ML19318D068
| ML19318D068 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/30/1980 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TLL-315, NUDOCS 8007070287 | |
| Download: ML19318D068 (4) | |
Text
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L7e Metropolitan Edison Company Post Office Box 480 Middletowrt, Pennsylvania 17C57 717 2ncocci 948-8000 Writer's Direct Dial Number Mr. Harold Denton; Director June 30, 1980 Office of Nuclear Reactor Regulation TLL 315 U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
Three Mile Island Nuclear Station, Unit II (TMI-2)
Operating ense No. DPR-73 Dockt No. 50-320 Submerged Demineralizer System This is in response to your letter of May 28 to Mr. Dieckamp and myself.
Our review of your letter and the basic issue of the contaminated water which exists in the Unit II containment building leads us to the conclusion -hat it would be helpful to clarify the Company's porition on several of the items addressed in that letter.
Submerged Demineralizer System The SDS was selected by the Company after revi w of several almernatives and e
af ter obtaining technical assistance and input from a number of sources. The obj ect-ives for the system included that it provide a reliable, well-developed method for accomplishing a major reduction in the mobility of the fission products dispersed within the plant by capturing at least 99.999% of the radioactive material in the containment building vater, that it meet all ty4ating codes and standards, and that it not preclude further processing of the water. During the system design development, your staff was apprised routinely of our efforts.
A Technical Advisory Group (TAG), made available by the Department of Energy, functioned no a technical oversight group dur.ng the design development. Oak Ridge National laboratory conducted laboratory tests and evaluations to verify the effi-cacy of tf4 system design. Recently, the TAG, after careful review of the design development work and the ORNL test results, recommended that:
"GPU proceed with deliberate speed to complete the SDS hardware and put the system into operation-The objective of raconcentrating the dispersed fission products into a secure and more mtnageable form as soon as possible is i. ;rtant to add confidence in protecting the public's health and safety.
The improvement in public protection that can be obtained is important enough to proceed even though further optimization and later criter a may reouire some reprocessing or adjustments.
P yv btary,s a Ve ce cf t e Geren Ett:
8007070 Meuccoon dmson O Utd tu System
SMr. HOrold Denton June 30, 1980 Reconcentration of the fission products will improve access to plant equipment for maintenance thus enhancing the reliability of remaining operational functions and minimizing in-plant personnel exposure."
We strongly support the TAG's recommendation.
We believe treatment of the highly contaminated water in the containment building represents a very high priority activity and the next objective to reduce both actual and percei'ad threat to public health and safety. Hence, it is our judgeent that providing timely capability to process the water is in the best interest of the public health and safety.
Even for the longer term, the water is of safety concern because it is an adverse environment for plant equip-ment and it impedes building access and activities necessary for removal of the core. For these reasons, we have since the accident placed great emphasis on getting into place a capability to expeditiously immobilize the fission products dissolved in that water.
As a result of our best efforts, an adequate system for treating the highly contaminated water will not be available until about eighteen months after the accident. While we recognize this effort has been undertaken at our own risk in that NRC has not completed its rev!ew of the system, we believe that the contain-ment building water posed the potential for developing into an emergency situation.
We are of the opinion that our responsibility for protection of public health and eafety demanded that we procaed.
In short, the proposed anu required action is not only treatment of the con-tainment building water, but treataent at the earliest possible opportunity.
Time, we believe, is an essential ingredient and your NEPA review should reflect that fact.
Based upon our work to date, we still believe the SDS represents an excellent approach to treatment of the highly contaminated water and use of the SDS should not be delayed to conduct research for better alternatives. Use of the SDS does not preclude subsequent additional treatment, if experience with the performance of the SDS indicates that additional treatment is necessary.
We would reemphasize that the primary rationale for proceeding with SDS has been to provide an opportunity as quickly as possible for addressing by an accept-able method a public health and safety issue of potentially major proportions.
Your May 28 letter does not reflect the importance we attach to the prompt clean-up of contaminated water in the contsinment structure.
It can, in fact, bs-read as requiring both completion of the entire PEIS and extensive considera-tiin of all alternative treatment systems, regardless of their availability er state of development, before a decision is reached on operation of the SDS. This would not, in our view, be consistent with the Commission's policy statement of November 21, 1979, which recognized that the public interest in decontamination of the containment water might require early action in advance of the completion of the PEIS.
In fact, deliberate delay would foreclose the action we propose--
namely, acceptable treatment of the containment water as quickly as possible.
Accordingly, we request that NRC take the steps necessary to permit approval of the operation of the SDS consistent with the availability of the system for operation.
[b!tc.'EtroidDenton Ju'na 30, 1980 Solid Waste Disposal writeria which have been applied to all activities associated with the cleanap effort have included packaging of radioactive waste so that it can be transported to, and accepted by, waste disposal sites in compliance with existing regulations.
We recognize the concerns which exits as to the form, content and ultimate dis-posal of the material collected by the proposed operation of the 3DS.
5.'e are also ersre of the various proposals to modify the existing regulations. Because of the.e circumstances, we have made provision, in the design of the SDS and the availability of interim on-site storage for contaminated resins, to permit pro-ceeding with the immobilization of the fission products without foreclosing future options for treatment to improve their suitability for long-term off-site storage or disposal. These features of our planning are key elements in our rationale for proceeding with the design, procurement and installation of the SDS.
Your letter indicates "further guidance" will be available concerning solid waste disposal as work is pursued on the PEIS. We urge that resolution of these issues be given very high priority through an interagency task force with repre-sentation from all the concerned federal agencies.
Contingency Plan for Transfer of Untreated Water Your letter states that we are " developing a conticgency plan for transfer of the water frcm the coatainment building to suitably shielded on-site tanks."
In our submittal of the SDS Technical Evaluation Report dated April 10, 1980, we discussed on Pages 1-3 the implications of installing shielded storage tanks. We concluded that it is not feasible to provide long-term on-site storage for the highly contaminated water. Of particular note is that installation time for such tanks would exceed two years. Pursuing such an effort would require the defini-i tion of criteria to be applied to design of such a facility and thus may also be dependent upon completion of the PEIS.
I was requested by Mr. John Collins to review the options available for removal of the water from the containment building in the event that became absolutely necessary. Such a review is in progress. In general, storage volume is available in Unit 2 tanks and spent fuel pools equivalent to the estimated i
600,000 gallons presently flooding the lower level of the containment building.
However, transfer of the water to such rterage poses significant radiological problems and can only be justified on the casis of relieving an immediate emer-gency situation such as leakage from3the building.
Our review is directed at calculating the radiation levels that would exist within the plant, if that water were placed in the various tanks or pools. The results of this review would be used to minimize the adverse impact of imp'.ement-ing such a contingency plan. We must emphasize that even at this stage aid with-out the detailed results of a completed review, expe ditious cleanup of the water to minielze reliance on such a contingency plan is very clearly preferable.
We believe that the TMI cleanup requires substantially greater coordination of federal, state and Company activities.
Mr. Dieckamp's letter of March 4, 198 to Chairman Ahearne, included a recommendation fer formation of a senior oversig and coordination group with representatives from the responsible organizations.
u urge you to consider this recommendation and whether or not you could support his proposal or an alternate one.
,hhk.'HaroldDenton Juna 30, 1980 We accept that we have the lead responsibility for initiating actions which accomplish the cleanup as expeditiously as possible and recognize the responsi-bilitins residing with other organizations for regulating and monitoring those activities. Fulfilling our responsibilities requires that we have defined criteria.
The csntinued absence of clearly delineated criteria is extending the cleanup which, in our judgment, is inimical to overall safety and is introducing an inefficiency in the expenditure of our resources that we can ill afford. Neverthe-le',s, we will continue to work to ensure our activities are cutually supportive or achieving our common goals.
Sincerely,
(_
R. C.
rnold Senior Vice President RCAralb cc:
H. Dieckamp B. Snyder, NRC J. T. Collins, NRC
.