ML20215M389

From kanterella
Jump to navigation Jump to search
Forwards Detailed Comments on NRC Programmatic EIS Re Decontamination & Disposal of Radwastes Resulting from 790328 Accident at TMI-2.Recommends That NRC Not Select Alternatives Involving Discharges to Susquehanna River
ML20215M389
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 04/24/1987
From: Sanderson R
ENVIRONMENTAL PROTECTION AGENCY
To: Masnik M
Office of Nuclear Reactor Regulation
Shared Package
ML20215L984 List:
References
NUDOCS 8705130214
Download: ML20215M389 (6)
v • d • e


Text

e 10 5 r th 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 2046o i Mutft OFFICE OF EXTERNAL AFFAIRS let to W Dr. Michael T. Masnik TNI Project Directorate Office of Nuclear Reactor Regul ation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Dr. Masnik:

In accordance with Section 309 of the Clean Air Act and our responsibilities under the National Environmental Policy Act, the U.S.

Environmental Protection Agency (EPA) has reviewed the U.S. Nuclear Regulatory Consnission's (NRC) Draft Supplement No. 2 to the Progransnatic Environmental Impact Statement (EIS) related to decontamination and disposal of radioactive wastes resulting from the March 28, 1979, accident at Three Mile Island (TMI) Nuclear Station, Unit 2. This draft supplement (NUREG-0683) addresses the environmental and health impacts of disposal of water generated by the accident or used for cleaning up after the accident. The draft supplement identifies a number of potential alternatives for disposal of the water. These include on-site and off-site evaporation, direct solidification, continued on-site storage, and discharge of the water to the Susquehanna River after further treatment.

After extensive review and analysis, EPA has concluded that there are no significant radiation impacts from the proposed alternatives identified in the draft supplement. For each of these alternatives, NRC's calculated EPA dose exposures are below regulatory limits set by EPA and/or NRC.

has therefore rated this draft supplemental EIS L0, indicating a Lack of Objections to the proposed alternatives.

However, because this action involves a new non-routine discharge, EPA recommends that NRC not select either of the alternatives involving discharges to the Susquehanna River. An extraordinary national and multi-institutional (federal and state) effort is presently being implemented toward the restoration and protection of the Chesapeake Bay and its tributaries, including the Susquehanna River. A fundamental part of this restoration effort is to reduce the pollutant burden flowing into the Bay. Therefore, as a general rule, we believe that if there are viable alternatives to such non-routine discharges to the Bay or its tributaries, they should be given great weight.

8705130214 870507 DR ADOCK 05000320 PDR

Finally, because of public concerns regarding TMI and our desire to ensure that the NRC presents the most accurate description possible of the consequences of choosing any particular alternative, we are providing detailed comments to help clarify the basis for NRC's decision-making process.

I have asked Dr. William Kirk (FTS: 590-3909), Director, EPA Three Mile Island Field Station, and John R. Pomponio (FTS: 597-1181) of the Region III staff to provide any needed assistance to you.

Sincerely ,

Richa d E. Sanderson Director Office of Federal Activities Enclosure l

l

l+% wI ? if hw!)

.~ ;

Detailed Comments of the U.S. Environmental Protection Agency on the U.S. Nuclear Regulatory Comission's Programmatic Environmental Impact Statement related to the decontamination and disposal of radioactive wastes resulting from March 28,1979, accident at Three Mile Island Nuclear Station, Unit 2.

Draft Supplement Dealing with Disposal of Accident-Generated Water

1. Page V, Paragraph 3 -- We suggest adding "and lesser amounts of other radionuclides" to the second sentence. A table (or tables) should also be added to Section 2 with complete analytic information for all 25 or so compartments where accident water is located. These tables should include results of all analyses done, with Minimum Detectable Amounts (MDA) provided when results are below detection limits.

The Summary here, the data in Table 2.2, and the initial case data taken from the licensee's (GPUN) proposal for disposal of the accident water seem to conflict with the original tank content data provided by GPUN and what is achievable by ion exchange. For example: if Cs-134 is present in concentrations only 2-10 times less than Cs-137 in the untreated water, it will not be totally removed from the treated water while Cs-137 remains .

2. Page xxi -- Add "U.S." preceding " Environmental Protection Agency."
3. Page 2.2, Paragraph 2 -- Is it appropriate to say "very slight traces" for Sr-90 when the achievable (i.e., after initial treatment) concentration exceeds Appendix B, Table 2 (10 CFR 20) limits by a factor of 33, and exceeds the base case by a factor of 3677 In the base case, Cs-137 also exceeds the Maximum Permitted Concentration (MPC) in Appendix B, Table 2, of 10 CFR 20. We recognize that the table is correct and, that after final treatment, all standards will be met.
4. Page 2.3, Table 2.2 -- We recommend noting that the base case represents retreatment of 40% of the water as it currently exists and the " achievable" represents 100% retreatment.
5. Page 2.5 -- What is the source of the quoted background levels of Cs-137 and Sr-907 For example, EPA's latest Environmental Radiation Ambient Monitoring System (ERAMS) data published for Oct-Dec 1985- and Jan-Mar 1986 indicate a range of 1-3 pC1/1 Sr-90 in milk. A review of data 'or Region III indicates that concentrations have reached or exceeded 5 pCi/1 only two quarters since January,1975, and have not exceeded 3 pC1/1 since September, 1982. Yet, the document lists 5 pCi/l as the background level for Sr-90.

_m - _ _ . . _ _ _ . _ _ . _ _ _ . _ _ _ . _ _ _ _ . _ _ . __. .

,' 2

, 6. -Page 2.7, paragraph 2 -- This paragraph suggests that the only time '

that analysis was done for tritium in the Susquehanna River was in 1977.

> In fact, daily to quarterly sampling and analysis for tritium and other isotopes are done at 17 locations on the Susquehanna by Pennsylvania or EPA (either TMI or ERAMS) and other locations by several utilities including GPUN. The MDAs for these determinations are all of the order of 200-300 I pCi/1, however, and the results are below these levels. These routine programs should be mentioned to avoid giving the impression that no j

sampling has been done since 1977.

7. Page 2.10 - .Is this 1963 report the latest and definitive data on boron?

We recommend that NRC consider more recent references.

8. Page 2.13, para. 4 -- To assure consistency of presentation, we reconsnend extending the drinking water limit discussion to include all isotopes actually present in tanks.
9. Page 2.14, Table 2.5 -- (1) While we do not believe the results would be 4

affected, we reconnend NRC extend the presentation to include all isotopes

^

present in tanks, including a comparison of MOAS to Maximum Permissible i.

Concentration for Water (MPCw) (10 CFR 20, App. B, Table II) and Drinking Water Limits for isotopes found to be below MDA. (2) The MPCw for tritium

( App. B, Table II) is 3x10 3uci/ml, not 3x10 5 uCi/ml . The drinking

- water limit is 2x10 5 uCi/ml .

10. Page 2.15 -- The State of Pennsylvania is in the process of becoming i an Agreement State. If this occurs, it could have an effect on the disposal options for the waste.

i

11. Page 3.1 -- We recommend the use of BEIR 1980 as a reference rather

, .han BEIR 1972.

12. Page 3.2, Table 3.1 (Note b) -- Unless demonstrated to be absent, other isotopes should be mentioned if present in the original tanks.
13. Page 3.14, para. 3.2 -- To clarify this alternative, the standards in 49 CFR 173 for bulk shipment of liquids should be explicitly compared with the nuclide concentrations in the water.

l

14. Page 3.15, Section 3.2.1.1, para. 3 -- Has in situ vitrification been successfuly tested for quantities of waste this large? Intuitively, it seems the electrical demands would be very high.

i

15. Page 3.16 -- The assumptions for nuclide concentrations for accident

]

analysis should be explicitly stated. Both the base case and achievable case given in this supplement represent the average case of 2.1 million <

gallons of water which is actually in 25 separate compartments or tanks 4

! with concentrations as much as 2-3 orders of magnitude different from n the base case. There does not appear to be any simple way to achieve one uniform batch of water.

, _ . _ - - , _ _ _ . _ _ _ _ _ . _ _ . _ _ , _ _ . _ . , _ _ . _ . _ _ _ _ . -- . _ , , . - , . _ . ~ . _ . - _ _ , _ _ _ _ , _ _ _ _ .

3

.. p

16. Page 3.20, para. 3.3 -- Has the rist of transporting cement to the site been considered in the accident predictions for the options involving solidification of water or evaporator bottoms?
17. Page 3.23, Table 3.9 -- The predicted concentrations of Cs-137 in the finished cured concrete are not different from the average concentration in soil in this area. This would not add to gama exposure since it would, in effect, become part of an infinite slab source.
18. Page 4.9 -- Routine determinations of gross alpha and beta activity, as well as radium, etc., are done by Pennsylvania at many locations and should be mentioned.
19. Page 4.9, Sec. 4.1.3, para. 1 -- What are the units for the water table gradient? Offsite well monitoring conducted by GPUN and EPA should also be mentioned.
20. Page 4.12 -- The description of the vicinity given here should be cl ari fied. TMI is in the extreme NW corner of the area described.

Interstate Route 95 and State Route 10 have minimal importance to the area while routes not mentioned (Interstate Rtes. 81, 283, and Rtes.11,

' 15,322,422) are important.

21 . Page 4.13, Fig. 4.7 -- The figure shows TMI to be in the Northeast part of PA instead of the South Central, and does not show routes from TMI to Interstate Rte. 80.

22. Page 5.1, Sec 5.1, para. 2 -- The level of 87 mrem is probably somewhat lower than real per capita background exposure. From the Aerial Radiation Monitoring System overflight data, ambient external gama radiation ranges from 70-120 mrem /yr. Also, many houses in the TMI area have elevated radon levels, resulting in lung doses much higher than the external gama levels.
23. Page 5.2, Table 5.1 -- The impact of the Short-Tem River Discharge is the same as that of Long-Term River Discharge only if the same river flow is used. If a more reasonable higher flow is used, impacts are much lower.
24. Page 5.3, para,1 -- We recommend adding "at 87 mrem /yr." before "300,000 people will receive..." .

l

! 25. Page 5.4, Sec. 5.2, para. 2 -- EPA policy is to use BEIR 1980 values and the relative risk model for calculating risks which, as noted, will yield slightly higher risk estimates.

I

a

! 26. Page 5.8, Sec. 5.4, para. 2 -- The accident scenario described here

' would appear to be impossible rather than highly improbable since the water is in 25 separate tanks / compartments.

27. Page 5.9, Table 5.2 -- See comment for page 3.2 - Cement transportation.
28. Page 6.1, Section 6.0, Conclusions -- EPA concurs with the NRC Staff's
conclusion that no significant environmental impact from a radiological I standpoint will be incurred from any of the proposed alternatives.

! 29. Appendix B is so generally written that persons without a technical

! background cannot understand how the calculations were made. Many references, including the applicable NRC regulatory guides, are not mentioned. It is not clear how the pathways to man were calculated, what bioconcentration,

accumulation, and transfer factors were used, what fish / shellfish species were considered and how food web elements were incorporated into the model . Major clarification or explanation is needed.

1

30. Page B.1 -- Where do the data for swimming come from? There appears to be very little swiming in the Susquehanna River in the TMI area.

1 31. Page B.2 -- What is the basis for the shellfish harvest and consurption figures? No references are given.

! 32. Page B.3 -- What is the basis for 434 lb./yr. vegetable consumption?

This sounds high, especially if this is supposed to be local consumption ,

of locally grown vegetables.
33. Page B.4 -- What is the basis for doubling innalation dose to account for

, ingestion of contaminated vegetables? This sounds very conservative for Nevada where precipitation, fog, etc., are relatively rare and gardens

- would have to be irrigated.

I 34. General. For the sake of clarity it would be instructive to include a section or appendix explaining what estimates of 0.03 or 0.4 or 1.5 i

cancer deaths really mean in terms of likelihood of having 0,1, 2, 3, 4 i cases or deaths.

4 ,

i I

l I

l l

~ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ . . . . . _ _ . _ _ . . . _ _ - _ _ _ _ . _ _

Retrieved from "https://kanterella.com/w/index.php?title=ML20215M389&oldid=3233631"