ML19322D670

Forwards Response to Submitting Questions Re Plant Operation.Reactor Bldg Radioactive Atmosphere Poses Significant Risk to Workers Only If Entered Prior to Kr-85 Cleanup

ML19322D670
Person / Time
Site:	Crane
Issue date:	01/22/1980
From:	Ahearne J NRC COMMISSION (OCM)
To:	Hart G SENATE, ENVIRONMENT & PUBLIC WORKS
References
NUDOCS 8002200258
Download: ML19322D670 (14)

Text

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'o, UNITED STATES yI' WASHINGTON, D. C. 20555 NUCLEAR REGULATORY COMMISSION g, _,

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L0mm January 22, 1980

CHAIRMAN The Honorable Gary Hart, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public -Works United States Senate Washington, D. C.

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Dear Mr. Chairman:

This is in response to your letter of November 15, 1979 with which you submitted a number of questions regarding Three Mile Island Unit 2.

The specific responses to each question listed in the order in which they were posed are enclosed.

Sin erely, I

(

hJohnF.Ahearne

Enclosures:

1.

Responses to Questions 2.

Statement of Policy and Notice of Intent to Prepare a Programmatic Environmental Impact Statement dated N;

,iber 21, 1979 3.

Met Ed's Cleanup Proposals 4.

NUREG-0584, " Assuring the Availability of Funds for Decommissioning Nuclear Facilities" cc: -Senator Alan Simpson b

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i Responses to Questions i

Question 1 Do the risks to the public and worker health and safety increase as cleanup activities are delayed, i.e., specifically:

We believe that delaying cleanup activities beyond that necessary for a careful review, modification if necessary, and approval, if appropriate, of the licensee proposals will increase the risks to the general public and the worker health and safety, as specifically discussed below, la.

What are the risks associated with the radioactive atmosphere presently contained by the reactor building?

The radioactivity that would be encountered by workers in the reactor building is from three primary sources:

the radioactivity contained in the atmosphere, primarily krypton-85; the radioactivity deposited on the walls, floors, and other surfaces, primarily cesium-137; and th'e radioactivity contained in the water in the reactor building basement, primarily cesium-137. The whole body dose rates, resulting primarily from cesium, vary from few rem per hour in the upper levels of the reactor building to over 200 rem per hour near the basement water level. The skin dose rates from the krypton-85 are seseral hundred rem per hour throughout the reactor building.

In contrast to the body-penetrating gamma rays characteristic of cesium-137, krypton-85 results essentially in skin dose because it emits beta particles which are stopped in the skin. At these levels of radiation, worker entry would be possible but not desirable.

Therefore, the radioactive atmosphere in the reactor building poses a significant risk to the workers only if entry were made prior to cleanup of the krypton.

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Risks to workers and the general public increase somewhat if cleanup is delayed, because materials deteriorate with time and thus the potential for leakage from the reactor building from such things as valve seats and seals will increase with time. This, combined with the potential for an operational error, could result in an uncontrolled release of the reactor building atmosphere.

In addition, it is not expected that the reactor building internal pressure can be maintained at a negative level, with respect to outside atmospheric pressure, indefinitely.

From the standpoint of radioactive decay, little would be gained by delaying cleanup of the containment atmosphere since the half-life of Kr-85 is 10.76 years.

Even taking into account these considerations, we expect that the consequences of significant leakage would be small.

As outlined in the response to part b on the dose of the surrounding population, if all the Kr-85 were released over a two-hour period, the f

dose to surrounding populations would still be small.

lb.

. hat would the health effects of a hypothetical ground release be?

W We understand that your question concerns an accidental release of Krypton-85 gas (a ground level release of.radioact,ive gases) from the reactor. building.. Normal controlled releases would be through the plant vent stack (elevated release).

The reactor building presently contains about 4.4 x 104 Ci of Kr-85.

Although it is unlikely that all of this material would be released, we have assumed a worst case scenario in which the Kr-85 was released over a 2-hour period. Although the exact dose e.etimates depend on site specific conditions (e.g., wind speed and direction), we have estimated 1

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a most likely dose based.on meteorological conditions previously measured at Three Mile Island. However, depending on the specific meteorological conditions at the time of such a release, if it occurred, the actual doses could be 100 times lower or 100 times higher than the most likely values given below.

Noting these uncertainties, we estimate the cumulative whole body person-rem exposure within 50 miles of the plant to be 0.2 person-rem.

The most likely maximum dose to an individual who remained at the site boundary would be about 0.2-millirem whole-body and about 19 millirem skin dose. The dose to the average individual within 50 miles of such a release would be 1 x 10-4 mill i-rem. While the risk to the maximally expcsed individual of premature death from cancer is less than one chance in 10,000,000, the risk to the average individual would be 1000 times less than this.

Even under the worst meteorological conditions, which might increase the maximum individual dose by a factor as high as 100 (i.e., approxi-mately 20 millirem whole-body), the risk to the individual exposed to the maximum dose would be small compared with the risk from continuing exposure to natural background radiation (about 125 millirem per year.)

A final consideration is whether the reduction in risk by allowing some of the radioactive krypton to decay is significant enough to outweigh the need to expeditiously proceed with decontamination activities.

Because the half-life of Krypton-85 is 10.76 years, it would take over 10 years for the level of radioactivity in the containment ' atmosphere to diminish by h.

After 2 years, the radioactivity would be reduced N

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by only 12%.

In onsidering the extremely low projected person-rem doses discussed above, we do not believe that the small net reduction in person-rems that would be saved by letting the krypton decay can justify this action in light of the risk of an uncontrolled release of radioactivity which increases as a function of time.

lc. What are _the risks associated with a delay in the processing of the contaminated water contained in the reactor building?

The current rate of increase in the water level within the reactor building is conservatively estimated to be about 1.5 inches per month.

Delay in processing the contaminated water in the reactor building would allow the water level to continue to it. crease, caused by reactor coolant system leakage, which is conserva.tively estimated to be about 0.5 gallons per minute.

Continued water level rise with no compensating action taken would create the.following potential risks:

(1) reactor building out-leakage of contaminated water to adjacent i

buildings (auxiliary, fuel handling and control buildings) or d

to the ground; (2) increased build-up of sedimentation in the reactor building sump, thereby hindering the future cleanup operations; and (3) the need for realignment of impartant systems that i.nterface with the Reactor Coolant System (RCS) so that they can be maintained in an operable condition for use at a' later date if required (an example is the Decay Heat Removal System).

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_. Items (1) and (2) above are long-term concerns and corrective action can be delayed much longer than for item (3). The contained water level inside the reactor building is currently significantly below grade level.

Due to the construction features of the reactor building (steel-lined against a four foot thick pre-stressed concrete wall), the probability of water seepage is low.

Leakage across instrument penetra-tions is not expected to occur because the reactor building has been designed to withstand an internal pressure of 60 psig. Also, recent limited visual examination through one of the penetrations has shown no structural damage inside the reactor building.

The shorter term concerns associated with a delay in removing the water from the reactor building (Item 3) would be the potential loss of the ability to operate some motor-operated valves in the containment build-ing.

This could result in having to isolate the RCS pressure boundary from the decay heat removal system (located outside the reactor building) with one valve instead of two. We estimate conservatively (assuming an RCS leakage rate of 0.5 gallon per minute) that it would be six months or longer before certain components might be rendered inoperable.

Isolating the reactor coolant pressure boundary with one valve may create a greater potential for intersystem leakage with contaminated water.

However, if this leakage were to occur, it would be confined inside the Auxiliary Building and should involve increased risk to the public. Worker access to the affected area would be limited.

Id. Can the water in the primary building leak out if too much time passes?

We believe that the probability for water to leak out of the reactor building would increase if "too much time passes" and no actions were taken to remove the contained water. The reason is because of possible but unforeseen occurrences, such as human error. At this time, we see no likely leakage paths; if such are found, we would require action to be taken to eliminate them.

le. When is the earliest that the building could leak?

We do not know when, at the earliest, the reactor building could leak.

However, we have approved the licensee's design of a ground seepage detection system which will be used to detect any reactor building out-leakage that might occur. The design consists of eight ground wells strategically located around the periphery of the reactor building.

The water pumped from these wells would be monitored for radioactivity.

This detection system is expected to be installed by the end of this year.

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Is there any urgency associated with the removal of the nuclear core?

The safe boron level has been cited at 3000 parts per million. Could stratification of the coolant lower the concentration in the core to below this level?

There is no immediate urgency associated with the need to remove the nuclear core. We require that the Reactor Coolant System (RCS) be maintained at a boron concentration ranging from 3,000 to 4,500 parts permillion(ppm). We expect no boron stratification in the RCS. The reasons are:

(1) there is adequate flow to promote mixing of the injected concentrated boron solution in the RCS and to have it diffused in possible stagnant regions of the core (boron concentration as i

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l low as 900 ppm can prevent return to criticality), and (2) the coolant is pressurized, thus there are no boiling regions that may cause a change in boron concentration. Also, for the boren to precipitate at a concentration of 4,500 parts per million, the RCS temperature would have to be less than 40*F.

It is unlikely that the RCS temperature would ever approach such a low value.

How long can each specific activity be safely delayed?

With regard to your comment on how long each specific activity can safely be delayed, we expect that a minor delay would have little impact on the health and safety of the public or on-site workers.

In addition, in case of an emergency, for example if the water in the containment got too high, emergency operations can be undertaken to correct the situation. However, because materials degrade with time, maintenance cannot be readily dor,e because of the contamination, and operational errors cannot be excluded, we expect that in a ~ time frame of a year or two, some small uncontrolled leakage might occur. The result-ing increased risk to workers or the public would be highly dependent on specific circumstances, but as discussed in the answer to Question lb, any increased risk to the public is expected to be small.

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. _ uestion 2 Q

Please describe more specifically than you were able-in our hearing, how a -

modified EIS procedure, license modifications or orders are expected to be utilized in future cleanup activities at TMI.

On November 21, 1979, the Commission issued a Statement of Policy and Notice of Intent to Prepare ~ a Programmatic Environmental Impact Statement regarding future cleanup activities at TMI-2. A copy of that document is enclosed.

This policy statement reflects the Commission's determination that an overall enviromnental study of the decontamination and disposal processes will not only assist the Commission in discharging its regulatory responsibilities to protect the public health and safety but also assure that the public is info'rmed and, indeed, involved in the Commission's decisionmaking process.

Such a statement will include an overall description of anticipated activities and a schedule for their completion, as well as a discussion of alternatives o

and the rationale for the choices made.

In making this determination, the Commission is, of course, mindful that such a programmatic statement may well have to be supplemented as additional information regarding the exact condi-tion of the core and other areas and equipment in the reactor building is obtained. _Nevertheless, it is believed that such a statement can serve as a useful planning tool. As -necessary, individual portions of the overall cleanup effort will be accompanied by the preparation of an environmental assessment followed, as appropriate, by a negative declaration or environ-mental impact statement. The Commission intends to coordinate with the President's Council on Environmental Quality (CEQ), including consultation, before determining the scope of the programmatic impact statement.

1

As discussed more fully in response to Question 5 below, the Commission has recognized that there may be a rveed to take action during the development of the programmatic environmental impact statement. Consistent with the exigen-cies of a particular situation, the Commission intends to consult with CEQ regarding its NEPA responsibilities. Actions taken will be accompanied by an environmental assessment followed by a negative declaration or preparation of a full impact statement as appropriate.

In the event that a presently unfore-seen emergency situation should arise, the Commission will, to the extent practicable, consult with CEQ as well.

A careful balance must be reached as to activities, or specific aspects thereof, which require the imposition of particular license limitations to protect public health and safety and the environment, and the need to permit operational flexibility in areas which would not affect the external environ-ment. Currently, an Order is being finalized which will impose a number of license conditions in the form of Techni:al Specifications and provide a single compilation of requirements to replace the hRC-approved procedures under which the facility has been maintained since the March 28, 1979 accident.

Specific prohibitions on the discharge of the intermediate radioactively contaminated water (currently being successfully processed by the EPICOR-II system) and high-level water in the reactor building, and on the purging or other treatment of the reactor building atmosphere, pending completion of l

appropriate environmental reviews, w.ll be included.

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. As necessary to assure the continued protection of the health and safety of the public and the environment, the Commission will require, by order.that the licensee conduct its activities in a prescribed manner. The Commission intends to fully utilize the authority conferred by the Atomic Energy Act to take this type of action as the public interest warrants.

Question 3 If an EIS is prepared for the cleanup of TMI, who will do it?

The NRC staff will prepare the programmatic environmental impact statement

.for the cleanup of Three Mile Island Unit 2 (TMI-2).

Assistance in preparation of the statement will be obtained from.one or more national laboratories, depending on the availability of the necessary expertise. This effort is currently underway.

Question 4 How long will that take?

We expect that the Programmatic Environmental Impa'ct Statement will at first be issued as a draft for public comment in May or June 1980. The final statement is. expected to be issued at the end of November 1980.

Question 5 What.about actions necessitated by conditions on-site during the process of preparing the Environmental Impact Statement? Will they require a separate EIS? An Environmental Assessment?

As discussed in our response to Question 2 above, the Commission, in its.

policy statement regarding preparation of a programmatic environmental impact statement, has recognized the possibility that there may be a need for prompt action during development of the programmatic statement. Action of this

kind will be preceded, to the extent practicable, by consideration of advice

'from CEQ on the flRC's flEPA responsibilities and will not be taken until it.

. has undergone an appropriate review. Such review would take the form of an environmental assessment followed, as appropriate, by the issuance of a negative declaration or a full environmental impact statement.

Question 6 What about venting of krypton gas from containment? Will an assessment of possible environmental im,mcts of alternate treatments of Kr-85 be prepared?

On riovember 13, 1979, the licensee proposed that atmospheric venting be the means for removing the contaminated gases, mainly Kr-85, from the containment.

~The licensee considered various alternatives and concluded that the venting j

operation can be done with no significant hazard to the site or to the general population (i.e., by purging the reactor building atmosphere through the station vent stack, and by employing a meteorological feedback system to implement release over a period of time under favorable meteorological conditions). Under these conditions the licensee has calculated that the i

4 cumulative dose within 50 miles of the plant would be about 0.75 person-rem.

1 The peak beta skin dose at the site boundary is calculated to be from 2.9 -

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5.6 millirem with a whole-body dose between.04 and.10 millirem. An advantage to venting is that it can be accomplished in a much shorter time than the other alternatives considered. We are currently preparing an Environmental Assessment of the licensee's proposals.

(Copies of the licensee's proposals are enclosed.) This Assessment may be used as part of a near-term decision regarding the krypton, but in any event will be fully incorporated into the programmatic EIS.

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Question 7 Should the NRC consider the financial ability of a utility to withstand the

, effects of an accident or decommissioning? Have any formal proposals been made by any NRC personnel with respect to this issue.

If so, please supply the Subcommittee with such a. proposal.

Under the provisions of 10 CFR 50.33(f) and Appendix C to Par.t 50, the staff determines whether an operating license applicant 'has reasonable assurance

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of obtaining the funds necessary to cover the estimated costs of permanently shutting the facility down and maintaining it in a safe condition." In making this determination, the staff reviews the applicant's decommissioning cost estimate for reasonableness by comparing it to independent estimates prepared.for the staff by the Pacific Northwest Laboratory.

In addition, the applicant must demonstrate that it has a method for assuring that funds will be available for subsequent decommissioning.

The Commission is now considering development of more explicit overall policy for nuclear facility decommissioning which would include specific guidance on decommissioning criteria for production and utilization facility licensees. As part of this effort, a staff task force is studying alternative methods for assuring the availability of funds for decommissioning. Although the staff has not yet made any final proposals in this regard, the enclosed publication, NUREG-0584, " Assuring the Availability of Funds for Decommissioning Nuclear Facilities," presents various funding alternatives that are being studied.

In light of the severe financial consequences to Met Ed and GPU caused by the TMI accident, the Commission has directed the staff to analyze alternative approaches for assuring that each licensee has adequate financial arrangements to facilitate recovery from a major accident, including, but not limited to, consideration of a requirement for adequate utility insurance or a connitment of a holding company's assets for accident recovery. The Commission's regulations do not now provide for such arrangements. However, the financial consequences of the accident to Met Ed and GPU will be a factor considered by the staff in determining whether there is reasonable assurance that the licensee can obtain the necessary funding in the TMI-l restart proceeding.

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The NRC staff is monitoring the utility and nuclear industry's current joint effort to establish their own insurance pool (through a mutual insurance entity related to the Institute for Nuclear Power Operations) to help cover the costs of replacement power required as a result of a nuclear accident.

Losses sustained by third parties in a nuclear accident are covered by provisions of the Price-Anderson Act.

Additionally, many utilities, at their own discretion, maintain "all risk" property insurance on their nuclear facilities which could cover some or all damages to the facilities. We will continue to monitor the industry's efforts to provide its own replacement power insurance for an accident, so that we can make a judgment as to the adequacy of the coverage provided.

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ENCLOSURE 1 STATEMENT OF POLICY AND E0TICE OF INTEllT TO PREPARE A PROGR;JSiATIC EUVIRomiEliTAL Ili?ACT STATEMENT l

-AGENCY:

U.S. Nuclear Regulatory Co= mission

' THIS DOCUMENT CONuma P00R QUAUTY PAdig ACTION:

Statement of Policy SUl2iARY :

The Fuclear Regulatory Commission has decided to pre-pare a programmatic environmental impact statenent on the decon-tamination and disposal of radi'oactive wastes resulting from the March 28, 1979 accident at Three Mile Island Unit 2.

For some time the Coacission's staff has been noving in this direction.

In.the Cocaission's judgment an overall study of the decontamina-tion and disposal process will assist the Commission in carrying out its regulatory responsibilities under the Atomic Energy Act to protect the public health and safety as decontamination progresses.

It will also be. in keeping with the purposes of' the National Environmental Policy Act to engage the public in the Cornis sion's decision-caking proces s, and to focus on environmental issues and alternatives before cocrittents to specific clean-up choi.

are made.

Additionally, in light of the extraordinary s

nature of this action and the expressed interest of the President 's Council on Environnental Quality in the TMI-2 clean-up, the Cocaission intends to co-ordinate its actions with CEQ.

In s

l particular, before determining the secpe of the programmatic environcental impact statement the Commission will consult with CEQ.

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The Commission recognizes that there are still areas of uncer-tainty regarding the clean-up op.eration.

For exacple, the precise Dapc k qq,

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condition of the reactor core'is not known at this. time and cannot be known until the containment has been entered and the reactor vessel has been opened.

For this reason, it is unrealistic to expect that the programmatic impact statement will serve as a blueprint, detailing each and every step to be taken over the coming months and years with their likely impacts.

That the planned progracmatic statement inevitably will have gaps and will not be s complete guide for all future actions does not invali-date its usefulness as a planning tool.

As more information becomes available it will be incorporated into the decision-making nrocess, and where appropriate supplements to the prograccatic environmental innact statement will be issued.

As the decontamina-tion of TMI-2 progresses the Cocaission will make any new inforna-tion available to the public an~d to the extent necessary will also prepare separate environmental statements or assess. cents for individual portions of the overall clean-up effort.

The developaent of a progranaatic impact statement will not pre-clude proapt Commission action when needed.

The Commission does recognize, however, that as with its Epicor-II approval action, any action taken in the absence of an overall impact statement will lead to arguaents that there has been an inadequate environ-mental analysis, even where the Commission's action itself is supported by an environmental assessment.

As in settling'upon the scope of the programmatic inpact statement, CEQ can lend assistance here.

For example should the Ccamission before completing its programmatic statement decide that it is in the s

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.and the rationale for choices inade i!e are alse. directing our staff to keep us advised of their progress in rhese matters.

Dated at Uashington, D.C. this M day of November, 1979.

For the Corrission

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S. CRUEL J.

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l ASSURING THE AVAILAEILITY OF FUtiDS FOR DECOMMISSIONING NUCLEAR FACILITIES ROEERT 5. WOOD ANTITRUST 5 INDEMNITY GROUF OFFICE OF NUCLEAR REACTOR REGULATION U. 5. NUCLEAR REGULATORY COMMISSION July 1979 i

i (Note:

Any opinions or conclusions contained in this paper are those of i

the author and do not represent official NRC policy.)

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mas Me erv starr cTose COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS WASHINGTON. D.C. 20510 November 15, 1979 The Honorable Joseph Hendrie Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Chairman Hendrie:

Thank you for your participation in the November 9, 1979 hearings held by the Senate Three Mile Island inves-tigation.

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In the hearings, we attempted to surface issues f

relevant to recovery at TMI.

However, because of time constraints, many important questions were not fully 5-addressed.

In view of this, and the need to have on the record your views on these matters, we would appre-ciate your responding in writing to the questions attached

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to this letter.

Please supply the reasoning behind your responses.

We would appreciate your comments as quickly as you can provide them.

In order for your answers to be factored into our investigatory report, they should be in our possession by November 26.

Answers received after this date may be utilized at a later date.

Thank you very much for your cooperation.

"1 Sincerely yours, 4

Alan K.

Simpson Gary H t

Ranking Minority Member Chai n

Subcommittee on Nuclear Subc mmit ee on Nuclear Regulation R gula ion Enclosure S/H/kes

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What about venting of krypton gas from containment?

Will an assessment of possible environmental impacts of

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2 alternate treatments of Kr-85 be prepared?

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7.

Should the NRC consider the financial ability of a

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utility to' withstand the effects of an accident or de-

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commissioning?

Have'any formal proposals been made by 1

any NRC personnel with respect to this issue?

If so,

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i please supply the Subcommittee with such a proposal.

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QUESTIONS FOR JOSEPH HENDRIE, NRC 1.

Do the risks to the public and worker health and safety

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increase if cleanup activities are delayed, i.e.,

sp.ecifically:

a.

What are the risks associated with the radio-active atmosphere presently contained by the reactor building?

b.

What would the health effects of a hypothetical' ground release be?

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c.

What are the risks associated with a delay in the processing of the contaminated water con-tained in the reactor building?

d.

Can the water in the primary building leak out if too much time passes?

e.

When is the earliest that the building could leak?

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Is there any urgency associated with the removal l

of the nuclear core?

The safe boron level has been cited at 3000 parts per million.

Could y

stratification of 'he coolant lower the concen-F c

tration in the core to below this level?

How long can each specific activity be safely delayed?

2.

Please describe more specifically than you were able in our hearing, how a modified EIS procedure license modifications or orders are expected to be utilized in future cleanup activities at TMI.

3.

If an EIS is prepared for the cleanup of TMI, who will do it?

4.

How long will that take?

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5.

What about actions necessitated by conditions on-site during the process of preparing the Environmental Impact Statement?

Will they require a separate EIS?

An Envir-onmental Assessment?

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Richard Ve umir Nove=bar

,1979.

G4L ikl6 While details of the proposed purging operation are contained in the report, the salient features include-l 1.

The controned purge of the approximately hh,000 curies of Kr-85 is acco=plished from an elevated stack vith significant dilution before reaching the site boundary.

l In addition, purge vill be permitted only under conditions of favorable meteorology. Cc=prehensive evaluations indicate that the maxi =um off-site dose resulting from total release vill be less than 5 mre=.

Environ = ental monitoring vill be e= ployed to detect the off-site ground level presence of any Kr-85 above background.

2.

Controlled purging does not require storage of Kr-85 for prolonged periods of time. It accordingly is a permanent solution and eliminates all risks arising from accidents with the three alternative methods.

3 Purging requires only slight =odifications to existing equipment and, hence, is an operationally desirable and safe approach.

We are cognizant of the concern on the part of sece members of the surrounding c-mities aboue the venting of the Kr-85 We are convinced, however, that this iis the most prudent and safest approach, vith negligible radiological i= pact of handling the contai=ent Kr-85 The Company vill do vnatever it can to provide sufficient infor=ation to the public to assure the= they will be aware of the timing of releases and the results of the monitoring of both on-site and off-site radiation levels.

We vill be technically ready to proceed with contai=ent pur-ing in e

apprcxi=ately one =enth.

We are requesting your approval to proceed with purging, subject to verification by NRC personnel on site of equipment and procedures, and are ready to meet with you to review the attach =ent or any other questions which you might have.

Very t ay yours, L.---

R. C.

ld Senior Vice President Metropolitan Idison RCA:UE:tas Atta.:hment

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Middletc.wn, Psam.vivania 17057 717 944-4041 Writer's Direct Dial Nurneer

- Nove=ber 13, 1979 GQL lkl6 TMI Suppcrt Atta: Richard Voll:er U. S. 'luelear Re6ulatory Cc==issic:

Washington, D.C.

20555

Dear Sir:

Three Mile Island Nuclear Statics, Unit 2 (TE-2)

License No. DFR-73 Docket No. 50-320 Reacter Containment Building At=csphere Cleanup The ulti= ate safe ec dition for the reacter and reactor contat==ent building requires deccetsmination and re= oval of the reactor fuel.

To accceplish this it is necessary that the existing reacter 'cuilding at csphere, containing Kr-85, be re=cved. Over the past few =onths

~ ve have studied the varicus alta atives for accomplishing re=cval of the Kr-85, including a ec=prehensive safety and enviro== ental assess-ment. The results of these studies are ecstained f.: the attached repcM.

Of the four optic s exs=ined; charcoal adscrption and storage, gSS co=pression and storage, c:70 genic precessing and ctorage, and at=cspheric purge, we strengly recc==end that at=cspheric pu ge be the =eans for accerplishing the disposal of Kr-85 Our studies shov that the purge operatic:, using centrolled venting through the plant exhaust stack and =eteorological feedbach, cc he de e with no significant hacerd or radiatic exposre either to the general pcpulation or the site. The purge es: =eet all technical specificatices and NEC radiological criteria. A significant advantage to the purge operatics is that it es: be accc=plished i= a relatively short ti=e cc= pared to the two to three years required for alternatives and this shcrt time scale, in itself, is a significant safety advantage. The ti=e to i=ple=ent alternatives to purge are such that ve can ct guarsstee full ecstain-

=ent integrity and veuld, in fact, cxpect generr.1 populatics deses to exceed those =ini=u levels resulting frc= p rge.

a DUPLICATE DOCUMENT r

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entered into system under:

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