ML20002C851
| ML20002C851 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/20/1980 |
| From: | Hedeman W ENVIRONMENTAL PROTECTION AGENCY |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20002C843 | List: |
| References | |
| NUDOCS 8101120173 | |
| Download: ML20002C851 (9) | |
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UNITED STATES ENVIRONMENT AL PROTECTICN AGENCY
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OF F 4C L OF T MC AOM tNIST m A tom Dr. Bernard J. Snyder, Progam Director Three Mile Island Program Office U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Dr. Snyder:
In accordance with Section 309 of the Clean Air Act, as amended, the U.S. Environmental Protection Agency (EPA) has reviewed the Draft Programmatic Environmental Impact Statement (DPEIS) Related to Decontaminazion and Disposal of Radioactive Mcstes Resulting from the March 28, 1979 Accident at Three Mi a Island Nuclear Station, Unit 2 (NUREG 06 5 3 ?.
EPA hss been involved in monitoring the impacts of this accident on the environment since March 30, 1979, so we are in a unique position to recognize the unusual nature of this We commend the Nuclear Regulatory Ccmmission's action.
determination to protect public health and the environment Unit 2 during the decontamination of Three Mile Island, disposal of the resulting radioactive (TMI-2) and the permanen wastes.
EPA's detailed comments are attached; our major concerns are described below.
We hope they assist-the Nuclear Regulatory Commission (NRC) in the selection of alternatives in authori:-
ing and licensing utility actions during clean up and disposal.
The final programmatic EIS (or a supplement to the DPEIS) should provide more information on:
and disposition of radioactive (1) the amount, nature, wastes from the TMI-2 decontamination; the health ef fects associated with various levels (2) of exposure (public and occupational);
the effects of possible transportation accidents; (3) the cumulative ef fects on the public of all (4)
(this would exposures suf fered as a result of the acciden include the krypton-85 venting);
)3 S103120 l
(5) the estimated costs of the clean up actions; and (6) the psychological impacts of each alternative.
EPA believes that the FPEIS should be organized in such a fashion that all information pertaining to an alternative be contained in one section.
The FPEIS should be written in
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plain language so that the public can readily understand it.
EPA recommends that the NRC issue a supplement to the DPEIS which satisfies the concerns which we have regarding the inadequacies in the DPEIS.
EPA also recommends that NRC issue supplements to the FPEIS as additional data and information become available during the clean up operations.
Should you or your staff have any questions about our comments, please call: Mr. Jeremiah Manley (NEPA Matters,' 755-0770) of my staf f; Mr. Terrance McLaughrin (Technical Mr. stars, 557-7604) of EPA's Of fice of Radiation Programs; or Mr. Matthew Bills, Senior EPA Coordinator for TMI, (Monitoring Matters, 426-4452) of EPA's Office of Research and Development.
Sincerely your,
3 toe u
William N.
Hedeman, Jr.
Director Office of Environmental Review Attachment i
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S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
DETAILED CO 01ENTS ON THE DRAFT PROGRA.1AT.'..C ENVIRONMENTAL IMPACT STATEMENT (DPEIS)
J RELATED TO DECONTAMINAIION AND DISPOSAL OF RADIOACTIVE WASTES RESULTING FROM THE MARCH 28, 1979, ACCIDENT AT THREE MILE ISLAND NUCLEAR STATION, UNIT 2 (DOCRET NO.59-320, NUREG - 0683) 1.
The FPEIS, or the supplement to the DPEIS, should clearly identify the type and amount of radioactive wastes as an inventory.
This-should include the high specific activity wastes, damaged fuel elements, decontamination liquids, and those of processed water anticipated during cleanup.
It should also include those amounts that are estimated to have been inadvertently vented during the accident and intentionally vented during the bulk krypton-85 and weekly /=cnthly ventings.
2.
The FPEIS or Supplement should detail the options available now and the best available estimates of options available in the future (i.e., the reasonable expectation of time to be considered for clean up operations) for the ul'timate disposal of the radioactive wastes from the decontamination.
3.
The FPEIS should clarify the statements made on the subject of transportation of radioactive liquids and should rigorously explore and evaluate all reasonable alternatives.
The FPEIS should address the technical feasibility of 4.the off-site deep well injection as well as that of ocean We recognize that legislative, administrative, disposal.
and other obstacles may currently prevent the use of some But we urge the NRC to address all_ technically alternatives.
This possible alternatives and their costs in the FPEIS.
would then allow the recommendation of changes in legislation and/or regulation to allow the selec ion of a technically superior alternative for waste disposal.
5.
The FPEIS, regardless of preferred alternative for should disposal of low specific activity processed water, similar to that done for the krypton-provide an assessment 85 venting.
It would he beneficial in showing not only the worst case impacts but also the best controlled conditions for minimizing radiological exposure, psycnological stress, and other impacts.
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6..
Ihc FPEIS should eliminate the inconsistencies in wasto and tritiated water inventories as well as clarify the occupational exposures should tritiated water be used in decentamination.
Ventilation failure accidents could lead to significant exposures.
7.
The DPEIS includes the alternative of releasine licuids into the Susquehanna River.
Two alternatives for iiquid disposal a:
permanent storage en site or evaporation.
These liquids represent what is left after the 4SO,000 gallens of radicactive water has passed through a treatment phase which is likely to be an ion-exchange (EPICOR II).
The resulting water would then be mixed with uncontaminated water so that it satisfies EPA's interim drinking water standards (40 CFR 41) at the plant discharge.
The plan to meet the drinking water standards calls for mixing the radicactive liquid and dilution water at the respective rates of 0.8 gpm and 36,000 gpm.
It would take 416 days to discharge all this water to the river.
To demonstrate that this precedure would work consider the data tabulated below:
Input Cutput Concentration Concentration Isotope Concen-Concen-when mixed that Gives tration tration*
with Dilution a dose of (pCi/)
(pCi/1)
Water 4 mrem /yr (pCi/1) to a Critical Organ (cCi/1) 9 S.4x10f 19 200 Cs-137 S.4x10 9
1.4x10 3.3 SO 3
Cs-134 1.4x10 9 4
0.33 S
Sr-90 1.4x10 1.4x10 7
J 0.07 SO Sr-39 3.2x10 3.2x10 As can be seen frcm this analysis the concentration using the evaporation / resin process is at least an order of magnitude below the drinking water standards.
However, a number of cuestions arise.
The mixing ratio of 0.S/36,000 is a very large one.
The FPEIS should indicate how this is to be achieved, whether it is possible to get reasonably ccmplete and uniform mixing with this big a difference, and is range of the potential variaticns in concentration.
- Effluent from p:ocessing decontamination liquids by the evaporation / resin process.
The fate and transport characteristics of the licuid wasto will depend on the properties of the radioactivity contained.
The isotopes listed above are the main contaminan'ts; however, others are present and comprise a wide variety of chemical elements.
The different chemical elements would behave in different ways.
For example, if the radioactivity was in icnic or particulate form, what would determine where it would go?
If the radioactivity were part of the particulate fraction, it might sink to the river bottom and become part of the sediments.
This would not be a permanent sink and could, for example, be stirred up in a dredging operation.
Has the possible problem of a buildup of radioactive sediments been investigated?
In some cases, chemicals are more toxic to aquatic life than to humans.
Is the radioactivity in this case more toxic to humans or aquatic life?
Fish and other aquatic life are known to bioconcentrate metals and other toxic substances.
What are the biccentration rates for these radioisotopes being ingested by aquatic life -indigenous to the Susquehanna River?
What is the resulting human exposure from eating such fish?
8.
The FPEIS should correct the statements made in the DPEIS concerning EPA's activities in the following sections:
I.
Section 11.3 (a)
Effective 12/31/80, EPA will have 13 stations out to 5 miles.
(b)
Analyses are done at EPA's TMI Field Station, Middletown.
The Harrisburg setup was phased
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out in June 1980.
Sample and analysis frequency is now once per (c) week for the charcoal filters and 3 times per week for the particulate prefilters.
Both will be changed to once per week as soon as telemetered gamma monitors are installed.
(d)
The TLD dosimeter layout was changed the first week in October, 1980 to that given in Appendix D to EPA's Long Term Monitoring Plan, revision 2, to be provided to NRC shortly.
(e)
Weekly continuous compressed gas samples are taken for Kr-S4 analysis at Sainbridge, Goldsboro, Middletown, Hill Island, and the TMI Observation The Hill Island Station was pulled Center.
October 3, 1980 because of pending shut down of the marina where the boat is kept.
The Kr sampler at 3rinbridge will be moved to Yorkhaven Jan 1, 1980 when the Sainbridge station is shut down.
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. f)
As soon as the samplers are built and analysis
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arranged (approximately Dec. 1980) tritium in air samples will be taken at the sama stations as the nr samples.
(g)
EPA also collects and analyzes water samples as follows: (EPA does gamma spectroscopy, DER analyses for tritium, gross alpha and gross beta: weekly composites are analyzed for Strontium 89 and 90 au the Eastern Environmental Radiation Facility, EPA, Montgomery, Ala.)
(1)
TMI Outfall (All plant discharge, both units)
- daily, (2)
Lancaster Water Works intake - daily, (3)
City Island - (upstream river water) weekly, and (4)
Sediment pond, TMI (run off water) behind Unit.2 cooling tower.
There is a continuous gamma monitor on the 001 TMI outfall with a high-level alarm that automatically alerts EPA and DER to the presence of gamma activity in the water in excess of 1,000 pCi/l 137Cs (1/20 of permissible level).
(h)
EPA Press releases are now on a weekly basis on Friday.
II Section 11.5.3 Community Monitoring Program.
Most of the EPA recorders have been pulled back to the test site due to equipment Units remain shortages in the off-site monitoring program.
at Newberry, Fairview and West Donegal.
Reports are no longer issued on a daily basis.
III Appendix M This Appendix has been substantially revised and will be made available to the NRC shortly.
9.
The FPEIS should explain why, in spite of the fact that the decontamination is going to be done using processed water gentaining tritium at concentrations up to 0.98 uCi/cm, no =ention is made of tritium as an occupational hazard.
Perhaps this is factored into the doses given, but the specifics should be given more clearly.
Tritium is both an inhalation and immersion hazard, but the occupational fcse discussicns appear to be limited to the external dose.
Tritium is also omitted from several tables-in Section 6 where it should appear (cf Tables 6.4-5, 6.4-6, 6.5-1 through 6).
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10.
The FPEIS should correct the following items with re' gard to Kr-S5:
e..
(a)
Page 2-13, Sect 2.2.1.4.
Not all of the Kr-55 has been re=cved.
There is still potential for the release of =cre during water treatment and during the defueline. crerations.
(b)
Sect 6.1. Kr-85 =ay still be ec=ing frc= the
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primary coolant and the fuel rods.
If so, this should be stated and factored into cumulative impacts and inventories.
(c)
Sect 6.1.4 Should note the initial problems with the particulate alarm system, the cause thereof, and the resolution.
The presence of the IPA Onsite Cocrdinator in the control roc =
durin3 curc.in9 should be noted.
(d)
Table 6.1-2 and sect 6.1.6. Should include a comparison of the =ersured deses - EPA, Met Ed etc. - to the estimates presented.
It may be reassuring to the public to show how conservative the estimates being made actually are.
(e)
Sect 8.1.4.1 What about Kr-85 release?
(f)
Sect 8.1.5.2, 3rd pp. line 6.
If Kr-85 releases can vary by a. factor of 500 from the estimated 100 Ci, we have a real problem.
It is intended that the actual deses resulting frc= a given release will be within a facecr of 500 of the c.rediction.
The entire question of the isotope balance for Kr-85 is unclear.
It would be very helpful to state how much was present in the rods before the a :cident, how much was released in the accident and during the purging, and hcw much is left.
Taking the number of fuel assemblies (177) and the 320 Ci of Kr-85 per 8.2.4.2 ene could estimate about 56,000 Ci of Kr-55 in the reactor.
This may represent the activity that was present with all reds intact.
This should be clarified.
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entry under itbe4.3x10{g?
(g)
Table 10.1-4.
The 8.5 x 10 uCi.
l 85 may be in error.
Should not 11.
The FPEIS should clarify the discussion of accident scenarics.
The scenario en page 6-27 appears to indicate that the total exposure resulting frc= the accidental release of 500,000 gallons of water frc= storage over a two-hour period would be less than that frc= a planned release.
Co vcu mean to i=-1v. that the alternative of rapid discharge to r
.the river is prefe.able?
12.
The FPEIS should clarify the statements in the DPEIS that there are 51,000 Ci of Krypton-85 in the core.
There is no mer. tion of it being in the primary coolant.
13.
The FPEIS should include a discussion of the technical feasibility of ocean dumping of low-level radioactive wastes.
The current Ocean Dumping Regulations can be found in the Federal Recister of Jan 11, 1977 with the criteria for discosal in section 227.11.
We believe this is necessary to ' fulfill the mandate of NEPA for assessing all feasible alternatives, even though we recognize that, as a matter of policy, no permit has been issued by EPA to ocean dump radioactive waste at any level, and that there has been no ocean dumping of radioactive wastes since 1967.
Neither the Marine Protection, Research, and Sanctuaries Act (MPRSA) nor the Londen Cumping Convention (LDC) preclude the dumping of low-level radioactive wastes; they prohibit the ocean du= cine of hich-level radioactive wastes.
The designation of Sis 5osal sites requires an application to EPA with the acclicant responsible for time consuming, expensive studies,
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and for monitoring to assure selection of an environmentally sound al'ternative.
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