ML20215M422

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Comments on Draft Suppl 2 to Programmatic EIS Re Decontamination & Disposal of Radwastes Resulting from 790328 Accident at TMI-2.Suggests That Analysis Should Also Discuss Plans for Mitigation Measures to Be Undertaken
ML20215M422
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 03/03/1987
From: Blanchard B
INTERIOR, DEPT. OF
To: Travers W
Office of Nuclear Reactor Regulation
Shared Package
ML20215L984 List:
References
NUDOCS 8705130228
Download: ML20215M422 (1)


Text

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Tf31 mum E i m-6 United States Department of the Interior

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OFFICE OF ENVIRONMENTAL PROJECT REVIEW WASHINGTON, D.C. 20240 m:

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T, ER 87/66 l/AR 1987 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:

The Department of the Interior has reviewed draft supplement 2 to the programmati environmental statement related to decontamination and disposal of radioactive wastes resulting from the March 28,1979 Dauphin County, Pennsylvania, and has the following comment. accident at Thr The draft supplement to the programmatic environmental statement indicates plans monitor ground water, both upgradient and downgradient from possible sources of contamination.

We suggest that the analysis should also discuss plans for mitigatiori measures detected. to be undertaken in the event that movement of pollutants in ground water is Sincerely,

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Dr. Michael T. Masnik TMI Project Directurate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

RE: Draft Supplement No. 2 to the Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting f rom March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2 (NUREG - 0683)

Dear Dr. Masnik:

The above referenced document has been reviewed by various agencies of the State of Maryland. This transmittal provides collective comments on the subject document and reflects the State of Maryland's position regarding disposal of the accident-generated water.

Maryland concurs that disposal by any of the nine evaluated options would result in insignificant environmental or radiological impact given the radionuclide inventory and chemical constituency described. We also agree that liquid storage onsite (no-action alternative) provides no reasonable benefit and merely forestalls the disposal issue. It should receive no - further consideration.

With regard to the licensee's proposal--forced evaporation and offsite disposal of evaporator bottoms--we have no objection to approval of this alternative by the Commission. It would appear however, that options involving bulk shipment offsite would result in a substantial savings in money and, more importantly, in time. Adoption of one of these alternatives would seem to t better serve the cause of expediting the TMI-2 cleanup, a desire expressed by consensus. The draft supplement notes that Department of Energy (DOE) approval is necessary for implementation of elements within bulk shipment options or forced evaporation. However, there is no discussion of DOE's willingness to accomodate the licensee's proposal or their preference among the alternatives.

It would seem that the next logical step would be NRC solicitation of DOE approval for options which require their participation, advisement of which would dictate the range of remaining alternatives. Only after this interaction can the Commissioners review the licensee proposal and evaluate its merits relative to bulk shipment alternatives.

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Although we agree with the Commission that the envirorrer.tal and radiological consequences associated with disposal of the accide.ut ' generated inventory are trivial, we are opposed to implementation of either of the two options which result < in releases to the Susquehanna Riv er. The degree of perceived risk and public opposition to a river discharge remains high. This fact was recognized by the licensee in ' their proposal, and influenced their selection of another alternative. We _ acknowledge the Commissibn's awareness of this sustained sensitivity and encourage consideration of this fact in the evaluation and approval of a disposal alternative.

The Sute of Maryland offers no substantive comments on form or content other than 'those indicated above. We appreciate the opportunity to review the document and provide these comments.

Sincerely, Richard I. McLean Admicistrator, Radioecology Power Plant Research Program Department of Natural Resources RIM /rva ec: David Carroll, Assistant to the Governor

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