ML19309E015
| ML19309E015 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/25/1980 |
| From: | Fredrickson C AFFILIATION NOT ASSIGNED |
| To: | NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE |
| References | |
| NUDOCS 8004150407 | |
| Download: ML19309E015 (4) | |
Text
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a TMI Support Staff 3/2E/80 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Draft Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor Building Atmosphere, March 1980
Dear Sirs:
I have personally reviewed your Environmental Assessment for Decontamina-tion of the TMI Unit 2 Reactor Building Atmosphere and offer the following comments as constructive criticism of your report. Although I agree with your conclusion, that being that purging the reactor building is the most intelligent option available in consideration of the need to maintain the instrumentation and equipment inside, I do have some general criticisms which are identified below, as well as some specific coments, attached.
The EA lacks the perspective required by the public to understand the significance of the proposed action. A comparison of the dose consequences of each alternative, including the "no action" alternative which you have not specifically addressed, should be made to natural background exposures for each critical organ (skin and total body).
It might be helpful to compare Kr-85 exposure to the maximum individual to exposures which result from radon gas exposures in homes made of brick or stone in that both Kr-85 and Rn-220 are radioactive gases.
The most important issue, indeed, the subject of the EA, is removal of the Kr-85 from the reactor building to allow maintenance of instrumentation and equipment inside. All other reasons such as decommissioning, recovery of the unit, removal of damaged fuel etc. are secondary at this point in time.
It is the public health and safety risks associated with not maintaining / refurbishing the safety-related instrumentation and equipment inside the building which should be of primary concern. This is not consistently clear in the current EA.
The presentation of two different reactor building Kr-85 concentrations (1.0 pC1/cc and 0.78 pCi/cc) is confusing as is simply defining the quantity contained as curies of Kr-85. This says nothing about the relative hazard of krypton gas, and because it is a big number (57,000 C1) is somewhat intimidating. A thorough explanation of what Kr-85 is, how it reacts or doesn't react with human body, what limits apply to operating reactors, etc. would be helpful to the public.
O Ysp 7 (
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8 004150 h,,[)7 1
In summary, I find your Environmental Assessment, although technically sound, to be of little value to a lay person who must derive some understanding of the hazards involved.
It is with this concern that these criticisms are offered. Also attached are specific comments to the report.
If you should have any questions on these comments, please do not hesitate to contact me.
Sincerely, kthj-
/G' Craig Fredrickson 2742 Veranda Rd. N.W.
Albuquerque, NM 87107 (505) 344-1048 I
l
Specific Comments 1.
Section 1.0, page 1-3 (line 5) - The dose consequences of planned releases are not suspect. They can be well defined within limits according to the rate of purging and coinciding meteorlogical conditions.
2.
Section 1.0, page 1-3 (line 13) - Although the releases associated with accidents during a lls to 4 year waiting period may be smaller than the controlled release of Kr-85 contemplated, the actual dose consequences of an accidental release at some time in the future could be greater if unfavorable meteorlogical conditions exist.
This should be stated.
3.
Section 1.0, page 1-4 (lines 1 & 3) - Same as Coment 1.
4.
Table 1.1, page 1 The comparison of dose consequences should include a comparison to the range of natural background exposures for each critical organ. Also, the occupational exposures should be defined as whole body exposures.
5.
Table 1.2, page 1 An advantage to reactor building purge is low occupational exposure. Since this segment of the population (radiation workers) is the highest exposed, minimizing their exposure is desirable and consistent with ALARA considerations. Similarly, a disadvantage of the cryogenic processing system is high occupational exp;sure.
6.
Srction 4.1, page 4-1 (line 12) - Purging of the reactor containment does not per se represent a way to dispose of the Kr-85 gas. This alternative would be better termed " controlled dispersal" rather than disposal.
7.
Section 6.1.2, page 6-2 (line 13) - Administrative limits for the controlled release of Kr-85 should be defined.
8.
Section 6.1.4, page 6-4 (line 9) - This section states that a particulate removal efficiency of 90% is assumed for the two-stage HEPA filter system.
Although the HEPA filters would not remove Kr-85, the credited particulate removal efficiency is unrealistically low. A two-stage HEPA system would be expected to provide a reduction in the source tenn, due to 6
particulates, by a factor of 10,
9.
Section 6.1.4, page 6-4 (line 20) - The X/Q values assumed should be accompanied by their corresponding stability class.
It is likely that dose consequences could be reduced by more than the factor of 2 or 3 stated by venting only when dispersion conditions exceed certain limits.
- 10. Section 6.1.5, page 6-6 (line 13) - The calculated dose consequences of the worst-case accident are not defined in terms of the dose receiver; i.e., is it the maximum individual offsite, average individual offsite, maximally exposed worker? Also, it is not clear that the accident limits of 10 CFR 100 are appropriate in that they apply to major accidents at operating nuclear power plants and are used primarily for siting.
It might be more correct to compare the dose consequences to 10 CFR 20 limits or perhaps both parts 20 and 100.
0 O.+
- 11. Section 6.1.5, page 6-7 (line 1) - Guaranteeing continued reactor building isolation is not possible for any of the alternatives including purging.
It would be true, however, to state that the likelihood of an accidental release is increased with the delay associated with implementing the alternatives to purging. Also, in the last paragraph of this page " interpretation" should be
" misinterpretation."
- 12. Section 7.3, page 7 The Connonwealth of Pennsylvania radiological monitoring capability consists of fixed filter cams which would be of little use in monitoring for Kr-85. Therefore, credit should not be taken for this monitoring capability as part of the program.
- 13. Section 7.6, page 7 The discussion of the DOE radiological monitoring program includes objectives which are not relevant to the task of monitoring the purge operation and which do not belong ir, this Environmental Assessment.
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