Text

Forwards Environ Assessment of Using EPICOR-II Sys for Cleanup of Radwaste Water from Auxiliary Bldg at unit-2. Waste Disposal Is Not Included in Plan
	ML20244A732
Person / Time
Site:	Crane
Issue date:	06/20/1979
From:	Vollmer R; NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE
To:	Harold Denton; Office of Nuclear Reactor Regulation
Shared Package
ML20244A735	List: ML20244A732; ML20244B879; ML20248B870; ML20248B918;
References
	FOIA-89-88 NUDOCS 7907180507
	Download: ML20244A732 (150)
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{{#Wiki_filter:. e i ' ' f 7% (' CLEAR REGULATORY COMMIS$10N f 4 U b -- g 1 ., wam aton. o. c. no g} p JUN 301979 / MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM: Richard H. Vollmer, Director TMI-2 Support

SUBJECT:

ENVIRONMENTAL ASSESSMENT ON USE OF EPICOR-II AT THREE MILE ISLAND W Enclosed for your coments is an environmental assessment op_ the u of_EDfCOD-11_for decontamination of intermediate level water at TMI-2. )'~g This is in response to the Commission directive of May 25, 1979. OGC y is requested to route this to the Commission' for coment. Following the incorporation of comments, which are requested by June 26, 1979, we plan on holding a briefing in either Middletown or Lancaster, Pennsylvania to discuss this assessment and to provide copies to interested. members of the public. Following a brief period.for pubite coment, we will evaluate coments received and detennine if the use of EPICOR-II is appropriate for the processing of intermediate level water. hM ' Richard H. Vollmer, Director TMI-2 Support cc: D. Eisenhut J. Collins S. Eilperin, OGC

5. Ostrach, OGC /

Larry Chandler, OELD J. Fouchard, PA F. Ingram, PA R. Mattson D. Ross TMI-2 Support Task Force

Enclosure:

gh As stated g0 _f f o______________ J

~7- ~r -c c ENV8RONMENTALA$.SSMENT:USE OF EPICOR-f X AT TbE HRE fStANd. f .1.0 Proposed Action The proposed action is to use a system, EPICOR-II, for the cleanup of radio-Jk? active contaminated waste water which has accumulated in the Unit 2 auxiliary building tanks as a result of the March 28, 1979, accident at Three Mile - Island (TMI). The proposed action is limited to cleanup and storage of such j waste and dose not include the disposal of, the decontaminated water or the. disposal of solid waste generated from the cleanup operation. l l 2.0 Introduction i l As a result of the March 28, 1979, accident at the TMI Unit 2 facility, a sig-nificant amount of. radioactive contaminated water has been generated; and collected in Unit 2 auxiliary building tanks. This waste water was produced primarily from the following four sources:

1) an inventory of waste water existed in Unit 2 auxiliary building tanks prior to the accident. 2) during the

~ early phases of the accident, contaminated water from the reactor containment building sump was transported to the auxiliary building and collected in vari-ous tanks, 3) letdown from the reactor coolant system has resulted in a net increase to the inventory of letdown water which existed prior to the accident, and 4) leakage from system components in the auxiliary building has been a small but continuous source of waste water to the inventory which currently exists in the auxiliary building tanks (approximately 265,000 gallons). The level of contamination of the water in these tanks ranges from 0.1 to 35 uCi/ml of Cs-137. Because of the relatively short half-life of I-131 (8.1 days) to that of.Csr137 (30 years), Cs-137 has become the dominant isotopic contributor. f The quantities and activity levels of the current inventories in' tile auxiliary buildingtanksirediscussedinSection3.3.3. i L

e.,c. s h () ' s 4 Following the March 28 accident, Metropolitan Edison Company (the licensee) ini tiated the design and construction of a system which would have the capability of decontaminating water with an ac ivity level up to 40 uCi/ml of Cs-137. The design and construction of a new processing system was necessary for the following reasons. The existing liquid waste processing systems for Units 1 and 2 were designed for processing water with significantly lower levels of activity than currently exist in the TMI Unit 2 auxiliary building tanks. For example, the expected reactor coolant concentration of Cs-137 during normal operation of the plant is 0.018 uCi/mi or a factor of approximately 2,000 times lower than the highest Cs-137 concentration presently in the auxiliary bulding tanks. In addition, the contaminated condition of the Unit 2 auxiliary building after the accident rendered the building unusable for the purpose of continuous, planned processing of the inventory of waste water from the build-ing radwaste control panel. The recognized need for a new processing system resulted in the development of the system which is known as EPICOR-II. In response to a complaint for injunctive relief filed by the City of Lancaster, Pennsylvania, in the' United States District Court for the District of Columbia, the United States Nuclear Regulatory Commission directed its staff to prepare an environmental assessment regardino oroposals to decontaminate and dispose of radioactively contaminated waste water from the 114I Unit 2 facility. The assess-ment is to be divided into several portions of which the first. This portion f deals with the proposed decontamination of the intennediate-level

waste water in Unit 2 auxiliary building tanks using EPICOR-II system.

This assessment i

Intennediate-level waste is defined as waste having I-131 and Cs-137 concentrations greater than 1 uCi/ml but less than 40 uCi/ml.

} ,.c (i} 3-includes discuss!cn of potential risks to the public health and safety, in-cluding occupational exposure and the risk of planned (gaseous) end accidental (gaseous and liquid) releases, and a discussion of alternatives to the EPICOR-II system. It does not consider the disposal of the decontaminated water inte-the Susq"Maar River following use of EPICOR-II since this is precluded pending an evaluation of the various disposal alternatives. f M A m w. This assessment is the fonnalization of the evaluations and regulatory guidance that have been provided by the NRC staff at TMI from March 28 to the present. During that period, and on a continuing basis, the NRC on-site support staff has been engaged in design and safety evaluation of the licensees proposed means for processing intermediate level waste water, including en evaluation of the need for EPICOR-II (see Section 2.p). The NRC staff concurred with the ' I [ licensee that desian construction, and operation of EPICOR-II should proceed h W d p-on a high priority basis. The NRC staff has provided design guidance and cri-teria for the EPICOR-II processing system, the building housing the system, g the building exhaust filtration system and the process vessel vent filtration system. The NRC staff has monitored and inspected the design, construction, and preoperational testing of EPICOR-II since its inception. The EPICOR-II system, which has evolved from this regulatory effort, has been designed for remote receipt, handling, and processing of contaminated water from the TMI Unit 2 auxiliary building with minimal occupation &1 exposure and no adverse N impact on the health and safety of the public. 2. Need for Waste Water Processing The March 28 accident at TMI Unit 2 and subsequent recovery operations have

c 1 (. (, 1' 4 t-generated a substantial amount of contaminated water which is contained in the reactor building and in tanks in the auxiliary building (see Section 3.3.3). Although these buildings are of high integrity such that the contaminated water can be positively controlled for an indefinite period, there are several reasons why decontamination of the water is e3JanHel; The waste water in the TMI Unit 2' auxiliary b ing continues to be a source of release of. gaseous radioactivity to the auxiliary buliding and subsequently to the en-l vironment, because o degassing. The waste water is also a direct source of ec exposure to operations and construction personnel who need access to the auxi-h liary building. The continued safe shutdown of TMI Unit 2 depends upon the operability of original plant ' equipment located in the auxiliary building and the use of additional. equipment being installed in the course of. completing deifications in progress. The surveillance and maintenance of this equipment, h which is necessary to assure maximum reliability, is adversely affected by f radiation levels associated with the stored liquid. In addition, available e f(p v capacity of the tanks in the auxiliary building is needed in the event that / pumping of water from the reactor building is necessary to protect the opera-bility of reactor building components and systems which maintain continued safe shutdown of the facility. Therefore, it is necessary to process the in-ventory of waste water in the Unit _2 auxiliary building hin order to im-mobilize the entrained activity and thereby reduce potential sources of environ-mental and occupational exposure and provide surge capacity for water trans-ferred from the reactor building should this become necessary. The EPICOR-II processing system has been specifically designed and constructed'for the purpose

,r N r p p w .S. / of processing TMI Unit 2 intermediate-level waste and represents the best b D / \\ alternative for desired decontamination of that waste (see Section 5.0, Al-ternatives to the Use of EPICOR-II). The NRC staff believes, therefore, that protection of the public health and /! safety would be enhanced by the processing of the contaminated water in the TMI Unit 2 auxiliary building to the maximum extent possible. Immobilization of the activity currently held in the liquid by processing through EPICOR-II would render this activity a less likely source of public or occupational ~ exposure. 3.0 EPICOR-II System 3.1 Chemical Cleaning Building i The EPICOR-II system is housed in an existing on-site structure called the chemi-cal cleaning building. This building was originally intended to be used in the chemical cleaning of the steam generators for THI Units 1 and 2. It is a rec-tangular shaped building with dimensions of 48 ft wide by 60 ft long by 52 ft high. The foundation of the building and the walls up to a height of 13.5 feet above the basement floor are concrete and the upper walls and roof are of i structural steel. The foundation of the building is designed to seismic Category I criteria as are i the primary concrete walls and structural steel frame. The building also con-i tains a stainless steel lined sump and is therefore watertight up to s height of 13.5 feet above the basement floor and w~ould contain the release. of water in the event of rupture of the tanks in the buiding. The chemical cleaning building

,a ,,s, %::' O contains two large water storage tanks, the chemical cleaning solution tank (CCST) with a capacity of 95,000 gallons and the rinse hold tank (RHT) with a capacity of 133,000 gallons. 3.2 Modifications for EPICOR-II-In order to convert the chemical cleaning building for use in processing inter-mediate level waste, several modifications were made to the building. These included the following: 1. Installation of the EPICOR-II system (vendor supplied equipment) to the ' 'y v 8"' ?* building. Specifically a prefilter, two demineralizers, a precoat and a chemical addition tank and associated pumps, pipes, valves, and instru-j I mentation for the EPICOR-II system; 2. Addition of shiesa walls aro~und EPICOR-II equipment. The shield walls were added for the protection of personnel involved in the operation of this system (a description of the shielding is contained in Section 4.0); 3. Addition of an overhead monorail hoist system. The hoist system was pro-vided for removal and replacement of the demineralizers and prefilters. The monorail system extends from the north side of the building above the pre- )w filter through the south end of the building, extenMac 1 Ajaa+ notside the h' f j building over a cask loading area at which point the shielded prefilter and (U q demineralized casks can be loaded onto a truck; , 4. The chemical cleaning building was constructed into a low leakage confine- ,g ment building by spraying the interior of the structural steel portion of the building with an epoxy sealant. The sealant was added.to prevent air and radioactive material outleLage from the building; 4 l

u -,n p p .e w 7, 5. The addition of an exhaust ventilation filtration system to maintain the chemical cleaning building at a negative pressure. This also minimizes air out-leakage and directs air flow through the filtration system. This sy' stem includes filtration of the air through a prefilter, a high 'effi-ciency particulate air (HEPA) filter, a charcoal' adsorber and a final HEPA filter. The purpose of this filtration system is to remove radiciodine and radioactive materials in particulate fonn present in the air before it is released to the environment. A new building was constructed, directly adjacent to the east side of the existing chemical cleaning building, to house the air filtration equipment; 6. Addition of a TV monitor' control building directly adjacent to the north-west section of the chemical cleaning building. Since operation of the EPICOR-II system is by remote means, this building is provided for remote system operations where the EPICOR-II system can be viewed and controlled. htf' ign of the EPICOR-II System-3.3 Des The EPICOR-II system consists of a vendor supplied liquid radwaste processing system. The system is designed to process by filtration and ion exchange radioactive contaminated water contained in the auxiliary building tanks of TNI Unit 2 and to transfer this processed water to Unit 1 for ultimate dis oy position. The EPICCR-II system is designed. 'ctio A such a manner to h i limit releases of radioactive material to the environment to levels which are "agis reasonably achievable", in accordance with 10 CFR Part 50.34a and){ h 10 CFR Part 20. In addition, it is designed to be operated and maintained in k f%D such a manner to maintain exposures to plant personnel to levels which are f

o - {}. () "as low as is reasonably achievable", in accordance with the guidance given l ~ in Regulatory Guide 8.8. 3.3.1 Description of the EPICOR-II System The EPICOR-II system consists of the following components, all of which are located in the chemical cleaning building except as noted: Y 1. Cap-GunPumps(5)

2. ~ Transfer pump 3.

Prefilter - containing silver impregnated charcoal 4. Demineralizers (2) -- one cation bed followed by a mixed bed-5. Miscellaneous waste holdup tank - located in the TMI Unit 2 auxiliary building 6. Clean wastes receiver tank (fonnerly the rinse hold tank) - 7. Off-spec water receiving / batch tank (fonnerly the chemical cleaning solutiontank) 8. Chemical cleaning building sump pump 9. Monorail hoist system

10. Ventilation filtration system A flow diagram of the system is attached as Figure 1.

The liquid waste pro-cessing system operates at essentially atmospheric pressure in the following manner. The miscellaneous waste holdup tank (MWHT) is located in the auxi-liary building of TMI Unit 2 and receives water from the specific auxiliary 4 building tank to be processed. The first Cap-Gun pump is used to pump water from the MWHT to the prefilter in the chemical cleaning building through the yard piping. The piping is enclosed in a shielded guard pipe, the open end

.a V,' ;~ . rp ~ ) of which tenninates inside the chemical cleaning building. Thegrefilter con-h tains a precoat material which enables it to remova yrticu; ate radioge wastes (e.g., activated corrosion products) of greater than 5 microns and other suspend'ed solids. The prefilter also contains silver impregnated charcoal l l which is highly efficient for the removal of indina from the waste stream J (removal efficiency greater than 99.9%). After passing through the prefilter, the water is circulated by the Cap-Gun pumps through the two demineg h, ar, ranged in ler.ias. The first demineralized contains cation resins which are highly efficient for removal of cadom from the waste stream (removal effici-encyofapproximate1"90%). The second demineralized contains _ mixed resins (cation & anion) which are efficient for removal of various radionuclides in-cluding cesium and iodine (removal efficiency of approximately 90%). After processing, the water s collected in the clean water receiving tank (CWRT) which has a capacity of 133,000 gal. In the CWRT the water will be sampled g and a,nalyzed for nuclide identification. (f the analysis shows that the pro-ctivith acceptable limith(fil cessed waste contains concentr the g411 than he transferred tofu U.-" 1 - M sposai m .. O i.m y un e un. Processed wast ichTnot suitable for transfer to TMI Unit 1 will be pumped to the off spec water receiving / batch tank (0WRT) which has a capacity of 95,000 gallons. Watqr in this tank will be rec _ycQed through the EPICOR-II system fopi.el precessing. Thekonorail hoist systkonsists of a 20 ton hoist mounted on a monorail which extends from above the prefilter, acrosr; the top of the demineralizers, and to approximately 18 feet outside of the chemical cleaning buiding over the cask

= ,e (, 43 10 W o loading area. The purpose of the hoist system is to provide for removal and replacement of the demineralized and prefilters when they have reached the maximum radioactivity loading permitted by the operating procedures or become chemica'lly depleted. The radioactivity loading is limited by Contact radia-Y# tion deprTa~te ra2M@ on the vessel to meet personnel handling requirements. d.er 3 The operapn of the monorail hoist system is done. remotely by use of a closed circuit TV system located in the control building located adjacent to the chemical cleaning building. l i The chemical cleaning building ventilation system maintains a negativepure in the building. The exhaust ventilation system consists of a heating unit, a moisture separator, a filtration unit, a fan assembly, a radiation monitor and a weatherproof enclosure. Building exhaust air is passed through a moistuie separator and an 80 KW heater to remove moisture from the air and lower its re-lative humidity to improve the iodine removal capabilities. Th s then-passed throuch the filtrAtv =it M9 centf:t; cf ; pr:filte, : high ;ffi_ cigacy- ;;rti:L1 aie air (nen) iil Lc., : charca=1 ah urher and a m a1 wroa filter. The HEPA filters are used to remove radioactive material in particulate fonn, while the charcoal adsorber is used to remove any radiciodine that may be present in the offgas. The fan assembly draws air from the building and exhausts it through a duct to a local stack at thb roof line of the chemical cleaning building. The radiation monitor installed in the discharge duct !yicatg. ic._ of ventilation from the fan samples air in the fan discharge line. $ system exhaust activity is provided both locally and remotely in the control building in the event that radiation levels in the effluent stream exceed a preset level, w< t

4 4. The chemical cleaning buildino sumo _is a stainless steel lined pit located in the northwest corner of the building. Ang water frem erneess vessel over-flow or from other ecuinment leakaae is collected in the sumo. A sump pump trans'ars water from the sump to the 0WRT. The sump pump starts automatically on a level indication in the sump. 3.3.2 Sources of Radioactive Water Yq $gi The EPICOR-II system will process approximately 265,000 gallons of intennediate 6 sk$ level waste water currently contained in TMI Unit 2 auxiliary building tanks. J Waste that is acceptable for processing in the EPICOR-II system is that which g'd i has iodine-131 and cesium-137 concentrations of lesp.han 40 uCi/m1_, rege;ti;;-- . I IF WThe tanks in THI Unit 2 auxiliary building which are to be processed using y the EPICOR-II systan are the following: 1. reactor coolant bleed tanks (3) 2. miscellaneous waste holdup tank 3. auxfliary building sump 4. auxiliary building sump tank 5. neutralizer tanks (2) 6. waste evaporator condensate tanks (2) 7. contaminated drain tanks (2) 8. miscellaneous sumps (4) 1 3.3.3 Volume and Activity of the Waste Water to be Processed by the EPICOR-II System Table I contains a listing of waste water inventories stored in TMI Unit 2 aux-iliary building tanks which are intended to be processed by the EPICOR-II system.

h () 12 - Table 2 contains a listing of princip radionuclides concentrations for each of the sources in Table 1. Table 3 lists the half-lives cf the principdradio-nuclides listed in Table 2. e The liquid volumes are established from tank level measurements taken by plant personnel. Activity levels are established from liquid samples analyzed by in- ) plant staff, as well as by various subcontractors, thus providing duplicate sam- '\\ ple analysis in all cases. All liquids processed through the EPICOR-II system N will be at aqtivity levels of less than 40 uCi/ml of Cs-137. Cs-137 will be the' predominant and controlling isotope at the time these liquids are processed. 3.4 Design Features for Spill Prevention There are a number of design features built into the EPICOR-II sys. tem to prevent spilsofradioactivewater. The following is a listing of these features and_ a discussion of each: a. The piping carrying radioactive contaminated water from the miscellaneous waste holdup tank in the auxiliary building through the yard to the EPICOR-II system in the chemical cleaning building is enclosed within a 4" d,iameter cuard pipe,. Radiation shielding has been provided around the guard pipe to minimize personnel exposure (see Section 4.0 for a discussion of radiation shielding and personnel exposure);, b. The chemical cleaning building is of watertight seismic ratagnry T concrate construction _n to a height sufficient to contain the water in the large hold-up tanks in the event of rupture of these tanks; mn +n the chemical cleaning building sump. The c. All sygem overflow linae sump pump routes all collected leakage to the off spec water receiving

' (,. ,a ..).J batch tank. The sump pump 'is started either manually from the control ' panel or automatically. If pump. start is automatic, it occurs when the sump level reaches a preset height. A high sump. level' alarm is also pr'ovided on the control panel in the control building; d. Water level in the prefilter is maintained by a level probe and a sole-i noid valve. On high level, an alann will sound on the control panel in l the control building; Level g r" = t:tian in the demineralizers is simila_r to that for the e. prefilter. The high level alann for the demineralized will annunciate i in the control building; f. For the clean water receiving tank and the off spec water receiving batch tank, an overflow line with a loop seal is provided near the top of the tank. Tank level indication is provided on the control panel in the con-trol building; ( All ptem componerLte dich be C av45'- 5: -ana-nlons are nravidad uth g. e i . drip trays to collect leakage. Tubing from these drip trays is routed to k the' nearest floor or equipment drain; h. All system liquid piping is welded stainless steel to prevent system leak-age. All installed fittings and hoses have pressure ratings that exceed the maximum discharge pressure of the pumps used. All discharge hoses have a pressure rating of 600 psig or greater. AlQsesandfittingswil]e hydrostatically tested oria pump diaphragms are designed o rup-ture at pressures greater than 125 psig. The maximum available air pressure to drive the pumps is 100 psig (thus protecting diaphragm 1'ntegrity). All hose connections are taped and wrapped with plastic to contain drips from fittings.

m Q J - s There are also des,ign features to orevent spills of radia=rtie -nn+==4nste water from the tanks in the aoriliary buildina which are to be processed in l EPICOR-II. These features have been previously evaluated and found acceptable in the 'S,afety Evaluation Reoort related to the operation of the Three Mile Island Nuclear Station, Unit 2, NUREG-0107, dated September 1976. As indic ed in that document these design features will include level instrumentation which will alann in the control room, and curbs and drains which will collect liquid spillage and retain it for processing.. Also, the release of all pro-cessed liquids from TMI Unit 2 is through the TMI Unit '. discharge li.ne. This discharge line h'as a radiation monitor which will alann and automatically ini-tiate closure of the discharge valves on a preset value. We have also evaluated the potential consaeuances of a nice break in tha EPICOR-II system inside the chemical cleanino building. From a radiological standpoint the ' worst case pipe break is a break in the liquid waste inlet pipe to the EPICOR-II prefilter. We conservatively assumed that during the acci-dent, the EPICOR-II system operator would not monitor the syst.em parameters,. for loss of liquid flow, CAP-GUN pump shutoff from each of the three process vessels, or notice any abnormalities on the remote TV viewing system.

Further,

& Y AM we assumed that the entire contents of approximately 20,000 gallons from the 4 miscellaneous waste holdup tank would spill on the' floor and partition iodine with a factor of 0.0075. We assumed that the iodine concentration in the spilled water is 3 uCi/ml (the highest con, centration) and tha+ thawateris)N fr.cm one n# t % r= ;.m coolant okd t96 The building air is ventilated through the chemical cleaning building air filtration system consisting of HEPA filters and charcoal orbers and the iodine is subjected to an assumed

a i a Ly f decontamination factor (DF) of 20. Assuming a X/Q of 4.5 x 10-5 sec/m, the 3 i calculated inhalation dose to an individual at the site boundary is approxi-I mately 0.004 of the 10 CFR Part 20 limit (500 mrem). 3.5 esign Features to Minimize Gaseous Releases. 1 There are a number of design features built into the EPICOR-II system to mini-f4 .y mize gaseous releases to the environment. The following is a listing of these features and a discussion of each: a. The chemical cleanino haildhg has been sealed with an epoxy sealant to minimize both inleakage and outleakage of air; b. An exhaust ventilation system has been added to the building to maintain the building at a negatiya pree g e. This prevents outleakage of air from the building and also routes any airborne radioactivity in the l l building to the exhaust ventilation filtration system; c. The filtration system, consisting of HEPA filters and a charcoal adsorber provides removal of radioactive particulate' and radioiodine, respectively, l 'from the building air before it is released to the environment; i d. A radiation monitor in the ventilation system ductwork provides an indica-tion of radiation levels both locally and in the control building. In addition, the radiation monitor will provide an alarm if the radioactivity I in the release exceeds a preset level. In this manner, releases of radio-activity will be carefully contrelled within raq"f eed 14=4+e z e. Within the building the system tank vents are provided with in-line heaters, moisture separators, HEPA filters, charcoal a orbers, and HEPA filters to

~ 1 i [- ,a gb SDI M. y' l adsorb / evolved tod1" and remove particulate. The vents from the pre-filter and demineral._ ers are vented to the off spec water receiving batch tank.- f. Th'e building sump will be a covered sump. Iodine fixing chemicals will be added to the sump to minimize iodine releases. g. Iodine fixing chemical will also be added to the off spec receiving batch - tank and to the clean water receiver tank to minimize fodine releases. We have calculated gaseous releases as a result of operation of the EPICOR-II system based on the design capabilities of the system and the contaminants in the waste water. Based on these calculations, we estimate the relaaee 4 Xe-133 will be less than 1 e4e i.t.e.ciease vi i-iWwill be less than r 10~4 Ci as a ra@t Of preeersing dl_gf the auxiliary building water. 1 The off-site dose, as a result afssuch releases, will be6 significant The bases used in this estimate are as follows: a. Data obtained on nuclide activity levels in the reactor coolant and the reactor coolant. bleed tanks; b. Data on EPICOR-II system flow rate and chemical cleaning buildi.ng ventila-tion rate; c. Design of charcoal sorbers on the off-spec, receiving tank vent and in-the chemical cler.ainc building ventilation exhcust filtration system, 3.6 Conformance of EPICOR-II System Design with NRC Regulttory Guides The EPICOR-II system has been dg,in accordance with the fn11nwing Dap-Guides: 1 J

,.t, (j:1 d e 1. The EPICOR-I waste processing sys and the building housing the system meet the design guidance given in Regulatory Guide 1.43. "De-sign Guidance for Radioactive Waste Management Systems, Structures and j Coinponents Installed In Licht Water fnnled Nue1sar Power Plants." The%1 ding ventilation systgfor the building housing EPICOR-II is de-2. signed in conformance with Regulatory Guide 1.140, " Design, Testing, and i Maintenance Criteria. for Nomal Ventilation Exhaust System Air Filtrab and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." 3. Th uent monitopor the building ventilation exhaust system for EPICOR-II is in confomance with the requirements of Regulatory Guide 1.21, l " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactivity in Liquid and Gaseous Effluents from Light-Water-C,ooled Nuclear Power P1 ants." 4. The rrdiativogtouongf the EPICOR-II system, the chemical cleaning facility, and the spent filter and resin handling systems are consistent with the guidance of Regulatory Guide 8.8, "Information Rele-vant to Insuring that Occupational Radiation Exposure at Nuclear Power l Systems will be As low As Is Reasonably Achievable." i 4.0 Occupational Exposure A design criterion for the facility was that (ccupatic31 exposupr should be maintained "as low as is reasonably achievable." Thergfore, th.e design was 3 made cgant with the guidance of Regulatnry Site 8.8. The sections below describe the design and operational feat'ures included to minimize occupational f ~ exposure. The anticipated dose rates and occupational exposures are also described. i

N hy 18 - V Cogrete shield walls,12 inches thick and 13.5 feet high, surround the EPICOR-II processing area. The Mis installed inside a gylindryical concrete cask, 12 inches thick. The cask is then surrounded by a rectangular lead be'ick wall, 5 inches thick. The top of the steel liner which houses the prefilter is filled with 3 in:hes of lead shot. The prefilter is also covered ' by a steel lid, 5 inches thick, The lid has cutouts for the hose con.iections. The p r-Hval demineralizerjs installed inside a cylindrical concrete cask, 12 inches thick. The cask is surrounded by a rectanguNe lead brick wall, 5 inches thick. The cesium removal demineralized is covered Sy a steel S'ield collars will be lid, 5 inches thick with cutouts for hose connections. h installed around the pipes in'these cutouts on the prefilter and c'sium removal e demineral izer. The mixed bed demineralized is also surrounded by a rectangular lead brick wall, 3 inches thick. The strainer is shielded with 8 inches of concrete block. The post-filter is shielded with 3 inches of lead brick. The feed line from the TMI Unit 2 auxiliary building is shielded by lead bricks, 4 inches thick. The shield bell used to transfer the prefilter and the cesium t removal dejneralizer.onto the truck provides 3-1/2 inches of l'ead shielding. Concrete walls, 24 inches thick, separate the rooms through which the building l is accessed from the room containing the filter and demineralizers. A water box window,18 inches thick, is included in this wall to allow direct viewing of the system from a shielded area. The EPICOR-II facility is equipped with radiation monitors mounted inside the lead, brick walls around the prefilter and the demineralizers_. The design cri-teria call for the prefilter to be changed if the prefilter reaches a dose l l

,c, n ((. l (/ 3 rate on contact of 2500 rem per hour. The cesium removal demineralized, mixed bed demineralized, strainer, and post-filter will be changed when dose rates at i contact reach 400, 20, 3 and 3 ran per hour, respectively. j The truck which is used to transfer the spent filters and demineralized has a i cylindrical reinforced _c,oncrete shell 15 inches thick. The transfer shield bell holding the spent filter or cesium removal demineralized will be placed inside this concrete shell for additional shielding. The mixed bed deminera?- izer will be lifted into this shell without a transfer bell. The gntrol building for EPICOR-II is located outside of the chemical cleaning The operators control the system from the control building by means i of remote cameras, controls and readouts from instrumentation. Using the crane and transfer bell, the spent filters and demineralizers will be removed from the facility without entering the EPICOR-II room. Since the hose connections and disconnections of the filter and demineralized process vessels will require '(f rect handling by personnel. ouick connectfH:ccre hnsas /nd cans will ha Qsed. Ladders will be provided to facilitate access to the tops of the filter and demineralizers to make connections. Features are included to allow flushing of piping and hoses and to allow sampling to be performed from the outside of the EPICOR-II room. l The operators for EPICOR-II will be trained in the operations of the system. This training will include numerous trial operations of the various systems before radioactive water is processed. The EPICOR-II system uses the same type of equipment that the operators are already experienced in operating. l

A ,m (..; / tc . - Covera'ge by health physics personnel will be provided whenever the EPICOR-II building is accessed. Based dn the contact dose rate limits on the filter and demineralizers, the shielding provided for the process vessels, and the thickness of the lead brick walls, the following is a discussion of estimated radiation dose rates. The estimated radiation dose rata n"tside of the -lead brick walls surrounding the filter and demineralizers is _15 millf ram nar hnor. The estimated dose rate on top of the steel cover plates is 100 millirem per hour with I rom car hour above the cutouts due to streaming. The estimated dose rate above the mixed bed demineralized is 20 rem per hour. The estimated dose rate at contact with the strainer and post-filter is 3 rem per hour. The estimated maximum dose rate outside of the facility is 2.5 millirem per hour except during filter or demineralized removal by crane. The estimated dose rate outside of the transfer bell with a cesium removal demineralized in it is' 100 millirem per hour. The estimated dose rate outside of the shield shell on the truck with the mixed bed demineralized in it is 100 millf rem per hour. For a very short time before being lowered onto the truck, the mixed bed demineralized could have a maximum dose rate on contact of 20 rem per hour. }& gmaximtan dose to an individual at the site boundary on [conti f4r The estima Qdps lau mil 1[ rom. Tnis dose includes all of the handling than 1 operations and is less than 4% of the 25 milfrem annual limit in 40 CFR 190. EPA Uranium Fuel Cycle Standards. t

./ n up,w. c,.- m. Disconnections of hoses and capping of spent filters and demineralizers will be the highest occupational dose activity associated with EPICOR-II opera-tion. These activities require direct handling by personnel in radiation streami'ng fields of 1 rem per hour. We estimate that a filter or demineralized can be disconnected and capped by a trained operator in an average time of about 30 seconds. Based on the number of times that these activities will be necessary, we esti-mate that operation of EPICOR-II will cause 1-5 man \\ Mn This estimate includes all activities involved in the operation of EPICOR-II, up to the time when the spent filter cask or spent resin cask is loaded on I the truck for shipment. This estimate is a very small percentage (less tha'n 1%) of the ' total annual occupational dose at an operat'ing nuclear power plant. The dose to individuals involved in the operation of EPICOR-II will be within the limits of 10 CFR Part 20 and maintained as low as is reasonably achievable. The dose to individuals will be of similar magnitude to th'at nonnally received by individual workers at an operating nuclear power plant. 5.0 Alternatives to the Use of EPICOR-II There are two basic alterna ives for handling the TMI Unit 2 [edg level radioactive waste. ne is continued storage of liouid in TMI Unit ? - auxiliary building tanks and e other is processing to clean the water for ultimate disposition. v r(quirements. The effects of the overall accident would be expanded to f equipment and plant systems (Unit 1) not now exposed to the accident pro-duced intermediate level waste. 2. gwEPICOR-IIRadwasteSystem h* The EpICOR-II radwaste system is specifically designed to process intermediate level waste and, therefore, it is capable of producing

k \\' b a ~ $h l discharge quality water by means of a proyen technology (i.e.. f on-15 i exchange methndM rg). The system N operational allowing a recovery sequence to proceed in an orderly and timely fashion. Although it' is a newly' constructed system, sufficient time is available to fully test it and demonstrate its operability, reliability, and operator pro-ficiency. M p3 A 3. New Radwaste Systems The most viable alternative to a filtration / demineralization process for i the cleanup of intermediate level waste is the process of evaporation. g/ / A evaporation process was rejected on the basis of the lona lead time 4 I required to make the system available (at least six months). In additio, i systems employing evaporators ar_e not as reliahla u filtration /demineral-h o T ization systems and, thus, would be less efficient in reducing the large E) ./ inventory of intennediate level waste. The required additional mainten-9 k I ance on an evaporator system would_ result in hicher o'ecupational exposures d than fe: a filtration / demineralization system. It is therefore concluded that the best alternative is to process intennediate level waste through a system specifically designed for that purpose, namely, the EPICOR-II processing system. 6.0 Summary Our evaluation supports the conclusion that 'the proposed EPICOR-II system is acceptable because: (1) The design of the EPICOR-II system meets or exceeds the guidance given in Regulatory Guides 1.143, 1.140, and 1.21;

[Wt x /. o, 25 - a \\/ J (2) The system is design to prevent spills of radioactive water; even in the unlikely event of a spill, our evaluation of the consequences of this event show that they are insignificant; (3) Th'e system design is such that releases of radiaoctive material in gase-aus effluents will be insignificant; (4) The design and operational considerations to minimize occupational ex-1 posure are consistent with the guidance given in Regulatory Guide 8.8; (5) The occupational exposure due to system operation corresponds to less than I percent of the normal annual average for an operating nuclear power plant; (6) The dose at the site boundary due to direct radiation from the system i operation will be a small percentage of the limits of 40 CFR 190. Based on our estimate of gaseous releases during operation of the EPICOR-II system, including the release due to an accidental spill, our estimate of occupational dose and our estimate of direct radiation off-site, we conclude that the operation of this system does not constitute a significant environ-4 qtntal impact. We further conclude that the health and safety of the public will not be endangered by operation of the system in the proposed manner and that such activities will be conducted in full compliance with the Commission's regulations. I A p 3 bs1, .~ n w. J r 7.0 Evaluation of Impacts M5 Mg d-e processing of contaminated waste by the EPICOR-II system will entan avno > sure tQorkers as described above and releasae " =l' "6un_ts' of Xe-133 and I-131 to the environment. Occupational exposures of less than 5 man-rem con-stitute about 1 percent of the anticipated man-rem ex.<ure for one year of n

p% p o' t.,, ' ue normal. facility operation. Offsite exposure is expected to be less than one mrem which is wil within applicable EC and EPA guidelines. l Since the major source of direct and airborne radiation in the auxiliary building will be removed by processing the intermediate level waste water j through EPICOR-II, the occupational exposure would be less than the arnosure c s incurred by laws; t;m ,m m te, i.; -+arace. Also, by processing the waste l water to allow for component maintenance and decontamination activities, the l = offsite releases in gaseous effluents can be reduced from current levels. Therefore, we conclude that the processing of the auxiliary building contami-nated water through EP'COR-II will not have an adverse impact and will probably lessen the impact of the already contaminated water. 8.0 Conclusion We have detennined, based on this assessment, that the proposed use of EPICOR-II for the processing of contaminated waste fran the TMI Unit 2 auxi-11ary building will not significantly affect the quality of the human environ-ment. Therefore, the Commission has detennined that an envirorrnental impact statement need not be prepared, and that, pursuant to 10 CFR 51.5(c), issuance of a negative declaration to this effect is appropriate. i ..____________.____________m_ .m__ w

g" e = J. ,i, 15,-' - TABLE 1 t,' l Radioactive water volumes for TMI Unit 2 which will'be processed by EPICOR-II. VOLUME (callons) Reactor Coolant Bleed Tank A 42,000 Reactor Coolant Bleed Tank B 75,000 Reactor Coolant i Bleed Tank C 75,000 l Neutralizer Tank:A 8,780 Neutralizer Tank 8 3,760 Miscellaneous Waste Holdup Tank; Auxiliary Building Sump and Sump Tank; Miscellaneous Sumps 26,300 l Waste Evaporator Condensate Tanks; Contaminated Drain Tanks 15,000 G 4 e w

l "* TABLE 2 n s y;( f.. - .e CONCENTRATIONS OF PRINCIPAL NUCLIDES IN THI UNIT 2 AUXILIARY BUILDING TANKS TO BE PROCESSED BY EPICOR II CORRECTED FOR RADI0 ACTIVE DECAY TO 6/15/79 (uCi/gm) Reactor Coolant Reactor Coolant Reactor Coolant Bleed Tank A Bleed Tank B Bleed Tank C I-131 1.9 2.8 3.0 Cs-134 6.5 7.6 7.7 'Cs-136 0.28 0.29 0.28 Cs-137 28 35 35 l Ba-140 0.09 0.3 0.29 H-3 0.23

NA

NA 1
Table 2 (cont'd) Miscellaneous Waste Holdup Tank Auxiliary Evaporate Neutralizer NQihralizer Bui1 ding Sump and Condensat Tank A Tank B Sump Tank; Miscellaneous Tanks; Cc Sumps Taminatec. Drain Tar: -131 0.15 0.18 1.0 10-l ps-134 0.56 0.72 2.4 10-- ks-136 0.01 0.02 0.08 10 - ss-137
2. 5 3.3 10.1 10-fa-140
.01 0.03 0.8 10-l \\ 4-3
NA

NA

NA

NA l
l e
NA - not analyzed l
l .. s.,. ',.e a y.. n j: '- TABLE 3 j ') t.., Radioactive Half-lives of Principal Nuclides. Radioactive Half-lives 1-131-8.08 days Cs-134 2.07 years Cs-136 12.9 days Cs-137 30 years Ba-1'40 12.8 days H-3 12.2 years i { V 4 8 9
nn w ~ G.. 1 ) () g - UNITED STATES 3 \\~ )xI NUCLEAR REGULATORY COMMISSION .,.ff,, a wAsmNGTON, D. C-2036 %~y.....,$ ERRATA SHEET i FOR. . ' '.-y':, " Final Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor Building Atmosphere" l NUREG-0662, Vol. 1 f .y. Please note and correct the following errors: P-ag e, 1-1. In the second paragraph, replace March 29, 1979 with March 28, 1979. 1-1.. Ic the second sentence of the fnorth paragraph, replace March 1979 + with March 1980. 1-3. In Section 2. Purgino, replace the second sentence with the following: "The smaller of the two systens was designed as a backup system to i the hydrogen recombiner system to reduce the hydrogen concentrations to prevent possible gas explosions." 6-11. In Section 6.2.5.3.3. Environmental Imoact, final sentence, replace viable with visible. 6-31. In Section 6.8. Onsite Lono-Term Storace of Krvoton-85, first paragraph, first sentence, delete the final four worcs "or off-site disposal." 6-32. In Table 6.8-1, under the Advantages column, first item, the expression " low peak"'should read " low leak". 9-2 Final paragraph on this page, delete the last scatence. 9-5 Replace first new paragraph on the page with the following: "Dr. Henry W. Kendall, UCS chairman, said the organization ultimately decided to recomend against implementation of the existing Met Ed/NRC venting plan, but he emphasized that this was primarily because of the stress problem." 12-2. 'ould be defined as Minimum Detectable Level. / )
c-(, i !,jMg-)n i NUCLEAR REGULATORY COMMISSION ,g 4 wAsmucTow. o. c. : ossa \\;* v / + ERRATA SHEET i FOR -u 4.. 4-- " Final Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor Building At:nosphere" NUREG-0662, Vol. 1 Pleasenoteandcorrectthfollowikg' errors: ~' Pace 1-1. In the second paragraph, replace' March 20, 1979 with March 28, 1979. 1-1.. In the _ second sentence of the-fourth paragraph, replace March 1979 with March 1980. 1-3. In Section 2. Purcing, replace the second sentence with the following: "The smaller of the two systems was designed as a backup system to the hydrogen recombiner system to reduce the hydrogen concentrations to prevent possible gas explosions." 6-11. In Section 6.2.5.3.3. Environmental Imcact, final sentence, replace viable with visible. 6-31. In Section 6.8. Onsite tono-Tenn Storace of Kryoton-85, first par:.grrph, first sentence, delete the final four words "or off-site dispos 31." 6-32. In Table 6.8-1, under the Advantages column, first item, the expression " low peak" should read " low leak". 9-2 Final paragraph on this page, delete the last sentence. 9-5 Replace first new paragraph on the page with the following: "Dr. Henry W. Kendall, UCS chairman, said the organization ultimately decided to recontcend against implementation of the existing Met Ed/NRC venting plan, but he emphasized that this was primarily because of the stress probl em. " 12-2. MDA should be defined as Minimum Detectable Level. e 9
O W IE"d s. w e =C 2 5 g3* ~ S 5_ g 5 S a N m su 5 b .ga s w m -Q aw 3 d 'w E au-E -5 ds i a 'r 2 W g= - 5 @= d w, a W-C. 5 m >- = = 3 b d h 5 is C ~ A S_, ww 5 Y"Q C r r a~
=
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E.1 E 2 w eg sawm e s_ S + w m -e g< h @55 e 2 -y 5 N e - m ,h b sece a
T --( j BASES FOR RECOWdENDAT!0N REACTOR SUILDING ATMOSPHERE NEEDS TO BE CLEANED UP SAFELY AND PROMPTLY PuaLIC HEALTH AND ENVIRONMENTAL IMPACTS OF L3.Y ALTERNATIVE EXAMINED ARE NEGLIGISLE IHE SLOW, CONTROLLED METHOD IS AVAILABLE NCW PSYCHOLOGICAL IMPACTS MAY INCREASE WITH FURTHER DELAYS IN INITIATING CLEANUP OF THE REACTOR SUILDING CONTROLLED ? URGING IS THE QUICKEST AND SAFEST FOR THE WCRXERS AT TMI 0 i i 8
o ( i 4 EST M AED G AM M A DOSE RA"ES 11\\ SI D E R EACTO R B U _D'.\\ G (Kr-85 Seta Dose To Bare Skin is 150 rad /hr) 85 3/4 From Kr g4 From Walls , & Sump 1.3 rem /hr Total Sody 3a7 Level _ ~, ',., / ersonnel P ', 3 From Kr85 / Airlock 2.3 R/ n.r< s From , Walls & Sump 305' Level _. \\ 120 R/hr 0.1 R/hr l' From Sur' ace Inside 290' Level _ L _-z i-Airlock r.,, Water
i-q,,1 y b COMMENTS RECEIVED 300 - OPPOSED CONTROLLED PURGE 133 - GENERALLY SUPPORTED CONTROLLED PURGE M - NO POSITION OR RECOMMENDED ALTERNATIVE 800 TOTAL (APPROXIMATELY) ALL SUBSTANTIVE COMMENTS TO BE PUBLISHED AS VOLLUME 2 TO NUREG-0662 AND MADE PUBLICALLY AVAILABLE
q .c g \\ l i i NRC STAFF CONCLUSI % _ LONTROLLED PURGING IS THE PRE.: ERRED ALTERNATIVE TO MI;i!MIzz LONG-TERM ? PSYCHOLOGICAL STRESS, i i 1 f I i
I (, ; i k NRCSTAFFCONCLUSION: CONTROLLED PuRetNG WILL HAVE NO PHYSICAL HEALTH EFFECTS' [NDEFENDENTLY ASSESSED BY A NUMBER OF GROUPS, REACHING SIMILAR l CONCLUSIONS NCRP . EPA HEW UCS .!RDC 1
s I b l M w r 2* ^ k N W n, U O y W M h W I LO I C j .M .J X D z s P'% Z C v d C }W'W O O cc cc .J ) < = n H H - C Z C M s J H H 1A = m M E @ Z E ~ w w w & E 2 M W I W E E J Z x Z J c I .~ N O W 'M Z f i 2 % C CC H. M w M M M 5 L M % C tC a. uJ f% LA B ~ C 3 W m = C u: .m m "3 H C . C I 'I I U M "3". Cl "E C J
2 H
? ~'T. M w W E ct) O O O .J cc C W up v .J<3 W Q^ W co C J c c. Q O Z Z w C = c. H W Z 4 J C ~ ~ t.LJ C D E .J v2 C ca l C "Q O C = Q -c. m E J .J W WN H Z J C D O <N ~ ~ Q H M E C: v M w E C W E m <C C = w E -a E N 4 e-A = C M O w
SL A 0 3 5 6 1 5 T 0 9 0 9 3 3 O 3 1 1 1 3 I Y T I L S A R T* O R M T O E MR M R N S S S S S I T E O SR S S R R R R S C S Ae SR SR SE SE S E E E N R n AE Ae Ai Ai A C l l l I i A E M1 l t T I T I T N I I I i i K CP E0 MT MT MO MO M o A S K EO Eo E E E C L6 UL K K KL KL KNL I R A0 EL UL UL UL UL UI L L 1 1A EL EL [A [A E (5A A I Y T (A LA [ [ (5 T T N R 00 ~ 1 8 6 A E E 55 0d 05 S7 30 8 0 F I L T P 11 f S5 21 2 1 A o 1 T P 0 l ol 00 if P 0 0 R. UO lK R G fA C E G C A I F T I A C l i E T PS FO E Y G Y D A L O N B F O O L D A Y E T t S O fA O T M PM M U P O E S 0 C R 0 R S N N 6 R S S O O A S R R I S E R A A T R E o Y A E E S A E G R E Y Y E L P A E 9 Y G U 9 0 0 A P 6 T U 0 2 7 O 7 0 1 L P N 1 0 L 0 0 1 1 2 A A I R O F
Li (; ' 1 \\ NEED FOR DECONTAMINATION 0F THE REACTOR BUILDING ATMOSP4ERE ) l PERMIT LESS RESTRICTED AND PROLONGED ACCESJ ' GATHER INFORMATION
MAINTAIN EQUIPMENT (E.G.s AIR CCOLERS, NEUTRON MONITORS)
OETAILED RADI ATION MAPPING LOCAL SHIELDING PLACEMENT 4 PRELIMINARY' DECONTAMINATION WORK ASSIST WATER PROCESSING WITH AREA WASH DOWNS PROCEED TOWARD TOTAL DECONTAMINATION OF FACILITY, INCLUDING DEFUELING O e _____._____.-._.______.____________m_
( ( \\ .) 4 1 i 1 .'l E E FOR 3ECCMTA.MINATICN (CON'T) - FRECLUDE FUTURES UNCONTROLLED LEAKAGE (NO KEALTH EFFECT, BUT CAUSES ANX ITY IN AREA) - ?RCMPT OECONTAMINATICN OF ATMCSPHERE SHOULD HELF REDUCE LONG-4 TERM ? PSYCHOLOGICAL STRESS 3Y MAXING A ?OSITIVi M.0VE TOWARD CLEANUP OF IM[-2 AND SMCRTENING CVERALL TIME FCR CLEANUF I l
l' 'i (. l i i i i l i 4 i IlEED FCR DECONTAM:NAT:CN (CCN'T) - ?RESENCE OF KR-83 LIMITS ENTRY TO CNLY 15-30.xtNuTES; CNLY
ELIMINARY RADIAT!:N SURVEYS POSSI3LE
- SEOUCES RISKS TO WCRKERS
XEDUCES TOTAL 50DY GAMMA CCSES 3Y / h, AT UFPER LEVEL, m
1 l 30% AT L:wsR LEVEL SECUCES R;5< CF :ALLING :R TEAR:NG 5U:7 WHICH CCULO i RESULT !N SETA EXPOSURE 1 I
1. (, .1 PROTECTIVE CLOTHING AND EQUIPMENT (APPROXIMATELY 85 PCUNOS) CLOTH HCCD CRANIA- .A. Ng} 2ANSCE!VE" ?,}e) i }; \\ PLASTIC HOOD l/ ' f i FECENER = ..s 3REATHING MASK s . _. I I ks EFEAThlNG CHEST TLD'S f [ LCNG UNCERWEAR Y PAPER FROTECBE l L) d \\. ( CLOT'ING noC ,/' I / \\ \\ -RUS8ER SUIT ' CWER EACK l' I 4 \\ { f ESLT.:ASTENEC (% PLAST!C JACXET T:. EMETE? FED DCSIMETERS pd,; 1 i i L. '\\ BACX-UP UGHT ' \\. eh"\\ ].I j/ l'- h Id i EACX-UP l d i SEL.:-PEACING hf' AIR SUFCLY l COSiMt:!:R j' / j k l CN FCFEAAM '1 CC TON I S. / / d f GLOVES 1 I W ALX:E TALX;E -:,.3 gggggg gLp. \\ li 1 GLOVES ie f / \\ f; vN 1 r TWO FINGER %} f/ ' \\. SURGECNS RING TLD'S \\. GLCVES j .I \\\\ \\ // p vSmC xN S \\ / \\\\ ScCxS ANKLE-- l / // h g ,3 EFACELE Ra'S f / ) ) l l L_ _ l
~ 't (/ I ., ~ ( 1 i ALTERflA-"/ES CONSIJEiED DO NOTHING
l i
i CONTROLLED FURGE $LCW - 150 FT. STACK f FAST - 160 FT. STACK ] ELEVATED RELEASES l 250 Fr. STACx, HEATED EFFLUENT
400 FT. STACX

1 1000 FT STACK

2000 FT. TETHERED 3ALLOON

SELECTIVE A3SCRPTION CRYOGENIC CHARCOAL ADSOR?T!cN GAS CCMPRESSICN COMBINATION ?ROCESS/? URGE

EVALUATED FOR FIRST TIME IN FINAL EA i
1
S N )A ? O C P R E S IT N ( E y ( A S a n c n o n Z i A e y i a s g n I NE v s ) A E a l i m O p L y A D m s n E n m o o G ( n R o i e y C t R C c g P e n r OG y e o t f r o o N o r n s i P E d DI h a t t f E l l NR l a u a o e g n t AO n a t e T wR e n t e i n m l SI m o o ra n p EN m e o r t o r a r I C O ml i c v p t o u n e e NM C N E D M E O e O e e GA l
s_. NRC STAFF RESPONSE TO C0tViENTS BY i THE ~1TY OF LANCASIER, PA Comment: 2.0 Only cesium-137 and iodine-131 are discussed. The concentrations Pg. 2 ano characteristics of every radionuclides present in the wastewater should be discussed. For instance, Tables 2 and 3 of the assess-ment list suveral other nuclides (cesium-134, ~ cesium-136, carium-140, and tritium), but these are not discussed. This is particularly disturoing since their half-lives are longer than that of iodine-131. What are the direct and cumulative impacts from the release of these and other radionuclides in the wastewater? ' Response: a.' Cesium-137 and iodine-131 were the isotopes of primary concern when related to a potential impact on the environment in the event of accidental releases. b. Table 2 repres'ents rample results as of June 15, 1979. It was not ~ necessary to discuss eacl, s a;+ ope for the fellowing reasons; (1) different isotopes of the same elemerd 7: ;t chemically the same when l related to decontamination, and (2) radioactive decay will eliminate other isotopes from the waste prior to processing. c. An evaluation of the cumulative impact for releases is outside the scope of this EA. In accordance with the Commission Order of May 25, 1979, dispositions of the processed water will be the subject of a separate environmental assessment. Comment: 2.1 Exactly how does the continued safe shutdown of TMI Unit 2 depend upon original and aaditional equipment in the auxiliary building? i Wnich original equipment must be operated? Which accitional equipment must be operateo? i l 4
3 ~
Response
a. Continueo safe shutdown of TM1 Unit 2 cepends on maintaining access to controls for pumps, and remotely operated vaives, located in the Unit 2 auxiliary building. There is also a need to maintain instru-mentation used to measure parameters such as pressure and temperature for systems located in the auxiliary, fuel handling, and reactor building. b.,'~0ri@inal equipment such as the plant's sampling system, the radwaste control panel, valves and pumps associateo with the letdown and decay heat removal systems, gages used to measure levels in various tank and sumps must all be used to access plant conditions. New systems such as the mini-decay heat removal, new sampling systems c. and pumps and valves used as tie'in to existing plant system must De used. Comment: 3.3 Wnat resin would be used? What are its physics and chemistry? How would its properties change with temperature and radiation?
Response
The prefilter demineralized resins will be a strong acid cation type resin, j a. the second demineralized will contain a strong acid cation and weak base resin, l I and the third and final resin bed will De a mixed bed cemineralizer consisting \\ of cition and onion resins. D. The resins have a maximum temperature limit of 140*F, influent temperatures will De at ambient temperatures. 0 c. The resins can withstant radiation levels to a maximum of 10 rads.
l 4 C omment: 4 Pg. 3 How can the NRC staff objectively review EPICOR-II when it admits it decided in favor of EPICOR-II prior to preparing the assessment?
Response
It mus;t be recognized that the licensee proposed the EPICOR-Il system within the first week following the accident to process contaminated eter in the J ~ auxiliary building as a result of the accident. During this period the NRC , onsite staff met fr.equently with the licensee to discuss the various alter-natives noted in the EA and to review and r' prove the design and construction cf this systeme it was not until May 25, 1979, that the Commissioner's o'rdered the st.aff to prepare an environmental assessment on the use of EPICOR-II. The staff decided in favor of EPICOR-II because it represented the best ] alternative and provided the maximum protection to the health and safety of the peblic and the operating personnel. j l Comment: 3. 3.1 What are the " predetermined limits" to which the wastewater would be Pg. 8 processed? How will processed water be segrecated from other water { in the TMI liquid waste management system, so that it can be disposed of separately?
Response
Predetermined limits as used here defines design bases values used to a. assure that pH, conductivity, and radioactive concentrations are l maintained within acceptable limits. These limits are defined in the system's operating procedures. 1 b. Processed water will be routed to specified tanks, and these tanks will be isolated from all other plant liquid systems to prevent an unauthorized release to the environment. lN ]
,N 4 s ( l C omment: Ps. 9 What predetermined radiation levels in the ventilation system exhaust would be allowed? What levels would cause a shutdown of the system? What types of. radioactivity would be monitored? The reference to the plant radiological effluent technical specifications confirms our concerns that the NRC staff intends to allow exhausts to the atmosphere l - in accordance with specifications set before the accident and'its traumatic effects.
Response
In accordance with current operating procedures the maximum release a. rate via the ventilation exhaust is 3 x 10 -10 uCi/cc. t. Area radiation ~ monitors located in the chemical cleaning building are used to indicate off normal conditions, these monitors :re used to allow corrective actions to be taken. The set point for these monitors ace contained in the system operating procedures. These procedures also define the actions to be.taken, such as When to shut the system down. .. System radiation monitors measure gross beta and gamma activity.
c. "New radiological effluent technical specification are based on Appendix I to 10 CFR Part 50 limit, i.e., to maintain releases as
_ low. as reasonably achievable. I i Comment: 3.4 At what preset values would automatic valves close to prevent a ? g.11 discharge to the river? Are these the same preset values used before the accident? If so, why? What are the potential i consequences of a break in the piping between the auxiliary building tanks and the pipe leading to the chemical cleaning building? What are the potential consequences of a break in the pipe leading to the chemical cleaning building? How would such I spills be cleaned up? I 1
I t ,\\ '
Response
( f a. In conformance with the Commission Order of May 25, 1979, routine release 1 of waste water from TM1-2 are prohibited. Present plant Technical Specifi-cations require automatic valve closure if the concentration of radioactivity in the aischarge stream exceeds the valves given in 10 CFR Part 20, Appenoix { i _B, Table II. These are the same preset valves used. before the accident ) and are consistent with staff requirement imposed on all operating nuclear power plants. b. The consequences of a break in the piping between the auxiliary building tank and the chemical cleaning builaing will extremely be minimal since this pipe is protected b'y a guard pipe. (A guara pipe is a welded pipe that surrounds the waste transfer pipe for the entire length from the auxiliary binding to the chemical cleaning building). The leakage will De directed to the chemical cleaning building, and the auxiliary building tank will De isolated. Leakage in the chemical cleaning cu11 ding is routed to the builoing sump. c. 1 Water collected in the building sump will be pumped to the off-spec tank and will be processed in EPICOR-Il system. Cocment: j Page 12 Why is only iodine ciscussed? Why not all of the other nuclides -present in the waste water as well? What will De the radioactivity content of the domineralizer media after wastewater is processed? If the media leaves the liner, how will it be retrieveo? What exposures woulo clean-up crews receive? Since the demineralized media would be relatively dry material, it will be easily disbursed by the elements. What will the exposures be if wino olows spilled aemineralizer media into the Susquehanna, or across the river to i Hiocletown or Lancaster? esponse:
a. ' From a dose standpoint iodine was the most restrictive isotope.
See response to 2.0 Page 2.
c. The radioactive content of the demineralizers will depend on the l ~ volume of water processed through a particular demineralized. During processing revins leaving the liners will be trapped in c. resin trays included as a part of the system design. Operator will { ~ i remove clogged resin traps as part of normal system operations. Operators changing our resin traps will follow normal radiation l 1 work permit (RWP). limits and operating procedures when changing out ] ) resin traps. In this manner operator exposures are limited to levels -{ within applicable radiatioil work limits and plant administrative limits. J l ~ There are no physical ways for resins to leave the system during system e. operations. f. Not applicable, see e above. .i i Comment: l 3.5 If the exhaust ventilation system maintaining the building at a i P g. 13 negative pressure f ails, nuclices in the building would leak ) directly to the atmosphere. In what amounts? Wnat is the pre- ] determined level at which radiation monitors will provice alarms? What actions would be taken and notices would be given to public officials? 1 Resconse: a. On loss of the building ventilation system, all operations in progress would be stopped. - By design the chemical cleaning ouilding is s'ealed so that radioactive material in the building will be contained in the ouilaing until the ventilation problems are corrected. D. The amount of leakage from the sealeo chemical cleaning building will be insigni.ficant, i.e., less than minimum cetectable limits (MDL). ^ ~ l l c. See response to question 5, page 9. ] i l j
L
1..
d. Since activity levels will be at MDL, failure of the building exhaust system will have no impact on the public, and there will be no need to notify public officials other than through normal notification procedures. l l Comment-l P g. 13 To which releases does the staff desire to apply 10 CFR 50, Appenaix I? To which releases does the staff desire to apply 10 CFR 207 What is the relationship between these cifferent standards? What more stringent standards will apply oecause of the accident and continuing problems at THI?
Response
a. Only gaseous. release are considerea in this EA thus the as low as is reasonable criteria of Appendix I to part 50 will be applied to 4 gaseous releases. b. Part 20 limits will not be applied ciregtly to any gaseous releases from _ the EPICOR-II system. c. Not applicable to EA. d. See response a above. ._ Cc:nenti j 3.6 Because of the accident the public has no faith in regulatory guides Pg. 14 developed before the accident. Mucn stricter stancards should apply to TMI Unit 2 af ter the accident.
Response
~ a. As low as is reasonably achievable criteria will be applied. Also see response to Comment Page 13 above. e
.e. s \\ l Comment: ( 4.0 What wil1 be the occupational exposures when filters and domineralizers Pg. 15 are transferred from the chemical cleaning ouilding to the truck outsioe? Wnat w-l11 be the exposures if tne filter or demineralized falls off the monorail, or cracks the concrete shell on the truck, or falls off the i I truck? How will spent filters and liners be transferred from the transfer bell to individual ~ cells? What will be the occupational expcsures if a spent filter or liner is cropped and cracks open? How will clean-up be cone?
Response
Based on all operations associated with the EPICOR-II system including ~ a. { handling and transfer of liners the staff has esti,aated a total occupation l dose of 1 to 5 man-rem. b. Accidents such as dropped demineralized from the monorail have been evaluated. Procedures covering such an accident are contained in the systems emergency procedures. During resin liner movement no operators will ~ De in the area therefore direct exposure to operators from this type of accident is not applicable. c. In the event of a crack in the concrete shield on the truck the maximum cose rate to an operators standing next to the crack would De less than 60 millirem per hour, Spent resin liners will be transferred from the shielded transfer bell to d, individual cells using extentions rods and a crane. e.- As reference in b above, emergency procedures have Deen developed to handle a droppea liner. T'hese procedures define actions to be taken based on a worst - case-crop accident to prevent over exposure to workers and to minimize the possiole impact to persons off site. Exposures to workers curing the clean up woulo cepeno on the extent of a possible resin spill. f.- To reouce exposure the clean up will De carried out using crane and long hanole tools after an evaluation of the conditions has been completed.
N. . \\ Comment: l f l . Pg. 17 Roping off the storage areas is certainly the least expensive alternative. For more satety for workers and the public, storage shoula De in reinforced builcings, not out in the open air behind ropes. Ropes do not stop wind, lightning, tornadoes and small planes. How will those ri;sks be protected against? How was the estimated maximum cose to an individual at the site bouncary on a continuous basis calculated? What is the present oose to an ~ indivicual at the site boundary on a continuous basis? How was the total integrated occupatiopn dose of 1-5 man-rem calculated?
Response
a.' The area will be fenceo in. b. Storage of spent resins will be in an engineered facility, not out 'in the open behind ropes. c. Not applicaole, see above response. 3 c. Not applicable, see above re'sponse. e. Reteren Section 4.0 Comment: 5.1 Once again, the NRC staff admits its significant participation Pg. 18 in the development of the interim and concrete storage facilities on site, and then seeks to promote them. The promotion of these facilities cannot be unbiased. Restonse: One of the primary responsibilities of the NRC staff is to cevelop design criteria for various systems used in nuclear power plants and to review lizensee's submittals for conformance with applicable regulations, criteria, anc staff guidance. In the case of systems installes at THI, the NRC staff performed its normal functions, of provioing design criteria and the review l anc approval of the various modifications necessary for the recovery program. Tb6 staff cia not promote these f acili^ ties but performea its normal regulatory f u ncti ons.
'W , l l j ) Comment: l z-5.2.1 What leakage and drippage might occur from cells stor.ed in the j Fg. lv interim storage facility? When will a well De drilled in the proximity of the interim storage facility for the monitoring of ground water? Clearly, no use of the storage facility should be made until several wells are drilled and backgro.:nc -activity j determinec. A grading of the area to cirect rainwater away from the cells will also direct leakage away from the cells. What if the sump overflows with leakage from the cells? What will be the occupational exposure of containing it? How often will the cells be checked for leakage? What will be the occupational exposure of doing so?
Response
a. Resin will be vacuumed de-watered prior to storage in the interim storage facility and due to the limited storage time allowed in this facility it is highly'unlikely that drippage or in leakage will. occur. o. A well nas already been orillec in close proximity of the interim storage-facility for the monitoring of groundwater. c. kot applicable', see b above. d. Grading was part of the design to cirect rain water away from the interim - f acility. e. There is no sump associatec with the interim facility. f. Not applicable, see e above. g. Not applicable, 'fa'cility ha's only a four month use approval'. h. Not applicaDie. I e
11 - r Comment: ,5.5.2 Why will concrete storage modules be b'uilt only on an as-needed Pg. 19 basis? Will they be needed or will they not be needed? Will the modules, described as rectangular concrete tubes, have plugs on their ends? If not, why not? How was this alternative chosen? 4 What are its acvantages and disadvantages? What other alternat,ives are possible?
Response
a. Concrete storage modules will be built only on an as needed basis to prevent the construction of unneeded facilities. b. The need is depended on the availability of shipping cask, the time required for transportation to a licensed burial facility, and the number of liners being generated. c. Yes. d. Not applicable, see c above. e. Not applicable, see e above. f. The advantages are good shielding characteristics and protection from environmental hazards. 1 g. Not applicable. 1 ) i Comment: Pg. 20 How often,will liquids in the washdown and drippage sump be sampled and analyzed? How will it be detennined which cells are leaking? How will they be repaired? What will determine whether the samp water will be discharged to the station drainage system? How many ) licensed shipping casks are available today? The licensees should I be required to have all the needed casks on site prior to operation of EPICOR-II. This would ' obviate the need for interim and concrete storage facilities. 1 l 3
12 - 4. e s 1 r O The sump wil'1 be sampled prior to any water transfers. a.
b. --Fedividual cell do not have leak detection capability.
If radioactivity water is detected in the sump an investigation would be initiated to locate.the leaking c, ell. c. The only possible sources of a leakage are faulty seals around the top plug or incomplete de-watering of a liner. Since liners must be vacuumed de-watered completely before storage (there must also be a rupture of the liner bottom) this would not represent a realistic source. ~ Water in-leakage from a faulty seal at the top plug would not be radioactive and would be collected in the facility sump. When the radioactive liner is removed for shipment the faulty seal would, be repaired. d. Tht sump will be discharged to the station drain system only after sampling results show no radioactivity in the sump water. 9 e. There are two shipping casks available, f. Not a realistic requirement. g. The lead time for building and licensing shipping casks are to j long. G e e 0 e e t d
Ccement:
{ 6.0 . Exactly what ocf ational expoi;ures ' result from ech of the Pg. 21 following action.t Making plant modifications? perating the gaseous radwaste system? Taking radiation surveys? Perfonning maintenance? Decontaminating the auxiliary building? What water leakage is occurring? What movements of water are required? Which components are leaking? What gaseous effluents are leaking to the environment? Why cannot the EPICOR-II tanks be used for surge capacity? What possible reasons could arise for the transfer of the highly contaminated water in the containment? Why would containment building water have to be transferred to the auxiliary i building? How much leakage is occurring to the containment building? j What compont.1ts in the lower elevations of the building are threatened? l What contingencies could arise which would require transfer of the
ontainment building water? What components r.ecessary for the continued safe shutdown might fail? Why might they fail?
j f
Response:
a. The occupational exposure that results from: (1) making plant modifi-cations; (2) taking radiation surveys; (3) performing maintenance; (4) decontamination functions; and (5) operating gaseous radwaste systems, depends on the number of people involved in the work, the location., and radiation field in the affected areas and is outside the scope of the EA. D. Water leakage is occurring in both contaminated and non-contaminated systems. c. The dominant sources of leakage in the auxiliary building are from the component cooling system, demineralized water system, reactor building evaporator cooling system and from the recirculation $ of tanks prior to sampl ing. Most of this leakage is non-contaminated water but it becomes contaminated while passing through floor drains and sumps which are provided to collect the leakage. Another source of water, although minor in volume' (approximately 10%) is from leakage in the reactor purification and makeup system which is also located in the auxiliary building and contains primary coolant water. This leakage is likewise to be expected and is from pumps and valves.
( In summary tni leakage of water from various sources which results in an increase in the amount of contaminated water is from normal leakage paths. d. The primary gaseous effluents leaving the plant are noble gases at 1ess'than 1 Ci per month. e. Notwithstanding the lack of adequate shielding of the tanks in the 'l chemical cleaning.builoing transferring unprocessed water to the EPICOR-Il i tanks to gain surge capacity is coing nothing but spreading the results of'the March 28,1979 eccident outside the Unit 2 auxiliary building. f. Transferring ' water 'from the containment builcing is outside the scope. of this EA. Comment: 6.0.1 The reference to "procucing water of sufficient quality for discharge" increases cur concerns that the NRC staff and licensees intend to discharge the processed water to the Susquehanna. The reference to " satisfying release requirements" heightens our concerns that the NRC staff and the licensees still maintain their business-as-usual attitude despite the accident and the public's fears and cistrust. Resoonse: The capability of producing water of sufficient quality for discharge for the system selectec to process intermediate-level wastes was one of the oesign criteria for the system since discharge into the Susquehanna River is one of the alternatives that will De consicered in a later environ-mental assessment. The requirement that the system be capable of producing discharge quality water coes not foreclose other options for the disposition of ne processec water in any way. w--- - - - _ _ _ _ _ - _ - _ _ - __ _ _ _
1 4 j / i 6.0.2 Again, tt; reference tok " producing discharge quality water" increases our concerns
Response
a. See response to 6.0.1 above. ' Comment: 6.0.1 The assessment's conclusions are unsupported hy any detai,1s Pg. 23 or data. The staff proposes to remove some of tne radioactivity from the wastewater in the auxiliary cuilding tanks, which are 'inside a heavjly reinforced builoing, and concentrate it in dry demineralized resins to be stored outside. There is no explan-ation given as to why this is a.less likely source of public or occupational exposure. The staff's next statement, that the earlier water processing occurs, the less the total likely exposure, occupational and public, is also totally unsupported py calcu)ations or data. What exposures to the public are now occurring becaQse of the storage of the radioactivity in the auxiliary building? How can this be more than the potential exposure wnen the radioactivity is stored outsioe?
Response
See response to 6.0, page 21, page 17. a. Ccenent: 6.0.3 The reference to a long lead time required for an evaporation Pg. 22 process directly conflicts with sworn testimony by Robert C. Arnold, the utilities' man in charge of TMI, that an evaporation system was ordered in May for possible future use. Since the assessment states that special design provisions could reduce the occupational exposures from the use of an evaporation system to those of the use of EPICOR-II, there is no safety related reason to reject the evaporator alternative. Clearly, the staff is recommending EPICOR-11 because the staff nelpea create it, and tecause use of EPICOR-Il woulo De quick and inexpensive, since it is already installed.
Response
The evaporator reference is not related to EPICOR-II system. The a. evaporator is being proposed for a cleanup of the higher level water in the reactor building and the primary system. c. Not applicable. cm ura maWSDlh
e Cocnent: 7.0 What releases of xenon-133 and iodine-131 will be made to the Tg7 23 environment if EPICOR-II is used? What other nuclides will be released to the environment? It is not reassuring that "off site exposure is esected t6 be... well within applicable NRC and EPA guidelines. The pre-accident guidelines should not be applicable to TMI after the accident. Certainly, the operator and equipment malfunctions during and after the accident were not expected. The public has no confidence in NRC staff " expectations." We have no reason to have confidence in the NRC staff's estimates of radiation releases. 'The NRC stated in mid-July that the xenon-133 release during the accident was more than 20 times that previously estirnated as the maximum credible release from such an accident.
Response
a. Due to radioactive decay release of Xe-133 and I-131 will be insignificant vi,a the gaseous pathway. As of October 1,.1979, the I-131 and Xe-133 activity levels are approximately 1x10 and 1x10 -6, respectively, of their activity level s of June 15,19[9. Relea'selvi' the liquid pathway are not applicable.' a b. Not a'pplicable for liquid. For the gaseous pathway less than Appendix I limits. ~ Not applicable. c. d. Appendix I to Part 50 will apply for airborne releases. f 0 m e e auma I { I l l ________.____.________.____.,_n__._______
17 .~ s 1 Comment: 1 7.0 What off-site releases in gaseous effluents are currently Pg. 24 occurring? How do these releases differ from the total possible releases which might result from the use of EPICOR-II? ' Responsei a. Weble gases at less than 1 Ci per month.. j b., There are no significant dissolved noble gases in the waste water, therefore, on a worst case bases f aseous releases from EPICOR-II will be only a fraction of current plant releases. Cot:. ent: The assessment's conclusion that the use of EPICOR-II would not significantly affect the quality of the human environment is shocking anc unjustified. How can a major step in an unprecedented attempt to decontaminate the site of the worst commercial nuclear reactor accident in history, which caused an evacuation and wide-spread fear and trauma, not significantly affect the quality of the human environment? Resconse: a. See staff evaluation and all responses provided. i O e e W"A-----_-----__w_-
& e;u w v msey e - s uw womsmoe, mu a THE COMMONWEALTH OF PENNSYLVANIA
i V
9 ,C oment: g Section 3.3 indicates that the decontaminated water will be transferred to Unit 1 for ultimate disposition. Without a clearly defined schedule or method of ultimate disposition, the transfer to Unit 1 could interfere with the schedule and the requirements for the restart of Unit 1. Consideration should be given to the storage of this decontaminated water in other than Unit 1 tanks. ] } Resporise: As stated in Section 1.0 of the EA, the proposed action does not include the disposition of processed water from the EPICOR-II system. Disposition i of processed water will be covered in a later assessment in accordance with the Commission's Order of May 25, 1979. / I 'C omment: Section 3.3.1 (page 8) states that the intermediate level water will be processed until the levels are below predetermined limits. 4 These limits for the various radionuclides should be included in ~ this document or an indication should be given of the expected decontamination factors for the various radionuclides along with their final expected concentrations.
Response
I The fin.a1 expected concentrations of radionuclides along with the expected decontaminate n factors will be a part of the assessment on the disposition of processed water from the EPICOR-II system to be issued at a later date. The requirement that the system be capable of producing discharge quality 5 water does not foreclose othe-options for the disposition of the processed [ water in any way. Comment: Section 3.3.1 (page 9) states that the ventilation system exhaust will be monitored and alarm at a predetermined level. The type of monitor and alarm setpoint should be specified. The significance of this alarm setpoint should also be discussed along with any protective. actions that may be required. /
. ~. - n a .w -=.x 2-3 4
Response
The monitor is a beta-gamma scintillator with an alarm setpoint at 20% of the limits of 10 CFR Part 20, Appendix B, Table II,. for gasecus effluents to an unrestricted area. C omment: i Section 3.5 (page 13) states that the noble gas releases as a result of the operation of EPICOR-II will be less than 1 Ci of Xe-133. This evaluation.should also address the possible release of Kr-85, even if it is insignificant.
Response
Kr-85 has not been detected in the auxiliary building tank water samples. From-this it can be assumed that the~ concentration of dissolved noble gases including Kr-85 is well below the detection limit of the analysis -5 ( 10 uCi/ml). Comment: y Section 5.1 states that the solid waste which is generated will be hendled, stored and disposed of as dewatered resin. It would appear, as if dewatered resin would be less stable for certain types of accidents and after disposal than if these resins were solidified in some stable media. A discussion and a benefit-impact evaluation should be added to provide assurance that tha handling and disposal as dewatered resins is the most appropriate alternative.
Response
The need for. solidificat. ion of resins from TMI is currently under discussion by the NRC staff and the Commissioners. In the interim all resins generated i~ rom the use of EPICOR-II will be vacuum dewatered utilizing careful control to-[ssure that all free water is removed from the contaminated resins prior to shipment. In addition all resin liners will be shipped in type "B" casks to minimize the impact from accidents during transportation to a licensed burial ground. _ _ _ _ ___i__ _ _ _ _ _
W. I (i L P Comment: The EPICOR-II system should be pressure tested with fresh water at least 2 times the nomal operating pressure of the system. This will help detect any bad connections and allow their corrections before contaminated water is put through the system.
Response
The ~EPICOR-II system has been hydrostatically tested in accordance with appl'icable ASME and ANSI codes as specified in Regulatory Guide 1.143. Comment: . -All floor drains within the building housing EPICOR-II should be dye-tested to insure that they drain to the appropriate sumps arid not to the storm water system.
Response
The chemical cleaning building does not interface with the storm water system. f 4 3 4 9 a-
,Q r O RESPONSES TO COMMENTS BY NRC S1 FRAdsEIN AND MARSHALL COLLEGE Comment: The assessment estimates dangers and exposure levels to the public based only on the use of EPICOR-II to clean a small fraction of the, radioactive water at TMI. Since the biological effects of radiation are cumulative, the public health will be affected by all radiation emissions resulting from the complete cleanup of THI. In order to evaluate the advisability of using EPICOR-II, data on resultant l exposure levels from other cleanup activities are first needed. In addition, EPICOR-II and its alternatives should be compared in the context of total exposure resulting from complete cleanup of TMI. Until assessments covering each phase of the cleanup (up to and including removal of TMI's fuel rods) are completed and published, l it will not be possible to evaluate the impact of EPCIOR-II's use i will have on the public.
Response
' As stated in.Section 1.0 of the EA, the proposed action is directed to the i I use of the EPICOR-II system and the scope and context of the EA is in v ~ i accordance with the Commission's Order of May 25, 1979. Coinment: While the assessment does provide estimates of off-site exposure l levels resulting from the use of EPICOR-II, no data or explanations are provided on how these estimates were made. The assessment deep provide an explanation of how on-site exposure levels were calculated, but detailed inspection of these estimates reveals serious ambiguities (see Section 3 of this report).
Response
The occupational radiation exposure levels were estimated based on expected dose rates at sources and workers expected occupancy time. The off-site d exposure levels were estimated based on expected dose rates at sources and a conservative distance from the sources to the public. j
3 Commenti i m The assessment leaves unanswered a numbar of critical questions about the use of EPICOR-II and the ultimate disposition of the 2500 cubic i feet of EPICOR Tt generated radioactive waste. It is not clear whether EPICOR-II will be used to process water other than that in the auxiliary building. The construction of more oresite waste storage l modules than required for the liners suggests that additional treat-ment of contaminated water,.beyond the 280,000 gallons of intermediate-le. vel radioactive waste water described in the assessment, is being considered by Met-Ed or by the NRC. If additional treatment is i projected, the added radiation to which the public>and plant workers will be subjected should be clearly described. Although the exposure 1evels expected during the operation of EPICOR-II. are discussed, the ~ as.sessment does not consider whether the EPICOR-II system's compcnents will become radfoactivt at t result of its proposed use. Plans for dismantling and disposing of the contaminated system are not included in the assessment. 1
Response
As stated in Section 1.0 of the EA, the proposed action is directed to the use of the EPICOR,II system and the ultimate disposition of the 2500 cubic feet.of EPICOR-II generated radioactive solid waste. Dismantling and disposing of the contaminated system, and the use of EPICOR-Il for other th'an the auxiliar,y building water are not within the scope of this EA. Comment: I Description of the interim storage facility (5.2.1), which will house the radioactive waste, does not include estimates of seismic integrity, details of the structural strength of the corrugated metal walls, j calculations of the effects of freezing and thawing, and.an estimate o.f the possibility of flooding by. groundwater infiltration. Most j - significantly, the assessmert does not provide an estimate of the time span over which the integrity of the interim storage facility is { assumed. The assr.ssment states that a well will be drilled near the interin storage facility "to assure that no activity migrates 'from the liners to the groundwater" (page 19). If rad $oactive contamination is detected in this well, we doubt that the well could assure that migration of radioactive material had not or would not occur. In fact, the presence of a well might even accelerate such migration. 1
9 Resoonse: ( / ^ The interfra storage facility is not designed to meet any seismic require-ments since the facility is contructed for temporary on-site storage until the ::oncrete storage facility is completed (estimated completion is December 1,1979). The corrugate.d metal walls are imbedded with surrounding concret'e and t'he structural strength of the metal walls are needed on1.y during curing stage of concrete. The facility will be freeze-th.aw protected on an as-needed basis. The concrete base of the facility will prevent any groundwa'ter infiltration. The staff does not expect any contamination of the groundwater because of the dewatert4 nature of the liriers-and the multiple barriers of protection provided oy the facility, including the l'iner itself, the drip pan, and the corrugated steel cell. 1 Comment: Description of the concrete storage facility, which will provide longer term storage of the same wastes, suffers from the same deficiencies as does the interim storage facility (except for freeze-thaw" considerations). The assessment provides no estimate of how long radioactive wcstes will be stored at TMI. Respense: The concrete storage facility is not designed to meet sny seismic requirements but the facility sump which may contain radioactive water l I is designed to the seisraic criteria of Regulatory Guide 1.143. The leak integrity of the liner and the cell will prevent migration of radio-activity from the liners to the groundwater. In addition, the cell plates i are provided with a ~ drain line leadirig to 6 sump to collect any liner drippage. The liners will be shipped off-site from the facility as transfer casks become available. l l
{ - e C or=ent: ~ The concrete storage facility is described (5.2.2) as consisting of' modulss of 60 storage cells each capable of housing one large or two small' resin storage liners. EPICOR-II is anticipated to i generate 50 liners. To satisfy storage requirements for EPICOR-II waste only one module is needed. Section 5,2.2 indicates space is available to building.6 modules for storage of radioactive wastes. Before the assessment is, accepted, it should be clearly stated what will be stored in these other modules and the resultant exposure levels to plant personnel and the public should be determined. R6soonse: 1 The additional storage modules will be built on an as-needed basis and i the facility is not limited for EPICOR-II use only. The resultant J exposure levels to plant personnel and the pubife from the fac'ility j will be reassessed if and when the additional storage modules are buil,t. Coamenti i section 5.2.2 discusses final disposal of the radioactive wastes and indicates th'at off-site shipment will occur as " licensed shipping casks become available." Since on-site storage will result in release of radiation (5.2.2) the assessment should first determine if licensed shipping casks are available, as well as when and at what rate transport to a licensed burial ground is to take place. Tne assessment does --not consider the alternative of demineralizing the radioactive water at a rate commensurate with the availability of licensed casks, thus eliminating unnecessary on-site storage and associated radioactive rel eases. Responsei f i The licensee will procure.two licensed shipping casks which should provide sufficient lead time for water processing, the liner on-site storage, and transportation to a licensed burial ground. G 1 b
x - 5, - L_ ^ l Com5ent(, The assessment's occupational dose estimate of 1 to 5 man-rems as a result of-using EPICOR-II cannot be verified using the data presented in the assessment. Workers will have to change EPICOR-II's prefilter/ demineralized and to domineralizers (one cation bed and one mixed bed demineralized) in radiation fields of 100 millirem /hr, 40 millirem /hr, J and 20 rem /hr, respectively (section 4.0). Each change is estimated to take 30 seconds. Ambiguities in the assessment leave unclear how many changes personnel will have to perfonn. Section 4.0 ' states '.'We estimate that there will be approximately 50 changes of prefilter/ 1 demineralizers and demineralizers." Left unanswered is whether there will be 50' changes of each of 3 units or a total of 50 changes for all 3 units. In the case of the former, the resultant occupational 3 exposure would be 8.39 man-rems, well above the 1-5 man-rems estimate i for EPICOR-II use. In the latter case it is impossible to calculate the exposure level since the number of changer of each type filter is not specified in the assessment. Since the exposure incurred j during. the change of each type of filter will vary considerably, the total _ exposure cannot be calculated with the limited information given. These ambiguities prevent verification of the estimated worker exposure levels cited in the report. 5 p ._.esponse: The 50 changes include approximately 32 prefilter/deminertlizers (26 millirem), S cation beds (3 millirem), and 6 mixed-bed demineralizers (1 rem). C omment: Several scenarios of possible accidents that could occur while EPICOR-II is in use are described in section 3.4 and 5.2.1. They include pipeling rupture. causing radioactive water to leak into the building housing EPICOR-II and dropping radioactive resin casks while moving them around the plant site. For each schnario exposure levels are estim4ted only for people outside the plant. No estimates of exposure levels are provided for on-site worker s. Estimates of the time needed to clean up spilled radioactive ne:erial, contingency plans for cleanups and evacuation plans for workers in the immediate area are' lacking. e -____w------_.--
P. Corxnent: ~ The assessment deals with three alternatives for processing radio-active water on-site (section 6.0): using existing radwaste systems at the plant,.EPICOR-II, and removal by evaporation and condensation. The assessment only provides estimates of resulting exposure levels to.the public and plant workers for the use of EPICOR-II. The first and third alternatives are dismissed for reasons of expediency without considering if these alternatives would result in lower exposure l evel s. Resoonse: The resulting exposure levels to operating personnel for the first and --thtrealternatives will be much greater then the second. alternative, the use of the EPICOR-II system. The first alterriative of utilizing the existing radwaste systems will result in expanding the overall accident to equipment and plant systems (Unit 1) not now exposed to the accident which produced intermediate-level waste. The third alternative of using an evaporation process will require additional maintenance due to evaporator outages (based on operating experience at other plants) which will result in higher occupational exposures than for a filtration / decir,eralizer system. \\ e P e l
'.; s g ..,4 N B-t, i 1 f Cen ent: Section 2.0 of. the assessment states 7the NRC staff has provided design guidance and criteria for the EPICOR-II processing system, the building housing the system, the. building's exhaust filtration syste:a and the process vessel vent system." This participation by NRC staff in the design stage of the system exceeds and I compromises the regulatory authority of the NRC since the same staff was called upon later to prepare'an environmental assessmant. Resbonse: The NRC staff.has bacn approving design guidance and criteria for design and, J i construction of nuclear power plants by means of Title 10 of the Code of Feaeral Regulations and various Regulatory Guides. Providing the design i i guidance and criteria for the EPICOR-II system is no exception to this and in no way compromises the regulatory authority of the NRC. f .1 J i .e j
~ NRC STAFF RESPONSE TO COMMENTS BY U. S. DEPARTMENT OF HEALTH,. EDUCATION, AND WELFARE j e 4 Comment: Our general evaluation of the NUREG-0591 is that it fails to f d provide any justification for the specific use of EPICOR-II versus other alternatives. No relative data on radiation doses, and environmental impact are provided for EPICOR-II vs. the other alternatives. j ' Response: Alternatives to the use of EPICOR-II and the reasons for the selection of ibn-exchange technology as the best alternative atte presented in Section 6.0 of this EA. Comment: Potential >indivic'ual and population dose estimates are cited, as are occupational dose estimates. However, no information is given as to how these dose estimates were obtained. There are no descriptions of the environmental pathways and* dosimetric models employedd, the adequacy of methods employed for the assessment { Hence, although the problem of pottntial doses is addresse 4 cannot be evaluated. q R_ssoonse: i The occupational exposures are estimated based on radiation levels at sources and expected occupancy time of operating personnel. The maximum dose to an individual at the site boundary is estimated based on radiation levels at sources and a conservative distance f*6m the sources to the site boundary. Comnent: Inasmuch as NUREG-0591 covers neither the disposal of the processed '1 water which will contain tritium nor the environmental impact of the disposal of the contaminated resins and filter beds, it is not evident that there was any need for this assessment. V
' i 2 g
Response
The-scope and content of this EA is in accordance with the Commissioner's ] Order of May 25, 1979. Disposition of processed water from EPICOR-II and j the capability of producing water of sufficient quality for disposition will be, considered in a later environmental assessment. The environmental j impact of disposal and burial of solid waste generated from the operation ) of'EPICOR-II is discussed in Section 5.0 (Management of Solid Waste) of this EA. i Comment: There is no indication of the availability of a back-up filtration system in the event of failure of radioactivity penetration. Resoonse: There 1:: no need for a back-up filtration system since the EPICOR-II system will not be in operation if the filtration system fails. Comment: No infomaticn is provided on the control actions that are or can be taken to limit plant effluent's to within technical specifications. Thus, the assertions of this report must be taken on faith alone.
Response
The control actions are described in the system operating procedures. An alarm point on the radiation monitor is predetermined at a level 207. of the limits of 10 CFR Part 20, Appendix B, Table II, for gaseous effluents to an unrestricted area so that releases of radioactivity will be carefully controlled within the predetermined limit set forth in the plant radiological effluent Technical Specifications. {
J ^
r*
r Cocment: This section on alternatives is totally inadequate in its ommission { and failure to discuss the disposal of liquid wastes through the use of solidification processes. Such solidification processes have been used for many years and it is almost inconceivable that anyone would consider the shipment and disposal of liquids as a visable alternative. Responset The disposal of liquid wastes through the use of solidification will result in unacceptable occupational exposures to operating personnel .I and an increas'e of pbpulation dose exposures. On the basis of tne long j lead time required to make solidification system available at the site and the long operational process time required for solidification, this was not conside',ed to be an available alternative. r C omment: It would be helpful in evaluating the need for this processing if quantitative data were provided on the rate of risk of the water level in the containment with regard in vital components. ~ ~ Response: The current leak rate in the containment results in an increase in volume of about 430 gallons per day and a level increase of about 2 inches per month. Since tne EPICOR-II system was designed and constructed for the purpose of treating water in the auxiliary Duilding the rate of source of water in the contair. ment is not applicable to 'he findings setforth in the EA. The processing of contaminated water in the containment building will be the subject l of a separate EA in accordance with the Commission Order of "ay 25, 1979. l 1
3 -4 o ,. ; y ( Coment: i-l In the absence of quantitative data, it is not possible to determine that the release of gaseous effluents will be insignificant. For instance, what happens to the tritium during this processing? Does it all remain in the liquid phase? I
Response
The staff estimates the release of Xe-133 will be less than 3x10 ~9 Ci (asofOctober 15, 1979). The discussion of the concentrations of radionuclides that would be left in water processed by the EPICOR-II , system will be a subject of a separate assessment for the disposition of the processed water. Comment: It.is not clear whether the gaseous waste from the vent header through the HCH filter units has a separate discharge from that _ of the. HCHF filter unit. R_esponse: The vent header is vented into the building through the HCH filter units _and,th,e building ventilation is discharged into the atmosphere through the H' HF filter units. ~ C omment: The concentrations of principal radionuclides should be corrected for radioactive decay.as of the date processing is to'be initiated. The date of June 15, 1979, is meaningless. Further, it would be infomative. if the total activity of each radionuclides to be processed were given. 1 1 1 I d m
i
.1 '
b Federzl Register / Vol. 44. N3.182 / Monday. August 20, 1979 / Notices 480?.9 l 7 e y 4 ?. one's assertions f Pellation Control Section, Land andN is neccesary.er illpbte to se--d Cer*ificatles 3 NaturaLResources Division of the I herebY certify that the National ( of Department of Justica. The Hearings Earthquake Prediction Evaluation
!4 Councilis in the public interest in I"*""""'**
l Persons wishing to testify at the connection with the performance of A8'i**t A ti mey Cenend.Landend hearings shouldnotifyns of theirintent responsibilities assigned to the-by September 7.nore planning to Ceological Surveyin the National M D* "' *d *** * * *"I LI submit a statement for the recordhave eres coot ma ~ Earthquale Hazards Reduction Program. until October 1to do so.Testbnony or transtnitted to the Congress on June 22, sfatements ofintent to testify shou.ld be 1978, by the President under Sec. 5(f)(1) NATIONAL FOUNDAT[ON ON THE addressed tm Nonfuel Minerals Policy of the Earthquake Hazards Redaction j Review,OfBee of the Assistant Act of 1977, and in furthering the ARTS AND THE HUMANITIES l Secretary for Energy and Minerals. objectives of Sec. 202 of the Disaster { Room 0649 Department of the Interior, p,g;,g ge, og 1974, Human!iles Panet; Meeting Date Washington, D.C. 20240. Coples of the Dated: Aegust9.197s. Changed l . report on issues may be obtained'by Cecli D Andrus,w August 13.19ts. l l 'e writing to this same address. ( This is to announce a change ir. the I Secretary of the Interior. date of the Humanities Panel announced Witnesses wiU be asked tolimit their-r -a a43 remarks to no more than.10 mmutes' h erwJocoos .me in the Federal Reg!. ster on August 2, although no limits are set on the lengt 1979,vol. 44, page 4503, item No.10. of written statements. Testimony willbe The meeting to review applicat!ons in j heard by representatives of the Policy ax Coordinating Committee, who may wish DEPARTMENT OF JUSTICE - History will be held on September 27 ) to questio,n witnesses idlowing th ~ and September 28,1979 instead of j presentation of their staMments. - Off cc of the Attorney General $eptember 20 and 21.1979. Stephen pfcCleary, 6 The hearings wiU be opeat to the 0nited States v. The Dunker Hill coa Advisory committee nncgement O! ricer. l public and the press, and the Consent DecreeIn Accon_.To Enforce p omm.u mm,_3,e w proceedings will be recorded. Compilance With Provisions of the en,wa coog 733%, { Further Information Clean Air Act l . For additional information, atl! or !$ accordance with Departmental f write to Bernice Steinhardt or Lorraine policy,23 CFR 50.7. 38 FR 19029 cotice NOCLEAR REGULATORY i DuBose. Office of the Assistant is hereby given that a proposed consent COMMISSION Secretary for Energy and Minerals, decree in UnitedStates ofAmerica v. Department of the Interior, Room 6649, The BunierHillCompany has'been Aval! ability cf Environmental, Wa shington, D.C. 20240, 202/343-4357. lodged with the United Etates District Assessmer.t for Decontamination of Court for the District of fdabo.The Intermediate Level Radioactive Waste U 'I "' v decree imposes on defendant The Water at Three Mlle Island Unit No. 2 l J an Da venpat' - Bucker HiU Company certain Pursuant to the National Assis tant Secn tory--thergy andMTnem/s. requirements and compliance dates with Environmental Policy Act and the U.S. j Department of theinterior, respect to the operation of its zinc Nuclear Regula tory Commission's a tm w2s mu-m% fuming plant at Kedogg. Idaho.. regulations in lo CFR Part 51. notia is 8"' "3 "" ns The Department of Justice will receive hereby given that en Environmental ' s ' for a period of thirty (30) days from the Assessment end Negative Declaration ' { flational Earthquake Prediction date of this notice, written commen'ts prepared by the Commission's Ofnce of "k I r 6' Evaluatien Council; Establishment relating to ne p wased consent decree. Nuclear Reactor Regulation related to Comments should oc addressed to the lhe decontamination of intermediate I r i This noticeis published in accordance Assistant AttorneyCencralof the Land level radioactive waste water at the j h with Sec.Ha)t2) of the Federal Advisory and Natural Resco~ces Division. Three Mile Island Unit No. 2 nuclear Corrmittee Act (Pub. L U2-403). Department of Justice, Washington, D.C.~ power plant is available for comment. Following consultation with the General 20530 and should rcier to UnitedStates ? ferropolitan Edison Company, the i Services Administration, notice is o/Amedca v. The Bunker H // licensee for Three Mile Island Unit'No. } j hereby given that the Secretary of the Company,11J. Ref. 9"M-2-5-14..
2. proposes to use an EPICOR-Il bn j
interior is establishing the National ' The consent decr2e may be examined exchange decontarnination system a e Fqthquake Prediction Evaluation at the office of the United States ~ decontaminate the intermediate level Council to advise the Director of the Attorney District of Idaho, Federal radioactive waste water which has been l United States Geological Survey in Building Room 83,550 West Fort held in tanks at Three Mile Island since l deciding whether to issue a predictica or Street. Boise, Idaho 03724: at the Region the accident at that facility or March 22 other information pertinent to the. X Office of the Envitor"nental Protection 1979 The Assessment considers the I potential for the M.currence of a future Agency,1200 Sixth Avenue, Seattle, envirocmer.tal impacts resulting from
e significant earthgoake.
War,hington 98W1: and the Pollution use of EPICOR-Ilincluding risks from Further inferrnation regarding the Control Section. Land and Natural possible accidents, and it also considers Coundl may be obhined from Dr. Resources Dhision of the Department on alternatives to use of EPICOR. The it Robert L Wesson. Chief. Office of Justice. Room 2025, Ninth Streei and Assessment and the accompanying Emhquake Studies. Reston. Vir7, inia Pennsylvania Avenue N.W., Negative Declaration conclude that the 22092$03) 860-6172. Washington, D.C. 20530. A copy of the environm(nulimpacts of use of s The certifica tion of establishment is proposed consent decree may be EPICOR-II wiE not significantly affect I a published below. obtained in person or by mail from the the environment, and therefore that t) p l l
~, ] c. '48830 Federal Register / Vol. 44. No.162 / Monday. August 20, 1979 / Notices l ~ ' ~
l~
k preparetf.cn of en FnvironmenlalImpact. For the Atomic Ssfety and tJcensing Docrd. Amendment l s ) Staiement is not required. ( Andrew C. Goodbope {
19. Amendment No. 03 to UcenseNo
/ DPR-25, Amendment No. 53 to Ucense ne Assessment does not consider CAoirmart No. DPR-29. and Amendment No. 50 to j ultimate dispesalof the decontaminated gra on.n-um na s.st-n su== Ucense No. DPR-30. and (3) the I~ waste water because use of EPICOR-U owwo cooc rsm:., Commission's related Safety Evalualm, I will not foreclose ariy options for such Allof these items are available for N ultimate disposal and because disposal ?* will be the subject of a subsequent. f Docket Nos. 50-237,50-249. 50-254 and public inspection at the Commission's 4 Public Document Room.1717 H Street, j 5' " Assessroent.Furthermore the : -.. 50-2s51 NW., Washington. D.C., and at the d Assessment dces not consider the
Commonwealth Edison Co.'and town-Morris Public Ubrary,604 Uberty Strei
{ decontamination or disposal of the high-Imnols Gas & Electric Co.;1ssuance of Morris. Ullnois, for Dresden 2 and 3. er Amendments to Fact!!ty Opersting at the Moline Public Ubrary. 50t.17th j ee 11 slan.Dec ntam at n'and Street. Moline. Dlinols, for Quad Citics j t.! censes disposal of that waste water will be The U.S. Nuclear Regulatory and 2. A copy ofitems (2) and (3) may Commission (the Cornmission) has be obtained upon request addressed tc consideredin future Assessments. ' The Assessment is available for. Issued Amendments Nos. 44 and 39 to the U.S. Nuclear Regulatory public inspection at the Commission's Facility Operathig Ucenses Nos. DPR-13 Commission. Washington. D.C. 20555 b Public Document Room.1717 ff Street.- and DPR-25. Issued to Commonwealth - Attention: Director. Division of N.W., Washington D.C. 20555 and at the Edison Company, which revised the Operating, Reactors. TMI-21.ocal Pub!!c Document Room in Technical Specifications for operation d Dated at Bethesda, Maryland, this 13th d l ~ the Covernment Publications Section' the Dresden Nuclear Power Station. of August 1979. Units Nos. 2 and 3. located in Grundy For the Nuclear Regulatory Commissloo. uca Bui in8 o onwealth and. County. Illinois. The Comm,lssion has nom'as A. !ppol to, i
c3f,
( i fo*p"efffthe s's e nNave een also issued Amendments Nos. 53 and 50 Diri,f, op,,eting Reactors smoch No. 3. I g t 8 ' Nos. jon ofoperating geoctor,. I-circulated for comment to other federal DPR 0 sue I to in om fS45m Na 6Wuu a=l agencies to the Commonwealth of Pennsylvania and to local and municipal h,"*$" inns e bmp as d El governments in the Three Mile Island which revised the Technical / area. Any comments or suggestions on Specifications for operatlou of the Qua3 ! Docket No. 70-13081 .the Assessment should be filed within Cities Nuclear Power Station. Units Nos. 30 days from publicAlon of this Notice 1 and 2. located in Rock Island County. General Electric Co. (GE Morris by addressing a copy to the Secretary of 111 nois.*fhe amendments become Operation Spent Fuel Storage Facifit-the Commission.U.S. Nuclear effective as of the date ofissuanca. Hearing on Application for Renewai4 Regulatory Ccmmission. Washington. The amenchnents modify the Materlats Ucense flo. SNM-1265 D.C. 20555. Attention: Docketing and Technical Specifications to change the . Regulatory Commission (Comm, c On April 24.1979, the U.S. Nu Service Branch. All comments received withdrawal schedules of the' pressure ission) by the Commission will be made vessel material surveillance capsules to published in the Federal Register (44 F ~ available for public inspection in the-bu in accordance with 10 CFR 50. 24354) a notice with respect to its Commission's Public Document Room. Appendix H. consideration of Generel Electric After analysis of the comments, the staff The application for the aciendments Company's (Ucensee) appUcatin to. will brief the Commission and the comp!'es with the stenderds and renew its Materials I.icense No. SNM-Commission will then decide whether to requiremer.ts of the Arc nic Energy Ad 1285 at the Ucensee s fuel storage adopt the staff recommendation. of1951, as emended (th' Act), and the s HI, ou o s c Commission's ruf ss and regulations.h Dated at Washington. D.C. this uth day of Commission has loade a";ropriate authorizes the applicant to receive. j August.197g-findings as required by tite Act and the Commission's rules and reg lations in 10 possess, store, and transfer irradiated j roe the Commissloo. fuel received from light water reactors Nm Cmo%s. CFR Chapter I. which ce ret forth in the ps Morris Operation fuel storago facil: Assistant Secretary o/the cornmission. license amendmtnts. Pdor public notics gra on. 7sesm raa aar-ra nai.=1 of these arrendrr.ents w cs ::ot required The notice provided that any persor since the amendments do not involve a who:e interest may be affected by the omso coos nwess significant hazanis cor.iideration, proceeding may file a petition for leav The Commissicn ha determined that to intervene and request for hearing [ Docket No. 50-471 CP) the issuance of the.ac rmendments wiD pursuant to,10 CFR $ 2.714 by May 25. l 1979-l not result in any r!gnificant doston Edison Co. (Pilgrim NucJear environmentallmpact and that pursua:s On May 21.1979, the State ofiilinoi! I I Generating Station, Unit 2); O(der to 10 CFR i 51.5(d)(4) en environmental Nthrough its Attorney General filed a I impact statement, or ne;ative. petition for leave to intervene. This The hearings presently scheduled to arah and Mrcnmedal bped We h Ge he d Ems has k l commence on August 27.1979 will be appraisal need not be prepared in granted by this Board. l convened in the Blue Room of Me'moriaj e nnection with issuance of these - In addition. four individuals, namels l Hall. 83 Court Street. Plymouth, amendments. Bridget uttle Rorem and Ralph Rotem i Massachusetts
For further details with respe:t to this Jr Essex. Illinois: Keith Storey.
j 7t is so ordered' action, see (1) the appi; cation for Kankakee Illinois: and Everett Quigle i Dated at Bethesda, Maryland.nis uth amendments dated May 16.1977, as Kankakee, Illinois, also filed a petitior. day of Augusnom supplemented Nov' mber 3.1978. (2) for leave to intervene. The petition of e + 1 i
Il , p ~ ~

~~--1 a,

JMEG-osn \\ 3g a ca:.u :c m [ _u:0. s A in Co-326 44FRM29 9' / SUSQUEHANNA VALLEY ALLIANCE'S COMMENTS CN NUCLEAR REGULATORY CCMMISSION'S ENVIRONMENTAL ASSESSMENT USE OF EPICOR - II AT THREE MILE ISLAND, UNIT 2 g, g ~; c' 4 y$e ? f 5-7 2
S 0
$ g e $ o$ i g 9 .j 4/ w Susquehanna Valley Alliance BY: CvbW / "[ ~ Larty B. /SelXowitz WIDOFF, 2 EAGER, S ELKOWIT Z & ADLER PC P.O. Box 1547 Harrisburg, PA 17105 717-763-1383 AND: l Suite 540 2000 L Street, N.W. Was hi ng to n, D.C. 20036 ,200-659-3232- $ 4,f t, [C-;W / / AIcert J. Slap PUBLIC INTEREST LAW CENTER OF PHILADELPHIA 1315 Walnut Street, suite 1600 Philadelphia, PA 19107 215-35-7200 i d 4s &^ A-m Je a n..c y e r Kohr / / MINNEY, MECUM A6D KOHR f 121 East King Street Lancaster, PA 1760-2 { Date: Septer.ber 13, 1979 f a ,n. S.%.i.f ~4 a,us fl \\
,o s -s s 4-OCTLINE I. Int roductio n II. The EAS is legally defective in that the process used { is segmented in violation of NEPA ) i i III. Section-by-section analysis i IV. Technical com:nents V. Conclusion i e e ea 4 0
e a e I. INTRODUCTION The Susquehanna Valley Alliance is comprised o f private cititens who reside in the Susquehanna Rive; Valley and who rely on the Susquehanna for drinking water, fishing, swimming, boating, and other recreational and life-sustaining uses. These citizens are deeply concerned with the continuing assault on their environment by the accident at, as well as the planned decontamination and restart of, Three Mile Island Unit i 2. They have already expressed their concern by bringing suit in the Federal Court for the Middle District of Pennsylvania (Civil Action Number 79-658) to prohibit the violations of the Co ns ti tu t io n, the Atomic Energy Act, the Clean Water Act,'and the National Environmental Policy Act w'hich are occurring at Three Mile Island. As the comments that follow will clearly demonstrate, the Environmental Assessment Study to which reference is made here is deficient in nearly every aspect and represents a further violation of the NEPA as well. 1 j J
l l N l x .~ g 1 i ] l l II THE EAS IS LEGALLY DEFECTIVE IN THAT THE PECCESS USED IS SEGMENTED IN VIOLACION OF NEPA The EAS process being followed by the NRC staf f violates the National Environmental Policy Act with which it purports to co mply. The NRC staf f along with Metropolitan Edison (Met-Ed) and its parent company, General Public Utilities (GPU) have announced that the environmental aspects of the attempts to decontaminate and restart Three Mile Island i 2 will be assessed in small increments in order to comply with NEPA. The instant assessment (on the use of EPICOR -II) is to be followed by an assessment o f the disposal of water processed through EPICOR -II. Subsequent assessments would address other phases of the project. l This alleged compliance with the requirements of the National Environmental Policy Act is in f act a total subversion of those requirements, designed to avoid tne obvious need to do a comple te, cohesive and comprehensive Environmental Impact Statement regarding the entire project o f decontamination and restart. Fo r example, the NRC staff and the GPU have already divided the cleanup operation into the following steps: 1. Adding an EPICCR I unit for the cleaning o f low-level waste. 2. Building, without permit, the entire E.:CCR II system. t _________-_____Q
a 6 N 4 s b ( 3. Processing water through EPICOR II. ( Enviro nmen tal Assesment-NUREG 0591.) I l 4. Disposing o f water processed through EPICCR II. (Environmental Assessment -NURIG- 0591.) 5. Removal of krypton gas f rom the reactor containment building. 6. Preparations for the construction of a system to treat highly radioactive water. 7. Building and operating a system for the treatment of highly radioactive wastes. This segment may or may no t include disposing of the water treated by the high-level cleanup system. 8. Removal of damaged fuel rods and decontamination and refurbishment of the reactor containment building in preparation for restart. Depending on the steps used in Num er 7 above, these are only the minimum segments currently identif.ed of one co mp rehe ns ive, continuing program being undertaken by the NRC staff and GPU designed to decontaminate and restart TMI y 2. This segmentation, is intended to create the illusion that no single segment has any potential significant envir0nmental I impact, thereby negating the requirement of preparing a full environmental impact statement (EIS) covering the entire p rog ram be fore the p regram commences. However, NEPA, as repeatedly interpreted oy the courts across the country, does i
s not permit such a tactic to thwart the clear intent of the Act. The case law on " segmentation" is consistent, as summarized by the Court in Sierra Club vs. Bergland, 451 F. Suppl. 120, 129 (N.D. Miss., 1978) (involving the dredging of a watershed) quoting City of Rochester vs. U.S. Po s ta l Se rv' ice, 541 F. 2d 967, 972 (2 Cir. 1976): In ascertaining the significance of a :ajor federal action, the project must be assessed with a view to the overall cumulative impact of the artion proposed, related federal action and the projects in the area and further actions contemplated. As the Court reasoned in Bergland, id: such a statement (EIS), ho wev e r, is absolutely required where the proposed action may f airly be said to have a potentially significant adverse ef fect. The Court concluded its reasoning as ts the 'need for an EIS by stating that: Considerations of environmental f actors "to the fulles extent possible," and "beginning at the earliest possible point" are necessary. 38 Fed. Reg. 10556, 19865 (1973). As recognized by the Second Circuit, in Conservation Society of Southern Vermont, Inc. vs. Sec. of Trans-oo r t a tio n, 508 F. 2d 927, 936 (2 Cir..974) Congress was quite aware that incremental ef f ects o f small, but repe titive, proj ects, co uld have majo r long-term e f f ects. Footnote 37 of the Conservation 5:ciety case was highlighted in Footnote 3 of the Bergland case.. ______-.________.-__.___m_.________m___.______._-___. ___________m.__.__m.__._____
3 Footnote 37 of this case discloses an important aspect of NEPA's legislative history in these wo rd s : The Senate report acecmpanying NEPA states expressly that one function of the Act is to prevent decision-making that af fects the environment to take place "in small but steady increments which perpetuate rather than avoid the recogni:ed mistake of previous decades."
5. Rep. No. 91 296 91st Cong., 1st Sess. 5 (1969).
The segmentation issue was also addressed in Sierra Club v s. Mo r to n, cited above, which involved the f ailure of the Departments of the Interior, Army and Agriculture to issue a comprehensive environmental impact statement on the development of coal resources in the Northern Great Plains, even though individual EI5 's were done in conjunction with the approval of specific mines. Pages 870 through 373 of that decision contain a thorough analysis of the background of the segmentation problem and of the rationale for not allowing NEPA to be circumvented by the division of large projects into smaller pieces and assessing the environmental ef fects of each of the small pieces alone. Quoting Jones vs. Lynn, 477 F. 2d 885 at 891 (1 Cir. 1973), the segmentation approach is " an approach akin to equating an appraisal of each tree to one o f the forest.". e
n s The Court in Sierra Club vs. Morton cites 40 CFR, Section i \\ 1500. 6 (2) (1974) and no less than six other cases which' support the conclusion that the goals o f NEPA can.-* be allowed to be abandoned by the actions of an agency in dividing the project into its less noxious components so that the whole project can be accomplished sans an EIS. In assessing the Council on. Environmental cuality's view of this question, which is in accord with that of the Susquehanna Valley Alliance, the Court said: This interpretation of the statutory term is eminently reasonable, both because NEPA plainly candates comprehensive consideration of the ef fects of all federal actions, 42 U.S. C. Section 4332 (2) (A), which consideration would be defeated if impact statements were recuired only for individual projects of " major" size, and because any other interpretation would provide an escape hatch, through agency - subdivision of " major" projects, from the impact statement requirement. -Almost every project can be divided into smaller parts, some of which might not have any appreciable ef f ect on the environment. The court would be forced to take each p ro j ec t apart piece by piece Peop'e of Enewetak vs.
Laird, D.
Hawaii, 53 F. Supp. 311, 821 (1973). Thus the courts have had no dif ficulty in requiring impact statements for " major Federal actions" that were no acre than the cumulc ;ive ef fect of related minor federal actions.
See, Natural Resources Defense Council, Inc. vs. Grant, e.g.
E.D.N.C., 341 F. Supp. 356, 367 (1972); Pecple of Enewetak l vs. Laird, supra; Minnesota PIRG vs. Butz, D. Minn., 358 F. Supp. 584, 622 (1973); SCRAP vs. United States, D.D.C., 346 F. Supp. 189, 200 (1972) (three-judge court), reversed on other grounds, 412 U.S. 659, 93 S. Ct. 2405, 37 L. Ed. l O O O
A;. * '.
P 1 2d 254 (1973) (" the ' necessity of preparing an impact by breakirig statement cannot be avoided or postponed '(the action) into minute component parts"). Cf. Named Individual Members of San Antonio Conservation Society vs. Texas' Highway Department, 5 Cir. 446 F. 2d 1013, 1022-1023, cert. denied, 403 U.S. 932, 91 S. Ct. 2257, 29 L. Ed. 2d 711 (1971). The same result was reached in Scientists Institute for Public Information Inc. vs. Atomic Enerev Commission, 156 U.S. App. D.C. 3895, 481'F. 2d 1079 (1973) in which the AEC was re-quired to provide a comprehensive EIS for the Liquid Metal Fast Breeder Reactor program even though an EIS had been done for the only plant built and it was planned to do one for each plant subsequently built. Ano ther context in which the segmentation issue is commonly addressed is that of highway construction. The case of Indi.a3 Lookout Alliance vs. Voice, 484 F. 2d 11 (1973) is only one of a series of cases on highway construction wherein the Courts have addressed the size of the project to be made a part of the EIS. The test to be applied is whether the project has the " requisite independent u tility" (ibid, at 20) to be the segment covered by the EIS. It is submitted that the attempted clean;p o f TMI is one project and that the eight or more segments enumerated above each lack independent utility to accomplish the aim of the cleanup, i.e., the restart of TMI i 2. In addition, the problems attendant to such segmented.
t i environmental review are highlighted by any reasonable attempt l to assess the use of EPICOR II. Time and again, as detailed in the sections that follow, a complete appraisal of the possible environmental ef fects and their severity can only be accomplished in relation to other parts of the attempted decontamination and instant project, including the restart o f TMI i 1, for which no environmental assessment study has yet been done. It is therefore submitted that any attempts to assess the significance of the environmental ef fects of the use of EPICOR II without a simultaneous comprehensive assessment of the entire plan to decontaminate and re-start TMI # 2 is unlawful and that the partial assessment of the use of EPICOR II, to which.these comments are submitted, is wholly without merit or legal foundation. 1 8 _a_
4 i . ~.. s 4 III.. SECTION BY SECTION ANALYSIS 1.0 Proposed Action m Above we. have ref erred to the argu. ment that the EAS.is illegally segmented and under these circumstances the NRC should not limit the EAS to clean-up and storage of the contaminated wastes. Fu r ?,h e r mo r e, the EAS does not evaluate the impact of temporary storage, packaging, handling, transportation, and burial of solid waste generated from the clean-up. The illegalysegmented EAS does not fully evaluate alternatives, including, discharge alternatives, thereby may preclude development of a more sophisticated system capable of dealing with all the wastes, including the high level waste water. Such a system may be more cost effective and present fewer hazards to public health and safety. Although the EAS allegedly does not include :he disposal of the decontaminated waste, in fact, p ro j ec td" dis ch a rg e " (into the Susquehanna River) underlies the Assess:ent. On page 22 o f the Assessment, under Section 6.0, Subpart 1, the NRC states: j TMI Unit 2 water can be processed in the existing i TMI Unit 1 or 2 radwaste systems. However, since these systems are not specifically designed for handling intermediate-level wastes, the systems are not capable of producing water of suf ficient cualitv for discha rge. Although the EAS purports to be, in evaluatica of the effect of the proposed action on public health and saf ety, _ _ _ _ _ _ _ - _ _ - _ _ _ - _ _ _ _
i o f s s 4 I in fact, by its f ailure to include an adequate treatment and "wcrst case" analysis, the NRC has no t accurately estimated the impact on human health f rom radiation doses which may occur. Furthermore, ecological impacts have received no consideration whatsoever. The NRC, while it discusses dosace f rom releases o f Xe-133 and I-131, do e s no t translate the dosage into health impact. This EAS is in the context of the nation's werst co mme r cia l nuclear accident. The accident at TMI has and continues to exert great psychological stress en the residents of central Pennsylvania. The populatien has been sensitized to the danger of radioactive releases f rom the damaged reactor and the treatment p ro ce s se s. The NFC has ignored this serious problem of the psychological ef f ects o f its proposed action. 2.0 Introduction The NRC labels Cesium 137 as the " dominate iso topic co n t r ib u to r ", but f ails to discuss the ef fect of C 137 in human and biological systems. Furthermore, the NRC fails to discuss what other isotopes may be vented to the air (though the EAS does provide for a vent filtration systes) or n srs through the system, such as tritium. Further, the Assessment f ails to treat in any way the chemical interactions of the isotopes in the ion-exchange system. (See Part IV, Technical l l Co rtmen ts ) - _ _ _ _ _ _ _ _ _.
( The Assessment should state which radioactive isotopes will be vented, at what concentration, in what amounts and should report the calculations and figures upon which such statements are made. The Assessment should describe the solubility and/ volatility of each isotope. 2.1 Need for Decontamination The NRC has no t made a clear case to justify the risks o f decontamination. The Assessment states but does not explain why decontamination is necessary to maintain safe shutdown. It appears'that EPICOR II was chosen as a relatively quick method to treat the intermediate waste. Because delay in this case will only make wastewater safer due to decay of radioactive isotopes into stable isotopes, we cannot understand why the NRC staff and Me: Ed wish to rush the decontamination of the stored water. As a second rationale for speedy decontamination, the NRC staff cites undue exposure. The Assessment does not describe how the workers are exposed nor do they discuss how worker exposure can be mitigated without processing the wastewater. Extra-shielding and cleaning of contaminated surf aces should be evaluated. It is our understanding that 50% of undue exposure is due to contaminated surfaces and that such contamination is now _
~ I ~ r i being removed. In the EAS a comparison is made between the occupational i exposures to be encountered if.the EPICOR system is not used and the occupational exposures f rom operation of the EPICOR system. The comparison, however, is no t adequate' in that ' the q entire process from beginning operation of the EPICOR system to end disposal is not evaluated. Furthermore, operating procedures have not been defined to such a level that the number of employees needed in the transfer of spent resins is specified. In order to make the threshold determination concerning the need for the operation of the EPICOR II
system, this further clarification is needed to compare the man / rems of exposure in both cases.
Nowhere does the EAS discuss the availability of additional shielding to protect workers while they maintain the Reactor in a safe shut-down mode. It is possible that this additional shielding would obviate the need for the use c ' rPICOR II and would allow the agency and the company to let the radioactivity decay naturally while they study in greater depth the alternatives available. < at It is notAall clear that cuf ficient storage capacity exists for the 245,000 gallons to be processed in the TMI [I auxiliary building. It is clear that some of this waste will have to be re-circulated back through tanks f rom which it came. 1
s 1 ) j l These tanks are contaminated with radioactivity, and some of 1 that radioactivity would be transf erred back to the cleaned up water. 3.2 Modification of EPICCR II 3 I The construction, in s talla tio n, and use of EPICOR I after 1 i the March 28, 1979 accident constituted a violation of the { Atomic' Ehergy Act in that application for and issuance of a construction permit are recuired under the Act. Although the financial interests of the licensee would i be served by a f ast' decontamination me thod, the NRC staff must under NEPA explore alternatives such as iso'ating the plant, biologically, f rom the environment. 3.3 Cesign of EPICCR II Syst'em j i
EPICOR Il has no record of operational experience.
Bold / assurances that it will do the job the NRC staff says it will j i ] do are no t e no ug h. Icn exchange is not the best available 1 t e ch no lo gy, and it does not provide the protection of the j environment which would exist if a combination of evaporation, i ion-exchange and carbon absorption were used. (See Technical I l ) Comments) 3.3.1 Description of EPICOR II System The NRC staf f states the ion-exchange resins will result I in 90% removal ef ficiency for radio-nuclices. The staff l f ails to state, ho w e v e r, the basis for that assertion. Further 1, J l i l 4
1 t it f ails to report data on flow rate and resin capacity which would enable indepen tent analysts to evaluate NRC's assertions. Data on the caoacity of resin beds is essential because the i filtering function terminates when the bed is exhausted. Data t i on desintecration of the resin beds is equally essential i because the resins disintegrate when bonded to radioactive i isotopes. l The NRC bases its plan for storage o f processed water on the use of tanks f rom Unit 1. Because this assessment is legally segmented, no plan for Unit 1 is present&d, although proceedings for re-opening Unit 1 are going forward. What will happen' to water processed through EPICOR II if Unit 1 is re-opened? We believe that the NRC staf f plans to discharge this water into the Susquehanna River. No other alternative is i i provided in this Assessment. 3.4 Design Features of Spill Prevention 1 The EAS is extremely sketchy on a worst case analysis. ) The EAS totally f ails to put the radiologic risks of operation of the EPICOR II system into context. The cation demineraliter i spent resir, will have a radioactivity such that it would give a dose of 400 rems per hour, a nearly lethal dose. The important f f actor here is timing. Nowhere in the EAS does it differentiate be t'a een of po t in context the levels of radiation involved in f 1 the opera tion o f EPICOR Il aad compare it to not operating the i 3
1 N i I
s.
+ 1 J 1 system. It is not clear f rom the EAS all the number o.- i steps that will be tequired to move the radioactivity out of the water and to its final resting point. We have estimatcd preliminarily that there would be over 200 ( individual handling steps for each of the resins. This I creates the risk of substantial human eyposure. j t 4 The only "wcrst case" discussed is a " worst case ( pipe break", explained a.s 'a break in the liquid waste { inlet pipe to the EPICOR II prefilter/deminerall:er." (Assessment, p.11) j Cn page 12 of the Asse<. ment, the NRC staff refers to the HEPA filter and charcoal absorber system and i estimates the thyraid dose f rom normal air ventilation thro ugh the filter. But the NRC f ails to mention the serious risk of spontaneous combustion and fire in this filter system. In the NRC's Answer to the Susquehanna i Valley Alliance's Interrogatories, the risk of fire is described as follows: t 3.5.4 Fire 3.5.4.1 Ventilation System ShEEld tney become too hot, the charcoal absorber beds in the ventilatio. unir coul. i l ignite. Upon indication o f ignition of th - charcoal bed, the r.anually actuated fire protection sprays should be cut in. l l
2 J s A fire in the filter vent system.ould result in i serious releases of Iodine 131 to cae public. This risk l should be ~choroughly reviewed in a :omplete wors t-sase f analysis. 3.5 Design reatures to Minimize Gaseo;s Releases The HEPA filter and charcoal abscrber system as described by the NEC staf f has, only o te radiation monitor. The lack of backup monitors is a problem whi:h permeates this treatment system. If one monitor malfunctions, another one would continue to do the jcb. Even in the absence of mal-functioning, double monitoring prov ; des a ecnstant chack for validating radiation readings. The NRC staff states that " Iodine fixin; chemicals" will be added to minimize gaseous releases. Nowhere does the Assessment say what these chemicals ar. Most important, the Assessment does not describe the a feet such chemical additives will have on the io n-ex c.' :ng e re s ins ' aoility to clean the water. (See. Technical C;mments) 4.0 Occupa tio ns 1 E;:po su re This section o f the Assessment s defe:-ive, surprisingly
me+7
~ since occupationaljis put forth as "me major reason for proceeding ) with treatment of the radioactive wa:-r. Although shielding of the EPICOR II processing area is descr. bed in detail, there is little data givan as to what kinds e.1 obs will be performed inside the processing area, what nc : mal main enance tasks are necessary, what emergency maintener e can be anticipated and, j
.,y / i i i 1 what protective ceasures will be taken. ) i Further, numerous transfers of the concentrated ) radioactive resins in cas's are clearly anticipated but a f no data is givea as to worker exposure or protection o l during these transIers. L Transport to of f-site dist 3.1. f acilities is no t di.scus~ed at all. What protective measures.will be taken 3 s to eliminate exposures to workers and 'the public during ) transport? ) Again thic. section ref ers to "... off-site disposal in l an approved fac;11ty." Many critical cuestions are left. I l unanswered here. tihat kind of disposal site? Where is the . facility? Has dis 7 sal in a facility received necessary governmental appre als? In its discus ion of estimated radiation dosa rates, 1 the NRC staf f n er takes the necessary second step-the j i analysis of the dose and translatio~n into health.ef f ects, q Clarification end substantiating data are necessary to give. ] 1 the conclusory statements regarding dosage credibility. I l 5.2.1 The Interi;n $torage Facility ] In order to m_ aitor potential contamination of groundwater f rom "n-site storsge of concentrated radioactive resin beds, the M;C staf f proposes that a well be drilled in { the vicinity of the buried beds f rom which samples can be . j J
3 ) j i taken. If such a well is an accurate monitor, more than one should be drilled. The A7.;sessment provides 'no discussion i regarding contamination of the suscuehanna River from the " groundwater" unuer the island, i f Complete geological data is necessary before o. i .s te storage of these high-level radioactive wastes can proceed. l The perf unctory treatment of the construction of this on-1 aite radiaction-waste storage f acility is sb.ocking. ) \\ O l j 4 4 1 i i 1 I i ( j i i 4 )
. Y.'., TECF.NICAL COMMENTS (LOUIS hKOS.EEO_ l ' i hs dcccent is in respcnse to a public req.:est by tm *.hited States l Nclear Regulater/ Ccmissien cencerning any c.v.ents regardi g the prelimi- ':ar/ envirc=eatal ussessnent of the EPICCR-II ater treatnent system at the hree Mile Islani eclear pcwer plant - Unit 2 (IMI-2) facili y. ne enviren-mental assess =ent was issued by USVC on August 14, 1979 and reta';.s the desig-I natica, UREG-0591. The evaluation herein is previded en behalf of the Susque-l hanna Valley Alliance. The prine motivatien of 0.3 gTcup, which has retained rf services, is to cer.st:uctively review the posts;ident activities which are presently being cend.:cted at IMI-2. He basis of their review is to maintab a pestre which emphasi:es that "all activities which are cenducted to clean up the present prchlets related to the Ma:r.h 28, 1979 accident" are carried ut in a :.anner which nz_ximi:es and assures the health and safety of persons ia the area of IMI and the Susquehanna River Valley. This evaluaticn is an unbiased discussion of the text cf !LREG-0591 en-titled Envircrmental Assess.ent: Use of EPICOR-II at ihree Mile Island, Unit 2. 'Ihe term unbiased refers to the fact that de preposed syste EPICCR-II is ob,' ectively evalua:ed regarding 1) perfore.ance or ncn-perfe:.ance, 2) p:evious pe-icn ance of similar systems as extrapolated to the unpre':edented quality of water which is specified by NCREG-0591, and 3) the designatica of a feasible sia: cent techno1cgy (ies) as based upcn prud:nt scientific @.cesht. Prime c=phasis is placed en the capability of EPICCR-II to prcduce an effluent cen-cr ent with GR Title 10, Part 20, Appendix 3, Tabic 2, alternate techno1cgies wt.ich will picduce a crpliant effluent, s.nd the characteristics of the water which requires treatnent. The purpose cf N?rG3-0591 is best defined within its cwn text by these c:.:ed sta:=ents: 19
k "This assesment is an evaluaticra of the effect that the proposed action 'il'. hve en the ;nblic '- ale r.d s&y and cr. the envirement including a '+ wideraticn of occupa' e.a1 ex;csures r.d the risk of at dental releases arai a discussien of alternatives to the EPICCR-II systm." '- "This assess-3 ment.... deals vid the preposed decentaminatien of the intermediate level (was te)" Sirply, the basis of.GE 0591 is to establish the decenta=iutien capability cf EPICCR-II cn intermediate icvel waste-water and the effect that this decen- ) ati.atien syste= will have en a) occupttiena.1 exposures, b) the envirc=ent viein which the decentaninated water i's to go with respect to public health r.d safety, c) the possibility of accidental releases, and d) alternative ned.o:is. J l Prelinitary Evaluatica De water which cer.tains intermediate levels of radiation (<40 niere curies per nilliliter) and requires treatment has been cbtained frca the folicwing sCt:"ces. - existing centaninated water prior to the accident - contaminated water ficn the reactor centai=.ent su=p - reactor ecolant systm letdewn (purge) - leakage frcn systen cc=penents Dis water of a volu.e cf 288,0C0 gallens is cenuined in the auxilliary building 1 ta _ks and cnly the cler..up of these tanks is presently prcpesed in ES-0591. ) 1 l D.e varicus tanks holding this liquid are defit.ed with regards to levels of I-LII, Cs-134, Cs-136, Cs-137, Ea-140 c.d H-3. Si=e the basis of defining a treatment techoicgy to decentaninate this j i l sster is established by the characteristics of de water which requires trest- \\ \\ an extensive review cf the na:ure of the water's ccnstiments d.cu.1d be j l .ent, i l cen:=cteg pror.o equi;nent e-ge.e atien, tecnuse of e.e vari = scurces f 20 l I
1 of de water and an unclear idea of the integrity of the reactor arxi coolirq \\ , system which includes integrity of the feel rods, por ,n of spent fuel in i de reds, severity of red ds age, st:uctural integrity of cooling systto ccm-i j pcnents and the leachi:q characteristics widin de fuel reds, the fission 1 1 preducts usually associated with nuclear reactors are cf prine concern as well j i as activatien/ccrresien products, dissolved gasses, suspended solids (c:ud) and salindty (dissolved solids). The radionuclides usually asscciated with I fission product contamination arn listed in Table 1. The original quantity of the varicus fission products which could be present are a function of deir fissica yield. n.e prese.: gantity of the i varice.s fissien products that exist are a functicn of their i-dividual radio-active half-lives and the equilibria established between daughter and decen-dan: isotcpes. Because of the 171 days which has elapsed frz: March 28, 1979 to September 15,1979, :nost of the beta arNor gs=a emitters have dis:ipated bemme of radioactive decay. The ' t retaining' colunn in Table 1 defines the l persistant fissien nuclides which might possibly be centained within the fater-i mediate level water in significant quantities. Hence, to effectively establish -l a design basis for the decentaninatien systen, analyses siculd be ccnducted to ( check de levels of these persistant fissica products which nay possibly be f ? I present in contaminated water, q i In additien to the fissien and equilibrated r:uclides e.ith are present, de possibility exist.s for the water to contain varicus radi: active cerrosien/ l activatien products. These prcducts are listed in Table 2. The prcducts are 1 fc=ed by the additien of a neutron frcra the reactor core to the r.ucleus of a 5:.dle isetcpe and sccetines results in the fematien of a radienuclide. Tnese species, be dey radioactive er stable at de tine, are ccrreded frca de struct".ual compenents of the system by the acticn of the water 2.ich is ~ present. Again, de radioactive half-life of the isctcpe will define de per-I f sistant species a.d dos [which will require treatent. The '% recair.ing' 21 i l
Table 1. Radic=clides a:seciated with fission product contamination j l Mc<' of Major er.ergy % F.eraining I {sotepe Half-life de. y level ()fev) Scurce State at 9/15/79 0.662 dan-hter Cs-136 colid <0.0001 Barium - 137m 2.fn y - 139 34m 3/y 2.3/0.166 fission c0.0001 - 140 12.3d g/y 1.02/0.537 fissien <0.009 3rr,ir.e - 82 35.1hr 3/y 0.444/0.534, n-capture, 3r-81 volatile <0.0001 0.619 - 33 2.41*3 S/y 0.93/0,53 n-capture, Se-82 <0.0001 - 34 31.8m s/y 4.68/0.88 fission <0.0001 - 35
3. 6 s
2.5 fission <0.0001 Cerium - 141 32.5d S/y 0.581/0.145 n-capture, Ce-140 solid 2.6 - 143 34.0hr S/y 0.293 n-capture, Ce-142 <0.0001 - 144 285d s/y 0.31/0.134 fissien 66.0 Cesits - 134 2.05y S/y. 0.662/0,605 n-capture, Cs-133 solid 85.4 - 136
13. 5/.
3/y 0.657,0.341/, h-138 0.015 0.813 137 30.0y S/y 1.176,0.514/, fissien 98.9 0.662 - 133 32.1m S/y 0.340/1.426 fission <0.0001 - 139 9.5m y 1.65 fissien <0.0001 Iodine - 129 1.7x10 y S/y 0.15/0.04 fission volatile 99.99 7 - 130 12.5hr S/T 1.04/0.7 n-capture, I-129 <0.0001 - 131 S.06d S/y 0.S06/0,364 fission <0.0001 - 132 2.I:x Sh 2.12/0.773 daughter Te-132, <0.0001 l fission - 133 20.8hr S/y 1.27/0.53 fission <0.0001 - 134 52.4m S/y 2.43/0.89 fission <0.0001 - 135 6.Thr S/T 1.4/1.23 fission <0.0001 i 0.009 daughter Rb-83 gas <0.C001 KO7tcn - 83m 1.86hr y. - 35m 4.#.: s/y 0.32/0.134 fission <0.CC01 0.67/0.514 fission 96.9 - 35 10.3y g/7 - 37 75m S/y 3.8/0.403 fissien <0.0001 - S3 2.8h-S/y 2.3/0.191,2.40 fission <0.0001 - C9 3.2m 3/v 4.0/cceplex fissien <0.CCC1 - 90 33s S/y 2.8/0.536 fissien <0.0001 Lantha- =m - 140 40.3hr Sy 1.69/1.57 daughter Ea-140, solid <0.001 / fissien - 142 92.5m 5/y 4.51/0.65 fission <0.0001 .tlyb-dentra - 99 66hr g/y 1.23/0.181, n-cap tur e,}'o-98 sclid <0.0001 0.760 fissica Need p- ,.S1/0.091 fissi:n solid 0.23 it:3 - 147 11.1d S/y 0 l Nicbitra - 95 35d S/y 0160/0.765 daughter 2r-95 solid eg.ilibriu: <0.0001 97m 1.Cn v~ O.747 daugh er 2r-97 4 97 74m S/y 127/0.665 descendan: 2r-97 <0.0C01 i l 22 1 i l 1
Table 1. Centinued. N M04n of Major e.e:gy t Re.aining ..Isotrpe Half life 5 y 1cvel 0!er) Scurce State at 9/13/79s Praseo-d ci.= - 143 13.6d 3 0.933 fission solid 0.016 - 144 17.3m s/y 2.99/0.695 daughter Ce 144 equilibrium J Rhodi.s-103m 57m y 0.04 daughter N-103 solid <0.0001 - 105 36.2hr S/y 0.57/0.32 n-capture,N-104 <0.0001 - 106 3035 S/y 3.54/0.512 daughter, h-106 equilibrium bbid-83 100d y 0.53 3r.83 30.6 i- '88 17.7m S/y 5.3/1.26 daughter,Kr-88 fission solid <0.0001 89 15.4m S/y 3.92/1.05 fission <0.0001 h the-nium - 103 37.5d S/y 0.7/0.497 fissien-volatile 4.98 - 106 369d S 0.039 fission 72.5 Stron-89 50.6d S/y 1.463/0.91 daughter Eb-S9 solid 9.61 ti'.m 90 28.0y S/y
0. 54 6 fission 98.84 91 9.7hr S/v
.2.67/102 fissicn <0.0001 92 2,7Fe S/y 1.5/1.37 fission <0.0001 Tec':ne-992 6.Ch-~ y .0.14 daughte Mo-99 solid <0.0001 tium 99 2.1x105y S 0.292 daughter Mo-99 fission equilibriu:n Tellu-rium.- 12~m 109d S/y 0.73/0.06 fission solid 33.7 - 127 9.4be S/y 0.7/0.36 fission <0.0001 - 129m 33d S/y 1.6/0.69 fission 2.76 - 129 67m S/y 1.45/0.03 fissien <0.0001 - 131 a 30hr 3/y ? 46/0.7S fission <0.0001 - 131 24.2m S/y 4.14/0.15 d.aughter Te-131.t <0.0001 - 132 73hr S/y 0.22/0.230 fission < 0'. 0001 - 134 43m y 0.204 fissica <0.0001
Tritium 12.26y S
0.0136 n-capture,H-1 liquid, gas 97.39 Xenen - 131m 11.80d y 0.164 daughter I-131 g?.s equilibrium - 133m 2.26d y 0.233 fission <0.0001 - 133
5. 4d S/y 0.346/0.081 fission
<0.0001 - 135m 15.5m y 0.527 daughter I-135 <0.0001 - 135 9.14hr S/y 0.92/0.250 fissicn <0.0001 - 137 3.80 S/y 4.1/0.455 fission <0.0001 - 138 1"m S/y 2.4/cca:: lex fissica <0.0001
0. 2'2 fission
<0.0001 l - 139 43s y 1 23 \\ l I d
t i Table 1. Conti=ed - { Mod of Major energy ) Fr.ainir4
l
' Isotcpe Half life dl.y level (Mei) Scurce i State at 9/15/79 .Yttri.m - 90 -64.5hr S. 2.27 f.aughter Sr-90 solid <0.0001- - 91 -58,3d s/y ' 1.505/1.21 fission .13.1 ~l - 92 3.5hr s/y 3.63/0,5,0.934 ?_aughter Sr-92 fissicn <0.0001' - 93 10.1hr ,'3/y 2.89/0.267 fission <0.0001 1 Zirco-fission-solid 16.15 niu:s - 95 65d 3/y 0.39,0.356/0.74 - 97 17hr S/y 1.91/0.747 fission <0.0001 j ~
Inf ::atien obtained fran references 1-8 i
1 6 I i i sep l i
~ Table 2. Radioactive corrosion / activation proa: cts associated with r:uclear reactors
Mod of.V.ajor energy
-.Isotdpe Half-life dewy level Ofev) Source 5 tate t ?.er.aini.g Cumius - 51 27.Sd y 0.32 activaticn solid 1.4 Cobalt - 38 71.3d 3/y 0.474/0.18 activation solid 19.0 93.9 - 60 5.2y S/y 155/0.06 activation Iron - 55 2.6y y 0.23 activatien solid 88.3 - 59 45.6d 3/y 0.48/1.095 activatien 7.4 Mangs-nese - 54 '303d y 0.835 activation solid 67.6 - 56 2.57hr S/y 2.85/0.85 activation <0.0001 Nep:a-nit:n - 239 2.14x10 y a/y 4.78/0.086 daughter u-237 solid equilibrit:a 6 Nickel - 63 92y S 0.067 activation solid 99.6 Niobit:a - 92n 10.16d y 0.934 activation solid 0.0009 Phospho-reus - 32 14.3d S 1.71 activation solid 0.03 - 33 25d B 0.248 activation 0.9 Sedit:a - 24 15hr 3/y 1.39/1.37 activation solid <0. 0.001 Tin - 117:n 14d y 0.158 activation solid 0.02 Tungs m - 185 75d S 0.429 activation solid 20.6 137 24hr 8/y 1.31/0.686 activatien <0.0001 j l Ut anit:a - 237 6.75d s/y 0.248/0.06 activation solid <0.0001 j f I
references are 1-3 1
1 1 i 4 25 w-__
i ('co1*. a in Tabic 2 defines the persistant activation type nuclides which might be contained in the wati at significant levels. An important parameter which is recuired in defining the treatment system that will effectively decontaminate a stream such as this is the physical fc= of the radicmelide. The various physical fo ms are: gas, liquid, and solid. Tnere are tw types of solids, dissolved solids and suspended solids l which have been temed 'emd'. Padicmclides can be volatile which means the i j their physical fem can change frm solid to gas depending en the physio-chmi-cal enviren=ent. The ir:pertance in 'c.cwing a cceplete profile cf species that-i =ay require re=cval (Tables 1 and 2) is related to the use of different func-ticr.a1 c:rponents within a system. Sphasis on the dc=inant state =ay define i a requirement for addition of stabili:i.ng ccrcpcends, a gas st-ipper, liquid l purification cc=penent, deinerali:er or filtration system or a cc=bination thereef. Tne water characteristics define the most applicable decentninatien tec'noicgy. A characteristic which is a result of Oe elecental radienuclide alone or ith oder ele =ents to fem a expour.d is valence. Valence is the charge which the radienuclide retains as its given fem in solutien. Valence can cha.ge wid pH, exidatien state, de cenversion of the elemental fom to the cc=cunded fem, and choical reaction with other constituents. Tr.e pre-de '. ant valence of a specific isetcpe er grcup of isotepes plays a critical parc in the design of a decenta-dnatien system. Table 3 lists the lcng lived radionuclides asscciated with fissica reactors and the valence cf these nuclides in their ele = ental and ccc:peunded for.s. Solubill.ty is another i. ;ortant factor in desi,,ning a decentninaticn system. The physicochemical envircnnent of the water and the ecdificatiens to the water ccncurrent with specific treatment ccr::penents will in scce cases l affectthesclubilitycfradicactivespecies. If a constituent changes frc a soluble to insoluble species (cr visa versa) de physical fem has been 26 I j
~ . Long-lived radier:uclides associated with fission reactors Table 3. I H.ighest.Mer red Required CF Isot=pe Half-lire Valence Level (pCif _)* (9/15/79)' 3ari m - 140 12.8d +2 0.006 0.8 Ceri n - 141 32.5d +3,+4 ?H I - 144 235d +1 ?N I Cesi m - 134 2.05y +1 7.1 3.2x105 - 136 13.5d 0.024 1.07 I - 137 30y 34.8 6960 Chrar.J.- tm - 51 27.3d. +2,+3,+6-1,-2 ?N I Cobalt - 58 71.3d +2,+3 60 5.2y ?M I 7 Icdine - 129 - 1.7x10 y +1,45,+7-1 >N ~ I - 131 8.C6d. 0.0013 17.3 Ir n 55 2.6y +2,+3 >M I l - 59 45.6 ?M I re,.: ten 35 10.3y ?M I 'Yr.ga-ese - 54 303d +2,+3,+4,*6,+7 ?N I Neptu-nit::s - 239 2.14x10 y +3,+4,+5,+6 ?N I 6 Nickel - 63 92y +2,+3 ?N I The spho-rcus - 32 14.3d +3,+5,+2,+3 >N I - 33 25d ?N I bbid-it= - 83 100d +1 ?N I hthe-nits - 103 39.5d +3,+4,+6,+3 ?M I St :n-ti'.m - 89 50.6d +2 }M I I - 90 28y ?M I l Tec.5 e-tits - 99 2.1x10 y +7,-1,-2 ?M I 5 Tellu-rim - 127m 109d +4,+6,-1 ?N I - 129m 33d ?N I Tin - 117m 14d +2,+4 ?N I I 27 a
) Table 3. ' Conti:::ed a Highest Me3< :r d Recuired DF i ' Iso::pe Half-L e Valence level (pci ?,8 (9/15/79) l
Tritit:a - 3 12.26y
+1 0.966 1.29- ?ms-sten - 135 75d. +6,-1,-2 .w .I, diri'.n - 91 58.3d +3 .94 I l 21::.0- .a.its - 95 65d +4 N4 I .W - not measured -l I - insufficient data - level calculated to 9/15/79 i a O e e' M 28
altend and an alte-2 e decentrtinaticn tech..olegy =ay be required. a,. Tne aforecentiened rs=eters designate that an extet te aralytical effert is required to:
1) det2=i.e all cf de radionuclides which require decc..aminatien, 2) the percentages of varicus radionuclides which desig. ate
) the predcnirate physical for s, 3) establish the valence and solubility of de.uclides to be cogni: ant of suggested design requirements and 4) establish the presence and capability of other non-radioactive species t.'at may inter-fere or disrupt the operatien of a preposed decent 2ninatien crpenent or system. 5 The envirc= ental assessment, N.7.EG-0591 does not reflect an extensive an-aly-ical effort nor testing program which w?.s ained at fully defining the narre of de water which requires decen"-i.atien. A =cre ca.plete analysis shedd involve a characteri:atien of suspended solids, ncn-radioactive dis-sol.ed solids, a -2terial balance of all nuclides present r.d the nature plus quantity of dissolved gasses. Granted, several significant radioactive I species were defined, but in view of the previeusly discussed emplexities which ccCd arise, additicnal infor.2 tion is required prior to de selection cf a abatement system. Mere i=pertantly, additicnal data is required to assess the feasibility of a successful, efficient techno1cgy. l Decenta.tinati:n Facters The radioactive constituents Icdine-131 and Cesi=-137 are defined as de ) pri.nciple radionuclides presenc in the waste wster for radiological dose cen-sideratiens with Cesium-137 bei.g the major isotepic contributor due to the 30 year half-life. Tne additional iscrepes: Cesium-134, Cesi=-136, ?2ri=-140 and Tritium are also defined as to their level in the inte=ediate level waste-2.e accepted teminology which defines the extent to which a cent 2mi.ated wace r. e.tity can be decent =.i.ated by a trea ment technolegy cr should be decen-t'".ated is temed de decen 2:ti 2tien facter (DF). Tne deccata-d2atien factor i 29
is calculated by dividing the ntrnerical valus of the influent entity by ths l n=erical value of the f. luent entity (9). The charactc,' tics Of any unrestricted discha 3ed effluent streaa nust be within the lisits established by L-x Title 10, Part 20, Appendix 3, Table 2 concurrent with the lirtits established in de license, which in this case reali:es a dilutien factor of 250. The decentartiration factors which are required for a disdarge to be in expliance can be calculated if the influent level is kncun. >UREG-0591 des-ig:.ates influent levels for I-131, Cs-134, Cs-136, Cs-137, Ea-140 and tritit:n. If any of the icng lived isotcpes in Table 3 are centained in the inte: ediate level waste-water and a high probability dces exist, it is i. possible to calculate a requi ed DF with the data given in SUREG-0591 t: Cess additicnal analyses are conducted or reported. Referring to Table 3, M represents the pcssible influent species which were not delineated in !UREG-0591 and I repre-sents insufficient data to nake the CF calculation en a specific isotcpe. Utili:ing the data which is provided in $12EG-0591, a dilutien factor of 250, and 171 days of radioactive decay, de required DF values can be calcu-la ed. As indicated in Table 3, the DF required for the receval of Barit:a-140 fr=n the auxilliary building tanks is 0.8 as of 9/15/79. 2.e EF value of 0.8 for Earit:a-140 designates that dere is no trear ent requirement associated with dis isotcpe. The treatment requirement does net exist for Earit=-140 because the levels of this isetepe are belcw the regulated value f:r discharge. The level of Earit: -140 has been significantly reduced by radioactive decay because of its 12.8 day radioactive half-life. He CF required for Cesit:n-134 as based upcn the cperating license CPR-73, a dilution facter of 250, NCREG-0591, and 171 days of radioactive decay is 315,555 or 3. 2x 10. In relative terms, this EF is extre ely high. The usual 5 r:nge fer a CF is 10 to 1000 and in special cases as high as 10,000 (10). This va've is 31. 5 ti':es J.igher dan 10,000. The CF require ent for Cesit: -134 is 30
1 specified in Table 3 and very little advantage can be gained by radioactive ' decay because de half, "e of Cesitn-134 is 2.05 years, he time requirement for de Cesitn 134 to be at a DF of 1000 because of radioactive decay is apprcxi 2:ely 17 years. The radionuclides Cesits-136 was specified in.WFIG-0591 as being centained ) in the liquid presently stored in the at:xilliary building tanks. 4 plying a l 250 dilutien factor, the DF requirement as of 9/15/79 is 1.07. This DF is .relatively Icw and is such because due to the 13.5 day half-life of this isc:cpe, over 994 of this isotcpe has dissipated. The DF value of 1.07 is listed in Table 3. An additient.l isotcpe of cesitn which was delineated in 175G-0591 was Cesi'.n-137. Ccn: paring the regulated levels of this isotope with the level cf Cesiu:n-137 actually present, the required DT is 6960 to prcduce an acceptable ef~uent. In relative ter:s, this DF is screwhat high. The amount cf Cesits-137 which has dissipated because of radioactive decay is negligible since this ise cpe has a half-life of 30 years. Very little advantage can be gained by allcwing this isotcpe to decay because of the icng half-life. Another isotcpe which was identified by %72G-0591 as far as actual levels
i. the auxilliary building tanks was Iodi.e-131.
Since icdine is volatile, a ce-ain a cunt will be centained as a gas, and the remainder will be as a dis-selved solid. The variability cf volatility can be minimi:ed by pr:per pre-treat.ent of the water. Assining all of de Iodine-131 exists as a dissolved sclid, and incorporating a dilutien factor of 250, the DF requirement is 17.3 as of 9/15/79. A significant portien of this fissien prcduct has dissipated due te its 8.06 day half-life and has thus decreased the required DF. The levels of tritita were meanced in de auxilliary tanks and de levels of this isotepe which is usually asscciated with nuclear pcwer facilities is designated in 175G-b591., Utili:ing de dilutien factor of 250, with negligi-4 ble decay because of a 12.26 year half-life, the required decentr.i.ation facter 31
is listed in Table 3. This DF is relatively Icw. ' D.e required CF vr s as based upcn the analytical. a specified in ?L753- 0591 range fica 315,555 to 0.8. As the isotepe(s) which retain the high-est OF.alue are the limiting nuclides which delineate the basis of a water trea nent system's design, emphasis must be placed on reccving Cesium-134 Mcsever,.%72G-0591 places this primary emphasis regarding decontamination en Cesim-137 and Iodine-131. Since the isotepic fers of the nuclides are iso-electronic, their che=ical preperties are alike and thus de final decentami-natien system should emphasi:e the removal of cesium a.d retain a DF of 315,555 fer Cesium-134. Because the design of EPICCR II is based upcn a value of less dan 100 pei/c1 of Cesium-137, this limiting value sheuld be stated regarding Cesi.:m-134 as this is the mest critical radienuclide. Cf the nuclides present in the auxilliary tank building, the levels of Ea-ium-140, Cesium-136 and Iodine-131 have dissipated solely due to radioactive decay. This radioactive decay has significantly reduced er eliminated the recnited CF for these isotopes. Reviewing the icng-lived isotepes, Cesium-134, Cesim-137 and Tritium, radioactive decay has not significantly altered the levels of these nuclides present and subsequently has not reduced the required EF values. The review of additional fissicn prcducts which have been pTcVen to exist at nuclear pcwer facilities (Tables 1 and 2) and the su=ary of icng-li.ed isotepes which may be present in the auxilliary building tanks (Table 3) but have not been addressed in hUFIG-0591; designates dat if any cf these iscrepes are contained in the auxilliary building tanks that they will be re-tai.ed at the levels near their criginal amounts of radioactivity. Because the isotopic centributien by these nuclides, which was not addressed in 1UPIG-05-1, might be significant and their required DF values will not significantly de: ease due to radioactive decay,. this is another justificatica fer additicnal rdicanalytical werk to be ccnducted en the water centained in the auxilliary bui'. ding tanks. Again, the e phasis of these analyses is placed upen =cre fully 32
V icharacteri:ing the. liquid so that a design engineering fort.at can be estab-l l 14 iished to substantiate r; aatment techno1cgy (ies) to faf c tate radioactive j decentan hatien. Decentaninatien Technelegies I The dccc.ent tL72G-0591 has justified the requirement for a new processing system fer intermediate waste decentaninaticn. As there is an established 3 I need for a new system, this system should be defined by the operational require-i cents placed upon it as well as the decentaminatien systes's ccrgatability with l de water which requires treatment. Since the cnly criteria established in-I I 1 WF2G-0591 regarding operational require:ents is to properly decentaninate the water centained in the auxilliary building tanks, emphasis is placed upcn re-1 c,uired DF values. He present range fer specific DF values as based upcn nuclide j leve's specified in WFIG-0591 is 315,555 to less than 1.0. Although the DF values associated with treatment technologies retain levels i cf variability associated with cperaticn, water chenistry, DF for specific j 1 iset: pes and en-site parameters, an alig rent of DF versus technology is avail- ] i 1 able frem published deezents. This aligr=ent of DF versus technology is one basis for establishing the ces appropriate techno1cgy for decentninating the j liquid centained in the auxilliary building holding tanks. ~he technology of (distillation) evaporation has an average CF range of 1000 to 100,0C0 (6,11, 1 12,13) for a single effect system without a ncn-volatile solute. The cperatien of an evaporator can be significantly affected by. entrainment, splash ever, fea:: and volatili:atien of solute (12),, The techno!cgy of icn exchange has an average DF range cf 2 to 1000 (2, 3, I 6, 7,14) and the efficiency of operatien is mcdified by the ccc;csitien of l i waste liquid, 'backgicund constituents, the type of exchanger, regeneration Octhods, undesirable oils and suspended solids. The technoicgy of reverse ~ csrcsis has an average DF range cf 10 to 100 (6,15) and is disr.7:ed by 33 i
' c.e-h c. ' ydrolysis due & excessive pressure or temperature, chemical deterio-ratic. and fouling frembpended c.aterial. Precipitation used but the efficiency of this physioche tical is related to the solubility of the radio-l cuclide and is specific to certain elements (10). As based upon current state of-the-art technology, published data, and I the technology of pr.:. dent scientific $cught in the area cf water treat: ent, evaporation is designated to be the best alternative for achieving the re-quired DF for Cesits-134 as well as for the other isotepes. UREG-0591 specifies dat "EPICOR II... represents the best alternative for desired decentaninatien." Mcwever, there is no basis presented nor data centained in t'.is doct=ent which justifies such a statement. The design basis upcn which this quote and EPICCR II is based upcn is cited as both NUREG/CR 0141(16) and Sl~AEG/CR-0143(7). NUREG/CR-0141 discusses the present use of varicus types of filters to re.cVe both radioactive and non-radioactive suspended solids frco stres:.s i These filters when :crbined with icn asscciated with nuclear pcwer reacters. exc'.ange retain a DF of 1.1 to 10.0 for suspended gress beta and ga ma activity and 1.6 to 2.5 for specific suspended nuclides (16). The dcccent S E G/CR-0143 is a state-of-the-art review of de uses of icn exchange to decentaninate strez=s associated with nuclear pcwer plants. The decentaminatien factors designated in this doc =ent for ion exchange, with regard :: the specific isctcpes defined in ht'AEG-0591 as being present in de auxilliary building ta.k, range frcu II.1 to 1000. He technology of icn exchange will not re-cVe iset: pes that are dissolved gasses nor will it recove radi: activity in the for= of suspended solids except by filtration (7,14). Therefore, it is suggested t'.at an extensive explanation by NRC be directed to SUREG-0591 which verifies
filtratien/icn hev EPICOR-II is so advanced past de present state of the art n
exchange to retain a decentaminaticn facter of ever 6000 for Cesitn-137 and de cperating data which substantiate this claim. The citatien cf.WG/CR-0141 in SUREG-0591 also substantiates varicus 34
..= addressed questicns in WREG-0591 regarding the use of fil:-ation as part of EPICOR II..NUREG/CR-01'. dpecifies that varicus paramete>- =.h as: weight-vol=e-particulate si:e distribution of the solids concentra:icn, chemical c:n-pa:ahility of the filter mediun with the slurry, oils present, and the actal radioactive centent of the suspended solids in the s1=ry shc=1d be well defined pricr to filter selection. Rese para:neters are not addressed in hUREG-0591 and therefore again designate that a more extensive analysis :f the water in de auxilliary building tanks.be ccnducted befgre a treat =en: system is designed, built or i;nplenented. As the deconta::tination technology of evaporation is defined as the techno1cgy which is incogerated when inte=ediate levels cf radioactivity are enccentered (13: the basis of incorporating EPICOR II (filtraticn + icn exchange) is c. clear. The basis of incogorating EPICCR II is also t= clear in ligh of the fact that a -z:er profile which is probably incomplete is being utili:ed and that a DF of 315,555 isrekuired. The alternative to EPICCR II
hich is specified in 1' REG-0591 is evaporation but this alternative is dismissed because of: a long lead ti e to make the system available and an unreliability which could be mitigated by special design provisiens. A justification of this dismissal in htPIG-0591 shc.dd be given by NRC in light of the fact that ht7.EG/CR-01:3 designates that principals associated wid DtI have sdmitted information c KRC delineating I
da: both TMI units ene and om presently have a waste-water emperator and ic exchange system operating in ccrplinentary roles (7, Table 23-#18, Table 34 418). Process Design of EPICOR Il The process desigti of EPICCR II as defined in 17EG-0591 censists of a prefilter, caricnic icn exchange bed, mixed bed icn exchange, a resi.n trap, and a.ssociated interconnecting piping, pt.- p and :an%2ge. In additien to the EPICCR !! system, a gas treatrent system is supplied whic.h ccnsists of moisn:re 35
5 \\ jepa ators, HEPA filters,' charecal adsorbers, fans, and radiaf.cn monitoring ' equi.r.e n t. This cxp1(.lesign was chosen as defiM in 2G-0591 to remcVe suspended solids concurrent with icn exchange, remove disselved nuclides by icn exchange and re=cve radioactive gasses which have evolved to the ventila-tien system frca the liquid stored in the auxillialy building tanks. /dhe E design of EPICCR II nor hUREG-0591 address the removal of isetcpes which are diss.cived gasses within the liquor stored in the auxilliary building tanks. Since icn exchange or filtration will not re=cve dissolved radioactive gasses free the liquor (7,14,16), the potential exists for the discharge of radio-active gasses via the treated liquor ahich is the focus of.WREG-0591. There-fore, it is appropriate for NRC to direct attentien to the quantity of radio-active gasses which are dissolved in the stored liquid and address a means to re. eve these dissolved gasses frcn solutien prior to discharge. Again, an ex-tensive characteri:ation of the liquid stored in the auxilliary building holding tank is required tc, verify the treatment technology which is required to prep-erly decontaminate the'liquer. Within the process design of EPICCR II, there exists a ' clean water re-cei.-ing tank' and an 'off-spec water receiving tank' which will hold treated water which is not within acceptable limits. 'Ihe ficw schematic of 'iPICCR II is delineated in Figure 1 of SUREG-0591 and desipates that all water which is effluent of EPICCR II enters the ' clean water receiving tank. ' Water which has not been decontaminated to specifications will be trsasfer ed to the 'cff-spe: water receiving tank' to be retreated by EPICCR II. Two potential design er ::s are designated in the Figure 1 schematic. The first potential design is t5at both the off-spec and clean water will enter the ' clean water re-err : cei.-ing tank' and the seccnd is that the off-Sec water will be directly sent back to EP!CCR II for repressessing. With all decent =inated streams entering the clean water receiving tank, the potential exists for the contamination of the acceptable quality water by 36
E \\ '.una9ceptable quality water (cross-centminatien) and additienal water decen-taminatica requirenend I respectfully sugg'est that NRC'. ' view this flew sde=atic to make modifications such that dis potential centaminatien problem is circ =/ented. Cr.e neans to circ :: vent this probable centasination problem is to utilite an additional tank as the ' clean water holding tank', utili:e the present ' clean water receiving tank' as a distribution tank, and retain de present 'off-spec water receiving tank' with the ss=e functicn. This will maxini:e the prcducticn of clean water because it ninini:es cross-contamination. The clean water would be transferred freci the distribution tr.k to the 'new' clea-. water holding tank enly if the quality of de decenM.ated water was wie.in specifications. The seccnd potential error in Figure 1 of htEG-0591 is de recycle of off-spec water fcr further decentaninatien by EPICCR II. He dccrent CFSL-4792 (14) specifically addresses de error associated with the rec /cle of partially decen-tani.ated water to a loaded or partially leaded icn excha:ge 1: tit. The cnly neans by which such a reefcle system can be used is to operate the reefcle loep only wid virgin resin. It is obvious that de logistics of a recycle operaticn caly en virgin resin is feasable, but such icgistics were net specified in ht?lG-0591. Hence, a potential error in such a recycle systen dces exist. Also, wi9in the proper reefcle logistics (use of virgin resin) the capacity of de eff-spec water receiving tank must be re-assessed to be sure dat all of the surge capacity is not used prior to resin change and that de off-spec suter is t eated enly when virgin resin is present. Additienal Cctrent Several ccr ents which were centained in ?GEG-0591 we:e nebulcus in nature i and. shculd be addressed prior to the i: plenentaticn of UICCR II. Cne of these s stements is, "the EPICCR II systen...has been desigt.ed...wid no adverse i gact en Se health and safety of the public." No decenstratien nor definitien 37
~ of the capability of EPICCR Il to.eet the regulations specified in CFR Title 10, Part 20, Appendix f( Ible2,hasbeenestablishedin e[MG-0591norhas any previous successful operating experience been denenstrated in hUREG-0591. Another such statenent is "EPICCR II is specifically designed to handle inte=ediate waste." The design of the EPICCR II system as defined' in R"AEG-0591 is no more advanced nor different thar designs which were disc.ased in 175G/CR-0143 (7), CRhl 4792 (14) or REG /CR-014 (16) and these data wculd not justify that a CF larger than 1000 ns reliably obtainable frce the EPICCR II system. A cuestien which shculd be answered by NRC is 'what inf ation justi-fies the fact that EPICCR II will cperate as to have no adverse irpact en the hea'.th and safety of the public which is exposed to unrestricted discharges? The limits of radioactivity in the decontaminated water, air exhaust, and release of precessed liquids frem DtI 2 through DfI 1 are centro 11ed by " pre-detemined limits (which) will be specified in the system operating. precedures and in the plant radiological effluent technical specifications." As these lirtits of radioactivity gcVern the entire operation of EPICCR II and the re-lease of effluent, they should have been addressed in RREG-0591 because of deir critica.1 nature. Hence, these predeterrdned levels shculd be defined and made public prior to design or inple=entation of any decentarti.atien tedr. ology because these levels are not gcVerned by the tec' nology. such as i EPICCR II but are gove=ed by CFR Title 10, Part 20, Appendix B, Table 2, the operating license. CPR-73, and 17EG-0432 (Appendix 3). The law defines the levels to which the water must be treated, the quality of the weer which re-I quires decentmination in light of legal ccmpliance defines the treatment tedr.olegy that is best suited for the jcb and all of this should be bcun befcre any procurement takes place. 2 In addition, the statement unpreven in EREG 0591 is, 'Therefore, we cenclude that processing of the auxilliary building contaminated water thrcugh EPICCR II will have no adverse i= pact," is used as a ccnclusion. Utis 33
of treated water 5" 2/ re-assess icg cs of off-spec water recycle sys.2 3/ furder elucidate nebu.icus statements, predetermined cperaticnal limits and substantiate cenclusicas 4/ investigate en-site evaporator capacity as defined in 172G/CR-0143 Tne conclusions of this cement regards.g E72G-0591 are: - not encugh data are specified concerning the quality of the auxilliary holding tank uter to dete=dne if EPICCR II will peric= properly - previcu.1 perfor >.nce of si.tilar syste.s desip.ates that EPICCR-II will not perfem within ce=pliance en the s:cred stress as defined in 172G-0591 - Evaporation is deemed the cost appropriate preven abatement technology as based upcn required decen" '.atien facters (CF's). G h l. .I 5 em 40
,1.. N N r Car.entary Affidavit. 3EFCRE ME, the undersigned authority, en this day persenally appeared. I.cuis J. Kosarek kncun by me to be a credible persen who having been upon his cath deposes and says: i i This affidavit was cccpiled in response to a public request by de United States.4: clear Regulatcry Camissicn for c:ments concerning hU.E-0591 entitled ""nviremental Assess ent, Use of EPICCR II at Tnree Mile Isla-d, Unit 2." Dds evaluatien of hD.EG-0591 was cenducted en behalf of the Susquehanna Valley Alliance. This dec=ent fccuses en the envircnnental L.,.ac. of EPICCR II with i respect to public.heald and safety, an assess ent of the tecnolcgy used in EPICCR II, and a review of the basis upcn './nich de cenclusiens of N! REG-0591 are established. Tne notivation behind this dec.nent is to constructively, prudently, objectively and scientifically review. Tis 1G-0591 and submit c=ents g ealth and safety of de activities n.i are proposed h which affir:s the publi to take place as defined in.WREG 0591. Furder depenent said not. ..Y . 'f$ ) p u M s J. 105.vsix SU3SCRIEED and SKM TO before me, de =dersign authr.arity, en this the _j'f day of Secte ber, 1979 by;Tu de rv 4. 6decido cer:if-which, wit.ess Ly hand and Seal of office. ^.. $ C C.-.ission expires: $l . t.c. l ~~~ k.'N]dh.t l te / Notary F lic El Paso Counu/, Texas l .H,;C t T H A W A A.~ 04 fictary Nblic ne m 3 *er El A u, 3 rity f *su thy CC m.?.51'On SI Dl C d D 1979 l 42 i i j
t. t, i s..n 4 5. The NRC completely ignores the serious psychological stress generated by the whole " clean-up" process and farther, attempts to deceive the public with unsubstan-t:sted performance and safety claims, which contributes to further : tress and lack of confidence in the NRC. t 4 Congress created the Nuclear Regulatory Commission to p ro t e c t the pe:lic health and safety when fissionable materials were made available to utility companies for com.mercial use. The Commission, if it endorses the work of the NRC staf f in this Assez ment, will f ail to uphold that sacred trust. This Assessr.ent fails; it fails legally; it fails technically; and most i portan:1y, it f ails to demonstrate to us, the people of the Susquehanna River Valley, that the NRC will apply the b=.: ef for:s possible to protect us in further action at inree Mile sland. . 5 9 m______.________________ .__}}

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