ML20003B044
| ML20003B044 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/04/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| References | |
| LL2-81-0009, LL2-81-9, NUDOCS 8102100263 | |
| Download: ML20003B044 (3) | |
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Metropolitan Edison Company Post Of fice Box 480 II Middletown, Pennsylvania 17057 i
Writer's Direct Dial Nuinber February 4, 1981 LL2-81-0009 TM1 Program Office Attn:
Dr. B. J. Snyder, Program Director U. S. Nuclear Regulatory CoLmission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No.
DPR-73 Docket No. 50-320 Programmatic Environmental Impact Statement In response to your letter dated November 26, 1980, we would offer the following comments:
1.
Comt ntors Dr. A. H. Barbas and Mr. S. Sylvester (November 19, 1980, expressed concern with respect to the adequacy of the Environmental Monitoring Prograa around Three Mile Island.
Specifically they question the response to short-term releases to the environment, inadequate monitoring of ground and surface water, and aquatic biota.
We would like to take this opportunity to reaff.frm our position that a most complete and extensive monitoring program has bean in effect around TMI for some time. As part of this program, fifteen surface and drinking water sampling locations are routinely monitored both upstream and downstream of TMI.
Samples are collected on a continuous basis throughout the year thereby permitting assessment of the Susquehanna under all conditions.
Integrated into the waterborne pathway are sampling of sediments, aquatic vegetation, and fish species. Flexibility inherent in the program permits increase in sampling locations and frequencies as. conditions dictate. The groundwater monitor-ing program around Unit 2 is extensive with fifteen monitoring wells that are sampled and analyzed on a weekly basis.
4 With respect to monitoring capabilities for short-term releases,
_a computer model specific to the site and utilizing real-time c)
[heteorological data,.p'rovides the means of plume tracking and
- 9 (ldoseprojections. Extensive fixed monitoring etations and the c.:
Uq pyse of mobile monitoring teams, if needed, provide an inter-h [,
E-f(active method of ensuring. proper assessment of any release Qf(
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$10 S ig - Metropofitan Edison Company is a Member of the Genera! Pubhc Ut hties System
3 Dr. B. J. Snyder LL2-81-0009 2.
The November 13, 1980 transmittal by Pennsylvania Department of Environmental Resources (DER) presents a few points we would comment on.
a.
With respect to the release of airborne particulates through the use of EPICOR II we would not anticipate this to be a source of concern.
EPICOR II is an ion exchange process and in itself would not generate particulates. The particulates from "more complex" operations deal with the generation and controls of airborne species and should thereby provide the maximum values anticipated.
b.
The apparent lack of detail on dases to individual organs is based in the primary source cf dose i.e. tritium and immersion dose.
Consequently, the whole body becomes the critical organ and is emphasized.
Should other isotopes be released which causes another organ (other than the whole body) to become of critical importance then this would be considered and reflected in the cancer fatalities which would be even lower as suggested in their transmittal.
The use of the 5 x 10-3 sec/m3 dispersion value is conservative and c.
may la actuality be lower depending upon meteorological conditions at the time of a release, d.
The annual average dispersion factor is used since it represents conditions most likely to be found near the site in the event of a release.
j e.
We would concur with the comment on potential recriticality of the core.
However, regardless of the rational used by the PEIS timely removal of the damaged fuel to safe storage is of paramount importance.
f.
With respect to decay heat valves, we take exception to both the PEIS and PaDER. To say the valves'must remain operative in order to maintain safe cooling is wrong.
Safe cooling can be maintained without an operational mini decay heat removal system (KDHRS).
g.
There is no need to state a specific reason for operation of the MDHR system or not operating the in-plant decay heat system.
The decision to use either of these systems should be based on considerations of all operational constraints that exist at the tirt a decision is required. The reason the MDHR system was installed is to provide an option that would minimize the contamination, both intermal and external, and direct radiation that would result from operation of the in-plant system.
h.
The SDS as currantly designed will have particulate filters. The vents will eventually be handled by the Auxiliary and fuel Handling Building ventilation system.
i.
The Cs-137 values provided by the PEIS for airborne releases due to water processing are orders of magnitude less than MPC per 10 CFR 20.
In any event, we prefer the conservatively highest assumption for which the environmental impact is acceptable.
e.
Dr. B. J. Snyder LL2-81-1009 With respect to the liquid release comment, we have previously commented that process streams do not go directly to discharge.
Therefore a 30 gpm discharge rate is unlikely. The distharge rate at anytime will be consistent with all appropriate regulations.
- j. 'With respect to the krypton inventory, the PEIS refers to a fuel rod as opposed to the fuel assembly assumed by the commentor.
4 k.
Nonradioactive water sludges are not rel..ed to Unit II recovery and thus should not be included in the Pn S.
1.
CPU concurs with commentor with respect to analysis of potential accidents resulting from natural calamities i.e. tornados, floods, etc. on waste storage buildings not qualified for these design events.
We believe such an analysis would be useful if it addressed the question of maximum allowable storage without significant environmental
- impacts, The amounts of radionuclides permitted to be discharged in the m.
processed waters are low.
GPU feels that the environmental impact should be assessed for the regulatory limits-as well as projections of the processed water quality.
3.
GPU concurs with the U.S. Department of the Interior. (October. 8,.1980) in 'that the analysis of leakage.of the reactor building sump water into the groundwater and subsequent percolation into the river is not discussed in sufficient detail.
The analysis need to be explained in greater detail since in its present form, leads to.the conclusion i
that there is little incentive to proceed deliberately with cleaning i
up the sump.
j I hope you will' find the information contained.herein to be of value and germane to the review process.
l Sincerely,
~
(
. K. Hovey l
Vice-President and-l Director,'TMI-2 GKH:GGB:djb
-L. Barrett,. Deputy Program Director-
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