ML19344A584

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Transcript of 800814 Discussion of Draft Programmatic EIS on Decontamination & Waste Disposal at Facility,In Washington, Dc.Pp 1-56
ML19344A584
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Site: Crane 
Issue date: 08/14/1980
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NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8008210183
Download: ML19344A584 (58)


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,t NUCLEAR REGULATORY COMMISSION C

C' In the Mattar of:

DIECUSSION OF DRAFT PROGRAMMATIC EIS ON DECDNTAMINATION AND WASTE DISPOSAL AT TMI i

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DATE: August 14, 1980 PAGES:

1 thru 56 I

AT: ' Washington, D. C.

T-(, REPORTING ALDEIL%Y C

400 Virgisia Ave., S.W. Washington, D. C. 20024 b

Telephone : (202) 554-2345 6 008240M

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UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION

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5 DISCUSSION OF DRAFT PROGRAMMATIC EIS ON 6

DECONTAMINIATION AND WASTE DISPOSAL AT THI 7

8 Boom 1046 9

1717 H Street, N.W.

10 Wa shington, D. C.

20555 11 Thursday, August 14, 1980 12 13 The Subconsittee met, pursuant to notice, at i

14 10 :0 5 a. m.

15 16 3EFORE:

17 J0'SEPH M.

HENDRIE, Commissioner (Presiding) l 18 VICTOR GILINSKY, Comnissioner 19 PETER BRADEORD, Commissioner 20 21 22 23 l

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1 STAFF PRESENT:

2 B.

SNYDER 3

B. DIRCKS

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4 P. LEECH 5

J. COLLINS 6

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LYNCH 7

S. EILPERIN 8

L. BARRY 9

E. CASE 10 H. SHAPAR 11 'ALSO PRESENT:

12 MATT BILLIS, EPA 13 14 15 s

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ALDERSON REPORTING COMPANY. INC.

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O, DISCT.ArdIR o

nis is an unofficial =anscript of a nasci g of the United States Nucles: Regulatory Comission held on Aueust 14, 1980 in cha Commission's officas at 1717 E Screac, N.

W., Washington, D. C.

n a maating was open to public at:andanca and observacion.

21s c:anneript has soc baan reviewed, correc:ad, or edi:ad, and it may contain. inaccuracias.

j The =anscripe is incanded sola17 for gn=aral infor=ational purposes.- As provided by 10 CTE 9.103, it is soc part of the formal or informal record of decision of :ha ma :ars discussed.

Expressions of opinion in this c anscript de set cacessarily reflect final deca +=tions or baliafs.- No plead 1=g or other paper may be-filed. with :he Commission i.. any procanding as -da resul: of or addressed. to any stacamane or arguman: contained.

harain, axcept as the Commission =ay authorUs.

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CONKISSIONER HENDRII:

We will come to order, p

3 please.

4 I should note that the Chairman is tak?.ng some 5

well-deserved leave this week.

My other colleagues will 6 join us directly.

7 We meet this morning to hear from the staff 8 briefing a discussion of the programmatic environmental 9 impact statement on decontamination and waste disposal for 10 Three Mile Island Unit 2.

11 This effort has been under way since late last 12 fall, when the Commission determined that a programmatic 13 environmental impact statement would be appropriate and 14 necessary.

We have waited long for its accomplishment, and 15 are very pleased finally to have the draft statement in hand.

16 We have with us Mr. Dircks and Mr. Snyder of the 17 THI office and ottar officers of the Commission.

On my way 18 in, I saw Matt Billis of EPA, so I know at least we have 19 representation from that side of the government.

20 Bill, why den't you go ahead?

21 MS. DISCKS:

The statement that is before the 22 House, as you know, Mr. Chairman, we produced a statement a 23 little bit ahead of the schedule we forecasted back in 24 Novenber, and I think we pushed it at least until today, 25 which is somewhat ahead of the time that we talked about ALDERSCN REPORTING CCMPANY. INC.

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1 last spring at the urging of the Commission.

2 Bernie Snyder is the director of the project 3 office he will pick up the burden of the briefing.

He has 4 Paul Leech here and Oliver Lynch, and as you mentioned, Matt 5 Billis is sitting back there among the audience, and EPA 6 did --

7 CONNISSIONER HENDRIEs He seems to be suitably 8 hidden ("sa whern I sit.

I now locate him.

9 HR. DIBCKE:

Staff, tid meet with representatives 10 of various of fices in EP A last week and did a preview of the 11 statement at that time, and Matt, if you call on him, I am 12 sure he will be ible to address any points you might want to 13 hit his with or attempt to.

14 Bernie, why don't you pick up the meat of the 15 briefing?

16 COMMISSIONER HENDRIE Please go ahead.

I will T7 only say to the people who have come to the meeting this 18 morning that particularly er the back of the room, or some 19 of you may be behind a post, if it gets so you cannot hear 20 what is going on up here, why, stand up and wave a hand, and 21 I will caval the speaker into greater volume.

22 Okay, please go ahead, Bernie.

23 MR. SNYDER:

Thank you.

24 The preparation of this document has been a major 25 effort of my office, even prior to my joining it in the ALCERSON REPCRTING COMPANY. INC.

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1 first part of April.

A large number of people contributed.

2 Our major contractor on the job was Arcon National 3 Laboratory, and a little later on in my opening statement, I 4 will make sention of some of those individuals who did 5 contribute considerably to this document.

6 As you mentioned, Commissioner Hendrie, in respone 7 to a directive issued by the Commission on November 21, 8 1979, which is contained as an appendix to the 2EIS, we were 9 directed to prepare this document, and in so doing, the 10 staff has enviewed the status of the contaminated facilities 11 and the surroundings.

12 We surveyed the methods available to carry out th e 13 cleanup operations.

We analyzed the impacts of the cleanup 144 activities on the environment, members of the public, and 15 the workers of the plant. The staff has found that methods 16 exist or can be suitably modified to perform all of these 17 operations with a minimal -- with minimal releases of 18 radioactivity to the environment.

i 19 Generally, the required technology needed is 20 within the state of the art in our opinion.

The staff has 21 basad its analysis on plans received from the licensee, 22 where they were available, as well as a large number of 23 alte rna tives t.".a t the staff has independently developed and 24 assessed.

25 The alternatives considered are in general ALDERSON REPORTING COMPANY. INC.

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1 dependent upon the radiological and techological conditions 2 encountered.

Eince the precise condition of the reactor 3 core and reactor building are not known, the staff has c

4 described and assessed probable or bounding situations.

5 In our view, the PEIS has a general purpose in 6

mind, the use of it has, that basically what we intended to 7 do with this draft and will intend to fira up in the final 8

is to find the scope of all known activities and attempt to 9 bound them as far as their environmental impacts might be.

10 We would anticipate issuing supplements only if

  • 1 necessary, that is, if we have missed or the conditions of 12 the' plant are such that we had not anticipated a certain 13 c ondition.

We have to consider other alternatives, et 1-4 cetera.

Than and only then would we issue supplements.

We 15 do not view the document, the PEIS, even the draf t of the 16 finsi form, as being a decision-making document, but rather 17 the support for making decisions.

18 The PEIS was completed at the end of July.

We 19 have printed 4,200 copies which a're available for 20 distribution after this meeting.

A limited number of copies 21 were made available to EPA and CEQ.

As Bill mentioned, we 22 did have a meeting last week in which we discussed the 23 document with EPA.

Copies are available in the back of the 24 room, I believe, and we will be making them available to the 25 Federal, state, and local officials and any requesting I

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1 seaber of the public for review and comment.

2 We have made it very clear in this document that 3 the PEIS is the draft and a staff position, and the g%

4 Commissioners have not reviewed it in detail.

We have also 5 ande available in the back of the room copies of the 6 document which you have seen earlier.

It is NUREG-0698, 7 which is the NRC staff plan of action, how we are ' going to 8 go about doing our business on THI II.

That is available 9 also in the back of the room.

10 I mentioned that there were a large number of 11 contributovs to this document.

Just very quickly, I would 12 like to run through them.

Besides my own office, we had 13 assistance from other offices and other branches within NRB, 14 including the Radiological Assessment 3 ranch, the Siting 15 Analysis Branch, the Environmental Enceinering Branch.

16 Our Offire of NMSS has provided major input and I'7 has continued to support this project in a very good 18 manner.

The Waste Management Division and the Task Force

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19 group headed up by Bob Browning has been involved on a day 20 to day basis with this project.

21 The Argonne National laboratory, EIS Division, l

22 under Jim Opelka, sitting back here in the black suit, was 23 the project manager for the job, and vill continue to be our 24 manager for the Argonne activities.

25 The SAS Civision -lso contribute.d significantly l

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,j from Argonne in the Chicago ares, and Argonne West provided 2 considerable expect input.

There was a major contractor --

3 consultant, rather, to Argonne National laboratories, the gm 4 Waste Management Group, and their head, Peter Tweed, is 5 seated next to Jim, and they provided a considerable amount 6 of input.

7 A number of other subcontractors worked on this 8

project as well.

9 I would like to mention the very major conclusions 10 of the document, and they will be discussed in more detail, 11 and more of the conclusions will~ be discussed subsequently.

12 COMMISSIONER HENDEII:

Pefore you embark on that 13 more substantive part of the discussion this morning, as I 14 recall -- let me probe a little bit so I understand quite 15 clearly the place in the procedural aspects of the matter 16 that the programmatic environmental impact statement holds.

l'7 As I recall, when v'e decided that we'should do a 18 procrammatic environmental impact statement, it was, as I 19 recall, in part, on the basis that it would replace a series 20 of action-specific environmental studies.

We had at that

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21 time just completed -- the earlier year had gone through the 22 agonies of deciding whethat or not to go forward with th e i

23 Epicore II processing system to get a hold on the l

i 24 contaminated water accumulating in the auxiliary building.

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2 procedure under NEPA or one thing or another, and it seems 3

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to se that one of the -- part of the quid pro quo was to 4 produce a progranaatic environmental ispact statement.

This 5 was to prevent what I believe is now -- let me see if I can 6 remember the ters.

No, I can't.

7 MR. ELPERIN:

Segm enta tion.

8 COMMISSIONER HENDRIEs Segmentation, a process 9 which 'you would kind of expect might occur in certain long 10 worms or other lower forms of life.

11' (General laughter.)

12 C3E5ISSIONER HENDRIE:

At any rate, to avoid the 13 clearly staggering evils of segmentation in the 14 environmental review process, we agreed to go forward on 15 this major work.

Now I turn more to the counsel's office, 16 Bernie, than to you, and say, now that the draft statement 17 -- people will comment on it.

There vill ultimately be a 18 final statement.

19 As we approach the successive steps from there in 20 the Three Mile Island II cleanup, Steve, how much protection 21 is this and its successor documenta going to be with regard 22 to procedural requirements under NEPA?

That is, is it going 23 to be enough, assuming that the final document, you know,

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24 deals fairly with all comments, or are we at each step in 25 addition going to have to do a process-specific assessment?

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29. ELPERINs I think the answer probably depends 2 upon the detail of the programmatic impact statement, and to 3 what extent it covers what future specific action you g

4 propose to undertake.

I think it has to fairly cover the 5 major alternative's of specific future actions, and if it 6 doesn't, and if that future specific action is itself -- it 7 may itself have a significant environmental impact.

You 8 will have to do a statament dealing with'that as well.

9 I think the Commission's statement of policy last 10 November envisioned that the prograssatic im pact statement 11 by necessity could not answer all questions, and th a t is,

12 th s Commission finds new infornation along the way, and nov 13 actions that would be supplementary would in some form be 14 nade available.

It is not a panacea by any means.

It 15 depends on to what extant it actually rovers whatever is the 16 particular rourse of action or next action.

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'c05MISSIONER HENDSII:

Yes.

All right.

I can 18 vell understand that if a proposed future step is considered 19 to fall outside the umbrella of things that have been 20 consideyFu in the progranaatic statement, that indeed you 21 have something that changes that overall contour, and it is 22 fair enough that you go back in the context of the overall what that lusp looks like in the 23 to look to see what that 24 environmentil impart sense.

25 Now, suppose I had a specific step which is 1

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proposed which is well within the overall umbrella, a vaste 2 disposal stap or a decontamination step or whatever, but now em 3 for the specific step I know I as going to use a certain 4 kind of solution, and the hose pressues, nozzle pressures 5 are going to be certain values, that I now have a pretty 6 good estimate on how much effluent wash water I expect to 7 have, or what the solutions are going to be, and I look in 8 ay programmatic statement, and I find that, well, this step, 9 for instance, has been covered in a perfectly general var

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10 and bounds have been put'on the expected occupational dose, 11 the potential external effects outside the plant boundary, 12 and the environment has been considered.

13 Nevertheless, the statement itself does not t21k 14 about specifically doing it this way with -- I don ' t know, a 15 hoghair bristle brush and hose pressures o' 807 pounds, and 16 a solution which has 1 percent detergent in it, and so on.

e' tant before that goes 17 Now, you know, to what x

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19 environmental impart type which then deal with all of those 20 specifics.

l 21 MR. ELPERIN:

I don't think it is an eacy question l

22 to answer.

I think the answer really depends upon to what 23 extant thosa details are of themselves either minor details 24 or major alternatives, and the one case that comes to mind 1

25 is the Hanford waste tank space and the DC circuit, where ALDERSON REPo9 TING COMPANE INC.

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th e Department of Energy has done a very generalized impact 2 statement, programmatic impact statement about how they 3

g-would handle waste disposal in general, but had not done the 4

specific alternative design to the proposed tanks for 5 Hanford and Savanna River for handling vastes.

6 I think the standard the Court set in that case 7 was that where the -- where there were -- where the action 8 itself was a major action, building a~ waste tank to handle 9 defense vastes for a long period of time, and the 10 alternatives to that action -- there were major gaps in the 11 way alternatives to that action had been examined in the 12 programmatic statement.

For example, important elements of 13 design had not been treated in the programmatic impact 1<4 statement.

16 That then required a separate statement dealing 16 with those tanks, so I thin't the question is not susceptible 17 of an a priori answer.

ft really depends upon to what 18 extent can you say the alternatives and their major contours 19 have been fairly examined in the overall programmatic impact l

20 statement.

21 MR. 5HAPAR:

I would agree with that, but it boils l

22 down to whether or not you are co"ered adequately in the l

23 impact statament, even though you may not have every detail, 24 but if ycu can say, there ha's been adequate coverage both in 25 terms of the description of the environmental impact and a ALCERSON REPORTING COMPANY. INC.

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2 certainly take care of the segmentation probles.

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With respect to an individual action, that road 4 any fork.

Ihat action may require an anvironmental impact 5 statement if you are looking at it fresh,'in which case you 6 decide whether or not the programmatic statement has done 7 the job.

It may not be that significant an action, and you 8 are going to run the gazut and bring minor actions to major 9 actions, and you may want to have specific environmental 10 assessments for some of these specific actions in cases il where you feel that the programmatic statement does not 12 adequately cover it.

13 You do not necessarily need a new specific EIS if 14 the action'itself is a very minor action.

So, it all boils 15 down to whether or not the coverage in the programmatic 16 statement siequately describes the environmental impact in 17 the context of a specifi'c action down the line.

18 If the prior treatment has not been adequate in 19 some manner, you are going to have to fill that gap.

20 MR. SNYDERs I would like to make one comment on 21 that.

It is our intent in finallring this document to be am 22 clear ac possible on each of the major activities identified.

l 23 COM3ISSIONE3 HENDRIE:

I commend that direction, l

24 if it can be arhieved without great delay.

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I hasty to disband your environmental analysis forces.

Why 2 don't you go on with the sub stan tive -- more substantive 3 elements of the briefing, which are, how did it all come out ?

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MR. SNYDE2s Okay.

I would like to talk about ten 5 of the major conclusions.

There are more that are covered 6 in the document, and the other speakers, in particular Ollie 7 Lynch, will embellish a bit what I am going to say now, but 8

I felt that there were -- the following major conclusions 9 that came out of our review so far.

10 The first one is that we believe methods do exist 11 or.can be suitably modified to d'econtaminate f acilities and 12 defuel the rauctor at TMI II with minimal releases of 13 radioactivity to the environment.

There is enough 14 experience in othec decontamination efforts to give us 15 confidence.

Our second conclusion is that partial cleanup 16 alternatives which have been examined in the PEIS in which 17 the re' actor building would be sealed and some or all of the 18 ' radioactive sources lef t in place either would not eliminate 19 the potential risks or would convert part of the TMI II site 20 into a long-term permanent vaste depository.

l 21 Wa do not f avor that alternative.

It is our view 1

22 that all of the cleanup operations must be performed, 23 whether TMI II is decommissioned or rehabilitated to l

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I do want to point out that the PEIS 24 25 does not treat the question of decommissioning or ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE. S.W., WASHINGTON. o.C. 20024 1202) 554-2345

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I rehabilitation.

That is a future decision to be made.

2 Our thiri conclusion is that the cleanup of the 3

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facility should proceed in a timely manner.

Our view is 4

that this would sinimize the risk to the public and the 5 workers, and, we believe, based on advice we have gotten 6 from our consultants, reduce psychological stress.

7 The staff estimated as a fourth conclusion that to 8 accomplish all the tasks involved in these cleanup 9 activities, it would take five to seven years, starting f rom to April, 1979.

The range in this estimate is largely due to 11 substantial uncertainties regarding conditions within the 12 reactor building and the core and uncertainties with regard 13 to worker ef ficiencies that can be realired under these I'4 dif ficult condition s.

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15 We have made no estimate of cost in the draft 16 EIS.

Recently, within the last week, Eetropolitan Edison

'17 and dPU have issued publicly a revised cost estimate 1 15 schedule.

Their schedule is somewhat more optimistic than 19 ours.

20 Our fifth conclusion is that contaminated liquids 21 from the auxiliary and fuel handling building, the reactor j

22 building sump and reactor coolant system and various 23 decontamination activities can be processed by several 24 altarnativa water treatment systems considered by the staff.

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Let me ask you, is the l

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effort which ther plan to put on this cleanup consistent I) 2 with your schedule?

3 MR. SNYDEas We have not had an opportunity to see gm, 4 a detailed breakdown in terms of man hours.

I really cannot 5

answer that question.

They are providing us, and I guess 6 they have done it already -- I have not seen its it just some detailed cost estimates, and we 7 arrived this morning 8 will discuss this cost estimat's with them, and we plan to do 9

that Is it early next month?

10 MR. LEECH 4 It is early next sonth.

11 COMMISSIONER GILINSKYs Are you saying it can be 12 done in fiva to seven years?

13 MR. SNYDERs It appears to us based on what we 14 know about the conditions in the plant that, you know -- I 15 guess I would personally view that as being a minimum time.

16 It is going to take at least that long.

This is based on 17 the job, and trying to do sone estimates as to man hours 18 required to do the job.

Seven years was arrived at.

It is 19 a pretty crude estimate.

I think theirs is also a pretty 20 crude estimate.

21 We will include in the final environmental 22 statement, to the best of our ability, estimates of cost in 23 order to do a full NEPA type review, which does require a 24 consideration of dollar cost.

We will discuss to the extent l

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1 of the cost of various alternatives, so that information J

2 will be available and will be one of the factors in making 3 the decisions.

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I do not view that as being overwhelming, and for 5 that reason we did not do anything on that subject for the 6 draft.

It was a lower priority item.

Our fifth --

7 COMMISSIONER HENDRIE:

The cost benefit balancing l

8 here is a little bit different.

9 ER. SNYDER:

Yes.

10 COMMISSIONER HINDRII:

Normally, the question is, 11 do you build a plant, should you build a plant, and are the 12 benefits to be derived f rom its product commensurate or 13 Greater or at least commensurate with the environmental 14 costs, defining that in the broadest possible way.

15 Hare you are not precisely daciding whether TMI 16 Unit 2 is to produca a product which is worthwhile.

Rather, rou have a substantial difficulty if you do net remove it.

17 18 I as not su:;e.

You know, the costs are obviously of l

19 interest, and I suppose there is sone interest in what 20 appear to be cost differences between alternatives, but I do 21 not know if you decided the overall cost of the cleanup was 22 going to cost, you know, $200 million, $5 billion, 57 23 billion, $2 billio n, I don't know that it sakes such of a 24 daan.

25 HR. D!ECKS:

I think that is the important point.

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1 COM!ISSIONER HENDRIE You are going to clean it 2

up.

3 MR. DIRCKS4 This is removing an environmental 4

problem.

5 COMMISSIONER GILINSKYa Still presumably there are 6

alternatives, modes of cleanup.

7 MR. DIRCKSa There are alternative ways of 8

cleaning it up, but the question is alvars -- always you 9 have to keep in sind, you have to get on with the thing, and 10 get rid of the source of the problem, not putting a nov 11 problem in place.

That is the whole thrust of this 12 statement, to look at alternative ways of ge tting rid of the 13 probles, just not put something in its place.

14 COMMISSIONER GILINSKY Sure.

15 MR. DIRCKSs That has been the dif ficulty all 16 along, how to remove the problem.

17 COMMISSIONER GILINSKY:

Ielis always a question in f

18 dealing with alternatives.

If the thing isn't there, then

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19 the alternatives are different.

20 MR. DIRCKSs Having it there or not having it 21 there.

That is the alternative.

22 COMMISSIONER GILINSKY:

Well, of course.

23 ER. SNYDER:

To continue, the fifth conclusion, 24 major conclusion that I wanted to single out was that we 25 feel contaminated liquids from the auxiliary fuel handling sa l

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1 building, the reactor building sump, reactor coolant system, 2 and the decontamination activit.ies can be processed by 3 several alternative water treatment systems considered by 4 the staff.

5 Aftee dilution, any of these process weters could 6 within our regulations be released to the river without any 7 adverse environmental impact.

However, as I pointed out 8 earlier, this is not a decision-making document.

It is not 9 our purpose here to make a decision on that very sensitive 10 psiat.

It is clear to me that thera are very viable 11 alternatives to releasing into the river, and we are going 12 to explore those in some greater detail as we go through and 13 finalize this docuent, and we will get public input on that 14 point.

15 It is probably the more -- that in my view is the 16 most difficult decision that has been made on this whole 17 p r o.i ect.

18 COMEISSIONER GILINSKYs I am not sure I understand 19 your point about this not being a 'ac sion-making document.

20 It is part of the decision-makinr l; ass.

21 MR. SNYDER:

It is past o f thta process, but we are 22 not saying, yes, we are going to dump to the river in this 23 document.

Even in the final, when we reach a decision on 24 the document, basi : ally, it is going to --

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25 COMMISSIONER GILINSK!:

It is supposed to be a l

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1 discussion of alternatives.

2 MR. SNYDER:

Right, exactly.

It will have them 3 all there in as much detail as we can provide.

I only gs 4 mention that one because it is obviously a very sensitive 5 subject.

6 Our sixth conclusion is that radioactive fuel and 7 other high specific activity wastes f rom TMI II must be 8 packaged and may have to be stored at the site until a 9 suitable disposal site is established elsewhere.

No 10 significant environmental impacts are expected from this 11 storage, and we have taken a strong position in the document 12 that TMI II will not become a final waste dipository site.

13 However, there are some problems with the higher 14 specific activity wastes that we envision being generated.

15 As f ar as the lower level vaste --

16 C3MMISSIONER GIIINSKY:

Let me pursue that a 1'7 soment.

You have'not taken a position for the site being a 18 final resting place for the fuel.

19 MR. SNYDER:

The f uel or other high activity.

20 COMMISSIONER GIIINSKY:

There you are making a 21 decision.

22 MR. SNYDER:

.n a sense, I guess we are.

It just 23 seemed to me, and that was my personal doing, it is pretty 24 clear that you do not want to have a final waste repository a vaste repository in the middle of the river.

It is 3

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I clear that something needs to be done in order to move those 2 materials off the site.

p 3

C05EISSIONER HENDRIEs You would have to admit, 4 Bernie, if you can make the case for it on Three Mile 5 Island, it would be pretty easy almost any place.

6 ER. SNYDER:

If we could convince ourselves that 7 was right, then we would have the problem solved, but it is 8 clear to se that that is not the place for those materials.

9 There may need to be some storage over a period of time, and 10 there are facilities that are planned or under construction 11 for that purpose, but that is not the long-term solution or 12 the final solution.

13 COMMISSIONER GILINSKY:

All right.

14 MR. SNYDER:

I was referring to the higher level 15 m a te rials.

As f ar as the low level materials, it is clear 16 that the environmental impact of decontaminatio'n and 17 disposaf of those and shallow land burial is definitely a 18 minimal impact, and can be done within the normal waste 19 disposal schemes tha*. are used at the moment for operating 20 plants, shallow land burial.

21 COMMISSIONER HENDRIE:

For the high level stuf f,

22 anything in fact which exceeds materials acceptable at the 23 existing commercial low level waste grounds, we or Met Ed or 24 somebody is going to have to find a place to put them.

If 25 they are to reside on Three Mile Island until there is a ALDERSON REPCRTING COMPANY, INC.

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1 full-fledged commercial repository, I have a notion I am not 2 going to view that as a very good alternative, both because 3 it is likely in my view to take too long unnecessarily --

4 not unnecessarily, but just take too long, and secondly, 5 because that damaged fuel -- and I would guess that there is 6 not 'a great deal of the core where there has not been some 7 damage to the fuel assemblies -- is not precisely what you 8 have in mind when you envision sliding, you know, no rmal 9 service, spent fuel assemblies into some kind of a 10 cannister, and then putting them in the ground, and in fact, 11 I think that one will probably want to do some processing of 12 these damaged fuel elements, core matertals before ultimate 13 final disposal, and what that means.

14 Both of those reasons, the long time, I think, l

15 until there is a commercial repository, relatively long 16 time, and the fact that I think the material is going to 17 need some processing from the form in which you take it out 18 of the reactor, suggests very strongly to me that down the 19 line here we ought to begin to talk to DOE about a suitable 20 place in the government's system to take these materials.

l 21 MR. DIRCKSs We have been.

Not only the fuel that 22 ve are looking at.

23 COM3ISSIONER HENDRIE:

It is anything that will 24 not go into a commercial low level ground.

25 3R. DIRCKS:

You talk about processing the water (s

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-- you talk about processing the water.

There are the 2 resins, for exangle.

We have been talking to the industry 3 about making some strangements for their assistance in this

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4 area.

5 COMMISSIONER HENDRIEa Fair enough.

Let's get on 6 with it.

7 MR. SNYDER:

One of the important areas that I 8 have not mentioned are'the occupational and off-site doses.

9 Ollie lynch on my right will discuss those as the third iten 10 on this agenda.

A conclusion which we have reached based on 11 our consultants in the psychological stress area is that a 12 high level of psychological stress felt by some members of 13 the community should be considerably relieved now that the 14 bulk of the krypton gas has been successfully released and 15 well sonitored, particularly the monitoring program of 16 EPA's, which is the most extensive ever used.

It worked out c'

17 reasonably well.

That has been the feedback we have gotten 18 from the community as well.

'4e have a limited followup psychological field study beinc done for us.

It is under 19 20 way.

The casults of that should be published some time this 21 fall.

22 The consultants have advised us that low levels of 23 stress will continue during the cleanup, but they do advise 1

24 that they do not see or an ticipate long-term psychological 25 effects resulting fron the cleanup.

Their bottom line l

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24 I) 1 basically is completing the cleanup as expeditiously as 2 safety considerations will allow is desirable to minimize 3

the stress for the public, and decisive decision-making on g-4 the part of our agency and others that are involved will 5 certainly help.

6 On balance, the benefits of full decontamination, 7 core removal, and disposal of the radioactive vastes from 8

the accident in our opinion greatly outweigh the 9 environmental costs of the activities, and as mentioned 10 earlier, it is clearly a situation that needs to be cleaned 11 up.

There are not any real alternatives there as f ar as 12 partial cleanup.

13 I would like to turn it over to Paul Leech, who 14 will discuss how the PEIS was created, what the methodology 15 used was, and a general discussion along those lines.

16 MR. LEEC$a When the staff was directed in L

l'7 November,-1979, to prepare the programmatic statement, we 18 were confronred with an unusual situation with regard to 19 information available f rom the licensee.

l 1

20 As you know, the environmental and safety analysis 21 reports provided by an applicant for construction permit for 22 operating license usually contain most of the inf ormation l

23 needed for our review.

Such reports had not been developed 24 for the cleanup of TMI II.

We therefore faced the necessity 25 of ga thering much of the needed inf ormation and performing L.

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I technical evaluations in many of the areas, if the 2 programmatic statement was to be completed expeditiously.

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3 This has been accomplished with a large amount of

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4 technical assistance from the Argonne National laboratory 5 and its consultants.

6 While we were in the process of organizing our 7 environmental review team last December, we found that two i

S documents were available from Metropolitan Edison Company

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l 9 which were helpful in formulating our. task.

10 One of these documents I have here in front of 11 se.

This big, thick thing is called A Planning Study for 12 Containment Entry and Decontamination.

It is dated July 2, 13 1979, and it had been prepared soon after the accident.

It k

14 included a preliminary assessment,of radiation within the 15 reactor containment building.

It does not cover the 16 activities being planned for defueling, cleanup of the 17 reactor itself, and the primary coolant system.

18 There was a supplementary document which came out i

19 in May of this year which did get into those.

20 There is a second document, which I believe you 21 say have seen in the past.

It is called The Summary 22 Technical Plan, and it was issued by the utility on December l

23 12, 1979.

It identifies all the major steps involved in the 1

l 24 cleanup, and includes a planning schedule.

That planning 25 schedule is reproduced with some slight changes in it as a

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1 vu-graph, lA, and it is in your briefing package if you care 2 to look at it.

3 It lists them all, and if you would like, we can

(-

4 go into that.

5 Based on these two documents and our environmental 6 standard review plan, we developed the preliminary outline 7 which was tailored to the cleanup steps in the approximate 8 sequence in which they are planned to occur by the utility.

9 This preliminary outline and the proposed content 10 of the statement were^ discussed with staff members of the 11 President's Council on Environmental Quality, and then we 12 requested and received an extensive briefing at THI from the 13 utility and its consultants.

This was back in January.

1-4 During that same month, we initiated a series of 15 public scoping meetings which lasted through March 20.

16 ' Members of our team have toured a similar plant at Eldland, 17 Michigan, at a time which enabled them to inspect physical 18 parts that are not accessible at TMI.

19 Decontamination experience at other nuclear 20 f acilities has also assisted the reviewers and the licensee 21 has continued to provide useful information as it becomes l

22 available.

Now, as we progressed through the scoping 23 sessions and preparation of the statement, we have made 24 modifications of the original outline, in order to be l

l 25 responsive to suggestions, and as we found changes to be t

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1 necessary.

2 There is another vu-graph, 2-3, of which you have 3 a copy, that identifies the major chapter headings in the C

4 PEIS.

You also have the PEIS there.

I guess you can look 5 at either one if you wish.

~

6 No w, actually, the utility's major activities that 7 he proposes to undertake or is undertaking are covered in 8 sections -- Chapters 4 through 9.

Number 4 is maintenance 9 of the reactor in saf e conditions.

Of course, they have 10 been doing that for quite a while now.

If you go into 11 Chapter 5, you will find decontamination of auxiliary fuel 12 handling building which has been under way since December, 13 1979 -- no, April, 1979.

1-4 Because of the fact that that has been under way, there has been l' ttle point for us in belaboring a review of 15 i

16 various alternatives as to how you would do th a t in the 17 PEIS.

Consequently, our section of the document is Section 18 S.I.

It simply describes what is going on in that regard.

19 The only sense in which you would, I think, view 20 those descriptions as alternatives would be the degree to 21 which you used one method or another.

We do assess, of 22 course, the occupational doses and so on that result from 23 those alterna tives.

24 Now, in Chapter 5, where we talk about 25 decontamination of the reactor building and equipment, we ALDERSON REPORTING OCMPANY, INC.

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have listed a number of activities, one of which -- two of 2

which have really already occurred in some aspect.

6.1 3 discusses the purging.

We had originally prepared a rather

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4 extensive examination of that and various ways of doing it, 5 and as you know, an assessment was produced and 6 authorization was given for those who want the information.

7 That assessment was reproduced in an appendix to 8

the document.

So, in 6.1 we don't go into it in any great 9 length.

We simply suzzarize it.

10 In 6.2, where we talk a' bout entry and radiati in 11 asse.ssment within the building, we know there has not been 12 an antry, but until we get that, we may have here and there 13 aissed a place we might have changed to acknowledge that 14 fact.

Please bear with us on that point.

That may happen.

15 Now, going on from there, though, you get into 16 6.3, and here we talk about processing of water in the sump 17 of the reactor building.

There we do in our usual format 18 the way these chapters are structured, first of all, by 19 scope of the situation, the status, the situation that is 20 there, and then we talk about various alternatives that l

21 people ha ve brought up or that we thought of ourselves.

22 We select those that we think are feasible ones, 23 and we go into those at some length, and then we analyre the 24 environmental impacts that will result from those 25 alternatives.

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1 That is the basic way in which all of these 2 particular chapters are structured, and that goes to the 3 other chapters as well, Beactor System Inspection, Primary 4 Water Processing, et cetera.

5 COMMISSIONER HENDRIE:

Before yoa get away from 6 6.3 in the processing of water, let ze'ask of the'five 7 alternative methods for processing the contaminated water in 8 the reactor building, I judge that such things as 9 solidification in cement do not correspond with Met Ed 's 10 current plants.

11 That is clear enough to me.

Eut since I have not 12 had -- read anything very detailed about the scheme that Met Ed is going ahead with at their own risk, and since you do 14 not use their nomenclature for that system, at least, I have 15 to inquire how well one of these alternatives provides a 16 f air covera 7e of their -- what is it -- submerged l

17 domineralirer sy'stan, or whatever it is you call it.

18 Is it a combination of them ?

How do these things 19 fit together?

20 MR. LEECH I believe that the casin system which 21 is identified as one of the five is a generic approach.

22 COEMISSIONE3 HENO3IE:

Is that essentially the 23 process that you are proposing?

l 24 MR. LEECH:

Yes, there are some differences in the 25 numbers that Met Ei has identified fro = the generic l

w.

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2 We will have to go into that more precisely when we do the 3 final statement to make it clear.

s 4

MR. SNYDEEt At the time that this document was 5 being prepared, of course, Eat Ed was just finalizing th eir 6 position.

They may be proceeding with hardware, and are 7 still in tha process of doing some design as well.

8 C3MMISSIONER HENDRIE:

Clearly the process of 9 events over the time of preparation of the document leaves 10 rou -- you know, the draft words are not precisely what you 11 would say if you were to create them all instantaneously 12 today with what you know todsy.

Th::e is obviously a time 13 lag.

14 Okay, so the final vill bring that out.

It seems 15 to se that since they nave concluded that they ought to go 16 ahead and buy some equipment and make preparations and so on 17 even in advance of staff raview and approval, that it would 18 be helpful that this document be clear on what their 19 particular approach amounted to, and how it fit within these 20 alternatives.

21 Okay.

You have answered my question.

22 MR. LEECH:

I will not go into much more detail 23 about the organiration of the statement at this time unless 24 you wish me to do so in response to some questions.

You 25 vill find that in each of these sections, 5, 6,

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1 that the last one in the section deals with the business of 2 handling waste, and then all those -- the last sections of 3 each of those chapters are brought togetner in Chapter 9,

{m 4 where you also deal with the subject of solidification, 5 packaging and shipment.

6 In Chapter 10, we have a summary of the 7 environmental impact of all these activities.

In presenting 8 tnas kind of a summary, we have given the bounds of the 9 impacts.

For impacts relative to any one activity, you have 10 to go oack to that particular section and look at the

~

11 comparison of impacts for those alternatives, but in Chapter 12 10 rou will fit.d that we take the upper bounds of each one 13 of those types of impacts and we present them.

14 Oliver Lynch will present that in a minute.

l 15 In Section 11, we present the monitoring programs l

16 that are going on by EPA and NRC and others, and 12 will 17 give you a summary of the major conclusions.

18 I suggest that next we ask Oliver Lynch to give 19 his summary.

20 COMMISSIONER HENDRIEs Please do.

21 NR. LINCH:

Ihank you.

22 Ihe principal environmental impacts will be borne 23 by the TEI work force, which will receive a significant 24 occupa tional radiation exposure, significant fractions of 25 the quarterly exposure limits, while they decontaminate.the t

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facility, remove the fuel from and inspect the reactor 2 system, and package, handle, store, and transport 3 radioactive vastes.

4 Members of the general public will receive 5 Virtually negligible of f-site doses, and heal'th effects from 6 projected sleanup activities.

A maximum whole body dose to 7 any individual off-site exposed to gaseous and liquid 8 releases from cleanup operations is essentially equal to th e.

9 saximum dosa to a member of the public located along the 10 transportation route that he might receive from close 11 proximity to a radioactive vaste shipment.

12 The cumulative population exposure of 26 to 66 13 person rem which could occur to the population within the i

14 2,300 mile vaste transportation corridor from all IMI II 15 waste shipments is the major off-site population dose.

Only 16 six person.res vill be accumulated by the population I'7 residing within 50 miles of TEI II.

Ihis dose will relate 18 from all caseous and liquid effluents resulting from all 19 routine cleanup activities.

20 Non-radiological effects will be minimal.

Social-21 impacts during the cleanup could include reduced property 22 values, competition between the work force and tourists for 23 temporary housing, and traffic congestion.

Potential 1

24 economic impacts include the effects of increased s

25 elartricity ra es, reduced tourism, and possibly resistance s

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1 to consumption of agriculture and fishery products that the 2 public any think are radioactively contaminated.

3 Families involved in agricultural production are

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4 likely to be affected to the largest degree.

Effects from 5 non-radiological effluents released into the environment t

6 vill be less than or at most no different from those 7 identified in the final supple 2ent to the final 8 environmental statement related to the operating license for 9 THI II.

COMEISSIONER GILINSKYs Do your estimates for the 10 11 doses include the possibility of mishaps?

12 MR. LYNCH:

Yes, sir.

13 COMMISSIONER GILINSKYs So you are including some 14 probability of something going wrong?

lb MR. LYNCH:

We have not included the probabilities 16 of sccidents.

We have includei analyses of the accidents 17 that we think might happen.

In our analysis of accidents, 18 ve did determine that through, I think, seven multiple 19 failures, there could be one -- a release of the sump water 20 to the river.

That pathway has been blocked.

21 All the other accidents include -- as best we can 22 speculate -- at least some mechanis::: where you could have 23 releases.

V.

24 MR. SNYDER:

I would like to comment on that.

In 25 going through the review, I believe it is correct tha t we ALDERSON REPCRTING COWANY. INC.

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did discover this one possibility, and that particular 2 section has been physically blocked off as a result, so ttst r

3 is one of the fallouts already from this report.

The six 4 milliren -- six person res, rather, that we mention in this 5 statement here is for routine cleanup.

It would be somewhat 6 higher depending upon which accidents you assume happen.

7 Those effects are all tabulated in Chapter 10.

8 COMNISSIONER GILINSKY:

Are you. going to say any 9 more about the occupational doses?

10 HR. LYNCHs Oh, yes.

We can go to Sheet 3A.

If 11 you want to use the screen, we can, but I believe everybody 3

12 has a copy of this.

Sheet 3A is occupational doses and 13 health effects.

Do you need a copy of these?

14 C3MMISSIONER GILINSKY:

No.

15 COMMISSIONER HENDRIE:

I think we have some.

16 MR. LYNCH:

I wouAd like to point out that the

~

l'7 vu-graph indicates majo r cleanup operation, 'the occupational 18 dose to the work force in person rem, the potential fatal 19 cancers, potential genetic effects in the of fspring.

20 You will note that the major occupational dose 21 occurs from the building' and equipment decontamination.

l 22 COMMISSIONER GILINSKY:

Those doses are spread 23 over how many persons, roughly?

24

38. LYNCH:

We were unable to indicate completely l

25 the work force that would be involved, but you would expect l

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1 on the order of 2,500 people max.

2 MR. SNYDEBs Basically, Met Ed applies an 3 administrative limit of one rem per quarter as opposed to 4 the three rem per; quarter that we apply.

So, if you assume 5 it were evenly distributed, you could just divide it by that 6 number.

It looks like there are going to be a couple of 7 thousand people involved.

8 MR. LYNCH 2,500 at one time, fuel cycles in and 9 out as they go along.

Some people -- we expect that people 10 vill be used for one tem per quarter.

There is no reason 11 why they could not be used up to three tem per quarter'.

And 12 in some cases, they may very well --

13 COMMISSIONER GILINSKY:

The limit is now five?

14 MR. SNYDER:

Five annually, three per quarter.

15 Met Ed's practice is, unless there are extraordinary 16 circumstances that require higher level approvals, is not to 17 limit it to three per quarter, as we allow, but one per 18 quarter.

19 COMMISSIONER GILINSKY So it is upwards of one 20 per person for the cleanup.

21 MR. LYNCH:

Yes.

22 MR. SNYDER:

On the average.

23 COMMISSIONER GILINSKY:

On the average.

[

24 COMMISSIONER HENDRIE It may be more at the lower 25 end of the band.

The band goes up to = ore than four times ALDERSON REPORTING COMPANY, INC.

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that.

2 COMEISSIONER GILINSKYs One to four.

3 C3MMISSIONER F.ENDRIEs Yes, and my guess would be 4

that out of a work force of -- total work force for cleanup 5 of 2,50'O people, it will not be a uniform distribution, and 6

that you will have 1,000 or so that will pick up the bulk of 7 the dose.

8 ER. LYNCH:

.I would say a few hundred at most will 9 pick up the bulk of the dose.

10 COEMISSIONER GILINSKYs That is over a period of 11 several years?

12 ER. LYNCHs Yes, sir. That activity is five to 13 seven years.

14 HR. SNYDER:

That is total, but the building and 15 equipment dacontamination, that is a couple of years.

16 COMMISSIONER HENDRIEs You need -- at 12,000

^

17 person rem, you need 1,500 people to do it to get it done 18 in two years.

19 ER. LYNCH I think the five to seven years is 20 cleanup for all operations, but specifically cleanup of 21 equipment is about two years.

ZZ ER. SNYDERs

'4e may be very high on these 23 estimates also.

The first entry a couple of weeks ago into 24 the containment building, indications were that any 25 estimates being sade were a f actor of two or three higher ALCERSON REPORTING COMPANY, INC.

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1 than what was actually seen.

That was a very limited 2 survey.

And tomorrow they are coing to go in with two teams

(

3 of two men each and get a better handle on it, and as time s.s 4 goes by, in the next few months,they will get a much better 5 indication.

We should be able to reflect some of that data 6 in this document..

7 Ny guess is, these are very high.

8 C03HISSIONE3 GILINSKYs Who supplied these 9 estimates?

10 MR. SNYDER:

We developed thase basically on --

11 with Argonne's help, using the limited about of data that 12 was available.

There were some samples taken within the 13 building prior to the entry.

These are all pre-entry 144 numbers.

There were some, for example -- for example, when 15 the TV camera was put in the building, the penetration that 16 that went through, there were samples taken from that.

17 COEHISSIONER HENDHIEs Let's see.

As you go 18 forward toward the final statement and have the benefit of 19 some measuraments inside the containment about radiation j

20 levels, you have obviously a much bot.er handle on the l

21 starting point in terms of the r

. tion levels.

22 On the other hand, tne exposure numbers depend not 23 only on those levels, but also on how long pec 11e are goin'g

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24 to be exposed ss they work through the hopefully diminishing 25 radiation field as the cleanup goes on, and you have, of L..

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course, built in some estimates of the number of sortees 2 that have to be saie, and the length of time people will be 3 in at certain levels, and then a little washdown helps.

The 4 next party works at a lower level, and so on.

1 5

You have to keep in sind that if this stuff sticks 6 a little harder on the walls than you estimated, the contact 7

times -- you still have to preserve a substintial recognized 8 error band on your estimates of contact times, I guess is 9

what I am stumbling around trying to say here.

10 MR. LYNCH:

I believe that is reflected here.

11 (Whereupon, at 11:04 a.m.,

Commissioner Bradford 12 entered the hearing roca.)

13 COMMISSIONER HENDRIE:

I would not necessarily tr7 14 to divide everything necessarily by what has been found to 15 be the actual internal radiation levels versus those you 16 would assume.

In fact, I was surprised that the range was 17 as low"as it was.

I would not have been surprised to see a 18 somewhat greater occupational exposure over the whole 19 operation, on no calculational basis at all, you understand, 20 but just an intuitive feeling that it is a pretty big job.

21 MR. SNYDERs It is certainly a big job.

You 22 should keep in mind, though, that we do have -- the site has 23 considerable experience, having pretty well cleaned up the

(

24 auxiliary and fuel handling building.

25 C0!MISSIONER HENDRIIs

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2 HR. SNYDER:

They are on the upward part of the 3 learning curve.

There is no question about it.

And that

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4 same experience will be applied to the containment. building.

5 COHNISSIONER HENDRIE:

Okay.

Please go on.

6 MR. LYNCH:

We will look at the total numbers 7 here, the occupational dose ranges from an expected low of 8 2,700 man cas -- person ren to 12,000 person res, reflecting 9 the unknown conditions in all areas.

Ihe potential fatal 10 cancers to the work force are expected to be he' tween 0.3 and 11 16 potential fatal cancers to the work force, and the 12 potential genetic effects in offspring, 0.63 offspring of 13 the work force.

14 If we look at Figure 33, a summary of the off-site 15 doses and health effects from the TMI II cleanup, we can see 16 the total -- we have the operation again indicated, total 17 body millires dose to the maximum exposed individual, and i

18 the maximum exposed individual's health effects, the 19 probability of cancer death over the lifetime of that l

20 individual, the probability of genetic ef f ects over the next 21 five generations from that exposed individual.

22 The principal exposures occur from decontamination 23 of auxiliary and fuel handling building', defueling and

(.

24 decontamination of the primary system, and truck 25 transportation of radioactive waste.

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effects in the off-site area around TMI are 1.6 millires to 2 the maximum exposed individual.

To the maximum exposed 3 individual for vaste transportation, we would expect 1.3.

4 Milliren total cumulative population exposure for 5 the entire cleanup in the THI off-site area within 50 miles 6 for a population of 2.2 million, as was indicated before, 7 six person ren, and the 2,300 mile corridor of waste 8 shipments, about 100 feet to about one-half mile from the 9 route, a population of 700,000, 26 to 66 person rem.

10 You can see the maximum health effects to the 11 saximum exposed individual are on the order of one in ten 12 millionth, or slightly above that.

13 Figure 3C is a summary of the estimated number of 144 waste shipmants, since the principal exposure would proba'.ly 15 come from the waste shipments themselves.

We have indicated 16 a total of 660 waste shipments as the best case, and the 17 worst case is 1,700 waste shipments.

18 Damaged fuel assemblies would probably be the 19 source of the greastest exposure in transportation 20 greatest potential exposure, excuse me.

21 Vu-graph 3D-1 and 2, we have indicated the 22 accident exposure.

We quickly go to the center of Page 23 3D-1, the worst arridents occur in the reactor building sump

(_

24 liquids.

We have identified four accidents that produce the 25 worst effects.

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. e.,

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The first one is leakage through a crack in the 2 floor of tha sump.

That would produce at the nearest water 3 intake to a person eating one kilogren of fish caught from

{

4 that water 1.3 millires.

This would be predominantly due to 5 strontina 90.

6 The second accident, failure of processed water 7 storage tank, we have two cases.

One case, the Bed Hill Dam 8 is over top from the spill.

Let me point out, what happened 9 is that the spill occurs, water flows into the stora system, 10 flows to the Bed Hill pond.

If the water flow is efficient 11 enough in the river, the Red Hill das could be overtopped, 12 and we could get four millirem if a person drank 20 liters l

13 of that water at the nearest water intake, which is Brunner i

14 Island, and if the river flow was insufficient to overtop 15 Red Hill Dam, water would be retained behind the dam until 16 there was sufficient flow for the water to overtop the dam 17 again.

18 We have considerably more mixing in that case, and 19 we have 1.6 millires if a person drank 20 liters of water at 20 the nearest water intake.

21 (Whereupon, ar 11:10 a.n.,

Comnissioner Gilinsky 22 left the hearing room.)

23 MR. LYNCHa The maximum effect accident is a

(

24 bitumin fire, with a heat filter failure at 1 percent of one

[

25 kilogram amount of feed or burn, and released.

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get 6.4 millires.

This would result from cesium-137 and 134 2

to an individual who took about one-third of his vegetables r-3 from a vegetable garden.

(

4 The fourth accident is failure of the heat filter 5 during a zeolif.e/ resin process.

The radionuclides would be 6 casium-137, 134, and an individual vould receive one 7

millires if he had one-third of his vegetables from a 8

vegetable garden.

9 Those are the major impacts of accidents.

10 I believe that is all I have on the environmental 11 impacts.

12 The next thing would be to discuss the schedule 13 for the final PEIS.

This is graphic SA, sta rting with the I

14 statement of policy and notice of intent to prepare the PEIS 15 which occurred November 29, 1979.

The draf t was completed 16 July 29, 1980.

The draft was to be issued today.

The EPA 17 Federal Register Notice on the availability of the statement I

l 18 which begins the public comment period is the 22nd of 19 August, and the end of the public comment period is October 20 6, 1980.

21 We would expect to complete the final programmatic 22 impact statement around the 9th of December, 1980, and issue 23 it on the day of completion.

i 24 C3!!!SSIONER 3RADFORD:

Let's see.

Does that 25 contemplate the Commission review of it?

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1 HR. LYNCH:

It contemplates public, Federal, 2 state, local review of the draft statement, and comments 3 thereto.

4 COEHISSIONER BRADFORD:

But the schedule would 5 contemplate you :.atting them into the package without 6 forwarding them to the Commission.

7 ER. SNYDER:

We anticipate we will brief you as we 8 are going out.

It is a staff document basically, and it is 9 not, as I sentioned, perhaps before you came, Commissioner 10 Bradford, it is not a decision-making document per se.

The 11 decisions that would be made on each of the individual 12 actions that need to be done at the island to clean it up 13 would be made in the context that they would use this 14 document.

15 Hopefully, we properly scoped it so we don't need 16 to do an individual environmental assessment, but it was our 17 plan basically to issue it as a staff document when it was 18 completed.

19 3R. DIRCKS:

An outline of technical alternatives 20 and their impacts which would go into allowing the 21 Commission to make decisions -- it does not recommend 22 decisions that the Commission might make.

23 COM3ISSIONER BRADFORD:

Let's see.

One of the

(

24 factors obviously in the decisions we make are what the 25 environmental impact would be.

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1 ER. SNYDES:

Yes.

2 COEEISSIONEE BRADFORD And this document would 3

be, I assuaa, the basic document for assessing that.

4 ER. SNYDER:

Yes, that is correct.

5 C3MMISSIONER SEADFORD Okay.

6

23. LYNCH:

Okay.

7 MR. SNYDER:

Let's see..

Basically, I believe that 8 is -

'Je arm open for questions for comments.

That is the 9 comp 3.etion of our pre-planned presentation to you.

I would 1(L be more than happy to respond.

I as sure the Argonne people 11 who are here would respond.

12 C3MMISSIONER RENDRII:

Let me ask a question, and 13 then Consissioner Bradford say want to pursue scae points.

14 The prograssatic statement now goes out for public comment, 15 government agency consent.

The prospect here is that 16 December 9 will see a -- see us back at the table being 17 briefed on the final prograssatic statement.

Thca, after a 18 certain amount of discussion back and forth about whether 19 the draft -- schedule f or the draf t ought to be -- you in 20 fact have done rather well with it.

I should have mentioned 21 that at the beginning, and I congratulate you.

22 Let's see.

This is August -- part of the var 23 through August.

September, October, November, Dece=ber.

24 That is four sonths to the final statement.

How soon do we 25 need to be considering the next step the cleanup?

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1 is, are they going to 'be ready?

Is there going to be a need 2 to get on with processing the water in the containment

('

3 building before the 9th of December, or approximately that s._

4 time, and the publication of the final statement?

5 HR. SNYDER:

Let me respond to that.

It-is hard 6 to pin down when either of the two things will be done.

7 There are a lot of contingencies that are not allowed for in l

8 the finalization of this document.

There is a 45-day 9 comment period involved.

If we find that we get extensive 10 comments, and we fully anticipate that we will --

11 COMMISSIONER HENDRIE:

Yes.

12 MR. SNYDER4

-- it is conceivable it might be t

13 later.

This is the minimum schedule.

1<4 COMMISSIONER HENDRIE4 A minimum of four months, 15 and t: could stretch out a bit.

16 HR. SNYDER Hight.

To answer your question, my 17 understanding of the schedule for completion of the system 18 that Met Ed is advocating, it is about the same schedule, 19 and I think we are'within a month or so.

20 My view on that, however -- and we recently sent a 21 latter to Matropolitan Eaison which Harold Denton signed --

ZZ I guess Ed Case signed for Harold -- in which we have 23 advised them again that they are proceeding at their own 24 risk.

We don't see any emergency need to process the 25 water.

We would like to get on with it as soon as we have ALDERSON REPORTING COMPANY, INC.

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1 met our comaitments in the process.

2 So, I don't think the schedules are that far off.

~

3 I as not making any promises that we would approve that 4 particular system.

However, we are continuing to review 5 that system by the way.

6 C3MMISSIONER HENDBIE:

Unfortunately, you know, it 7 vill still -- it sounds to se as though we are not going to 8 quite catch up until just after the next stage, that is',

9 a'ftar we begin to grapple with the decisions on the 10 containment water processing.

In some ways, it takes a 11 substantial time to do these analyses, and so I -- it would 12 be very useful in future significant accident cases if we 13 could anticipate the accident by about a year and start to 14 do the analysis of cleanup measures about a year before the 15 accident, and then de would be about in phase, so, those 16 analyses could feed neatly into the decisions that need to 17 he made after an accident.

i 18 I think -- it does sound as though we are going to 19 have another situation in which we would be looking at a 20 cleanup step in advance of the completion of the 21 programmatir statement.

22 MR. SNYDERS 3asically, we are doing them in 23 parallel.

We have agreed to continue to review the details (s

24 of the design and the operating procedures, and as a 25 professional technical review process, but in the meantime, k

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1 ve are working independently and looking at alternatives.

2 So, we are proceeding down parallel paths basically.

3 COMMISSIONER HENDRIE4 I don't see auch other way

(

4 -- auch other way to do it.

Obviously, if circumstances 5 should change or parception should change in which you feel 6 increased urgency about starting the. process, why, we can go 7 through the contine we have gone through twice before.

I 8 don't expect that to be the case, but I must say, I as also 9 of the view that quite without regard to any decision on the 10 serits of the process they have selected, I think Met Ed is 11 trying to do a responsible thing in getting on with the 12 design and the procurement for this next step.

13 If they don't do it, then it is mid-December or 14 some time thereaf ter before one has a final statement.

Then 15 presumably they would sit down and read the final statement, 16 and decide uhich of these options is in all respects best, 17 and at that point start design, and then a little later 18 procurement.

And what that means is, they would not be able 13 to start processing the confounded water for six to twelve l

20 months later than will be the case this way.

21 For whatever -- I think it is usef ul for them to 22 try to get on with it.

I only wish we were f ully caught up 23 with the process.

(.

24 Pater?

Let me stop for a minute.

25 C33XISSIONER BRADFORD:

I just have a couple of l

1 l

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questions.

2 With regard to the disposal of the spent fuel 3

itself, and whatavar highly active wastes come out of the 4 process, I have only been able to find a paragraph in here 5 saying there is nothing available at present.

Is that 6 really the best we can do by way of assessing the impacts?

7 Presumably there are choices, and something can be said 8 about them.

9 M2. SNYDER:

Let me ask Ollie Lynch to explain.

10

38. LYNCHs We have assessed the impacts of the 11 storage of the waste at the island, and we have ascessed the 12 impacts of running the vaste to a vaste disposal site, i.e.,

13 to the gate of the site, and we have indicated the amount of 14 land that would be utilired foc disposal of the waste.

15 We have not indicated the environmental impact of 16 that vaste disposal, figuring it would be done at a licensed l'7 site which would have its own environme'ntal impact statement'.

18 MR. SNYDER:

The question was about the high level 19 waste, not low level waste.

20

38. LYNCH:

For high level vaste, no site has been 1

~

21 identified.

22 COMMISSIONER HENDRIE:

The same would be true of 23 either.

l 24 MS. LYNCH We have considered the en vironmental sm 25 impacts of trancportation to the ga s, and we have used a ALDERSON REPORTING COMPANY, INC.

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2,300 mile away site as a worst case, i.e.,

Hanford, not

/

s 2 indicating or even speculating that they would be there.

3 That is a fairly maximum transportation route.

4 COMMISSIONER BRADFORD4 I see, so your impacts 5 then are calculated on the basiu of having to take high 6 level as well as lov level waste off-site?

7 MR. LYNCH:

Worst case.

8 COMMISSIONER BRADFORDa You have'not then gone on 9 to calculate impacts associa ted with what, long-tera storage 10 or disposal?

11 MR. LINCH:

No, not any waste repository, no.

12 MR. SHAPARs Could you use the 53 numbers?

U HR. SNYDER:

These are a small fraction of them.

14 MR. SHAP U.s If you wanted to --

15 MR. SNYDER Very small fraction.

16 COMMISSIONER HENDSIE Estimates of that kind are 17 obviously going to be pretty rough.

There is a question of 18 whether they are really any good, too.

That is, whatever 19 the impacts of the high lavel waste or all of the vaste, for 20 that matter, is going to be, it is just going to be.

That 21 is, you do not have an alternative that says, oh, boy, we 22 don't have to suffer those impacts.

23 You know, hopefully, they will be minimized within C

24 prudence and caref ul application of technology ultimately, 25 and all of that good stuff, but you know, whatever they are,

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1 you are going to have to put up with them'.

2 I was commenting, I think, before you came in, 3

Peter, that it seems to me that at some tise along the line, 4 not necessarily tosorrow, but on the other hand, I would say 5 not years down the line, we are going to have to benin to 6 bear down a little harder on other branches of the 7 government with regard to where these higher level wastes 8 are going to go.

That is, anything which is not acceptable 9 in one of the commercial low level sites.

10 It seems to me I would not regard it as a great 11 idea to think about leaving that stuff on Three Nile Island 12 until such time as there is a commercial high level 13 repository operating.

You know, it is clearly going to be 144 20 years, and both because of that long time and because I 15 as convinced that these damaged -- that the core fragments 16 and damaged assemblies -- one is going to have to do some l'7 processing on those before you would want to put them down 18 ultimately in the ground, that f or bo th these reasons, these l

19 n terials ought to go off to a suitable DOE site.

20 As I understand it, the Department of Energy is 21 not notably enthralled with that prospect.

22 COMMISSIONER BRADFORDs I have heard rumors to 23 that effect.

24 COEHISSIORER HENDRIE:

I guess we have had some 25 discussions with then.

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HR. SNYDER:

And some future ones planned for next 2 month also.

It is a continuing process.

3 COUNISSIONERHENDRI5 I think as time goes on, 4 why, perhaps after December, we o2cht to settle down to some I

5 serious hardball negotiations with our collesques over there.

6 COMMISSIONER BRADFORD:

I make the comment because 7 it seems to se at least one of the purposes of the document 8 is to enable somebody reading it to say, here is the 9 proposed course of action with regard to whatever the 10 problems are.

It says, I should think, what should be done 11 with the fuel rods.

That should be pretty high on the 12 list.

Here is what is to be done, and here is why it is 13 preferable to the other things that might be done to solve

-14 it.

15 I gather what you are telling me is, reading the 16 document, as to the spent fuel rods themselves, a reader is 17 not going to be able to tell what is going to be Ule to 18 tell what is going to be done.

19 MR. SNYDER:

He will have all tha alternatives l

20 that are reasonable.

There are alternatives.

Basically, 21 the document is one of discussion of alternatives and their 22 impacts.

Not picking a particular alternative.

That was l

23 not the intant of this document, to do that, and we did not 24 get that as being the Commission's intent of their November 25 statement of last year, either.

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We will,have other mechanisms by which those 2 decisions will be made.

3 COMMISSION 5R BRADFORD:

Let's see.

That is a ks 4 little different from, I take it, the normal structure of an 5 EIS in which you are laying out a proposed Federal action 6 affacting the environment, and then what the alternatives to 7 it are.

What you are saying here is that we really have not 8 laid out a set of proposed actions, but simply a number of 9 possible ways of dealing with the cleanup.'

10 MR. SNYDER:

Yes.

Under the circumstancas, I 11 could not see any other way to do it.

12 COMMISSIONER BRADFORD:

I sympathize with the 13 problems involved.

Was the Citizens Advisorv Group much 14 involved?

What can roc say about the involvement of the 15 Citizens Advisory Group?

l 16 MR. SNYDER:

At the moment we don ' t have -- that l'7 h'as not been establish'ed yet.

18 COMMISSIONER 3RADFORD:

I guess I lost track of it.

19 MR. SNYDER:

Chairman Ahearne had made a 20 ccanitment in the hearing before the Udall Subcommittee, I 21 guess it was, about a month or a month and a half ago, that 1

22 such an organization would be formed, and we will in the 23 near future make some succestions to the Commission as to 24 how to go about dotag that.

25 COMMISSIONER HENDRIE:

Let's see.

We were going 1

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1 to have -- Do I remember that Governor Thornburg was going 2 to suggest some people?

3 MR. SNYDERs That has come in the last few days, I 4 guess.

I have not seen the response to a letter that was 5 sent to the Governor.

That was the first step in the 6 process, to discuss with the Governor some suggested names.

7 We hope, given that, we can probably provida some 8 suggestions to the Commission.

9 COMMISSIONER HENDRIE:

'I would think that --

10 ER. SNYDERa There is another panel that we will 11 be working with.

In fact, Dr. Wagner is sitting over in the 12 corner here.

He is the Chairnan of Governor Hughes' 13 Advisory Panel in Zaryland.

We have had meetings with him.

14 We were just discussing it before this meeting, future 15 meetings, but I should mention that there were scoping 16 meetinos held, and there were three or four -- four public 17 scoping meetings that were held beginning in the early part 18 of this year and running through March, both in the 19 Harrisburg and Baltimore areas, which did help to define the 20 ccope of this incument.

21 This was when it was in its very formative stages, 22 and we will be meeting with other groups subsequent to this 23 report.

24 COMMISSIONER BBADFORD:

I was going to ask you 25 about that.

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1 M2. SNYDER:

Our plans are not entirely firs yet, 2 but it is intended to jointly with EPA and the states of 3

Pennsylvania and Caryland, depending on where the seetings 4 take place, we would propose to carry out pretty much the 5 same discussion program that took place prior to our trip 6 down there in which I believe there were about 40 meetings 7 held with tha public and certain groups.

8 COMMISSIONER BRADFORDs You say the. plans are not 9 entirely fits.

With a 45-day comment period, you have to 10 get some plans.

11

38. SNYDEat We have had some dis =ussions with 12 EPA, and John Collins at the site.

We vill probably fica 13 those up in the next week or two.

We are bringing back to 14 the site office Mr. Sasser, who is a full-time state 15 liaison, and we have established the contacts -- those that 16 were established previously will be used again.

17 There are hundreds of people we have talked to in 18 the past, and we will talk te them again.

19 COMMISSIONER 3RADFORD:

How was this document 20 actually distributed?

21 MR. SNYDER:

They can ask my office.

We have sent 22 400 copies up to the downtown-siddletown office.

We peinted 23 a very large number.

We have a mailing list that is being how many?

1,800 copies on the mailing list.

It 24 sent out 25 is a best seller.

We give it to anybody and everybody that ALDERSON REPCRTING COMPANY, INC.

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vants it.

2 COMMISSIONER HENDPIE:

I think I have run out of 3 questions.

Peter, if you have, for the moment, why, let me c3

(

4 ask if there are any of your colleagues -- Matt, did you 5 vant to say anything on behalf of our good friendr in EPA?

6 MR. BILLISs We did have a meeting last week with 7 Bernie and his staff for a quick review of the docusent.

We 8 have not had a chance to actually go over it.

There were a 9 few minor errors in it that I think can be easily corrected 10 with an errata sheet.

We will be looking very closely at 11 the disposal of the waste, the water and all.

12 One comment.

I think the uS-day comment period is 13 over-optimistic.

I pointed that out to Bernie at that 14 aceting.

I would say that I think the Citirens Advisory the group up there like that in that area, in that 15 Group 16 askaup, I think, =an help a lot in advising the people and I'7 assuring them what is going to happen.

18 One of the things I think we want to make sure is 19 that people don't feel they are backed into the wall.

They j

20 had opinion on the krypton.

We got down to the end.

We i

21 have to get rid of it, but we don 't have time to look at 22 these other methods.

e l

i 23 We definitely have to assure the people there that l

24 the time table allows them sufficient time to comment, and l

25 what we are going to do, and we need sufficient time to look i

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at all the alternatives.

We vill be working with Bernie's 2 people again on the 26th and we vill go over some of those 3 comments.

4 We vill try very hard to get EP A's comments within 5

the 45-day period, but I think it is a little bit 6 over-optimistic time frame.

er 7

COMMISSIONER HENDRIE Thank you very much.

8 Anything else?

9 (No casponse.)

10 COEHISSIONER HENDRIEs All right.

Very good.

11 Thank you.

12 (Whereupon, at 11:37 a.m.,

the meetino was 13 ad jo urned. )

14 15 16 17 18 19 20 21 22 23 24 25 l

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NUCLEAR REGULATORY CO.W SSICN This is Oc certify that the a:: ached proceedings before the

)b L.

in the satter of: DISCUSSION OF DRAFT PROGPRSUsTJC EIS ON DECONTAMINATION AND WAETE DISPOSAL AT TMI Date of ?roceeding:

Aucust 14, 1980 Docket !! umber:

Place of Proceeding: Washington, D. C.

were held as herein appears, and that this is the original :.anscript thereo f.for the file of the Cc==Lssior..,

David S._ Parker Official Repor:er (Typed) s' u

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