ML20210P848

Comments on Draft Suppl 2 to Programmatic EIS for Disposal of Radioactively Contaminated Water Stored at Site.No Existing or Proposed Corps of Engineers Projects Would Be Affected by Work Described in Draft Suppl 2

ML20210P848
Person / Time
Site:	Three Mile Island
Issue date:	02/06/1987
From:	Jerrica Johnson ARMY, DEPT. OF, CORPS OF ENGINEERS
To:	Travers W Office of Nuclear Reactor Regulation
References
NUDOCS 8702170035
Download: ML20210P848 (3)

Text

-

- DEPARTMENT OF THE ARMY S ALTIM OR E DISTRICT, CORPS Olr ENGIN E ER S P.O. BOX 1795 l .-

E ALTIM O R E. MARYLAND 21203-1795 atPLY TO ATTENTION OFI 6 February 1987 Planning Division Mr. William D. Travers, Director TMI-2 Cleanup Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington,-D.C. 20555

Dear Mr. Travers:

Reference your letter of 29 December 1986, regarding the review of the Draft Supplement 2 to the Programmatic Environmental Impact Statement (PEIS) for disposal.of radioactively contaminated water stored at the Three Mile Island Nuclear Station site. The comments provided below address the

, Corps of Engineers areas of concern, including direct and indirect. impacts on Corps of Engineers existing and/or proposed projects, flood control hazard potentials, and permit requirements under Section 404 of the Cleen Water Act.

There are no existing or proposed Corps of Engineers projects that'would be affected by the work described in the Draft Supplement 2 to the PEIS.

The PEIS should include documentation of the effects on the flood plain and compliance with Federal, State, and local flood plain. regulations, as appropriate.

Three Mile Island Nuclear Station, Unit 2, is located entirely within the boundaries of the 500-year flood plain. The PEIS does not address Executive Order (E.O.) 11988, Flood Plain Management, dated 24 May 1977, which is applicable to this review as several of the alternative disposal. solutions occur on the

( flood plain. In accordance with the U.S. Water Resources l Council " Flood Plain Management Guidelines For Implementing Executive Order 11988", (43FR 6030), 10 February 1978, the proposed actions may be considered critical such that even'a

slight chance of flooding would be too great. The document must evaluate alternatives with respect to E.O. 11988 and demonstrate that they have been designed to minimize adverse effects on the flood plain. If the selected alternative is to be located in the flood plain, it must be demonstrated to be the only practicable alternative.

l I

t 8702170035 870206 ADOCK 05000320 00 Il PDR D PDR Il0 L >

a .

Each of the 10 alternative disposal methods were reviewed to assess potential impacts on the flood plain. Those alternatives which include total or partial on-site storage and/or treatment at.Three Mile Island are subject to flood hazards which could reintroduce the contaminated material into the environment. The alternatives known to be susceptible to flood hazard are:

Alternative #1 Evaporation, solidification of bottoms, disposal at a licensed burial site.

Alternative #2 Evaporation, solidification of bottoms, and retention on-site.

Alternative #6 Permanent onsite storage of solidified waste.

Alternative #8 Long-term discharge into the Susquehanna River.

Alternative #9 Short-term discharge into the Susquehanna River.

Alternative #10 Liquid storage in tanks at the Three Mile Island site.

The risk of flood' hazard is minimized by those alternatives which minimize the amount of time materials are stored on-site.

The-risk of reintroducing hazardous materials into the environment can also be minimized by adopting flood resistant-design and construction methods for containers.

The alternatives listed below are not located at Three Mile Island, are not within the Baltimore District, and cannot be-judged for susceptibility to flood hazards.

Alternative-#3 Off-site evaporation at the U.S.

Department of Energy (DOE)

Nevada Test Site.

Alternative #4 Deep-well injection at the DOE's Nevada Test Site.-

Alternative #5 Crib Disposal at the DOE's site in Hanford, Washington.

Alternative #7 Solidification and disposal at a commercial low-level waste site.

Under'Section 404'of the Clean. Water Act, Department of the Army. authorization is required prior,to-any discharge of dredged -

or fill material into waters of the United States, including

~

their associated wetlands. Since the proposed work.does not involve work or placement of fill in waters of.the. United' States, Department of the Army authorization is not required.

If there are any questions concerning this matter, feel free-

.to call me or my action officer, Mr. Larry Lower,-at (301) 962-4710.

Sincerely, b- A F::

James F. Johnson Chief, Planning Division

, , . -