ML19309B588
| ML19309B588 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1980 |
| From: | Wagner H MARYLAND, STATE OF |
| To: | Vollmer R NRC - NRC THREE MILE ISLAND TASK FORCE |
| References | |
| RTR-NUREG-0662, RTR-NUREG-662 NUDOCS 8004040375 | |
| Download: ML19309B588 (7) | |
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JAMES 8 COULTER LOus$ N PmPPS A setetrase et.ute Sacetta**
STATE OF MARYLAND DEPARTMENT OF NATURAL RESOURCES ENERGY ADMINISTRATION
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TAWES STATE OFFICE BUILD:NG ANNAPOUS 21401
, 1301) 269-2251 March 31, 1980
!!r. Richard H. Vollmer Director of Three Mile Island Support Office of Muclear Reactor Regulation U.S. Nuclear' Regulatory Commission Washington, D.C.
20555 RE: Draf t Environmental Assessment for Decontamination of the Three !!ile Island Unit 2 Reactor Building Atmosphere (NUREG-0662)
Dear !!r. Vollmer:
These comments and recommendations are submitted on behalf M the State of Maryland.
They represent a consensus of Maryland's Department of Health and F! ental Hygiene and its Department of Natural Resources.
The !!aryland Covernor's Committee on Three tiile Island concurs in these recommenda tions and has submitted to the Covernor its own report, wt ich is appended.
Having reviewed and checked the quantity of Kr-85 potentially available for release, the likely dispersion during transit to the f!aryland border, and the resultant dose to Maryland citizens, we conclude that the radiological impact in !!aryland would be negligible from venting the containment building over a period of approximately 60 days as described.
Our predictions of doses to the most exposed
!!aryland citizens are less than 0.1 nrem to the skin and 0.001 mrem to the whole body.
Our own radiation monitoring data shows that variations in dose due to natural radioactivity frequently exceeds one millirem from time to time and place to place within Maryland over a similar 60 day period.
Consequently, Maryland has no reason to oppose the venting option.
O Pq N e
8004040375
Page Two Mr. Vollmer March 31, 1980 i
1 Of course, in determining the proper choice for handling the containment gases, it is necessary to consider the impacts on Pennsylvania's citizens, particularly those residing in close proxinity to Three Mile Island.
We note that projected radiation doses for all options presented are within the limits imposed by the plant's Operating License and the values established in 10CFR50, Appendix I for keeping radiation doses from operating reactors to the public as low as reasonably achievable.*
On that basis, we believe all the options presented should be considered to have acceptable levels of radiological impact.
However, as in the case of an operating reactor, every reasonabic opportunity should be taken to minimize the discharge of radioactivity to the environment during the cleanup of Three Mile Island.
It is in this context that the alternatives for handling the containment gases should be evaluated.
Although Maryland supports the concept of a programmatic Environmental Impact Statement to address the overall decontamination operation, we believe it is proper to make a decision regarding the containment building atmosphere at this time.
It appears that a decision based upon the programmatic EIS could not be forthcoming for at least another year.
At that time, the additional two or more year wait to implement any one of the options utilizing krypton capture devices would weigh even more heavily in favor of the purge option than it does now.
A decision to purge the containment building at this time would not preclude, but rather facilitate other options for the remainder of the decontamination process.
On the other hand, if the decision is to utilize one of the krypton capture devices, making that decision now would preclude fewer options than would making the identical decision one year from now.
Therefore, because there is no benefit but there is substantial loss in delaying the decision, Maryland supports the separation of this decision from the programmatic EIS schedule.
- Ne believe the goals established for a single unit in 10CFR50, Appendix I are the appropriate values to be considered (ie., maximum off-site dose rates from gaseous effluents should not exceed 10 mrad /
year from gamma radiation and 20 mrad / year from beta radiation, and doses to the maximally exposed individual should not exceed 5 nrem/ year to the whole body nor 15 nrem/ year to the skin).
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I Page Three Mr. Vollmer March 31, 1980 Maryland continues to be extremely concerned over the presence of approximately one million curies of bicaccumulatable radionuclides in aqueous solution within the power plant.
Should error or malfunction cause discharge of even a very modest fraction of this material, public water supplies and fishery resources in Maryland are in peril of serious contamination.
Even chronic leakage at a level suf ficient to produce a detectable increment of radioactivity in Maryland seafood would jecpardize the marketability of our harvest and the live 11 hoed of our watermen, due to public aversion in the marketplace.
We believe that it is in Maryland's best interest to decontaminate the plant's water inventory as expeditiously as is consistent with, careful planning, review and control.
Due to the long lead times involved in implementing any of the alternatives to containment purge, it would be at least three, perhaps five years af ter the accident before there would be reasonably free access to the building.
We do not feel it is prudent to wait this long to replace and repair instrumentation nor to maintain vital equipment in the containment building, and Maryland is opposed to any decision which would effectively prohibit containment entry for such protracted periods.
Consequently, the evaluations of the various options should be rewritten to include the unavoidable releases and occupational doses inherent in performing the necessary containment entries over the respective periods prior to completion of the krypton removal.
Although it has suf ficiently demonstra ted that containment purge can be accomplished within established dose limitations, the Environmental Assessment is deficient in that it has neglected to properly evaluate the dose reduction which can be accomplished by limiting krypton releases to periods of rapid dispersion, as indicated by real-time meteorological data.
We believe this option is a practical o population.pportunity for reducing radiological dose to the local The Environmental Assessment should specifically delineate the actual scheme for this control, and, based on an historical set of sequential meteorological data, estimate the dose reduction probably achieved and additional time probably required should purging be conducted with these limitations.
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Page Four Mr. Vollmer March 31, 1980 Other deficiencies noted in the Environmental Assessment relate to the monitoring activities described in Section 7.
Only those air grab samples to be collected by Metropolitan Edison at the estimated plume touch down point seem intended for feedback capability to the Unit 2 control rocm.
It is not clear from the description if adequate real time dose rate or beta-emitting gas detectors will be used by the sampling crews to ensure that they are actually at the point of maximum ground level concentration when each sample is taken.
Reliance solely upon atmospheric transport modeling seems inadvisable for assurance that such samples are taken at the point of maximum impact, even at relatively modest distances.
In addition to the radiological impact of each alternative, there is a non-trivial psychological impact to be considered.
We note that the local public sentiment mentioned in the Environmental Assessment expresses the unattainable goal of no further planned or accidental release of radioactive materials.
Clearly, this cannot be used as an acceptance criterion, since both planned and unplanned releases will occur for any of the options considered.
We note that even a process which is 99.9999% effective in capture of the krypton would result in a release somewhat greater than the 47 mci of Kr-85 which caused much public consternation when the airlock was recently entered.
It is not clearly stated in the Environmental Assessment how much Kr-85 would remain in the containment building after the operation of each of the alternative krypton capture devices.
Apparently, each would be operated t reduce the containment 5
building atmosphere to the MPC level of 1 x 10 pCi/cc.
At this point, 0.6 Ci of Kr-85 would still remain in the containment building.
The Environmental Assessment should clearly state whether this would be intentionally purged or eventually leaked during repeated building entry.
All descriptions of krypton capture devices execpt that of the Cryogenic Processing System give the impression that krypton release would be zero.
In weighing the psychological impacts inherent in each of the options, ue make the observation that public reaction has not been directly proportional to the number of curies in a release, and it should not be presumed to be so in choosing among the options in this case.
A sense that every practical opportunity will be taken to reduce public radiation exposure would certainly aid in achieving public acceptance of any proposal.
In that regard, the Environmental Assessment is particularly unsatisfying due to its cursory treatnent of meteorological restrictions which could be imposed in the venting l
process, as mentioned above.
Other factors which we believe would i
Page Five Mr. Vollmer March 31, 1980 be useful in reducing public stress are provision of more certainty as to the scheduling of any releases and the maximum dose associated I
with the releases.
Real-time of f-site dose rate monitoring provides I
direct confirmation and an opportunity to catch errors in prediction.
The publicly accessible monitoring programs to be conducted by the Department of Energy appear to be useful for ediancing and maintaining public confidence that suf ficient control is being maintained over the sixty day purge duration.
The Ccmmission should encure that these DOE programs are in readiness prior to commencement of the purge and that the resultant data is made available to and reviewed by Metropolitan Edison personnel as quickly as po;sible.
If properly analyzed for such factors as wind persistence and ranges of short term dose rates, the predictions mentioned earlier based on sequential hourly historical data could be very useful in interpreting the significance of individual neasurements from the DOE monitoring program.
In summation, Maryland agrees with the Ccomission's staf f recommendation that a decision be made at this time, and supports the choice of purging the containment building as the best available option.
However, we recommend that, prior to granting final approval of a plan to accomplish the purge, more detailed specification of the meteorological limitations and real-time environmental monitoring be required and be evaluated by the Commission to be sure that resultant public radiation exposure be kept as low as practicable.
Sincerely,
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Steven M. Long, Ph".D.
Director, Power Plant Siting Program SML:ps 1
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Ti1E JollNS 110PEIA3 MEDICAL 1A3TITUTl0A3 DIVISIONS OF NUCLEAR MEDICINE AND RADIATION HEALTil SCIENCES 913 NORTH WOLFE TREET BALTIMORE, MARYLIND 21:03 Telephone 301; 933 3330 March 28, 1980 The Honorable Harry R. Hughes Governor, State of Maryland Executive Department Annapolis, Maryland 21404 i
Dear Governor Hughes:
As members of the Maryland Governor's Committee on Three Mile Island, we have studied the Draft NRC Staff Report NUREG-0662 which assesses the problem of radioactive krypton gas in the reactor building, considers several options for removing it, and makes a recommendation.
In essence, the NRC officials propose to vent the gas out of a 160-foot stack over a 60-day period when the meteorological conditions are suitable.
We agree that the radioactive krypton within the containment vessel creates a major problem that should be solved as soon as possible. The radioactivity levels are so high that no one can safely enter the building to carry out the procedures necessary to keep the reactor in a safe shut-down condition and diminish the hazard of releases of radioactive water into the 60y.
There are fans operating inside the building that keep the temperature down in the face of heat still being generated by the reactor.
This cooling system has been in continuous operation for a year without the maintenance specified in their usual operation guidelines. The high humidity of the building is especially deleterious to the continued operation of the fans.
Their failure would permit the temperature within the building to rise, which in turn would cause the pressure in the building to rise above that of the outside atmosphere.
Should this happen, radioactive gas would leak out I
through seals and gaskets that have not been adequately tested because of high radioactivity levels.
In contrast to such uncontrolled releases, the proposed controlled release of the radioactive gas could ensure that expected levels are not exceeded.
We are reviewing the proposed monitoring procedures being carried out by the Department of Health and Mental Hygiene and the Department of Natural Resources of the State of Maryland.
The estimate of the whole bcdy exposure to persons at the site boundary over the 60-day period would be 0.2 mrem. The significance of this amount-of radiation should be vieled in the context of the exposure that all human beings receive from natural radioactivity, that is, frcm cosmic radiation,
The Honorable Harry R. Hughes March 28, 1930 page two J
from the earth, and frcm radioactive material that all human beings have always had within their bodies.
For example, the radioactive potassium within our body and other sources of internal radioactivity amounts to an exposure of about 25 mrem per year; cosmic radiaticn averages 45 mrem per year; and terres-trial radiation in this part of the country averages 25 mrems per year, the total of which is several hundred times as great as that which would result to persons naximally exposed to the released krypton. The exposure would be less than that resulting from variations in natural radioactivity in different parts of our State.
We believe that the pecposed release of radioactive krypton is the safest possible course of action if properly monitored.
We wish to assure you that we intend to verify the monitoring process and report any deviations above the predicted radiation levels immediately.
The citizens of the States of Maryland and Pennsylvania have a legitimate concern over the methods used in the clean-up of Three Mile Island.
We agree completely that the primary determinant of these methods should be the health and safety of all human, animal, and vegetable life.
It is in consideration 1
of all factors known to us at this time that we concur in the controlled i
release of the krypten gas now in the atmosphere inside of the containment
- building, j
Sincerely yours, Henry M. Wagner, Jr., M.D.
Chairman, Maryland Governor's Cocmittee on Three Mile Island dmm cc:
Mr. Charles R. Buck, Jr.
Secretary, Department of Health and Mental Hygiene Fifth Floor 201 West Preston Street Baltimore, Maryland 21201 T
Mr. James B. Coulter Secretary, Deparur,ent of Natural P.esources Tawes State Office Building 580 Taylor Avenue l
Annapolis, Maryland 21401 I
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