ML19308B299
| ML19308B299 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/25/1979 |
| From: | Walker R HOUSE OF REP. |
| To: | Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19308B297 | List: |
| References | |
| RTR-NUREG-0591, RTR-NUREG-591 NUDOCS 7912280313 | |
| Download: ML19308B299 (1) | |
Text
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' ROBE 'T C.WAL.KER
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GEcstGE W. JACKSON consestTTessi
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- SCENCE AND TECHPeOLOGY 31)ouge of Repredtutatibed Elasfjhtston,D.C. 20515 p
September 25, 1979
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Enh Honorable Joseph Hendrie Chairman Nuclear Regulatory Commission
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1717 H Street, N.W.
Washington, D.C.
20555
Dear Chairman Hendrie:
Enclosed please find the comments prepared by two geologists from Franklin and Marshall College in Lancaster, Pennsylvania ccncernirag your staff's Environmental Assessment of the Use of Epicor II at Three Mile Island, Unit II.
It is my view that their comments deserve your attention and consideration.
I will be looking forward to receiving your reply.
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FRANKLIN and MARSHALL COLLEGE LANCAsTER. PENNSYLVANIA 17604 O!PARTMENT of GEOLOGY September 14, 1979 Secretary of the Comission y...j.}
fluclear Regulatory Comission l!ashingten, D. C.
20555 Attn:
Docketing and Service Branch
Dear Cc=issioner:
Enclosed are our cements on your staff's report entitled Environmental Y
Assessment:
Use of Ecicar-II at Three Mile Island, Unit II. As scientists il familiar witn environmental assessments, we are appalled at the lack of
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precise data, the limitations of scope, and the overall poor quality of the scientific analysis presented by your staff.
We doubt that representatives of private industry would ever consider submitting to a regulatory agency such a vague and poorly-documented assessment of a proposed action involving dangerous materials.
If they tried, their assessment would be summarily rejec:e d.
It is inceed lamentable that,although the assessment was prepared by a federal regulatory agency, it does little to protect and reassure a skeptical and frightened public.
In addition, the preparation of this report was a waste of the taxpayer's money.
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We urge you to take a few minutes to read these coments carefully. They provice s:me insignt into the poor quality of regulatory efforts of the flRC.
, Yours truly,
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Arthur H. Barabas, Ph.D.
Assistant Professor of Geology Coordinator of Environmental Studies Program p
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cc:
Hon. Robert S. Walker Hon. Albert Wohlsen, Jr.
Steven Sylvester, M.Sc.
Hon. Allen E. Ertel Specialist in Geology Hen. William Goodling Hon. Richard Thornburgh Hon. Morris Udall Jean Kohr, Esq.
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Lancaster County Commissioners '
Susquehanna Valley Alliance Dr. Jonn G. Xemeny lDh 0
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FRANKLIN and MARSHALL COLLEGE LANCAsTER. PENNSYLVANIA 17604 OEPARTMEPeT of GEOLOGY iis E;fE E Z
The Environmental Assessment entitled Use of Eoicor-II at Three Mile Island, prepared by the staff of the Nuclear Regulatory. Commission, is a E=
q seriously flawed and incomplete study. The NRC staff's recomendations supporting the use of the Epicor-II system are unwarranted in light of the following significant shortcomings of the published study:
1.
The scope of the present assessment is too limited to allow the
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p>See craper evaluation of the particular cleanup step involving Epicar-II in the larger context of the entire cleanup operation at TMI.
2.
The lack of sufficient detail in the description of the Epicor-II
- leanup stage prevents a critical analysis of this step and does not support the broad c:nclusion: dnwn by the NRC staff.
3.
Detailed evaluation reveals ambiguities in the date on occupational radiation exposure levels cited in the assessment. Thus, the estimates of 1-5
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an-rems of exposure from the use of Epicar-II are suspect.
The study neglects c consider other aspects of worker safety.
4.
The evaluatiert of alternatives to the use of Epicor-II is perfunctory and appears to be based more on the expediency of justifying an already con-structed system than on considerations of possible impacts on the public health.
5 5.
Procedurally, the NRC staff exceeded and compromised the NRC's regulatory authority by providing design guidance for the Epicor-II system
- efore completing an environmental assessment of this system and possible alternatives to it.
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=m Bas'ed on the detailed discussion which follows, we recommend that the NRC Comissioners reject their staff's assessment. A broader, more detailed study should be initiated imediately.
Since the NRC staff provided significant rF assistance in the design and construction of the Epicor-II cleanup system
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(page 3, section 2.0), the new assessment should be done by a group or agency independent of the NRC.
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Detailed Discussion of Princioal Shortcominos of the Present Environmental Assessment 1.
Limited Scoce of the Present Environmental Assessment The assessment estimates dangers and exposure levels to the public based
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only on the use of Epicor-II to clean a small fraction of the radioactive water at TMI. Since the biological effects of radiation are cumulative, the public health will be affected by all radiation emissions resulting from the complete s
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cleanup of TMI.
In order to evaluate the advisability of using Epicor-II, data on resultant exposure levels from other cleanup activities are first needed.
In addition, Epicar-II and its alternatives should be compared in the context of total exposures resulting from comolete cleanup of TMI. (Jntil assessments covering each phase of the cleanup (up to and including removal of TMI's fuel rods) are completed and published, it will not be possible to evaluate the impact Epicor-II's use will have on the public.
2.
Lack of Sufficient Detailed Information While the assessment does provide estimates of off-site exposure levels
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resulting from the use of Epicar-II,no data or explanations are provided on how tnese estimates were made. The assessment does provide an explanation of how en-site exposure levels y ere calculated, but detailed inspection of these estimates reveals serious ambiguities (see section 3 of this report).
The assessment leaves unanswered a number of critical cuestions about the h
use of Epicor II and the,sitimate disposition of the 2500 cubic feet of Epicor-II generated radioactive waste.
It is not clear whether Epicor-II will be used to process water other than that in the auxiliary building. The construction of more on-site waste storage modules than required for the liners suggests that additional treatment of contaminated water, beyond the 280,000 gallons of mjje~
intermediate-level radioactive waste water described in the assessment, is being considered by Met. Ed. or by the NRC.
If additional treatment is projected, tne added radiation to which the public and plant workers will be subjected y
should be clearly described.
Although the exposure levels expected during the cperation of Epicor-II are discussed, the assessment does not consider whether tne Epicor-II system's components will become radioactive as a result of its proposed use. Plans for dismantling and disposing of the contaminated system are not included in the assessment.
The impact of the proposed storage and burial at TMI of the 2500 cubic
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feet of radioactive waste generated by Epicor-II is only incompletely assessed.
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Descripti'on of the interim storage facility (.5.2.1), which will house the radioactive waste, does not include estimates of seismic integrity, details of the structural strength of the corrugated metal walls, calculations of the effects of freezing and thawing, and an estimate of the possibility of flooding
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by groundwater infiltration.
Most significantly, the assessment does not provide
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an estimate of the time span over which the integrity of the interim storage facility is assumed.
The assessment states that a well will be drilled near e
the interim storage facility "to assure that no activity migiates from the W
liners to the groundwater" (p.19).
If radioactive contamination is detected
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in this well, we doubt that the well could assure that migration of radioactive material had not or would not occur.
In fact, the presence of a well might even accelerate such migration.
Description of the concrete storage facility, which will provide longer term storage of the same wastes, suffers from the same deficiencies as does the interim storage facility (except for freeze-thaw considerations). The assessment g
provides no estimate of how long radioactive wastes will be stored at TMI.
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The concrete storage facility is. described (5.2.2) as consisting of modules of 60 storage cells each capable of housing one large or two small resin storage liners.
Epicor-II is anticipated to generate 50 liners.
To satisfy storage requirements for Epicor-II waste only one module is needed.
Section 5.2.2 indicates space is available to build 6 modules for storage of radioactive wastes.
Before the assessment is accepted, it should be clearly stated what will be stored in these other modules and the resultant exposure levels to plant personnel and the public should be determined.
Section 5.2.2 discusses final disposal of the radioactive wastes and indicates that off-site shipment will occur as." licensed shipping casks become available." Since on-site storage will result in release of radiation (5.2.2) the assessment should first determine if licensed snipping casks are available, as well as when and at what rate transport to a licensed burial ground is to take place.
The assessment does not consider the alternative of demineralizing l
the radioactive water at a rate comensurate with the availability of licensed casks, thus eliminating unnecessary on-site storage and associated radioactive releases.
3.
Occucational Radiation Excesure Levels and Other Ascects of Worker Safety l
The assessment's occupational dose estimate of 1 to 5 man-rems as a result of using Epicor-II cannot be verified using the data presented in the assessment.
Workers will have to change Epicor-II's prefilter/demineralizer and two cemineralizers (one cation bed and one mixed bed demineralizer) in radiation r=.
fields of 100 milliem/hr, 40 milliem/hr, and 20 rem /hr, respectively (_section 4.0).
7 Each change is estimated to take 30 seconds. Ambiguities in the assessment leave unclear how many changes personnel will have to perform.
Section 4.0 states "We estimate that there will be approximately 50 changes of prefilter/
cemineralizers and demineralizers." Left unanswered is whether there will be 50 changes of each of 3 units or a total of 50 changes for all 3 units.
In tne case of the former, the resultant occupational exposure would be 8.39 man-rems, eell above the 1-5 man-recs estimate for Epicor-II use.
In the latter case it is impossible to calculate the exposure level since the number of changes of
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each type'of filter is not specified in the assessment. Since the exposure incurred during the change of each type of filter will vary considerably, the total exposure cannot be calculated with the limited information given.
These g
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ambiguities prevent verification of the estimated worker exposure levels cited a
in the report.
Several scenarios of possible accidents that could occur while Epicor-II
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is in use are described in sections 3.4 and 5.2.1.
They include pipeline rupture causing radioactive water to leak into the building housing Epicor-II m
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and dropping radioactive resin casks while moving them around the plant site.
For each scenario exposure levels are estimated only for people outside the plant.
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No estimates of exposure levels are provided for on-site workers.
Estimates of
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the time needed to clean up spilled radioactive material, contingency plans for cleanups and evacuation plans for workers in the immediate area are lacking.
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Weaknesses and Flaws in the Evaluation of Alternatives to the procosed Use of Eoicor-II While section 6.0 considers transporting the radioactive water in the auxiliary building to another site as an alternative to using Epicar-II, W
burial of the liquid is the only final disposal scheme which is discussed.
This possibility is rejected because there are no burial grounds that accept liquid radicactive waste. Transporting the radioactive liquid to an existing Epicor system for decontamination is not considered.
R. Vollmer, head, NRC Suoport Group at TMI, has publicly stated other Epicor systems do exist.
The acvantages of this alternative include reducing the cumulative public and acrker exposure levels as a result of the total clean up of TMI, transporting
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less concentrated radioactive material, and possibly performing the demineralization in a less densely populated area.
If existing Epicor systems are unable or
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ur.willing to treat TMI's waste, an Epicor system should be constructed in a emote, sparsely populated area rather than at a plant undergoing concomitant decontaminaticn and radioactive releases.
Contrary to section 2.0 which states that "use of Epicor-II (at TMI) does
,ct preclude implementation of the various disposal alternatives," its use 4culd preclude demineralization at an Epicor site remote from TMI.
r The assessment deals with three alternatives for processing radioactive aater on-site (section 6.0): using existing radwaste systems at the plant, Epicor-II,and removal by evaporation and condensation.
The assessment only crovides estimates of resulting exposure levels to the public and plant workers for the use of Epicer-II.
The first and third alternatives are dismissed for reasons of expediency without considering if these alternatives would result in L
icwer exposure levels.
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5.
procedural Shortcominos of the Assessment
[m Section 2.0 of the assessment states "the NRC staff has provided desian
- uidance and criteria for the Epicor-II processing system, the building housing
- .,e system, the building's exhaust filtration system and the process vessel vent
- ystem". This participation by NRC staff in the design stage of the system Exceeds and compromises the regulatory authority of the NRC since the same staff
.,as called upon later to prepare an environmental assessment.
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Based on the above information and our experience as geologists familiar
!b with enviror. mental assessments, we believe that the f4RC's Environmental Assessment does not provide an adequate evaluation of the proposed action.
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Done in a prefunctory manner, the assessment lacks sufficient scope and detail
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to provide assurances that the public and worker well-being would not be endangered. A broad, detailed study of the entire cleanup of TMI should be
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initiated im ediately. To insure rigorous, independent and scientifically i:
tound results, the new study should be done as an Environmental Impact Statement
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cy an agency of group independent of the 14RC.
is kf&,
g Dr. Arthur H. Barabas Steven Sylvester, M.Sc.
Assistant Professor of Geology Specialist in Geology Coordinator of Environmental Studies Program Se::: ember 14, 1979
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