ML19308C373
| ML19308C373 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/02/1980 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Simpson A SENATE, ENVIRONMENT & PUBLIC WORKS |
| Shared Package | |
| ML19308C372 | List: |
| References | |
| NUDOCS 8001230292 | |
| Download: ML19308C373 (9) | |
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q The Honorable Alan K. Simpson Suocosmittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, D.C. 20510
Dear Senator Simpson:
i I am writing in response to your letters of November 25,1979, to Mr. Harold R. Denton and Mr. Richard H. Vollmer in which you submitted j
a number of questions relevant to recovery operations at Three Mile The specific response to each question is listed in the Island.
enclosure in the order in which they were posed.
I hope these answers provioe you with the information you require.
If you should require additional information or clarification of the information presented, please do not hesitate to contact me.
Sincerely, p,,.r Lee V. Gossick Executive Director for Operations
Enclosure:
Response to Questions Distribution Copies:
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RESPONSES TO QUESTIONS IN NOVEMBER 25, 1979 LETTER FROM SENATOR GARY HART AND SENATOR ALAN K. SIMPSON 0
5 yisia s.
1 l
1 QUESTION 1:
Are you completely satisfied with the promptness of GPU in responding to NRC requests?
l ANSWER:
We are satisfied with the promptness of GPU anc Met-Ed in resp.onding to
' NRC requests on issues dealing with potential short-term public health and safety issues.
For these issues, we have generally been specific about the required time and scope of the response and our requirements have been met.
Further, since an NRC site off. ice is available to meet with the licensee on short notice, important short-term issues are handled on an expedited basis with follow-up documentation.
Response to some long-term issues, such as cleanup and decontamination, has not been as timely, however. Although the staff has requested, through the NRC site office, information about such things as the proposed disposition of water processed through EPICOR-II and the proposed method nd system for decontamination of the reactor building water, it has not been f orthcomi ng.
However, we recognize that these issues do not pose problems of an immediate nature, and we have not required specific response dates.
We further recognize that the licensee resources are heavily committed at this time.
QUESTION 2: There are 50,000 curies of krypton-85 gas in the reactor building.
What do you propose to do with the gas?
ANSWER:
On November 25, 1979, the licensee submitted its proposal for the disposal of the 44,000 curies of Krypton-85 in the reactor building in a report titled, "Three Mile Island Reactor Building Purge Program Safety Analysis and Environ-mental Report." The licensee examined four options for removal and disposal of the contaminated gases:
(1) venting, (2) charcoal adsorption and storage,
. (3) gas rompression and storage, and (4) cryogenic processing and storage.
Since Krypton-85 has a long half-life (10.5 years), disposition by racio a'ctive decay is not a viable option. As a result of'this examination, the licensee proposed venting of the reactor building gases to the atmos-phere as the preferred method and concluded that the venting operation could be done with no significant hazards to any individuals on or off-site, or to the general population.
The NRC is currently in the process of performing an independent 'tvaluation of the various methods of disposing of the Krypton-85 in the Unit 2 reactor building.
In addition to the S
four options examinea by the licensee, we are examining solvent extraction as a method of removing the Krypton-85. Upon completion of this evaluation, the NRC staff will make its recommendation in an Environmental Assessment which will be released for public comment. This assessment and the public comments and staff responses thereto will form a basis for a Commission decision on the disposition of the radioactive gas in the reactor building.
QUESTION 3:
Normally the regulations for an operating reactor allow release of certain quantities of radiation to the river and the atmos-phere.
Do you plan to adhere to these regulations for the l
cleanup?
If not, what alternative do you propose and why?
ANSWER:
The technical specifications for releases of radioactive materials from operating reactors are based on guidelines Appendix 1 to 10 CFR Part 50.
Appendix I to 10 CFR Part 50 provices numerical guides for design objective and limit ing conditions for operation to meet the criterion of "As Low as is Reasonably Achieveable" and which also meets the standard set in EPA's regulation 40 CFR 190 concerning radiation dose to the public from the uranium fuel cycle.
We will require that during cleanup and recovery operations the releases of radioactive material to the environment are maintained within the limits specified in Appendix I to 10 CFR Part 50.
However, the Commission may determine that if the public interest requires, additional measures be taken for the protection of the public health and safety such as a requirement for one of the cleanup options mentioned above. The efficacy of such additional measures will be an integral part of the Environmental Assessment.
QUESTION 4:
NRC regulations provide that radiation workers can receive up to 3 rem per calendar quarter.
Will stricter dose limits be applied to the cleanup?
ANSWER:
The 3 rem per calendar quarter exposure limit applies to an individual whose exposure is recorded annually, and who has an annual average exposure of 5 rem or less over his working lifetime since age 18. Individuals not covered by annual exposure record keeping must meet 10 CFR Part 20, Section 101a, which limits the maxinum quarterly exposure to 1.25 rem.
The 1.25 and 3-rem values are maximum values. We intend to apply the "As Low as Reasonably Achievable" (ALARA) provision set forth in Regulatory Guide 3.8 during cleanup at TMI. However, it is important to note that ALARA means minimizing the dose to all personnel involved in the activity.
In some cases, for example, where special expertise is necessary to do a job, the total dose may be minimized by allowing a highly skilled person
s
. to receive the 1.25 rem to complete a job rather than by allowing a number of less skilled persons, each of whom would receive a dose less than 1.25 rem, to do the job when the sum of their doses exc'eeds 1.25 rem.
QUESTION 5:
If so, why and what will the limits be? How will they affect the estimated 1.4 million man-hours required for the cleanup?
ANSWER:
As noted in response to Question 4, dose limits for radiation workers will be required to conform to 10 CFR Part 20 and the radiation protection program will be required to meet the ALARA guidelines set forth in Regulatory Guide 8.8.
The manpower estimates for cleanup of TMI-2 are cased on the current estimate of the radiation conditions and extent of damage ins.de the reactor building.
In addition, these estimates are based on the assumption that most of the radioactive gases and liquias in the building will be removea prior to entry for work and that all exposures to on-site personnel would be in accordance with ALARA considerations as outlined in the response to Question 4.
However, subsequent to reactor building entry, the deter-mination of the actual level of radiation, the chemical condition of the i
radioactive materials, the distribution of the radiation, and the condition l
of the core could have a significant effect on total manpower requirements to complete cleanup operations.
l QUESTION 6:
Are there enough radiation workers to accommodate the increased number of man-hours or will the cleanup have to be longer than presently estimated? What is the public health and safety impact of this decision?
o
. ANSWER:
We do not anticipate that the licensee will have any difficulty in obtaining the manpower with the proper skills to accomplish the decontamination and cleanup effort as it is currently expected to proceed.
As outlined above, conditions witnin the reactor building and the reactor could have a signif-icant effect on the man-hours necessary. However, because of access and space limitations within the reactor building and the nature of the cleanup work, there are a limited number of people that can effectively be utilized at any one time on any one task. Therefore, we expect that the decontamination an cleanup effort would primarily be accomplished by expanding the schedule, rather than by increasing the manpower.
As noted in our response to Question 3, all activities on site will be required to be carried out in such a manner that off-site doses will be within the guidelines of Appendix I to 10 CFR 50, irrespective of how long the effort takes.
Therefore, there should be very little impact on the public health and safety or the environment.
QUESTION 7:
Is there any urgency to any segment of cleanup activities at TMI, particularly:
(a) the krypton gas in containment (b) the radioactive water (c) the nuclear core (d) waste shipment i
ANSWER:
(a) There is a degree of urgency in making a decision on disposing of Kr-85 in the reactor building.
The longer a decision is delayed I
. the greater the potential there is for a ground-level uncontrolled release from the reactor building due to equipment failure or personnel error.
(b) Water in the auxiliary building is currently being cleaned up.
There is continuing in-leakage into the reactor building however; in order to protect essential equipment in the containment building, a deci-sion a decision to remove and cleanup this water cannot be delayed indefinitely.
In addition, the potential exists for leaks to develop through containment penetrations that could cause uncon-trolled releases.
Therefore, a degree of urgency also exists for this phase of the cleanup operation.
(c) As long as adequate cooling can be provided for the core, there is no urgency in removing the fuel.
The core is currently being cooled by natural circulation.
In addition, the licensee is providing a new, low-flow decay-heat removal system for near term use and for the time when the primary system must be depressurized to remove the vessel head and subsequently the core.
(d) The NRC on-site staff is following all phases of solid waste genera-tion, packaging, and on-site temporary storage to insure that the licensee is meeting all NRC, DOT, and burial-ground criteria.
The unexpected closing of comercial burial grounds woulo have an impact on the transport of wastes off the site.
However, the solid waste on site is stored in a form that prevents any adverse impact on the public.
. QUESTION 8:
If, instead of two years, it took five years or more, what would be the possible impact upon public health and safety?
ljWER:
All short, half-life radioactive materials have already decayed away to insignificant levels. Therefore, no significant recuctions in activity due to radioactive decay will occur.
Unnecessary celays in the cleanup would have no benefits whatsoever, in fact, the opposite would be the Delays would increase the potential for uncontrolled radioactive case.
releases due to equipment failures, leaks, and personnel error, thus leading to a situation that could have a greater impact on the public health and safety.
QUESTION 9:
Mr. Denton, what was the basis for the conclusion ' hat amend-ment of tne Unit 2 Tech Specs " involves an action which is insignificant from the standpoint of environmental impact" as stated in the draf t Safety Evaluation by the Offices of Nuclear Reactor Regulation supporting proposed Tech Specs amendments for Unit 2?
ANSWER:
The basis for this statement is that our evaluation shows that actions taken under the revised Tech Specs will provide for a safer operation and releases to the environment which are less than those previously eva,luated in the FES for this f acility.
I 1
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