ML20215M210
| ML20215M210 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/03/1987 |
| From: | Hossler D AFFILIATION NOT ASSIGNED |
| To: | Masnik M Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20215L984 | List: |
| References | |
| RTR-NUREG-0683, RTR-NUREG-683 NUDOCS 8705130123 | |
| Download: ML20215M210 (2) | |
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501 vine Street Middletown, PA 17057 March 3, 1987 Mr. Michael Masnik TMI Project Directorate Office of Nuclear ?
Reactor Regulation -
USNRC Washington, DC 20555~
Dear Mr. Masnik:
The fate of the accident generated water should be tied very closely to concerns of the population and the actual need to dispose of the liquid at this time.., ~ ' ~ ~
~'ifF Contrary to some opini'o^ns
[.believe the competence and integrity of GPU must always be questionedp3 Why should they be allowed to do anymore then concentrate]on]thevery delicate decon and defuel job at Unit 2?
After all the' basement of Unit 2 will likely not be completely cleaned untilitheJ21st century.
Why have GPU spend its fiscal and worker resourcesionja 12 million dollar operation never before completed at a civilian-reactor site and in particular since there are no medical studies 7that state GPU's preferred method is safe?
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I note the " errata sheet" of thelMRC document (NUREG - 0683, Supulement 2) has several computational errors which could relate to human health.
A study completed during Krypton 85 venting of 1980contradictedNRCestimateso(humanexposuretothat" assault" on area residents.
Pages A-173 t'o A-180 of NUREG - 0683 Final Programmatic Environmental ImpactJStatement Vol. 2 Appendices A - Z This March 1981 detail a history that we should certainly consult.
report deals with the venting of Kr 85 and other contaminants from June 28 to July 11, 1980 at TMI 2j Basically the Report says 4 million times the Strontium 90 greater then published predictions was vented which calculated to human life lost due to cancer.
The same Nureg discusses annual releases of tritium at 300 curies.
1 I ask where else has this technique which GPU wants to do as a "public service" been completed and assessed as to the effects on the residents?
I know Uni + 1 is emitting radioactive water and gasses as does
- Yes, Unit 2 but once again I come to competence, trust and integrity.
Let GPU concentrate on decon and defuel work.
4 GPU should use its monitoring and engineering expertise to be sure storage of tha contaminated water will remain in tanks on site.
I urocose GPU scend 2 million dollars for state of the art tanking with raserve caeacity.
This would allow them to apply the 10 million 8705130123 870507 PDR ADOCK 05000320 P
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dollars.
(Forced evaDoration costs 12 million) saving to working on the radioactive basement in Unit 2.
I believe they will exceed 1 billion dollars on the entire decon/defuel job, so let's not waste 12 million dollars on another experimental system.
Let GPU demonstrate their expertise at monitoring the safe storage of the contaminated water while spending more valuable time, money and worker resources on the serious problem of decon/defuel work inside Unit 2.
With sincerity, b.
Donald E. Hossler 9
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6 February 1987 Planning Division Mr. William D. Travers, Director TMI-2 Cleanup Project Directorate Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Travers:
Reference your letter of 29 December 1986, regarding the review of the Draft Supplement 2 to the Programmatic Environmental Impact Statement (PEIS) for disposal of radioactively contaminated water stored at the Three Mile Island Nuclear Station site.
The comments provided below address the Corps of Engineers areas of concern, including direct and indirect impacts on Corps of Engineers existing and/or proposed projects, flood control hazard potentials, and permit requirements under Section 404 of the Clean Water Act.
There are no existing or proposed Corps of Engineers projects that would be affected by the work described in the Draft Supplement 2 to the PEIS.
The PEIS should include documentation of the effects on the flood plain and compliance with Federal, State, and local flood
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plain regulations, as appropriate.
l Three Mile Island Nuclear Station, Unit 2, is located entirely within the boundaries of the 500-year flood plain.
The l
PEIS does not address Executive Order (E.O.) 11988, Flood Plain l
Management, dated 24 May 1977, which is applicable to this review I
as several of the alternative disposal solutions occur on the flood plain.
In accordance with the U.S.
Water Resources Council " Flood Plain Management Guidelines For Implementing l
Executive Order 11988", (43FR 6030), 10 February 1978, the proposed actions may be considered critical such that even a i
slight chance of flooding would be too great.
The document must evaluate alternatives with respect.to E.O.
11988 and demonstrate that they have been designed to minimize adverse effects on the flood plain.
If the selected alternative is to be located in the flood plain, it must be demonstrated to be the only practicable alternative.
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. Each.of the 10 alternative disposal methods were reviewed to assess potential impacts on the flood plain.
Those alternatives which include total or partial on-site storage and/or treatment at Three Mile Island are subject to flood hazards which could reintroduce the contaminated material into the environment.
The alternatives known to be susceptible to flood hazard are:
Alternative #1 Evaporation, solidification of bottoms, disposal at a licensed burial site.
Alternative #2 Evaporation, solidification of bottoms, and retention on-site.
Alternative #6 Permanent onsite storage of solidified wante.
Alternative #8 Long-term disernrge into the Susquehanna River.
Alternative #9 Short-term discharge into the Susquehanna River.
Alternative #10 Liquid storage in tanks at the' Three Mile Island site.
The risk of flood hazard is minimized by those alternatives which minimize the amount of t 'ene materials are stored on-site.
The risk of reintroducing hazarcous materials into the environment can also be minimized by adopting flood resistant design and construction methods for containers.
The alternatives listed below are not located at Three Mile Island, are not within the Baltimore District, and cannot be judged for susceptibility to flood hazards.
Alternative #3 Off-site evaporation at the U.S.
Department of Energy (DOE)
Nevada Test Site.
Alternative #4 Deep-well injection at the DOE's Nevada Test Site.
Alternative #5 Crib Disposal at the DOE's site in Hanford, Washington.
Alternative #7 Solidification and disposal at a commercial low-level waste site.
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. Under Section 404 of the Clean Water Act, Department of the Army authorization is required prior to any discharge of dredged or fill material into waters of the United States, including their associated wetlands.
Since the proposed work does not involve work or placement of fill in waters of the United States, Department of the Army authorization is not required.
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If there are any questions concerning this matter, feel free to call me or my action officer, Mr. Larry Lower, at (301) 962-4710.
Sincerely,
[
bA James F. Johnson Chief, Planning Division
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DEPARTMENT OF HEALTH & HUM AN SERVICES Public H;itth Strvice i
e Food and Drug Administration Rockville MD 20857 FEB 2 51997 Dr. Michael T. Masnik Acting Director i
- 'Ihree Mile Island-2 Cleanup Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cmmission Washington, D.C.
20555
Dear Mr. Masnik:
We Center for Devices and Radiological Health staff has reviewed the Draft Supplement 2 to the Programatic Environmental Impact Statement related to decmtamination and disposal of radioactive waste resulting from the March 28, 1979, accident at the Wree Mile Island nuclear station Unit 2 (NUREG 0683, Supplement No. 2, dated December 1986). Our efforts were directed to an evaluation of the public health and safety impacts associated with the proposed alternatives for disposal of water which wa.s contaminated as a result of the accident. We have the following comments to offer:
- l. We discussion in Chapter 3 has adequately assessed the alternatives for disposition of the accident-generated water together with the principal environmental impacts for each alternative. It appears that these impacts would involve minimum offsite individual and population dose and occupational dose from releases of tritium, cesium-137 and strontium-90 as a function of the alternative selected.
- 2. 'Ihe environ:aental pathways identified for each alternative covers the possible emission pathways that could impact on the population in the environs of 'IMI and at potential waste disposal sites. We radiation dose calculation methods and assm ptions presented in Appendix B have provided reasonable estimates of the doses to the maximally exposed individual and the population within the 50-mile (80 kilometer) radius of the site. 2e range of impacts frca the alternatives censidered are shown in Table 6.1 and indicate that the doses are minimal and well within current radiation protection standards.
- 3. %e discussion in section 5.2 has adequately assessd the radiological impacts and health effects to the workforce population, the maximally exposed i
individual, and the offsite population within 50 miles (80 kilcmeters) frem exposure to radioactive effluents. de unequivocally concur with the statement in Section 5.2, page 5.5, paragraph 2, that states "tese risks are very small in cmparison to cancer incidence from causes unrelated to the disposal of the accident-generated water."
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Dr. Michael T. Masnik, NIC - Page 2
- 4. Some of the alternatives.for disposal of accident-generated waste involve offsite truck shipnents. Consequently, it is possible to estimate the number of non-radiological fatalities and injuries that are likely to occur. We agree absolutely with the conclusion in Chapter 6.that the most significant potential impact associated with any disposal alternative is the risk of physical injury as a result of a transportation accident.
'Ihank you for the opportunity to review and comment on this Programmatic Environmental Impact Statement.
Sincerely rs, b wt yohn C. Villforth irector nter for Devices and
. Radiological Health e
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