capacity Volume Capacity)

Sources (gallons)

Aallons)

(gallons (gallons per day)

Remarks Reactor Building Waste Waterj N/A 6}0,000 N/A 430 See Tables 2 and 3 for detail f

Reactor Primary Coolant 85,000 85,000 0

N/A Auxiliary Building Tanks 415,190' 386,500 29,000 800 1000 See Tables 4 and l

5 for detail j

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l Sumary - Remaining days prior to filling all tanks at THI-2 based on past seven (7) day average leakage rate are 30 days l-l i

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TABLE 2 TMI-2 REACTOR BUILDING WASTE WATER INVENTORY Total Waste Water Volume

630,000 gallons Current Leak Rate
0.3 gallons per minute or 430 gallons per day Leak Sources (1) Reactor Printary Coolant System (valves, flanges and pumps)

(2) Containment Building Normal Coolers Rate of Level Increase

Approximately 2 inches per month Based on Current Leakage Mter Activity
See Table 3 1

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TABLE 3 RADIOACTIVITY CONCENTRATIONS OF PRINCIPAL NUCLIDES IN' REACTOR BUILDIt'G WASTE WATER _

(Average Value of Three Samples)

(pCf/ nil)

Cs-137 176 Cs-134 40 H-3 1.0 I-131 0.012 La-140 0.1 Sr-89 42 Sr-90 2.8 RADIO CTIVITY CONCENTRATIONS OF PRINCIPAL NUCLIDES IN REACTOR PRIMARY COOLANT (uti/ml)

I-131

<0.4 Cs-114 16 Cs-137 78 Sr-89 201 Sr-90 15.8 Ba-140 1.2 H-3 0.22 2009 085

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THI-2 AUXILIARY BUILDIfiG WASTE WATIR IfiVEriTORY i

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Haximum Waste Remaining Activity Tanks capacity Volume Capacity Conceritration (gallons)

(gallons)

(gallons)

(pC1/m))

1.

Reactor Coolant Bleed Tank "A" 77,250 77,250 0

Table 5 2.

R_ actor Coolant Bleed Tank "B" 77,250 77,250 0

Table 5 3.

Reactor Coolant Bleed Tank "C" 77,250 77,250 0

Table 5 4.

Miscellaneous Waste lloldup Tank 19,600 9,200 10,400

<0.1 1

5 Concentrated Waste Tank 9,000 9,000 0

<0.1 i

6 tieutralizer Tank "A" 8,780 8,780 0

Table 5 7.

ticutralizer Tank "B" 8,780 8,780 0

Table 5 8

Auxiliary Building Sump 7,000 3,000 4,000

<0.1 9

Auxiliary Building Sump Tank 3.200 2,600 600

<0.1 10.

Miscellaneous Waste Storage Tank - TMI 18,500 18,470 0

7.0

11. Tank Farm

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Upper 60,000 53,700 6,300 Lower 50,000 41,700 8.,300 1

1 TOTAL 415,190 386,500 29,000 No i

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TABLE 5 RADIOACTIVITY CONCENTRATIONS OF_ PRINCIPAL NUCLIDES IN REACTOR BLEED TANKS (uCf/ml)

I-131 0.011 Cs-134 7.8 Cs-137 37 RADI0 ACTIVITY CONCENTRATIONS OF PRINCIPAL NUCLIDES IN NEUTRALIZER TANKS (pCi/ml)

I-131 0.C32

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September 30, 1979 LICENSEE'S RADIATION PROTECTION PROGRAM AT THREE MILE ISLAND Subsequent to the March 28, 1979 accident, the licensee's radiation protection program has been unable to respond in a consistently adequate manner to the many unique radiation protection problems which the recovery operations present. Onsite, daily inspection and monitoring by the NRC have identified discrepancies and areas where improvements were needed to assure a greater degree of plant worker protection. Six major areas were identified which required remedial action:

Delineation of Radiation Protection Organization and Responsibilities Establishment of an augmented Quality Assurance Program Control of High Radiation Areas Evaluation of Airborne Activity Implementation ~of an Effective Bioassay Program Development of an Upgraded Respiratory Protection Program During the period February 26 through March 2,1979, at the request of Metropolitan Edison, the NUS Corporation conducted a review of the radiation protection program at Three Mile Island (TMI). The report of this review was obtained by the NRC staff an June 20, 1979 This report is critical of certain portions of the TMI radiation protection program and addresses the same general problem areas which had been identified by the NRC staff.

NRC efforts to resolve the past and current problems and obtain adequate corrective action by the licensee have been continuous. The onsite NRC 2009 088

staff has met frequently with various representatives of licensee manage-ment to identify specific concerns and obtain commitments for corrective action by the licensee. These meetings culminated on July 13, 1979, when the NRC staff discussed its intent to issue an Immediate Action Letter (IAL) to Metropolitan Edison; this discussion was held with Mr. R. Arnold, Vice President-Generation, General Public Utilities Service Company / Manager, TMI Site Operations and Mr. J. Herbein, Vice President-Generation, Metropolitan Edison Company, and members of their staffs. At that meeting the licensee agreed to take action on all of the issues identified by the NRC and in a letter dated July 18 confirmed the actions which would be taken and specified expected completion dates; therefore the IAL was not issued.

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Since July 18 the licensee has submitted reports (in letters dated August 6,

'13,16 and September 10) of the actions taken in followup of the ccIhnitments. Continuing NRC observations and inspections have shown, however, that improvements in the program have been and continue to be slow.

The following discussion identifies the six major programmatic areas which required remedial action and summarizes the deficiencies and current status of corrective actions.

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DELINEATION OF RADIATION PROTECTION ORGANIZATION AND RESPONSIBILITIES In the immediate post-accident period, the delineation of specific areas of responsibility for radiation protection activities were not sufficiently definitive to assure that all matters important to worker protection were adequately managed and implemented. The licensee has subsequently better defined and assigned the. responsibilities associated with matters important to worker protection. The adequacy of implementation of the assigned responsibilities is being monitored and evaluated by onsite NRC personnel on a continuing basis. The staff is not yet completely satisfied with the overall coordination of the total worker protection program at the site. The licensee was to establish a means for overall coordination of worker protection and delineate the specifics in its Radiation Protection Plan which was submitted for NRC review and approval on September 28. The staff has not yet completed its evaluation of the Plan.

ESTABLISHMENT OF AN AUGMENTED OUALITY ASSURANCE PROGRAM The magnitude of the radiation protection challenge during the recovery operations required that the licensee institute an augmented Quality Assurance Program which would provide a comprehensive overview of 2009 090

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the effectiveness of the radiation protection program and verify that necessary corrective measures are implemented. The new Quality Assurance Program was instituted by the licensee on September 10. The program is being implemented by licensee and contractor personnel who are not responsible for the conduct of the day-to-day radiation protection activities. Audit results from the program are not yet available for NRC review. As soon as they become available, they will be reviewed by the NRC onsite staff.

CONTROL OF HIGH RADIATION AREAS The accident produced many high radiation areas within the plant.

Identification of these areas and control of worker access to these areas during the recogry operations was and continues to be an item which demands continuous licensee attention. On September 10, the licensee completed development of procedures for identification and control of'high radiation areas. NRC has reviewed and approved the procedures.

Our overview indicates a lack of effectiveness of the licensee's implementation of the procedures; there are still some problems in implementing the " key control" aspects of controlling worker access to high radiation areas in Unit 2, and the procedures have not yet been implemented in Unit 1.

The NRC onsite staff is interfacing with the licensee to resolve this problem.

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e 5-EVALUATION OF AIRBORNE ACTIVliY The isotopic distribution of airborne radioactivity within the plant and the changing nature of this distribution during the recovery operation was not fully appreciated.

Consequently, the procedures and methods utilized for determining the concen: ration of airborne radioactivity within the plant were not always correct. On September 4, the' licensee issued temporary procedures for evaluation of air samples.

The NRC onsite staff has reviewed the procedures and found them to be adequate. Our onsite staff is monitoring the ifcensee's implementation of the temporary procedures. The licensee is scheduled to issue permanent procedures for evaluation of air samples by October 7.

The NRC will review the procedures for adequacy.

IMPLEMENTATION OF AN EFFECTIVE BI0 ASSAY PROGRAM Subsequent to the accident, the bioassay program in effect at the plant was found to be inadequate,especially as related to the deter-mination of suspected acute and chronic exposures to isotopes that are not expected to exist at nuclear power plants in normal operations (e.g., Sr-89 and Sr-90). The NRC onsite staff reviewed the licensee's revised procedures for the bicassay program on August 17, and was not satisfied that they were adequate. The licensee was provided with comments from our onsite staff and is scheduled to have new procedures submitted for NRC review by October 10.

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DEVELOPMENT OF AN UPGRADED RESPIRATORY PROTECTION PROGRAM The levels of airborne activity experienced in the auxiliary building subsequent to the accident and the potential for airborne activity during recovery operations dictated the need for an upgraded respiratory protection program. The need was identified for action levels for

'Sr-89 and Sr-90 analysis, for improved "staytime" calculation procedures, and improved procedures for the testing, use and cleaning of respirators. The necessary procedure improvements were completed and found acceptable by the NRC onsite staff on September 24. The licensee is presently training personnel regarding the use of the procedures. The revised program is scheduled for full implementation by October 7.

The effectiveness of the implementation will be monitored

'by the NRC onsite staff.

SUMMARY

The licensee has upgraded and continues to upgrade and improve the radiation protection program, but these improvements have been and continue to be slow. Our onsite inspectors have been and will continue to monitor the progress of the licensee in meeting his comnitments for improvements in the operational aspects of worker protection.

The August 21 report from Messrs. Neely and White demonstrates the diligence of our inspectors in accomplishing this function.

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-7 The radiation protection program that presently exists at Three Mile Island, in conjunction with the NRC health physics overview, is adequate to provide for protection of the general public and for worker protection at the present level of recovery activity. As the licensee undertakes additional operations (e.g., processing of the highly radicactive Unit 2 water, entry into the Unit 2 containment,

.and possible defueling of Unit 1), we will need to continue to be vigilant to assure that the radiation protection program is imple-mented in a manner that provides for continued worker protection. To provide additional assurance that both the licensee and the NRC have ccnsidered all facets of the radiation protection challenge that exist during the recovery operations, a five member " Blue Ribbon" panel will be convened'by the NRC staff to perform an independent

, assessment of the potential radiation protection problems that may be experienced during the recovery operations. A majority of the panel, including the Chairman, will. be composed of experienced health physicists from outside the NRC. A report to the NRC of their assessment is expected to be completed within one to two months.

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