ML20247E407
| ML20247E407 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/17/1979 |
| From: | Eilperin S NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Quinn T U.S. COURT OF APPEALS, 3RD CIRCUIT |
| Shared Package | |
| ML20244B007 | List: |
| References | |
| FOIA-89-88 NUDOCS 8904030068 | |
| Download: ML20247E407 (36) | |
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WASHINGTON! D. C.- 2055$
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October 17, 1979 t (.
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,1X Thomas ' F. Quinn, Clerk.
United States. Court.of Appeals 1
~for the' Third Circuit 4
Room 21400 - U. S.. Cour thouse 601 Market Street s
Philadelphia, Pa. 19106~
'l Re:
.Susquenanna Valley Alliance,.et~ al. v.
Three Mile Island Nuclear Reactor, et al.,
U.S.C.A.,
3rd Cir.,
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Dear Mr. Quinn :
s v Judge Rosen has informed me that the Court has set argument on
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appellants' motion for injunction pending appeal for tomorrow, 1
October 18, at 9:30 a.m.
I am enclosing four copies of the Commission's Memorandum and Order regarding the use of Epicor-II to decontaminate the -intermediate level' waste water at Three Mile Island Unit 2, and the administrative record on which that Memorandum and Order'is based.
I am also enclosing four copies of our Opposition to the Motion for Injunction Pending Appeal.
I would appreciate your providing the panel with a copy of these t
papers prior: to tomorrow's argument.
Tnank you for -your prompt attention to this request.
j Sincerely, 1
i m
Step en F.
El perin Solicitor 3
Enclosures:
j 1.
Memorandum and Order (4) 2.
Opposition to Motion for Injunction Pending Appeal (4) cc:
Larry B. Selkowtiz, Esq.
Fox Trowbridge, Esq.
J 8904030068 890329 Y
PERLMANO9-88 PDR !
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'WITED STATES COUR OF APF 'LS
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FOR THE THIRD - CIRCUI'l'
,u SUSQUEHANNA VALLEY A'LLI ANCE, ET AL.,
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Appe ll an t s ',
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v.
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Docket No. 79-
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i THREE MILE ISLAND NUCLEAR REACTOR,
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Appellees.
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NUCLEAR REGULATORY COMMISSION'S OPPOSITION TO THE MOTION FOR INJUNCTION PENDING APPEAL i
The Susquehanna Valley Alliance (SVA) has moved this court to enjoin, pending further court action, the Nuclear Regulatory (NRC) f rom approving the processing of radioactively contaminated ' waste water through EPICOR-II, a filtration and ion exchange decontamination -
systec et the Three Mile Island Unit 2 nuclear facility (THI-2)-.
There are four requirements which SVA must meet in order to obtain.a
, preliminary injunction:
(1)
A reasonable likelihood of prevailing on the merits; (2)
Im:ninen t and irreparable harm to themselves unless the injunction is granted; J
(3)
Absence of substantial harm to other interested parties; and (4)
Absence of harm to the public interest.
E.g.,
Ga r shman v. Pennsylvania State University, 395 F.Supp. 912, 920 (M.D. Pa. 1975); Virginia Petroleum Jobbers Assoc. v. F. P. C., 259 F. 2d 1
9 21, 92 5 (D.C. Cir. 1958); Canal Authority of the State of Florida v.
Callaway (Cross-Florida Canal), 489 F.2d 567, 572-73 (C. A. 5,1975).
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We believe. ' *11s' cI car from' the factus' :and = legal: analysis.
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'in the1 Commission's Memorandum and Order of October 16, 1979, attached 1
to this filing, which authorized operation.of EPICOR-II, that. SVA cannot meet any,of these tests. /
Accordingly, we respectfully urge the court to deny the motion for a preliminary injunction.
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.Particular points in the Commission's Memorandum and Order m
which we would stress in response to SVA's motien are these:
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Af ter consultation between the thclear Regulatory l
Commission and the Council on Environme'ntal Quality, the-Council i
agreed that processing by EPICOR-II should begin pronptly without delay for preparation of a formal environmental impact statement.
.See note 4 of the Memorandum and Order.
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Operation of EPICOR-II will involve no discharge of water, contaminated or otherwise, into the Susquehanna River.
3.
Operation of EPICOR-II is expected to immobilize at j
i' least 99% of the radioactive contaminants wSich are presently dis-persed in intermediate-level water requiring large volumes of rapidly j.
dwindling storage space.
4 Alternatives to operation of EPICOR-II all involve the spread of radioactive contamination and potential risk to health and safety.
5.
Operation of EPICOR-II should result in an immediate I
reduction in occupational radiation exposure to workers performing essential safety-related tasks at TMI-2.
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A copy of the Memorandum and Order is also included in the administrative record filed separately by NRC today.
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Inir ting..the operation of EPI l-II'would involve no p
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irreversible commitment except for the con tamina tion of a Lsingle. se t.',.
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of. resins and filters, for which there are ample shielded storage
. facilities at THI-2.
I For the above reasons, the motion for injunction pending-appeal should be denied.
Respectfully submitted, 9
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p STEPHEN F. EILPERIN Solicito E. LEO SLAGGIE Attorney 1
U.S.
Nuclear Regulatory Commission Washington, DC 20555 October.17, 1979 j
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______m__.___._m.
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j Ng CERTIFICATE.0F SERVICE r
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<I-hereby certify that I have served -the foregoing
" Nuclear ' Regulatory. Commission 's Opposition to the Motion' for t
'Injunctioh Pending Appeal" 'and administrative record by hand-
. delivery to:
i Larry Selkowitz, Esq.
c/o Albert Slap, Esq.
1315 Walnut Street Suite 1600 Philadelphia, PA Tox Trowbridge, Esq'.
Shaw, Pittman, Potts & Trowbridge i
1800 M St r e'e t, NW.
Washington, DC.
20036 i
STEFliEN F. EILPERIN
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Solicitor U.S. Nuclear Regulatory a.
Conci s sion Washington, DC 20555 October 17,- 1979 v.
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..lTED STATES'0F AMERICA NUCLEAR REGULATORY COMMISSION
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COMMISSIONERS:
idoseph M. Hendrie, Chairinan Victor Gilinsky.
-i Richard T. Kannedy Peter A. Bradford j
John F. Arearne 1
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In.the l'atter of METROPOLITAN EDISON COMPANY,,g al.
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Docket No. 50-320
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(Three Mile Island Nuclear Station,
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Unit 2)-
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MD40RANDUM AND ORDER i
Because of the March 28, 1979 accident at the Three 11ile Island Unit 2 i
nuclear power plant-(TMI-2), substantial amounts of radioactively contaminated
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waste eter have been collected in tanks at the facility.
As the initial step ir, a program to deal with this accumulation, th( Commission's technical staff has recomended that Metropolitan Edisor Company, the licensee for Three Mile Island, j
be permitted to operate an' EPICOR-Il filtration and ion exchange decontamination i
system to decontaminate intermediate-level radioactive este water now held in tanks in the TK]-2 auxiliary and fuel han'dling building.
This recommendation is accompanied by the staff's environmental assessment of the impact of using EPICOR-11 and an analysis of ccoments on the assessment by the public.
The staff has concluded, based on this assessment and analysis, that the proposed use of EPICOR-11 will not significantly affect the environment and therefore that no environ-mental impact statement need be prepared prior to authorizing the licensee to operate EPICOR-II.
The Commission is now called upon to decide whether the i
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l requirements of. the National Environmental Pol. icy. Act (NEPA) have been met..with 1
regard to the proposed use of EPICOR-Il and, if: so, whether the -licensee should j
be. directed -to operate the system.1/
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B AC XGROUND l
There are three major volumes of radioactively contaminated waste water' i
i accumulated at Three Mile Island Unit 2. (TH1-2) as a result of the accident in l
Ma rch 28,1979. These include approximately 630,000 gallons contained in the i
lowr levels of the reactor-containment ~ building, 85,000 gallons in the~ reactor I
coolant system in use to remove decay heat.from the reactor core, and about-i 387,000 gallons. stored in tanks in the auxiliary building.
The waste water stored in the auxiliary building has a total radioactivity. concentration less.
l than 40 microcuries/ milliliter and is referred to as intermediate-level waste l
The radioactivity concentrations of wasti water ir, the reactor building l
wa er, and in the primary coolant systems have been measured at greater than 100 pCi/ml
.for some isotopes'.
This waste water is ' referred to as high-level was te water.
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Principally because of leakage from the primary reactor coolant system,.the l
volume of water in the reactor containment building is increasing'in volume by I
about 430 gallons per day, equivalent to' a level increase of about 2 inches per month.
The present height is about 7-1/2 feet above the basement floor in the l
containment build ng.
Since no paths of Irakage to the outside have been iden-tified, decontamination of this water is not at present an urgent problem.
The l
situation is different with respect to the intermediate-level waste water now 1/
This decision does not address the subject of disposal of the decontam-inated water.
Pursuant to the Commission's Statement of May 25, 1979, i
discharge of THI waste water is not permitted, with certain exceptions set out in the Statement, pending completion of an environmental sssessment dealing with'such discharges.
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1 stored in the auxiliary building.
The inventory of this water is increasing at' '
the rate of.about 800-1000 gallons per day U Remaining capacity in the aux'il-iary building tanks as;of the end of September 1979 was' about 29,~000 gallons; Thus there is 'a pressing need to ' deal.with the intermediate level waste water.
In addition to the problem of inadequate storage capacity, the retention of l
contaminated water 'in the auxiliary building contributes to the occupational.
exposure of workers at the THI site.
The continued saf e shutdown of Dil-2 'de-l pends upon the use of equipment located in the, auxiliary builping.
Approximately 50 workers per day are currently ' admitted to the auxiliary building to perform necessary decontamination, operations, and consthoction activities. Occupational exposure to these verkers as a group, primarily as a result of radiation from the stored water, everages about 15 man-rem per month.
The licensee has developed a procedure to decontaminate the intermediate-level waste water using the EPICOR-Il filtration and ion exchange system con-structed at Thl-2 following the Ma rch 28, 1979 accident.
Decontamination would
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be an effective response to the problems identified abcve, since the processed
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water would not be a source of significant occupational exposure and could be readily stored in unshielded tanks outside the auxiliary building.
Successful operWon of EPICOR-Il will serve to transfer the significant radioactive con-ta;,inants from a mobile forTn (suspension in water) to a fixed fom (held in filter and ion exchange resin r,aterials).
I In : Statement dated May 25, 1979 the Commission directed its technical staff, pursuant to NEPA, to prepare an environmental assessment of the use of U
The dominant source of this increase is leakage from the component evap-orative cooling system, the demineralized water system, and the reactor building cooling system, and from recirculation of water in the tanks prior to sampling. Most of this leakage is non-contaminated water which becomes contaminated while passing through avriliary building floor drains and sumps provided to collect the leakage.
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.EPICOR-II.
Pursuant to' this Statement, the licensee was not pemiitted to operate 1
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'EPICOR-ll pending completion of the assessment and opportunity for public com-
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l' ment, except for testing with uncontaminated water.
The staff's assessment, "Use of EPICOR-Il at Three Mile Island, Unit 2," NUREG-0591, was issued for public coccent on August 20, 1979.
See 44 Fed. Reo. 48829.
The assessment concluded that the proposed use of EPICOR-Il would not significantly affect the quality of f
j the environment and that accordingly NEPA does not require, preparation of an.
impact statement prior to permitting EPICOR-II to operate.
Some 40 comments were received.
In written analyses of the comments and a and October 10, 1979, oral discussion at open Commission meetings on October the staf f responded to these comments and reaffirmed its conclusion that the
' I environmental effects of operating EPICOR-Il as proposed wuld be insignificant, See revised NUREG-0591, dated October 3,1979.
Tne public comments, the docu-ments submitted to the Commission by' the staff, and transcripts of the October 4 and October 10, 1979 meetings are included in the administrative record and for-the basis for the Commission's decision on tr.is matter.
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lHFACT OF EPICOR-ll Based on Comission review of the facts and analysis in the staff's environ-mental assessment and written and oral discussion of the comments, the Commission has determined that the proposed operation of EPICOR-Il will not tave a signi-ficant effect on the environment.
Pursuant to 10 CFR 51.7 and Si.50(d) the staff 4
is directed to issue a negative declaration stating that an environmental impact statement for the proposed action will not be prepared.
E With respect to the transcripts of the October 4 and October 10, 1979 l
meetings, the Commission has waived its usual rule that statements at an open meeting are not part of the record of decision of the matters dis-l cussed therein.
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In reaching this conclusion the Commission has taken note of comments which
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a rgue that the. Commission has violated NEPA by. considering 'the impact of EPICOR-II-separately and' apart from the overall impact of a-complete program for decon-q tamination of THI-2.
The Commission does not believe this " illegal segmentation" a rgument is well-founded in trils case.
In meeting NEPA requirements'an agency
- v may focus on the impact of a single action, even when it is arguably a segment of a larger program, when the action in question has independent utility. See e.o_.,
lookout Alliance v. Volpe, 484 F. 2d 11 (8th Cir.1973); Friends of the Earth v, j
Coleman, 513 F.2d 295 (9th Cir. 1975).
The Commission finds that use of EPICOR-l 11 meets this test.II The independent utility of EPICOR-Il is emphasized by the fact that decon-tamination of the intermediate-level water appears by a considerable margin to be the best available response to the impending accumulation of intermediate-level waste water in excess of adeovately shielded storage capacity.
The al ternative ~
1 to decontamination would be to find addiiional storage facilities, but problems 1
with this alternative are severe.
Construction of new tanks Mth the necessary l
shielding would require several nonths, at least, and could not be accomplished l
Al in.this regard, by letter of October 10, 1979, the Council on Environ-mental Quality asked to meet with the Cornission to discuss its concerns about prospective radioactive cleanup operations'at the Three Mile lsland Unit 2 reactor.
Our respective General Counsels and members of their staffs met on October il to discuss these matters, in an exchange of letters with the Commission dated October 15 and October 16 and based on 1
the assurances made in the NRC letter, the Council found that the prompt decontamination of the intermediate-level waste water through the EPICOR-11 system is an operation necessary to control the imediate impacts of an emergency situation (40 CFR 51506.11).
In so doing, however, the Council did not reach those questions concerning the legality of the l
Commission's actions thus far under NEPA.
These letters are part of the j
administrative record on which the Cocmission has reached its decision.
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6 before.the auxiliary building tankage. capacity is exceeded. Other than decon-
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tamination, there are at present only two. timely alternatives available to pro-f l
ide suitably shielded storage space for the intermediate-level waste water,'once v
the auxiliary building. tanks are filled.
One alternative sculd be to transfer
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the wa ter.to tanks at Unit.1.
This action sculd significantly raise the con-tanination, level of piping and tankage in Unit i and extend the scope of the j
. problem of occupational exposure.
The other, even less desirable, alternative would be to transfer the intermediate-level water to the TM!-2 reactor building, mixing it with the higher-radiation-level water presently in the containment, raising the height of that water and in effect increasing by almost 50" the
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amount of water which must subsequently be decontaminated by systems yet to be l
developed to handle high-level waste water.
Both of these alternatives in effect would enlarge rather than reduce the spread of radioactive contamination and woule involve potentially significant safety cuestions and environmental impacts.
Tne Commission has thus concluded that prompt decontamination of the intermediate-level water by EPICOR-11 is the best response to the situation.
The t
use-of this system will immobilize most of the radioactivity presently dispersed in the intermediate-level water, which requires large storage volumes and in-volves at least some possibility of leakage, by transferring this radioactivity to the compact, more easily stored EPICOR-Il resins, thereby reducing the poten-tial hazard to workers and the public of an excessive accumulation of intermediate-j
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level waste water.
Decontaminated water shich has been cycled through EPICOR-11 can be readily stored in conventional, unshielded tanks while disposal options are considered without any pressing time constraint. These benefits of EPICOR-II operation, together with the reduction of occupational exposure to wrkers in the r
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auxiliary building, establish the independent utility of the system,EI thereby cor. firming that pursuant to NEPA environmental aspects of EPICOR-II may be evaluated separately from an*overall programmatic analysis of cleanup at ml-2.5/
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Another objection to the scope of the environmental assessment made in some of the comments is that the environmental assessment did not consider psycho-logical impacts.
Without deciding whether l' EPA requires the consideration of such impacts, the Commission notes that use of EPICOR-II would provide no objec-tive reason for concern and there is no indication in the ccrraents received that l
the prospect of EP]COR-11 operation, as distinct from release of water, has in fact occasioned public alarm or fear.
Several of the comenters did indicate i
great concern with regard to possible discharge of processed wste ster into the Suscrehanna, but such disposal activities are separate from EPICOR-Il operation and lie outside the scope of the assessment.
The Commission stresse., again that
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decontamination by EPICOR-11 will not of itself result in any waste water dis-cha ges, and the question whether discharges shoulc later be approved is in no way prejudged by permitting use of EPJCOR-!!.
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Another criterion for permitting segmentation is that the proposed action will not foreclose subsequent alternatives.
Decontamination of the wa ter in the auxiliary building will not foreclose any alternatives with reoard to subsecpent processing or disposal options.
Ra ther, such decontamina-tion may reasonably be viewed as a prerequisite to a variety of alter-native actions sich may subsequently prove necessary and desirable in cleaning up TMI-2.
5I Whether a progrannatic impact statement for the overall cleanup of THI-2 may eventually be required is an issue the Commission need not address at q
the moment.
It seem, clear that no such statement is required at present because 1111-2 cleanup is a project in contemplation and is not yet a formal agency proposal.
The Supreme Court has stated that an agency need not have a final impact statement ready until "the time at Mich it makes a recom-mendation or report on a proposal for federal action." _Kleppe v. Sierra Club, 427 U.S. 390, 406 (1976) (emphasis in the original).
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8 With regard to the many technical issues concerning EPICOR-l! that wre raised by the substantive comments, the Connission, as previously acted, has found the staff's responses adequate.
Many of the doubts about EPICOR-Il ex.
pressed by commenters were not relevant t'o the question at issue in the environ-mental assessment, which is whether operating EPICOR-11 will have a significant environmental impact.
Some comments, for example, questioned whether EPICOR-Il will in fact achieve the decontamination levels expected by the staff.
In the Concission's judgment, we expect that EPICOR-Il will be able to remove at least 99% of the radioactive contamination from the intermediate-level waste water the j
sys tem will process.
But that aside, the dettils of the system's performance do not bear on the conclusion that EPICOR-ll does not require an environmental impact statement to justify its use.
For NEPA purposes, once it is determined l
tnat the proposed action will have no significant imoact, no iepact statement is required.
As notec, the Conmission believes the staff's performance expatiations for EPICOR-Il are reasonable, but even if these expectations are not met, addi-tienal decontamination by recycline through EPIC 07.-Il or, if necessary, by other 7/
- nethods would in no way be foreclosed.-
One aspect of the proposed EPICOR-11 operation requires further attention he re.
It is the Conmission's view that s' solidification of the EPICOR-11 radio-active waste products (filter and ion-exchance resin materials) prior to offsite M
An alternative decontamination technology frequently mentioned in the comments is the evaporation nethod.
Because an evaporation system is not presently available for use at TM1-2, this technology is not a realistic alternative in the present situation, in view of the need for prompt action.
The Conmission notes that the evaporator method has significant drawbacks, notably the fact that the highly radioactive sludge remaining after evaporation is in liquid fonn and may well be more difficult to i
dispose of than the resins and filters of the EPICOR-Il system.
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4 shipment will contribute to improved safety daring transportation and to the ease of final disposal, Accordingly, the Commission concludes that the licensee '
should be directed to construct expeditiously the necessary facilities for solidification and to store EPICOR-Il wastes;at l}il-2 until the resins have been-properly solidified.E There should be no shipment of non-solidified wastes offsite unless necessary to allow waste water decontamination to continue or unless otherwise required' to protect public health and safety.
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A staf f menorandum to the Commission, dated October 12, 1979 included in the record of this proceeding, indicates that unavoidable occupational exposure associated with the solidification process can be kept to accept-a ble levels. Although no specific facility designs have been developed f or the solidification operation at T141-2, the staff reviewed three topical reports on systems of this type which show that routine main-tenance and operation activities are expected to result in an occupa-tional dose of less than 10 man-rem per year.
Solidification of resins f rom EPICOR-II, which has not been specifically designed to accommodate solidification, will likely involve design features not previously analyzed by the staff.
Further, resins from EPICOR-Il will be more radioactive than the average from an operating plant.
However, the staf f M
judgment was that solidification of EPICOR-11 resins developed from decontamination of the auxiliary building water would result in occupa-tional exposure levels similar to those of systems previously reviewed if no unusual problems were encountered, and that a best estimate upperbound i
for the operation would be 25 man-rem.
l 10 AT3'11C ENERGY ACT RE0VIREMENTS j;
i t-L We now mov'e to the cuestion whether the Atomic Energy Act authorizes the-Cocnission to direct prompt operation of EPICOR-II.A/ For the reasons stated l
below, we conclude :that it does.
l Our earlier discussion about the accumulation of contaminated water at tlc Unit 2 indicates that public health and safety requires that some action be I
taken to deal with the intermediate-level waste water, and that the timely alter-natives to EP]COR-II operation all present health and safety problems.
Al though no action sich involves the handling of radioactive materials can be found l
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One of the ccomenters has argued that construction of E?1COR-Il without a construction permit violated the Atomic Energy Act.
We do not think that construction of EPICOR-11, a minor commit:nent of resources in a $1 billion f acility and unrelated to operation of the reactor itself, is a material alteration of a utili2ation facility within the meaning of our regula-tions and therefore requiring a construction permit.
- See, Portland General Electric Co. (Trojan Nuclear Plant), LBP-77-70, 6 NRC 1179, 1183 (1977).
Beyond this, the NRC staff has monitored the design and construction of EPICOR-ll from the beginning, so that there are no serious questions about whether the facility is flawed in some manner that might have been detected if a formal permit proceeding had been held.
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1 11 inr.erently free of all risk, the evaluation of EPICOR-Il indicates that no sig-j nificant health and safety (or environmental) impact will likely result from the
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prcposed operation.
We are thus confronted vith a situation dere some action must be taken to reduce health and safety risks, and an appropriate action to reduce those risks has been identified that itself entails no significant health j
a nd safety haza rds.
Under sections 161b. and i. of the Atomic Energy Act the Corr.ission is empowered to issue such orders affecting activities of licensees as it deems necessary or desirable to protect heal th and to minimize danger to life or property.
Further, every facility license, including the operating license for TH1-2, is expressly subject to further Cornission orders.
10 CFR $ 50.54(h).
An crder to the licensee here to promptly begin the process of decontaminating the int: mediate-level waste water by operating EPICOR !! would be entirely consistent with the purpose of the Act and regulations.
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Some of the public commenters have argued in litigation that the Concission h
cannot take such action without first holding an adjudicatory hearing under Sec-k \\ tice 189a. of the Atomic Energy Act to amend the El U it 2 operating license.
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We find section 189a. inapplicable to the type of order contemplated here.
Section 189a. is quite careful in specifying the types of proceedings to which it applies, even going so far as to cite to. specific sections of the Act.
A pro-ceeding for a Comission order under sections 161b. and i. is not one of the proceedings listed in section 189a.
Thus, the plain language of the statute supports the Commission's exercise of authority here. Of course it is possible to argue heie that the order alters the licensee's obligation to the Comission, as such har the effect of amending the license, and consequently that a Section
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189a. proceeding for such an amendment should be held.
We think, however, that the entire thrust of the Atomic Energy Act indicates tha t Congress intended the Commission to be able to act with dispatch een in its judgment the public health '
I and safety calls for pronpt action.
Even if for purposes of argument it is assumed that the order constitutes a form of license amendment, the result would i
be,a conflict between the authorization to issue irmediate orders necessary to protect health and safety in sections 161b. and i. and the hearing requirement in section 189a. We have no difficulty resolving that conflict in favor of pro-tection _of the public health and safety especially where, as here, there has already been a fair opportunity fer public participation in the form of written concents.
While w conclude that an order for operation of EPICOR-Il is not subject to section 189a. of the Act, the licensee itself has due process hearing rights I
i under the Constitution cuite apart from section 189a.
Tne law is clear that, given the public health and safety need for prompt EPICOR-Il operation, any due O
process hearing rights can be satisfied by an offer of a prompt hea....g af ter the
. order for EPICOR-Il operation becomes effective.
E.o., Ewino v. Mytincer &
Ca s sel berry, 339 U.S. 594 (1950); Ecwles v. Willinebaun, 321 U.S. 503 (19a4).
And, given that the licensee is free to re' quest a hearing for purposes of challenging the order, we believe that sound administrative policy in these circumstances dictates that other interested persons be given a similar right.
Accordingly, we provide below that the licensee and any other person whose interest may be affected may request a hearing with a view toward lif ting or modifying the order, but that the order shall remain effective pending decision in any hearing that may be requested.
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' One final matter warrants our attention.
Operation of EPICOR-Il will add several ef fluent discharge paths to those presently listed in the THI-2 operating license. As discussed in the staff's environmental evaluation, radionuclides discharges through these additional paths will have no significant impact on, the environment.
Further, the Commission's regulations in 10 CFR Part 50, Appendix A, Criterion (GDC 64), require that the new discharoe paths be monitored.
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been the staff's practice in developing operating license technical specifica-tions to include in the specifications a listing of discharge paths that require nonitoring under GDC 64 It is not necessary to amend the technical specifications to assure that monitoring will be conducted, given the cicar requirement of GDC 64 and the provision of 10 CFR i 50.54(h) that all facility licenses are conditioned on compliance with all applicable Ccamission regulations.
Nevertheless, we believe that the Commission's inspection and enforcement program will be simplified if the requirements for discharge path monitoring are spelled out in a single legal cocument -- the operating license -- tha t can be reedily referenced by the licensee and Conmission inspectors.
For the same reason there is merit in in-clucing in the operating license the cbligation to operate EPICOR-Il and the ccr.ditions associated with solidification and shipment of the spent resins.
Accordingly, we are proposing to amend the TMI-2 operating license to include these provisions.
In light of our disposition in this regard, and the reasons already discussed as to our authority under Section 161 of the Atomic Energy Act, we need not and do not reach the question whether such a license amendment is required here.
Under section 189a. of the Act, the licensee and other interested. persons may request a hearing on this proposed amendment.
Given the similarity of
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issues, hearings requested on this proposed amendment and on the order for EPICOR-Il ~ operation will be consolidated.
ORDER for the reasons stated above, the Commitsion orders as follows:
1.
~ The licensee shall promptly begin the process of decontaminating the.
j intermediate-level waste water from THI-2 by operating EPICOR-il.
Prior to operation, the licensee shall' consult the Director.of NRR for approval of the final operating procedures and design and construction details.
In order to reduce the inherent risk from the contaminated witer most expeditiously ~ and pr.dently, the licensee should to the extent possible process all the water once threugh the EPICOR-1) system.
2.
The licensee shall maintain suitable tankage at El-1 that could be used to store waste water from El-2 at an appropriate state of readiness. should additional storage capacity becone necessary.
3.
The licensee shall not ship spent resins of fsite unless they h3ve been l
solidified, and only-then with the prior approval of the Director of NRR, pro-l viced however, that the licensee may ship non-solidified but dewatered spent resins offsite if it deterTnines, and the Director of NRR concurs, that such ship-mer.. is required to assure contSued operation of EPICOR-Il or otherwise required to protect public health and sifety.
The licensee shall expeditiously construct a' facility for solidification of the spent resins anc shall use such facilities f or resin solidification upon receiving the Director of HRR's concurrence with the d'esign and operating procedures.
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4.
This Order, except as provided by the Commission's Statement of May 25, 1979, does not authorize discharge into the environment 'of any of the processed or unprocessed waste water, or processing of any waste water other than the intermedia te-level wa ste wa ter, in carrying out the actions directed by para-graphs 1, 2, and 3 of this Order the licensee shall be subject to all applicable Commission regula tions.
5.
The Director of NRR has been instructed pronptly to prepare and issue an order for the modification of the TM1-2 operating license to (a) add EPICOR-11 discharge paths to those presently listed in the technical specifications as requiring monitoring under GDC 64, and (b) include the provisions of paragraphs 1, 2, and 3 of this Order.
The order shall state that within 20 days o the 'date of this Order the licensee and any other person @ose interest may be affected may request a hearing on the proposed amendrent pursuant to Ib CFR ! 2.714 to be held prior to the amendment of the license, i.e., not prior to operation of Ep]COR-!! but rather prior to the adoption of the forcal amendment.
6.
Within 20 days f rom today, the licensee may file an answer to para-graphs 1, 2, and 3 of this Order, and the licensee and any other person ihose I
interest.may be affected may reouest a hearing pursuant to 10 CFR i 2.714 for the purpcse of challenging all or any part of paragraphs I, 2, and 3 of this Order.
In any hearing that may be requested, the issues will be those within the scope of eether (a) paragraphs 1, 2, and 3 of this Order are necessary and sufficient to protect health and safety or to minimize danger to life er property, and (b) actions directed under paragraphs 1, 2, and 3 would significantly affect the quality of the human environment.
Any hearing that may be requested shall be consolidated with any hearing that may be requested p;rsuant to the order to be published under paragraph 5.
The Commission finds that the public health, o
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' safety', and interest require that this Order become effective immediately and i
shall remain effective notwithstanding the filing of any requests! for a hearing.
7.
An Atomic Safety and Licensing Board, consisting ofliarshall Miller, 1
Chairman,'and Dr. Richard F. Cole and Dr. Martin J. Steindler, isL her:by appointed to. rule on' any reouests for'a hearing under paragraph 6, or any requests for a L
h hearing tha t may be filed in response. to the' order to be published under para-graph 5, and; to preside over any hearing that may be-held:vpon those requests.
~
In conducting any.such hearing the Board shall bear in mind that the process of l
ope ra ting EPICOR-11 to decontamina te-the intermec ia te-level wa ste wa ter may ta ke y
as little as tso months.
Accordingly, the hear?ng shail be conducted as expedi-tiously as possible, and the Board.is authori ed to immediately stay the effec-tiveness of all or part'of paragraphs 1, 2, and 3 of this Order should it deter-l mine,:ba sed upon affidavits or such other ' sum,ary stay procec;;res it cee ts appre.
priate, that this is rekvirec in order; to protect public heaith anc safety.
It ~ is so ORDERED..-
For the Commission
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SA."UE L J. { Ch X Secretary of ine Cocaission i
Da ted at Wa shington, DC, this[
day of October,1979.
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h IN THE UNITED STATES DISTRICT COURT
.I FOR THE
.r MIDDLE DISTRICT OF PENNSYLVANIA
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9-SUSQUERANNA VALLEY ALLIANCE,'
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y Plaintiffs,
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Civil Action No.79-658 l-
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' ERIE MILE ISLAND NUCLEAR
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'l De fendants.
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DEFENDANT NUCLEAR REGULATORY COMMISSION'S ANSWERS t
TO PLAINTIFFS' INTERROGATORIES SET fI i
I 1.
INTERROGATORY: Please state the amount of curies released in 1978 from Three Mile Island Reactors One and Two. Pleasa'11st separately for each unit.
(N 1.
RESPONSE: The information requested can be found in the following two semi-annual effluent release reports which the licensee is required to submit to the.NRC pursuant to 10 CFR Part 50.36a(2) I}
These reports contain complete data on the amount of activity, in curies, released in
(
1978 from Ihree Mile Island, Units I and 2.
References which trans-mitted these reports follows CQL I463, August 30, 1978, J. G. Herbein (Met Ed) to B. B. Grier (USNRC), Radioactive Effluent Release Reports for TMI-I and TMI-2 (Januery 1, 1978 to June 30 1978); and i
GQL 0269, March 2,1979. J. C. Herbein to B. H. Crier, Radf o-l s.ctive Effluent, Release Reports for TMI-l and TMI-2 (July 1, l
1978 to December 31, 1978).
These reports are provided as Attachments I and 2.
2.
INTERR00\\ TORY: Please statt the percentages of those releases as 1
between air and water emissions.
2.
RESPON3_E: The reports listed in the response to fi provide detail on 1
how much of the release is in air emissions and how much is in wat r
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emissions.
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3.
INTERROGATOR'f t Please state the quality of the air and wasta effluents
'y in 1978, broken down by the type of isotopes released.
L 3.
RESPON$Et. The reports listed in thd response.to fI provide detail on thespeAlfictypeofisotopesreleased.
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4.
INTERROGATORY: Please state the total amount of tritium released in liquid eff1 vents in 1978.
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4.
RESPONSE: The reports listed in the response to il list ti.e' total amount of tritium released in liquid effluents in.1978.
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5.
INTERROGATORY: Please state the total amount of noble gases dissolved in liquid offluents in 1978.
.i 5.
RESPONSE: The reports listed in the response to il list the total amount of noble gases dissolved in liquid effluents in 1978.
,1 6.
INTERROGATORY _ Please state the concentration of each isotope measured in the effluent in air and water from TMI One and Two in 1978. Please state separately for each unit.
6.
RESPONSE The reports listed in the response to il provide information concerning the totsi release and the average release rate of air efflu-ents from TMI Units I and 2.
This.is the form that NRC Regulatory Guide 1.21(2) requires this information and it is the form that is most '
useful in estimating offsite exposures. The reports listed in the res-ponse to fl list the total release,and the average diluted concentrations in water effluents from TMI Units I and 2 as required by NRC Regulatory Guide 1.21.
7.
INTERROGATORY: Please state the ansvers to Questions One through six above for 1979, by month.
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7.
RESPONSE The data requested for questions one (1) through six (6) were compiled in accordance with Regulatory Guide 1.21 on a quarterly basis. Since the March 28, 1979 accident, these data have been com-piled on a more frequent basis. Table I provides the data for the period March 28, 1979 to March 31 1979, and Table 2 provides these data for the months of April and May. For the period January 1, 1979 through March 31, 1979, these data were compiled on a quarterly basis and are provided in Table 3.
Tables 4 and 5 provide an isotopic 1
summary of liquid releases.
Following the March 28, 1979 accident, both airborne and liquid releases were reported to the NRC as mixed releases from Units 1 and 2.
In accordance with Section 50.36a of 10 CFR Part 50, the licensee is required to report these data to the Cour2hsion. Therefore, for the period January through June 1979, these data should be available i
approximately September I, 1971 8.
INTERROGATORY: Please state the total number of curies, to date, ex-cluding tritium and dissolved gases, released into the Susquehanna River as a result of f ie accident at Thres Mile Island on March 28, 1979.
8.
7'SPONSEt A cumulative total of 0.42 CL (as of May 31, 1979) of radioactive material, excluding tritium and dissolved gases, has been released to the Susquehanna River since the March 28, 1979 acci-dent.
9.
INTEPROCATORY: Please state what you consider to be the absolute IimIts in terms of total number of curies that can be emitted. from i
Three Mile Island Reactors One and Two in the ambient air.
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9 RISPONSEt The limitation on releases to amblent air from Three Mile Islaad Units I and 2 are given in Section 2.1 of the TMI-2 enviroe-mental technical specifications (Appendix B)(3)
Limitations.for gaseous effluents are based on the release rate from the plant and
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RESPONSE
(Continued) are excerpted from the techniest specifications in Attachment 3.
The release rate limitation for each specific radionuclides is dependent 4
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l upon the maximum permissible concentration (N*C) for each radionuclides.
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- 10. INTERROGATORY: Please state what you believe to be the absolute number l
of curies, excluding tritium and dissolved gases, that can be discharged q
into the Susquehanna RLyer and the source on which you rely for this l
response.
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- 10. RESPONSE: The TMI-2 environmental technical specifications (Appendix B) limit radioactivity released in liquid effluents to less than 10 curies per reactor per calendar qusrter for all radionuclides excluding tritium and dissolved gases.
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- 11. INTERROGATORY: Please state the answer to the last question in terms Fa total monthly quantity,' total quarterly quantity, and and total annual quantity.
- 11. RESPONSE: The response to Interrogatory 10 gives the limitations on the release of liquid ef fluents, excluding tritium and dissolved noble gases, on ; quarterly basis as provide 1 in the TMI-2 environmental technical specifications (Appendix B).
The TMI-2 environmental techni-cal specificatioco do not provide limitations on monthly or anc'jal quantities.
- 12. INTERROGATORY: Please state, if at.y. limits that you consider to be applicable to the TMI Rasetors One and Two for tritium and dissolved gaseous being discharged into the Susquehanna or into the ambient air and the source on which you rely.
- 12. RESPONSE: As discussed in the TMI-2 environmental technical specifi-
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i 11mhed fu 10 C.u du
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-7 Appendix B Table 2, to 3 x 10 uCi/cc in liquids and 2 x 10 uC1/cc in gases. Caseous releases of xenons are also limited by the same regulation to 3 x 10 uCi/cc for Xe-133 and I x 10~7 uci/cc for Xe-135.
-7 Liquid xenon releases are limited, as established in the THI-2 environ-
-3 l
mental technical specifications (Appenday B), to 5 x 10 uCi/cc for Xe-133 and i x 10~ uCi/cc for Xe-135.
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l Please state the total liquid storage capacity for l d Reactor radioactive water currently available on the Three Mile INTERROGATORY 13.
similarly for capacity still available for storage.
site.
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Based on data reported by the licensee on daily tank levels,
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- 13. _RESPONSEJ ity for.
the following table summarises the total liquid storage capacJuly 20, radioactive water currently available at TMI Units 1 and 2 as of o
a 1979.
TOTAL l
TOTAL TOTAL CAPACITY CAPACITY USED REMAINING CAPACITY (gallons).
(gallons) _
(gallons)
TAHK j
LOCATIO__N 257.115 Unit 1 Aux. Bldg.
334,700 77,585 317, 191
' 292,055 25,136 Unit 2 Aux. Bldg.
110,000 I
T'*it 2 tuel dandling 110,000 0
Bldg. Storage Tanks l
I 229,000 v'
Chemical Cleaning Bldg. 229,000 0
Tank (EPICOR-II)
It should be noted that not all of the remaining capacity listed in i
for the water table above is available for providing additional capac ty First of all, it is currently stored in the Unit 2 auxiliary building.
I auxiliary not desirable to use the retraining capacity in the Unit building tanks for the storage of Unit 2 water since it is advantageo Unit 1 Surge to keep the contaminated water from Unit 2 separate from capacity in Unit I will only be used to handle Unit 2 wastes in i'
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situations.
h In addition, it is not desirable to use the remaining capacity in t e Unit 2 fuel handling building (ntB) storage tanks for the storag These tanks were construct-the water in the Unit 2 auxiliary building.
iding ed in the Unit 2 FEB af ter the accident for the purpose of prov i
te water additional storaga capability for the high level radioact ve was h
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currently in the Unit 2 reactor building. ' Any other use of t e.
However, due to the Unit 2 FEB would compromise their original purpose.
etable water levels in the reactor building cump, surge the current f
capacity in the FHB tank.s can be used to handle water in i
auxiliary building tanks in emergency situations.
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- 13. RESPONSE:. (Continued)
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Also the tanks in_the chemical cleaning building (CCB) are currently part of the EPICOR-II system which was designed by the licensee to treat the water in the Und 2 auxiliary building. Any use of the tanks in the CCB to store radioactive water would compromise its intended purposes as part of EPICOR-II.
Therefore,' these tanks would preferably only be used 'o' store waste in an emergency situation.
t Thus, at the present time, there is only the surge capacity listed in the Unit 2 auxiliary building (25,136 gallons) which is available to hold the water in the Unit 2 anillary building.
.s 14. INTERROGATORY:
Please state whether it is your opinion that water con-taining hight 1evel radioactive vaste is currently etored on the Three Mile Island Reactor site.
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- 14. RESPONSEt Current federal regulations do not define high-level radio-1 active waste in the sense used in this interrogatory. However, water' contained in the reacter building basement and the reactor coolant system is considered to be highly radioactive when compared to levels of radio-i activity normally encountered (i.e., greater than 100 uCi/ml) in operat-ing PWRs. Water in the reactor coolant bleed tanks is considered to conhain intermediate levels of radioactivity (i.e., between i and 100 uC1/al) when compared to operating PWRs.
- 15. INTERROGATORY:
Please describe where that water is being stored and how it is being monitored.
- 15. RESPONSE Water in the reactor coolant system (RCS) and the reactor coolant bleed tanks is being monitored by periodic sample collection and analysis.
h.uav.c avAty in the reactor building sump is being non-itored by analytical methods which consider water balance and anal ses t
or radioactive material in the RCS. Although procedures are being developed, there is no method for directly sampling water in the reactor b.. ling sump at this time.
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- 16. INTERROGATORY: What structures or portions.of structures have been built or begun on the site of the Three Mile Island Reactor since March 28, 19797 l
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- 16. RESPONSEt The following structures have been built or begun Jince March 28, 1979:
t (1) Long-Term Solid Waste Staging Facility (Concrete Structure)
(2) Short-Term Solid Waste Staging Facility (3) EPICOR-II Cottrol Building (4) Ventilation system Building for EPICOR-II (5) Balance-of-Plant Electric Diesel Generator Building i
- 17. INTERROGATORY: For all structures or portions of structures mentioned in response to the previous question above, provide the following
-j (4) state the type, purpose, and size of the structures (b) state the j
date construction began, including the date the excavation for founda-tions, etc., commenced; (c) state the date construction ended or is
~
planned to end; (d) state the date on which application for a permit
.to construct such structures was filed by Metropolitan Edison or GPU, and the date on which approval was given by NRC; (e) if no permit appli-I cation was deemed necessary, provide a copy of any prior permit or por-tion of permit NRC, CPU, or Het Ed relied on in determining that such a structure could be built without additional permit (s).
t.
- 17. RESPONSE:
(1) Long-Term Solid Waste Staging Facility (Concrete Structure)
(a) Purposes To store prefilter media and ion exchange resin I
from the operation of EPICOR-1 and -II.
Size A s,odular structure with each module consisting of 60 storage cells. Each module to be built on an as-needed basis. Dimension 57 feet vide by 91 feet long by 19 feet high with 3 feet thick base and 4 feet thick walls.
(b) July 16, 1979
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(c) October 15, 1979 l
l (d) No application for a permit to construct this structure was 1
filed by Met Ed.
(e) The operating license of THI-2, provided as Attachment 8 in the response to Interrogatory 25, in referencing Section 50.59 of 10 CFR Part 50(5), was used in determining that this struc-l ture could be built without additional permits.
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- 17. RESPONSE: (Continued) l (2) Short-Term Solid Waste Staging Facility (a) Purpose To store profilter media and ion exchange resin from EPICOR-I and -II'until the loog-term staging area is
-1 completed.
Size: Sixteen cells 4.5 feet in ' diameter by 8 feet high I
and twelve cells 7 feet in diameter by 8 feet high.
(b) Started Construc' tion: June.1, 1979 (c) Completed Construction July 20,1979 i
l (d) See Response provide'l in (1)(d).
4 (e) See Response provided in (t)(e).
(3) EPICOR-II Control Building (a) Purpose / Types This building is used to provide remote control I
operation for the EPICOR-II waste treatment system. A wood j
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frame building was constructed.
Size: 24 feet long by 20 feet wide by 15 feet in height.
(b) Started Construction April 18, 1979 (c) Completed Construction: May 10, 1979 (d) See Response provided in (1)(d).
(e) See Response provided in (t)(e).
(4) Ventilation System Building for EPICOR-II (a) Purpose / Types To maintain a negative pressure in the chemical cleaning building and to filter the exhaust from the chemical cleaning building. The building is a concrete slab and con-crate block building approximately 60 feet long by 20.5 feet wide by 15 feet high.
(b) Started Construction: April 13, 1979 (c) Completed Construction: June 8, 1979 (d) See Response provided in (1)(d).
(e) See Response provided in (1)(e).
(5) Balance-of-Plant Electric Diesel Generator Building (a) Purpose / Type Used to provide redundant electric power to non-nuclear safety related equipment.
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- 17. RESPONSES-(Continued)-
Size: 68 feet long by 42 feet wide by 11 feet to roof with-l-
out a stack and 20 feet with a stack.
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(b) Started Construction: April 9, 1979 I
(c) Completed Constructions May 9, 1979 I
(d) See Response provided in (t)(d).
(e) See Response provided in (t)(e).
- 18. INTERROGATORY:. What structures, if any, are planned to' be built on Three Mile Island that are not specifically approved as part of the existing construction permit or operating license?
)
- 18. RESPONSE: See the response to Interrogatory 17. In addition, Metro--
i politan Edison has proposed to build a vaste evaporator building in the area' adjacent to the Unit 2 diesel building which would be used to pro-cess the hight contaminated waters in the reactor building sump and the primary system. This building is still in the planning phase and has not been reviewed by NRC.
- 19. INTERROGATORY: With regard to any structures listed in response to the question above, were any applications for amendments to the operating license or for new construction permits submitted by GPU or Het Edf l
- 19. RESPONSE: No applications for amendments to the operating license or for new construction permits have been submitted by Met Ed or GPU.
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- 20. INTERROGATORY: In reference to the structures listed in answer to question 18 above, has or will the NRC require either amendments to s
the operating license or construction permits be obtained by GPU or Het Edf 1
- 20. RESPONS3 At the present time, Met Ed has not made a formal proposal I
to build a waste evaporator building. When and if GPU decides to sub-mit a formal proposal to build a building to house a waste evaporator system, the NRC will perform an evaluation to determine the appilcability of requiring amendments to Het Ed's operating license or necessity for j
requiring a new construction permit using similar criteria as was used in the response to Interrogatory 17(1)(e).
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- 21. INTERROGATORY: Please state to the best of your ability where the--
steam released in the Three Mile Island accident fell.
- 21. RESPONSE During and following the March 28 incident. radioactive j
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materials in gaseous effluents were released from the auxiliary and fuel handling building ventilation systems which discharge to the environment through the Unit 2 plant vent. The corresponding dose from these releases to the population in the vicinity of the plant de-pends in part upon the local meteorological conditions, namely wind direction, wind speed, and plume dispersion characteristics, which varied during the period of radioactive release. Thus, there is no single location "where the steam released in the TMI accident fell."
However, throughout the accident period, the known meteorological con-ditions indicate that the NNV, ENE, and SSE sectors were the predominant directions from the plant in which radioactive material released from Unit 2 would be expected to be found. NUREG-0558 sumarises radiation measurements made at various times and locations around the Three Mile Island site. The staff made specific periodic estimates of the location f
e r
and relative concentration of releases throughout the course of the accident. These estimates are referred to, but not specifically pre-sented, in NUREG-0558. NUREG-0558 is provided as Attachment 4 in the response to Interrogatory 23.
- 22. INTERROGATORY: Please state whether any of this steam fell on the Susquehanna River and whether the addition of radioactivity to the River from this steam has been estimated. If such an estimate haa been made, please provide.
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- 22. RESPONSEt Some of the radioactivity released into the atmosphere sa a result of the Three Mile Island incident came in contact with the susquenanna Atver, specszic estimates were not maae so outermium one amount. However, total radioactivity in the river water from all sources was monitored by the licensee, personnel from the states of Pennsylvania and Maryland, and Department of Environmental Resources, Environmental Protection Agency, U.S. Geological Survey and U.S Nuclear Regulatory Comis sion. NRC measurements indicated no measurable increase in the
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- 22. RESPONSE (Continued)?
amount of radioactivity in the river, within the limitations of the in-struments, due to the incident..
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- 23. INTERROGATORY: Please list any and all environmental, public health, j
or other evaluations of the accident at Three Mile Island prepared by j
I NRC or Het Ed and provide Plaintiffs with a copy of such report.
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- 23. RESPONSE: The following is a listing of docureents which deal with the env.ironmental.and public health evaluation of the accident at Three Mile' Island.
(1) N3 REC-0558, " Population Dose and Ilealth Impact of the Accident at Three Mile Island Nuclear Station, Preliminary Estimates for the Peiiod March 28 through April 7,'1979," May 1979, prepared by the M Hoc Interagency Dose Assessment Group made, up of parti-
.l cipants f tma NRC, EPA and HEW 3 y
(2) CQL 0693, hay 15, 1979, J. C. Herbein (Met Ed) to B. B. Grier (USNRC),'Interin Report on the Three Mile Island Nuclear Station 1
Unit 2 (TMI-2) Accident;
- i
'1 (3) CQL 0780, June 18, 1979, J. C. Herbein-to B. H. Grier, Second
-Interim' Report on the Three Mile Island Nuclear Station Unit'2 (THI-2) Accident (June 15, 1979); and
-(4) July 16, 1979, J. C. Herbein to B. H. Crier Third Interin Report I
ontheThreeMileIslandNuclearStationUnit2iTMI-2) Accident.
cp Copies of the above reports are provided as Attachments 4, 5, 6 and 7, respectively.
- 24. INTERROGATORY: Please list (or provide page references to) any and all significant adverse environmental or public health impacts dis-covered in anv af *be above reports.
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- 24. RESPONSE _: Discussions of health and/or environmental impacts can be found in Section IV of the Metropolitan Edison reports and in all sec-tions of NUREC-0558.
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- 25. INTERROGATORY: Please provide the' Plaintiffs with copies of the 4
"i (1) Faciliry's Operating License Number DPR-13. Plus Attachments One i
and Twol (2) Report of Advisory Committee on Reactor Safeguards, October 22, 19763 (3) Office of Nuclear Reactor Regulation, Safety j
-Evaluation Report, September 1976, and Supplements One and Twol (4) Final Safety Analysis Report and Amendments theretol (5) Applicant's Environmental Report, dated February 28, 1975, and Supplements theretog (6) Draft Environmental Impact Statement, dated June 19723 (7) Final l
3 Environmental Statement dated December 19723 (8) Draft Supplement to-t Final Environmental Statement July 19761 and (9)' Final supplement to r
Final Environmental Statement, dated December 1976.
- 25. RESPONSES copies of itema 1, 2, 3, 6, 7, 8 and 9 are provided as i
Attachments 0, 9, 10, 11',12' 13 and 14, respectively. The 12 volume i t Final Safety Analysis Report and the 3 volume Environmental Report requested by items 4 and 3 lcan be obtained from the NRC's public docu-
. ment room located at the following locationes (1) NRC Headquarters,1717 H Street, Washington, DC.
3 (2) NRC PDR at the Covernment Publications Branch, State Library,-
Department of Education Building, Connonwealth and Walnut Streets, Harrisburg, Pennsylvania,
- 26. INTERROGATORY: Please state vbether Metropolitan Edison Company has provided to NRC any written evaluation of additional construction or operation activities as a result of the accident at Three Mile Island, prior to any approvals obtained from the Director, Office of Nuclear Reactor Regulation.
- 26. RESPONSE Yes, the NRC has received the following documents from the Metropolitan Edison Company (1) Safety Analysis Report for Transition to Natural Circulation, April 12, 19793 (2) Revised Safety Analysis Report for Transition to Natural Circula-tion. Hay 3, 19793 (3) FLR-Decay Best Removal System, May 1, 19793 W ane rnree interim Kaporrs, cated May 15 Juna 15 and July 16, 1979, o
identified in the answer to Interrogatory No. 23.
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- 26. RESPONSE (Continued)
In addition to these formally submitted documents, there were other written evaluations which the NRC staff has seen in the course of its a
continued presence at the Three Mile Island site.
- 27. INTERROGATORY: Please list all such written evaluations received by NRC since the accident at Three Mile Island I
- 27. RESPONSE: See response to Interrogatory 26.
- 28. INTERROGATORY: Were the environmental impacts from the accident at Three Mile Island, the subsequent cleanup, and alternatives to discharge into the Susquehanna evaluated by the Cotanission and Metropolitan Edison in the final environmental statement? If yes, please provide page references.
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- 28. RT.SPONSE : The environmental impacts resulting from loss of' coolant i
I accidents have been evaluated in the Final Supplement to the Final Environmental Statement related to the operation of Three Mile Island Nuclear Station Unit 2, NUREG-Oll2, dated December 1976. The specific accident which occurred at TM1 was not evaluated. However, the enviros-mental impact of a more severe accident, namely the loss of coolant accident resulting from a larger diameter pipe break, was evaluated in i
Section 7.2 of NUREC-Oll2. Also, the environmental impact of a similar i
accident, namely the loss of coolant accident resulting f rom a small I
i I
diameter pipe break, was evaluated in Section 7.2 of NOKEG-Oll2.
i The environmental impact of the subsequent cleanup and alternatives to discharge was not evaluated in NUREG-Oll2. However, as indicated in e
the May 25 directive from the Comission to the NRC staff, no cleanup or j
discharge of the water generated as a result of the March 28, 1979 i
i accident may begin until the NRC staff completes certain actions. An environmental assessment of the cleanup of this water and alternatives to discharge into the Susquehanna must be completed and the public nust At this p
be provided with an opportunity to conusent on the assessment.
time, the NRC staff is in the process of preparing the envirordnental i
assessment of the cleanup of the vaste water.
A
I l
29.
INTERROGATORY: Please state whether the annual total quantity of radio-active materials in liquid waste for 1979, excluding tritium and dis-4 solved gases, has exceeded five curies for TMI-2.
- 29. RESPONSE: The total quantity of radioactive material in liquid wastes j
released from TMI-I and -2 through May 31,1979 is 0.46 Ci, excluding tritium and dissolved gases. Refer to response to Interrogatory 7.
- 30. INTERROGATORY: Please state whether the annual dose to the whole body or any organ of an individual as a result of the accident at TMI-2 has exceeded five mrem from the combined releases at TMI Units one and Two.
- 30. RESPONSE: As indicated in NURE N0558 provided in the response to Inter-rogatory 23, the maxiana dose to an individual as a result of the accident is less than 100 mtem. This is greater than the 5 mres discussed' in this interrogatory. However, it should be noted that the 5 mrem is a design objestive dose for normal plant operation. A discussion of the health impact of the exposure is given in NUREC-0558.
- 31. INTERROCATORT: Please state whether the effluent from the cooling towers at Three Mile Island has exceeded, excluding tritium and dis-solved gases, 2 x 10-8 microcuri'es per milliliter since January 1, 1979, and state the dates on which such violations occurred.
l
- 31. RESPONSE: The concentration level of 2 x 10~ uCI/ml in the cooling tower effluent is not an instantaneous concentration limit, nor is it 6
an instantaneous specification limit. 'As indicated in the THI-2 en-vironmental technical specifications, it is a design objective to be met on an annual average basis to ensure that the instantaneous release i
rate for effluent discharges are within the limits of 10 CFR 20.
/
l Release concentrations are provided in Tables I through 3 of the res-ponse to Interrogatory 7.
Based on the data in these tables, the value of 2 x 10-6 was exceeded during the period March 28 to April 30, but as r
indicated above, this does not represent a technical specification violation. The linits of 10 CFR 20 specified in the technical speci-fications were not exceeded at any time.
l l
l f
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i Please state whether the' annual average concentration
. INTERROCATorlYJ 32.
of 'critium and liquid waste prior,to dilution in the environment has l
exceeded 5 x 10-6 microcuries per milliliter at any time during 1979,
't l.
and state the date on which violations occurred.
'7 l
l l
i 2
i
-6
- 32. RESPONSE: The concentration level of 5 x 10 in the effluent is not 'an j
instantaneous concentration limit nor is it an instantaneous specifica-j
/
' tion limit. As indicated in the THI-2 environmental technical spscifi '
p
- cations it is a design objective to be met en an annual average basis to i
ensure that the instantaneous release rate for effluent discharges are i
i within the limits of 10 CFR Part 20. Release concentrations are pro.-
vided in Tables I through 3 of the response to Interrogatory 7..
Based 6 l on the data in these tables, the value of 5 x 10 has not been exceeded during 1979. The limits of 10 CFR Part 20 specified in the technical specifications also have not been exceeded at any time.
al 1
- 33. INTERROGATORY: Please state whether the radioactive releases in the from Reactors One and Two have exceeded the values in 10 CFR 20, effluent Appendix "B", for unrestricted areas, at any tima during 1979; and state l l the dates on which such violations occurred.
- ;j i
\\
- 33. PISPONSE: See Tables I through 3 provided in the response to Interrog-story 7 which provides liquid and gaseous releases, January 1, 1979 to May 31, 1979.
)
1.
Liquid Releases The iodine and tritium release concentrations
-}
given in I.3 and I.C of Tables 1 through 3 are less than the 6
I 10 CFR Part 20, Appendix B, concentrations of 3 x 10"7 uCi/m1
~3 and 3 x 10 uci/ml respectively. The concentrations given in Y,
Part I.A of Tables.1 through 3 are not listed by individual nuclides, however, these concentrations are less than the values in 10 CPR l
Part 20 for the nuclides most 11kely to be present in the ef fluents i
(e.g., cestums, consits, strontiums, iodines, iron, manganese, mine, i
and barium-lanthanum).
2.
Caseous Releases The iodine-131 releases given in II.B of i
Tables I through 3 are within the limits of 10 CFR Part 20. The j
noble gases appear to have exceeded the limits of 10 CFR Part 20 on a short term basis using the annus1 average meteorological dis-
\\
to the Final Environmental persion factors from ths Final Supplement l
l r
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'N"'f."N P $w/%+Mygg _
9
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- 33. RESPONSES-'(Continued)
~
' Statement, NUREC-0112.- 10 CFR Part 20 does, however, permit i
c averaging these releases over a period of one year.
Future calculations based on actual meteorology will be necessary to determine if 10 CFR Part 20 was actually exceeded.' The exact t a dates of the release exceeding 10 CFR Part 20 will be determined
(
'~
'i when actual meteorological data and better gaseous release date
'l are available.
- 34. INTERROGATORY: 'Please state whether in acy quarter the total release of radioactivity in liquid effluent from THI-l and -2, excluding tritium and noble gases, has exceeded 10 curies per reactor.
i
- 34. RESPONSE No. As indicated in the response to Interrogatory 7, the release in liqaid effluents, excluding noble gases and tritium sas 1
0.15 curies for the first quarter and 0.31 curies for the second quarter of 1979, through May 31, 1979.
- 35. INTERROGATORY: 71 ease state whether the maximum radioactivity contained in any one of thn liquid radwaste tanks, excluding tritium and dissolved gases, exceeds lJ curies.
- 35. RESPONSE: Yes. Radioactivity levels in the Unit 2 liquid radwaste tanks exceed 10 curies, excluding tritium and dissolved noble gases.
I
- 36. INTERROGATORY: Please state where those liquid radwaste tanks are located.
- 36. RESPONSE: Radwaste tanks referenced in Interrogatory 35 are located in I
the Unit 2 auxiliary building.
4 37.
_ INTERROGATORY: Please state whether Zenon-131 h permissible concentration (168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) of 5 x 10~js exceeded the nazinsna microcuries per milli-liter at any time in 1979, and state the dates on which such violations occurred.
l 1
- - ----------_---_----J
/
I
- 37. RESPONSE: No. Discharges of Xe-133 in liquid effluents have not exceeded 1
-3 5 x 10 uCi/ml between January 1, and May 31, 1979.
I l
l l
- 38. INTERROGATORY: Please etate whether the maximum permissible concentra-tion of xenon-135 (158 hours0.00183 days <br />0.0439 hours <br />2.612434e-4 weeks <br />6.0119e-5 months <br />) has ever exceeded the level of I x 10-3 microcuries per milliliter, and state the dates on which such violations occurred.
- 38. RESPONSE: No. Discharges of Xe-135 in liquid effluents have not exceeded
-3 I x 10 uci/ml between January 1, and May 31, 1979.
- 39. INTERROGATORY: Please provide the sources for the responses to Ques-tion 29 through 38.
I i
- 39. RESPONSE: Sources for answers to Interrogatories 29 through 38 include data obtained from Metropolitan 1:dison and Babcock and Wilcox. This includes measured station eff12ent data and tank voluse and radioactivity I
analyaes data. It also includes radiological dose data taken from NUREC-0558 provided in response to Interrogatory 23.
- 40. INTERROGATORY: Please state the basis on which the dilution factor of the Susquehanna River of 250x vaa developed in the Three Mile Island, Unit Two, Facility Operating License Number DPR-73.
- 40. RESPONSE: The dilution factor of 250 for Three Mile Island, Unit Two, was developed to determine expected doses from the finfish consump-tion pathway for use in the assessments required by 10 CTR Part 50 The specific estimate of 250 was based upon the dilu-Appendix I tion of plant discharge by the average annual flow rate in the middle channel of the Susquehanna River at the site. The river flow is split at the head of TMI, such that during normal flow conditions, approxi-mately 30% of the average annual discharge of 34,000 cubic feet per second (CFS) is diverted to the middle channel on the west side of the island. The average annual discharge of 34,000 cfs was based on records from the U.S. Geological Survey stream gage at Harrisburg, Pennsylvania.
m
- -i.
- 40. RESPONSEt (Continued)
The average annual plant discharge is expected t'o be 80 cis. Therefore, the average dilution factor townstream of.the discharge was calculated to be 125. It was assumed that an individual fish would be upstream of the discharge point % of the time and downstream of the discharge point % of the time.
The dilution was,therefore, calculated to be 250 for the region where finfish exist (within a one-quarter mile radius of the discharge point).
- 41. INTERROCATORT: Please state the number of people living within a five-mile radius of the Three Mile Island plar.t, a ten-mile radius of the TMI plant, and fifteen-elle radius of the plant.
- 41. RESPONSE The projected 1980 population within a five-mile radius of TMI was estimated in the Final Safety Analysis Report for Unit 2 t
to be 28,821. Within a ten-mile radius the population for 1980 was 1
projected to be. 166,295. A projection for the fifteen-mile radius population was not made. However, the 1980 population projection for a twenty-mile radius was 1,178,584.
42.
INTERROGATORY: Please state the exact dimensions of Three Mile Island.
- 42. RESPONSE: A map of the TMI site is provided as Attachment 15. This map is taken from the Final Safety Analysis Report for TMI, Unit 2, Figure 2.4-IB.
-1
- 43. INTERROCATORT: Please state whether additional liquid effluents could be stored on the reactor site at Three Mile Island.
4a. RhSrvribe.: Ane response to Interrogatory 13 lists the current remaining i
storage capacity available at Three Mile Island, Units I and 2.
This 1
is the only remaining storage capacity available otsite at this time.
j As indicated in that response, it is not planned to use the remaining storage capacity in the Unit I auxiliary building, the fuel handling building, or the chemical cleaning building to accommodate additional effluents in the Unit 2 auxiliary building. However, this capacity could be utilized in an emergency situation.
l- ~~
f l
- 44. INTERROGATORY: Please list snd produce the test results of any sound-ings or drillings performed on the TMI Reactor site prior to the con-struction of facilities after the accident on March 28, 1979.
l
)
- 44. RESPONSE: There was core drilling prior to the conservation of both i
'the short-ters solid waste staging facility and the long-term solid l
waste staging facility. The results are attached in a cover letter entitled, " Preliminary Soils Information Solid Waste Staging Facility."
(Attachment 16.)
l
- 45. -INTERROGATORY: Please state the estimated doses from liquid and air radioactive emissions in 1978 and 1979, by month, from Reactors One and Two, to the whole body for the calendar year, for milliress in a seven consecutive-day period and for millirems per hour.
i
- 45. R'.SPONSE: The doses to the maximum individual 0.37 miles WNW of the site from January through December 1978, due to liquid and asseous -
effluents from Three Mile Island Units l'and 2 ares l
Unit 1 Iodines & Particulate in gases, total body adult 0.86 mrem Noble gases ' total body, adult 1.0 stem Liquid, total body, adult' l.8 arem Unit 2 Iodines & particulate in gases, total body adult 0.12 ares-Noble gases, total body, adult 0.0019 crem Liquid, total body, adult 0.035 mres Doses at other' locations would be' lower.
The dose due to radioactive effluents in 1979 are mody from the March 28, 1979 incident. The best estimate for' the maximum exposed individual is less than 100 mres. Details of this analysis are con-tained in NUREG-0558, provided as Attachment 4.
i e ti. ' InfrERxOGATURT : Flease list all documents on which you base your calcu-TTions of human exposure to radioactivity from the Three Mile Island Nuclear Reactor. Please site specific page references to documents in which mathematical models or calculations relied on are contained.
l 4
r.
4 30 i.
- 46. RESPONSE:.The following documents were usedt g
- (1)
U.S. NRC Regulatory Guide 1.109, " Calculation of Annual Doses to
[
Man from Routine Releases of Reactor Effluents for'the Purpose of Evaluating' Compliance with 10 CFR 50, Appendix I."
(See Attach-ment 17.) The specific pages are 2 through 7, 12 through 17, 20 through 22, and 24 th:nush'28.
/
~(2) Final Supplement to the Final Environmental Statement related to operation of the.Three Mlle Island Nuclear Station Unit 2, NUREG-Oll2, December.1976, specifically Chapter 5.4. -
- 47. INTERROGATORY: 'Please list'NRC operating procedures, guidelines, in-ternal memoranda, and policies established for the operation of nuclear-power plants that exceed permissible concentrations or total quantity of radioactivity within a particular period of time.
- 47. RESPONSEt The operating conditions imposed. on each nuclear power plant by NRC that exceed permissible concentrations or total quantity of radioactivity within a particular period oc time, can be found in the technical specifications for each operating facility, i
- 48. INTERROGATORY: Please list all NRC operating procedures, guidance, memoranda, and policies for the preparation of environmental assess-
_l ment statements for determining when a negative declaration is issued and for determining when an environmental impact statement is required.
- 48. RESPONSE NRC guidance for the preparation of environmental assessment statements is contained in 10 CFR Part 51(8),. This Part is currently I
being revised to conform with new CEQ regulations which become effective i
on 30 July 1979. In addition, there is a DOR Memorandum No. 5. dated f
9 Mr.rch 1977, which also gives some guidance in this area. (See 8.)
- 49. INTERROGATORY: Please state the name and address of the manufacturer of EPICOR-1 and EPICOR-II Treatment Systems.
- 49. RESPONSE The EPICOR-I and EPICOR-II treatmant systems were provided i
by EPICOR, Inc., 1375 Linden Avenue, Linden New Jersey.
_ _ _, _ _ _ _ _ _ _ _ - _ _ _ = _ _ _ _ - _ _ _ _ _ _ _ - - _ _ _ _ - - _ - - _ _ _ _. - _ _ _ _ _ _ _ =.
L
/
L L.j
- 50. INTERROGATORY: Please list the specifics of the design system of EPICOR-1 and EPICOR-II.
- 50. RESPONSE: See attached EPICOR-I and EPICOR-II System Descrip'tions l
(Attachments 19 and 20, respectively).
e.1
- 51. INTERROGATORY: Please list any and all information concerning the manufacture and specifications, manufacture of component parts, prior i
installations, and produce prior performance data on EPICOR-I'and j
EPICOR-II.
f i
i 1
- 51. RESPONSE: Information requested in Interrogatory 51 concerning system l
l design is given in the response to Interrogatory 50.
With regard to system performance dets, it should be noted that EPICOR-I I
l and EPICOR-II are systems that use ion exchange to treat the water. The use of ion exchange in the treatment of radioactive vaste water is standard practice in nuclear power plants and the principles and per-i formance data upon which they are based are described in NUREC/CR-O!43, provided as Attachment 21.
1 The EPICOR-I system has been wed oneita previously at Unit I and system decontaminate'lon factors were found to be satisfactory.
l
}
The EPICOR-II facility is similar to EPICOR-I. The major difference
- t lies in the fact that EPICOR-II is located insion a ventilated and fil-tered building. It is planned to use it to process liquid wastes that are of a higher activity level than those processed by EPICOR-I.
- 52. INTERROGATORY: Please state what NRC and Met Ed's' projected performance capability of EPICOR-II was on April 15, on May 16, and on May 25, 1979.
l l
- 52. RESPONSE: Ihe EPICOR-II system was originally designed to process wastes with a cesium 137 and iodine-131 specific activity of no greater.
than 100 uci/ml. This design objective has not changed.
i i
l
f O
-M-
- 53. ' INTERROGATORY: Please state the current characteristics in terms of '
concentration of various radioactive isotopes in the primary coolant ~
water, in all water held in tanks on the reactor site, in the reactor '
i
- core and containment building.
4 i ;
- 53. RESPONSE:
Concentrations of important radionuclides for radiological dose considerations at requested ' locations are presented in " fables 6 t
l and 7.
4
.9 q
Please state how the various water systems are pre-54. INTERROGATORY:
'i sently segregated or inter-connected through pluebing mechanisms or leaks.
j 54. RESPONSE Information concerning the 'various waste systems can be obtained fran the following drawings:
Flow Diagram - Radwaste Disposal Reactor Coolant Liquid, DWG 2027..
1.
i 2.
Flow Diagram - Radwaste Disposal - Miscellaneous Liquids, DWG 2045.
3.
Flow Diagram - Auxiliary Building Emergency Liquid Cleanup System, i
DWG N006.
4.
Flow Diagram - Fuel Pool Wste Storage System.DWG M014.
' These drawings are provided as Attachments 22 through 25.
- 55. INTERROGATORY:
Please list the projected treatment efficiency on primary coolant water for all radioactive components of EPICOR-II.
- 55. RESPONSE:
EPICOR-II was not designed to process primary coolant system water.
I
- 56. INTERROGATORY:
Please list all solid radioactive materials presently onsite, the level of radioactivity, and the disposal techniques anti-cipated.
l u
V---"*"
h u.rce.t inventury or solid waste includes approximately i
700 drums (55-gallons) of compacted low-level trash, 9 liners (50 cubic feet) of solidified evaporator bottoms, 46 boxes (4 feet by 4 feet by 8 feet) of noncompactible low-level trash, 9 liners (180 cubic feet) of dewatered resin, and 3 11ners (180 cubic feet) of dewatered filter l
I
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i l
..(._
b t; 33 i
t-56., RESPONSE (Continued) vaadium. All of these containers qualify as Low Specific Activity.
) material and will be transported to a licensed burial facility for ultimate disposal.
- 57. INTERROGATORY: Please state whether, to the Defendants' knowledge, there is any method currently known to determine the amount of cell -
damage caused by radiation as experienced from the Three Mile Island -
Reactor.
- 57. RESPONSEt We are not aware of any method to determine the amount of cell damage in humans caused by low doses of radiation (i.e., about 100 mren). In NUREC-0558 (Attachment 4) the dose to a hypothetical offsite taximum individual was estimated to be less than 100 mrea.
Recently DJ. Joseph Cong of the State University of New York at Buffalo presented a talk on the erythroid effects of radiation of rats in the I roentgen (R) range (Symposium on Biological Effects, Imaging Tech-niques and Dosimetry.of Ionizing Radiation, Bureau of Radiological Health, June 1979). At this symposium Dr. Cong stated that he has detected an increase in the amount of normoblasts for bled rats at doses as low as 50 mR. To the best of our knowledge, this is the lowest level of exposure at which cell damage has been observed in animals. However, we are not aware of any studies that have.shown l
4 i
similar effects in humans at doses of 100 mrem or less.
i I
j I, John Collins, Deputy Director, Three Mile Island Support Staff, j
declare under penalty of purjury that the foregoing answers were prepared under my direction and supervision and that they are true and corr'ect to I
the best of my knowledge and belief.
%n%
i
[/
JOHN T. COLLINS 1
I
R
-1
(.
1 REFERENCES
- l (1) Title 10, CFR Part 50.36a, " Technical Specifications in Ef fluents from Nuclear '
~
Power Reactors."
\\
(2) ' Regulatory Guide 1.21 "Heasuring,' Evaluating, and Re' porting Radioactivity in
)
Solid Wastes and Release of Radioactivity in Liquid and Caseous Effluents j
from Light-Water-Cooled Nuclear Power Plants,".Rev. l.
(3) NUREC-0432, Three Mile Island Nuclear Station, Unit No. 2, Environmental Technical Specifications (Appendix E), Section 2, " Radioactive Discharges,"-
February 8, 1978.
(4). Title 10, CFR Part 20. " Standards for Protection Against Radiation."
l (5) Title 10, CTR Part 50.59, " Changes Tests and Experiments."
. (6 )'
Title 10, CFR Part 50, Appendix I, " Numerical Guides.for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low As Practicable' for Radioactive Haterial in 1.ight-Water-Cooled Nuclear Power.
Reactor Effluents."
(7) Metropolitan Edison Co., PAnal Safety Analysis Report,' Three Mile Island Nuclear Station, Unit No. 2 April.J974.
(8) Title 10, CFR Part 50, " Licensing and Regulatory Policy and Procedures for Environmental Protection."
(9)' Title 10, CFR Part 71.4, " Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions, Definitions."
i k
j
3
-U 4
TABLE 1 PERIOD 3/28/79 - 3/31/79
- I.
. Summary of Releases (Llquid).
A.
Curies Discharged (excluding tritium & dissolved 1.lE-l noble gases)
Concentration (uci/cc)*
1.32E-7 j
B.
Iodine-131 Released' Total C6 ries 1.063E-l Concentration (uci/cc)'
l.24E-7 j
l.
'C.
Tritium Releases Total Curies 5.5E-1 concentration (uci/cc) 6.61E-7 l
i
- II. Summary of Releases (Airborne) j A.
Noble Cases Total curies 8.83E+6'
'I Release Rate (C1/sec) 1.12 i
B.
= Iodine Releases Total curies 4.57 Release Rate (uci/sec) 5.8E-l 4
1 i
)
3 1
L
../1 4 t TABLE 2 PERIOD PERIOD 4/01/79 - 4/30/79 5/01/79 - 5/31/79 I.
Sunnary of Releases '(Liquid)
Curies Discharged'(excluding 2.74E-l 4
- 0E-2 '
~
~
A.
tritium' E dissolved gases)-
concentration (uC1/ce)
.4.39E-8 6.2!E-9 y
e B.
Iodine-131 Released Total Curies 1.28E 5.lE-3 Concentration (uci/c_c) 2.lE-8 7.8E-10 C.
Tritium Releases Total curies 10.12
~ 4.7
-Concentration (uci/ce) 1.62E-6 7.3E-7 I
II. Summary of Releases (Airborne) l
.A.
Noble Cases-
. Total curies 1.1IE+6
'l.4E+3 Release Rate (C1/sec) 1.41E-1 1.74E-4 l
B.
Todine Releases Total Curies 9.5 7.8E-2' Release Rate (ucl/sec) 1.20 9.9E-3 4
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TABLE 3 PERIOD 1/01/79 - 3/31/79 I
I.
Summary of Releases (Liquid)
A.
Curies Discharged (excluding tritium & dissolved 1.5E-1 9
noble gases)
Concentration (uci/cc) 8.03 E-9 k
B.
Iodine-131 Released Total Curies 1.07E-l Concentration (uCi/ce) 5.7E-9 C.
Tritium Released Total curies 26.1 Concentration (uci/ce) 1.54E-6 II.
Summary of Releases (Airborne)
A.
Noble Gases Total Curles 8.83E+6 Quarterly Release Rate (Ci/sec) 1.12 B.
Iodine-131 Releases Total Curles 4.57 l
Quarterly Release Rate (uCi/sec) 5.8E-1 I
I
m 79
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n TABLE 4 4
SUMfARY OF LIQUID RADIONUCLIDES DISCHARCED BY 1SOTOPE PERIOD I/l/79 THROUGH 3/27/79_
l' i
Radionuclides Activity Cl 2.54E +1 H-3 1.65E -3 Cr-51 l
3.36E -4 Hn-54 2.13E -2 co-58 g
1.33E -4
.Fe-59 l.19E -3 i
Co-60 3.94 E. f 5
-Zn-65 1.43E -3
-Nb-95 7.71E -5
'Zr-95 8.88E -5.
Zr-97 8.56E -6
' Ho-99 7.37E -5 Ru-103 8.32E Ag-110 5 78E -5 Sb-122 3.77E -5 Sb-124 2.54E -4 i
~-
2.60E -5' l
Ke-131m-I-132 I-133 2.60E -5 t
Xe-133m Xe-133' 9.95E -3 3.21E -3 Cs-134 1.22E -5 Cs-136 4.55E -3 Cs-137 2.88E -5' Ba-140 3.94E -4 La-140
c.
- s. '\\.
i t
_iy
-p i
i v
M' t:
.s:
TEBLE5
. s.
. LIQULD RADIONUCLIDES DISCHARCEF JY ISOTO.>E t
3/28/79-4/30/79 5/1/79-5/31/79 Radionuclidj
-Activity (C1)
Activity (Cl)
E-3 10.670
' 4.' 7 1
-Cr-51 3.5E.-4 1.64E -[-
1.57E -4 l'{
Mn-54 4.1IE.-4 o
i
.j
~'
Co-58 0.022' l.24E -2 g.
Co-60 6.9E -3 1.4IE -3
,,q.
S.17E -4' Nb-95 1.82E -4i
.Zr-95 4.83E -5 7 22E -5 Ag-110m 1.25E -3 9 37E -4' I-131*
0.235 5.05E ~3 xe-131m 7.25E -4 I-132.
3.44E -4
..I-133 1.4 E '-4.
1.43E -5 Ie-133' O.012 7.5E -5 Cs-134 2.llE -3 2.18E;-3 2.7E -4 1.3E -3'-
i1 Cs-136 Cs-137 5,.61E -3 4.83E -3 Ba-140 5.99E -4'.
5.43E -3 La-140 1.29E -3 4.09E'-3 I
- I-13) is the only radionuclides of significance released to the river j
from Unit 2 accident of 3/28/79. Other radionvelides came primarily from Unit 1.
0 4
1
.___7
=,..
' /I
.-.7 TABLE 6
.~ Q i 1
~ ESTIIMTE OF CONCENTRATION OF ACTIVITY IN WASTE LIQUIDS (As of July 1,'1979)
- 1 d
' l pt
-ACTIVIT1 REACTOR L
-CONTAINMENT-4
' fr (uci/ml)
COOLANT n
SUle*
- 4 1
i H-3 0.2-0.3.
l.c-l.5 Sr-89 305-330'
'300-400 Sr-90/Y-90 17-19 10-18' 4
i
.I-131 0.5-0.6
-0.5-1.5 Cs-134.
18-22 30-40 Cs-137/Ba-137m
.90-110, 200-260 Ba-140/La-140 4-5 0!5-1 J
" total of others 0.1-5 0.1-10 1
1 i
i 1
- Ranges are estimated (sample has not been obtained for analysis).
j
- i l
j l
1 I
l h
1 l
4 I
l O
I i
i i
i
.c o
~f I
M i 'l.
i' t
'lj n TABLE 7
-):
CONCENTRATIONS OF PRINCIPAL NUCLIDES IN TMI UNIT 2 AUXILIARY BUILDING TANKS AS OF f
. JUNE 15, 1979
')y (uCi/ml) i, l.
Q-
. Reactor Coolant Reactor' Coolant Reactor Coolant
~
Bleed Tank A Bleed Tank B Bleed Tank C
.j I-131 I.9 -
2.8 3.0,
Cs-134 6.5 7.6 7.7
^
Cs-136 0.28 0.29 0.28:
3 s
Cs-137 28 35 3$..'
.'l Ba-14.0 0.09 0.3 0.29 i
H-3 0.23 0.21 0.29 4-
?
Evaporator Misec11aneous Waste Condensate Holdup Tank Auxiliary Tanks; Con-a Neutralizer Neutralize.r Bldg Sump & Sump Tank; taminated Tank A Tank B Miscellaneous Su:nps Drain Tanks
-3 I-131 0.15 O.18
').O 4 10
~I Cs-134 0.56 0.72 2.4
< 10 l
~I Cs-136 0.01 0.02 0.08
< 10
{
Cs-137-2.5 3.3 10.1 4 10"I if s
.g
~I' Ba-140
.01 0.03 0.8 4 10
- )
H-3 NA*
NA*
0.98 NA*
l Not analyzed es yet. E-3 levels are estimated to be less than 0.2 uti/gtn.
i i
l O
n
"