ML20008E350

Comments on Draft Programmatic EIS Re TMI Decontamination Program.Radioactive Water Should Be Promptly Processed to Avoid Potential Accidental Release of Highly Contaminated Water Into Chesapeake Bay

ML20008E350
Person / Time
Site:	Crane
Issue date:	09/30/1980
From:	Kelly N CHESAPEAKE BAY FOUNDATION
To:	Snyder B Office of Nuclear Reactor Regulation
Shared Package
ML20008E337	List: ML20008E340 ML20008E342 ML20008E343 ML20008E344 ML20008E348 ML20008E350 ML20008E351 ML20008E352
References
RTR-NUREG-0683, RTR-NUREG-683 NUDOCS 8010240616
Download: ML20008E350 (7)

Text

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j Chesapeake Bay Foundation G

~n-gS "Citi:er Representation. Environmental Education. Land Presenation" C

162 PRINCE GEORGE STREET, * " Tile CilURCll"

• ANNAPOLIS. MARYLAND 21401 301 268 8816 (Annapolis) 269 0481 (Balto.) 2612350 (Wash., D.C.)

O/Arrs September 30, 1980 C. TROWBRIDGE STRONG Freuden t GODFREY A. ROCKEFELLER 87ce P esident ROBERT St.llEWES. 3rd Mr. Bernard Snyder, Program Director 9

JA !ES E11PLETON Office of Nuclear Reactor Regulation U.S.

- Nuclear Regulatory Commission E.u OfNio Trusters Washington, D.C.

20555 GOVERNOR JOi!N N. DALTON R. C\\

G1 Re:

Draf t Programmatic Environmental Impact Stud t StateDent related to decontamination and E.T. BUCli ANAN E>nnhsten Charte, J. FA RKE R CROSS.JR.. Norfolk CAsprrr disposal of radioactive Wastes resulting fl\\YDEN ROSS. CLUNIS. l'ork Chsprer from March 28, 1979 accident Three Mile

'ttssEtt C. SCOTT. Richmond Cacprer Island Nuclear Station, Unit 2 (PEIS) flA S. ADKINS

Dear Mr. Snyder:

• GEORGE E. B AHEN.JR.

JOHN \\1. BLONO51 The Chesapeake Bay Foundation is a non-profit,

%IkQE[i(R private Conservation organization with over 6,000 3

R O VICTOR L. CRAWFORD members.

Our basic purpose is the protection of L. EtcENE CRONIN Chesapeake Bay water quality and natural resources.

T. MA R511 ALL DCER,J R.

CLAYTON EWING CHARLE5 5. GARLAND.JR.

The Chesapeake Bay is our nation's most ALBERI F.GOETZE.JR.

productive body of Water and its seafood. resources ss.

5' $NCR are most important to this country.

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, giL y D. H EYWA RD ll AMILTON, J R.

k lLLLAM J. ll A RGIS.J R.

The Susquehanna River upon which the TMI Unit f

2 is located is the single most important contrib-

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C. A. roRTER HOrKINs utor of fresh water to the Bay, supplying 80% of the ERNEST W.JENNES fresh water to the upper Bay and 50-60% to the E..* OLK KELLAM.JR.

xclUs j. K ELLAM entire Bay.

Thus, the decontamination activities CH ARLEi V. B. LaMOTTE at TMI are of vital interest to the Chesapeake Bay

]Od!E \\a Foundation and the citizens of'the State of Maryland 5 R N

CHARLES McC. MAllilAS JO5Ent a McL uN The PEIS which was prepared by the Nuclear I.NEN,. bt LLEN. !!

Regulatory Commission (NRC) is important as an k:Ltto: B. ut Lt ws analysis of therotential impact of those decontaminati L. CLEMINT NINOh activites.

However, we believe that there are

)).[550N several deficiencies in it and also note that it 7

TRU3 TAN T. 5EA\\ TANS presents a* series of alternatives, rather than a ARTHUR W. SilERh 00D o.l. a n.

LEONIE L.SDIMONS WILBUR E. $DIMONS.J R.

In order to guide the NRC in its review cf ROBERT L. sTEVENs DOUGLA5 WARNER.J R.

the varicus alt 3rnatives, we believe that certain Q.y *-].]Eyg criteria should be used.

It is our position that

!J!Jr.McRATii e 4 0240WG

Page Two Mr. Bernard Snyder the following criteria are mosf, appropriate:

1.

Clean up should proceed as expeditiously'as possible consistent with. proper

• planning.

For example, we are most anxious that the processing and removal of sump water begin in order to avoid additional damage to equipment essential for safe operation and control of the reactor.

2.

Adequate planning and impact assessment must be carried out to ensure that the safest and most effective procedures are chosen.

This may necessitate further preparation of impact statements if unanticipated conditions occur which require actions which have not been addressed in this PEIS.

3.

The accident-generated radioactive water should be promptly processed to remove most of its radioactivity in order to avoid the. potential accidental release of this highly

. contaminated water to the river.

4.

Decont mination procedures which would minimize the amount of liquid waste generated should be given

' ~ ~ " '

preference.

Processed water should be re-used as.much as possible in the cleanup activities.

5.

The processed accident water should not be discharged

'into the Susquehanna River since other alternatives are available and the potential impact on the marketability

.c of Bay seafood could be serious.

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Radioactive waste generated by the accident and sdbsequent eN cleanup activities must be promptly removed from 'the island

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so that TMI does not become our nation's first long-term high level waste disposal site.

Its location on an island 4.

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in the middle of a river which supplies 80% of the fresh

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water of the upper Chesapeake Bay is not appropriate for

• 'e s such disposal.

We urge that the NRC work with DOE to establish an appropriate disposal site for this material.

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In anticipation of waste transportation and disposal l

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problems, we urge the NRC when selecting procedures for 4-l

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cleanup, to chore these which generate minimum arounts of i

-e wastes which are at the same time, in form and level of radioactivity and most readily transportable and suitable

'for long-term disposal.

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Methods should be chosen which would keep levels of radiation,

to workers and the public to the lowest achievable levels.

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.i Page Three Mr. Bernard Snyder Rega. Tiro the Draft Programmatic Environmental Impact Statement it.

we have both general and specific comments.

It is sr special concern t[ us that the PEIS presents a number of alternatives but does not recommend a plan.

Consequently the public has no assurance of the procedures which will be followed or even of the criteria which the NRC may use in considering plans proposed by Metropolitan Edison.

We therefore request at this time that the public be given further opportunity to comment when actual proposals are made by Metropolitan Edison for cleanup and disposal activities.

A serious deficiency in the PEIS is the lack of cost estimates for the various alternatives.

Although we don't want to have decisions made which would provide less adequate treatment in order to save money, there may be times when such information might help in a choice between otherwise equal alternatives.

Particularly, we beleive that a decision regarding the feasibility of restarting Unit 2 should be based to some extent on the relative costs of cleanup to protect all the equipment for restart purposes, on the one hand, versus simpler and less expensive treatment that could be used if the equipment were going to be scrapped.

Since the Chesapeake' Bay Foundatlun is particularly concerned about the~ potential release of accident generated processed water to the Susquehanna River, we will confine our most detailed comments on the PEIS to that area.

We believe that the PEIS is deficient or erroneous in several instances:

1.

Estimates of the concentration and distribution of the constituents in the processed water are depen' dent on factors which are unknown at the present time, including the condition of the core and primary loop.

Yet no best case and worst case conditions are presented regarding this.

2.

Total radioactivity which would be released to the river as presented in Table 10.1-2 does not correspond with data in Table 6.3-5 regarding the volume of water and concentration of the radioactive constituents.

In fact, Table 10.1-2 shows a total of 2.5 to 3 Ci of radionuclides from the processing of reactor building sump water, whereas a calculation based on the effluent volume, concentration and 1200 dilution factor shows a total of nearly 3,700 curies to be released, most of which is tritium.

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Mr.~ Bernard'Snyder noted that.the average amount of tritium It shoul'd be released;from a normal' generating unit of this sizeLis 1

3.-

If the total amount of tritium in 400-500 curies / year.

it would take

.the processed water is'3700 curies, approximately nine years to release it at that rate, instead of the one' year that is being proposed.

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Calculations of the expected dosages to fish from the release of the processed water are presented in Table 4.-

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Assumed concentration factors are:

I 6.3-18.

i tritium 1:1 Csl37, Csl34 3000:1

.j Sr90,Sr89 500:1-L I

yet the' rationals for such factors are not presented in

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A number.of factors which will cause those concentration factors to vary are not.even mentioned, salin the PEIS.

such as temperature, L

potassium, etc.

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A number of studies have been done which discuss s p

variation in concentration f actors with many values being 5.

I significantly higher than those assumed by the PEIS.to 40,0 Concentrations ~ugj d'up to 30,000 times for strontium pter

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low in potassium-an There is even uncertainty regarding have.been documented.

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the potential,for bioaccumulation of tritium, most scientists believe that~ tritium does not bioaccumulat

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The potential impact of these radionuclides is barely Yet a recent report states, 6.

mentioned in'the PEIS.

"Because a large percentage of the cesium accumul'ated by

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fishes lodges in edible muscle tissue, sport and commerc fisheries' suspected to b be carefully ~ monitored".gj Strontium, on the other hand;

_The same report states,

-concentrates-in the bony portions."Because of this bone-s i

" fishes It goes on to state that, L

extremely dangerous."

such as sardines which are consumed in.their entirety and soft waters represent the greatest risk to humans, contaminated by th Since the Susquehanna.is for isotopic bioaccumulation".-

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l a drinking ' water source ius well as an important area for including shad which are

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sport'and' commercial fisheries, the disposal of often' eaten bones and'all, we feel that f

water containing these co'nstituents into this river is

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inappropriate and'the potential impact has=been under-

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estimated'in~the PEIS.

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1 Page Five j

Mr. Bernard Snyder its impact on the incompletely The hydrology of the river and distribution of radioactive isotopes is iver Estimates of concentrations in the r 7

mixing' during average low flows,are islands t addressed.

assume completeYet since therethe complete river is not available (p. 6-19).

6-24, fish Three Mile Island, As was noted on p.hich mixing was a mixing zone.

could be exposed to conditions in w20 times higher i

fc not complete, causing doses up to 6.3-18 than those presented in Table he' Susquehanna

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i ioned.

Sediment deposition processes with n tcomplex, yet the

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River are quiteBecause of dams downstream, sedimen The rather concentrated areas. absorbed ont deposited in certain i

ts" being crggted tendency of cesium to be

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creates the likelihood of " hot spo

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river and on the Susquehanna Flats._ incorrec water within the in in the believe that the PEISlarge percentage of the cesium will done on behavior of column for some time.

ll of the cesium t97 River and studies that have been cesium,we would expect virtually a i hin four days.-

have droppad out with the sediment w tWe a ts would cause i

i a sudden release and resuspens on t

sediments.

f processed water again stress that the release o t could have a l

i of Bay seafood, to the river is undesirable sincesubstantial impa We must 9

i which is worth millions of dollarsfor thousands of individ l

and provides employment for disposition of the water.bilized

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alternatives exist We would recommend that it be immoeventua l as is all the Viable 10.-

In its immobilized state it wouldan

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other low level waste.

t not represent a radiolrgical threaa low prio l

apparent inability of the federawaste disposal site is a seriou PEIS.

Yet its high-level radioactive 11.

The which seems to be avoided in the i l if the high level waste is to be a

We believe that the seriou problem

~is essent a resolutionfrom the island.

i Department of of this problem,should be fully expois given removed h

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"y Page Six Mr. Bernard Snyder 4

In summary, we feel that the PEIS has inadequately addressed certain areas regarding the potential impact of the release of processed accident water and particularly the impact of such an action on the seafood indsutry.

It also needs to address the ultimate waste disposal problem.

And finally, criteria must be developed to assist in the selection of appropri..e decontamination -

procedures.

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Sincerely, ffigt ;- _ - - ~

I' Nancy G. /

Kelly Senior Staff Biolo ist NGK/kaw 4

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FOOTNOTES 1.Preston, A.-D.F. Jefferies, and J.W.R.

Dutton.

1967.

The concentrations of cesium-137 and strontium-90 in the flesh of brown trout taken from rivers and lakes in the British Isles between 1961 and 1966: the variables in determining the concentrations and'their use in radiological assessments.

Water Res. 1(7) : 475-496.

j.

2 Krumholz, _L.A.~1956.

Observations on the fish population of a lake contaminated by radioactive wastes.

Bull Am. Mus. Nat.

Hist. 110(4): 277-368.

3 Bond, V.P.

Evaluation of potential hazards from tritiated water.

Brookhaven National Laboratory, p. 287-299.

4 Phillips, G.R.

and R.C.

Russo.

1978.

Metal bioaccumulation in fishes and aquatic invertebrates: A literature review.

Environmental Research Labrratory.

Office of Research and i

e Development, U.S.

Environnental Protection Agency, p.21.

4 5

Ibid.,p. 58,59.

6 Troup, B.N.

and 0.P.

Bricker.

1975.

"Progesses affecting the transport of materials from continents to oceans", in Marine Chemistry in the Coastal Environment.

American Chemical Society, p.

143-144 7 Phillips and Russo, p.

20.

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