ML19338F963
| ML19338F963 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/16/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Hossler D AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8010280134 | |
| Download: ML19338F963 (10) | |
Text
9 Distributirn:
Docket No. 50-320 Attcrney, ELD NRC PDR G Ertter (ED0-09254)
Local PDR S Cavanaugh LTERA-R Weller NRR R/F S Newberry N
TM1 P0 R/F 0 Lynch TM1 Site R/F SECY (3) 80-1236 BJ Snyder Docket No. 50-320 JT Collins
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HR Denton f""
EG Case
.PPAS B Grimes D Eisenhut R Vollmer i
Mr. Drnald E. Hossler D Ross 501 Vine Street S Hanauer Middletown, Pennsylvania 17057 F Schroeder
Dear Mr. Hossler:
1 1 am writing in response to your letter of June 10, 1980 to Chairman Ahearne concerning the issue of decontamination of the Thl-2 reactor building atmosphere.
Your letter references the transcript of the Comission meeting of June 5,1980 on staff presentation of its Final Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor Building Atmosphere (NUREG-0662) and includes general and specific coments on the meeting transcript.
It should be noted that the purge of the TMI-2 reactor building comenced on June 28, 1980 and was essentially completed on July 11, 1980. Your coments are responoed to in the attached enclosure.
Sincerely,
})'aro.Mwsi,cdBy O
E b. C,-
H ld R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Response to Comments 2.
Comission Order for Temporary Modification of License 6/12/80 3.
Commission Memorandum and Order of 6/12/80 4.
NUREG-0662, Volumes 1 & 2 soloesouf<
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RESPONSE TO COMMENTS OF MR. DONALD E. HOSSLER Comment:
First, I get the impression that the Comissioners seem to think the people fear 10-15 curie accidental releases to venting.
I feel you have been misinformed. We would have all gladly put up with 10 or 12 accidental puffs of 15-20 curies occa-sionally while selective absorption was put in place last year. We all know K-85 is constantly escaping. Ar alternative would have been a good faith move by the NRC to 1) reduce stress tremendously, 2) be available for further gaseous releases, 3) be available to be moved to the next accident and finally because you will limit the amount of K-85 by 1993.
Response
During the first few months following the accident, the attention of the licensee
- a. d the NRC was focused on the problems at hand which were assuring adequate cooling of the damaged reactor core and dealing with the large quantities of radioactive waste water. Correspondence and discussion with many local citizens indicates that the public was not willing to "put up with 10 or 12 accidental puffs of 15-20 curies occasionally". For example, on February 11, 1980, a small, but uncontrolled, leak developed from the TMI-2 makeup system.
The makeup system maintains water inventory in the reactor primary coolant system and controls reactor system pressure. Up to 1000 gallons of the primary coolant water leaked from the system to the TMI-2 aux.
iliary building sump and a small amount of krypton-85 (less than 0.3 curies) was released during the incident. The release was well below the regulatory limits of 10 CFR 20 and the TMI-2 Environmental Technical Specifications, however, it proved to be very disturbing to many citizens in the plant vicinity.
Metropolitan Edison Company submitted to NRC a " Safety Analysis and Environmental Report" (November 13, 1979) in which they evaluated alternative methods for the proc-essing of the krypton gases, such as purging and cryogenic processing, and selective absorption.
NRC also evaluated alternative methods for processing the krypton gas to determine what effect decontamination would have on workers, on the public health and safety, and on the environment. Based on its evaluation, NRC issued an Environ-mental Assessment (NUREG-0662 and two Addenda) for public coment on March 26, 1980, and received approximately 800 coments. These coments were considered in the staff's preparation of the " Final Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor Building Atmosphere," NUREG-0662, Vols 1 and 2, copies of which are enclosed for your information.
From this process emerged the following NRC staff conclusions:
--The potential physical health impact on the public of using any of the proposed strategies for removing the krypton-85 was negligible.
.. u took to reach a decision, get started, and complete the processi;. gnger it
--The potential psychological impact was likely to grow the i
~
--The purging method was the quickest and the safest for the workers on Three Mile Island to accomplish.
--0verall, no significant environmental impact would result from use of any of the alternatives discussed in the Assessment.
On June 12, 1980, the Comission issued a Memorandum and Order and an Order for Temporary Modification of License authorizing controlled purging of the krypton-85 from the reactor building atmosphere. Copies of both Comission issuances are also enclosed. Actual purging operations began on June 28, 1980 and were com-pleted on July 11, 1980. The doses resulting from the purge were well within those predicted in Section 7.1 of Volume 1 of NRC's Final Environmental Assess-ment.
Availability of krypton removal systems at other sites in the future is currer.tly being considered.
NUREG-0660, NRC Action Plan Developed as a Result of TMI-2 Accident, was developed to provide a comprehensive plan for the actions now judged necessary by the Nuclear Regulatory Comission to correct or improve the regulation and operation of nuclear facilities based on the experience from the accident at TMI-2 and the official studies and investigations of the accident.
The TMI-2 accident did show that a significant quantity of radioactive noble gas may be released to the containment atmosphere.
NUREG-0660 identifies.
program to determine the applicability and desirability of the use of available technology to minimize the release of radioactive noble gases during and fol-lowing various postulated accident conditions. The program will include an assessment of the various potential pathways for releases of noble gases, as well as considerations of accelerated rates for treating large gas volumes, such as those existing in large containment structures.
Concerning your reference to the limitation of Kr-85 releases by 1983, the regu-lation you refer to is set forth in 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations, paragraph 190.10.
It specifies, in part, that the total quantity of radioactive materials entering the general environment from the entire uranium fuel cycle, per gigawatt-year of electrical energy produced by the fuel cycle, shall contain less that 50,000 curies of Kr-85, effective January 1,1983. However, the standard applies only to releases for normal operation and does not include accident generated Kr-85.
Comment:
Page 41 - Comissioner Kennetty appears stunned that those who wrote coments opposed to purging did not always recomend an alternative.
I would like to remind the Comission that it took 7 months from the time of the accident to decide to do an EIS and nearly 4 months to relay via the media that Kr-85
i :-
would have to be " disposed" of. The Commission's responsibility is to be decisive and develop and implement alternatives that are in the public's interest.
I also remind the Commission that without intervenor funding it is difficult for " working people" to address an E.A. or E.1.S. in a purely technical matter.
Response
As stated above, during the first few months following the accident the attention of the licensee and the NRC was focused on the problems of adequate core cooling and radioactive water management.
In its Statement of Policy and Notice of Intent to prepare a Programmatic Environmental Impact Statement of November 21, 1979, the Commission stated that the staff would prepare a programmatic environmental impact statement on the decontamination and disposal of radioactive wastes re-sulting from the Three Mile Island, Unit 2, accident. The statement emphasizes the Commission's intention to (1) coordinate its action on this matter with the President's Council on Environmental Quality, and (2) provide the opportunity for public comments. The programmatic environmental impact statement (PElS) was issued July 1980 and focuses on the environmental issues and alternative methods associated with the performance of these cleanup activities and will in-corporate the comments received from the public.
Concerning funding for intervenors generally in the NRC licensing proceedings, the necessary statutory authorization does not currently exist to provide such funds.
Comment:
Page 42, line 21 and 22 - It seems your instruction should come from a variety of sources rather than just PUMA. The addendum for comment on psychological aspects of venting was only citations. Did you really expect me to research all of them? Funding for an independent analysis would have helped immensely and nay still help.
Response
"PUHA" should read " Human" from the Human Design Group, the Staff's consulting p sychologi sts.
In using the term " Instruction" in line 21 Commissioner Hendrie l
was referring to the Commission's role in instructing the Staff on the nature of the NRC's responsibility in dealing with the psychological and mental aspects of TMI related issues. Addendum 1 of the NUREG-0662 was intended only as a preliminary indication of the scope of various studies related to the psycho-logical stress issue. The Staff's full analysis of this issue is reported in the Final Environmental Assessment.
Comment:
Page 43, line 6 False, appropriate developments of alternatives in April 1979 would have helped immensely.
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Response
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The Staff's analysis of psychological stress examined only the alternative available in the Spring of 1980 as outlined in NUREG-0662. There was no retrospective examination of alternatives which might have been available p reviously.
Comment:
Page 43, line 20 I understand certain elements of the study which this gentlemen assisted were withheld from the final report of the President's Commission.
Response
The differences between the final draft of the " Report of the Task Force on Behavioral Effects" dated October 15, 1979 and the document released to the public on October 31, 1979 are minor and mostly stylistic.
The missions in Chapter X, which deals in part with the distinctions between short-term and long-term mental health and behavioral effects, are a set of specific recom-mendations for further research. Omission of these recommendations does not change the conclusions reached in the remainder of the report.
Comment:
Page 45, line 2, 3, 4 - This gentleman is not independent as stated on Page 44 line 20. Have any of the three mentioned reviewed recent data or done recent clinical interviews?
Response
By independent the Staff meant that Dr. Quarantelli was not affiliated with the NRC, Met Ed/GP.U or any other parties with continuing direct involvement in TMI.
The Staff is unaware of a recent involvement in TM1 research on the parts of Drs. Dohrenwend, Warheit, and Quarantelli.
Comment:
Page 46, line 15 Acute stressing is chronic in this area because the institution of nuclear energy are feared and viewed as reacting more to monetary than human consideration. The stress will not end with disposal of K-85.
The stress will linger because of NRC indecisiveness in 1979 and Met Ed's lost credibility.
Response
The NRC is aware of the existence of psychological stress in the vicinity of TMI and appreciates that questions of credibility and perceived indecisiveness are contributors to stress. These considerations in fact supported the decision for venting krypton-85 quickly to proceed with decontamination of Unit 2.
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, i Comment:
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- s :.
Page 48, line 3 Better comunication does not come about by ' discontinuing public meetings, which were open to everyone as held by DER. I can guarantee that 90% of the meetings held since the famous Liberty Firehall Meeting were not advertised to the general public. No attempt was made by your agency to outreach to those who have been most vocal, instead you merely say, "We are available." NRC has not reduced stress but rather selectively shut-out masses of concerned and knowledgeable citizens who can assist in your final deter-minations and expose areas of concern that you are not aware of 140 miles distant.
Response
The NRC has pursued various avenues of communication with the public concerning TM1 issues. The Liberty Firehall meeting of March 19, 1980 was held to describe and discuss the results of the Environmental Assessment on TH1-2 atmospheric decontamination (NUREG-0662).
In addition, written public comments on the Draf t Environmental Assessment were solicited. Approximately 800 written coments were received and reviewed. Also, the Staff has held four public scoping meetings concerning the Programmatic Environmental Impact Statement for Decontamination of Three Mile Island, Unit 2, and is soliciting written public coments on the draf t statement. Many public meetings have been held already and are scheduled in the near future to obtain coments from the public on the draf t PEIS. Com-missioners have met three times witn public groups on TM1 concerns generally.
An NRC office was established in Middletown to make the NRC staff available to local citizens on a continual basis, and NRC Staff members are available to met with citizen groups and other organizations upon request.
Staff members h;ve participated in a large number of these meetings in the past months.
Comment:
Page 50, line 3 Were first and second series of interviews by the Western Psychiatric Study reviewed in detail?
Response
Dr. Streufert's remarks did not reflect the findings of the second data set (March 80) of the Western Psychiatric study headed by Dr. Bromet. At the time of the hearing the late information was not available and will not be available to compare to the preliminary analysis (Dec. 79 - Jan. 80) until early Fall 1980.
1 Comment:
)
Page 51, line 5 Perhaps the control group is equally anxious (a high level) about nuclear energy in their backyard. Therefore, our exceeding them by a
" low amount" may be quite high.
4
'7"d
Response
Beaver Valley nuclear power plant was a control site to rule out the possibility that differences in mental health between respondents in the two areas could be attributed to living near a nuclear facility per se.
Nevertheless, Dr. Bromet's initial impression (pg. 29) is that the average (symitom mean) score of each of the subscales falls in the range considered normal, with the Beaver County mothers being closer to the norm. Thus, those 1!ving by the nuclear plant at Beaver Valley do not appear to be under any unusual stress.
Comment:
Page 51, line 10 The threat level will remain after Kr-85 " disposal."
Response
It was anticipated that at least some individuals in the population surrounding TMI would feel threatened and thereby experience some amount of stress during the decontamination period. However, the potential psychological impact was likely to grow the longer it took to reach a decision, get started, and complete the process.
Comment:
Page 51, line 18-19 "Af ter TMI was already over with." This accident is not over.
Is this " independent" man telling us about his bias to nuclear energy?
Response
Dr. Streufert was referring to the intial emergency period during March and April.
His statement should not be construed to mean that events during that period do not have continuing ramifications.
Comment:
Page 53, line 25 and Page 54, line 1 The " symptomatology" will remain through the cleanup. Without clinical interviews how can one conclude "they are functioning normally."
Response
The psychological measurements made by a number of researchers, including the Behavioral Effects Task Force of the President's Comission on TMI, Dr. Evelyn Bromet, and Dr. Peter Houts indicated that the psychological profile of the TMI population is little different from the population as a whole.
, Comment:
S Page 56, line 15 What has the Comission done to reduce stNss for the past 15 months?
Response
During the past 15 months the NRC has attempted to comunicate to the public each step proposed or approved in insuring protection of public health and safety. Some of the efforts made to communicate were mentioned above in our response to your comments on "page 48, line 3-6".
Comment:
Page 57, line 1 Selective absorption disposal could remain and be monitored in the dacomissioned Unit 2 reactor.
Response
Onsite Long-Term Storage of Kr-85 is discussed in section 6.8 of NUREG-0662 Vol. 1, enclosed.
It was concluded that storage or burial of the Kr-85 gas was not the best alternative, due to the potential for subsequent uncontrolled release to the environment.
With regard to decommissioning Three Mile Island Unit 2, the licensee has not yet submittad to the NRC a proposal for overall plant recovery, or decomissioning although the licensee is conducting feasibility studies.
It is not possible at this time to determine when such proposals for recovery or decomissioning may be submitted or i e much time will be needed for the required reviews and approvals. Whether decommissioned or recovered, Unit 2 must be decontaminated.
Cornent:
Page 57, line 19 I know people who were not that concerned but in spite of the UCS report are in stressfdl times. You must remember that the utility has a long list of problematic mistakes and extremely low credibility which is connected to human psyche and extremely difficult to regain.
Response
We share your concerns that TM1 is a stressor to many people in the vicinity and that low credibility of any organization with responsibility toward TM1 will contribute to higher stress levels. These are reasons why NRC has attempted to improve comunications and its availability to the public in the TM1 area.
Comment:
Page 58, line 7 Will " disposal" of Kr-85 make the plant stable?
Response
Your question refers to Dr. Baums remark that prior to the purging of the Kr-85, the plant was " unstable". Taken in context, it appears that Dr. Baum is referring to the uncertainty associated with the selection of a reactor building atmosphere decontamination alternative and the possibility for accidental leakage until the choice is made. The answer to your question therefore is, yes.
Comment:
Other comments - By sampling out to 15-40 miles you dilute the serious concerns within 5 miles of the plant. Also with 1700 people working at TM1 and living in the area, neighbors and economics tend to keep people suppressing true feelings which will be detrimental to them, personally, in months ahead.
Response
The major TM1 studies treating attitudes and/or stress have either focused on the close in population or have been designed to account for distance as a determinant of attitudes or stress.
It is difficult to anticipate the effect of a la;ge TM1 labor force on the nature and degree of pychological stress.
Your position that, " neighbors and economics tend to keep people suppressing true feelings which will ba detrimental to them personally, in the months ahead" may have some validity. On the other hand, interaction with those working on the TM1 decontamination may have a beneficial effect on individual's perceptions of TMI.
Comment:
Is the Human Design Group backed by EPRI money or other vested interests of nuclear energy? The informal interviews surely needed contacts, who were the contacts?
Response
The Human Design Group is not backed by EPRI money or other vested interests of nuclear energy. The information interviews referred to on page 55, line 15, were residents of Middletown and Elizabethtown interviewed in their homes.
.x
.- Coment:
A The utility will never regain its credibility and fears of the people will not be decreased by " disposal" of Kr-85.
It is very important that the Commission pay more attention to TMI than just setting up a special office.
You need to become proactive rather than reactive.
You need to plan and utilize methods to educate the public about what the cleanup will involve.
Response
We believe the evidence we have examined supports the proposition that elimi-nation of the krypton-85 problem will result in lower stress than otherwise would exist. This does not mean that stress will be eliminated or that new events won't increase stress.
In its Statement of Policy and Notice of Intent to prepare a Programatic Environmental Impact Statement of November 21, 1979, the Commission stated that the staff would prepare a programatic environmental impact statement on the decontamination and disposal of radioactive wastes resulting from the Three Mile Island, Unit 2, accident. The statement emphasizes the Commission's intention to (1) coordinate its actions on this matter with the President's Council on Environmental Quality, and (2) provide the opportunity for public comments. Public meetings were held in the Harrisburg-Middletown area to discuss the scope of the impact statement. Meetings and activities s'milar to those conducted prior to the reactor building purge are being held to solicit coments on the PEIS and will likely be held for key recovery activities at the site.
Comment:
When is the Comission going to know whether Unit 2 will be decomissioned?
Once again here is a need for a decision. A prompt review and decision is needed. Surely, just the costs of decontamination alone make it wise to decomission Unit 2.
Response
As stated previously, the licensee has not yet submitted to the NRC a proposal for overall plant recovery or decomissioning. A proposal to restore or decom-mission the facility would probably not occur until a detailed inspection and 1
engineering assessment is made of the nuclear steam supply system and more in-l formation is known about its condition. Cost estimates to date show that the decontamination costs would be the majority of the total recovery cost so that the decision to decomission may not be made on a cost basis.
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