ML20210P943
| ML20210P943 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/21/1987 |
| From: | NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2 |
| To: | |
| References | |
| NACTMI, NUDOCS 8702170055 | |
| Download: ML20210P943 (155) | |
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UN11ED STATES NUCLEAR REGULATORY COMMISSION tP
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IN THE MATTER OF: DOCKET NO:
A h ADVISORY PANEL FOR THE DECONTAMINATION OF TMI, UNIT 2 4
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LOCATION: LANCASTER, PA PAGES: 1 - 121 DATE* WEDNESDAY, JANUARY 21, 1987 l
i ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Cacitoi Street Washington, D.C. 20001 8702170055 870121 ADOCK 0500 0 l gDR NATIONWIDE COVERAGE l
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[ Advisory Panel for the Decontamination of TMI-2 Stenographic record of hearing held at 201 North Duke Street, Council Chambers, Lancaster, Pennsylvania, Wednesday January 21, 1987 7:00 p.m. - 10:00 p.m.
EDD21 22Hb212.91229D%
Arthur Morris - Chairperson Michael Masnik Thomas Smithgall Joel Roth Nici Hald Anne Trunk Gordon Robinson Kenneth Miller Thomas Gerusky John Leutzelschwab
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2 UNITED STATES NUCLEAR REGULATORY COMISSION ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND UNIT 2 Agenda for the January 21, 1987 Meeting in Lancaster, PA b
Minutes Chairman's Opening Remarks - A. Morris 5 1.
15
- 2. Status Report on Defueling - GPUNC 5
- 3. E. Epstein 40 4 .' Supplement 2 to the PEIS - NRC 10 S. Break 10
- 6. Supplement 2 to the PEIS continued - NRC 5
- 7. E. Epstein 10
- 8. F. Skolnick 5
- 9. B. Tompkins -
20
- 10. Public Coment
- 11. Discussion of Topics for the February '
26 Commission 10 Meeting I
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. 3 1 THE CHAIRMAN: Good evening, ladies 2 and gentleman. I would like to, if I could at 3 this time, call the meeting of the panel to 4 order.
5 Just a couple of preliminary 6 comments ~. One is that I did hear from both Mr.
7 Rice and Joe DiNunno that neither one could 8 attend the meeting. And I don't remember from 9 the last meeting, but there were one or two who 10 ~ indicated they could not attend as well. There 11 may be a good reason why all four could not 12 attend.
13 Two items I would like to mention -
14 are, one for the panel, February 26 is the date 15 that has been selected for us to meet with the 16 Commissioners in Washington at 11 a.m.,
IA hopefully with a premeeting at 10:15 a.m.
18 And information for the public is 19 that copies of the supplements to the PEIS are 20 availab]e if you would like one. We will try 21 to limit it to one per person so there are 22 enough to go around.
23 With that said, we can move on to the
- 24 next item of business, which is the status i
25 report of the defueling by GPU. If they could
4 1 come forward to the table to do that.
y(_ I' don't know if everyone has a copy 2
3 of~ the agenda for tonight or not; if not, let 4 me.tell you what it will be. Following the 5' status of the defueling by GPU, which is listed 6 for'15 minutes, Eric Epstein has asked for time 7 on the agenda on two occasions. Five minutes 8 is provided following GPU's presentation for
'9 Eric. Is he here?
10 (Indication he is not present.)
11 If you would see him come in while 12 this presentation is going on, p] ease alert him
( 13 that he would be the next on for five minutes.
14 We would then have the supplement 2 15 to the PEIS, which is initially a 40-minute 16 presentation. We will then break. We would
'17 continue the presentation by the NRC on the 18 supplement for about ten minutes and then begin 19 the citizen part of the meeti.ng.
20 Eric Epstein had again asked for 21 five minutes on that. Francis Skolnick 22 requested ten minutes and Betty Tompkins, five 23 minutes. Then public comments, with finally a I 24 discussion of topics the panel feels we should
(
25 bring up on February 26.
5 1 With that said, Frank?
12 MR. STANDERFER: I have good things 3 to report tonight. It appears that we solved
'4 . the problem of operating our filters at the 5' plant. '
6 We successfully ran the first filter 7 with the new regime, which I will describe, for 8 half a million gallons. The current filter 9 looks like we are going to get a million 10 gallons out of it. And this is the way the 11 system was designed to operate. ,
12 As you know we have been suffering f .13 with poor water clarity for a year. And we I 14 have gone through a number of different 15 approaches to getting these filters to work, I 16 and they are working now.
17 For the first time the defuelers had 18 good water clarity whenever they wanted it for 19 the past week. And we put a press release out 20 to that effect. It didn't get front page 21 coverage like the problems get, but we are '
22 really happy about that. Let me describe a -
23 little bit about how that works.
' 24 This is a schematic of the system;
- 25. the reactor vessel, the water, and its core.
. . . . . _._________.______________________J
6 p l - Water is taken from the reactor vessel, put
}. 2
- t h r o'u g h' f i l t e r s , and sent back to the reactor.
- 3. 3:e also can-take water and put it through ion 4 exchangers to remove the radioactivity. These 5 filters plugged with the fine particles that 6 were present.
7 The first thing we did last spring 8 was add an addition system, which is called a 9 body feed system. This is what one of the 10 filter cartridges look like. There are.187 of 11 these in one of our big filters assemblies.
12 This system here right was the f 13 addition of diatomaceous earth, the same kind 14 of thing people have in their swimming pool 15 filters. This is a particular fine material
.16 called super cell. Here is some of that mixed 17 with water. And when we made this addition, .i t
~
18- really didn't help very much.
19 So the next approach was to find a 20- coagulant, a long-chained polymerized .
- 21 organic -- just polar parts in the molecules.
22 We organically ended up with a commercial 23 product we get from Betz Chemical called Betz 24- 1182.
25 And with the addition of this I
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7 I c o a g'u l a n t that collects these small particles
'2 ' and the body feed, which provides additional 3 filter surface on the filters, the filters are
- 4 wor' king well.
'5 MR.-GERUSKY: What' is the particle 6' size of the material you are trying to filter?
7 MR. STANDERFER: The particle size, 8 of. course, ranges everything from one-tenth of
.9 a micron up to rocks, the whole range. And 10 ' these half micron filters were plugging on the 11 small material.
12 These filters cost $70,000 a piece.
I 13 So it wasn't very practical to use them the way 14 they were plugging and use one up in a day.
15 This is a diagram of pressure drop, 16 how much force it is to force water through the
~17 filter against water that has been processed.
18 And when the filters were plugging, they would 19 go up to the 60 pound limit on'the filter after 20 processing about 30,000 to 40,000 gallons. And[
21 we needed about one million gallons through the 22 filters.
23 And finally we got this set up to use i 24 the coagulant and the body feed. The first .
(
'25 filter we started running on the 8th of ,
1 8
l' January. It ran for half a million gallons.
I. 2 Based on how it ran, we adjusted the 3' concentration of these additions. And we 4 expect on the second filter to get one million 5 gallons.
6 So I think, unless something else 7 changes in this area, we will be able to 8 produce good water clarity for the rest of the 9 defueling program, which certainly is going to B
10 allow that to go easier and better.
11 Next on defueling we a,1 s o made 12 significant progress since the last meeting. I
( 13 have to apologize for this slide. In the Xerox 14 machine it got discolorations.
15 As you remember, in October and -
16 November we drilled the center section of the 17 core, which was the hard layer, which was 18 difficult to load. And when we back in around 19 Thanksgiving, we were unable to load that the 20 way we hoped it 'would.
21 And when I talked to you on the 9th 22 o f' December, we were here at 56,000 pounds l 23 loaded to d a't e . Most of that was loaded in the 24 spring of 1986.
25 On the 20th of December we finally 1
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9 1 got a hole _ started. And since the 20th of
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2 D e c e m b e r ,- we loaded 16,000 pounds. This curve
- 3. is posted when the fuel is transferred to the 4 . fuel transfer canal. As of this morning, we 5 had 68,788 pounds transferred to the refueling 6 canal. We have'three cans full in the i
7 defueling system itself, so we have actually 8 loaded about 72,500 pounds, which is 25 percent 1-l 9 of the core. This was 19 percent of the core.
i 10 We have made five fuel shipments off f-f 11 the island. We have shipped 40,000 pounds off 12 the island. And these are the kind of rates we
- f 13 had hoped to get in the Thanksgiving time l 14 frame. But we are now defueling at that rate 15 and that is the rate we have to defuel at to 16 finish on schedule.
, 17 Just to review the defueling 18 schedule, this is the schedule I showed you in 19 October. That said that we would, by the 20 middle of February, finish removing fuel from 21 this hard layer area and we would start to 22 remove the partial fuel assemblier in the 23 middle of February. We are currently on that i 24 schedule.
25 So at the present time, I have got no
I i
10 fl~ reason'to change the schedule. We are still
. , .d- ~
2 projecting the finishing of defueling at the 3 end of the year. It will be tight and I am not 4 making any promises, but we are defueling at 5 the kind of rates we wanted to achieve.
6 I guess the last comments I want to 7- make are on the principal topic tonight of 8 water disposal. And I would like to reiterate 9 that we were sensitive to the interests of the 10 people in the central Pennsylvania area as we 11 put our proposal together last summer.
12 Let me read --
to set the record
[ 13 straight, let me read a comment I saw in one of 14 the papers. "GPU officials wi)1 be advocating 15 those means which are least financially 16 burdensome to them." And I want to say that is 17 not correct.
18 In fact, we proposed the evaporation 19 technique, which is the most expensive. It is 20 the most difficult for us to accommodate, but 21 we believed it was the best all-around solution -
22 for us and for the area.
23 It does not make a long-term waste
/ 24 disposal site of the TMI site, and it does not
(
25 discharge waste into surface waters in the
11 1 ~Susquehanna River. So again, we really believe k 2 we made the right recommendation. It is not 3 the easiest for us to accommodate and we stay 4 with that.
5 Finally, we will be making our 6 comments to the NRC on their draft, as will the 7 rest of the public. And one of the things that 8 we will be providing them is our most recent 9 water analysis of the waters that will be 10 discharged.
11 We just now are completing a number 12 of new water analyses which are being completed l(
l
'13 in compliance with the Regulation 10 CPR 61, l 14 which deals with waste going to burial grounds.
15 And those analyses will be provided to the NRC 16 for there inclusion in the final issue of their
~
17 PEIS.
18 The analyses do not change the 19 principal isotopes of interest, which is 20 tritium or strontium-90, nor does it change our 21 recommendation to evaporate water.
22 With that I will be glad to answer 23 questions on this material.
/ 24 THE CHAIRMAN: Does the panel at this .
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25 point have any questions of Frank's ,
4 m
12.
1- presentation, realizing that the whole rest of I 2 the presentation will be provided by the NRC on 3- the water issue on their Supplemental EIS?
4 I do want to say I think it is good 5 news that you solved the filtration problem.
6 You feel it may be tight but you feel you are 7~ back on schedule with the removal of the fuel.
8 That is good news.
9 MR. STANDERFER: There are several of 10 the coagulants and we tried 40. We had one 11 that worked well last fall; and after we 12 processed water through the purification
( 13 itself, we changed the chemistry and it didn't 14 work. We had to find another, and this is the 15 second.
16 I think we have the answer for now, ,
17 although we maybe changing it again during the 18 year.
19 MR. SMITHGALL: What have you done S
20 that allowed to you increase your loading ,
21 capacity? Is it because of the water clarity 22 or because of other things?
23 MR. STANDERFER: It was similar to i 24 what happened last spring. This material packs ;
(
25 density. It is like people familiar with clay l
e 13 1- soils, trying to dig in your garden in clay, h 2 Once we got a hole started and the sides 3 started to cave in, then we were able to load 4 the material.
5 Next week we have a new air lift
~6 vacuum system we will be deploying, which can 7 load the fi,nes that are in the corners and so 8 forth. And we expect that we will load at high 9 rates.
10 So up to now it was just a matter of 11 getting started and whether this new tool will 12 get us high rates where the spade bucket is no
( 13 longer effective.
14 THE CHAIRMAN: Any other panel 15 member? .
16 (No response.)
17 Eric, you are on or you can save your 18 five minutes and take ten minutes late .
19 MR. EPSTEIN: I would like to take 20 ten minutes later.
21 THE CHAIRMAN: This will give you 22 time.
23 MR. TRAVERS: I am Bill Travers and I
( 24 am Director of NRC. .We are here to talk, as
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25 you know, about the NRC staff's recently issued
- i..
14
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~1 ' draft Supplement 2 to the Programmatic 2 Environmental Impact Statement.
3 Before I jump into that, let me 4 inthoduce Linda Munson. Mrs. Munson is the 5 program manager out at Pacific Northwest 6 Laboratory where we contracted most of the 7 work. Linda is going to be assisting me this 8 evening. She will be making part of the 9 presentation.
~10 It was projected that there be about
'11 2 million gallons of accident-generated water 12' which will need to be disposed of before the cleanup is completed. Since the accident, this
'( 13 14 water has been stored and has been used in 15 various cleanup processes inside the plant.
16 There was initially and immediately 17 right after the accident a lot of public 18 concern on the part of the City of Lancaster 19 and others as to the possiblity that this water 20 might be discharging into the Susquehanna 21 River.
22 As a result of that, the NRC entered 23 into an agreement with the City of Lancaster in 24 May of 1979. That agreement specifically 25, prohibited discharge until the issue could be
15 1 addressed in full. And that agreement also k 2' offered the City of Lancaster and other parties 3 to the agreement an opportunity to meet with 4 the. Commission prior to any Commission approval 5 to discharge that water into the Susquehanna 6 River.
7 In March of 1981 the NRC staff issued 8 its Programmatic Environmental Impact Statement 9 on the cleanup. It was intended to provide a 10 very comprehensive estimate of environmental 11 impacts that could result from all of the 12 projected cleanup activities that occurred
( 13 during the entire process.
14 And that Environment Impact Statement 15 did address the disposal of accident-generated 16 water. A number of alternatives were assessed 17 and environmental impacts were reviewed. He lh are now in the process of summarizing for you 19 what we have done most recently in updating 20 that information.
21 Basically the decision to supplement 22 the Programmatic Environmental Impact Statement 23 was based on a number of factors. First off, 24 we have much more specific information now t h a :2
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25 we had back in '81 about the water, about
16
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. 'l < alternatives that might be used to dispose of b 2 'i t .
3 In August of last year, late August, 4 we received from GPU Nuclear a specific 5 proposal for how they would propose to get rid 6 of this water. And lastly, and probably most 7 importantly, continuing public interest -
8 prompted to us update and provide for comment 9 an environmental impact supplement on this 10 issue.
11 Let me start by saying it is not a 12 very good slide, but I think I can speak to the
] 13 principal contaminants that make up the concern 14 associated with disposal of this water.
15 Basically, as I mentioned before, 16 there is approximately 2 million gallons of the .
17 water that it is estimated will ultimately 18 require disposition. There are three p r i n c i.p.a 1 ;
19 radioactive contaminants that have been .
20 identified by GPU and for which we have 21 estimated environmental impact.
22 Let me start with tritium. T h e r e. - ke. :
23 an estimated 1,000 curies of tritium that will 24 ultimately be released into the environment.
25 Tritium, as you probably know from discussions E' -
m- ___.-..--..._--.-....m i
17 1 we have had in the past, is not removed as a 1 2 result of the various decontamination processes 3 that have been used to remove most of the 4 radioactive material from the water. Tritium 5 is a nuclide that is found in the environment.
6 It is produced by predominantly cosmic ray 7 interaction, the upper levels of the 8 atmorphere.
9 An estimated 4 million curies per 10 year of tritium is produced in this fashion.
11 It has also been associated with and continues 12 to linger in the environment as a result of f 13 nuclear weapons tests, and also nuclear power 14 plants release tritium into the environment.
0 15 An average of 1,000 curies a year is released 16 by pressurized water reactors in the country.
17 Tritium is a radionuclide that, when 10 taken into the body, is very uniformly 19 distributed. It doesn't concentrate in any 20 particular tissue. It is associated with what 21 we will be talking about later, an impact term 22 " total body dose." And we will throw up some-23 terminology later that refers to dose that can 24 be thought of in terms of very even 25 distribution of radionuclides into the body
Y' s r 4
' 18 -
1: versus' organ' dose.
k 2 .And in this case, we will be talking 3- a little1 bit later about bone dose. And that
.4 is' associated with the next radioactive 5 component of the water strontium-90.
6 ~There is an estimated 0.9 curies of 7 strontium-90 that will be contained in the 8 water when it is dispositioned. That is not to 9 say all of it makes its way into the 10 environment. Some of will be removed in 11 several altegnatives, for example, by.
12 . evaporation.
[ 13 But let me just continue with the 14 thought that strontium is a radionuclide that 15 is concentrated in the bone. We will see later 16 that that is the case. And when we talk about
-17 bone dose, it will be essentially from 18 strontium-90.
19 Cesium-137 is the third radioactive 20 component. This is a beta and gamma remitter, 21 where the other two are principally beta 1
22 emitters. Cesium is found in the environment 23 as a result of weapons tests. It is concained 24 in fruits and vegetables to a certain degree.
25 In the body it is similar to tritium in the
c 19 1 sense that it is rather uniformly distributed
( 2 in tissues.
3 Let me continue with the nine 4 radioactive components of the water that we 5 evaluated in terms of the environmental impact.
6 There are two and they are boron, and in this 7 case, present in a borate ion. There is an 8 estimated 150 tons of boron in the water, and 9 sodium ion, in this case estimated 11 tons.
10 These two components are 11 non r a dioa ct ive. They are part of the processed 12 water because. they have been added to the
{ 13 systems principally to maintain subcriticality 14 in the reactor during the defueling cleanup 15 operations. The sodium has been added to 16 control pII to assure against any corrosive 17 properties in the water during the cleanup.
18 I am going to talk in general terms 19 about the alternatives that we have reviewed in 20 the course of carrying out this environmental 21 impact assessment. Linda will talk in some 22 more detail about them. But let me note that 23 we have, in accordance with the legal
/ 24 requirements in connection with preparing the .
(
25 environmental impact statements, looked at a M
20 1
.1 number of alternatives. Basically they can be
, 2 categorized into a n u m b e,r of general areas.
~3 The first set that are shown here 4' relate to alternatives for disposition that 5 involve on-site evaporation of this material.
6 You will recall, I am sure, that GPU's specific 7 proposal involves on-site evaporation of water.
8 And we will talk a little bit later about that 9 in some more detail.
10 Another category of alternatives that 11 we reviewed involved bulk liquid shipment of 12 the water off the TMI site. The next category
( 13 involves direct solidification of the water.
14 Another category involves the discharge of the 15 water into the Susquehanna River.
16 He looked at two particular options 17 in this regard; long-term river discharge and 18 short-term river discharge. And again we will 19 talk about those in a little bit of detail.
20 The last alternative we looked at is 21 on-site storage of the liquid in the tanks, and 22 it is essentially a status quo. That is where 23 the witer is now. And again in the context of
( 24 the legal requirements associated with
(
25 performing environmental impact statements,
i 21 1? .this;is one_ option that is required that we 2 l'ook at.
, s 3 Let me ask Linda now to summarize 4- some of the alternatives and briefly touch on 5 them that were also. considered but for one-6 reason or another were not evaluated in any 7 more detail.
8 Linda will also summarize in a little 9 bit more detail the alternatives that were 10 looked at in some additional detail.
11 MS. MUNSON: Let me say first that it 12 is a 1~ittle bit unusual to look at quite as ,
(' 13 many alternatives was we did in this particular-14 case, but there were reasons for it.
15 We looked at a total of about 11 16 alternatives that we felt were either less 17 desirable technically or clearly inferior to 18 some of the alternatives that we did discuss in 19 detail.
20 So the first of those that are listed 21 here; ocean disposal either as a liquid or as a 22 solid sounded rather good for this rather low 23 activity material. Unfortunately, there is an 24 international moritorium on the ocean disposal 25 of any radioactive material, and the U.S. is a
22 1 signatory to that.
1s 2 So this might in the far distant 3 future'be a possibility, but it didn't seem to 4 fit into the time frame that was being I
5 discussed'and we rejected it without doing any 6 dose calculations or intensive evaluation.
7 We also looked at the evaporation of 8 the water in ponds on-site. Pond evaporation 9 is practiced in a number of parts of the 10 country.
11 In this part of the country, however, 12 the precipitation rate and the evaporation rate
( 13 are about equal, so a pond of water would 14 eventually come to an equilibrium. Essentially 15 there would be some evaporation, there would be 16 some refilling, and you would still end up with 17 a pond of water to get rid of.
18 The licensee's alternative that we 19 did evaluate looked at evaporation on-site 20 through an evaporator. And we felt that was 21 clearly preferable in that you then had a 22 determined amount of material you could dispose 23 of.
24 And we also did look at pond 25 evaporation off site in the Nevada Desert, and
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< - 23
+
il I will talk about that a little more.
I. ' 2- We looked at cooling tower 3 evaporation on-site. And.that was discussed a 4 little bit in the PEIS. We found that cooling 5- towers have a problem known as drift. And
'6 there would essentially be more'of the 7 particulate, the cesium and the strontium 8 released to the environment, more of the boron 9 released to.the environment.
10 And furthermore, the cooling towers 11 are designed so the blow-down goes to the 12 river. So what didn't go to the atmosphere
( -
13 would end up in the river.
14 So we felt that either an evaporator 15 on-site or some sort of a river discharge would 16 bound that condition and it would be a much 17 more practical alternative.
, 18' We looked very briefly at deep well 19 injection on-site. In order to get an EPA
- 20 permit for deep well injection, and both EPA 21 and State approval is_ required, you have to 22 have very detailed information on the deep 23 hydrology in the strata that the water would be 24 going into. .
25 That information on the deep strata '
t I,
24 1 on the site'is not currently available. The i
2 Northeast typically does not have particularly J
3 good geology and hydrology for that. And it 4 looked like a protracted process to find out if 5 it was feasible. And for that reason we 6 rejected it.
7 We did look at some variations of 8 deep ground disposal off site, and we will 9 discuss those in a minute. We also looked at 10 the Oakridge National Laboratory hydrofracture 11 facility.
12 They have a process that is used at
( 13 Oakridge where waste waters are mixed with a 14 grout and then injected into deep strata as a 15 liquid where they then set up. And it is a 16 mobilization technique that is used very well.
17 The capacity of their system is not such that 18 they could handle the additional water in a 19 short period of time.
20 It would also require some DOE 21 approval. And it looked like a rather 22 protracted process to develop both the 23 equipment and the approvals for that.
24 There are some other deep disposal 25 techniques that we looked at that looked much
't
c 25 I more feasible. 'Looking at that next list, we
- g. .
\ 2 did look in some detail at the possibility of 3 recycling either the bulk water or the 4 evaporator bottoms, if it were to be 5 evaporated.
6 When we looked at places where the -
7 water might be used, since it does contain 8 low-level radioactivity, we looked primarily at 9 commercial reactors and at DOE facilities that 10 are accustomed to dealing with radioactive 11 material.
12 We found from most commercial reactor
( 13 uses that there are some slight impurities in 14 the water, bits of silt and so on, that make it 15 undesirable to put into their primary system.
16 And basically the water that is used in those 17 reactors goes through a purification process 18 not too different from Three Mile Island's and 19 ultimately ends up in the environment anyway.
2g So that it didn't look like recycling 21 the bulk water would really reduce your 22 environmental impact substantially. It had a 23 lot of agreements that would have to occur, and
( 24 it would be a protracted process to get to it
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25 happen.
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26 11 We also looked at the. possibility of
.I 2 recycling the' boric-acid concentrate.
4
~3 Unfortunately, the standards for purity for 4 boric acid that.is used in reactors requires a-5 .crystaline material of extremely high purity 6 that, without additional purification, this, 7 the evaporator bottoms, would not m'e e t .
8 We looked at the possibility of 9 spraying it on land at the Nevada test site.
10 It is very low-level material, so spraying it 11 on an arid climate was considered briefly.
12 Ilow e v e r , we had also looked at two different
( 13 alternatives involving trucking the water to -
14 the Nevada test cite.
15 One alternative was either 16 evaporating it in the pond at that site or 17 injecting it into one of the weapons test 18 cavities that are sometimes used for the 19 disposal of liquid wastes. Both of those 20 appeared to have lower dose rates and a little 21 higher a ccepta bility than simply spraying it 22 out into the environment, so we abandoned that.
23 The combined catalytic exchange and d
24 distillation are processes that have been used 25 commerically to separate tritium from stable
a
' ~
27 I hydrogen in aqueous solutions.
(
=2 Neither process has ever been used on 3 a' solution that has this small amount of 4 tritium in it, so it would be quite a 5 developmental process. And it is very doubtful 6 that the partitioning of moving the tritium
.7 into a concentrated form and thereby 8 essentially purifying the bulk water would be 9 particularly successful.
q 10 It looked like it would take a long 11 time to develop the process to build the 12 equipment; that it would be very expensive from
( 13 an energy consumption standpoint; and that it 14 would probably not be a timely solution.
I 15 We looked briefly at high altitude 16 disposal where the water might be loaded in 17 airplanes and disposed of at very high 18 altitudes. This essentially puts it all out i 19 ' into the environment anyway.
20 Instead of releasing it from a stack 21 57 feet above the ground, it releases the 22 entire concentration of the water perhaps over 23 the ocean. It didn't seem to be a very 24 practical alternative. And it would also be (f
2% extremely expensive.
28
'l We also looked at the Maxey Plats 1~ Kentucky site.
2- This is a waste burial ground 3 that has a tritium problem already. They have 4 some water that collects in their trenches and 5 is routinely evaporated to the environment. So 6 they have a tritium evaporation facility where 7 they get rid of about 30,000 curies of tritium 8 a year; and the additional 1,000 curies or so 9 from TMI, we figured, they wouldn't notice.
10 But unfortunately, their present 11 facility doesn't have anywhere near the 12 evaporation capacity to handle 2.1 million
!( 13 gallons in any sort of timely fashion at all.
14 That would also require approval from the 15 Commen?*al.th Kentucky; and we felt they would 16 probably feel that it was interfering with 17 their timely closure of that site and it 18 didn't, again, look very promising.
19 So we will go to the ten alternatives 20 that we did feel had reasonable feasibility and 21 deserved a detailed evaluation. The first two 22 involve on-site evaporation.
23 In the first case, the water would be
- 24 taken from the storage tanks and would be
(
25 routed through a commercial-type evaporator.
'~
29 1 The vapor would be injected through an existing 2 stack on-site. The evaporator bottoms would 3 contain about 99 percent of the strontium and 4 99 percent of the cesium, something less than 5 10 percent of the tritium, and about 99-percent 6 of the boron and sodium.
7 Those evaporator bottoms would be S collected, mixed with concrete, and poured into 9 liners where they would solidify. During the 10 solidification, about half of the remaining 11 tritium would be lost.
12 About half of the water is lost
( ~13 immediately when concrete sets up. But once 14 that water was lost, there would be a little 15 bit of exchange of the remaining tritium and so 16 on; but it would essentially immobilize the
~ 17 boron, the cesium, the strontium very well.
18 The liners would then be available to 19 be shipped to a licensed burial ground. As I 20 am sure you are aware, the burial spa ce becomes 21 an issue there and GPU has applied to the i
22 Department of Energy for allocation for 23 emergency space for that.
- If 24 The second alternative that we 25 considered under on-site evaporation is very
- 1
30 1 cimilar. It was --
in our line of thinking it 2 was something like, well, if they didn't get 3 that allocation, what else could they do with 4 the evaporator bottoms?
5 And for this second alternative, we 6 did presume that they would use some 7 reprocessing of some of the water that is 8 stored in tanks. It could be run through the 9 existing ion exchange systems, and an 10 additional amount of cesium and strontium would 11 be removed. It would generate a little more 12 waste that way, but it could be done.
.( 13 We presumed that if you were going to 14 evaporate the bottoms for any kind of permanent 15 disposal on-site, you would want to do that.
16 This kind of alternative was never 17 considered in the original Programmatic 18 Environmental Impact Statement, probably 19 because it was not felt that the evaporator l
20 bottoms would ever get to a point where it 21 might be clean enough to consider that.
l 22 There is a provision, it is 10 CFR 23 20, Section 3.02, which allows a licensee to 24 apply to the Commission for some alternate 25 disposal method given a criteria that there
31 G would be no more than a few milirem per year of i 2 .'d o s e to the maximum 1y exposed individual even 3 after the site were essentially released for 4 unrestricted use, and the population dose would 5 be low.
6 We did some calculations using the 7 NRC codes and determined that those criteria 8 could, indeed, be met by the evaporator 9 bottoms.
10 We looked at three alternatives which 11 require the bulk liquid shipment. Again, this 12 kind of alternative was not originally looked
( 13 at in the PEIS; but the radioactivity in the 14 water is low enough that it can be shipped as a 15 liquid. Ordinarily radioactive materials 16 can't be, but this falls below the level where 17 it comes under shipment as radioactive 18 material.
19 To ship 2.1 million gallons of water 20 anywhere takes about 420 truck shipments, so it 21 doesn't become a trivial thing at all to ship 22 it. But it could be shipped to the Nevada test 23 site and evaporated in ponds. It could be 24 covered afterwards. This yields quite a low .
25 dose, and it certainly removes the problem from ,'
l
32 l' this_ populated area.
.2 Also, as I mentioned, at the Nevada 3 tect' site there are a number of weapons test 4 cavities that have been used to dispose of 5 ' liquids. Th6y are pretty well glassified on
-6 .the inside. They tend not to leak to the 7 environment. That was also considered.
8 We also looked at the possibility of 9 crib disposal at the Hanford site. Hanford hac 10 a long-standing practice on the 600-mile 11 reservation of disposing of rather low-level 12 liquids by pouring them into an underground
.( 13 disposal facility and letting them seep 14 through. And the concentration of the accident 15 water is much less than most of the liquids 16 that that is done with.
17 Now, any of these would require some 18 DOE approval. We did not take the step of 19 inquiring whether or not DOE would be amenable l
20 to such a thing, and it would be definitely a j 21 change in precedent. But since DOE was -
l l 22 involved in the low-level waste site 23 allocation, it didn't seem unreasonable to 24 consider these as potential alternatives.
25 We also looked at a couple of
33 1 alternatives involving direct solidification i
i- 2 of the water, simply mixing it with concrete on 3 the island, either in a large trench where it l 4 would remain or pouring it in liners where it 5 would be shipped to a low-level waste burial 6 site.
7 The problem with this or the limiting 8 factor on this, at least, is that there is an 9 awful lot of water there. And to solidify 2.1 10 million gallons in this manner generates 11 somewhere between 390,000 and 460,000 cubic 12 feet of waste.
[ 13 Also, of course, as I mentioned 14 before in the curing of the concrete, about 15 half of the tritium is released immediately and 16 the tritium continues to be released. So it 17 doesn't eliminate the tritium release but it 18 does reduce it some.
19 We looked at both of these 20 alternatives. We did some dose calculations, 21 which we mentioned later. We looked at the 22 leachate that might occur from this solidified 23 mass buried on-site and found it did, indeed,
/ 24 meet the criteria of that 10 CPR 20.3.02 that I
.(
25 mentioned earlier, the dose to the maximum
34 1 individual being l e's s than 1 mil.irem per year.
f,. 2 The solidification and disposal at a 3 commercial low-level burial site is --
it 4 stands out.a great deal from the other
'S alternatives in that it has about three times 6 the amount.of. truck shipments. That requires-7 between 12,000 and 16,000 truck shipments. 1 8 And as a result, and with the large 9 volume of waste that would have'to go to a
, 10 commerical burial ground, it also stands out as 11 being the most expensive by far. Other 12 alternatives run somewhere between $2.5 million
{ 13 and S6 million. That alternative runs 14 somewhere between S34 million to $41 million.
15 So it is a little bit unique as far as the 16 alternatives we considered.
17' MR. SMITHGALL: Excuse me, you mean 18 1,200 truck shipments, don't you?
+
19 MS. MUNSON: Excuse me. Yes, I mean 20 1,300 to 1,600 Thank you very much. It is a 21 lot of truck shipments, but it is not that 22 many.
j 23 We did look at two options of T 24 discharging it to the river. In this case, we i
25 presumed that all of the water would be
35
~'
I retreated through the existing - that the
. g:
2 stored water would be retreated through the 3 existing ion exchange systems.
4 The alternative, the long-term river 5 discharge, we looked at over a period of two 6 years. The short-term river discharge we --
7 the boron concentration the NPES permit is a 8 little bit vague as to just what might be 9 allowed there; but we presumed that it would be 10 _the past value of .5 parts per million boron 11 and the effluent; which m e a n t; if GPU were to 12 maximize their waterflow through, that they
.( 13 could probably dispose of it in about 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
14 That would be the absolute minimum time.
15 It turns out, as far as the dose to 16 the public and so on, if we presume that no one 17 avoids ta king in water during the discharge or 18 whatever, making the assumption that everyone 19 continues to use water normally, and using the 20 conservative kind of assumptions we do in the 21 dose calculations, it really makes no 22 difference on the time. So those alternatives 2 are evaluated.
24 As Bill mentioned, we also looked at 25 continuing the status quo, essentially leaving
36 1 all of the liquids stored on- s i t e in tanks.
'k 2 And, of course, that stuff doesn't require a 3 lot of money, does not result in a lot of 4 impact unless you have a spill. It also does
)
5 not dispose of the water, though.
6 Those briefly are the alternatives we 7 looked at. Each one of the alternatives we 8 evaluated according to, essentially, five 9 categorice of criteria; the occupational 10 radiation exposure, which it turns out not to 11 be much of an issue as far as the water. We 12 evaluated relative to that because, you will
.( 13 recall, the Programmatic Environmental Impact 14 Statement concluded that the most important 15 impact at cleanup was occupational radiation
~16 exposure.
17 The first supplement to the PEIS 18 dealt exclusively with occupational radiation 19 exposure. But regardless of what is done with 20 the water, it will be a very small fraction of 21 the total exposure used in the cleanup.
22 We evaluated radiation exposure to 23 the public. It is rather low compared to the 24 sorts of things we used to evaluate in this 25 category, but there are numbers provided there.
37 1 And we have used the NRC approved models.
) 2 There are some appendices explaining some of 3 the modeling a s's u m p t i o n s and so on that are 4 used.
5 And, of course, we have gone --
the 6 URC actually'has gone through and taken the 7 dose numbers and converted them to risk of 8 premature deaths from cancer and risks of 9 genetic. effects.
10 We looked also at the commitment of
. 11 resources. This is part of the requirement of 12 the National Environmental Policy Act.
{ 13 Land area. There were a few 14 alternatives, either evaporation at the Nevada 15 test site or concretion into a mass on land.
. 16 There involved a small commitment of land area, 17 and those.are quantified.
18 We also looked at waste burial ground 19 space as being a resource. We see with the 20 Waste Policy Amendments Act that there is some 21 limitation on the amount of burial space 22 available, at least in the near future until 23 regional sites are available, and we quantified 24 that.
25 We have given some cost values on
F-38 1: each. . T' hey are essentially relative numbers.
4 '
2- They are in current-dollars. They are.not 3 intended to be absolute. They do not include 4 the utility's cost and getting approval and 5 this kind of thing. But they provide a broad 6 basis for comparison.
e 7 We also looked at the accident 8 potential. It turns out, when you talk about 9 accidents on-site involving the water, you are 10- basically talking about spills of liquid.
11 When you are talking about off-site 12 accidents, the primary ones are transportation
.(' 13 accidents. There is a potential for off-site 14 accidents that would spill water in some of the 15 alternatives, but that turns out to be a 16 relatively small impact.
17 The number of injuries and property 18 damage and f a t a l i t .' u s from accidents, from 19 automobile-type accidents, does tend to be one 20 of the principal concerns, or at least one of 21 the larger impacts that we quantified.
22 We have also given some discussion of 23 the regulatory consideration which is related
/ 24 to the feasibility and probably the time i
25 required to implement any of the alternatives.
\
9 39 1 And now I will turn it back to Bill 2 to summarize what the impacts of these 1
3' alternatives are.
4 MR. TRAVERS: The next few slides in 5 your package provide a summary of the 6 environmental impacts that were assessed. And 7 the summary includes an assessment of 8 environmental impacts for all of the ten 9 alternatives that we looked at in some detail.
10 The first slide gives you a 11 quantitative assessment of the radiological 11 impact on the off-site population. That was
'( 13 assessed in terms of a range for all ten 14 alternatives.
- 15 In the case of radiological impacts, 16 we segregated out dose in terms of both the 17 maximum individual; that amount of dose that 18 can be conservatively assumed to be imparted tc 19 the man or woman or child who lives closest to 20 the plant and happens to drink water very near 21 the discharge point of the plant or eats fish l
22 caught near the discharge.
23 A number of conservative assumptions 24 go into the attempt to conservatively assess 25 the maximum individual dose that could result
40 1 f r om any -of ~ these ten alternatives.
.2 And in addition to that, we looked at 3 the population dose that could occur as a 4 result of these ten alternatives. And in this 5 case we are looking at a 50-mile population 6 that includes approximately 2.2 million people, 7 at least in terms of people who would be 8 exposed to atmospheric discharges. And the 9 population of some 300,000 people who might be 10 affected by liquid releases from the plant.
11 These are people who might use the 12 river for recreational purposes, may drink
,( 13 water as a result of intakes on the river, 14 people-who eat fish, and that kind of t h i n'g .
15 In the range of maximum individual 16 doses that we found are categorized here and 17 range from between zero to one-half a milirem 18 for a total body dose. And the strontium bone 19 dose --
I mentioned earlier that strontium 20 imparts.something we calculate in terms of bone l 21 dose, ranges from 0 to 3 milirem per person.
22 For prospective you can look at the 23 individual doce that is received as a result of 24 natural background in the Harrisburg area, and G
25 that equals 90 milirem per year.
--- - - - - - , -, .- , , , - - - - - - - - - , - , - - , , - - , - , - - - e- - - ,,,---,a
- - 41 l t' l'
The ' highest-range in terms of total 2 body dose for the population in the ten 3 alternatives range from 0 to 3 person rem. And 4 that is equatable for prospective in terms of 5 background dose to that same population --
the 6 same population in a given year receive about 7 190,000 person rems.
8 As Linda mentioned, we have taken 3 'these doses and translated them into terms of 10 potential cancer fatalities and genetic
- 11 disorders that might result from these kind of 12 doses. And those values are given here in Q 13 terms of their potential for occurrence. It is 14 rather low.
15 We estimated from 0 to 0.001 fatal
. 16 cancers could develop from these range of 17 impa ct s . We estimated that a range of 0 to 18 0.002 genetic disorders might occur in the 19 first five generations of progeny in the 20 population. And this value for genetic 21 disorders also includes the dose and the 22 resultant potential for genetic disorders that 23 occurs from occupational dose.
24 And I will talk about that on the next slide.
25 The environmental impacts that we
e
, 42
~
1 assessed in terms of the worker population are 2- summarized ~here. And for all ten alternatives, 3 wesestimate.d a range between 0.5 to 25 4 person-rems to workers from any of these ten 5 alternatives. And as Linda mentioned earlier, 6 you can compare this to the 13,000 to 46,000 7 person-rem that we estimated might occur as a
'8 result-of the total cleanup job.
-9 The radiation cancer fatalities that 10 correlate to this kind of dose range from 0 and 11 .003. It is interesting to note, I think, that 12 the total worker doses that have occurred l 13 through the calendar year 1986 from the cleanup 14 equal about 3,600 person-rem per date.
15 The next slide summarizes some of the 16 nonradiological impacts that Linda has 17 mentioned somewhat earlier in terms of land 18 usage, in terms of waste burial ground volume, j
19 in terms of relative cost, and in terms of the 20 time that would be needed to implement any of 21 these alternatives.
22 And, again, this is an assessment for all ten 23 of the alternatives.
24 And I should note, when we looked at .
25 cost, we made a rather gross estimate of costs m .
-- - , .. ,y, ,- -r-- n, -- --
l 43 g
'~
- 1. in;trying to identify whether any particular 2 alternative stood out as significantly more 3 costly or less~ costly than any of the others.
4 The next slide summarizes for all ten 5 alternatives again the environmental impacts in 6 terms of the impact from transportation related 7 activities. And it turns out that for this 8 activity, the disposition of accident-generated 9 water, the ~most significant impacts that you 10 can estimate might occur are associated with 11 the impacts from transportation. They are 12 small, but nonetheless, they happen to be the
[ 13 largest ones we were able to quantify in terms 14 of impact.
15 The lowest number of impacts is 16 associat'ed with forced evaporation and 17 retention on-site. Obviously, there are very 18 few shipments associated with that. I believe 19 the only shipments that we assumed attributable 20 to that particular option involved the shipment 21 of the resins that would be used to process the 22 water.
23 The largest number of accidents are 24 certainly associated with the alternative that 25 Linda already mentioned, and that involves the
f 44
. 1 ' solidification of the bulk volume of all the 2 water'and.the several hundreds of shipments 3 t'h a t would be required to take that material 4 off the site.
5 As a result of.looking and 6 quantifying to the best of our ability the 7 environmental impacts associated with 8 disposition of accident-generated water, we 9 came to the final conclusions. Dasically, it 10 is pretty clear to us that there are a number 11 of alternatives that could, in fact, be used to
+
12 dispose of accident-generated water that would
( 13 not impart a very significant or a significant 14 environmental impact.
15 In looking at the alternatives that 16 we evaluated in detail, we were unable to .
17 identify any alternative that, in terms of 18 environmental impact, was clearly superior to 19 the others. As I mentioned previously, the 20 most significant. environmental impact comes I
i 21 about as a result of the transportation-related 22 activities.
23 And the last conclusion we made is
( 24 related to the final alternative, the status 1
25 quo alternative associated with continuing for
,- - . - - - . - . , , . ,,.- . - .,, -. ,, - -- -.-.,--,,,n. - , ,
l
+
' - 45 a
~
I an indefinite period to store the 2 accident-generated water in tanks on-site.
3 Dasically in the sta f f's view, this 4 simply defers a decision, an ultimate decision 5 on the disposal of water. It also conflicts 6- with'a policy that the Commission has held for l 7' sometimer and that is, that the island ought l
8 not to be a site where radioactive waste, even l I
9 very low level radioactive waste, ought to be ,
1 10 stored indefinitely. ,
1 11 These are the conclusions we r'e a c h e d .
12 I would be glad to attempt to answer any 1
( 13 questions with Linda's help that the panel may 14 have, i 15 MR. WALD: In terms of the low-level 16 waste, rad waste A, B, C, where would this fit?
17 MR. TRAVERS: If you are talking 10 about the water --
in fact, if you are talking 19 about the water or the bottoms, for example in l
l i
20 the evaporation process, this fits in the 21 lowest category, Class A or B.
22 MR. WALD: And if it solidified? I 23 am particularly addressing 3.2, the disposal of 24 the commercial low-level burial site.
25 MR. TRAVERS: That would be
l 46 1 considered low-level radioactive waste.
2 MR. WALD: That would be Class A or 3 B?
4 MR. TRAVERS: Yes. The point we were 5 making earlier about the possibility of on-site 6 disposal revolves around the possibility that 7 you could, if you demonstrated that the waste 8 has a potential for imparting very small doses 9 on the order of 1, 2, maybe 5 milirem per year 10 to someone standing on top of it, argues 11 successfully that the Commission ought to grant 12 you an exemption to allow you to dispose of 13 that on-site and eliminate the other costs; for
[
14 example, transportation that might be 15 associated with getting it off the site.
16 That is not something that we in this 17 document have concluded would be acceptable 18 from the Commission's standpoint, but it is 19 certainly something t h a t' we can't close the 20 door on. 'e W think it wculd be a viable 21 alternative that would be considered if the l 22 requests for an exemption were made.
l l 23 MS. MUNSON: I have the dose to the
,! 24 maximum individual from the stored waste, if .
lI 25 you are interested. ,
.w --,, --, -- -~-,.,-.p.--, -
- - , - ,--,y-,,,-w,- - - - - - - -- - ---e.-
~ ,
. ,17
~
47 1 If you were to solidify the entire 2 ' bulk.1iquid and store it on-site, the dose from 3 the. stored material at the time the site were 4 released 30 years from now using the NRC's Code 5 Impacts B or C, the dose to the maximum 16 individual is 0.004 milirem per year to the 7 bone. And the whole body is even lower than 8 that on order of magnitude.
9 So it definitely would be a sort of a ID candidate for that from the radiation dose 11 . standpoint.
12 THE CH AIR MAN : Maybe what we should 1 13 do is take the break that is on the agenda for 14 ten. minutes. We will return. And if you 15 could, we will give the panel members time to 16- ask questions if there are any, and then we 17 will go right into the public comment.
18 MR. TRAVERS: I thought the one thing 19 I would do after the break is summarize 20 administrative 1y where we go from here and how 21 it will be handled.
22 THE CHAIRMAN: That would be a good l
i 23 way to kick it off.
24 (Brief recess.)
25 THE CHAIRMAN: We will return back to
- - - _ - _ _ , , ~ _ _ _ - _ _ _ _ ,
. 48 l' the meeting.
p 2 Bill Travers indicated he would try 3 to outli'ne the procedure of the supplemental 4 EIS. Then we will ask the panel members if 5 they have any quick follow-up questions prior 6 to going into the citizen participation part of 7 the program.
8 MR. TRAVERS: As I mentioned at the 9 beginning of the presentation, what we put out 10 so far is a draft. It is an Environmental 11 .Im pa c t Statement for comment.
12 It has been mailed to a number of I 13 Federal and State agencies, as well as to all 14 the members of the panels and to other 15 interested parties. And at the request of any 16 individuals, copies have also been mailed out.
17 The NRC intends to review any and all 18 comments we get on the document. The closing 19 date for receipt of those comments is February 20 28.
21 Following that we intend to review,
- 22 consider, and address all of the comments we
. 23 received in a published final version of our -
24 Environmental Impact Statement on this issue.
25 I don't know how long that will take, but I
I i 3
' ~
, . s 49 11' suspect approximately a month after the closing
~
p; 2- date.
3
-After issuance of our final 4 Environmental Impact Statement, what we plan to 5 do, what the NRC staff plans to do, is to 6 provide a recommendation to the Commissioners 7- on GPU's specific proposal for disposing of~the 8 water.
9 A, s you know, and as I think most 10 people know, the Commission when it issued the 11 Programmatic Environmental Impact Statement 12 back in March of 1981, indicated that all or
[ 13 any plan'for. disposing of the water should be 14 referred to them for consideration and approval 15 or disapproval,'and we intend to do that.
16 The last administrative hurdle in the 17 implementation of any alternative, whether it 18 is this one or some alternative subsequent to 19 -this, i s a required change in the current 20 license in one aspect.
21 The license currently prohibits .
22 disposition or discharge of the water pending 23 Commission approval. And to change that, the i
24 lawyers inform me that we have to go through a 25 very formal license amendment process that I -
i
! 50 e
- 1 affords.public opportunity for requests for l (. 2 hearings, for exampic.
3 So that is administrative 1y the last 4 hurdle that would have to be faced prior to 5 implementation of the licensee's plan or any 6 others that may come up subsequent to this 7 proposal.
8 THE CHAIRMAN: Let me just before I 9 forget to say this, tonight I would like to 10 attempt to conclude the meeting by ten o' clock.
11 There are people who have traveled a fair 12 distance. And I know one in particular who has
( 13 a pretty good distance to go back. It is .
14 calling for snow in the wee hours of the 15 morning or late tonight; so I do expect to 16 conclude the meeting by ten o' clock.
17 We will probably devote most of the 18 rest of the time to citizen comment. So I just 19 want to say that now so you don't feel we are D
20 rushing it at the end.
21 While we have not discussed this as a 22 panel, I do expect that this topic would be.
23 something that we will need to discuss 24 concerning where we go from here as a panel. I .
25 would hope we would be able to discuss this
1 51
'I again at the next panel meeting, so this is not b~ 2 thellast-opportunity to comment either on the 3 PEIS or'the recommendations made by GPU.
4 At this time I ask the panel members 5 if there are any questions that they would like
. 6 to ask.
7 (No response.)
8 I don't see anybody,. so I would like 9 to call on Eric Epstein to come forward.
10 MR. EPSTEIN: In that this is a very 11 sensitive subject, I think that the panel 12 should not rigidly enforce time constraints on
( 13 questions and presentations by the community.
14 And in addition, I think you have already 15 addressed this, I hope the water disposal issue 16 does not become a secondary item after this
- 17 meeting.
l 18 I do appreciate the fact that GPU 19 responded to my questions concerning post 20 defueling monitor storager however, I am not 21 satisfied with a number of the responses, -
22 especially the ones dealing with 23 decommissioning. And rather than pursue a line f 24 of questioning tonight, I will defer to the 25 next meeting if that is okay with you, Mayor.
52 1 THE CHAIRMAN: Actually I would 2' +preferLthat. And I would appreciate if the
-3 . individuals coming forward tonight speaking on 4 the record would keep their comments 5 specifically on the subject matter before us, 6 because there will be opportunities in the 7 future to talk about other items. And we would 8 like to give those people a chance to comment 9 on the record on the water issue.
10 1U1. . EPSTEIN: I am submitting a list 11 of questions, about 22, to the NRC concerning 12 their revised Environmental Impact Statement.
I 13 I request that they be made a part of the 14 official record. And rather than distribute 15' them to you right now, I think it would just 16 distract from my presentation, I will give it 3
17 to you later.
18 Tonight I am speaking on behalf of 19 Three !!i l e Island Alert, which is a nonprofit 20 safe energy group based in Harrisburg.
21 Both the NRC and GPU have stated that i
22 the quantities of radiation released during the 23 the disposal of the contaminated water would be 24 insignificant. But we must realize that they 25 always say this. We don't believe that any v- g , - - - - - . -,,-,-,,---,,-,---.-,-------r -
t 53 1 radiation dose is safe, especially in this area
( '2 where radiation has been vented steadily for 3 the last 14 years.
J4 I don't remember a time when the 5 utility admitted that significant levels of 6 radiation have been released, including the 7 43,000 curies of krypton-85 vented on central 8 Pennsylvania for 13 days in July of 1980.
9 We have serious reservations about 10 the disposal options sanctioned by the NRC. In 11 fact, disposal is an incorrect term. There 12 uill be no actual disposal and no guarantee of
( 13 containment. Instead, radioactive materials 14 and industrial chemicals will be dispersed in 15 the environment.
16 He do, however, have certain 17 obj e c t ives we would like to see met. Our prime 18 and overriding concern is minimizing radiation 19 exposure to the local population and the 20 environment. For example, we would like to see 21 100 percent of the water filtered and processed 22 within a closed cycle.
23 We also think that workers' exposure f 24 should be minimized since many of them have L
25 been human sponges for the last seven and a
.g: f , f. 3 ; ,. '-ify:_4i;[% G.yy[.& h W 9 l L; ; l% .i ;A. '.? R4:"4 , . i.::~5 '-ll.$h l: . m. / ' e ..'(_; . 4,s c * .. *%
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. 2 Dose rated to populations outside of [ b
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N ~ 3 central Pennsylvania should also be minimized. f .'1) . - -
- - t u .e.
i, .g !t.: ..N 4' In addition, cost and time should not :
.. fya . ; -,4 k ;% ,h' 5 be factors. GPU should spend as much money and y %' . g,-g*
v+ a :.9.... ,. :.. . n ., 6- t'a k e as much time as needed to find the safest c..e
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. . .o method of disposal., V. '. ' ,
7 I a. Y
- p. !. 4. i S 8 Considering these objectives, '; ; W y a. . , &, -
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.. ; 9 alternatives such as dumping the water into the z
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3 - ~.. -- 10 Susquehanna River and on-site evaporation are 0 q :-(%. ?f -ar 11 clearly unacceptable due to the potential ,. [.,yj,
- g. (,* .; g{
1p 12 harmful physical and psychological threat tnat - a, . . gk;y... '.' . . .
.V. ( 13 they present to the community. f8 " .)4 :;.
. , . e ,: . y
[s 14 We do request the following steps be I. s :n 15 taken before a final decision is it made: A
'f.4
.egt%j
<f
- a
;,: _: q -
- - i..,
.:; 16 meteorological study of the area surrounding f'6 "
- p y: - < . -
.y < ;'4 r 17 TMI; a study examining the psychological stress >A pp ' -
iy. 5 *f.:;. .. 4p 18 that would result from the planned disposal s% ~ < ,;f. f.9c
- 2 19 methods; an inventory of all the radioactive 4J.f,:/[3.g y - 20 elements and chemicals that are in the water; D 74
. ., .. u ...s.., [" 21 and a review of the GPU's current proposal and b; b. h .q,_ N:2c f 22 the NRC's revised EIS by an independent agency 'jf - .h 23
. ?, b .G
., V+ not affiliated with the nuclear industry of the '7 i
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- e. f 24 Government. 4 T
1~,g( (
- l,( -p
- p 25 At this time I would like to remind d
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>( 1 the. panel of.some of the past behavior of this ,s : < /
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'o util'ity and the NRC, because this is a crucial ": ,.
2 . F I;
- s. ; q.r..
3 . - < q 3 factor in. understanding the built-in distrust
, , i p?::7
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[c,. 1 4 and fear of area residents. :'; -) .
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1.. ~ " .; . j 5 We remember that in July of 1980, YJ . V i
.g v.: ,' 6 43,000 curies of radioactive krypton-85 and -[f. l?.c ,! ;
- - y
.1 ~ ;
s 7 other radioactive gases were vented from Unit f+.,....,- 4
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f n.; ' j 8 2, e 'v e n though TMI 2 was designed to release ;; g
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,p 9 approximately 770 curies of krypton-85 a year.
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10 The venting occurred a little over a
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.~H .11 'y 'e a r f a f t e r the accident amidst widespread fear _M NJ a .s o
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j 12 and' concern. Later in November, the U.S. Court I gJg'k[.
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*e 13 of Appeals f o r, the District of Columbia ruled
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'q .r: . .. ...$ 15 venting was illegal. l-J '"?
.y _- p;:$ o 16 We remember,that in the spring of - '
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~1 1983 three senior-levd1 engine'ers charged that 4 1 E M. . - . .
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p] 18 GPU and Bechtel deliberately circumvented psi.:% y- + . . ;.. -
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- - 20 , reporting safety violations. The NRC fined GPU R,.i. . / ,
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21 and Bechtel S64,000 for intimidating and , M. Ve
,i .. } W.,. ..; g ., '49. . -
22 harassing Larry P a r k 's . MF[.9,Q..
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, 23 A n ci , of course, we r e m e m b e'r the -
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24' reactor head lift between J u l y 2'4 and 27, 1983, NN
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4
, 56 1 Ep'o l a r crane. GPU vented radioactive gases into E
{ ' 2 the environment despite pledges by the NRC and-3 GPU that.no venting would take place during 4 that head' lift operation. GPU was later fined
.1 5 $40,000 by the NRC for the brake problem.
6 We remember that on June 1, 1984, the 7 NRC released transcripts of closed NRC l 8. Commission meetings. The transcripts revealed 9 a commitment on the part of the Commission la majority to restart TMI 1 as soon as legally 11 and politically possible. 12 .Also evident was a significant ( 13 6 disdain for public views on the restart issue 14 and a serious lack of understanding of the 15 legal and technical issues. This is the same 16 agency who will ultimately decide how the water 17 will be disposed. 18 We remember that between February 10 19 and 12, 1985, the Philadelphia Inquirer 20 reported records at TMI demonstrated that in . 21 hundreds of cases, workers had been 22 contaminated by radioactive materials either on 23 the skin or through ingestion. The result was T 24 that workers were living in a state of anxiety, 25 fearing cancer, birth defects, and possible
- p. % - e-
e 4
- 57 I genetic damage for s future generation.
( 2 We also remember the health suits,
~
3 the spills, the fines, the leaks, the 4 miscalibrations,'the exposures, the criminal 5- convictions, and the one-celled organisms. 6 So when the NRC and GPU say venting, 7 dumping, or burying 2.1 million gallons of 8 radioactive water will have a negligible impact 9 on our health and environment, people just 10 don't believe them. _ Why should they? 11 People live with,a fear that they and 12 future g e rie r a t i o n s have suffered serious health ( 13 effects as a result of the accident and GPU's 14 mismanagement. This fear he fostered a great 15 deal of phychological stress in our community. 16 Stress can be translated i nto long-term health j 17 effects, and they are very difficult to 18 measure. Yet it is one factor that the NRC 19 will not identify in measuring health risks 20 from the disposal of the water. 21 Let me conclude by saying that we are 22 not scientists and we do not feel that the 23 burden of producing a safe and expedited method 24 of disposal should fall on the shoulders of the .
- 25. community. The decision on what to do with ,
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'l -this' water should not be made in haste and
(.~ e
- 2. should not be made until all possible 3 alternatives are explored and exhausted.
4 People in this area have been dumped 5 on enough. I think we are just tired of being 6 the guinea pigs. That concludes my official 7 statement.
. 8 MR. ROBINSON: What agency, 9 independent agency, would TMI Alert recommend?
10 MR. EPSTEIN: I don't know what 11 agency. It maybe doesn't.have to be an agency, 12 but people that aren't tied to the industry or
.( 13 the Government would be helpful to us.
14 Of course, whoever we recommend, I am 15 sure the utility and the NRC would resist as 16 being bias or subjective, but that is the same 17 kind of bias we feel with the NRC and perhaps 18 the utility have done. 19 HR. ROBINSON: Have about EPA? 20 MR. EPSTEIN: EPA again is a 21 government agency. And, you know, Bill is a 22 nice guy.and all that good stuff, but EPA if 23 you look at the way they have handled chemical
.( 24 i-s s u e s throughout the country, it has not been 25 real good.
~
a- W L, ,_ . ' m , y 59
,t 1 ,
So if you would like, I can get a 2 list of' folks; and if you would like to forward 3 them to the NRC, I would be happy to do that. 4 MR. ROBINSON: I would like not a 5 list of folks, but hopefully some group or 6 agency or something that -- yes, I would like a 7 list. 8 MR. EPSTEIN: Perhaps " folks" is not 9 the best terminology. But I can produce that 10 if that would help you. 11 HR. MILLER: In your opening 12 statement dealing with the water, you mentioned ( 13 the fact that you would like to see the water 14 filtered through a closed-loop system. 15 MR. EPSTEIN: Right. 16 MR. MILLER: What do you have in mind 17 there? 18 MR. EPSTEIN: I don't know what I 19 have in mind there. But one of my questions 20 here is that they had to make an adjustment to 21 the filtering system that is usually not 22 closed; and I was wondering, if they had to 23 make an adjustment to open it, why they 1 24 couldn't keep it closed? And that is one of .{ 25 the questions I had submitted to the NRC. e g w - - - ' - y w y--w w e --o ,
, 9
N ' 4.f. ,
. 60
'l -
Here it is, Question 5, "tihy not let
'2 f t,he' f t r a n s p o r t a bl e evaporator operate in'a ,
3 ~ .c l o c e d ' c'y c l e ? " And I asked, "How accurate has 4 Ithe ' volume reduction figure'been in other 5' plants?" 6~ Rather than go into that, it deals
.7 with the specifics of the EIS. I don't see why-8 it has to.be open and vented. That is my main
! 'L 9 . question.
-10 What are you having a problem 4
11 understanding? 12 MR. MILLER:. I don't see how you
]( 13 accomplish anything with what you are 14 proposing. Basically you are just running it i
15 'through a closed system and accomplishing
'16 nothing.
17 MR, EPSTEIN: What I am asking is 18 that it be processed and cleansed as much as l 19 possible. I notice on proposals that 50 i 20 percent of the water is -- why not 100 percent 21 of it processed and gleaned for as much
~
l- 22 chemical elements as possible?
.23 Why not go the extra yard? is all I IT 24 -a m saying.
ll ( 25 THE CHAIRMAN: Are you suggesting
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; 61
- l' further- filtration of sorts; because if you are ik' 2 -. talking about a closed evaporation system, the 3 idea really. is to reduce the volume. And if 4 you are not going to reduce through 5 evaporation, then the volume stays the same.
, 6 MR. EPSTEIN: I mentioned evaporation 7 is unacceptable to our group, so I think they 8 should probably deal with that.
.9 THE CHAIRMAN: So you are talking 10 about further filtration?
11 MR. EPSTEIN: And processing. You 12 still look befuddled, Ken. ?( 13 MR. MILLER: I guess I just don't 14 understand what the end point would be that you 15 have i n mind by doing this. 16 MR. E P S T E.I N : Well, I don't think 17 there is an end point. 18 MR. MILLER: If you are not going to 19 evaporate the water, there is no point in 20 further filtration. 21 MR. EPSTEIN: I am not going to sit 22 here and take other people's time bantering 23 back and forth with you. 24 THE CHAIRMAN: I realize that . 25 citizens that come forward to make a statement .
,- p* , y- -y-g ,y ,-.,yy, . - - , p. - -
7 u h i a 62 N. el really,should be. prepared to stand up and k- ~ 2 leave, or they can answer questions. It is not 4 3' a requirement that do you that, answer 4 questi'ons. 5 MR. EPSTEIN: I would stay here all 6 night'with you, Art. You are a nice guy and 7 'p o u are a nice panel, but other people have 8 t.hings to say. 9 THE CHAIRMAN: I understand that. I 10 just want other people to understand that if 3- 11 you come forward to make a statement and you 12 don't want to answer questions, you really ( 13 don't have to do that. 14 I am not saying that to be smart; I 15 just want the people to feel comfortable. 16 MR. EPSTEIN: All I need for the next 17 meeting.is a written list of individuals and 18 agencies for you? 19 MR. ROBINSON: Yes, if you would. 20 THE CHAIRMAN: The next person who 21 asked for time is Francis Skolnick.
'22 MS. SKOLNICK: Francis Skolnick.
23 I am speaking for the Susquehanna 24 valley Alliance, a safe energy organization !j/ 25 formed in 1979 to prevent the disposal of the
i'
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.1 ~ . accident-generated water into the Susquehanna 2 River, our.' drinking water source.
L , '3 The SVA established as one of its ! 4 goals t h~ e safe disposal of this radioactive 5 w a t e.r . And we are as committed as ever to 6 . achieve that goal. 7 I.am speaking here this evening to l 8 raise major concerns with this panel about the 4 9 disposal of the water, with the hope that its 10 members will seriously study and evaluate these 11 concerns and find suitable answers and 12 explanations.
- ( 13 I believe that.it is important to 14 clarify certain points about this radioactive 15 water, estimated to be about 2.1 million
, 16 gallons. But who knows.at this time whether or 17 not it might amount to 3-million or even 4 18 million gallons when end-point is reached, an 19 event whose definition has not yet been 20 clarified. l 21 All of this water is not sitting in 22 tanks on-site just waiting for disposal. It is 23 stored in various locations, including the 24 r ea ct or core system covering the damaged and l 25 melted fuel and in the reactor buil' ding sump,
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', I the area where presently only robots'mayogo L'. '
l j . ' ' " 2( 'because itLis so highly contaminated. 3 -Therefore, a large quantity of this water about 4- whi'ch we_ speak is still-in contact with highly 5- radioactive elements.
'6: Furthermore, it is my understanding
^ 7 that this accident-generated water is to be 8 used for flushing and washing out the system 9 'after defueling. Defueling is a hazardous 10 procedure which continues to meet with 11 obstacles and time delays,. including the growth 4 12 of micro-organisms and the inability to get the [ 13 chunks of material broken up. 4 14 Which brings me to our concern about 15 the presently listed contents of this water.
~ 16 To list tritium, strontium, cesium, boron and 17 sodium only serves to simp 1fy the matter and 18 insults yours and my intelligence.
19 Unit 2 ran for a matter of months 20 before it expired, and not at all gracefully. 21 According to Dr. Carl Johnson, M.D., M.P.H., . as 22 many as 500 radioisotopes are formed during the 23 fission process. Fifty-two of these 24 trans-uranics are formed. Some of these 25 trans-uranics are less toxict however, some are i~
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65
. 1- highly' toxic to. man, ' including plutonium.
2 Another trans-uranic, nepunium-239, after a
.3 chort life becomes plutonium.
4 When plutonium and similar radionuclides enter the tissues and the body of: 6 man, they become a permanent resident in the
.7 body and continue to emit-alpha radiation. The 8 excretion rate is very slow; about one-half 9 would be excreted every 200 years.
10 In animals plutonium causes cancer of 11 the lung, bone, kidney, mammary gland, lymph
.12 nodes, nesothelium and ten types of soft-tissue E( . 13 cancer.
14 Trans-uranics are soluble in water. 15 I n'd e e d , they were found in the water in Denver, 16 which is downwind of Rocky Flats'and also in 17 Broomfield, close to Rocky Plats. Excess 18 cancer incidence as been reported in those 19 areas. 20 It seems crucial to us then that this l' 21 water is tested independently and with 22 sophisticated alpha radiation monitoring 23 equipment, starting right away, and continuing 24 for the duration of the cleanup. . 25 We demand a table of contents of the , g-,--y ,y.e- yy ,,,,s- - > . , , , , . - - , p,, ,o g,ym, ,
,p,,-y,,e -
y,,,--y-- y 7,r,m4,,, ,,g,--n-- ,,.n.---a -,.e,-, -4g,
66 m 1 -water,-which would include a list of the
- l. Telling us that a radioisotope 5 '2 ,trans-uranics.
3 is below detectable limits is not enough. We 4 .need' assurance that the correct equipment is 5 being used to detect trans-uranics, and what 6 the lowest detectable limit is for that machine 7- for each radioisotope. Then and only then can 8 we evaluate the health impact of any of these 9 methods of disposal. 10 Dr. Carl Johnson also advised me 11 about the alpha recoil effect which causes 12 particulate matter to pass through filters. [ 13 Dr. Johnson would be more than pleaced to come 14 before this panel and explain the whole matter 15 of trans-uranics. 16 What we also need and want to 17 evaluate is an inventory of the core prior to 18 the accident, the amounts which have left the 19 area and their content; then we can estimate l 20 the radioisotopic content of what is left. 21 Other el ement s not listed in the 22 table of contents, and which must be listed in 23 order to make an evaluation of the disposal i 24 methods, should include the chemicals used in i 25 the decontamination solutions and the oils and l l
67 1 greases which were clearly alluded to in the 3l 2 Environmental Impact Statement of 1981. 3 We do not want to be told they are 4 below detectable limits. We want to know 5 ' quantities and concentrations used to date and 6 projected quantities and concentrations up to 7 the end-point. 8 It is also imperative that we know 9 how this water would be processed prior to 10 disposal, since concerns have been raised in 11 the Environmental Impact Statement of '81 about 12 chemically-laden water clothing the Epicore and ( 13 the SDS systems and causing them to work 14 ineffectively. 15 What we are suggesting, therefore, is 16 that it is premature to consider the disposal 17 of a liquid whose contents are not yet 18 clarified and could change. 19 We believe that it is unwise to give 20 GPU Nuclear the freedom to dispose of this 21 water by a certain method when, perhaps in six 22 months or a year, we could discover that the 23 Epicore or the SDS is no longer adequate for I 24 treating this water, and the method selected 25 for disposal would no longer prove adequate and
68 1- s'a f e .
. 2 I have addressed the tritium content
- -3 of the water and its possible health
~4 consequences in my last statement to this
~
5 panel. It is not the innocent radionuclide 6 which'the NRC and GPU would make us believe. 7- It is more likely to have been deemed innocent 8 because of the-unavailability of technology to 9 remove it from water. 10 Tritium is the unstable element of 11_ ' hydrogen and has a half-life of 12 years, which 12 means it is will be toxic for 120 years.
]( 13 Experiments with tritium have 14 concluded that tritium does have negative 15 effects upon organisms. These experiments 16 include those by Dobson and Cooper, who 17 concluded that there is no threshold below lb which reproduction in mice is not adversely 19 affected, Zamenoff and Martens observed that 20 mice who were continually fed low doses of f
21 tritium suffered brain damage. 22 Experiments conducted by Mewissen and 23 Ugarte to determine the cumulative genetic 24 effects from exposure of male mice to tritium 25 for ten generations led to a reduction in the i
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.off-spring and a rise in infant mortality.
k~ 2 Since the preferred chemical state of-3 tritium is water, it has free access to our 4 bodies and other living organisms. It can
~
5 enter into our bodies in three ways; (1) 6 ' inhalation, (2) ingestion, and (3) absorption 7' through the skin. 8 It readily enters into our food chain 9 through plants and animals who are subjected to 10 the same contaminated environment. We are not 11 only talking about the people, plants, and 12 animals of central Pennsylvania, but also those ( 13 of the Chesapeake Bay and Baltimore area. 14 Our conclusions about tritium and its 15 adverse health effects lead us to press for 16 greater efforts to isolate this radionuclide 17 from our environment. It just isn't good 18 enough or acceptable that thousands of curies 19 of this radionuclide is allowed to contaminate 20 our water and our air. 21 I wish to draw your attention to a 22 document. It is Nureg CR 39773 prepared for 23 the division of Waste Management office of 2p Nuclear Material Safety and Safeguard, the , 25 Nuclear Regulatory Commission, by Brookhaven l
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70
~
yz 1 National L'aboratory, Department of Nuclear
~
.2 Energy, which discusses alternative containers 3 for-low-level wastes containing large amounts 4 of tritium.
5 The availability of these recommended 6 containers whose life span is up to 250 years
- 7 would give us an option of maintaining that
, 8 water on-site in a safer manner than at i
9 present. 10 The impact of the disposal of this 11 water on our health cannot be seen outside of 12 the context of all previous, present, and ( 13 future releases of radiation into our 14 environment, from not only TMI but all the 15 other nuclear plants and industries releasing 16 radioactivity. 17 An overwhelming amount of data have 18 been accumulated that show there is no safe 2 19 level of exposure. And there is no dose of 20 radiation so low that the risk of developing a i 21 malignancy is zero, l 22 It is evident also that all persons 23 do not run the same risk of developing a 24 malignancy from a given radiation exposure; and l 25 that the risk of some types of cancer is l
U' ' 71
.1 greater for some people than for others.
2 'The data presented by the NRC 3 concerning risk of exposure to the population 4 by-any disposal method is both controversial 5 . and not acceptable to us. 6 There was, indeed, an air of 7 flippancy ~in the NRC document considering 8 disposal methods. Two of these methods should 9 never have even been considered at all since 10 they are not available: Those include the 11 dumping into the ocean, which is banned by 12 international treaty; and the other is the use
~ .( 13 of Maxey Flats, which as a low-level waste site 14 has been closed because of leakage.
15 When the Nuclear Regulatory 16 Commission discusses dilution as a possible 17 means of reducing population exposure to 10 radiation, many reputable scientists scorn that 19 idea. i 20 In a conversation with Dr. Richard 21 Piccioni, senior staff scientist for Ascord 22 Research of New York, he said, and I quote "On 23 the basis of the~ linear model of cancer risk
' 24 and radioactive exposure, it follows that it i
25 doesn't help to dilute the radioactivity into
,' i 72
.1 the environment. It only allows them," meaning
- {-',' ,
, :2- .the NRC and GPU, "to get below certain 3 legalistic-limits."
'4 ~We.were deeply horrified and insulted 5- - w h e n fD r . Travers at a recent Harrisburg. meeting 6 informed us that this water was not pure enough
, 7 f o r- the' nuclear. power plant's pipes, however, 8 it is being considered to be put into our , 9 environment. 10 It is evident that this document and 4 11 the future disposal of the water needs close 12 scrutiny by independent scientists. I believe !_ ([ 13 this panel must convene before meeting with the
'14 Nuclear Regulatory Commission to do exactly 15 this.
16 If any method is given approval at
- 17 this time, we feel that we are giving GPU 18 Nuclear license to further disregard any I- 19 problems which will undoubtedly arise with this 20 water.
21 We do not trust GPU Nuclear with l 22 preserving the integrity of our environment. 23 Their track record validates our position. 24 Our message to you and the NRC is 25 clear and simple. There must be independent i l
f
; 73 1 <
review of this document, not only'by way of
-( 2 letter to the_NRC but through this panel and in 3 .the form of a public meeting. This 4 organization has independent scientists willing 5 to come forward.
6 We will on no account tolerate this 7 water being disposed of into the water or the 8 air. We need further research and discussion 9 on the method to keep the radioactivity from 10 entering our environment. 11 We intend to use all our resources to 12 achieve the goal of this organization, which is ( ' 13 to see the safe, and I repeat safe, disposal of 14 this radioactive waste. 15 MS. TO!!P K I NS : Betty Tompkins. 16 I am Betty Tompkins and I live here. 17 You are lucky I lost half my notes. 18 If I was convinced that health and 19 safety issues were primary, both with the NRC 20 and GPU Nuclear, I could have attended my 21 Sunday school class teacher's meeting this i 22 evening; however, it is not my policy to deal 23 with convicted criminals or to believe them. 24 I am not a physicist; but more . 25 importantly, I am a citizen of the United ,
'4b sh D-74 1 States of America which guarantees me the right k~ 2 to the pursuit of happiness. For the last 3 eight years, this has been --
my right to such 4 has been denied and it continues to be denied.
, 5 As I listen here this evening, I 6 coul'dn't' help-but be ~ reminded of a court of law 7 where sometimes truth and justice is desolved 8 by how good the two lawyers are. And we 9 heard --
a lot of preparation has gone into it
- 10 by staff people, by paid people. We are just 11 volunteers,-but we have done our homework. I 12 concur with the last two speakers.
- 13 One of the things that really gets to 14 me, and it says right here, is that the TMI 2 15 license currently prohibits disposal of the 16 accident-generated water and will require 17 amendment before any disposal maybe performed.
18- I think the whole -- this is
. 19 premature. There is a lot of homework that
- 20 they have to do and they have not done it.
21 - There is a lot of things that they have to 22 concur with. DOE must give its approval. The 1 23 TMI license does require amending. 24 I cannot understand why a damaged 25 reactor even has a license. That is a real
75
.1 ' puzzle to me. I just don't understand that.
'2 If a person is sick, they are given a power of 3 attorney because they are considered to be 4 incompetent to' manage their affairs. But a 5 n u c 1'e a r reactor can still operate on its same 6 'old license. It puzzles me.
7 There are lots of things that have to 8 be done. The amount of strontium-90 and 9 cesium-137 to be released during evaporation, 10- the amounts are undetermined and will depend, 11 it says in here, on the design of the 12 evaporator and how many times they lift the ( 13 lid, however that does happen. 14 The time for public input on this has 15 been 4f days. It is not enough. I really 16 tried to do my homework. I got this about two 17 weeks ago through the mail. I have read 18 halfway through it and made comments. And for 19 us to -- the public j ust to have 45 days to [ 2p comment is not enough. There is a need for 1 21 public meetings to comment on this and for the 22 public to have adequate input. 23 The Pacific Northwest Institute and 24 the Department of Energy seem to be together. l ([ l 25 There is no -- I don't see any independent
,w ,..,..-n,,-,,,. , ,-,-..-,.,__.--,-. - ,.
r 76
~
~1 surveyor work done here. The tritium k~ 2 concentration in the Susquehanna River was 3 measured ten years ago. There needs to be an 4 ~ update on that. It says that right in here, 5 " ten years ago." It probably has changed.
6 It.says it will be monitored. We 7 have come to realize -- the releases -- h-8 whatever system they go with, they say the 9 release of radioactivity into the air, the 10 water, or anywhere will be monitored. It has 11 been our experience that monitoring is a very 12 loose term unless we sit on them night and day ( 13 to see that they are monitoring it properly, 14 and have the proper things to do it with. 15 I think I said that about the small 16 amount of the cesium and all that other stuff 17 that goes into the air. 18 I don't have very much to say today. 19 I am not a physicist. I said that at the 20 beginning. I am a citizen here. I have 21 studied this for eight yearn. I don't think 22 that it is my responsibility to come up with an 23 adeguate way to dispose of this water. 24 In my innocence, I would say let it 25 sit on-site and decay naturally. I have heard i
77 1 the young lady back here, I think she is I 2 probably a scientist, say they didn't really 3 come up with any one way that was preferable 4 over any other way. I think that needs to be 5 considered. 6 I also believe, I really believe that 7 there ought to be some real concern about the 8 health and safety of the persons downstream. 9 We can't all live upstream. And I don't think 10 that has really been given a lot of 11 consideration. 12 We met with DOE one time. I know ] 13 people who tied up into a lot of this ~ 14 technology, and health and safety doesn't seem 15 to be a primary concern. It needs to be. We 16 live here. 17 And to expedite for the sake -- and I 18 know it has been answered, but not to my 19 satisfaction, that in the expedition of the 20 removal of the water, dollars have not counted 21 into it. I believe it has. 22 So I would ask this panel (1) to ask 23 for an independent study; and (2), to give some i 24 direction to GPU. Not to let -- sometimes it , t 25 is the tail wagging the dog. And we need to be ,
78 1 ..t e l l i n g . t h e m how we would like it cleaned up I ' 2 and what we would'like them to do with our 3 -environment, not just listening to them and 4 letting them floor us with all the technology. 5 I believe, I think I said that I had i 6 an eight-year course and failed it. I would 7 believe if all the panel was given a test on 8 what was said tonight by the experts, I believe 9 that you might get a C or something because it 10 is difficult to follow along with what they are 11 saying. 12 So take that into consideration. Ask ( 13 for an independent study, public hearings, and 14 send them back to the drawing board. 15 THE CHAIRMAN: Did I see a show of 16 hands? I think there are five individuals who 17 would like to speak. 18 Again, to keep the time, to those 19 five or six individuals, if we provide you with 20 five minutes each, that would take us to about 21 nine-thirty. That is about the time we are 22 looking for because there are three other items 23 we need to discuss as a panel before ten 24 o' clock. j 25 Who would like to be first? (Hands l i
.I .
79~ 1 raised.) Y o u ,- sir.
- 2. MR. BROWN: My name is Dick Brown.
I 3 live in Lititz'. I am a science teacher. I 4 have been involved in the environmental 5 movement probably for 20 years. 6 Several years ago I spoke to the NRC 7 representing the Lancaster Environmental Action 4 8 Pederation on our position opposing the restart 9 of Unit 1. I am speaking as~ a citizen tonight. 10 I am not representing any entity except myself 11 and my own experience. 12 One of the things that I found in the ( 13 NRC's presentation that disturbed me was the 14' calling of the tritium, radioactive nuclide. 15 What we are really talking about is radioactive 16 water. The stuff that we are talking about-17 releasing is radioactive water. It is not a 18 little big name thing sitting around just 19 giving off different kinds of radiation. It is ! 20 a water molecule that just happens to have a i 21 hydrogen in it that is radioactive. It is H20. 22 H2O makes up 70 percent of our body 23 and covers 72 percent or 71 percent of the f 24 earths surface. It is found in every living ,4 1 25 thing on this planet. And, yes, there is some
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80
.1 tritium water in-nature. It bas been there for k 2 probably billions of years. But in the 3 ' concentrations we are talking about, it doesn't 4 e x i s' t that way.
5 The problem I have with this release 6 is that the tritium water that would be 7 released or evaporated from this waste would be 8 allowed to enter all of our environments. It 9 would act as all water does. This water would 10 form as dew on the leaves. It would become 11 snow. It would become rain. It would be part 12 of the water of plants as they absorbed it ( 13 after the rain into the roots. It would become 14 part of their system. Every animal that eats 15 that plant would then absorbed that tritium 16 water into their bodies. 17 All of us would eat plants raised in 18 the most productive nonirrigated county in the 19 United States. We would be part of the system. 20 That tritium would become part of the ecosystem 21 of this county or other surrounding areas. 22 It would not go out into the ocean or 23 somewhere else. It would end up, a lot of it 24 would end up here, as the water that is already 25 here. And my concern is that it shouldn't be l
i 81 1 introduced into this system. 2' What should be done, in my opinion, 3 -is.taking the first alternative, which I think 4 is probably in.some respects good; and that is 5 to separate the tritium water and the other 6 water that is not tritium contaminated from the 7 other radioactive materials. 8 That water should not be evaporated 9 into the air but should be distilled. You know 10 what a still is. We simply take the water and 11 recollect it by cooling it. Then we have just 12 the tritium water minus as much of the crap as ( 1,-% . we can get out of it. 14 Then we find a way to take that 15 tritium water and put it somewhere else, but 16 not in Lancaster County. And I think that is 17 what has to be done. I don't believe it should 18 be released in any way, shape, or form in this 19 county, stream, air, or anything else. And it ! 20 , should be taken off site, as should the other 21 waste as well. 22 MR. BRUNS: I am Alan Bruns. I live 23 in Lancaster and teach at Franklin and 24 !!a r sh a ll , teach physics. . 25 I want to second the concern of one
,-w- -
- , _ _ _ - . . - - - ~ , . . _ _ , _ _ _ _ _ , , , , _ , , , , ,._- _._ - < - ,- , -,
82 1 of'the people who spoke of the trans-uranic
~L ~2 elements. Now, that may have been d e a l t: with 3 in another report; but I didn't see it at all
~ 4 in this report, and"I have not read on this S reports. 6 They are produced in large quantity. 7 They were produced in large quantity while the 8 reactor was acting. And all that has been 9 exposed to the water that we are contemplating 10 discharging. 11 To give you some figures that will 12 indicate the severity of this, I refer to a {' 13 book -- well, I can't seem to find it. I must 14 have left it at my seat back there, but I have 15 the figures. 16 It is a book written by four authors 1.7 who are from'the Energy Institute in Palo Alto, 18 so it is a substantive book. It speaks of the 19 dangers in reprocessing materials, which isn't 20 being done now, but in a sense we are dealing 21 with materials in a state which normally would 22 be reprocessed. l 23 The most dangerous is cesium-137 .I 24 But only 10 percent as dangerous is 1, 25 amerisium-241 (phonetic), which is produced in
83 1 'a quite a large amount. And curium-244, which 2 is one-tenth as dangerous as the cesium. 3 Now, the study or the report seems to 4 indicate considerable attention to the cesium
'S problem, but I see no mention of amerisium or 6 curium. Plutonium has a danger which is lower 7 than that.
8 Another way to indicate to you the 9 significance of small amounts of these 10 trans-uranic elements is to give you, out of 11 that same reference again, figures on the 12 concentrations that are allowed for materials. -( 13 Plutonium-239 if discharged into the 14- water is allowed to have a concentration of .1 15 pCi/l above natural background. Now, I don't 16 know whether that is in the direct discharge or 17 after it rumbles around in the river a little 18 bit and mixes up above the dam or not. 19 That converts to .0001 pCi/ml, which 20 is one one-hundred thousandth of the achievable. 21 strontium-90 after retreatment. So we are 22 dealing with figures which are extremely small 23 for these alpha remitting trans-uranics T 24 compared to cesium, strontium, and tritium, k 25 which the report addresses.
s. 84 1 Again, to give you a feeling for how 2 tenuous that concentration is, you get ten to 3 the minus four pCi/ml if there is but one atom
- 4. in ten to the sixteenth plutonium. If it is 5 discharged into the air, that same table in 6 that reference which I can supply, it says that 7 you can have a level of two times ten to the 8 minus ninth pCi/1 of air. That is unbelievably 9 small.
10 I don't know what that converts to in 11 terms of concentration, but it is certainly 12 infinitesimally below parts per million. (. 13 So I just want to give you those 14 figures as a way of trying to impress upon you 15 that what this other person said, who is not a 16 scientist whatsoever, I think has behind it 17 some concerns that bear out the request to get 18 definitive statements on what is the 19 concentration of the trans-uranic elements that ! 20 we are dealing with. 21 MR. MANIK: I am Al Manik. What I 22 want to state here is I did some research and I 23 was quite concerned. 24 I would like to help the good people 25 in Lancaster County and Dauph.in County get rid
~ .e );
,e , 85 1 of-this junk. I went to Manly-Regan Chemical
' ~
2 Com pa ny . 'I was concerned. They were shipping 3' chemicals ~in and out almost every day. They 4 are a' pretty. busy outfit. They are not real 5 big,-but they are busy. 6 I stated to them that I had a 7 problem; that if we shipped this material out 8 by railroad. tank cars, how would it go. They 9 said one tank car carries 10,476 gallons of 10 water. So may be we need 200 tanks cars, and 11 everybody in Dauphin County. and Lancaster 12 County would be real happy. ( 13 In case anybody wants that again, I 14 will give it to you, or you can call up any 15 chemical company and they will tell you what 16 size tank cars they are using and what sizes 17 are available, or you can call the railroad 18 people for that matter. 19 Thank you. 20 MS. DAVIS: My name is Beverly Davis. 21 First of all, I think one of the main 22 problems that people have with this plan or any 23 . other plan is that we do not trust, as has been t 24 mentioned before, the inventory of what is . 25 actually in this water.
86
. .l' When it has. washed against the fuel 2 in the reactor coolant system for~some years 3 here, it seems unbelieveable that there are
~~4 only seven elements that were not able to be 5 filtered out of it. Just one resource that I 6 read said 36 elements, and that wasn't even 7 counting trans-uranics, would be manufactured 8 in there, in the process of creating 9 electricity.
10 Another thing that we do not trust is 11 the f a ct 'tha t, even though we are given these 12 as absolute figures, it appears that we have { 13 only monitored and have only filtered or tried 1,4 to filter certain things. The SDS system has n 15 worked hard at getting cesium. The Epicore 16 worked hard at the strontium. Therefore, we 17 seem to have good figures at cesium and 18 strontium. 19 I am wondering if there are a lot of j 20 other things that we either do not have the 21 technology for or simply have not been listed 22 that should be included. 23 Another thing that we have a problem 24 with is the sources of all the water. We keep 25 hearing about outfall, and maybe that is only
- . 87 l' the water which comes from rain which is I 2 .collecte'd in potholes on the island. I am not t.
'3 'really convinced that is the only kind of water-4 that is coming out of the outfall.
5 The additional water which would be 6 used at the end of the time process, which
.7 would be in the fuel canal, I am not sure 8 whether that water is included in what we are 9 talking about or not. That would seem to me to 10 be highly contaminated water. The water which, 11 I believe if I am not mistaken, is now over 12 sludge in the basement in order to contain the
( 13 radioactivity, is that water included in this 14 inventory? We are not sure that all of it is 15 being trapped by tne filters, as I said before. 16 Going back and reading some of the 17 earlier drafts and reading some of the earlier 18 information, it appears that there were fines 19 which are not filterable. One of the reasons
.20 that they were not able to be filtered is they 21 clung to boron in the waters and they, 22 therefore, were not separated by the normal 23 natural processes that were being used.
24 I was also told at least twice here 25 that trans-uranics were not soluble.
r . L l 1 88
. i
. 1 Therefore, we didn't need to worry about those j
- ~ , - ,
i s 2 being' steamed out of the water, yet I read that 3 there are different kinds of trans-uranics. 4 I don't know which trans-uranics are
- 5. contained within here, whether they are all 6 actually nonsoluble or not; but I understand 7 there are different kinds, some are more 8 soluble than others. We have not received all 9 of the scientific studies which might bear on 10 the release of what has already been delivered 11 to us from this plant.
12 For instance, the Public Ilealth Fund
.( 13 has never r e l e a s e'd the study by R. Patrick, as 14 far as I know. That was supposed to be giving 15 us accurate information or up-to-date 16 information, as I understood it, about what 17 might have gone through the food chain or might 18 have been in the sediment i n the river.
19 What we have already gotten has got 20 to be considered in this. And I think that 21 that is one of the things that bothers people a 22 #41ot, is that there has never been any kind of a 23 definitive cumulative total given of what we 24 have already acquired as a public from this 25 . plant. w-- -- , , . . , . , . _ , . - .
, . , _ - ,--.y --,,-,---.,--._-y ,.~,_-___,-__.-,..,v. . , , . _ _ _ - - - _ _ .,
, Yy -
89 We keep saying, Well, this'is just a
'1 l ,' -2 little bit more. We don't mind adding a little 3 -bit'more of this and a little bit more of that.
4 The public does'not feel very secure about that 5 because we feel that the cumulative dose adds 6 up to a lot more than these minuscule doses 7 that people keep talking about. 8 We don't trust GPU that they could 9 deliver any kind of a release of anything. 10 They have not been able to be trusted to do 11 anything right up to this point. They always 12 make mictakes. They always have technical l 13 difficulties. I don't think anybody in;this 14 public trusts them to do anything in terms of 15 even the release of what you are saying is a 16 very low level of radioactive water. 17 One of the things which is not 18 included in the report which bothers me alot is 19 that there i s no evaluation in the 20 environmental section of the report on the fact i ! 21 that this is a closed-air basin. I don't know l l 22 what the technical term is for it, but I know 23 that a certain burning is prohibited. I know r i 24 that we have many inversions. . I 25 I know that along the river we are ,
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90 4 I subject to fog. I know that from reading some ( 2 others things, that the aerosol effect of 3 radionuclides being injected is maybe different 4 in a biological sense than to simply receive 5 them as particien or as air gases. 6 Mainly, I think the biggest thing is 7 that people are concerned here that you have 8 not evaluated the effect on people. And I 9 don't mean in terms of taking a technical 10 reading of what radionuclides they might absorb 11 through this. Ih tih a t we are talking about is public ( 13 policy. And if I may give you a very crude 14 simile on this. I have a septic tank in my 15 backyard. And when it fills up after ten years 16 or five years or whatever, I have someone come 17 in and pump it out and take it away. 10 I can live with that septic tank full 4 19 or empty in my backyard and with the , 20 possibility that it might leach. But I cannot 21 live with the possibility that someone is going j 22 to take a bucket and dump it over the head of 23 everybody in my family. I think that in the 1 24 way the people in this area feel. 25 They feel that when the krypton was
91 ) 1 vented out, the public policy had not up to 1 2 that ~ time said -- they had said that there were 3 caustics, there were chemicals, there were 4 things that might leach, there were things that 5 might accidentally escape. There could be all 6 sorts of transportation accidents. 7 But for the first time in my 8- knowledge, or in my experience, a whole public 9 was told that we are going to give it to you. 10 We are going to push it down your throat. We 11 are going to give you toxic material, which we 12 agree is toxic, which could be detrimental to (' 13 your health. And we are going to give it to 14 you because we want to get rid of it. We don't 15 know what else to do with it, and we are going 16 to give it to you, the public, and let you 17 absorb the dose and then figure out the 18 consequences. 19 I think that is despicable public ' 20 policy. I think that is what is happening l 21 again. And I think that is what is bothering 22 people, more than even knowing whether there i s 23 very much radioactivity in this water or not. 24 It is the insult to the population that is 25 being told we are going to dump some more junk
- , , - , - . ~ . , . - --._--.-,n-,. - , - . . , ,-------..--n---- , - , - , _ , . , , - ,.a, , , - - , - - - - - - - - -
rc i l 92 1 o n' top of you.
'k . 2 We don't know what we have gotten 3 already. We know that we have al r ea dy been
~4 exposed to this at least once, this kind of 5 public policy. We have another dose coming at 6 us, and people are saying, Don't worry. It is 7 fine. Nothing to worry about.
8 I believe that the public would react 9 most. favorably to leaving that water on-site in 10 tanks where it is contained. It is not being 11 dispersed. It is not being evaporated. It is 12 not being put down the river. It is not being ( 13 put in their drinking water. It is being
, 14 contained.
15 I resent that in this report and also 16 in the report that was given the other night, 17 that there is an adjective of "merely." We 18 would merely hold this on-site, as if there was i 19 nothing to be gained by holding this on-site. 20 As I read the half-lives of the i 21 elements which are listed by this report -- 22 THE CHAIRMAN: Excuse me, just to be 23 fair, I am cutting in here so I can explain. 24 You are up to eight or nine minutes. And the ; 25 reason we do this is, if you need more time i
- , - _ _ ,~._ . _ . ~ _ . . _ . _ . _ , - ,_... _ __ __ _ .__..._. _ ___ _ _ _ __ _ _,__ _ ._. -
P 93 1 than five minutes, we ask you to call and k 2 ' contact us and we will give you that. We did 3 give it to people who did call.
.4 It is important --
I know I see 5 people. shaking their leads, but in order to 6 give everybody an opportunity tonight and to 7 conduct some additional business, we have to
- 8 have some time sequence.
9 MS. DAVIS: One-half a minute. 10 . The greatest half-life that I 11 ' understand in the elements that are listed in 12 30.2 years. l( 13 Apparently the license allows at l 14, least for this to be stored through the 15 half-life of the most dangerous or the most 16 long-lasting element that is in here. There 17 would seem to be a great deal of advantage to 18 that. 19 If you have to come along and pump 20 out the septic tank at that point, that is 21 another problem that somebody maybe can take 22 care of. But until that time, I am very happy 23 to have it sitting there in stainless steel 24 tanks. . 25 The only difficuir'.es that I would , 4
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't 94 4.,
1 see with that is the danger of floods, the I C 2 dangers of ice jams, which Jeff Minik evaluated 3 and nobody else has evaluated in any of these 4 things in terms of what is happening on the 5 island. Those are the only problems. 6 There is one little thing in the 7 report that says something about the vents in l8 the tank allowing evaporation to occur from 9 these tanka, even if they sat there. That 10 bothers me a lot. 11 Dut there seems T#o be very little 12 against it. This panel has two missions, an I ( 13 see its one of the missions is that a lot of 14 you on here are scientists, very distinguished 15 acientists with a background of solid 16 scientific information. We depend on this 17 panel to give us that third-party scientific 18 background to educate us and to ask the hard 19 questions of the people that come forward. 20 The other thing we depend on the 21 panel for is to convey and to establish public 2 policy. And I would hope that both of these , 23 things would be addressed by the panel. 24 MS. DAVENPORT: I am Debra Davenport, 25 Concerned Mothers and Women.
T '
, 95
,. ,,1 I just wanted to briefly say that I
( 2 am also definitely thinking that this should be 3 retained on the site temporarily, for a period 4 of years, perhaps, until some other sites can 5 be determined or a way to transport that water 6 out of there can be thought about; or it should 7 be taken to Nevada, which is clearly cheaper 8 than evaporating waste on-site. 9 And in reference to that, I do have 10 one question. Why evaporate and what will thin 11 cost? What will it cost to run the heaters? 12 And who vill provide that energy? And what { 13 will that cost? Will it cost the consumers? 14 MS. HUNSON: The estimated cost for Il the entire evaporation option, and this is a 16 relative cost, is between $6.2 million and $12 17 million. 10 MR. TRAVERS: In answering the 19 question about who pays for it, I don't know. 20 I don't know the answer to that. You would 21 have to ask the Public Utility Commission. 22 MS. DAVENPORT: So there is some 23 possiblity that the consumers would have to pay I 24 for that? 25 HR. STANDERFER: The monies for the
- - . - . - - - - , - - . , ,--..w , - - - - - - , - ~ - . - , - , , -- ------,--,~,,--n-, --- ---- --vr- , , - - - - - -
4 96 l' evaporation of the water are included in the 2 . current total estimate for the cleanup. 3 It would be covered within the 8965 4 million which we have set as the cleanup costs. 5 So they are budgeted. 6 MS. DAVENPORT: That's all I wanted 7 to know. 8 MS. SHIVA: Elizabeth Shiva 9 (phonetic), I live in Middletown three miles 10 from T!! I . I would like to speak on behalf of 11 the Concerned Mother's and Women and my many 12 neighbors who were not able to be here tonight.
~
( 13 First of all, we do not have any l 14 faith in GPU, their directors of the cleanup, 15 and the same loss of faith in Hilliam Travers ) 16 of the NRC. We do not believe their quoted ' 17 figures of percentages of radioactive doses to 10 be released during the venting over an 19 excruciating two-and-a-half-year period. 20 How can they know the doses that will 21 be released when they don't even have an idea 22 of the amount of molten waste or a way to 23 remove it? We have much less faith in the f 24 so-called facts and figures spouted off to the 25 press by Gordon Tomb and Lisa Robinson. They
i I 97 1 are wasting'their breath and 'our time. l', 2 would like to know if Gordon Tomb's
-I 3' and William Travers' families will live in Middletown or the surrounding areas during the 4
4 5 two-and-a-half-year venting period? 6 How dare you do this to us. My God, 7 do we have'to live through this for another two 8 and a half years? 9 MS. RODB: I am Doris Robb. 10 The last time I addressed this group 11 I had asked a question of you, Mayor Morris, 12 about the monitoring system for the water in
~
f 13 Lancaster. At that time you told me to contact
-14 Michael Friedman, whom I did, and ask him
. 15 questions about the type of system that we do 16 have in place. That was the system that we a 17 received in Lancaster following the suit that 10 we had against GPU Nucl ea r after the accident 19 at Three Mile Island. 20 He told me at that time he was not 21 able to find out the name of the system, and + 22 that didn't really make any difference to me. ! 23 I wasn't really concerned about that. But I 24 did ask him what the system was equipped to , l 25 monitor. And he said it is a gamma monitor. I I l .-
m
- 96 1 I notice from the presentation
}. 4 2 tonight that tritium and strontium are both 3 beta emitters, and that also strontium is a 4 beta, as well as a gamma, emitter. And so I am 5 very concerned that Lancaster County really 6 doesn't know, or the City of Lancaster, doesn't 7 know what may be coming from Three Mile Island 8 in the way of beta emitters coming down the 9 Susquehanna River. 10 THE CHAIRMAN: Are there any other 11 comments from the public? We still have a few 12 minutes. Is there anyone else who would like } 13 to speak? 14 MR. RESH: I am Brian Resh. 15 Pirst off, I would like to express my 1h total disdain for the condescension shown the 17 public by GPU and the NRC. 18 And my very brief question concerns 19 the s965 million projected cleanup cost, and 20 exactly how much of that will be borne by the 21 consumer, the rate payer or both? 22 I believe the spokesman from GPU has 23 the answer to that. 24 THE C H A I R il A N : Mr. Standerfer, could 25 you respond to that?
, I l
l 99
~
1 MR. STANDERFER: That portion -- that l 3 2 'n i the Thornburg Plan, and about $200.million 3 is borne by the consumers in New Jersey and 4 Pennsylvania.
. 5 THE CHAIRMAN: If there is nobody 6 else who wishes to speak, Betty, you are free.
7 MS. iC::eKINS: Betty Tompkins. I 8 would like to speak about the water of the City 9 of Lancaster. I will speak now for the 10 locked-in poor citizens of Lancaster City who 11 drink that water and cannot afford bottled 12 water. f 13 I have in the past c o n t a c t e d !! r . 14 Friedman about the water, and I had a statement 15 mailed. I am not technically thinking right 16 now, but what Doris said is absolutely right. 17 The City of Lancaster is not 18 presently monitoring for these elements that we 19 feel might be coming down from Three Mile 20 Island. And so I ask you, as mayor of 21 Lancaster, to look into that. 22 THE Cl! AIRMAN: The City of Lancaster 23 has equipment at the plant site that does -- we 24 do run tests on a daily basis. And in addition 25 to that, I don't know if Bill Kirk is here and l
o
' s: . , . 100 1 can speak to the fact that there are tests run k' '
2 separately from the city on the water at the 3 plant that we receive. 4 MR. KIRK: Bill Kirk. There is no 5 good way to monitor beta on-line. There is a 6 sample taken. As I recall, every hour or two 7 there is a slug put into a jug and we get that 8 weekly and analyze that, including tritium and
~
9 strontium. 10 There is a continuous sample taken 11 from the discharge at Three Mile Island. That 12 is monitored on a daily basis, analyzed on a ( 13 daily basis for tritium and on a weekly basis 14 for strontium. And we are monitoring it at the 15 source. 16 MR. WALD: Isn't there also a 17 requirement of the EPA under the Federal Clean 18 Drinking Water Act that the drinking water of 19 any public purveyor of water to the public be 20 monitored for all alpha, beta, and gamma 21 radiation? 22 MR. KIRK: Right. The clean drinking 23 water standard for tritium is 20,000 pCi/1, 24 which is very much higher than anything we ever 25 deal with here.
101 1 THE CHAIRMAN: I think what needs to (: 2 be remembered is the test we run is a daily 3 test with information available right away. 4 The tests that are run why EPA take a
$ longer ~ period of time than that. And we don't 6 get those results for several weeks following 7 the tests.
8 We have not had a test that has shown 9 positive, however, since the beginning of the 10 p r o bl em in 1979. 11 HR. KIRK: I think there was one 12 sample in eight years that bearly exceeded the 13 detectable limit. And that was 350 or 400 )( 14 pCi/1 several years ago for one day. 15 And other than that, it was below the 16 Jetection limits in the order of 200 or 240 17 pCi/1. 10 MR. GERUSKY: Of tritium? 19 MR. KIRK: Yes. 20 THE CHAIRMAN: Again, the 21 understanding when we received the equipment 22 was we would have equipment that we could use 23 with our own plant personnel on a daily basis i 24 that would give us a very quick verifiable . ( - 25 feeling of an immediate problem.
~
- i. .
102 l' That is what we are doing. We have a { '2 backup.with EPA, but it takes a longer period 3 of time to get that information, but it is 4 checked. 5 g MS. SKOLNICK , Is that for all three 6 types of radiation? 7 MR. KIRK: The analysis includes'a 8 gross alpha and gross beta analysis, and 9 cpecifically a tritium, and an alaquat 10 (phonetic) is analyzed for strontium. 11 Dasically we take a piece of each 12 daily s a m p 1' e for a week and analyze the weekly ( 13 sample for strontium. 14 11 S . SKOLNICK: It is my understanding 15 from different scientists that it is extremely 16 important to understand that alpha radiation 17 can only be picked up by extremely, 18 sophisticated alpha monitors. 19 I think what we are trying to point 20 out tonight is, Do you look for gamma radiation 21 with one type of monitor? Do you look for beta 22 radiation with another type? And do you look 23 for alpha radiation with another type of 24 monitor? 25 HR. KIRK: Certainly. That is the
3 A q ;_ 103* 3: ' I o n ly : w a'y to do it. Nl 2 MS. SKOLNIK Can you write down the 3 names of the kind of monitors? 4 MR. KIRK: I will be happy to talk 5 with you. I can give you generic answers. If 6 we get down to specific instrument types, then 7 we have to get the particular instrument that 8 is being used. 9 I don't normally carry mark and mode 10 in my head. 11 MS. SKOLNICK: And I would like to 12 find the number of times during the month that
;[' '
13 each particular radiation type is looked for. 14 MR. KIRK: If you would look in the 15 Long-Term Monitoring Plan, which has been 16' published, there is a schedule of all the 17 analyses which we do in that plan. 18 As far as the results are concerned, 19 we have published the result of our tritium and l 20 air analyses. We have not specifically 1 ( 21 published the results of most of our water 22 analyses, because they have been negative. 23 There hasn't been anything to publish. 24 The State has pubilshed the gross 25 alpha and gross beta and tritium readings from
1. 104
'1 all of the-samples in .their yearly report, in
(' .2 their annual monitoring report. The alpha and 3 beta and tritium numbers have been published to 4 '85. 5 MS. SKOLNICK: When you said 6 "nothing," do you mean zero or do you mean 7 below the detection limits? F. 8 MR. KIRK: Below the detection 9 limits. And we have given you the detection 10 limits for the different types of analyses, I 11 believe in the monitoring plan. I know for 12 gamma we have and for tritium. (~ 13 T!! E CHAIRMAN: Is it possible for you 14 and Francis to talk about this either by 15 telephone or after the meeting? Can you 16 provido her with the information that she is 17 requesting? Is that okay? 18 !! R . KIRK: No problem. 19 THE CH AIR!! AN : This will be the last 20 question. I hope everyone stays for the panel 21 discussion because it will involve how we will j 22 proceed on this particular question into the l 23 future. 24 I think that might be helpful for you l (T 25 to hear.
r,; 105 1 A SPEAKER: It is my understanding
'2 'that at t'h e end of '87 the EPA will be phasing 3 -out their monitoring; that that is the plan for
-4 concluding the cleanup.
5 My question is, if EPA will be 6 leaving at the end of '87, who will be 7 continuing to monitor, particularly if the 8 waste water is dispersed in some way throughout 9 the atmosphere or discharged in the river? 1,0 MR. KIRK: The long-term plan that we 11 had proposed perhaps several months ago calls 12 for some of these things to be taken aver by ( 13 the State of Pennsylvania, the Pennsylvania 14 Department of Environmental Resourses. 15 He had called for in that plan to 16 find out certain types of monitoring when the 17 fuel was canned up and ready to ship, and other 18 types at the time it has been shipped. 19 I am sure you realize what happens in 20 the Federal Government when budget time comes 21 along. Everyone gets uncertain for another 22 year. My guess on whether something that we 23 have set forth as a plan this year will 24 continue to be true two years from now is as . 25 good as yours. ,
, V 106 1 I at one time would have sworn to it
- { 2 and other times I won't not swear to it. It 3 depends on what state is of the budget process 4 we are in. I have been wiped off the books 5 five times in the last seven years, and we are 6 still here.
7 A SPEAKER: So there is a possibility 8 of future monitoring? 9 !! R . KIRK: Beyond the shipping of the 10 fuel, there are no plans for EPA to continue 11 opecifically monitoring here. 12 EPA does not have any legal mandate
](' 13 to monitor around operating reactors. Once 14 that cleanup has been finished, our role here 15 is done.
16 T!! E Cil AIR M Ati: Thank you. 17 If I could at this time turn the 18 panel's attention to a discussion of how we 19 proceed on the water issue. And I guess there 20 are a couple of different items that are going 21 on at this particular time. 22 One is the Supplemental EIS and the 23 other is the plan that has been put forward by i f 24 GPU on a specific recommendation, and that is il 25 evaporation. i 1 - . - . - . _ - - _ - . - - - - - - - --.
107 l 1' Just let me mention at least at this 2 point, I too feel'that the 45-day comment 3 period is not going to work out given the fact 4 that, in my mind, we do need at least another 5 meeting to discuss this issue. It would really 5
'6 depend on what we can accomplish at that 7 meeting as to whether there would be a need for 8 additional time to talk about it during the 9 draft period.
10 So it seems to me that one the items 11 we probably should talk to the NRC about in our 12 February meeting is some kind of an extension ( 13 on the comment period. 14 But beyond that, how do you see 15 proceeding? Another meeting to allow us to 16 maybe go through the transcript? 17 MR. MASNIK: I think the Commission 18 on that February 26 meeting is looking forward 19 to the panel's comments on the water issue. 20 So perhaps one of the ways we can do 21 it is to have another meeting at the beginning 22 of next month. 23 THE CHAIRMAN: I understand that they f 24 are looking for comment from'uA an'dI don't see ,l i 25 any reason why we can't give them comments. _ _ . _ , - - _ , . _ _ _ . , . - . _ _m-,_-. _ , , . , - _ . _ . - - _ , . _ _ . . . _ . -._
, 108 1 I feel at this point that comments
(- 2 are ~ one thing and some kind of comment as to 3 whether we agree with a certain option is 4 another. I am trying to be practical about it. 5 I don't feel we are going to be in a position 6 to do that come the 26th of February. 7 We could schedule another meeting. I 8 would be happy to have us do that. That was 9 the last item I had for the panel, but let's 10 talk about it. 11 Do you feel we should have a meeting 12 before the 26th to further discuss this topic; ( 13 and if so, we can decide at that point as to 14 what detail we need to go into it with the 15 Commission. 16 MR. ROTH: Why the need for the
- 17 February 26 meeting with the Commission at this 18 stage? I guess.I am perplexed on the 19 Commission's timing.
20 MR. HASNIK I think the reason is 21 that the Commission had originally wanted to 22 meet with the panel on the order of three timec 23 a year, three or four times a year, f 24 We have not met with the Commission b 25 since the middle of last summer. And really we
109
;l probably should have met with them towards the 2 end of 1.a s t year.. So we are sort of behind.
3 TII E CII A IR M AN : I really look at this
. 4 as a regular update-type of meeting with the 5 Commission, one that we really shouldn't feel 6 obligated to speak to any particular issue 7 unless we are directed by the Commission to do 8 so.
9 I expect that and feel we should 10 speak to the water issue in some form. As to 11 how we will do that, I don't know.
-1 2 MR. G ERUS KY : Can I suggest or
'13 request the Chairman to write to the Commission 14 requesting-an extension of the 45-day period?
15 I don't feel that is enough time for us or the
~16 public to make adequate comment.
17 Til E CHAIRMAN: Do you have a 18 suggestion on that? What kind of extension do 19 you suggest that we ask for? j 20 MR. G ERUS KY : Thirty days. Well, 45. 21 Make it 45 so it is a total of 90. l 22 THE CHAIRMAN: Any objection? 23 (no response.) I' 24 MR. G ERUS KY : Do you want to vote on . -( 25 this or not? ,
. c w.
110 li T!! E Cil A I.R M A N : I think we have a
, - 2 consensus that we will do that.
'3 , f R. G ERUS KY : I have the same feeling 4 that the'public has concerning, not the EIS, L
-5 but the documentation behind the EIS. And 6 there is a lack of information available to us 7 to make a proper decision on any proposal.
8 I think we need much more detailed 9 information from both the Commission and the 10 utility before we can even expect to comment to 11 the Commission on this issue. 12 I think at the next meeting (1) we f(- 13 chould get more detailed information ahead of 14 time and (2) we should have the technical 15 people here who proposed or who worked on the 16 draft, on the documents, both the submission to 17 the NRC and again, I'm sorry to say, asking the
.18 lady to fly in from Washington so that we could 19 do a much more detailed review.
20 I d o n '.t think we have the time to 21 even review it ourselves. And I have questions l 22 all over the place that I want answered, but 23 the resources aren't there yet. 24 THE CHAIRMAN: Tom, on the more 25 detailed information needed, do you have
111-1 something that you could request at'this
.{
~
.. :2 particular time?
3' MR. GERUSKY: No. I would like to 4 see what was submitted again. I would like to 5 take a look'at it. 6 THE CHAIRMAN: So you are really 7 saying we need more time'to review the 8 information we were provided? 9 MR. GERUSKY: I am not sure what we 10 were provided because I get mailings from about 11 four different sources. So I am not sure what 12 comes to me as a committee member and what { 13 comes because it is a state agency. So I am 14 not sure what the committee has received. , 15 Did we get the application? 16 MR. MASNIK: The original proposal
'17 from the licensee you received last July.
18 MR. GERUSKY: And nothing since? 19 MR. MASNIK: You got the response to 20 some questions that the NRC asked of the 21 licensee and the PEIS. 22 MR. GERUSKY: Is there anything else 23 that was -- the correspondence, documentation, f I 24 and so forth that was submit'EE['to ihe 25 Commission staff that we didn't receive? _ ., _ 1 __ .._ _. -
112 1 . MR. MASKIK: Between the licensee L 2 an'd --
~3 MR. GERUSKY: Yes.
4 MR. MASNIK: No, there was not, there 5 was nothing else submitted. 6 Til E CHAIRMAN: Might I suggest this, 7 I am pretty sure I have in my hands the GPU 8 submission. But it may not hurt for the panel I 9 to get the mailing of that and the questions 10 again so that we don't have to search and some 11 of us not find those pieces of information? 12 I believe that everybody has the EIS; ( 13 if not, you might mention to Mike to'get an 14 extra copy of it. In fact, there are copies of 15 that here that you can get before you leave. 16 So if we could get the information prior to 17 that submission, it would be helpful. 18 Is it possible to have technical 19 people present, or Linda could you make it to 20 the next meeting? Is that possible? 21 MS. MUNSON: A date would be helpful, 22 but I imagine so, yes. 23 THE CHAIRMAN: How about the GPU f 24 people? Can we have the technical people b 25 .present?
4 113
'l UR.-STANDERPER: I can have anybody
- { 2 .here who you would like.
3 THE CHAIRMAN: When would you like to 4 meet next?
.5 MR. GERUSKY: Maybe we can postpone 6 the meeting for the Commission for a month.
7 If' we are going to have to comment to 8 them and we aren't going to see them again for 9 another six months or nine months, I think we 10 better make sure the next meeting with the 11 Commission is a solid one. And I suggest 12 postponing it until after we have had a chance f( 13 to review. 14 THE CHAIRMAN: If we get the 45 day 15 approval, when wculd the 90 day be up? 16 !!R . MASNIK: First of all, I don't 17 know whether or not 45 days is -- there is 18 provision within our regulations for an 19 extension of the comment period. 20 I am not certain that 45 days is a l 21 number that is, I wouldn't say allowed, but 22 normally given out. That is something I would 23 have to check. 24 THE CHAIRMAN: I feel comfortable , 25 that we would get it. I just have to feel that ,
f - 114 1 we do not ask a lot of times for special 2 extensions and I have to bel'ieve that on this 3 issue, being as important as it is, we will get 4 it. 5 If we would get it, just assuming
*~
6 that they approve it, when is that 90 days up? 7 MR. MASNIK: the comment period has 8 been set to end the 28th of February, so 45 9 days would put that into the middle of April. 10 THE CHAIRMAN: What we need to be in 11 a position to do here is we need to have met 12 with the NRC, I believe, prior to that date. ( 13 We. don't want April fools, I don't think. 14 Could we check with the Commissioners 15 to see if we can change that date to sometime 16 in early April? 17 MR. MASNIK: I guess if the panel is 18 not prepared to talk about the water issue, we r 19 really haven't any substantive issues since the 20 last meeting to talk to the Commission about. l- 21 The issues that have been presented 22 since the June meeting have been the water 23 issue and have been the licensee proposal for 24 long-term storage at the facility. And I don't 25 believe there is really much comment on that
I n l
- j. . .
115
'l issue, kt ;2 So I guess I will attempt to have the 3 meeting changed to early April.
~4 THE CHAIRMAN: I will send a letter 5 to that effect with the request for the 45-day 6 extension and, hopefully, we will get support 7 on their behalf.
8 When do you want the next meeting? 9 MR. MILLER: February 26. 10 THE CHAIRMAN: How does Februar'y 26 11 suit the panel members? 12 !! R . GERUSKY: I would suggest that we ( 13 start during the early afternoon. I don't 14 think -- people 'are tired really at this time 15 of the night. IIwould t like to start fresh. 16{ Til E CHAIRMAN: What time? 17 MR. G ERUS KY : One o' clock. 18 THE CH AIRilAN : What is the reaction 19 from the public? I see one person going like 20 - this (thumbs down). 21 How many people have problems with an-22 early afternoon start? (Hands up) It is 23 important that we have the public present and , (I 24 able to discuss this issue. ..How about a later 25 afternoon start, more like a three o' cl oc k time
116
~1 or something like that?
2 I 's a w people.here shaking their heads 3 when I was trying to be pretty tight 4 schedule-wise. There is one way to relieve 5 t h a t., and that is get going earlier and allow 6- more time for the meeting. 7 I. don't think starting at seven and 8 allowing five or six hours makes sense. Three 9 hours is the limit. And the question is from 10 the panel's standpoint, I guess, we do want to 11 have citizen input; but I would be inclined to 12 say, l 'e t ' s at least get going in the afternoon ( 13 sometime. I think one o' clock maybe early if 14 we want to have citizen involvement. 15 !!ow about three o' clock or four 16 o' clock? 17 MR. GERUSKY: Then you have the 18 dinner break problem. 19 THE CHAIRMAN: We could break for 20 dinner, I guess, and conclude earlier. We 21 could brown bag it. Let's try for a three 22 o' clock meeting. 23 MR. GERUSKY: I just think we need f 24 longer time and we need to be more fresh than I 25 coming in at seven o' clock in the evening. 1
- . -= .
x- . 4 117 1- MR. SMITHGALL: ' Fla y b e we should do , 2- whatever de' liberation we want to do in the 31 afternoon and break for-dinner and come back 4- and have public' comment for an hour and a half 5 or two hours. 6 'MR. GERUSKY: Except some of the 7 questions the public would have maybe answered, 8 or they may have additional questions as a 9 result of our questioning, so I don't think
. 10 that is fair.
11 If the public can't be present, I 12 think it is a waste of time. ( 13 THE CHAIRMAM: Let's plan on meeting 14 somewhere around three or three-thirty on that ik day. We will go for a couple of hours. We 16 will break for about an hour or so and we will 17 reconvene the meeting for several more hours 18 that evening. 19 We will end up concluding -- and Niel 20 is about-to say we shouldn't do that, but we 21 will end up concluding that meeting about 22 eight-thirty or nine o' clock. 23 MR. WALD: I just wanted to request , 9 I 24 that we stick to the Wednesday rather than . 25 Thursday.
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l' Okay, .then, how is 2 Wednesday?
~
. 3- .M R . WALD: I would prefer Wednesday.
4 THE CHAIRMAN: I think the idea of 5- going with Thursday on this time is a pretty 6 good one, because we have already set that time 7 up. 8 !!R . S MITilG A LL : That was only this 9 evening that that was set up. 10 Til E C il A I R f-I A N : I can make it either 1 11 time. Who can't make it on Thursday? 12 ( Il a n d s . ) Three people. 13 THE C il A I R f' AU : !!ow about Wednesday? 14 (Panel discussion on day.) 15 Tile C H A I R f1 A N : Who cannot make it on 16 Thursday? 17 FI R . ROTH: I can't. 18 T il.E CHAIRMAN: Possibly one or maybe 19 two; and Wednesday again is at least two or
- 20. three.
21 ~ Thursday is the best day. So I think 22 we go for Thursday. We begin the meeting 23 something like three-thirty, and we will go to (' .l i 24 five-thirty or six o' clock. He will refine 25 that-and break for an hour and continue to
N 139 1 eig'ht-thirty or nine o' clock.
- k 2-
~
We_will have the meeting in Lancaster 3 on,the 26th and st'arting at three-thirty in_the 4 afternoon. 5 MR. S!!ITHG ALL: Can the panel, or do 6 we want to call in any other people?
.7 THE CH AIR!: AN : We can talk about that C now, if you want. I think that maybe something 9 that we will --
we will have time to talk about 10 that at the next meeting and hold a meeting in 11 March. 12 MR. SUITHGALL: When do we want what 'k._ 13 night be' considered independent people to come 14 in and speak before the panel, as was suggected 15 here tonight. 16 Ti1E CHAIRMAN: Any comments from the 17 panel? 10 !!R . MILLER: We really don't know 19 what questions exactly we are going to have, so 20 it would be hard to invite someone in and tell 21 them what we want addressed unless we know 22 ourselves. ' 23 MR. SMITHGALL: I guess the next r ,( 24 question is, do we want to bring in indepenfent 25 people; because if we do, it might not be a bad
4 s 120
'l idea tofatart planning that if we are going to 2 start talking to people.
3 THE Cil AIR M AN : Tom, what I heard said 4 was that we don't know that yet.
~
5 I agree with you that the problem 6 will be if February 26 we feel we need 7 somebody, we are not going to have much time to 8 bring somebody in, but I think that is 9 unavoidable at this point. 10 Is there anything else that we need 11 to bring up tonight? 12 !! R . R O T !! : I would like to thank the ( 13 public for showing up and speaking as they did 14 tonight. It was nice-to see. 15 MR. SMITHGALL: Yes. 16 MR. GERUSKY: I would like to reoues: 17 before the next meeting from GPU a complete 18 analysis of the water, the last analysis they 19 did of the water that they are now talking 20 about that will be cleaned up, including the 21 sensivities of the instrumentation and the 22 minimum detectable levels. Everything that is I 23 in there. I ( 24 THE Cil A I R t!A N : Any other comments 25 from anybody? J. - . _ _ _
~
121.
'l' i would like to thank the public for 2 att'ending-and hope.the attendance at the next 3 meeting dollars is just as large as it is - 4 toni~ght.
5
.6 (Hearing adj ou rned at 10:00 p.m.)
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r. 121 1- meeting dollars is just as large as it is ' - '2 tonight. i 3 (Hearing adj ou rne d at 10:00 p.m.) 4 5 6 7 8 9 10 11 12
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-SEM1E1. CME I hereby certify that the proceedings are contained fully and accurately in the notec taken by me during the hearing of the foregoing cause, and that this copy is a correct transcript of the same. .
IO $ Gwen A. Leary, Reporter Notary Public 8 l l s
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MI Ua n Tunct MILE CLAND ALERT, MC. 315 Peffor St Norrieber5. Poses.17102 (717)233-7897 3 TMI A's COMMENNTS TO Tile NRC ADVISORY PANEL ON Tile NRC's REVISED EIS ON Tile DISPOSAL OF RADIOACTIVE WATER In thct this is a very sensitive subject I think the Panel should not rigidly enforce time constriants on questions and ' presentations by the community. In addition, I hope the water disposal issue does not become a secondary item af ter this meeting. I appreciate the f act that GPU responded to my questions concerning Post Defueling Monitored Storage. However, I'm not satisfied with a number of the responses, especially the ones dealing with decommissioning. Rather then pursue a line of questioning tonight, I'll defer until the next meeting. I am submitting their revised a list of questions to the NRC concerning EIS. I request that they be made a part of the official record. I'm speaking tonight on behalf of Three Mile Island Alert, which is a non-profit, safe energy group based in llarrisburg. Both the NRC and GPU have stated that the quantities of radiation released during the disposal of the contaminated water would be " insignificant." They always says this! We don't believe that any radiation dose is safe, especially in this area where
> radiation has been vented steadily for the last 14 years. I don't remember a time when the utility admitted that "significant" levels of radiation have been released, including the 43,000 curies of Krypton-85 vented on Central Pennsylvania for 13 days in July 1980. .
We have serious reservations about the disposal options sanctioned by the NRC. In fact disposal is an incorrect term. There will be no actual disposal, and no guarantee of containment. Instead, radioactive materials and industrial chemicals will be dispersed in the environment. We do however, have certain objectives we would like to see met. Our prime and overriding concern is minimzing radiation exposure to the local population and the environment. For example, we would like to see 100% of the water filterad and processed within a closed cycle. Worker exposure should be minimized, since many of them have human sponges for the last 7 and 1/2 years. Dose rates to populations outside of central Pennsylvania should also be minimized. Cost and time should not be f actors. GPU shduld spend as much money, and take as much time as needed to find the saf est method of disposal. 1
_m .; t ~ = u 1 f e p . r > h L, Considering these objectives, alternatives such as dumping the water into the Susquehana River and on-site evaporation are e clearly unacceptable, due to the potential harmf ul physical and psychological threat they present to our community. i; i We request the following steps be taken before a final [ decision is made: a meteorological study of the area surrounding i TMI; a study examining the psychological stress that would result p from the planned disposal methods; an inventory of all the radioactive 4 elements and chemicals that are in the water; and a review of the h GPU's current proposal and the NRC's revised EIS by an independent 7 agency not affiliated with the nuclear industry or the y government. n d i At this time I'd like to remind the panel of some of the past i behavior of this utility and the NRC, because this is a crucial j factor in understanding the built in distrust and fear of area ( residents. h J We remember that in July of 1980, 43,000 curies of ? radioactive krypton-85 and other radioactive gasses were vented f rom Unit-2, even though TMI-2 was designed to release ft J approximzately 770 curies of krypton-85 a year. The venting occurred a little over a year af ter the the accident admidst I widespread fear and concern. Later, in November the U.S Court Of Appeals for the District of Columbia ruled in Sholly vs. the NRC j , that the krypton venting was illegal, f We remember that in the spring of 1983, three senior level engineers charged that GPU and Bechtel deliberately circumvented k i safety proceedures and harassed them f or reporting safety violations. The NRC fined GPU and Bechtel S64,000 for intimidating and harassing Larry Parks. E
- We remember the reactor head lif t between July 24 - 27, s 1983, which was delayed due to brake failure on the polar crane.
)
GPU vented radioactive gases into the environment, despite pledges by the NRC and GPU that no venting would take place l during the head lift operation. GPU was later fined $40,000 by 4 the NRC for the brake problem. [* We remember that on June 1,1984, the NRC released d transcripts of closed NRC Commission meetings. The transcripts revealed a commitment on the part of a Commission majority to @ restart TMI-l as soon legally and poltically possible. Also p evident was significant disdain for public views on the restart a issue, and a serious lack of understanding of the legal and technical issues. This is the same agency who will ultimately y decide how the water will be disposed. i k P, i E 2 k ~~ N == M- 5 l r-E . . . .4
We rememember that between February 10-12, 1985 the Philadelbhia Inquirer reported records at TMI demonstrated that in hundreds of cases, workers had been contaminated by radioactive materials either on the skin or through ingestion. The result was that workers were living in a state of anxiety, fearing cancer, birth defects and possible genetic damage for future generations. We also remember the health suits, the spills, the fines, the leaks, the miscalibrations, the exposures, the criminal convictions and the one-celled organisms. So when the NRC and GPU say that venting, dumping or burrying 2.1 million gallons of radioactive water will have a negligible impact on our health and environment ... people just don't believe them. Why should they? People live with in fear that they, and future generations, have suffered serious health ef fects as a result of the accident and GPU's mismanagement. This fear has fostered a great deal of psychological stress in our community. Stress can be translated into long term health effects, and is a very difficult to measure. Yet it is one f actor the NRC will not identify in measuring health risks f rom the disposal of the water. We are not scientists, and we do not feel that the burden of producing a safe, expedited method of disposal should fall on the shoulders of the community. The decision on what to do with this water should not be made in haste, and should not be made until all possible alternatives are explored and exhausted. People in this area have been dumped on enough. Were tired of being the guinea pigs. v 2 ..
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cyc .v. o I .s. r - [ GPU Nuclear Corporation W 1 Nuclear :::,oma= Middletown, Pennsylvania 17057-0191 [ 717 944 7621 : TELEX 84 2386 Writer's Direct Dial Number: (717) 948-8400 5 4000-87-S-019 Document ID 0147P January 14, 1987 ] Mr. Arthur E. Morris Chairman, The Advisory Panel for the Decontamination ; of Three Mile Island Unit 2 P.O. Box 1559 Lancaster, PA. 17603 ,
Dear Chairman Morris:
Sub ject: TMIA Questions Concerning Post-Defueling Monitored Storage Pursuant to our commitment at the Panel's December meeting, we are submitting to you the answers to questions raised by Mr. Eric Epstein, Three Mile Island Alert, Inc., concerning Post-Defueling Monitored Storage (PDMS) at TMI-2. We will continue to keep the Panel informed on PDMS as our planning proceeds. In answering Mr. Epstein's PDMS questions, it is important to emphasize that the document submitted to the IRC by (PU Nuclear is "for information only." This document is based on G)U Nuclear's concept of PDMS - it is a conceptual overview -- and is necessarily general in nature. (PU Nuclear has not requested NRC action regarding PDMS on the basis of this submittal. Formal W C review of PDMS will occur during consideration of a GPU Nuclear request to change technical specifications under the TM1-.2 Operating License. This change request is currently under development and its submittal is planned by the end of 1987. The submittal will contain more detailed information on the TMI-2 PDMS configuration and provide a basis for the EC to take action with respect to PDMS. An opportunity for public participation will be afforded during the process of revising the technical specifications in accordance with 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities." E 1 4 3 l" GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation i
Chaiman Morris &nuary 14 ,1987 4000-87-5-019 b Based on the preliminary nature of the information available on PDMS, some of Mr. Epstein's questions cannot be answered in full; however, we have provided tha most current information available. Copies of this reply have been provided to Michael T. Masnik for forwarding to THIA. Sincerely, f
. R. Standerfer
' Director, THI-2 FRS/eml Attactynent cc: Dr. Michael T. Masnik - Project Manager, TM1 Project Directorate (2 copies) w Y
BCC LIST: 4000-87-S-019 Executive Vice President - E. E. Kintner Deputy Director, TMI T. F. Demmitt Director, Communications - C. Clawson Director. . Licensing and Nuclear Safety - R. E. Rogan Manager, Public Infomation - D. Bedell 7 4 4 7
ATTAC M T 4000-87-S-019 RESPONSE TO TMIA QUESTIONS CONCERNING POST-DEFUELING MONITORED STORAGE 9 Question 1: In the event G'U becomes insolvent, or bankrupt, what contingencies are in place to ensure this " final stage" will be iglemented and carried out? Response: This is a question best referred to the E C. Federal laws provide for assumption of responsibility should an W C licensee, for any reason, be unable to ensure public health and safety. Question 2: How long is this stage (PDMS) projected to last? Is PDMS analogous to decomissioning? Why or why not? Response: The length of time TM1-2 will be in PDMS is not currently defined; however, as stated in Section 2.1 of the PDMS report, this condition can continue safely until the time of decommissioning of THI-1. The EC proposed rule on Decomissioning Criteria for Nuclear Facilities, which was published on February 11, 1985, defines a As decomissioning alternative, SAFSTOR, that is similar to POMS. defined in the rule:
"SAFSTOR is the alternative in which the nuclear " facility is placed and maintained in such condition that the nuclear facility can be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."
However, decomissioning also implies permanent cessation of GPU facility operation with the intent to dismantle the facility. Nuclear does not consider PDMS to be analogous to decommissioning as no decision has been made concerning the disposition of THI-2. Question 3: Since you won't be utilizing Control Room personnel, does this igly you've ruled out restarting Unit 2? Response: As discussed in Section 2.4 of the PDMS description, plant conditions during PDMS will be such that Control Room Operators will not be required. No further i g lication should be assumed. 7
ATTACi+ENT AD00-87-S-019 Question 4: How many employees will be utilized during this stege, in what capacity, how long will they be on the Island and how much of the work during PDMS will be sub-contracted out or perfomed by non-GPU employees? Response: Specific staffing levels for PDMS have yet to be detemined. Preliminary plans anticipate that a total of 50 to 100 persons will be required for security, surveillance, radiation monitoring and the like. Question 5: Will the Japanese or any other representatives of foreign governments / utilities play a role in PDMS? Response: It is not anticipated that the Japanese or other foreign governments / utilities will play a role in PDMS. Qu'estion 6: There are a number of assumptions in GPU's presentation, but I'm just going to focus on two:
- 1. GPU maintains, "The Program (PDMS) will be underway for the disposal" of 2.1 million gallons of radioactive water. What if it is not? What bearing will that have on post monitored defueling?
- 2. GPU believes that during PDMS there will be allowable time "for the resolution of current limitations on national waste disposal capabilities so that selection of processed may be less dependent on volume reduction." Anybody who has been involved with the waste disposal issue knows that it is unpredictable, volatile and burdened with endless delays.
How much time is GPU " allowing" for this national issue to be resolved? What if waste disposal becomes delayed indefinitely? R sponse: 1. Placing the plant in PDMS is not contingent on completion of the disposal of the 2.1 million gallons of radioactive water. This statement merely reflects GPU Nuclear's current expectation of the status of that activity when the plant is ready to enter PDMS.
- 2. There are two separate waste disposal issues to be resolved:
high level waste and low level waste. With respect to high level waste disposal, THI-2 is a special case. A memorandum of understanding (MOU) between the tEC and the Department of Energy (DOE) which addressed this issue was originally entered into on July 28, 1981, and subsequently , revised on April 15, 1982. The objective of this MOU was to
" ... help ensure that the TMI Site does not become a long term waste disposal facility." The MOU defines DOE's roles and responsibilities at THI-2 with respect to high level waste as follows:
= [ ATTA04ENT . _1 _ 4000-87-5-019 ] i "Where DOE determines that generally beneficial p research, development and testing of the TMI-2 i accident generated solid wastes can be carried out, DOE will perform such activities at appropriate DOE
; facilities. For those other wastes that cannot be
- disposed of in comercial low level waste facilities, DOE may also assume responsibility for removal, l storage, and disposal to the extent that the licensee provides reimbursement to the DOE. .
l Based on this MOU, THI-2, unlike other nuclear facilities, can [ and is disposing of high level waste. . 3 ' With respect to low level waste disposal (NOTE: The PDMS . . statement referenced above was specifically intended to address .- .. this issue), G'u Nuclear does not consider the issue to be - - nearly as likely to be "... unpredictable, volatile, and burdened with endless delays" as the high level waste disposal issue.
?
The amendment to the Low-Level Radioactive Waste Policy Act of f 1985 specifies milestones and a timetable for resolution of this _,y issue. GPU Nuclear expects that Pennsylvania will meet its f l((..['g- f s commitments under the Act. e V . 3l g [ f.~.(g s . r
- , Question 7
- If the plant will be in a condition of " inherent stability", what c,, . ; .:.. .
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was it's condition before? t ;.'.! .. : y ? .r n c . . h.[ J i ~ Response: Inherent stability means that the plant is in a benign state not requiring the normal " operating reactor" safeguards to protect t.; A-Y @ public health and safety. This condition is not considered to have 53; . '; been achieved until fuel is removed and shipped off-site. .,t , ' r. 5
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; Question 8: In that the utility will be utilizing " positive monitoring and .{.
+L i control," is there any major difference in the approach compared - '. ..;
to the current monitoring system? Is there a concept known as @,, i#. 4 } " negative monitoring?" {g
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.,3 Response: No.10 CFR 50.36a, " Technical Specifications on Effluents from 3:? 2 : ,
[ Nuclear Power Reactors" in part requires plants to monitor 6 h9:; " radionuclides released to unrestricted areas in liquid and gaseous M,!. ;Q 1 k effluents and to report the total releases to the E C - semi-annually. G)U Nuclear will continue to be subject tn this eb-4 requirement during PDMS; therefore, a method to monitor twse releases is required. D.].. - [
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ATTAD E NT 4000-87-5-019
. Question 9: How can the public be assured that waste from Unit-1 or Oyster
,. Creek won't be stored at Unit-27 Response: There is no present intention to store nuclear wastes from any source at TMI-2. Furthermore, such storage is outside the scope of Post-Defueling Monitored Storage and would necessitate a change to the plan. In any case, such action would require prior approval by . the Nuclear Regulatory Commission. Question 10: What will be the role of the M C, EPA, and the Advisory Panel during this stage? Response: This question is best referred to the M C, EPA and the Advisory Panel. Question 11: Will there be backup power and redundant safety systems exployed during this stage? Response: No. Backup power and redundant safety systems will not be required. Question 12: Could (PU be more specific on their plans for flood protection and seismic qualifications? Response: The flood protection features of TMI-2 and the seismic qualification of TMI-2 structures are described in Chapters 2 and 3 of the TMI-2 FSAR.- These features have remained essentially unchanged during the TMI-2 Cleanup period and can be relied upon during POMS. Question 13: Where exactly will the residual fuel be stored, where will the fuel that is not enclosed be stored and what will the " aggregate quantities" be? Response: Residual fuel, by its very nature, will not be stored at TMI-2. Residual fuel is that fuel which is not removed from the plant during the defueling process. Table 2-1 of the PDMS report provides a list of possible locations of residual fuel external to the reactor vessel. Additionally, some residual fuel also is expected to remain imbedded in the reactor vessel and its components. As stated in Section 2.3 of the PDMS report, the total quantity of residual fuel expected to be present in the plant during PDMS will be substantially less than 400 kg of TMI-2 fuel, the amount which constitutes a quantity of Special Nuclear Material of Low Strategic Significance as defined in 10 TR 70.4. a
l ATTACl+ENT 4000-87-S-019 i Question 14: How exactly will radioactivity be " fixed or contained"? Response: All residual radioactivity will be contained within closed system, sealed cubicles and/or within the containment building which will be maintained as a contamination barrier. Some contaminated surfaces also may be covered with fixatives such as paint or other coatings which will reduce or halt the migration of contaminants to the surface. Question 15: What will the criteria be for off-site radiation doses that will purportedly be "substantially lower than the limits pemitted for an operating nuclear plant?" Who will enforce these limits? Response: As stated in Section 2.5 of the PDMS report, ". 10 CFR 50 Appendix I has been established as the PDMS standard. A small fraction of the Appendix I off-site limits is expected to be maintained for nomal conditions prevailing during PDMS. The potential off-site radiological doses resulting from postulated off-normal conditions will be within the 10 CFR 50 Appendix I limits." GPU Nuclear anticipates that these limits will be established as Technical Specification requirements and will be subject to enforcement by the MIC. Question 16: Who will be conducting the inspections of the reactor building and the auxiliary building. Response: The inspections discussed in the POMS report will be performed by GPU Nuclear personnel. The results will be submitted to the NRC. Question 17: What's the difference between PDMS and making Three Mile Island Unit 2 an indefinite low-level /high-level waste disposal site? Response: As defined in the TMI-2 License, THI-2 is pemitted to possess and use source, byproduct and special nuclear material. The present license provides no provision to dispose of low-level or high-level waste on-site. In order for THI-2 to become a waste disposal site, licensing under 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste," for a license as disposal site would be required. G)U Nuclear does not intend to request such authority.
i a THREE MILE ISLAND ALERT, MC. m 315 Peffor St Herrisburg. Penna.17132 (717)233-7337 QUESTIONS CONCERNING THE NRC's REVISED EIS O_N Tile DISPOSAL -
- OF RADIOACTIVE WATER 01:p.2.6 (p.3.1 & p.5.6 second paragraph).Second paragraph. 1 "There is no evidence for a significant concentrartion process for tritium in either plants and animals". (NCRP '7 9 ) . "No e apparent enrichment or concentration ef fect for tritium has been -
found in aquatic or terrestial food chains." (NCRP '7 9 ) . Does no # concentration mean no adverse health effects? Are there are any _: studies that contradict these findings? Was this study the sole - basis of your reporrt concerning tritium and its interaction with biological systems? If so, why? ; Q2: p.2.11 What levels of boric acid or boron in the water would 5 cause you concern? Also refer to last paragraph p3.28. 03: p.2.13 When was the EPA's NIPDWS draf ted? Was it ever . revised? Same ? for RCRA. T Q4: p.2.15 Since Pennsylvania is a non-Agreement state, and is l bound by the NRC's decision, what recourse is left to the state - or citizens who are dissatisfied with the NRC's decision? Can a , ! decision be binding even if it violates other Pennsylvania l environmental laws ? What if Pennsylvania becomes an Agreement
. state before the water issue is reolved? What bearing will that C have on the process?
05: P.3.1.1.1 Why not let the transportable evaporator operate in r? closed cycle? How accurate has the volume reduction figure been - in 3.1.1.2 at other plants? What if it is skewed a few z magnitudes? t 06: p.3.7 Do the maximum dose rates assume that all plant, _ aquatic and human life are chemically and radicactively pure i before their exposed to the radioactive emissions f rom the water? 07: Do any of your cost breakdowns take into account inflation, [' regulatory / legal delays (3.1.1.4) logistical delays, etc. Ilow much of a f actor is economics when you analyze the alternatives? 08: p.3.1.2 & p3.10 Second paragraph. Would the NRC allow GPU to place concreted waste in a trench on site? Sixth paragraph. When is the NRC going to consider long-range monitoring at TMI? 1 09: p.3.10 What is a liypalon cap? Is it any relation to the ( i dicasterous clay cap used at chemical sites in California? ;
- Q10
- p. 3.12 Would DER allow unrestricted use of site af ter 30 -.
years? p.3.13 You would have no problem w/ building or f arming on
, this site af ter 30 years? Who will monitor the site?
Q11: p.3.15 Last paragraph. How do you assure that no civilians are upwind? Q12: p3.22 First paragraph. How do you monitor the 50% tritiated water, and keep it separate f rom the 50% that is not monitored? Does this' mean that the other 50% will not be monitored? 013: Why has the NRC adopted the De Minimis Waste Impacts Analysis Methodology? Are there methodologies that contradict or call into question the De Minimis methodology? Q14: p.3.24 What i' no LLW burials ite wants the waste? What if GPU doesn't want to use their alloted space at a site for the disposal of this_ waste? Q15: p3.4.1 Will the release be publiciz.ed before disposal? 3.4.1.2 How are you so sure all exposures will be ' diluted? What guarantees exist to prevent GPU from adding more highly radioactive water before disposal? What will the NRC monitor? And how? 016: p. 3. 4.2. 3 Accident analysis. Why is a discharge of a batch of accident generated water before treatment unlikely? 017: p3. 31 What is meaiiit 'by " ultimate,' disposal"? p. 3.5.1. 2 No ' other expected pathways of exposure to public? - Q18: p3.5;1.4 Why are no other impediments expected before license , termination? Q19: p.5.3 The environmental, health, economic and human costs associated w/the no action alternative is minibal. Why not < endorse it? Q20: p.514 Third paragraph. What is meant by "... biological 7 mechanisms that can repair damage caused by cancer at low- ' levels". < 021: Is there an endpoint to this process? Does the procesh end 1 precisely at 2.1 million gallons of water? If so, what happens to additional water? u. Q22: Why was there no meteorological study conducted? 1 4 8 # 2
/
a
4 NUREG-0683 l Draft Supplement Dealing l With Disposal of Accident-l Generated Water December 1986 ' 1 4
l The PEIS was Supplemented Because: 1 l i l l e New, more specific information e Licensee's proposal to dispose of the water i e Continuing public interest
TABLE 2.4. Summary of Characteristics of Contaminants in the Accident-Generated Water Italf-Life, Decay Background Exposure Contaminant years Radiation Concentration Sources s
- Tritium 12.3 Beta 150 pci/L in Water and (liydrogen-3) Susquehanna plant and River. animal tissues Cesium-137 30 Beta, gamma 0.2 pCi/I. In Fish, meat, (daughter decay) surface water and milk Strontium-90 28 Beta (radio- 5 pCi/1. Hilk and -
active daughter in milk other food-also beta) stuffs llo r on (pre- Nonradioactive Normal human Fruite, and ncnt n !s the , intake in 10 v er,e t ab l e r. horate nulon) to 20 mg/ day Sodlun ton Nonradioactive 6 to ll's mg/l, lible;ui t our, in frenh water
!!upport lug i j !:h l
i i l i Ten Alternatives Evaluated i l 3.1 Onsite evaporation l - 3.1.1 Evaporation, solidification of bottoms j and disposal at a licensed burial l ground i - 3.1.2 Evaporation, solidification of bottoms and retention onsite 3.2 Bulk liquid shipment
- 3.2.1 Evaporation at NTS
- 3.2.2 Deep well injection at NTS
- 3.2.3 Crib disposal i
t Ten Alternatives <' cont'd} 1 l 3.3 Direct solidification i
- 3.3.1 Permanent onsite storage of solidified waste
! - 3.3.2 Solidification and disposal at a j commercial low-level burial site 3.4 River discharge l
- 3.4.1 Long term river discharge
! - 3.4.2 Short term river discharge 3.5 Onsite storage ,
- 3.5.1 Liquid storage in tanks
l 3.6 Alternatives Considered but Rejected e Ocean disposal (as either a liquid or a solid)
- o Pond evaporation onsite e Cooling tower evaporation (onsite) with residue discharged to the river e Deep well injection onsite e ORNL hydrofracture facility
, ,e- --- -,,- - -n.
l
- 3.6 Alternatives Considered but Rejected ' cont'd'j j i I
l e Reuse (either as a bulk liquid or as a i concentrated boric acid residue) e Land spraying at NTS , o Combined catalytic exchange I e Distillation e High altitude disposal o Evaporation at Maxey Flats
i l Ten Alternatives Evaluated
- l. 3.1 Onsite evaporation
- 3.1.1 Evaporation, solidification of bottoms-and disposal at a licensed burial i
ground l - 3.1.2 Evaporation, solidification of bottoms l and retention onsite i
~
- 3.2 Bulk liquid shipment
- 3.2.1 Evaporation at NTS
- 3.2.2 Deep well injection at NTS
- 3.2.3 Crib disposal i
j
i i l i Ten Alternatives { cont'd} 1 l i ! 3.3 Direct solidification l - 3.3.1 Permanent onsite storage of solidified i waste ; l - 3.3.2 Solidification and disposal at a ! commercial low-level burial site l 3.4 River discharge
- 3.4.1 Long term river discharge l - 3.4.2 Short term river discharge 3.5 Onsite storage
- 3.5.14iquid storage in tanks l O
, Alternatives Evaluated Relative ! to: . i ! e Occupational radiation exposure l e Radiation exposure to the public , e Commitment of resources
- Land area
- Waste burial ground space
- Cost e Accident potential
- Onsite - liquid spills '
l - Offsite - transportation accidents i l e Regulatory considerations l - _ _- __ _
i l Environmental Impacts of the Ten ' Alternatives i l l Impact on the Offsite Population Maximum Population Individual i Bone dose 0-11 person-rem 0-3 mrem
~
..i Total body dose 0-3 person-rem 0-0.5 mrem Radiation caused cancer fatalities O to 0.001 ;
Radiation caused genetic disorders O to 0.002 i 1
I i Environmental Impacts of the l Ten Alternatives Impact on the Worker Population e Total body dose 0.5 to 25 person-rem , e Radiation caused cancer fatalities to 0.003 1 4
l Environmental Impacts of the Ten Alternatives l Impact of the Commitment of Resources Land 0 to 1 Acre Waste Burial Ground 0 to 460,000 cubic feet Volume ! Cost $2.3 to 41 Million Time 2 to 36 Months ! l
~
Environmental Impacts of the Ten Alternatives Impact of Transportation l Number of Accidents 0.5 to 12 Number of injuries O.4 to 10 Number of Traffic Fatalities 0.03 to O.8 l
t I Conclusions e Water can be disposed of without significant impact e No alternative is clearly preferable e The most significant impact is the risk of physical injury associated with transportation e Extended liquid storage in tanks would also have a small impact but is inappropriate because it merely defers ultimate disposal f . - . - ,m _,-,,.. _ . . - _ . _ , . . . _ . . . . - . . - _ . . , . _ . . , - .
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g 4 sto y DISTRIBUTION LIST FOR MATERIAL TO THE ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND UNIT 2 Chainnan Zech H-1149
, Commissioner Roberts H-1149 Commissioner Asselstine H-1149 Commissioner Bernthal H-1149 Commissioner Carr H-1149 L
H. R. Denton, NRR P-428 PANE W. D. Travers (5 copies) TMI Site Mail Pouch P.O. Box 268 M. Masnik P-320 Middletown, PA 17057 J. R. Hall P-320 F. Congel 244 Mr. Frank D. Davis J. Zerbe H-1013 200 Gettysburg Pike M. Libarkin, ACRS H-1016 Mechanicsburg, PA 17055 T. Major H-1016 J. Fouchard MNB-3709 Ms. Beverly Hess , TMI-PIRC R. Browning, NMSS 55-623 1037 Maclay Street Docket File 50-320 016 Harrisburg, PA 17103 PDR 016 LPDR 016 Mr. Edward Charles DCS 016 90 Nittany Drive I F. Miraglia P-202 Mechanicsburg, PA 17055 Director Mr. John H. Murdoch Power Plant Siting Program 44 Kensington Drive Department of Naturi.1 Recources Camp Hill, PA 17011 Tawes Building B-3 Annapolis, MD 21401 TMI Alert - c/o Xay Pickering 315 Peffer Street Ms. Ruth Gentle Harrisburg, PA 17102 1 Virginia Circle Mechanicsburg, PA 17055 Dr. Frank Parker School of Engineering Susquehanna Valley Alliance Nashville, TN 37203 P. O. Box 1012 Lancaster, PA 17604 Ms. Michelle Voso Society of Nuclear Medicine Dr. Sid Langer 475 Park Avenue, South P.O. Box 1625 New York, NY 10016 Idaho Falls, ID 83415 Mr. Dave Janes Mr. E.E. Kintner Analysis and Support Division Executive Vice President U.S. Environmental Protection Agency General Public Utilities Nuclear Corp. 401 M. Street, SW (ANR-461) 100 Interpace Parkway Washington, DC 20640 Parsippany, NJ 07054 Mr. Kenne+.h L Miller, Director Division of Health Physics and Associate Professor of Radiology Milton S. Hershey Medical Center Pennsylvania State University Hershey, PA 17033
T 2 Mr. Bob Leyse Ir John Luetzelschwah_ o EPRI-NSAC Professor of Physics 3412 Hillview Avenue Dickinson College Palo Alto, CA 94303 Carlisle, PA 17013-2896 Mr. Willis Bixby Mr. Thomas Gerusky, Director U.S. Department of Energy Bureau of Radiatien Protection P.O. Box 88 Dept. of Environmental Resources Middletown, PA 17057 P.O. Box 2063 Harrisburg, PA 17120 Mr. F.R. Standerfer, Director Three Mile Island Unit 2 Elizabeth Marshall GPU Nuclear Corporation 736 Florida Avenue P.O. Box 480 York, PA 17404 L Middletown, PA 17057 Mr. Thomas Smithgall Mr. J.J. Byrne 2122 Marietta Avenue Three Mile Island Unit 2 Lancaster, PA 17603 GPU Nuclear Corporation P.O. Box 480 Niel Wald, M.D. Middletown, PA 17057 Professor and Chairman Department of Radiation Health The Honorable Arthur E. Morris University of Pittsburg Mayor of Lancaster A512 Crabtree Hall P.O. Box 1559 Pittsburgh, PA 15261 120 N. Duke Street Lancaster, PA 17605 Dr. Gordon Robinson Associate Professor of Mr. John Minnich Nuclear Engineering Dauphin County Commissioners 231 Sackett Building P.O. Box 1295 University Park, PA 16802 120 N. Duke Street Harrisburg, PA 17108 Jim Detjen Philadelphia Inquirer Dr. Henry Wagner 400 N. Broad Street Johns Hopkins School of Hygiene Philadelphia, PA 19101 615 N. Wolfe Street Room 2001 Dr. William Kirk Baltimore, MD 21205 Environmental Protection Agency TMI-2 Field Station Mr. Ford Knfght 100 Brown Street Westinghouse Electric Corp. Middletown, PA 17057 P.O. Box 286 Madison, PA 15663 Mrs. Ann Trunk 143 Race Street Trederick S. Rice Middletown, PA 17057 Chairman, Dauphin County Comm. P.O. Box 1295 ffr. Joel Roth Harrisburg, PA 17108 RD 1, Box 411 Halifax, PA 17032 Mr. Glenn Hoenes l Pacific Northwest Laboratory ! P.O. Box 999 l Richland, WA 99352 l
D 3 Pro-Women Ms. Leslie Klein c/o Judy Branett Intelligencer Journal 320 Elm Court 8 West King Street Middletown, PA 17057 Lancaster, PA 17603 Joyce Corradi Marjorie and Nondn Aamodt Concerned Mothers and Women on TMI 180 Bear Cub Road 2 South Nissley Drive P.O. Box 652 Middletown, PA 17057 Lake Placid, NY 12946 f
< Mr. Joseph DiNunno Francine Taylor 44 Carriage Lane 151 Hamilton Rd.
g Annapolis, MD 21401 Lancaster, PA 17603 Mr. Ad Crable Jane Lee Lancaster New Era 183 Valley Rd. 8 W. King Street Etters, PA 17319 Lancaster, PA 17603 Pepper, Hamilton and Sheets Dr. Frederick J. Shon P.O. Box 1181 Administrative Judge Harrisburg, PA 17108 Atomic Safety and Licensing Board Panel c/o Debbie June U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Rep. Alan Kukovich US Environmental Prot. Agency House of Representatives Region III Office Harrisburg, PA 17101 ATTN: EIS Coordinator Debra Davenprot Curtis Building (Sixth Floor) 1802 Market Street 6th and Walnut Streets Camp Hill, PA 17011 Philadelphia, PA 19106 Dr. Ronald R. Bellamy, Chief Radiological Protection Branch U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Ms. Mary Osborn 4951 Highland Street Swatara, PA 17111 Robert L. Vree Box 72 Middletown, PA 17057 l l John Kabler, Director Chesapeake Division Clean Water Action Project 2500 N. Charles Street Baltimore, MD 21218
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