ML20196B604
| ML20196B604 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/26/1988 |
| From: | HERITAGE REPORTING CORP. |
| To: | |
| References | |
| NUDOCS 8806300313 | |
| Download: ML20196B604 (145) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of: )
)
, MEETING: THE ADVISORY PANEL )
FOR THE DECONTAMINATION OF )
THREE MILE ISLAND, UNIT 2 )
Pages: 1 rough 117 Place: Harrisburg, Pennsylvania Date: May 26, 1988
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1229 L Street, N.W., Sehe ete I WanWestos, D.C. 20005 (292) 628-4888
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2 OFFICE OF NUCLEAR REACTOR REGULATION 3
MEETING: THE ADVISORY )
4 )
PANEL FOR THE DECONTAMINATION )
5 )
OF THREE MILE ISLAND, UNIT 2 )
6 )
7 Thursday, 8 May 26, 1988 9 Holiday Inn, Ballroom AB 23 South 2nd Street 10 Harrisburg, Pennsylvania 11 The meeting convened, pursuant to notice, at 7:02 12 p.m.
13 BEFORE: THE HONORABLE ARTHUR MORRIS Mayor of Lancaster, Pennsylvania 14 Chairman 15 PANEL MEMBERS:
16 NEIL WALD, Ph.D.
Chairman of Radiation Health 17 University of Pittsburgh 18 THOMAS GERUSKY Director, Bureau of Radiation Safety 19 Pennsylvania Department of Environmental Resources 20 JOEL ROTH ANNE TRUNK 21 Ret vsenting the Public 22 K6NNETH MILLER Director, Health Physics Division 23 Hershey Medical Center 24 (Continued on Page 2.)
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2 1 PANEL MEMBERS (Continued):
2 JOHN LUETZELSCHWAB Professor of Physico 3 Dickenson College 4 LEE THOMAS Project Manager 5 Three Mile Island Unit 2
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3 1 C O N T E N.T S 2 AGENDA PAGE 3 Chairman's Opening Remarks - MAYOR A. MORRIS 4 4 Status of Cleanup Activities - GPUN Staff 5 i
5 Status of Accident Generated Water Hearing - NRC Staff: 13
- 6 l PEIS Draft Supplement 3 Dealing with 7 Post-Defueling Monitored Storage and
. Subsequent Clean up - NRC Staff: 17 8
Public Comment:
1 9 Frances Skolnick 53 10 i Eric Epstein 67 11 Vera Stuchinski 79 12 Kay Pickering 86 13 14 15 16 17 l 18 19 20 21
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4 1 PROCEEDI NGS 2 MAYOR MORRIS: Good morning, ladies and gentlemen. I 3 would like to welcome you to the panel meeting this evening.
4 And the first order of business is the Chairman's opening 5 remarks. And I have just very brief comments this evening.
- 6 First, I did receive a call from Gordon Robinson. He 7 could not be present this evening.
8 And the only other item I wanted to comment on 9 tonight was that people had seen the agenda, which they may 10 have already, and there is an item missing that was indicated 11 that would be on it for this meeting, and that was a discussion 12 regarding the purchase and installation ahead of time of the-13 evaporation equipment.
14 I was requested or contacted I should say by Eric 1E Epstein who indicated that while he might want to personally 16 speak to this issue this evening, that he felt because of the 17 other item, main item on the agenda tonight, the PEIS, that he 18 preferred for it not to take up time from that very important 19 topic, and so we did not schedule it as an agenda item, as we 20 indicated we would at the last meeting.
21 That concludes my opening remarks. And I would like
. 22 to at this time call upon the GPUN staff regerding the status ;
23 of the TMI cleanup.
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1 PRESENTATION OF FRANK STANDERFER, DIRECTOR, THREE MILE ISLAND 2 UNIT 2 CLEANUP PROJECT FOR GPU NUCLEAR CORP.
3 MR. STANDERFER: I'm Frank Standerfer, Director of 4 the TMI-2 cleanup project for GPU. I have a short presentation 5 with some videotape and two viewgraphs.
6 I'd like to mention though that an event of interest 7 happened on Monday that you may have seen in the paper.
8 When we were installing the plasma arc cutting 9 equipment back in the vessel on Monday, one of the boilermakers 10 accidentally stepped in a spot on the work platform where the 11 deck plates had been removed and fell partw.y into the vessel 12 before he caught himself, and did have his legs wet below the 13 knees. And it was relatively easy to decontaminate him. It 14 did not result in any serious injury to the man, but it is the 15 kind of thing that we have been careful to try to avoid as 16 people have worked around an open tank of water over the last 17 three years. And I wanted to mention that.
18 This was at a time when guard rails were removed, so 19 this equipment could be installed. He had a safety belt on.
20 His drop was over and he stepped away from the platform, 21 disconnected his safety belt, cnd then chose to do another task
. 22 which resulted in him actually backing up and forgetting the 23 hole was open, and slipped in the hole.
24 So we are redesigning the tether system that the 25 fellows use and we've admonished the crews again to be careful. !
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6 1 We also will have one of the people on the platform 2 standing by any temporary open holes such as that so that if 3 someone accidentally moves towards one we can stop them. I 4 thought I'd mention that, if you'd seen it in the paper.
5 MAYOR MORRIS: Thank you, Frank.
6 MR. STANDERFER: Let me step over, and I've got two 7 viewgraphs.
8 This is the status of the fuel interactive vessel.
9 As you renember in the last meeting, the fuel from the original 10 core region is removed. We are currently cutting pieces of 11 this structure apart and removing them from the vessel so that 12 we can get access to the fuel that's in the bottom of the 13 vessel and this upper portion of the core support structure was 14 removed in the end of April.
15 The core bore equipment that was used early in there 16 to cut through a number of these lower plates in the plasma arc 17 cutting system now is being used to cut the next plates down.
18 And I've got some good videotape of that in a minute.
19 But the videotape you'll see will be the top of this 20 structure before cutting. After cutting you'll see several l e i 21 pieces of this structure being lifted out of the vessel.
22 You'll see the next plate as it appears today ready to be cut.
23 One other viewgraph, just to get some numbers. As you noticed 24 on the chart before, the full core was 293,000 pounds. We've ,
25 removed 66 percent of the fuel to date, 195,500.
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l 1 Another fuel shipment was.made last weekend. We've l
2 now shipped 65 percent of the fuel and the fuel shipping is 3 current with the fueling. We've shipped 191,300 pounds.
4 Now, this will be the top of that core support 5 structure as it appeared back in March, March 6th before the
- 6 cutting started. These cells are eight inches square and 7 that's where the original fuel elements fit into the bottom of 8 the core.
9 Atter the several drilling operations, the cell 10 structures have been severed in several locations and there are 11 13 pieces that are subsequently lifted out.
12 This would be the first of the pieces that are 13 removed from the vessel. Again, part of that structure.
14 This is down in the vessel underbater being picked up 15 by one of our tools.
16 This is a section of that which has been lifted free 17 of the water and is dripping over the defueling slot in the 18 air, above the defueling platform.
19 This is the largest' piece. It was the centerpiece, 20 five foot square. And it is being lifted well above the 21 defueling platform on the way to the four flood tanks where !
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. 22 these pieces were stored.
23 A first order was suspended in there and counted with 24 a special radiation counter to determine whether there was any 25 fuel on the surfaces of the metal.
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8 1 As you can see, these pictures will be very clean, 2 shiny.
3 This is one of the core flood tanks. The top has been 4 cut off and is currently being used as a storage position for 5 these pieces that we are removing from the reactor vessel.
. 6 They're stored underwater in.the core flood tanks.
7 This is a picture of the plasma arc cutting torch 8 that is currently being used to make the next cuts.
9 In this picture it's being positioned and checked out 10 before cutting. This is nitrogen gas which is a shield gas 11 that shields the plasma arc as it operates. When it is 12 operational there is a heavy glass that goes over the TV camera 13 and you'll see the flame in a minute. Some similar to what a 14 welder coating would be. It is not cutting now, just being 15 positioned. ,
16 Here is a picture where the arc actually is struck 17 and the cut was made and this is another shot of the torch at 18 another location prior to 1other cut.
19 The upper parts of the core support structure are 20 bolted on. These plates are bolted on. We have to take these 21 plates off. That'll be done later this Fall. And this is a
. 22 tool that was developed to remove these bolts. And you see the 23 bolts are hex set bolts with a pin across there, and it's 24 welded at both ends. So this ratchet tool actually cuts the 25 pin and then removes the bolt, in one operation.
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9 1 And this was tested back on the 18th of this month.
2 They are to remove the bolt and.now another tool will 3 take the bolt out of the ratchet device.
4 I believe I did remove five or_six bolts just to make 5 sure that it worked it several locations.
- 6 There is the bolt with the' pin where it's been cut on 7 both ends, previously welded.
8 After the grid section is removed, this is what the 9 next plate, the distributor plate looks like, and you can see 10 these are locations where the core bore has cut it around a 11 support post and as we cut this with a plasma arc and then it 12 will lift out. There's another core bore cut there.
13 So it's been partially cut with a core bore machine 14 and will be fully cut into four pieces with a plasma arc.
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15 Again, these are spots where the core bore drill cut.
16 It had been welded at that location there.
17 Also we've done some cleaning so that the top of this 18 plate is relatively clean now. In an earlier picture it had 19 some debris 6n it. l 20 In the pressurizer, we removed loose fluffy material.
21 Under it we found some gravelly material. And this ic a mini-
. 22 submarine that was put in the pressurizer and was actually 23 maneuvered hydraulically with motors and on the front of it 24 there is a claw type pickup device and we've been picking up 25 that gravel with these claws here'and putting.them in a small l Heritage Reporting Corporation (202) 628-4688
10 1 bucket which is then removed.
2 Here is again some of the gravelly material. Here 3 are the claws on the mini-submarine and you can see it's 4 picking up some of the gravel.
5 Later on we devised a scoop type device which went on 6 these draws and actually the material was then scooped up 7 rather than picked up.
8 I've got a second brief tape. It's a tape taken by 9 the rover robot in the basement. Obviously, the rover robot is 10 not a very good camera person because the tape is not real 11 good.
12 Here the rover robot is holding a cutting wheel and 13 it's cutting a square section of screen away from the surface 14 of the block wall in the basement around the inclined stairway.
15 This is the block wall that has the large amount of 16 strontium and cesium in the cinderblocks.
17 When this window was cut in this screen, we then come 18 in as you'll see with a hole cutting device to cut a hole, cut 19 several holes in the cement blocks and then we'll pump water 20 into the interior of the cement blocks and flush water down i
21 through the wall which is predicted to remove a considerable 22 amount of the reactivity that is currently absorbed in the 23 concrete blocks.
24 Again, this TV camera is mounted on the rover and 25 allows the operator to control the rover. This is now rover Heritage Reporting Corporation (202) 628-4888
t 11 I with a differe'nr tool the hole cutting device, and we're 2 cutting a two and a half inch diameter hole in-the cinderblock 3 and you can see the grout lines and this is the regular 4 cinderblock that most of us are familiar with.
5 There's about 40 of these holes that are being cut. .
6 And water will be introduced into the wall through the holes 7 and allowed to flush through the blocks from the center out.
8 As you talk about the environmental impact statement 9 later, I believe it is based on the assumption that this block 10 wall will not be reduced further in radioactivity so these 11 optional tasks which we're currently doing will be getting the 12 basement at lower radiation levels than the levels that the il environmental impact statement assumed.
14 That ends my presentation, iftherewere($$sLivna.
15 MR. GERUSKY: The gravel in the pressurizer, what is it 17 MR. STANDERFER: Well, it's a mixture of zirconium 18 oxide and fuel material which probably went into the 19 pressurizer as water was exiting the top of the pressurizer 20 during the accident as fine material. As it sat in the l
21 pressurizer over the last eight years, it slowly consolidated I 22 into a layer of material which when we disrupted it it 23 fractured into smaller pieces. But these pieces are friable.
24 As you squeeze them they break up so they aren't hard lumps but 25 they are consolidated fine material.
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12 1 In fact, there were some rocks larger than the 2 entrance hole to the pressurizer so we know they must have been 3 smaller when they originally were transported there.
4 MAYOR MORRIS: Ken? Neil?
5 DR. WALD: Can you'tell us the external radiation
. 6 measurements for that plate when it was called up that time, 7 five foot one?
8 MR. STANDERFER: Yes. In contact, these plates read 9 about 150 "r" per hour on the upper surface and 100 "r" per 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> on the lower surface.
11 There's about five inch thick web. This is almost all 12 cobalt 60, activation of cobalt from operation of the core, and 13 the prediction, calculated prediction would indicate that you 14 would have about a 50 percent higher level on the top as from 15 the bottom as you move away from the core and this -- these 16 radiation levels correspond fairly closely to what was 17 predicted.
18 The plates on the sidewalls where the bolts were are )
19 about 1000 "r" per hour so they're about eight' times more 20 radioactive than cobalt 60 than that lower grid.
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21 DR. WALD: Is that related to the composition of the j
. 22 metal?
23 MR. STANDERFER: Well, related to the core neutron 24 flux profile. And early in core life, most of the power is 25 being generated around the belt line in the center of the core.
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I 13 1 As you get 20 and 30 feet away from a plate like 2 that, people can.be in the building as they're moving and the 3 radiation is of course when you get up close.
4 MAYOR MORRIS: Does anybody else have any questions?
5 If not, thank you, Frank. And we could move on now if we may
- 6 to the third item, which is the status of the Accident-7 Generated Water Hearing - NRC Staff.
8 STATEMENT OF DR. WILLIAM D. TRAVERS, CHIEF, EMERGENCY 9 PREPAREDNESS BRANCH, THE UNITED STATES NUCLEAR REGULATORY 10 COMMISSION 11 DR. TRAVERS: I'm Bill Travers of the NRC Staff. And 12 Mike Masnik left some items which referred to the status of the 13 current Accident-Generated Water hearing.
14 Number one item of note is the fact that the 15 licensee, GPU Nuclear, has filed a motion for summary 16 dispcsition of the contentions which have been raised by 17 intervenors in the proceeding and I understand that this was
- dblac 18 done on May 9th and 16th.
19 (Continued on the next page.)
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aob 1 The staff and intervenor responses to this motion 2 are due the week of June 20th, and the responses can either ,
3 support or oppose the motion made by the licensee for summary 4 disposition.
5 Basically, summary disposition would allow, at this i
. 6 point in the proceeding, the elimination of either some or all 7 of the contentions which have been raised for possible 8 inclusion in the formal part of the hearing.
9 Any party opposing the licensee's motion has an 10 opportunity to respond to any new argument contained in the 11 licensee's motion, and apparently that process, according to 12 Mike, would take us to about July 5th, at least on time line.
13 The board then reviews all previously submitted 14 information and determines which, if any, of the contentions 15 will be dismissed and which, if any, will go to formal hearing.
16 Mike Masnik estimates a board ruling by early August, 17 wit's writtee testimony due by early September, and a possible 18 start of the hesring by late September. That's an I
19 approximation of Mike's best understanding of the way events i 20 are developing on the hearing.
21 MAYOR MORRIS: Any questions from the panel on that?
. 22 Okay, Bill, any other comments?
23 DR. TRAVERS: Not on the hearing, and no other status
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24 items. The next agenda item I'm prepared to speak to is the 25 Supplement No. 3 to the programmatic internal impact statement.
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1 MAYOR MORRIS: Well,-why don't we just go right into 4
2 that.
3 DR. TRAVERS: Okay. Thank you. i 4 We are here to discuss the staff's recently published 5 draft Supplement 3 for the Programmatic Environmental Impact
. 6 Statement rhich deals with GPU Nuclear's proposal to place the 7 TMI 2 facility into storage following of completion of the 8 current activities regarding defueling.
9 By way of introduction, I should note that during the 10 preparation of this document, I was the director of the Three 11 Mile Island Cleanup Project Directorate. That organization no 12 longer exists as it did in the period during preparation of the 13 document. Currently, I am the chief of the Emergency 14 Preparedness Branch and I am physically located in Rockville, 15 Maryland.
16 With me, by way of introduction, is Becky Harty and 17 Becky is the project manager for Pacific Northwest 18 Laboratories. The NRC staff contracted with Pacific Northwest 19 Laboratories to assist us in the preparation.of the draft and ,
20 final documents related to GP's proposal to store-the facility.
21 Linda Munson also assisted in the preparation of the 22 document, and Linda, who was once with Pacific Northwest 23 Laboratories, is recently a private contractor.
24 I'd like to point out that with us this evening is 25 Oliver Lynch who also assisted. Oliver is a section chief in l
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'U 16 1 the radiation protection branch, and he'll be available to 2 answer any questions you may have later on with regard to the 3 way the staff estimated health effects attributable to'the 4 activities in the alternatives evaluated in Supplement 3.
5 The Supplement dated April 1988, as I mentioned, a 6 deals with GP's preposal to place TMI 2 into monitored storage 7 following completion of the current defueling. Specifically, 8 the draft supplement evaluates the environmental impacts of the 9 licensee's proposal to store the facility and to defer full 10 completion of the cleanup. It also evaluates the environmental 11 impacts of a number of alternatives including proceeding 12 immediately to complete the cleanup without any storage period.
13 The supplement to the original 1981 PEIS which 14 evaluated environmental impacts from the entire cleanup process 15 was necessary since the original evaluation did not include an 16 assessment for the environmental impacts associated with the 17 proposed storage period.
18 As was done with the original PEIS and its previous 19 supplements, this supplement is a draft and the NRC staff is 20 seeking comments from appropriate federal and state agencies, 21 from the public and, of course, from this panel.
. 22 It should be noted that the original 45-day comment 23 period will formally be extended as a result of a number of 24 informal comments that we, the NRC staff, has had since 25 issuance of the draft, including a discussion with the panel Heritage Reporting Corporation (202) 628-4888
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17 1 chairman and Mike Masnik. I'm not sure, I don't have offhand, 2 the date, the actual date that it will be extended to but 45-3 days, I believe, takes us to near the end of --
4 MS. HARTY: July.
5 DR. TRAVERS: -- end of July. All comments on the
- 6 draft will be addressed in the final report which is 7 anticipated to be completed in September.
4 8 Let me turn now to Becky Harty who, as I mentioned, 9 is with Pacific Northwest Laboratories, a project manager for 10 the preparation of this document, and she is going to give you 11 a little bit of an in-depth presentation on what.went into the 12 document.
13 Linda Munson, Oliver Lynch, Becky Harty, and myself 14 will be available following the presentation to answer any 15 questions you may have.
16 STATEMENT OF: BECKY HARTY, PROJECT MANAGER, PACIFIC NORTHWEST 17 LABORATORIES l
18 MS. HARTY: My name is Becky Harty. The first thing j 19 I would like to do is give an overview of the organization of 20 the supplement and then I'll go into the details later, j i
21 As you can see, we have six sections and the first is !
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- 22 an introduction. The second deals with background information 23 affecting the cleanup alternatives and that gives an overview ,
i 24 of the cleanup progress to date. It gives the characteristics l 25 of the radioactive material that is currently in the' facility, s
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l 18 j 1 and.the regulatory and administrative considerations that are 2 associated with completing the cleanup.
3 Section 3 is the proposed and alternative plans for 4 completion of the TMI 2 clean up, and it includes a description 5 of the alternatives that were considered but not evaluated
. 6 quantitatively, as well as the basis for not evaluating them 7 quantitatively, and it gives a description and an analysis of 8 GPU Nuclear's proposal of post-defueling monitored storage, as 9 well as immediate clean up which is the alternative that was 10 evaluated quantitatively by the NRC staff, and I'll explain why 11 they came up with that one.
12 Section 4 is the effected environment, and it 13 includes the Three Mile Island site facility, the Susquehanna 14 River, Chesapeake Bay area, waste transportation routes, and 15 off-site disposal locations.
16 Section 5 is a comparison of the environmental 17 impacts of the late and immediate clean up.
18 Section 6 is the conclusions.
19 In addition, we've added a summary, list of 20 nomenclature, references, and an index, and there are some !
i 21 appendices. Appendix A is reserved for comments on the draft i
. 22 supplement, and six additional appendices provide further {
23 information on the assumptions and calculational methods that 24 were used in this report.
25 In Section'2.1 of the draft supplement, we discussed Heritage Reporting Corporation (202) 628-4888 I
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I 19 1 the conditions in the TMI 2 facility that were current as of 2 last January 1 and the activitie's that will-have to be 3 completed before the clean up process can be considered 4 complete.
5, For the purpose of this talk, I want to give a couple
- 6 definitions here. When talk about the end of de-fueling, we 7 mean the end of the current efforts to remove fuel from the 8 reactor, and when we talk about the end of clean up, we are 9 talking about the end point that was originally envisioned in 10 the PEIS.
11 According to the PEIS, the completion of clean up 12 will be achieved when four fundamental activities have been 13 completed. These activities are listed on the slide: building 14 and equipment decontamination, fuel removal and decontamination 15 of the reactor cooling system, treatment of radioactive 16 liquids, and packaging, shipment, and disposal of radioactive 17 waste.
18 At the completion of clean up, a decision would then 19 be made either to de-commission the fac3'ity or to refurbish 20 it.
21 These four activities are currently in various stages l 22 of completion and further progress is expected by the end of 23 defueling. I'm going to go through them one by one, and they 24 are highlighted there on the slide, which ones I'm talking 25 about.
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1 First, building and equipment decontamination. The 2- general area of radiation levels in the reactor building vary.
3 They are quite high in the basement where a lot of the 4 contamination remains, especially in the concrete block of the 5 elevator stairwell structure. And further decontamination in 6 this area will be necessary.
7 The general area dose rates on upper elevations are 8 low enough for access at the present time. However, additional 9 decontamination will be needed in these areas before the clean 10 up can be considered to be complete.
11 In the auxiliary fuel handling building most area 12 exposure rates are near the level of an undamaged reactor at 13 the end of life and continued decontamination is now occurring 14 and will continue through the end of the defueling in the 15 auxiliary fuel handling building in the basement.
16 The majority of the fuel, Item No. 2, will be removed 17 from the reactor at the end of the current defueling efforts.
18 According to GP Nuclear, there will be some fuel present. The 19 estimate in the supplement is 55 to 320 pounds, that estimate 20 was given to us by GP Nuclear, to be present in the reactor 21 building, either inside the reactor coolant system or in 22 several areas that are outside the reactor coolai? system.
23 Although we assumed in the supplement tl ; all the 24 fuel present in the reactor vessel would be removed by the end 25 of defueling, it now appears that some fuel may be left in the Heritage Reporting Corporation (202) 628-4888
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1 vessel.
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2 Treatment of radioactive liquids is the third item.
3 Although the question of final disposal of accident generated 4 water has not yet been resolved, it's expected that the water i 5 will have been processed. Either run through the Epicore 2 l
6 system and/or the submerged demineralizer system. Before or 7 surely it will have been processed shortly after the reactor l 8 vessel's been defueled.
l 9 Also, packaging, shipment, and disposal. Although 10 partially completed, it is expected to be finished shortly 11 after completion of defueling.
12 We looked at six alternatives to GP Nuclear's l
13 proposal. One was evaluated quantitatively, in addition to l
14 GP's proposal, which is referred in this supplement as delayed 15 clean up.
16 All the alternatives are considered to have a common 17 starting point and a common ending point in order to facilitate 18 the comparison. The starting point, as you can see on the 19 slide, is the completion of defueling. The ending point is the 20 completion of clean up.
21 Next, what I'd like to do is a give short description 22 of GP's proposal on delayed clean up and then I'll go back and 23 describe the six alternatives that we came up.
24 Delayed clean up involves three steps. The first is 25 a preparation of the facility for storage. The second is Heritage Reporting Corporation (202) 628-4888
l 22 1 maintenance of the facility in the storage mode. .This would be 2 a monitored storage mode. And the third is to complete clean 3 up following storage.
l 4 In general, before storage major portions of the l 5 reactor building and the auxiliary fuel handling building would
. 6 be decontaminated, but not to the extent that clean up would be 7 considered. Aqueous systems would be drained. Sections of the 8 reactor coolant system would be deactivitated and sealed as 9 necessary to contain residual fuel particles, and fuel transfer l
10 tubes would be sealed.
11 Systems and equipment not needed during the storage 12 period would be deactivitated. Those that are expected to have 13 some storage would be preserved. During storage, the reactor 14 building and auxiliary fuel handling building would be locked.
15 Periodic entries would be made to inspect, monitor, and to 16 maintain the facility, and r; identify changes in radiation 17 level, water intrusion, or other unexpected conditions, as well 18 as for equipment surveillance. No regular program of 19 decontamination is expected unless inspections indicate that l l l l
20 contamination has spread or if decontamination is necessary for 21 maintenance. Routine waste processing and shipping would be
. 22 performed for those activities generated as a result of storage 23 activities.
24 Following the end of the storage period, the 25 decontamination process would be resumed until clean up is l
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l 23 1 considered complete.
2 The environmental impacts of delayed clean up will be
- 3 discussed in a minute, but now I'd like to run through the six 1
4 alternatives that we looked at in keeping with, to meet.the 5 requirements.
6 The six alternatives are immediate clean up, 7 immediate clean up with a reduced level of effort, additional 8 clean up before storage, delayed clean up with a storage period l
9 less than twenty years, delayed clean up with a storage period 10 longer than twenty years, and no further clean up following 11 defueling. So, I'm going to explain these one at a time.
12 The principle alternative is immediate clean up. It 13 involves continuing and completing the clean up at the present 14 level of effort without a storage period.
15 This clean up would continue at the present level of 16 effort using a work force the size of the current work force.
17 In would require additional decontamination of the reactor 18 coolant system in the reactor building and then shipment and i
i 19 disposal of the resulting wastes to get to the end point where ]
20 the general area dose rates in the reactor building are
, l 21 comparable to those from an operating plant at the end of its 22 life. The impacts will be discussed in greater detail.
23 I want to now move on the to the second alternative 24 which is immediate clean up with a reduced level of effort.
25 The same procedures as described in the previous i
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24 l 1 alternative occur except there is smaller work force and a 2 longer period of time for the clean up effort.
3 The impact that we saw that would occur with this l
l 4 alternative would fall between the impacts of alternatives of i
5 delayed clean up and immediate clean up, and so it was not l- 6 considered in greater depth.
7 The third alternative is additional clean up before 8 storage. It would involved completing more extensive j 9 decontamination and clean up than that proposed by the licensee 10 before entering the storage phase.
11 This would reduce the radiation dose rates and the 12 radionuclide inventories below the licensee's stated goal for 13 delayed clean up or PDMS.
14 It's actually a combination of the alternative of 15 delayed clean up and immediate clean up. So, again, the 16 environmental impacts are encompassed and not considered 17 further. j 18 The fourth alternative is delayed clean up with a 19 storage period shorter than twenty years. The staff limited !
20 its evaluation of delayed clean up to a period of twenty years. {
21 So, storage periods of less than twenty years are encompassed
. 22 by the impact of immediate clean up where the storage is for 23 zere years and delayed clean up where we assume the storage is 24 for twenty years.
25 The fifth alternative, delayed clean up with storage Heritage Reporting Corporation (202) 628-4888
25 1 longer than twenty years, is feasible but we decided it was 2 best to evaluate it on the basis of experience gained from l 3 shorter tcrm storage periods and so we could look at it 4 farther.
5 The sixth alternative is no further clean up
. 6 following defueling. This is the no-action alternative that's 7 required by NEPA. The no-action alternative for this period, i.
8 for the period addressed by the supplement, implies that no 9 further action is taken to complete the clean up. In other 10 words, you finish defueling but instead of placing the facility ,
11 in storage or instead of completing the clean up, you just walk l
l 12 away from the facility. '
l l 13 The NRC staff has maintained, as a matter of policy, l i
! 14 that the clean up must be completed, and although neither l 15 requires that this alternative be considered the staff- i 16 considers that the no-action alternative is unacceptable.
l 1
17 An indepth evaluation was made of the two l 18 alternatives: delayed clean up and immediate clean up -- and I 19 think we're six slides past that -- number 23.
20 To facilitate a comparison, there is a common l
21 starting point and a common ending point. The common starting
. 22 point coincides with the end of current efforts to remove 23 damaged fuel.
24 Before this starting point occurs, additional 25 activities are assumed to have been performed, that are being l Heritage Reporting Corporation (202) 628-4888
26 1 performed now and will continue to be performed.
2 One is further decontamination of building and 3 equipment surfaces. The next is packaging and disposing of 4 radioactive wastes that's generated during the decontamination 5 and defueling activities, and removing the accident generated 6 water from the reactor building and also the refuel handling 7 building.
8 In addition, a quantification of the amount of 9 residual fuel left in the reactor coolant system in the reactor 10 building following defueling efforts.
11 The common ending point is the completion of clean 12 up, as we described earlier.
13 At this point, the following activities will be 14 completed: decontamination of buildings and equipment to a 15 level of an operating reactor at the end cf its lifetime, 16 complete removal of residual fuel, and decontamination of the 17 reactor coolant system, and final treatment of radioactive 18 wastes, and also the completion of the packaging, shipment and 19 disposal of the wastes.
20 Following completion of the clean up, additional 21 activities wculd be required either to de-commission the 22 facility or to returbish it. !
I 23 I have the graphic representation of the starting and 24 ending points so that you can see clearly what we're looking 25 at.
Heritage Reporting Corporation (202) 628-4888 l l
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27 1 The first is for delayed clean up, and you can see 2 the starting point is where the defueling is complete. At-that
- 3 point, the facility would be stored for what we assumed was 4 twenty years, and then there would be a clean up which we 5 assumed would take about four years, and at that point the 6 clean up would be complete and a decision would have to be made 7 whether to de-commission, refurbish, or store the reactor 9 again.
9 Immediate clean up, on the other hand, the second 10 alternative we looked at, has the same starting point:
11 completion of defueling. The completion lasts three to 12 four -- the clean up lasts three to four years, at which time 13 the clean up is complete and a decision again will have to be 14 made whether to de-commission or for additional storing of the 15 facility, i 16 The following impacts were evaluated. We looked at 1
17 the outside dose. We evaluated that for both routine releases 18 and accidental releases. We looked at the applicational 19 radiation dose, the waste management impacts.which include 20 transportation impacts, both accidents and routine 21 transportation impacts, and it also includes the waste volume 22 estimates. We looked at direct socio-economic impacts, the 23 commitment of resources, and the regulatory considerations.
24 Now, I'm going to go through these one at a time.
25 I'm going to start with -- I'm going to briefly describe what l
Heritage Reporting Corporation (202) 628-4888
I 28 i
1 we looked.
2 I'm going to start with delayed clean up where there 3 are three stages: preparing of the facility for storage, 4 maintaining of the facility during the monitored storage 5 period, and completing the clean up.
~
6 In the first stage, the preparation stage, it 7 involves modifying, deactivating, and preserving plant systems.
O 8 The activities are minor and they are not expected to increase 9 the amount of airborne or waterborne contamination from those 10 that are currently occurring.
11 During the second stage, maintaining the facility in 12 the PDMS storage mode, we looked at routine releases, both 13 atmospheric and liquid releases, and we also looked at an 14 accidental release and the only one that we came up with that 15 we felt would be valid is a fire in the reactor building.
16 For this evaluation, we assumed that the fire would 17 be in the location of the largest amount of contamination which 18 is the concrete block, stairwell elevator shaft structure in 19 the basement.
20 During the third state, clean up ' 'owing PDMS, 21 following storage, we also looked at routine releases, both l
22 atmospheric and liquid, and we came up with four accident i
23 releases. The first was the fire in the basement, the second 24 was a HEPA filter, high efficiency particulate air filter, !
25 failure which could happen due to physical damage such as
' )
Heritage Reporting Corporation (202) 628-4888 1
29 1 puncture or because of extreme pressure differentials or 2 because of water damage over a long period of time.
3 We assumed that this failure would be during the 4 critical time in the clean up process when the largest amount 5 of airborne activity was present, and then we could get the 6 worst case estimates on the effect.
7 The third accident was an accidental spill of 8 decontamination solution during decontamination of the reactor 9 cooling system, and we looked at the effects that going into 10 the reactor building atmosphere and then out of the building.
11 We also looked at an accidental liquid release. We 12 had to make the assumption that during clean up, contaminated 13 liquids might just, might be partially processed and could 14 potentially be stored in tanks before being processed through 15 the Epicore 2 system. So, we looked at the rupture of the 16 11,000 gallon storage tank of partially processed water and the 17 release of that to the Susquehanna River.
18 For immediate clean up, where as you will remember 19 there's only a clean up phase, there's no storage phase, we 20 looked at routine releases, both atmospheric and liquid, and 21 the same four potential accident releases that I described
- 1 22 earlier for delayed clean up: the fire in the basement, the 23 rupture of the HEPA filter during decontamination activities, 24 spill of decontamination solution, and the rupture of the 25 storage tank. !
Heritage Reporting Corporation (202) 628-4888
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30 1 So, now we have identified the alternatives and the 2 routine and accidental releases that we've considered, and now 3 I would like to discuss the results of the releases, evaluated 4 in terms of radiation dose to'the outside population. <
5 ,
The radiation dose, as we calculated it, is reported 6 as a 50 year dose commitment. This means this is the total 7 amount of radiation that would be received from the initial 8 exposure through the succeeding fifty years.
9 It was calculated for three groups of people: a 10 maximally exposed individual, the total population residing 11 within a 50-mile radius of.the plant, and the population 12 outside the 50-mile radius.
13 Now, I'd like to address the routine dose estimates.
14 This table indicates that the dose estimated for the entire 15 period of clean up. This includes the 24-year period for 16 delayed clean up and the 4-year period for immediate clean up.
17 The numbers that are not in parentheses are the total 18 dose for that scenario for, like delayed clean up or immediate 19 clean up. Foi the delayed clean up for the maximally exposed 20 individual total body is for milliren, for example.
21 Now the numbers in the parentheses are estimates of 22 the annual dose. That's the averago annual dose. So, for 23 instance, with the delayed clean up, it takes twenty-four years
]
24 for the whole thing to occur, and so we divided the numbers in 25 the first column by 24 to get the numbers in the second column.
l 1
Heritage Reporting Corporation (202) 628-4888
31 1 The same for immedicto clean up, where we divided the numbers 2 in the first column by 4, which is how long we estimated that 3 would occur to get the numbers in the second column.
4 Delayed clean up, as you can see, gives a greater 5 total dose, but when viewed as an annual dose the results are G the same or slightly higher than for immediate clean up.
7 I'd like to point out that the doses are all below 8 the ahnual limit of 25 milliren per year for the total body for 9 routine exposures to the general population. Also, that the 10 population dose that you see there is for a population of 11 between 2.2 to 3.2 million persons. We figured an i:. crease of 12 2.2 million people during 1988, '89, up to 3.2 million people 13 twenty years from now.
14 The dose estimates you see there are high. For the 15 purpose of analysis we made some very conservative assumptions, 16 but we're convinced that the actual doses would fall well 17 within the limits that we evaluated in the impact statement.
18 This next slide is a comparison of the annual dose 19 from background for the maximally exposed outside individual 20 and for the population within a 50-mile radius.
21 You can see that the annual background dose for the
. 22 maximally exposed individual in this area is 87 milliren per 23 year. The annual dose from delayed clean up is .2 percent of 24 that dose, and the same for immediate clean up. They came out 25 the same, well, very close to the same.
Heritage Reporting Corporation (202) 628-4888
32 1 The population within a 50-mile radius, the annual 2 dose from delayed clean up or from immediate clean up is like 3 3 one-thousandths of a percent of what you would receive from 4 annual background dose.
5 The next slide shows the range of doses from the 6 accidents that we assumed.for this analysis. There's a range 7 given because of the four different scenarios I described 8 earlier. We just lumped them all together on this slide.
9 These doses are also a small fraction of the 10 regulatory limits.
11 _The next slide shows the occupationa). dose impacts.
12 For delayed and immediate clean up alternatives, we looked et 13 the occupational dose on a task by task basis, and it's 14 presumed there's a range of values beccuse there's 15 uncertainties with the clean up process and the technology that 16 will be available, for instance when post-storage clean up is 17 performed twenty years from now and the kind of technology I'm 18 talking about is, like, robotic technology.
19 For a delayed clean up the estimates we made ranged 20 from 48 to 1500 personren, and this is over the entire 24-year 21 period. For immediate clean up the range is from 300 to 3100 l l
22 personren, and that's over the four year period. )
23 During the storage period and the clean up following i
24 storage, we estimated the impacts and the volume of waste that !
25 would be generated.
Heritage Reporting Corporation (202) 628-4888 I
i
l 33 l
1 For a delayed clean up we estimated a range of i
2 between 33,000 and 74,000 cubic feet of waste. This would be 3 transported to a low-level waste site, and we assumed that ,
l l
4 waste generated before and during the storage period that would-5 be disposed at the current re-license site near Richland, <
, 6 Washington.
7 The clean up following the storage period, we assumed i~
l 8 that the waste would be transported to an unspecified site l l
9 approximately or closer than 500 miles from the plant.
- We did l 10 this because for the current requirements for a regional site i
11 that are given in the Low-Level Waste Policy Amendments Act, 12 For a delayed clean up we estimated between .5 in one traffic 13 accident.
14 The column on the right should have said immediate 15 clean up. It just says clean up, but that is immediate clean 16 up.
17 We estimated a range for the volume of waste from l 18 32,000 to 70,000 cubic feet, and for the immediate clean up l 19 scenario we assumed that although low-level waste would be 20 transported to the low-level waste site near Richland, i
21 Washington and because of the larger distance required between
. 22 that, and assuming that some of the waste just and during 23 delayed clean up would just be transported less than 500 miles.
I 24 We came up with a larger number of traffic accidents, ranging 25 from 1 to 3.
Heritage Reporting Corporation (202) 628-4888 l
l t
34 1 The next slide shows the direct socio-economic 2 impacts. For delayed clean up, when you put the facility in 3 storage, it would be accompanied by a work force reduction from 4 the current levels, which are approximately 1150 persons to a ,
5 level of about 70 to 75 persons. This eraployment reduction is 6 about . 2. percent of the local base line of employment.
7 During clean up following the storage period, the 8 work force size would increase. For immediate clean up, the 9 present work force size would continue, about 1150 workers and 10 it would be maintained for the three to four clean up period.
11 For commitment of resources, we looked at the space 12 that would be required in the low-level waste site, and I 13 talked about that earlier on. I talked about the volumes that
. 14 would be generated of waste.
15 We also made estimates of the costs. These are rough 16 estimates and are made only for the purposes of comparison.
17 They were made in 1988 dollars for both scenarios.
18 The range in costs that we estimated for delayed 19 clean up was $200-to-$320 million and for immediate clean up 20 from S179-to-$249.
21 The last impact we looked at was regulatory
. 22 considerations. Regulatory considerations would not prevent 23 either long term monitored storage or the immediate clean up of 24 a facility.
25 Now, we move on the health effects. First, I would Heritage Reporting Corporation (202) 628-4888 A
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35 1- like to define -- we're always talking about fractional cancer 2 fatalities, and that's really a difficult concept to get 3 across, because when you talk, for instance, on the slide about 4 .002 cancer fatalities we're not talking about some person's 5 hand or finger gets cancer. What we mean by that is that there 6 are approximately 2 chances in a 1000 that one fatal cancer 7 will occur in the population which is 2.2 million persons 8 living inside the 50-mile radius as a result of the clean up.
9 In other words, there are approximately 998 chances 10 in a 1000 that no cancers, no fatal cancers at all, would occur 11 in the entire population living within the 50-mile radius as a 12 clean up activities.
13 So, now, I'm going to go to the slide. Here we have 14 fractional cancer fatalities for the worker population, for the '
15 off-site population. We have genetic disorders in the outside 16 population, and traffic fatalities.
17 The estimated range of health effects is shown. The 18 health effects are quite minor. There's a slighter greater 19 possibility of a health effect in the worker population than in 20 any of the other populations.
21 You can see from this slide that very small 22 differences are observed in the health effects between delayed 23 clean up and immediate clean up. These differences are small.
24 Now, I'd like to turn to Bill.
25 DR. TRAVERS: Based on all of the things that Becky's Heritage Reporting Corporation (202) 628-4888
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36 C
1 just described, the staff came up with several conclusions that 2 are listed in the document, and I'd like to-just touch on them 3 now.
4 Based on our evaluation, the licensee's proposed 5 plan, as well as staff-identified alternatives, were found to 6 result in environmental impacts which would fall well within 7 applicable regulatory limits.
8 Both the licensee's proposed plan and staff-9 identified alternatives could be implemented without 10 significant environmental impact, and that applies both to the 11 work force as well as to the outside public. .
12 For all of the alternatives, impacts fall within the 13 original estimates that were made in the staff's 1981 14 Programmatic Environmental Impact Statement for the entire 15 projected environmental impacts for the clean up. ,
16 Neither delayed or immediate clean up, from our 17 review, is clearly preferable from the perspective of 18 environmental impacts. Although we did find that quantitative 19 of various impacts varied, differed, and you've seen some of 20 those differences displayed here on some of the tables, the 21 differences weren't great enough for us to make a conclusion 22 that any of the alternatives we looked at were clearly 23 preferable.
24 We further concluded that the no-action alternative, 25 that alternative which would not result in completion of clean 1
Heritage Reportic q Corporation (202) 626-4888
37-1 up, was not acceptable. Becky touched on this alrearty. It 2 basically would not remove the remaining residual risk that we 3 feel is associated with the conditions that exist at the plant 4 pending completion of clean up.
5 Finally, we concluded that the benefits of the clean
- 6 up outweigh the small associated impacts, and the licensee's 7 proposed approach to completing the clean up will not 8 significantly affect the quality of the human environment.
9 That's a rather legalistic and bureaucratic term, but 10 it's a finding that we have to make in compliance with the 1 11 National Environmental Policy Act.
12 Basically, it's' consistent with what we determined or 13 what we concluded in the 1981 Programmatic Environmental Impact 14 Statement. When we looked at no action, the no-action 15 alternative in that case, would not be -- would be not carrying 4
16 out the clean up. That was one of the alternatives that we had 17 to look at.
18 Consistent with what we concluded back then, we have 19 concluded that the activity and the action necessary to clean 20 up is justified in this case, as it was in our 1981 evaluation.
21 Now, we'd like to try and answer any questions you
. 22 may have regarding any of what we've presented or anything you 23 may have read in the document. I 24 I'd like to reiterate once more that this is a draft 25 document, and consistent with the processes that you'va been l
Heritage Reporting Corporation '
l (202) 628-4888 l l
l l
38 1 involved with in the past, with regards to supplements 1 and 2 2 to the PEIS, we will be reviewing all of the comments received 3 and they'll be addressed in the form of changes to the final 4 document, or in the case where we don't think changes are 4
5 warranted we'll say we didn't make changes in the final 6 document.
7 MAYOR MORRIS: Okay. Just to -- and we'll go to Ken (
8 first, but just to mention what the process will be here
> 9 tonight.
10 I'd like to have questions from the panel. We will 11 then take a short break. We would renew with questions from 12 the public.
13 I do want to, at some point, before we do that to 14 find out from the members who requested time on the agenda. I 15 did not receive, Tom Smithgall, the topic of tne subject you 16 would be talking on and, therefore, I didn't know where to put j 17 it on the agenda. So, I'd like to talk to you about whether 18 you would want to be first as part of the public comment or 19 whether you would prefer to defer your time and allow public 20 discussion on this item, and then take up your particular time.
21 So, maybe during the break you could share with me what you 22 feel we should do. 1 l
23 With that, I'd like to first ask Ken to make whatever 3 24 comments he wants to on this. 1 25 MR. MILLER: I would like to know, can you do a l 1
Heritage Reporting Corporation (202) 628-4888
l 39 1 comparison for us between the contamination levels that will 1 2 exist at tho end of the defueling period with the levels you 3 keep referring to that exist at the end of a useful life or an 4 operating reactor? You're talking about a factor of 2, 10, 5 1000?
- 6 MS. HARTY: The activity levels? Is that --
7 MR. MILLER: Your comment -- you kept referring to 8 the fact that you would like to see the plant cleaned up to the 9 point where it matched the levels of contamination present at 10 the end of the useful life of an operating reactor.
l 11 DR. TRAVERS: Yeah, but -- and, Ken, basically, we 12 were talking in the context of dose rates in general areas.
13 MR. MILLER: Right, but I --
14 DR. TRAVERS: And you're asking in the context of --
15 MR. MILLER: Can you give us some sort of a 16 comparison? Maybe they are already lower and you don't have to 17 do anything -- but I doubt that.
l 18 MS. HARTY: I think the levels that we're looking at ;
19 for general areas where people move through would be on the l 1
20 order of 10 to 15 millirenken per hour, the exposure levels.
21 In that, any operating facility or operating reactor then of
'. 22 its lifetime, there's going to be certain areas where the dose 23 rates or exposure rates are a lot higher than that. So, it's i
24 very hard to answer your question unless we talk about exact 25 areas, j
Heritage Reporting Corporation (202) 628-4888
40 1 DR. TRAVERS: But we can answer it in the context of 2 I think what you're getting at, and that is, in the basement,
~
3 in general areas, dose rates exist that are much higher than 4 those -- several hundred hour per hour, for example, which are 5 orders of magnitude higher than these that would exist normally 6 in a general area, such as basement of a reactor building, in a 7 reactor at the end of its useful life.
8 There are cubicles in certain areas even in reactors 9 that don't have accidents that would have rather high levels of 10 radioactive contamination. We recognize that, and our 11 discussion is qualitative to a certain extent, but for general 12 areas is quantitative down to about 10 to, say, 20 milliren per 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
14 In the auxiliary building, as Linda just pointed out, 15 is about at those levels. The work that's been completed, it's 16 been extensive since the accident, has resulted in a reduction 17 of the dose rates in those areas to about what you would expect 18 in a reactor that hasn't had an accident at about the end of 19 its useful life.
20 MR. MILLER: So, the regt. ired additional clean up 21 will be strictly concentrated on those areas that are still 22 unreasonably high?
23 DR. TRAVERS: I should point out that when we talk 24 about required additional clean up, we wanted to try to match 25 apples and apples. So, when we talk about the end of clean up j
Heritage Reporting Corporation (202) 628-4888
41 i
1 we wanted to try to take some criteria that would allow us, in 2 the context of different alternatives, to get a handle on the 3 differences in the environmental impacts that might result in 4 achieving those liinits.
5 So, strictly speaking, there's no clean up 6 requirement on the books. What we've done in trying to scope 7 out environmental impact is try to get a-handle on the 8 environmental impacts that would result from the additional 9 work. For example, in the reactor building basement. To bring 10 those levels down. Similar to what has already been done in 11 the auxiliary fuel handling building.
12 For example, worker dose has been accrued in the 13 conduct of those operations. Worker dose sould necessary be 14 accrued in bringing the dose rates down in the reactor building 15 basement. Those are the kinds of things that we attempted to ;
I 16 quantify with somewhat of a broad range, admittedly, i l
17 MAYOR MORRIS: Tom. I 18 MR. GERUSKY: You made a comparison between a four
]
19 year clean up and a twenty-four year delayed clean up with a 20 total exposure comparison for four years and twenty-four years.
21 Would there be any environmental impact or any 22 exposure to the public following the immediate four year clean 23 up and after the twenty-four clean up that has not been taken 24 into consideration in comparing the two?
25 DR. TRAVERS: If I understand your question, the Heritage Reporting Corporation (202) 628-4888
. 42 1 answer is yes. And, again, for the purposes of scoping out our 2 document, we cut it off at we've defined the end of the clean 3 up.
4 For example, if the plant were cleaned up 5 immediately, I can envision -- it's still sitting there. It
- 6 still exists. There's still some residual contamination and 7 some level of environmental impact that could be projected for 8 some period of time prior to its de-commissioning.
9 So, the answer to your question is yes. And we did 10 it deliberately, again, so that we could, in a relative sense, 11 compare different strategies for completing the clean up. We 12 cut it off.
13 MR. GERUSKY: But you don't think that the public and 14 we ought to have a feel for what those doses are, what are 15 those environmental impacts are, for the same periods of time 16 until de-commissioning, assume you go to de-commissioning?
17 DR. TRAVERS: If you're addressing clean up, the 18 completion of the clean up, and that's what we're addressing, 19 those doses aren't the factor. They would certainly be much 20 lower and well within the kinds of numbers that we're kicking 21 around in this document today.
. 22 Again, the purpose of an environmental impact 23 statement, in this case, is to compare different strategies for 24 completing the clean up, completing those activities --
25 MR. GERUSKY: You're comparing twenty-four years Heritage Reporting Corporation (202) 628-4888
43 1 versus four years, and shouldn't you_ compare 24 to 24? That's 2 what I'm_asking. If you're going to an end point, shouldn't 3 the end point be the same for the exposures for both options?
4 MS. HARTY: The end point would be completion of 5 clean up after it's completed, whether it's de-commissioned or
. 6 whatever. There would be a separate action that would be taken 7 then and a separate document would be produced at that time.
8 That's generally what happens, as I understand it after a 9 reactor finishes its lifetime if they're going to ae-commission 10 it.
11 DR. TRAVERS : Yeah, but I.think --
12 MS. HARTY: No -- oh. We have -- We did look for 13 just basis of comparisons, what type of effect would occur 14 during the twenty years after immediate clean up.
15 I can show that to you if you'd like.
16 MR. GERUSKY: Is that in the document?
17 MS. HARTY: No, it's not in the document because the 18 document dealt only with the period of time for total l
19 completion of -- ;
20 DR. TRAVERS: We cut it off, but as an aside we !
21 attempted to evaluate those kinds of impacts.
'. 22 MS. HARTY: Here's -- the numbers. Here, this is for 23 a 20-year period of releases after immediate clean up.
24 MR. GERUSKY: This was not pre-planned, people. I 25 did not expect them to have this.
Heritage Reporting Corporation (202) 628-4888
44 1 DR. TRAVERS: We appreciate the question.
2 MS. HARTY: Yes, thank you very much.
3 You can see we have listed -- it's a 50-year dose 4 commitments from this 20-year period of releases ofter 5 immediate clean up, and we looked at it for the same three 6 population groups we looked at last time. These numbers are 7 smaller than they were for the 20-year period.
8 Delayed clean up, as you wou1d expect, because we 9 expected that a lot of that activity in the basement would be 10 cleaned up, contamination in the stairwell, and also the 11 reactor coolant system, but those are the numbers there.
12 For the record, it's maximally exposed individual the 13 critical argument would be bone, and that's 2 milliren. For 14 the total body it would be 0.2 milliren.
15 For the total population within a 50-mile radius, the 16 dose to the entire population would be 1.3 personren to the 17 volume and 0.7 personrens to the total body.
18 For the total population outside the 50-mile radius, I
19 we looked at that dose, too. The critical, arguing the bone 20 dose, would be 0.06 personren and the total body would be less 21 than 0.02 personren.
22 MR. GERUSKY: And that's for twenty years?
23 MS. HARTY: That's for a 20-year period, but the 24 problem comes in though, after immediate clean up we don't know 25 that the reactor would sit there for twenty years. That has
- Heritage Reporting Corporation (202) 628-4888
-__-____---._____-__________2____--___________--.
45 l 1 not been decided. It'hasn't even been decided whether to do 2 immediate clean up or delayed clean up.
3 MR. GERUSKY: Thank you.
4 MS. HARTY: Sure.
5 MR. GERUSKY: Can you provide that document to us?
. 6 >
DR. TRAVERS: Yes.
7 MS. HARTY: Oh, yes. I can.
8 MAYOR MORRIS: Neil, did you indicate? Anybody else 9 on the panel have any questions you want to ask at this-time?
10 I'd like to ask one, and I can almost guess the 11 answer but I'd lik.e to ask anyway. ;
12 Was there any attempt done to analyze, or is it part 13 of the study, to analyze the ability of the licensee to finance 14 this clean up? Whether they could financially afford to do it 15 immediately or whether, in fact, in twenty years from now 16 whether they'll be able to finance or be afford to do it at the 17 time?
18 DR. TRAVERS: That was not part of this evaluation.
19 In the context of the ongoing clean up, it's an ongoing 20 evaluation that is being done by the NRC staff. We are 21 continuing to monitor the licensee's financial health and i
- . 22 ability to carry out, to continue to carry out, the clean up i
23 effort, but as far as your question relates to long range, we 24 have not carried out that kind of evaluation.
25 We specifically haven't done it in this document.
1 Heritage Reporting Corporation (202) 628-4888
l 46 >
1 MAYOR MORRIS: Okay, but if it's not in this-
! 2 document, I would assume that the NRC would -- it would be a 3 consideration or a concern of NRC, separate from the PEIS, that 4 the licensee would be able to afford in. twenty years to do the ,
5 kind of work that needs to be done. Also, whether or not they 3 6 would have monies available now to do it, or else these l'
7 questions are kind of moot if there is a present financial 8 problem that the money isn't available or a future financial 9 problem.
10 So, it may be separate but I think it's a l 11 consideration, i
12 DR. TRAVERS: Absolutely.
j 13 MAYOR MORRIS: Whether you can determine those 14 factors, I don't know, but it's something that I at least i
- 15 thought of as I went through this.
- (
16 DR. TRAVERS: There's a parallel in the pending ,
17 Commission regulations on de-commissioning. You're right.
i
]
18 That's clearly an issue, that you'd want to have a warm feeling ;
19 about, that you were looking at a very long period of time.
] ;
20 MAYOR MORRIS: Yes, because you're talking about an j, 21 average cost for an immediate 1988 dollar average cost for i
i
- 22 immediate clean up of about $205 million and an average cost, j 23 if you average them, of $260 million in 1988 dollars, i j 24 So, financially, there's a fairly significant j 25 difference there, of some $55 million or so, or whatever that i
Heritage Reporting Corporation 1
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47 1- relates to percentage-wise -- 27 to 30 percent difference.
2 Joel?
3 MR. ROTH: Just a follow up on that. Is there any 4 provision'that the NRC can make to guarantee that the funds be 5 available at that time?
. 6 DR. TRAVERS: There's no provisions in the regulation 7 that I'm aware of that speak to it. I could be corrected, but 8 l'm not an expert in that area.
~
9 MR. ROTH: Okay.
10 DR. TRAVERS: This evaluation really did focus and 11 what we're most prepared to you tonight is the technical 12 evaluation that was done in looking at different alternatives 13 for completing the clean up.
14 MR. ROTH: No, I understand that, but I think this is 15 as good a time as any to put on the record the amount of 16 problems that occurred prior to getting all the funding just to 17 do the clean up and how that was a major battle on certain 18 stages.
19 Now, we're saying -- not we're saying, you're saying 20 that twenty years hence we're going to -- we believe the 21 utility will have the funds necessary to do that, and there's
. 22 no regulation or any way to make sure that does happen if, 23 indeed, you know, there is not a provision for it.
24 ' It seems to be almost to the point -- I'm not saying 25 it is the point, almost to the point -- that the utility could Heritage Reporting Corporation (202) 628-4888
- 48 1 walk away to a certain extent, through a reduction of work 2 force and all these other things, and twenty years hence the 3 time comes and the utility says: well, because of certain 4 problems, financially we can't really do it.
5 DR. TRAVERS: And that's not really a very viable :
. 6 scenario in my view.
4 7 This company holds, will continue to hold, a license 8 fer this facility until it de-commissions it. That's a 9 requirement.
10 The Commission continues to monitor the financial 11 health of the utilities that possess Part 50 Nuclear Power 12 Reactor Licenses. This utility also operates several other 13 plants.
14 MR. ROTH: Okay. I understand that --
15 DR. TRAVERS: My view is --
16 MR. ROTH: Okay. I think the point is, is that the 17 utility did not have sufficient funds to do the clean up by 18 themselves.
19 So, we're talking still many millions of dollars, and l l
20 I think the Commission in the past has always said, well, we )
21 really don't have control or we monitor, we look, but we.really
. 22 don't have -- and I think that's a real loophole, particularly 23 in this situation where you're looking twenty years down the 24 road and saying, yeah, ' hey'll be able to do it, but we really 25 don't have any provisions to make sure, other than, you know, Heritage Reporting Corporation (202) 628-4888 1
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1 j 49 l
l 1 licensing.
2 That's just a point. I think --
3 DR. TRAVERS: Yeah, and that's a valid concern. One l
4 of the things, or one of the areas, where the Commission has 5 addressed this concern, is in its de-commission rule which has I
l* 6 been proposed and is about to be issued in final.
7 That rule would require financial assurity to provide l 8 for ultimate de-commissioning nuclear facilities.
9 That rule will apply to TMI 2 and all of the nuclear 10 plants operated by GPU, as well as other utilities acrosc the 11 country.
12 So, it is an isaue, and it's one that's been 13 relatt.vely recently addressed more fully than it had in the l 14 past, i
l 15 MAYOR MORRIS: But if you -- just to pursue it a 16 little further, and to say that $260 million in 1988 dollars is 17 probably going to be three times more than that twenty years 18 from now, or something like $700 million. Probably. It's !
19 I probably going to get close to tripling that number.
20 We know that a billion dollars for the clean up was a big amount of money to even to try to assemble, and I'm just 4
21 l' 22 following up again on what Joel has indicated here.
l 23 I guess I would if the delayed clean up plan 1
24 ultimately is accepted, I would think what would go with that, 25 I would hope, would be some kind of a review by the NRC that Heritage Reporting Corporation (202) 628-4888 .
4 50 1 would require'some assurances thst money will be set aside over 2 a period, over the next twenty years, to have adequate funds' l 3 available to do the clean up, because they're big dollars.
4 -It's a concern that I express, at least at this time.
5 DR. TRAVERS : Yeah, that may be the kind of thing you 5 may wish to express to the Commission when it considers -- or 7 when you report to it on a regular basis.
8 MR. GERUSKY: Do you have an estimate of cost of de-9 commissioning TMI 17 10 DR. TRAVERS: There is a generic environmental impact 11 statement on de commissioning, I think. Is it $200 million --
12 does anybody -- I can't recall what it comes to.
13 MR. GERUSKY: And that's in today's dollar?
14 DR. TRAVERS: Yeah.
15 MR. GERUSKY: So, we're talking, say, ballpark "-
16 DR. TRAVERS: I'm throwing that number out, sir.
17 MR. GERUSKY: Yes, but it's still ballpark figures to 18 de-commissioning Unit 1 --
19 DR. TRAVERS: Yes, there was a reference study done.
i, 4
20 I forget.
21 MR. MILLER: Are the funds currently available to do
. 22 an immediate clean up?
l 23 DR. TRAVERS: Yes, wo believe they are, in the
] 24 context of our monitoring of the financial health of the 1
25 utility.
l Heritage Reporting Corporation (202) 628-4888 l 1
3
)
51 r
1 MR, GERUSKY: Is that out of the clean up fund or out r 2 of additional funds that the utility would have to spend on its t
! 3 own. I mean -- '
4 DR. TRAVERS: They can tell you best, but I'm 5 speaking from both the fund, the originally estimated $965-odd
. 6 million and the financial health overall of the company, as 7 monitored by NRC staff.
8 MR. GERUSKY: Okay, r
' l 9- MAYOR MORRIS: Any other questions from the panel at 10 this point? Okay. I'd just like to make, I guess, a couple of 11 quick observations and they're not so much questions although 12 maybe you can tell if I'm wrong, but when you look at the PDMS i 13 and the advantages and disadvantages of either way, it seems a 14 major point for delaying it, as I can see.
15 If it is a major point, and I'm not sure it is 16 because it doesn't seem to have been emphasized, but there's ;
i 17 less exposure to the worker and a chance that technology will l l
18 permit a greater ability to clean up in the future. They seem 19 to be the two main advantages.
20 The disadvantage to waiting, therefore the advantage
- 21 to doing it now, is that it is less costly to do it now than it
. 22 would be if it was waited. At least that's what the ranges 23 indicate, that it would be less costly by, again on average, by 24 a total of $55 million in today's dollars to do it now. j 25 As I read this and looked at it, I try in my own mind i
, Heritage Reporting Corporation (202) 628-4888 i
'52 1 to try to figure out why would you wait or why would you not 2 wait, and it just seems like -- I realize your conclusions were i 3 there doesn't seem to be a clear reason why one is better than 4 another.
5 DR. TRAVERS: Yeah. You're right, and we did note 6 quantitatively differences like occupational exposure. When 7 all is said and done, our estimate or the difference between 8 what it really would take -- you remember we give a range -- it :
i 9 might be larger or might bc smaller than what we estimated, but 10 based on our best ability to estimate, with a fair number of 11 uncertainties I might add, what those numbers would be, we 12 couldn't come to a firm conclusion that any of the different,
! 13 differing, levels of impact really drove the selection of l !
l 14 either of those two primary alternatives.
l 15 MAYOR MORRIS: And that's the very reason why I ,
16 stopped looking for a way to break that decision, and that's l
17 why money again, realizing you didn t look into the future 18 ability of the company -- that's why that starts becoming in my ;
1 19 mind, as one person, more of a factor and a concern, without '
i 20 hearing some of the comments that might come up following 21 questions by the public.
22 That's just an observation that I offer.
23 Any other questions by the panel or comments? If 24 not, we can break at this time a:.d then take the public comment 25 right after the break.
Heritage Reporting Corporation (202) 628-4888 1
4 I
53 i 1 (Whereupon, a brief recess was taken.) ;
2 MAYOR MORRIS: I'd like to start the second half of 3 the program if we could, and we now are into Item 7 which is t
4 public comment. Each of the individuals listed indicated that 5 they do have comment.to make on the PEIS Draft Supplement No. l 6 3.
7 The first person will be Frances Skolnick -- seems 8 like a very unfamiliar face.
9 STATEMENT OF: FRANCES SKOLNICK, SUSQUEHANNA VALLEY ALLIANCE 10 MS. SKOLNICK: At least, except for I, or none of us 11 'might be around much longer, either.
12 Actually, when I was sitting back there and looking :
13 over here, I was struck by the, like, dart, trying to hang it 14 over everybody's head. It just seemed as if everybody felt 15 like a deep feeling of hopelessness and that everything was 16 decided anyway, but anyway we will speak on regardless.
17 I speak for the Susquehanna Valley Alliance whose l 18 membership resides mostly in Lancaster County and whose mental 19 and physical health stands to be impacted upon by any decisions 20 made about Three Mile Island. Following is a list, a summary, l 21 of our comments on the EIS Supplement No. 3.
22 I am submitting a list of questions which I would ask 23 to have answered in a timely manner so that I can review the 24 answers prior to submitting comments to the NRC.
25 Hot on the heels of the NRC's refusal to permit the l
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l 54 1 storage of the Accident Generated Water at Unit 2 until a more l
l 2 suitable method of disposal was found whereby the radioactivity 3 would be retained inside instead of dispersed into the l
4 environment comes their consent to permit the placing of Unit 2 ,
5 into a storage mode prior to the completion of clean up, so l . 6 that more suitable methods can be found to finish the'claan up. !
7 PDMS is only a fancy name to conceal the fact that 8 TMI will, after ell, become a site for the storage of 9 radioactive waste. Indeed, PDMS closely resembles the no-10 action alternative since there are no assurances that Unit 2 11 will ever be cleaned up. ;
12 The NRC speaks of a twenty year storage period but 13 provides no rationale for choosing this number. This licensee 14 refuses to commit itself. ;
15 Obviously, delayed clean up solves two problems for i
16 the licensee. j 17 One: they do not have to proceed with an area of 18 clean up which would preclude the re-start of Unit 2, and, 19 secondly,m they won't have to worry about the messy and 20 inconvenient problem of what to do with the waste.
21 NRC tells us that immediate clean up would require
. 22 additional emergency allocations. That's in EIS Page 2.33.
I 23 Not so long ago, we heard of NRC's commitment to 24 prevent TMI from becoming a site for the storage of waste.
25 This EIS clears the way exactly for that. This waste, mind Heritage Reporting Corporation (202) 628-4888 t
I
55 1 you, will be in out of the way places, not immediately 2 available for monitoring.
3 We are shocked that it will take at least four more 4 years and, who knows, it could be more to clean up Unit 2.. It 5 seems like only yesterday that we were being accused of holding 6 up clean up because we had asked for hearings concerning the 7 disposal of the radioactive water by evaporation.
8 I ask why generate more water when we have already 9 accumulated the major medium for decontamination?
10 One of our major concerns with leaving Unit 2 so 11 contaminated for so many years is based on uncertainties about 12 the amount of radioactivity la buildings, pipes, and other 13 components.
14 We are informed in the EIS that the number and 15 quantity of the majority of radionuclides are estimated from
- 16 the amount present at the time of the accident.
17 The amount present at the time of the accident is 18 based on a computer code Origen 2. A computer code is only as l 19 accurate as the data that a person puts in. So, there must be 20 allowance for errors.
l 21 Studies have been undertaken to follow the paths of
. 22 the radionuclides as they were released from the damaged core.
23 This is an ongoing project and, as one reads through any 24 research reports on the accident, one soon is very aware of the 25 uncertainties which exist as to how and to where the Heritage Reporting Corporation (202) 628-4888 k
56 1 radionuclides were dispersed.
J 2 The NRC itself recognizes this developmental aspect 3 of the clean up. They state in the EIS, and I quotes 4 "Although predictions have been made regarding the 5 transport and deposition of materials released as vapors and/or
!- 6 aerosols during core heat up, refine'd modeling methods are not 7 available for accurately analyzing the transport and deposition 8 of the fragmentation debris or the leaching of soluble 9 materials from the damaged core."
10 That's on Page 2.22.
I 11 They also s. tate that plans to decontaminate the i
12 reactor building, following PDMS, are tentative because the 13 licensee has, and i quote from the EIS, Page 3.10:
14 "Incomplete information, although currently being
]
15 obtained, on the amount and location of contamination." '
l f
16 Table 2.4 in the EIS, which shows an estimate of the j 17 maximum amount of radionuclides left and their location comes 18 as a complete surprise in light of these two statements.
19 We want to know upon what information this table 20 might be based. Furthermore, we want to have a complete 21 accounting of the radionuclides present in the core at the time
. 22 of the accident.
)
j 23 Looking at just two of the radionuclides, tritium, which the NRC failed to mention was an important activation 24 25 product, and Krypton 85, it is impossible to account for all of Heritage Reporting Corporation (202) 628-4888
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t 57 1 both of these radionuclides. .
1 2 There were over 8,800 curries of tritium and over 3 97,000 curries of Krypton in the reactor at the time of the 4 accident. How does the NRC end up with less than 1 curie of 5 both tritium and Krypton 857 ,
- 6 And we want answers, not only to those radionuclides, 7 but to all the radionuclides that are in that reactor before we 8 can really make the decision as to how radioactive that reactor 9 is.
10 The approval of TMI to become a site for the storage 11 of radioactive waste raises questions about regulatory 12 procedures and, furthermore, the acceptability of this plan to 13 the State of Pennsylvania.
14 If clean up were to continue presently, then the 15 waste would go to out of the state sites. If it is delayed, it .
16 will largely remain within the state. :
17 I'd like to know from the state tonight, how does the i 18 state react to that? Would the state site be able to 19 accommodate this amount of waste? Would it also be expected to 20 accommodate the waste if Unit 2 were to be de-commissioned?
21 I ask how can the NRC dismiss the question of the 22 impact of the waste disposal by saying that it would be the 23 subjact of an analysis elsewhere? The disposal of waste at TMI ,
24 is a major issue to be dealt with at this time and it is in 25 keeping with the requirements of the National Environmental !
l l
Heritaga Reporting Corporation l (202) 628-4888 -
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58 1 Policy Act.
2 Obviously, the people of Pennsylvania will be 3 impacted upon, not only by the possible transportation 4 accidents when taking the waste to a site, but also by the 5 possibility that the site will be located in somebody's back 6 yard in Pennsylvania.
7 How will the NRC deal with the fact that Unit 2 is in 8 the hundred year flood plain? Will it have to manoeuver the 9 regulations in some way that TMI will be exempt from the 10 requirements? Will TMI be able to satisfy the ground water 11 intrusion criteria?
12 All these questions have to be answered, i 13 The health impact section, so neatly resembleu all i 1
14 other such sections in supplements to the Environmental Impact '
15 Statements.
16 I wish to call the attention of the NRC to some 17 revisions of the dosimetry of the survivors of the Japanese 18 atomic bombs which, together with the now increased follow-up 19 time for epidemiological studies, are being taken into account 20 by the United Nations' Scientific Committee on the Effects of 21 Atomic Radiation in producing risk estimates fe. ionizing 1
l* 22 radiation exposure.
23 This report will be used by ICRP in reviewing its 24 recommendations on the system of dose limitations. 'A 25 preliminary reassessment of the Hiroshima and Nagtsaki Heritage Reporting Corporation (202) 628-4888 .
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59 1 survivors has raised the fatal cancer risk for the exposed 2 population by a total factor of the order of 2.
3 The risk estimates could be substantially greater, 4 depending on the form of risk model used and the shape of the 5 dosa response curve, when extrapolating to low doses from 6 observations at high doses.
7 The most important aspect of the finding to us, is 8 that the standards must continue to be changed so that the 9 public is protected against 1 unnecessary exposure to low level 10 radiation.
11 One final point, which I am addressing to you, Mayor 12 Morris.
13 On reviewing some of the City of Lancaster agreement 7 14 papers, I just wanted to make sure that $10,000, or $100,000, 15 whatever it was, will be forthcoming from the licensee during 16 the entire period that TMI sits uncleaned rai still 17 radioactive.
18 Because, since we draw our water supply from the 19 Susquehanna River, we want to make sure that the city has the 20 resources to continue to sample the water and to check for the 21 addition of the chemical solutions which will probably be used l l
. 22 in decontamination somewhere down the line, and we'd like to l 23 know what steps the city will take to monitor this, so that our 24 drinking water will be provided some sort of protection.
25 That concludes my comments on the EIS.
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60 1 Before I go, when the EIS Supplement No. 2 came out 2 back in 1987, Dr. Karl Morgan had submitted comments on that 3 statement, and they arrived rather late, and they were in 4 pencil, and I submitted at that time as they were.
5 He has since had these typed up, and I would -- I 6 know in the EIS final it was really hard to read his comments.
7 So, I would like to submit them, this, as part of the record.
8 MAYOR MORRIS: For tonight's meeting?
9 MS. SKOLNICK: Yes, please.
10 MAYOR MORRIS: Okay. Would you give a copy of it 11 to --
12 MS. SKOLNICK: Yes, sure. That's all.
13 (Continued on next page.)
14 ,
15 16 17 18 19 20 i
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 l
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l 1 MAYOR MORRIS: Regarding the questions that you ask 2 .this evening, you asked whether, I guess,' Tom Gerusky is in a
! 3 position to answer certain questions this evening. .
4 You also raised several questions that seem to be 5 directed at the NRC, and my assumption is that on most of these 6 questions that the NRC will review the transcript and try to 7 answer whatever questions they feel they appropriately can.
8 I guess within whatever reasonable time period can be expected.
9 I offer that as a suggestion. If anybody has a 10 problem with it, please speak to it.
11 Tom, regarding the question tha'. was asked te you 12 directly, are you in a position.to speak to it or do you prefer 13 to wait?
14 MR. GERUSKY: The answer is yes.
15 MS. SKOLNICK: Yes, you will answer the questions?
l 16 MR. GERUSKY: No. Yes. You asked if Pennsylvania 17 was prepared to handle the waste from TMI, yes. In either i
! 18 case. I l
19 MS. SKOLNICK: I guess I want to know, too, how do l
20 you feel --
i-j 21 MR. GERUSKY: We don't know where the site's going to 22 be yet. All right?
23 MS. SKOLNICK: Okay. How do you feel about Three 24 Mile Island staying for an unspecified period of time? !
25 MR. GERUSKY: I haven't made up my mind yet.
i l Heritage Reporting Corporation (202) 628-4888
62 1 MS. SKOLNICK: Have you any idea when --
2 MR. GERUSKY: No.
3 MS. SKOLNICK: -- you will make up your mind?
4 MR. GERUSKY: No.
5- MS. SKOLNICK: Will that be a public statement? Will 6 be aware of that?
7 MR. GERUSKY: The Commonwealth will comment on the 8 document.
9 MS. SKOLNICK: And the document -- okay. And I l l
10 wonder, Mayor Morris, I guess the other thing, I would love to l 11 get an answer from the NRC so that I can submit further 12 comments then on the EIS. Do you think -- is that possible?
13 MAYOR MORRIS: An answer from the NRC? ,
14 MS. SKOLNICK: To the questions that I -- I am 15 submitting a list of questions which I feel I need to have 16 answered before I can comment further on the EIS.
17 MAYOR MORRIS: Are these questions in addition to the 18 ones that you asked on the record?
19 MS. SKOLNICK: Yes. Some of them are included and l 20 there are additional ones. Yes.
21 MAYOR MORRIS: I guess, really, I would need to see 22 if Bill Travers could speak to that because I don't know how 23 long the list is and 1 couldn't really answer that.
24 MS. SKOLNICK: Okay.
25 DR. TRAVERS: Well, I don't either. I'll be glad to Heritage Reporting Corporation (202) , 628-4888
63 1 take a look at it.
2 Clearly, when we're asked questions, just about in 3 any forum, we try to give the best arswer we can, in the 4 shortest amount of time.
I 5 I will be probably. unwilling to extend the comment 6 period based on any lack of our ability to get it back, you 7 know, within days or even a couple of weeks.
o 8 We'll try our best and work with you.
9 MAYOR MORRIS: I think a key point really is, as we 10 talk about answering questions, is when will the panel -- will 11 the panel make a determination tonight on this. My hope is 12 that they do not, that we wait until a future meeting because 13 the NRC has agreed to extend 45-days.
14 MS. SKOLNICK: The -- ?
15 MAYOR MORRIS: Well, informally, they have not taken 16 formal action, but I understand the intent, as mentioned on the l.
17 record already tonight, is to extend for 45-days and that would 18 make it, I think, somebody said July, or --
19 DR. TRAVERS: Towards the end of July.
1 20 MAYOR MORRIS: Towards the end of July. There's no 21 specific date, but somewhere towards the end of July.
22 I would hope that the panel would meet then, probably 4
23 some time, maybe, in the second week of July or something like J 24 that.
25 So, if we end up coming to some agreement on that I Heritage Reporting Corporation (202) 628-4888 l
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l 64-1 type of time schedule, then it would be important for the NRC '
2 to try to-get whatever answers to questions at least a couple 3 of weeks before that meeting, minimal, so that the individual l' l
l 4 receiving them has a chance to review them and'then come to 5 this meeting to discuss them.
~
6 MS. SKOLNICK: Okay.
7 MAYOR MORRIS: Okay.
8 MS. SKOLNICK: Yeah.
9 MAYOR MORRIS: I'm just trying to get a procedure 10 together hers.
11 MS. SKOLNICK: Okay. What I have, actually, in 12 addition to my statement, I do have a list of my questions u
13 which I am going to submit to have it put on the record.
14 MAYOR MORRIS: And Bill Travers said they will 15 attempt to answer them, but he says that with the condition 16 that the hasn't seen how many there are.
17 MS. SKOLNICK: Right.
18 MAYOR MORRIS: And they're going to try to be 19 reasonable in answering them.
20 MS. SKOLNICK: There's twenty-four.
21 MAYOR MORRIS: Os. '.y . You did ask me a question.
l ,
22 MS. SKOLNICK: Yes. l 23 MAYOR MORRIS: And I am not in a position to speak to ;
I 24 that this evening. It really depends somewhat on what final l
l 25 determination is made regarding delayed clean up or immediate '
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65 1 clean up.
2 As I understand, particularly if we proceed with 3 immediate clean up, there is something like half a million ,
4 gallons of water a year that is produced that would be 5 discharged into the Susquehanna River in accordance with what 6 this document indicates, I believe.
7 Certainly, the City of Lancaster would need to 8 consider that.
9 So, at this point, I think we need to wait and see 10 what happens before I really can give you a definitive answer.
11 MS. SKOLNICK: I suppose then another question which 12 I would have to ask is if clean up is delayed and resumed in 13 whatever period of time, whenever, and they need -- I think 14 it's over a million gallons for clean up -- would that water be 15 accident generated water?
16 MAYOR MORRIS: You can have somebody else answer that 17 question. I guess it,will appear on the record and would 18 appreciate if NRC can --
19 STATEMENT OF: LINDA MUNSON, CONSULTANT AND PRESIDENT, EVERGREEN 20 TECHNOLOGIES 21 MS. MUNSON: Well, there's a legal definition that l
. 22 would have, has to do with the amount of tritium, and I would '
23 not expect that that water would have enough tritium to be 24 classified as accident generated water unless it has tritium in 25 it when it's used to start with.
Heritage Reporting Corporation (202) 628-4888
u 66 1 MS. SKOLNICK: I'm not sure if it's just tritium,?
2 though. Aren't there other criteria?
3 MAYOR MORRIS: W' ell, could we defer the answer and 4 have you review whatever the definition is?
5 MS. SKOLNICK: Yes. .
i 6 MAYOR MORRIS: And possibly have the NRC answer that 7 question.
8 MS. SKOLNICK: Yeah. Okay.
l l 9 MAYOR MORRIS: I am aware, somewhat, of the time at l
! 10 this point, and I know there's three people that want specific l
11 time on the agenda.
12 Eric says he doesn't mind. He'll give up his time.
l 13 MR. EPSTEIN: No, I didn't say that.
14 (Laughter.)
1 i
15 MAYOR MORRIS: Thank you, Frances.
. 16 MS. SKOLNICK: Okay. Thank you.
17 MAYOR MORRIS: It is Eric next.
18 Let me just go back to the question, because one of l l
19 the panel members said there may be confusion on it, and I just 20 want to make sure that the record indicates it clearly.
21 As I understood Frances to ask, was that during the
. 22 additional clean up there will be about a million gallons of 23 water generated, and the question was will that million gallons i i
24 of water be considered accident generated water.
25 You were not trying to say that that is the same Heritage Reporting Corporation (202) 628-4888 l 1
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l 67 1 water as the 1.-some million gallons now in the tanks. You l 2 were saying? I 3 MS. SKOLNICK: No. It's not "the" accident generated l 4 water -- and after clean up? l 5 MAYOR MORRIS: Yes. Okay.. It's "a" accident
. 6 generated water. Okay. That's what I understood you meant, 7 and I just wanted to make it clear on the record. Thank you.
8 STATEMENT OF: ERIC EPSTEIN, TMIA: THREE MILE ISLAND ALERT, 9 INC., HARRISBURG, PENNSYLVANIA 10 MR. EPSTEIN: I assume I still have ten minutes?
11 MAYOR MORRIS: Yes, sir.
12 MR. EPSTEIN: Okay. For the record, my name is Eric i i
13 Epstein.
14 I want to just take a moment and take care of some !
15 old business from the last meetittg.
16 First of all, I'd like to thank Frank for supplying 17 me with the document which I requested on decontamination of 18 the basin at Unit 2.
19 I'd like to introduce the document which I supplied i
20 to the panel members concerning some people in Missouri who are
- j 21 opposed to the transportation of the waste from Unit 2, anc l
. 22. they -- it's outlined in that document for the legal parameters 23 they feel are inconsistent to transfer the waste.
I 24 In addition, I'd like to thank the NRC for extending 25 the comment period to 45-days. That's very gracious, and we Heritage Reporting Corporation (202) 628-4888 s
68 1 appreciate it, and -- I'll wait till Art's done.
2 And the last -- there were.two other items. . First of i 3 all, I did ask William Kuhn at the shareholders' meeting if 4 they'd be willing to divert $800,000 from their dividends they' 5 pay to the executives and have that pay for the evaporator. He 6 said that was inappropriate. I would tallow up on that.
7 Also, I would disagree with Bill Travers' assessment l*
l 8 that de-commissioning would generically cost $200 million.
l l 9 I would like to introduce documents at the next meeting that l
l 10 would dispute that.
l j 11 In addition, William Kuhns at the shareholders' 12 meeting indicated that they plan to de-commission and 13 decontaminate it, both Unit 1 and Unit 2 at the same time, 14 somewhere around the years 2010 and 2020. So, for the next 15 meeting, I would like to supply those documents and just let l 16 you know that Chairman Kuhns did address that issue.
17 Now, to the information at hand.
18 In reviewing the staff's comments, I was struck by 19 several and familiar and disturbing themes.
20 First of all, there is a heavy reliance on data 21 supplied by GPU. This lack of independence, coupled with the j- 22 staff's propensity to rely on outdated data, casts a shadow on 23 the veracity of this document.
24 Secondly, the PEIS relies heavily on assumptions and 25 conjecture relating to such items as the state of robotics and Heritage Reporting Corporation (202) 628-4888
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e 69 1 clean up technology, radiation locations, radiation levels, and 2 GPU's commitment and ability -- economic health, which we 3 discussed already -- to clean the plant up.
4 Thus, the PEIS is too abstract and theoretical and 5 allows GPU the flexibility of finishing the clean up when and 6 how it sees fit. This is clearly a textbook lesson on how not 7 to regulate.
8 Let me remind you that GPU has a knack of making rosy 9 projections that have failed to materialize. For instance, we 10 were originally told that, and I quote:
11 "Decontamination of the containment building will 12 take until late 1982. Then we'll need the balance of '82 and 13 '83 for fuel removal." -- end of quote.
14 Well, it is now 1988 and fuel is still being i
15 recovered and removed. The original projected cost of $400 i l
16 million is approaching $1 billion, roughly what it cost to l l
17 build both Unit 1 and Unit 2. Yet, the same people who are so l 18 proud of their pioneering accomplishments are content to 19 mothball the plant indefinitely.
20 Actually, if you look at some of the recent events at I 21 Unit 2, it would seems as though the plant is already 22 mothballed.
23 On January 19th, GPU notified the NRC, and I quote:
24 "that the training qualifications of senior health 25 physics technician had lapsed several months in the past Heritage Reporting Corporation (202) 628-4888
l 70 1 ... -- and they had just discovered it.
2 As you know, on February 22nd and 27th of this year, 3 fires occurred in the decontamination facility of the reactor 4 building, and in both instances assigned fire extinguishers 5 failed to operate.
l l 6 Finally, just in April, April 1st of all days, April.
l 7 Fool's Day, 1988, NRC inspectors toured the reactor building l 8 and determined that, and I quote again:
l p 9 "housekeeping on all elevations had deteriorated in 10 that paper towels, cardboard tags, plastic bags, and other l
11 transient combustible materials were scattered in work areas 12 and low usage areas."
l 13 So, I think there is a problem with attention to 14 detail and in adhering to procedures, already.
15 Throughout the PEIS, the NRC clearly accepted GPU['s 16 proposition that post-defueling monitored storage is somehow 17 separate and distinct from the clean up. I think this is 18 absurd. The clean up of Three Mile Island should not come to a
-1 19 screeching halt because GPU and the NRC have established an 1 20 arbitrary end point.
l 21 Ironically, some of the same arguments the staff used 22 against radioactive water storage were employed to endorse a 23 postponement of the clean up.
24 For instance, the staff argued that postponement will 25 significantly reduce radiation levels and allow time for the l
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1 I
71- l 1 development of innovative technologies to deal with some of the 2 problems created by the accident.
3 In contract, TMI-Alert and other-concerned citizens.
4 have~ consistently called for an expedited and safe clean up 5 which will hopefully include a resolution to the water problem 6 that will not result in direct, radioactive releases to the 7 public and the environment.
8 GPU has the means, both economical and technological, 9 as well as the experienced work force at its disposal to 10 continue the clean up. Moreover, the, staff did not have a 11 clear preference in resolving this issue and stated that, I 12 quote:
13 "TMI-2 should not be allowed to become a waste 14 disposal site." ;
15 Well, if the NRC doesn't have a clear preference, the ;
16 public does have a clear preference, and that is to clean the 17 plant up now.
18 I think, and I hope you do convey that message to the 19 Commission the next time you meet with them in June.
20 In addition to that, I would hope that you -- and 21 this is just an aside -- convey the message to them that we I
. 22 thought, and I should have mentioned this earlier, that it's 23 inappropriate, we felt, to purchase an evaporator prior to the l 24 resolution of the hearings.
l 25 We didn't get into a big deal about that resolution, Heritage Reporting Corporation (202) 628-4888
72 1 but I hope that someone in some capacity would mention that --
2 that we have a problem with that.
3 In addition, that I -- everyone that will speak 4 tonight, I think, will be opposed to making Three Mile Island 5 Unit 2 a low level waste site.
6 We think clean up means finishing the job you 7 started, regardless if it takes four or four hundred years.
8 Radiation doesn't take vacations, and neither GPU or the NRC.
9 We cannot allow these people to walk away from their 10 commitment.
11 Let me conclude by saying that there are several 12 problems intricately intertwined with the timing of the clean 13 up. To postpone the clean up is to postpone the inevitable 14 decontamination and de-commissioning of Unit 2.
15 It is high time for GPU, the NRC, the DOE, and the 16 industry to admit that they do not know how to de-commission 17 and decontaminate a nuclear power plant.
18 Due to their collective ineptitude and over 19 zealousness, there is a crippled but dangerous plant in the 20 middle of the Susquehanna River that needs to be retired.
21 But there's a catch: GPU doesn't want to clean it up
. 22 just yet. The NRC is content to leave the plmnt in limbo-land, l l
23 and nobody knows just how to decontaminate and de-commission l 24 it.
25 So, I think we're in a hell of a quandary, and I Heritage Reporting Corporation (202) 628-4888
73 1 would urge you to convey the message to the Commission that the 2 plant should be cleaned up as soon as possible.
3 I have 19 questions, and I dcn't know much time I 4 have left, and I don't want to read through all 19 of them, but-l 5 what I'd like to do, if that's all right, Mayor Morris, is
- 6 select a few questions and read them into the record, if thats l
7 okay with you.
l*
8 MAYOR MORRIS: You still have three minutes left on l
9 your ten minutes.
1 10 MR. EPSTEIN: Okay.
11 MAYOR MORRIS: Go right to it, Eric.
12 MR. EPSTEIN: Okay, I'm right to it. All right.
13 2.1, the staff noted that, and I quote, "The primary 14 difference between an undamaged reactor at the end of its 15 useful life and the licensee's PDMS proposal is that during 16 PDMS relatively high levels of contamination would remain in 17 the reactor building basement and a small amount of residual l 18 fuel would remain in the reactor coolant system storage."
19 What factual data are these ' conclusions derived from? )
1 20 How many undamaged reactors at the "end of their l
21 useful lives" have the NRC dealt with? Were technical experts ,
i 22 from these plants consulted? If so, is their input a matter of 23 public record? What other differences exist between these 24 plants and GPU's PDMS plan? Was embrittlement a factor at 25 these plants? What was the staffing level at these plants?
Heritage Reporting Corporation (202) C28-4888
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74 1 The second question, the staff argued that, and I 2 quote: "The reactor containment building is uniquely designed 3 and constructed to maintain its structural integrity with 4 almost no leakage during a wide variety of accidents."
5 I would like to ask how long after an accident was 6 the reactor containment building designed to maintain its 7 integrity? Was it specifically designed to house radioactive 8 waste material for an indefinite period of time? If not, would 9 not storage of such waste necessitate a license amendment?
10 The third question this evening, and I quote:
11 "Sectioning and. disposal of the reactor internals and reactor 12 vessel are not considered part of the clean up because 13 radiation levels expected for these componer.ts would be no 14 higher than in a normal reactor nearing the end of its life."
15 What are sectioning and positioning of the reactor 16 internals part of? What if radiation levels are incorrect?
17 What exactly are the radiation levels of a normal reactor at l
18 the end of its life? What constitutes a normal reactor?
19 I mean, there are constant references to a normal 20 reactor at the end of its life. I don't think these people 21 l have dealt with one at the end of its life. '
- l 22 I know Humbolt Bay is in limbo-land. I don't know 23 that they've de-commissioned or decontaminated a plant.
24 I mean, to make reference like this, I think -- it's 25 troublesome to me.
Heritage Reporting Corporation (202) 628-4888
75 1 Just a few more questions, if you'll indulge me.
2 One of them deals with one of the requests Francis 3 made, and we would appreciate it GPU or the NRC could furnish a 4 complete inventory of where all the radioactive materials have 5 gone since the accident.
6 Another question is, and I think this is a word-speak 7 problem, I didn't understand. In the document, is ventilating 8 the reactor building before each entry the same as purging it?
9 I was unclear if that was the same.
10 How will the liquid releases to the Susquehanna River 11 following PDMS differ in composition to the 2.3 million gallons 12 of radioactive water currently stored at TMI.
13 Also, just as a question, and I think I know the 14 answer, is the public entitled to intervene if the indefinite 15 storage option is implemented?
16 The final question, and I think I know the answer to 17 this, also. If the cost of the clean up is figured in 1988 18 dollars, then estimates for delayed clean up are imprecise and 19 inaccurate -- and I think you addressed that.
20 What I was curious is if the NRC factored into the 21 economic costs the costs for retraining and rehiring workers a
22 that have been gone for some twenty years. I mean, it's an 23 intangible and I don't know how you factor that kind of 24 experience.
25 Also, just in the last year, has shown us, Public Heritage Reporting Corporation (202) 628-4888
+- - -
i 76 1 Services of New Hampshire has declared bankruptcy -- the first 2 public utility to do so since the Depression.
-3 So, it's not unreasonable to expect that other 4 utilities will do so at the end of the century when their 5 plants have to be de-commissioned.
6 I have many other questions. I don't boro you or run i
j 7 away with other people's times. The request I would make, I i*
l 8 notice the last time when we had a PEIS and the NRC addressed 9 the questions, they decided to rephrase the questions to their 10 liking and bunch a few questions together and then give a 11 ,
generic response, 12 I -- I mean, you know, give me break. If they can, 13 and I know it's indulging Bill, if they could specifically 14 answer some of these questions, I would be appreciative, and I 15 think Frances made a similar request.
16 MAYOR MORRIS: I think he's indicated that he will 17 try to have them addressed in a timely fashion. I do i 18 appreciate the fact that the questions have been provided in 19 writing, Eric, and I thank you for that. I wonder if you could 20 provide for the record a copy of the questions.
21 MR. EPSTEIN: I have extra copies. I've already -- I
'* 22 provided a copy for the person who's scribbling away there.
23 (Laughter.)
24 MR. EPSTEIN: Would you like extra copies for 25 everybody else?
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_ e _. --m-,, ,-m.- -- - , , . , e,, .+,m - - - - - -
77 1 MAYOR MORRIS': I think we all have -- you do not?
2 MR. GERUSKY: No.
3 MAYOR MORRIS: If you have extra copies --
4 MR. EPSTEIN: Yes.
5 MAYOR MORRIS: Maybe it would be helpful.
6 MR. EPSTEIN: Is Bill going to be coming back, or is 7 this just a guest appearance. Who are we going to be dealing 8 with here?
9 MAYOR MORRIS: Mike Masnik called me and apologized 10 for not being able to make it, and he did indicate that, quote, 11 unquote, it was kind of a guest appearance by Bill. He can 12 speak for himself, as he'd like, but I understood that he's 13 really filling in for Mike tonight.
14 MR. EPSTEIN: Okay.
15 MAYOR MORRIS: And Mike Maanik will be back for the 16 next meeting, as I understand it. Now, he doesn't know when 17 it's going to be, so who knows whether he'll have a conflict or 18 not.
19 MR. EPSTEIN: Okay. Well, I hope when you meet with 20 the Commission you convey the concerns we have -- that it not 21 be put into long term storage.
22 In addition, we think that during a hearing 23 process -- and, you know, I don't want to argue about 24 this -- if someone just could convey that we were just a little 25 dismayed that we were just a little dismayed that they would Heritage Reporting Corporation (202) 628-4888
l 78 1 purchase an evaporator prior to the end of the licensing 2 process.
3 MAYOR MORRIS: Okay. Somebody on the panel may want 4 to bring that point up. You keep it mentioning it to.the 5 meeting, and you mentioned that one the phone to me this week.
6 MR. EPSTEIN: Yes.
7 MAYOR MORRIS: I know we talked about a meeting, but 8 I would really like to ask the NRC, is there -- has a meeting 9 been set for June and, if so, what is the date? And I ask that 10 pointedly because I -- maybe we've decided and it's just 11 slipped my memory.
12 MS. HARTY: For the Court Reporter's sake, my name is 13 Lee Thomas. I am the project manager for TMI-2 at the NRC.
14 We haven't set a date for June's meeting, and that 15 should be -- or our July's meeting -- whenever you choose.
16 That's our final order of business for tonight.
17 MAYOR MORRIS: Okay, it's not so much the next panel 18 meeting for sometime in July, as I mentioned earlier, but I 19 think Eric is indicating that we have a meeting with the NRC 20 Commissioners in June.
21 My question is do you know of that? Just so you know 22 that we're clear -- as far as I know, we do not have a meeting, 23 and I understand you want certain questions asked when we do 24 meet, but there's not one established.
25 MR. EPSTEIN: I assumed it was June. It was a Heritage Reporting Corporation (202) 628-4888
79 1 subliminal plant, I guess. I don't know -- because you did it 2 last year. You know, I'm nostalgic. I thought it'd be June, 3 again.
4 MAYOR MORRIS: Well, we can talk about that as last 5 order of business.
6 MR. EPSTEIN: Yeah. I don't want to take up other 7 people's time.
8 MAYOR MORRIS: Okay. The next person would be Kay 9 Pickering.
10 MS. STUCHINSKI: Vera. Going next.
11 MAYOR MORRIS: Switch?
12 MS. STUCHINSKI: Yes.
13 MAYOR MORRIS: Vera. Stuchinski.
14 STATEMENT OF: VERA STUCHINSKI, CHAIRPERSON, TMIA: THREE MILE ,
15 ISLAND ALERT, INC., HARRISBURG, PENNSYLVANIA 16 MS. STUCHINSKI: Yes. My name is Vera Stuchinski.
17 As chairperson of TMIA, I'd like to supplement Eric Epsteins's 18 presentation with some additional comments.
I 19 The thing that really concerned me in reading the EIS 20 was that the plan endorsed by the staff seems to lack any firm 21 regulatory requirements.
. 22 The summary states that the duration of the storage 23 period during delayed clean up was not specified by the 24 licensee so the staff assumed a storage period of twenty years.
25 If the staff feels that the storage period of twenty Heritage Reporting Corporation !
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80 1 years is appropriate, I would be interested in.some regulatory 2 language that would specify that the storage period would not 3 exceed twenty years.
4 I'm. confused about the regulatory guidelines.
5 Perhaps that's not the intent of the EIS, but it seems to lack 6 any teeth. What's to stop GPU from making their own rules? )
7 The EIS is just filled with references to the staff's approval 8 of procedures based on assumptions.
9 Two quick examples:
10 On page 3.10. "By the end PDMS it is expected that 11 the licensee will have made a decision on the future 12 disposition of the plant and the final clean up will be 13 per f o rmed . "
14 On page 3.23. "Although the licensee has not made 15 any detailed plans for the clean up following PDMS, it is 16 assumed that during the clean up the contaminated liquids would ;
17 be processed through the SDS and could be stored before being I 18 processed through the Epicore 2 system."
19 The assumptions are just made repeatedly through the 20 EIS. It's very disturbing.
21 In addition, there is a glaring inconsistency, which
. 22 other individuals have pointed out, with the staff's previous 23 position on monitored storage of wastes. l 24 The staff justified this proposal for PDMS by stating 25 that there would be less occupational dose contamination due to' Heritage Reporting Corporation (202) 628-4888
81 1 radioactive decay during the storage period. _Four pages after 2 this reference, the staff stated that after the completion of 3 clean up the radiation levels in the TMI-2 reactor would be 4 primarily due to Cesium 137.
5 Now, reading this carefully, Cesium 137 has a half 6 life of 30 years. So, it would take 30 years for just half the ;
l 7 total quantity of the Cesium 137 to decay. Approximately 300 8 years for the radioactive material to decay to insignificant 9 levels, according to the formula that's used. l l
10 Twenty years is obviously not enough to make a 11 significant difference. It's a ridiculous point to state that i 12 the radioactive material would decay away to less harmless 13 levels or more harmless levels.
14 I also want to_ remind the panel that when members of 15 the public asked the NRC to maintain the 2.3 million gallons of 16 radioactive waste water in monitored storage on the island, 17 rather than evaporate it, the staff vetoed the plan. l l
18 On page 7.4 of the final EIS dealing with disposal of l l
19 the water, the staff explained that in the absence of i 20 overriding benefits associated with storage waste on-site, the i
21 staff believes that waste should be disposed of as 22 expeditiously as possible.
23 Now, in this case, the staff concluded that there is 24 no significant benefit from continued on-site storage of the 25 water.
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82 1 It was noted that the tritiated water would remain 2 radioactive for such a long time that indefinite storage would 3 have a negligible effect on the amount of radioactivity.
4 Now, the contaminated water.contains tritium which 5 has a half life of 12.3 years. That's less.than half that of 6 Cesium 137 which was determined to be the main contaminant.
7 Let's see. It was also noted in'the introduction to 8 the EIS that there are anticipated advances in decontamination 9 technology expected to occur within the next twenty years.
10 Now, this very argument was rejected by the staff 11 when people asked that tritiated water be held on-site -- I'm 12 sure all of you remember. We've gone over this so many 13 times -- until a better method of disposition was available i
14 rather than dispersing into the atmosphere.
15 This is so blatant -- the language in the -- it's I 16 such a turnabout. '
17 Finally, the NRC staff insisted throughout the public 18 meetings on GPU's evaporation proposal that interim monitored 19 storage of the water on-site would make TMI a low-level waste 20 site.
21 I know Mr. Gerusky spoke to that, that the island is ,
I 22 not licensed for a low-level waste site. Even though we were j 23 not suggesting that it become a waste site, a permanent waste 24 site.
25 Now, I'd like to ask Dr. Travers why the staff does i
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83 1 not consider PDMS in the same manner as storage of the 2 tritiated water. If a low-level waste site license would'be-3 required for storage of the water, why isn't it required for 4 PDMS?
5 I'd also like to ask Mr. Gerusky if he could respond 6 to that.
7 Just to sum up, I found the EIS to be a shockingly 8 inadequate document, and I think it's clear that the NRC staff 9 has chosen to take no responsibilities to recommend any 10 stringent regulatory guidelines for the clean up.
11 If I could ask for a response in regards to the low-12 level waste site quandary.
13 MR. GERUSKY: There's no requirement that GPU have a 14 license. A low-level waste disposal site in Pennsylvania is a 15 requirement of Pennsylvania law. The utility is covered by 16 federal law.
17 It would not be a low-level waste site. It would be 18 a storage facility, in either case: if the water stayed on the 19 island or the radioactive material inside the plant.
20 MS. STUCHINSKI: Unfortunately, I don't have my EIS !
21 on the -- the final EIS on the water, but I do know that was
+
22 debated in some of the public meetings.
23 The intent seemed to be, you know, or was said to the 24 public was: That's nonsense. It can't be held there because 1
25 it would create the situation of a low-level waste site, l l
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84 1 MR. GERUSKY: It isn't -- it wouldn't be a low-l'evel 2 waste site in either case.
3 MS. STUCHINSKI: Okay.
4 MAYOR MORRIS: Okay, Bill.
5 DR. TRAVERS: Vera, if I may, take a shot at it. I 6 think -- just to drop back on what we did on the water 7 supplement, and then this supplement -- is that we concluded in 8 both that just about all of thetalternatives we looked at would 9 not result in a significant environmental impact.
10 In the case of storage of TMI-2 for some period of 11 time, twenty years or ten years, whatever, the operation or the 12 condition of the facility during that period would be covered 13 by a license from the Nuclear Regulatory Commission with very 14 specific stipulations -- tech specs -- that would act to assure 15 things like the assumptions about the status of the facility 16 and the migration of the radionuclides within it were 17 continuing to be maintained.
18 So, while you wouldn't need a disposal facility 19 determination or license, it would be covered under our Part 50 20 Power Reactor license and very specific requirements would have 21 to be met by GPU for some period of time.
22 Let's see, if I can remember what your other question 23 was.
24 I do want to reiterate that in the course of our 25 Supplement No. 2 on Accident Generated Water, we found that~ if Heritage Reporting Corporation (202) 628-4888
85 1 you store accident generated water on site that would not 2 result in significant environmental impact. It just wouldn't.
3 Water is so very -- what's the word -- the water contains such 4 very low levels of radioactive contamination that whether you 5 evaporate it or put it in the river or keep it on TMI-2 for
,- 6 some period of time, it just isn't a significant environmental 7 impact.
l*
8 What we tried to say in our water EIS is that because l
9 of the fact that there are such very small levels of 10 radioactive material to begin with in that water, that you 11 wouldn't accrue any significant benefit by waiting indefinitely 12 -- whether it's twenty years, or thirty years, or forty l
13 years -- before you do something with it. Because you are 14 ultimately going to have to do something with it. l l 15 So, that's sort of the differentiation that we tried 16 to make, even if we didn't explain it.
t l 17 MS. STUCHINSKI: What about advanced technology that 1 l
18 would allow a better method rather than evaporation?
19 DR. TRAVERS: We just don't see any reasonable l l
! 20 promise of such technology, given the chemical make up of )
=
l l 21 tritium is identical to that water. )
1 i
. 22 Again, the consensus of our review, is that to begin 23 with there's just such a small amount in there -- believe it or 24 not -- that it just doesn't make a whole heck of a lot of 25 difference just ac*. you do with it.
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l 86 1 MS. STUCHINSKI: DE you really feel that there would ,
1 2 be significant decay of the radioactive material within twenty l 3 years of any long-lived radionuclides in the reactor?
4 DR. TRAVERS: The significance of decay has l
5 inherently built into it the level at which you start at. ;
1 6 For example, in the reactor building based'on Three 7 Mile Island, if you start out with a thousand R or a thousand 8 Curies of Cesium, over twenty years you're going to get a 9 significant reduction in the potential exposure to workers who 10 must remove it.
11 on the other hand, if you start with accident 12 generated water that has very small levels of radioactive 13 material to begin with and project out twenty or thirty years, 14 or fifty years, the delta, or the savings, environmental 15 impact-wise, that you accrue from waiting that period of time 16 is not significant.
17 So, you have to look at the starting point and the 18 incremental savings of environmental impact that is accrued and 19 not just the physical or radiological half life, rather, of the 20 material.
21 MS. STUCHINSKI: Okay.
l 22 MAYOR MORRIS: Thank you, and now the third person, 1 l
23 who chose to be fourth, Kay Pickering. ~
24 STATEMENT OF: KAY PICKERING, OFFICE COORDINATOR, TMIA: THREE 25 MILE ISLAND ALERT, INC., HARRISBURG, PENNSYLVANIA Heritage Reporting Corporation (202) 628-4888
87 1 MS. PICKERING: Good evening. I come tonight with a 2 few comments.
3 Based on my experience with the public as a person 4 who's at the Three Mile Island Alert office most of the time, S Eric and I get the phone calls. We hear the comments from the
. 6 public.
7 When the newspaper article came out -- there was a 8 short article in the local paper -- talking about the draft 9 Environmental Impact Statement and it briefly stated the 10 position of the NRC staff on the clean up, the next couple of 11 days our phone was ringing with irate people saying what's 12 going on here.
13 They were under the impression, and most of the 14 public is under the impression, that Unit 2 was going to be 15 cleaned up, and that meant from start to finish, that the 16 project would start and that it would be completed, and it l 17 would be continuous.
18 They don't understand, and I don't understand, why 19 the about face and they the turnabout, and how the NRC and the 20 utility and the State of Pennsylvania is going to ensure to the 21 public that there will be proper monitoring, if it's not
. 22 clecned up now, and that, in fact, the utility will, at a point 23 in time, have the money, have the wherewithal, have the I 24 expertise, have the technology, and, in fact, do the clean up
- 25 at the end point.
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88 1 I guess most of us.have been conditioned by the j 2 bureaucracy. We look at the federal government. We look at 3 the superfund. We-look at all the other contaminants that are 4 invading our environment that have been here, not just five 5 years, ten years, twenty years.
6 Look at what the Army and the Navy and all those 7 other groups did to us after World War II and since World War O
8 II. We look at Olmstead. We look at all of the things that 9 are happening, just here in central Pennsylvania, to our 10 environment.
11 How can we believe that at some point, ten, fifteen 12 or twenty years, that because somebody says they will do 13 scmething that, in fact, that will ever happen, that anybody 14 will make them see that it happen.
15 I think we're all just in disbelief of what's 16 happening now and what could happen in the future.
17 I understand that there was a sale of one dollar 18 today. That the people in New York understand what's gcing on.
19 That the Shoreham Plant was sold for a dollar to the State of 20 New York, that that plant will never open.
21 I think we're concerned not just about Unit 2 and the 22 clean up, but we're very concerned about Unit 1 and how the 23 company's going to handle Unit 1 and, together, how they can 24 possibly afford the cost and the expertise and the technology 25 for both of those plants.-
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i 89 i
j 1- So, I further reiterate the questions that have come i
j 2 here tonight- and implore this panel to consider seriously the l 3 questions and the comments. And to give us some idea, if 4
) 4 you're going to be around for the next twenty years to monitor-i
) 5 the clean'up process.
i -
6 Thank you.
, 7 MAYOR MORRIS: Thank.you, Kay. Just as a comment I.
J 8 here so that everybody realizes,_ Frank Standerfer has indicated i
9 that at least before the meeting is over he wculd'like to come
! 10 back forward and speak to some of the questions that were 1
11 raised as to the cost of the clean up, I guess the ability of 12 the operator to pay for the clean up twenty years hence from l j
y 13 now and how that fits in with the action that the NRC is I
.14 looking at on de-commissioning costs.
15 However, prior to doing that, Frank, I would like to 4
16 allow the public an opportunity to ask any questions they want 17 to at this time or make any statements, those that have not had )
! 18 a chance yet to do so.
4 19 MR. TRUNK: -- and hope to get an answer to our l
- 1 4
20 question first.
j 21 MAYOR MORRIS: I'm sorry?
- 22 MR. TRUNK: Can't we get an answer to our question
. 23 first? Why are we considering this? The last person --
24 MAYOR MORRIS: Could you come up please and, I'm l 25 sorry -- for the record. I
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90 1 STATEMENT OF: ED TRUNK, PROFESSOR OF MECHANICAL ENGINEERING, 2 PENNSYLVANIA STATE UNIVERSITY 3 MR. TRUNK: There was a question in front of the
- 4 group and it wasn't answered.
5 MAYOR MORRIS: If you could just -- I'm just tryin,g 6 to get it on the record here.
7 MR. TRUNK: .I'm Ed Trunk, and I'd just like to 8 reiterate there was a question posed by the last guest and it 9 wasn't answered.
10 The question was why are we considering this question i
11 when we had a timetable before us and we're going down that 12 timetable. Why are we considering this? Why is there a change 13 in timetable before us right now?
14 MAYOR MORRIS: Okay. We'll see if we can get an 15 answer to the question, either from the NRC or from, probably 16 better, GPU. Would somebody like to attempt to answer that, 17 please, at the mike.
18 DR. TRAVERS: Well, I can only answer it from our 19 side and then maybe you can ask them.
20 We're addressing it, the NRC is addressing the issue, 21 frankly, because we are required to do so. We've been given a j
- 22 proposal, a formal proposal, by our licensee, and one of the i 23 things we do as a regulatory agency, required to do, is to 24 evaluate proposals, and that's what we're about, and this .is 25 just one aspect of it.
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91 1 MAYOR MORRIS: Would you like to speak to why there 2 is such a proposal, Mr. Standerfer? And if you could come 3 forward and briefly explair that.
4 MR. STANDERFER: The purpose of the clean up project' 5 was to remove the undamaged fuel, or remove the damaged fuel 6 and to bring the plant to a condition which is safe and not 7 dangerous.
8 As we evaluated the logical stopping point of the 9 current work, and we made our proposal a year and a half ago.
10 And Bill is right. I believe they must consider our proposal.
11 We clearly understood that to do further work at the 12 present time, and while significant worker exposure which did 13 not alter the hazard the public, whether it was done now or 14 later, we are currently reviewing the Environmental Impact 15 Statement, and we will be submitting our comments with other 16 reviewers.
17 We agree that the worker exposure in the delayed case 18 is one half of the --
1 19 MAYOR MORRIS: Excuse me. I think you answered the 20 question. I think you did say you want to come back and -- l 21 MR. STANDERFER: Yes.
)
22 MAYOR MORRIS: --
speak to those points, if you 23 could, and I just want to say I'm trying to give the citizens a l
24 chance first and then we're going to give you an opportunity, l 25 Frank, believe me. Thank you.
4 I
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92 1 Are there any other questions or statements from the
~
2 public at this point. If so, could you raise your hand and be 3 recognized and come forward, please. Then we'll go on from l 4 there.
5 Who else in the public would like to!make some 6 comment other than two individuals that have now indicated?
l 7 Okay. Frank, after these two.
l 8 STATEMENT OF: JOYCE CORRADI,_ DIRECTOR, CONCERNED MOTHERS AND 9 WOMEN l 10 MS. CORRADI: My name is_ Joyce Corradi, C-O-R-R-A-D-11 I. I'm representing Concerned Mothers-and Women.
12 My first question is in reference to what was told to 13 me tonight. In the presentation by the NRC, they said that in l
i 14 twenty years there would be three million or more people in the 15 area that they were relating to for their dose rate.
16 I'd like to know where they got their projection and l 17 how they got that projection.
l 18 MS. HARTY: The projected -- oh, this is Becky Harty 19 for the record.
l 20 The projected population distribution for the year
!' l l 21 2009 we received as data in a letter from Frank Standerfer of l
l .
22 the NRC. So, that was their estimate. GPU Nuclear's estimate 1
23 of the population in the year 2009.
24 MS. CORRADI: I'd like to know from Mr. Standerfer 25 where he got it from and how it was calculated.
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1 MAYOR MORRIS: If he could when he comes_ forward 2 speak to that question, because he~is going to be up here ,
3 towards the end, and I will -- we will ask him to speak that 4 question when he gets up here. '
5 MS.-CORRADI: Okay.
6 MAYOR MORRIS: You can continue on to.another 7 question.
8 MS. CORRADI: Okay. In all the years that this panel- .
9 has been functioning and all the information-that has been 10 shared and buffed and re-buffed, I-think this is.the largest 11 amount of garbage that's ever been presented to a group at any
- 12 one time.
13 If it hasn't insulted your intelligence , I can't :
j 14 understand why. It certainly has insulted mine.
15 MAYOR MORRIS: Thank you. I think there was a hand 16 that was over here.
17 STATEMENT OF: DEBRA DAVENPORT, MEMBER, CONCERNED MOTHERS AND 18 WOMEN 19 MS. DAVENPORT: This is Debra Davenport frora Concerned Mothers and Women, Camp Hill.
20 I'm always asking the 21 same question.
22 I want to know what the licensee plans to do to deal 23 with the materials that are directly under the reactor vessel.
24 Is this included in any of the assessments of removal of 25 materials from the plant?
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4
T 94 1 Repeatedly, you know, I see things now in last 2 month's -- or whenever the last meeting was -- saying, well, 3 we're going in through the bottom of the reactor vessel.
4 There's a great deal of material down there. We're going to 5 assess this. ,
6 But what is under the reactor vessel? What is passed 7 -- I know something in the book with the nozzles going into the 8 vessel, but what about the tubes leading into the nozzles.
9 What fuel is in there?
10 So, I really question whether we're being told about i
11 all the fuel that's in the plant and whether there is a full 12 assessment made on removing those fuels.
13 Also, I really wonder why, over a long period of 14 time, we repeatedly seem to have a drawback from explaining to ,
15 the public what might be under the reactor vessel in that 16 basement.
17 I just don't understand -- this is like the 18 evaporator. It's premature.
19 Would GPU have an answer to that?
i 20 MAYOR MORRIS: Yeah. I would ask Frank Standerfer
- 21 again on that one, too. Come forward -- when he comes up at 22 the end to give other comments, to speak to that question and 23 also to the question that was asked previously. ,
24 MS. DAVENPORT: The only other question I have really 25 was the evaporator, and I'm wondering -- with that, I don't Heritage Reporting Corporation (202) 628-4888
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1 know whether it's appropriate to bring it up. If it's, you 2 know,'everyone's now in -- but I'm wondering with evapcrator, 3 once it is finished, when you finish using this for the 4 evaporation, supposedly, of the clean up water, which I hope 1
5 they never do -- but if -- where will it go?
o 6 Will it be used in TMI-1 then if the life of their 7 evaporator runs out? What will be done with this evaporator?
8 And at the point, essentially, you know, will the public be l 9 paying for an evaporator for Unit 1 when it started off in Unit 10 Number 2, or will it be usvd for some other process? !
11 MAYOR MORRIS: I .can certainly see if Frank l 12 Standerfer can speak to that one, too.
13 MR. STANDERFER: Obviously, I want a full clean up 14 now. Okay. Thank you.
15 MAYOR MORRIS: Okay. Thank you. Frank, could you 16 come forward? If you could, answer the or try to answer the 17 three questions that were raised initially, if yoin would.
18 Please try to, and then you said you had other comments you 19 wanted to make. ;
1 l 20 MR. STANDERFER: Three questions addressed --
21 MAYOR MORRIS: The three questions that we asked on 22 population by Joyce, and then Ms. Davenport asked two 23 specific --
24 MR. STANDERFER: Population projections are included 25 in all of our safety analysis reports. On Unit is and Unit 2s, Heritage Reporting Corporation (202) 628-4888
96 1 and so forth.
2 At the next meeting, I could give~you the exact basis 3 for that, but it basically tracks back to projections made by 4 the State of Pennsylvania and by the federal Census Bureau.
5 These would be the primary references, I believe, but
= 6 this is -- GPU itself is not in the business of making 7 population projections but we're relying on state and federal 8 bodies to make those projections.
9 We're required to include those on our safety 10 analyses to produce valid safety projections over the next 11 fifty years.
12 MS. CORRADI: I'd like to know the date of the --
13 MAYOR MORRIS: Excust me. If you have a question.
14 Would you please come forward and ask that, to get it on the 15 record, please.
16 MR. STANDERFER: But I can provide at the next 17 meeting a detailed analysis of what those projections are for 18 the fifty mile radius -- or fifty mile circle around the plant, j 19 and what the primary source for those were. I 20 MAYOR MORRIS: Okay and --
21 MS. CORRADI: If, indeed, this is a criteria by which
. 22 they were using to get dose rates, I should like to know where 23 they came from, the year point end of them, and how valid and 24 updated they are.
25 MAYOR MORRIS: Well,-I think he's indicated that he Heritage Reporting Corporation i (202) 628-4888 i
97
, I will attempt to provide that information by the next meeting.
2 MR. STANDERFER: Yes. With regard to where fuel is 3 in the plant, we are required at the end of defueling to submit j 4 a defueling report to the NRC-which includes our measurement of 5 where fuel still remains in the plant at the end of defueling.
6 That's a required report which is -- will be 7 submitted to the NRC at the end of defueling.
8 MS. DAVENPORT: You haven't really answered my 9 question --
10~ MAYOR MORRIS: Excuse me. Not to give you a 11 difficult. time, but if you want to pursue, if you can be 12 recognized. Please come up here at this point. We're trying 13 to get it on the record is all, and they're having trouble 14 hearing it.
15 MS. DAVENPORT: That doesn't really answer all of my 16 question. Now it does answer one, but all the information is i
17 not in for the EIS that's been drafted in the forum.
18 We don't know what all the facts are. They're not in 19 because you don't know where everything is, and how much of it 20 is being J ef t there, and what type -- but I want to know, are 21 they going to check that area under the reactor vessel, because 22 this has been an off-again and on-again thing for the past
, 23 year. Are they going'to say what's there?
24 I think in one meeting it was mentioned they were 25 checking the neutron trunk protectors -- it was said it was too 1 Heritage Reporting Corporation 4
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98 1 hot to go into. Then it was too much money, according~to the 2 newspaper.
3 You know, I'd kind of like to know what's going to be 4 done about that material. Is it-going to be left there and-how 5 much of it is there?
6 The second one, in the inner core protector tube, is 7 materials from the -- or any materials going under the reactor i
l 8 vessel. When are we going to know about this?
9 MR. STANDERFER: Let me answer those one by.one.
- 10 We do not believe there is any fuel in the incore 11 detector tubes. We will know that as we defuel down to that 12 point, but currently there is no r,idence that there's fuel 13 there.
14 Under the reactor vessel, we have sampled the water 15 as part of the defueling process. We find no evidence of fuel 16 in the water under the reactor vessel. It's borated water, and 17 there is no reason to believe, at the present time, that there l 18 was any leakage from the reactor vessel to that area. Our 1
19 samples for far indicate no evidence of that.
20 MS. DAVENPORT: Why is it to radioactive down there 21 and you can't get in?
22 MR. STANDERFER: Well, because there's fuel in the 23 reactor vessel above and it is shining into that area as --
24 like an X-ray machine would shine.
25 MS. DAVENPORT: Why wouldn't it be the same -- as the Heritage Reporting Corporation (202) 628-4888
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2 MR. STANDERFER: Well, because there's no shielding 3 between that cavity and the bottom of the reactor vessel.
4 With regard to the evaporator, the arrangements for 5 the evaporator are that the vendor who provides the evaporator 6 services will remove the evaporator and, to the extent to which ,
7 that evaporator is usable in the future we will get royalties .
8 for its use.
P 9 Getting back to the reason GPU made this proposal, we 10 will reduce the hazard, as the NRC's EIS indicates, to a level
. 11 which is not significant as far as the public is' concerned. i 12 We have done enough analysis and will provide more.
13 detailed analysis to the NRC in our comments, which has 14 recently been done, to indicate there is at least a factor of 2 15 difference in worker exposure from doing it earlier than doing 16 it later.
l 17 he have done a step-by-step analysis, and our 18 analysis would indicate that the difference is about three l 19 times larger than the numbers that the NRC currently has in l 20 this document.
21 So, clearly the significant issue is worker exposure, l 22 and our proposal to limit that worker exposure by doing '
23 additional work at a later period.
l 24 We believe along the lines I think that Tom Gerusky 25 was point out, that if clean up was done twenty years from now Heritage Reporting Corporation (202) 628-4888 i.
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- 100 1 or immediately, to evaluate those two cases you must look at a 2 twenty-four year period in both cases. That is a monitoring 3 period for twenty years plus four years of cleaa up, or a clean 4 up period plus twenty years of monitoring.
5 Our assessment based on the cleanliness of the plant 6 at the end of the current work or the cleanliness of the plant
, 7 at the end of continued clean up is that the emissions from the 8 plant over the monitoring period would be roughly the same in l
9 both cases.
10 That indicates, then, that the public exposure in 11 both cases are roughly the same. The worker exposure, of 12 course, is much higher if you do the work early. The cost of 13 monitoring, since it's basically bar^ ro protection and 14 operation of ventilation systems a., ;arth, is roughly the 15 same in both cases.
16 When you add twenty years of monitoring costs to the 17 immediate clean up case, the total costs are slightly higher j 18 than the delayed clean up case.
19 With regard to costs, GPU under currently issued 20 regulations on de-commissioning, will be required to submit 21 de-commissioning plans for TMI-1, the Oyster Creek plant in New
~
22 Jersey, and the TMI-2 plant. Those de-commissioning plans must 23 address costs of work left to do to de-commission the plant and 24 must include plans for providing that funding.
25 The NRC in that process, under those de-commissioning Heritage Reporting Corporation (202) 628-4888
I 101 1 regulations, must address the company's ability to provide th-2 ose funds.
3 So, that will be analyzed in our responses to the 4 recently issued de-commissioning regulations.
5 MAYOR MORRIS: How soon, Frank, will that response be 6 submitted?
7 MR. STANDERFER: There's a time table in the 8 regulations that were just issued in the last week or so. I 9 believe it's within five years but, Bob, do you -- ?
10 STATEMENT OF ROBERT ROGAN, DIRECTOR, LICENSING AND NUCLEAR 11 SAFETY, GPU NUCLEAR CORPORATION 12 MR. ROGAN: I think the initial one's within five 13 years and then an update.
14 MAYOR MORRIS: Did you get that on the record?
15 THE REPORTER: I don't know who it is.
16 MR. STANDERFER: It's Bob Rogan, and I believe the 17 requirement for providing those plans is within five years, but l 18 there's a number of time tables in there. It's not longer than 19 five years, and it may be shorter than that, and we have to 20 study that regulation to understand exactly what the time table
' 1 21 is for each plant.
' 22 MAYOR MORRIF: Okay. My concern really was in making 23 a determination now of those options without knowing what 24 mechanism is in place for requiring some fundings to be -- l 25 MR. STANDERFER: Within the relatively near time, Heritage Reporting Corporation (702) 628-4888 >
102 1 near term, within the next five years, we must submit the de-2 commissioning plan for TMI-2. That must address all work that 3 has to be done to get to that point.
4 If.there's additional clean up required before de- :
5 commissioning, we must adoress that. The cost of that work' ;
6 must addressed, and we.must address the company's proposed 7 method of assuring that those funds are available.
8 MAYOR MC3RIS: I. understood that. What I was saying 2
9 was that you're saying it doesn't need to submit until --
10 except within the next five years and that's from this 11 determination? That's not -- . .
12 MR. STANDERFER: The de-commissioning plan, as I 1
13 remember -- I'd have to study it before the i. ext thing -- if a 14 plant was shut down, I believe you have two years tv supply 1 i
15 that plan. If a plant is in the process of clean up, as TMI-2 ;
i 3
16 is, the time table would start at some point in time and it may j 17 be at the end of the clean up, I'm not sure.
1 18 I believe that the five year is the longest period 19 that can be.
20 So, it would be less than five years or up to five !
i 21 years.
i
- i 22 MAYOR MORRIS: I'm not trying to argue with you or )
23 ask for additional info. I was just making a comment relative I 24 to the determination.
J p
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i 103 1 it's contained in our Programatic Environmental Statement under 2 Regulatory Considerations.
3 It's based on what the draft rule is, and I assumed 4 the final will have -- Let.me just read it. It says: ,
5 "The de-commissioning rule requires that de-6 commissioning plans be submitted within two years following a 7 decision by a licensee to permanently cease operations or one 8 year before tha operating license expires."
9 MAYOR MORRIS: Bill, what are you reading from?
10 DR. TRAVERS: This is from Supplement No. 3,-draft 11 Supplement No. 3 of the Programatic Environmental Impact 12 Statement.
'13 MAYOR MORRIS: Page?
14 DR. TRAVERS: Page 2.33. In the section on l 15 Regulatory and Administrative Considerations that are l
16 applicable to what we're doing here. So, there's -- '
17 MAYOR MORRIS: I'm glad you found it.
18 MR. EPSTEIN: Mayor Morris? Can I have just one 19 second before we continue?
20 MAYOR MORRISt I am -- yes. Is it one this?' If so, 21 could you come up and ask the question. I'm trying to --
22 MR. EPSTEIN: Yes. It is -- to the question he 1
23 poses.
l 24 MAYOR MORRIS: Sure.
25 MR. EPSTEIN: As you notice, it's five years. They Heritage Reporting' Corporation (202) 628-4888
104 4
?
i 1 don't have to put any money in escrow. And there are places, 2 for instance, in California where it-is established that 3 utilities -- for instance, you have to put money into escrow 4 every year to take care of the de-commissioning and 5 decontaminating costs.
4
- 6 This, the deferred monitor storage, allows them to 7 postpone a decision on de-commissioning and decontamination.
8 In essence, postponing using their resources which would -- I 9 just point this out that other states, other utilities, have 10 done this. Have taken the initiative.
11 I mean, that's not answering that I had to address.
12 I just wanted to clarify that.
4 13 MAYOR MORRIS: Sure. It's not clear to me just what 14 they're going to be required to do by the NRC, in any event.
15 What kind of financial responsibility the NRC would hold them !
16 to?
17 What I've heard hero tonight are certain 18 requirements, but there's nothing that's come with them. So, 19 it's, to me, I don't hear anything definitive other than a 20 number of years that certain submissions have to be taken place 21 by.
22 MR. STANDERFER: That is correct.
23 MAYOR MORRIS: If there are guidelines that say that 1
i 24 you have to put money in escrow every year and things like 25 that, fine, but I'm not hearing you say anything like that at Heritage Reporting Corporation (202) 628-4888
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l 105 1 this point.
l 2 MR. STANDERFER: GPU is currently accumulating monies 3 for Oyster Creek and TMI-1, and we must address the TMI-2 4 situation.
5 The vehicle is these plans that are required by the 6 NRC.
7 MAYOR MORRIS: I understand you must address, but-8 it's not clear to me in what form they will be addressed.
I 9 MR. STANDERFER: In the de-commissioning plan that l
10 would be submitted to the NRC.
11 As Bill says, within two years of discontinuing 12 operations, at least one year before the end of the license, 13 and I believe that the final rule had a five year period in it i
! 14 for plants that didn't fall in either category.
15 MAYOR MORRIS: It seems like we're chasing each other 16 in a circle here. I understand what you're saying with that.
( 17 All I'm saying, and nobody is saying anything differently, is 18 that I'm not hearing what that means -- that you have assure 19 that there's guarantee of a certain amount of money in place by 20 a certain given time period.
21 I'm not hearing anything like that. I'm just hearing 22 that you say you have to submit a plan.
1 23 MR. STANDERFER: That has a funding arrangements in ;
i l 24 it. l l
25 MAYOR MORRIS: It has a funding arrangement in it.
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106 1 MR. STANDERFER: Yes. ,
i 2 MAYOR MORRIS: But it doesn't say what that funding-3 arrangement shall be. Obviously, it's got to be fairly 4 general, but again it's not as specific as,_I guess, certain 5 people are looking for.
6 MR. STANDERFER: Yes.
7 MAYOR MORRIS: Are there any questions that anybody 8 from the panel has at this point of Frank's comments here?
9 MR. ROTH: All right. This goes back to the meeting
- 10 on April 14th, and it's very brief. I just wanted some 11 clarification. .
l 12 We had asked you to provide some background on the l
l 13 evaporator and other TMI-2 project decisions which require the 14 expenditure of funds before there was an NRC approval to 15 implement that particular task, and you go on to say the 16 purpose of this letter is to provide that background, t
17 I have the letter here, and I also ielieve -- and I 18 don't have a copy of April 14th's minutes since I guess I live I
19 in a rural area and it hasn't arrived yet -- but I do believe j 20 that you and I did discuss the fact, and you mentioned the 21 fact, that there were some times when you went ahead with 22 something and the NRC did not give you the approval.
! 23 I asked if that could be included in this letter, 24 also. Since it wasn't, I am wondering is that because there i l
25 weren't any or it was simply an oversight on your part on not j Heritage Reporting Corporation (202) 628-4888
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107 1 including it.
2 MR. STANDERFER: I have some minor cases where we 3 discontinued work because we didn't believe we'd get approval.
4 A number of these cases here, you notice, that when 5 we requested approval, the NRC's initial reaction required 6 considerable re-work and considerable additional costs to make 7 the proposal satisfactory to the NRC.
8 In some cases we could have chosen to discontinue 9 that approach. In most cases, we continued to make 10 modifications until we received approval.
11 So, in practice, what happens is in achieving 12 approval we might have to make substantial modifications to our 13 original plans and, in fact, junk some equipment if they had tc 14 be re-fabricated. 1 15 So, generally, you make changes until you can receive 16 approval. Approval is not necessarily automatic on the first 17 submission.
18 MR. ROTH: Okay. Just one further question, not to ;
19 belabor it. I guess then I'm asking on an overall piece of 20 equipment I can understand modifications. I guess what I'd 21 like to know is in a generic sense, say a project, you know --
22 like the evaporator, pieces of the evaporator. I was just 23 wondering, and that's what I had stated at the April 14th 24 meeting. Maybe I didn't make that clear.
25 A project that the NRC did not --
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108 1 MR. STANDERFER: Well, clearly, there's two big 2 reactors in'the northwest that -- ,
3 MR. ROTH: Well, now, I'm more interested in the ,
4 reactors on the river.
5 MR. STANDERFER: Yes. Yes.
6 MR. ROTH: So, if there any, I would appreciate 7 knowing a project that, you know, the NRC did not go along with 8 once you submitted it.
9 MR. STANDERFER: We have no significant project which 10 we didn't continue to develop it until it was satisfactory.
11 MRs ROTH: Thank you. Thank you, Frank.
12 MAYOR MORRIS: At this time, if we could talk about 13 where we go from here, particularly on this issue.
14 Does the panel have the same sense that I have that a
15 we should not tonight be attempting to take any action on this 16 particular document and that we should wait until we meet 17 again.
i
] 18 Anybody disagree with that? Okay. What's your 19 pleasure on the next meeting. How do you feel about a June 20 meeting versus a July meeting.
21 Let me just, as I say that, indicate that in July my 22 schedule is such that I'm fine, I think, the first ten days or 23 so, or eleven days in July after that I start developing 24 schedule problems throughout the rest of July, 25 So, if it would be in July, for me to be present, I Heritage Reporting Corporation (202) 628-4888 i I I i
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+
l 109 1 would ask that it be fairly early in that month. ;
i l '2- Anybody want to speak to a meeting date? ,
3 MR. LUETZELSCHWAB Tne first week is out for~me. I 4 think we may have --
l 5 MR. GERUSKY: The'first week is out for me,.too, for 6 the same reason.
7 MAYOR ltORRIS: Okay. What is the second week, 8 Thursday date. The 14th?
9 MR. GEh0 SKY: July the 7th and July 14th are the 10 first two Thursdays.
11 MAYOR MORRIS: Okay. I th' ink I'm. going to have a 12 problem with the 14th, but I don't my schedule to be the 13 overriding factor. Is there anytime earlier that week that l 14 would suit panel members? The 12th is bad, Joel?
15 MR. ROTH: I would go along with the majority, as I 16 usually don't.
17 (Laughter.)
18 MR. ROTH: Whatever is convenient, you know, for the 19 majority to do. Sure.
20 MAYOR MORRIS: Well, typically we go with a Thursday I
\
21 and I think most people have pretty well scheduled their time l
22 around that.
23 If the pleasure is for the 14th I don't know whether 24 I'm going to be able to be here or not, but we can at least try 25 to shoot for that.
Heritage Reporting Corporation (202) 628-4888
l 110 1 DR. WALD' That's Bastille Day.
2 MAYOR MORRIS: Well, then I know I don't be here.
3 (Laughter.)
-4 MAYOR MORRIS: Any problems from anyb'ody else on the 5 14th? Well, why don't we tentatively use July the 14th, with 6 the comment that it's my recollection that I will not be able 7 to make it. So, Joel would end up chairing that particular 8 meeting.
9 For agenda items, I would assume that we would j
10 . schedule the PDMS as the main item for discussion. Does l 11 anybody else have another item that they feel we should add? ,
l >
12 If not, then we would make that as the main one.
13 I did hear from Neil Wald earlier this evening that 14 he just visited Chernobyl and has some slides that he took that 15 he said he would be happy to share with us at some point. So, 16 if we don't do it at the meeting, unless there would be 17 problems with the panel, I would like at some point in the not 18 too distant future, maybe not at the next meeting, to have you 19 do that because I think it would be interesting to see those 20 slides.
21 The NRC might tell us we ought not to be doing those 22 things, but unless we hear otherwise --
23 MR. GERUSKY: A nuclear reactor accident, too. ;
1 24 MAYOR MORRIS: Okay. Fine. How about the next 25 meeting with the Commission?
l l
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-j 1 1 111 1 DR. TRAVERS: Do you want to first fix the location I 2 for the next meeting? Do you want to have it in Harrisburg or 3 Lancaster, or do you want to wait and see where we go on that?
4 MAYOR MORRIS: Here seems to be the right place. I'd 5 hate to see you hold it in Lancaster and then not show for it, 6 so. Let's suggest that it be in Harrisburg, unless anybody 7 strongly disagrees.
8 The question was will we have answers to some of the 9 questions that have been raised this evening by that date? Go 10 ahead. I'm sorry. Ken.
11 MR. MILLER: I think Bill had said by July 5th they 12 would have all the questions or responses in from the l 13 Intervenors in the Accident Generated Water situation?
, 14 DR. TRAVERS: Let me take a look at my notes.
15 MR. MILLER: I was wondering if we could get some 16 sort of an indication of what those concerns are.
17 DR. TRAVERS: Since I haven't been involved in it for 18 the last month, let me just go down this list very quickly 19 again, as best I understand it.
,, 20 GPU has filed a motion for summary disposition of a I 21 number, I think may be all, of the contentions that have been 22 raised by Intervenors.
3 23 Staff and Intervernor responses to that motion are 1
24 due by June 20th, and then apparently any party opposing GPU's j 25 motion has nn opportunity to respond to any new argument raised Heritage Reporting Corporation (202) 628-4888 {
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112
, f 1 by GPU's motiott and that process is scheduled to end on or ;
! 2 about' July 5th. That's an approximation. j i 3 MS. CORRADI: Well, I think that's new arguments e
4 raised by the --
5 MAYOR MORRIS: Please. If anybody,else wants to add 6 -- for the record.
f 7 DR. TRAVERS: I think I said it's new issues raised 8 by the summary disposition motion by the licenseo.
9 MR. MILLER: Your words were counter-respouses.
10 CR. TRAVERS: Excuse me. That's the process as best 4 ,
4 11 I can --
12 MR. MILLER: I'd like to get an update on what's 13 going on with that.
14 MAYOR MORRIS: Okay. We would schedule an update.
15 DR. TRAVERS: Yes.
16 MAYOR MORRIS: On that particular issue. l
! 17 DR. TRAVERS: I think Mike plans to keep the panel !
l 18 fully informed of what's going on in that regard. .
19 MR. ROTH: One further thing, Bill, or note.
20 DR. TRAVERS: Yes..
21 MR. ROTH: Could you supply that new directive on the 22 de-commissioning that you said is just about --
23 MR. STANDERFER: I think it may have been issued. I 24 may have learned something new tonight. We will supply the new
- 25 de-commissioning final rule to the panel, i 4 i
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! 113 1 MAYOR MORRIS: Thank you. Okay. I see a question.
2 Please come forward. I'm really -- this will be the last one 3 tonight, then we've got to conclude what we're here for.
~
4 MS. EPSTEIN: My question's really directly relevant ,
5 to the agenda next time which I thought Mr. Miller was getting !
6 at there, 7 MAYOR MORRIS: Okay. Yes.
i 8 MS. EPSTEIN: Would it be possible to have the :
l 9 questions that Eric and Vera, and Ken raised some, too, and ;
10 myself -- have those questions answered as part of the agenda l 11 for the next meeting?
12 MAYOR MORRIS: What I indicated earlier on that I 13 thought was agreed to was that when we set the date, which now '
14 is July 14th, that we would ask the NRC to try to have answers 15 to the questions two weeks' prior to that date, and I would ask ;
1 16 them really if they would mail them out to the individual that l
l 17 asked the question, and also send copies to the panel members.
18 MS. EPSTEIN: Okay.
19 MAYOR MORRIS: Now, that would give you a chance 20 ahead of time to review those answers, and then if you want to
- 21 ask additional questions or pursue them, that's your choice. I 1
- l 22 would rather do that than -- i 23 First of all, it looks like we've got this extension.
24 I don't know if we're going to get another one. So, we're l 25 going to have to, if we need to comment, comment by the end of l L
i Heritage Reporting Corporation !
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114 1 1 _ July or somewhere around that time.
2 We're meeting on July 14th. We will not have a ,
3 chance for another meeting, so I think it's better for you and 4 for us if 're get them answered ahead of time. l 5 MS. EPSTEIN: Okay. ,
i i
6 MS. CORRADI: Does that include -- !
7 MAYOR MORRIS: Please. The question is -- if you-8 have a question from the audience, just raise your hand and 9 we'll have you come forward.
10 That includes -- I am directing that to everybody l 11 that had the questions directed at them -- particularly GPU and 12 the NRC. So, there will need to be, hopefully, Bill, some j 13 discussion of the questions that were submitted between GPU and 14 the NRC to determine which ones should be answered and which P
15 question.
16 I know that's going to take some interpretation, but l
17 I would ask that that be done and that you divvy those i 18 questions up to the right party and then submit the answers ,
i i 19 directly to the person that raised the questions and copies to i 20 the panel members. Okay?
21 MS. EPSTEIN: Okay. Thanks. l 22 MAYOR MORRIS: Of course, if we could get copies of
)
2 i 23 the questions with the copy of the answer, it will be helpful.
24 DR. TRAVERS: Why?
{ 25 MAYOR MORRIS: Yeah. Why. Yeah, okay.
i Heritage Reporting Corporation
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115 1 Back to the question regarding a meeting with the ,
i 2 Commissioners. This seems like an important thing for us to be- l l
3 able to cscuss with the Commissioners and until we've really I 4 had a .' the July 14th meeting, it seems to me we l 5 probat n't be trying to meet with the Commissioners. ;
6 Again, c raising that. That we should meet with them 7 sore time tnereafter.
0 When do you feel, I guess, would be might a date that 9 we could get a meeting?~ Could we, for instance, meet with them i
10 sometime in August?
11 Comments would have been submitted on this at that 12 point. There would have been no decision made by the ,
l 13 Commissioners. So, I would wonder whether some kind of meeting 14 could be set up in August for us?
15 DR. TRAVERS: I obviously can't speak for 'he 16 Commissioners here and now, but we'll look into it. I can give 17 you a call or --
18 MAYOR MORRIS: Okay. Do panel members have a problem 19 with trying to get a meeting in that time frame? If not, why 20 don't --
21 DR. WALD: At the end of August would be --
22 MAYOR MORRIS: End of August. l l
23 DR. TRAVERS: _End of August? Okay. Mike and I will 24 look into that and particularly inform all the panel members.
25 We're going to have to pick a date and go with it, and hope l
Heritage Reporting Corporation (202) 628-4888 .
116' 1 that everyone can make that date because if we wait for the 2 next meeting-to ask everyone around,-then turn around and ask 3 the five Commissioners --
4 MAYOR MORRIS: Don't do that. There's no doubt that 5 at that time of the year, some people are going to be on 6 vacation and we're going to miss some 17 embers, but I think it's 7 better that you pick a date towards the end of August. 'Unless l 8 we find out that date only suits only two or three people and 1 l
9 it's a problem, we'll go with it. l 10 Okay. I did ask Neil Wald how long his presentation 11 would be, his slide presentation, and he scid he could do it 12 within about 15 minutes, so really --
13 DR. WALD: I could also take an hour.
14 (Laughter.)
l 15 MAYOR MORRIS: It depends. If it's an hour l 16 presentata n --
l 17 DR. WALD: Right.
! 18 MAYOR MORRIS: -- we would not do it at the next l
l 19 meeting. If it's 15 minutes, we would do that maybe early in 20 the meeting and we will provide adequate time for the PDMS, but 21 I think that would be an interesting topic. Let's schedule j 22 that as well.
t 23 So, it will be three items at least scheduled, the l 24 major item being the PDMS, update from the NRC on the l
l 25 evaporation matter, and Neil's presentation.
I i
Heritage Reporting Corporation (202) 628-4888
4' 117.
'l Hearing no other discussion, we.' stand-adjourned.
2 (Whereupon, at 10:06 p.m., the meeting was 1
3 adjourned.'). i 1
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'24 25 Heritage Reporting . Corporation (202) 628-4888
1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter of:
5 Name: Meeting: The Advisory Panel for the Decontamination of Three Mile Island, Unit 2 6
s 7 Docket Number:
8 Place: Harrisburg, Pennsylvania 9 Date: May 26, 1988 10 were held as hert..n appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate record of the foregoing proceedings.
16 /S/ /1 t [3Y O7' [ ert / M A 17 (Signature typed): Andrew M. Emerson 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 ,
l 24 25 Heritage Reporting Corporation (202) 628-4888 )
l l
l c - . . . _ , --
a Txact Mitt isLAN3 ALERT, INC.
E 315 Pef for St. liarrisburg. Peena.17102 (717)233 7897
\
l TMI-ALERT's COMMENTS TO Tile ADVISORY PANEL ON PDMS My name is Eric Epstein and I am the spokesperson for TMI-Alert. I would like to comment on the staff's Programmatic l Environmental Impact Statement on Post-Defueling Monitored i Storage at TMI.
In reviewing the staf f 's comments I was struck by several l familiar and disturbing themes.
First, there is a. heavy reliance on data supplied by GPU.
This lack of independence, coupled with the staf f 's propensity to i
I rely on outdated data, cast a shadow on the veracity of this I document.
1 Secondly, the PEIS relies heavily on assusptions and conjecture relating to such items as the state of robotics and l I
cleanup technology, radiation locations, radiation levels, and GPU 's commitment and ability (economic health) to clean the plant up. Thus the PEIS is too abstract and theoretical, and allows GPU the flexibility of finishing the cleanup when and how it sees l fit. This is clearly a textbook lesson on how not to regulate.
Let me remind you that GPU has a knack for making rosy projections that have failed to materialize. For instance, we l were originally told that, "Decontamination of the containment I building will take until late 1982. Then we'll need the balance '
of 1982 and 1983 for fuel removal" (Robert Arnold, The Evening News, July 14, 1980). It is now 1988 and fuel is still being "recovered" and "removed." The original projected cost of S400 million, is approaching $1 billion, roughly what it cost to build Unit-1 gnd Unit-2. Yet the same people who are so proud of their pioneering accomplishments are content to mothball the plant indefinitely.
Actually, if you look at some recent events at Unit-2 it '
would seem as though the plant is already mothballed: January 19,
- 1988, GPU notified the NRC "that the training qualifications of a 1 senior health physics technician (IIPT) had lapsed several months l i
in the past;" February 22 and 27, 1988, fires occurred in the Decontamination Facility of the reactor building, and in both instances assigned fire extinguishers failed to operate; and, April 1, 1988, NRC inspectors toured the reactor building and determined that "housekeeping on all elevations had deteriorated in that paper towels, cardboard tags, plastic bags, and other transient combustible materials were scattered in work areas and
' low usage areas". ( Source: NRC Inspection' Reports 50-320/87-15, 50-320/88-03, 50-320/88-01, 50-320/88-05).
Throughout the PEIS the NRC clearly accepted GPU's proposition that Post-Defueling Monitored Storage is somehow separate and distinct from the cleanup. This is absurd. The cleanup of Three Mile Island should not come toIscreeching halt '
because GPU and the NRC have established an arbitrary end point.
Ironically, some of the same arguments the staff used against radioactive water storage were employed to endorse a postponement of the cleanup. For instance, the staff argued that postponement will'significantly reduce radiation levels and allow time for the development of innovative technologies to deal with some of the problems created by the accident.
In contrast, TMI-Alert and other concerned citizens have consistently called for an expedited and safe cleanup, which will hopefully include a resolution to the water problem that will not result in direct, radioactive releases to the public and the environment (TMIA supports transporting the the sludge off-site to a low-level waste site, the Nevada Test Site or the Hanford Reservation).
GPU has the means, both economical and technological, as well as an experienced work force at its disposal, to continue the cleanup. Moreover, the staff did not have a clear preference in resolving this issue, and stated that the "TMI-2 site should not be allowed to become a waste disposal site" (NUREG-0683, PEIS, 3.1.5). The public has a clear preference, and we want to give the Panel a message to convey to the Commissioners: clean the plant up now! Cleanup means finishing the job you started, regardless if takes four or four hundred years. Radiation doesn't
)
take vacations, and neither should GPU or the NRC. We can not i allow these people to walk away from their commitment.
i Let me conclude by saying that there are several problems l intricately intertwined with the timing of the cleanup. To postpone the cleanup is to postpone the inevitable decontamination and decommissioning of Unit-2. It is high time for GPU, the NRC, the DOE, and the industry to admit that they do not know how to decommission and decontaminate a nuclear power plant. Due to their collective ineptitude and overzealousness, there is a crippled, but dangerous plant, in the middle of the
. Susquehan7a River that needs to be retired. But there 's a catch:
GPU doesn't want to clean it up just yet, the NRC is content to leave the plant in limbo-land, and nobody knows just how to
. decontaminate and decommission it. )
e 3
2
.. - . - . - , - - - ~ .. . - - -
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l l Questions on ])DMS
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- 1. 2.1 The staff noted that, "The primary difference between an undamaged reactor at the end of its useful life and the I
' licensee's PDMS proposal is that during PDMS relatively high levels of contamination would remain in the. reactor building basement and a small amount of residual fuel would remain in the reactor coolant system storage."
a What factual data are these conclusions derived from? How many "undamaged reactors at the end" of their "useful" lives have the NRC dealt with? Were technical experts from these plants consulted? If so, is their input a matter of puolic record? What other differences exist between these plants and GPU's PDMS plan?
Was embrittlement a factor at these plants? What was the staf fing levels at these plants?
- 2. 2.1.1 The s taf f a rgued that, "The reactor containment building is uniquely designed and constructed to maintain its structural integrity (with almost no leakage) during a wide variety of accidents."
How long after an accident was the RCB designed to maintain its integrity? Was it specifically designed to house radioactive waste materials for an indefinite period of time? If not, would not storage of such wastes necessitate a license amendment?
i
- 3. 2.4 How permanent are "permanent dose reduction techniques?"
- 4. 2.1.2 "Sectioning and dispesal of the reactor internals and l reactor vessel are not considered part of the cleanup because I radiation levels expected from these components would be no l higher than in a normal reactor nearing the end of its life." l What are "sectioning and positioning of the reactor l internals" part of? What if radiation levels are incorrect? What exactly are the radiation levels of a "normal reactor at the end
! I i
of its life?" What constitutes a normal reactor?
5. 2.1.4 What unique problems will the AFHB pose since it "was not designed to be leak free..." during a"... variety of accidents?" How much, and just exactly what, leaks from the APHB?
. What are the dose levels found in AFHB at the end of its life?
- 6. 2.2.1 Why weren't new calculations taken concerning the number and quantity of remaining radionuclides? Does the NRC or GPU have I
a comprehensive inventory of the radionuclides released since I the accident? Is it possible for radiation levels to shif t or relocate l from one section of the plant to another? If so, isn't possible that sections designated to have certain radiation levels may now be inconsistent with GPU's endpoint criteria?
t 3
- 7. 2.2.2.3 "The efforts that are being made to leach radioactivity from the concrete-block wall may reduce this inventory somewhat."
How much is "somewhat?" What levels are acceptable and/or desired'tur the NRC? Is the staff aware that GPU has already made incorrect projections in this area: "They predict about 6 to 8 years of leaching will be required to reduce the block wall activity to 10% of the present value. This may be compared to an earlier prediction made by Dr. Godbee of about two years" l Task Force Report: Reactor Building Basement Decontamination, p.9).
. 8. 2.3.3 Re: U.S. NRC's proposed decommissioning plans. At what levels would "unrestricted" use of TMI be acceptable?
- . 9. 3.1.5 Physically there is no difference between PDMS and the No-Action Alternative. (Theoretically preparation for PDMS appears to be the qualifier). When does the PDMS plan become the No- i Action Alternative option?
- 10. 3.2.1.2 What are the advantages of storing the plenum dry?
- 11. 3.2.1.3 Is "ventilating" the reactor building before each entry the same as purging it?
- 12. 3.2.2.1 Can the NRC quantify radiation levels produced by
"... aggressive decontamination efforts...?" (p. 3.16).
- 13. 3.2.2.1 How will the liquid releases to the Susquehanna River following PDMS differ in composition to the 2.3 million gallons of
}'
radioactive water currently stored at TMI? (p. 3.17).
- 14. 3.2.2.2 By NRC standards, was the March 1979 accident at TMI-2 considered "credible?"
- 15. 3.2.6 Does the NRC have an approved method for waste disposal, i.e. shallow burial vs. above ground monitored storage? j
- 16. 3.2.7 Is the public entitled to intervene-if GPU implemented "long-term monitored storage of the facility?"
i
- 17. 3.3.2. Is there any discernible difference for the potential of accidental releases during immediate cleanup as opposed PDMS?
- 18. 3.3.3 What are the occupational dose levels of "...an undamaged reactor, nearing the end of its life...?" i
- 19. 5.1 If the cost of the cleanup is figured in 1988 dollars, then estimates for delayed cleanup are imprecise and inaccurate.
Did the NRC factors such costs as retraining and rehiring workers or corporate insolvency and/or bankruptcy?
1 :
4 i
P CafY Mrs. Leo Orey 515 West Point Avenue -
,inivenity City, MO 63130 k April 2, 1988 l Mayor Glenn Sheffield Webster Groves City Hall 4 East Lockwood St. Louis, MO 63119 Dear Glenn It was good having the opportunity to meet with you yesterday. I';
sure *you must know that many people appreciate the time and effcet you have put into trying to understand the conflicting views about the Three Mile Island fuel shipments -- on the one hand, the concerns of the citizene who live along the route, and on the other, the assurances of the "experts" (the folks paid to assure the citizens that all is safe). It's easy with h inds ight, after an accident, to wonder how a dangerous activity could have been allowed (e.g., disposing of dioxin by spreading it along roads and on horse stable floors, or continuing to manufacture and install asbestos some 45 years after physicians knew of its hazards). It's a lot harder to raise questiens before the f act, that is, before an accident that -- with luck --
ray never occur.
I I realize this letter may well be the straw that finally topples over your huge pile of papers and reports about this cne concern. And I realize, too,
! I that you as mayor have many concerns' But here goes anyway.
- \.
)> I want te try to explain theyfour federal laws} that we think are being ig-nored, in preparation for your meeting here in St. Louis on Thursday with Terry Smith of EG&G Idaho, the DOE contractor for the clean-up, shipping and storage of the TMI fuel. Starting with the most recent law first:
- 1. The Nuclear Waste Policy Act of 1982 dictates that commercial irradiated c nuclear fuel is to be kept at reactor sites until a federal fuel reposi-tory is in operation. At that . time if the electric utility has paid in full for the permanent diseosal costs, the Departme st of Energy may take title to the fuel. GPU Nuclear, the owners of Three Mile Island, has l not paid for the disposal costs for its Unit 2 fuel and has only paid La '
part through 1988 for the interim storage costs.
This law does provide for the storage of a limited amount of commercial irradiated fuel at DOE facilities, but only if the Nuclear Regulatory Commission has first determined that the spent fuel pool at an operating nuclear reactor is so full that the reactor can no longer operate. The NRC has not made this determination about TMI-Unit 2, and Unit 2 is not an operating reactor. Unit One at the Three Mile Island plant is opera-ting,but its fuel pool is not filled up.
If the NRC believes that the TMI island is safe .enough to contain Unit 1 as an operating reactor (with from 15 to 20 billion curies in its reactor i
vessel and several hundred million curies in its fuel pool), the island should be considered safe enough to contain Unit 2's fuel pool (with what remains of the estimated 3 to 4 million curies of damaged fuel).
Or conversely, if Unit Two's fuel'is in too unpredictable a condition to
)
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Mcyor Glenn She ffield -- April 2,1988 -- pago two j i
stay on an island in Pennsylvania, how can the DOE or the NRC predict )
that it's safe enough to ship through downtewn and residential Pittsburgh, I l
Canton, Indianapolis, St. Louis ...? '
1 In addition, if a significant amount of commercial fuel is proposed for l storage at a DOE f acility, the Nuclear Waste Policy Act mandates .that an environmental assessment or impact statement must first be prepared, coa- l plete with. public hearings along the fuel shipment route.
- 2. The Energy Reorganization Act of 1974 dictates that the Nuclear Regulatory Commis sion, not the Department of Ener'gy, has surveillance and regulatory
, , responsibility for commercial nuclear power plants -- including all commer- l cial irradiated fuel (except small amounts for research) until such time i as a permanent federal fuel repository is in operation. (A site hasn't even j been approved as yet for the first repository.) Any away-from-reactor ;
facility used for the interim storage of a commercial reactor's irradiated fuel core (except small amounts for research) must have an NRC license .
under the Code of Federal Regulations, Title 10, Part 72. I
- 3. The National Environmental Policy Act of 1969 says that any major federal action that could significantly affcet the human environment requires at least an environmental assessment, if not a full environmental impact statement. The NRC's March 1981 programmatic EIS on the IMI-2 cleanup is not ad equat e. The DOE's fuel shipping and storage project is unique and cries out for an EIS. This project entails the shipping of an entire damaged fuel core some 2400 miles from one interim storage pool to another, in 4 hastily designed and fabricated canisters and casks -- using technologies never needed before because melted fuel in such quantities has never been shipped before, not even in Russia -- along a route described as follows by Senator John Danforth on May 12, 1987, at a Senata Commerce surface transportation subcommittee hearing: "It seems to me you (DOE] made a i beeline for large population centers." I 1
4 The Atomic Energy Act of 1954 says the federal government is not to '
subsidize commercial nuclear power plants. General Public Utilities, the i owners of TMI, has only paid "for some of the shipment costs and for l interim storage at the Idaho National Engineering Laboratory (INEL) only through 1988. Congress never agreed to have taxpayers nationwide bail out GPU for its huge, ongoing clean-up and decommissioning costs.
~
One final points Congress does not allow commercial nuclear fuel to be commingled with militarv nuclear fuel. Hearings have just been held in the past two weeks in (daho on the Draft Environmental Impact Statement of the
, proposed construction at INEL of a Special Isotope Separation facility at which plutonium would be extracted fron military spent fuel for use in making weapons.
Would anyone even remember someday to ask which fuel in the INEL Water Pit was to be used for weapons and which was to be kept for an indefinite period until a permanent repository for commercial fuel is built someday, somewhere?
.- Our original question is now two years olds why is .the Department of Energy k' shipping the full TMI fuel core? Our newer question is t are they doing it ,
with the authority of Congress? We hope you will join with Congressmen Bill ~
Clay and Dict Gephardt in requesting that Congressman Luken's Energy and Commerce subcommittee on transportation holu an oversight hearing.
S inc erely,
Comments Relative to Treatment and Disposal of 2,100,000 gal. of Contaminated Water at TMI-2 by Karl Z. Morgan
. March 19., 1987
- , Qualifications to Express an Opinion 1 - So far as I can determine I am the first person to publish a pcper showing how to calculate dose from internal exposure to ionizing radiation and set standards of MPC (Tolerance Concentration of Radioactive Substances," by K.Z.
l Morgan, J. Phys. & Colloto Chem. 51, 984, 1947).
2 - I was chairman of the Internal Dose Committees of both ICRP and NCRP for about two decades.
l 3 - I have worked with and researched ionizing radiation and health physics l
problems for over 50 years. l l
Materials Reviewed in Preparing These Comments 1 - NUREG-0683 Sup. No. 2 (draft report) 2 - GPU Nuclear Corp. Attachment 4410-87-L-0023 l
3 - GPU Nuclear Corp. Attachments 4410-86-L-0178 l
4 - NCRP Commentary No. 4, "Guidelines for the Release of Waste Water from Nuclear Facilities with Special Reference to the Public Health Significance of the Proposed Release of Treated Waste Waters at TMI," 1987 Comments l l
My comments are very brief because I have been able to spend only two days on this review.
l 1
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Comments on NCRP-Comm. No. 4 Report I believe that although the task group that prepared this report contained some experts in the area of radioactive waste disposal (e.g. F. L. Parker, J. W.
Healy and D. G. Jacobs), the final conclusions should not be accepted in the de-
- cision to dispose of the radioactive water by the methods proposed by GPU without some modifications. I agree with their conclusion that after evaporation the vapor should not be released up the 50 meter stack but pumped to the 11,000 gal.
condensate test tanks. Discharging the condensate via mixing with the 22,000 gal, per minute blow down water from the draft cooling tower is far better than direct discharge to the river but I am opposed to this method of disposal. I 6
urge that, rather, investigation be made of disposal of the 2.1 x 10 g,1, og t water by one of the following methods listed in decreasing order of preference.
1 - Load the water (condensed vapor) into tank cars and ship and transload
{
on a boat for disposal at sea. This would provide a far more rapid meons of dilution. This method of sea disposal should receive no seriouc challenge by those concerned with our International Agreements Regarding Sea Disposal because of the relatively low level of radio-activity and predominance of H-3. Using this method of disposal the insult to the marine environment and to man would be orders of mag-nitude less than those posed by the English operations near Seascale where they discharge radioactive waste into the Idsh Sea. The shipment of the 420 carloads using 5,000 gal, tank cars should present no seri-ous risks.
2 - Load the water (condensed vapor) in 5,000 gal. tank cars and send to a site prepared to dispose of the water by deep-well injection. Con-k One of these is that of the London Dumping Convention, IMO-198.
2 l
1 .. .
sidering there will be very little solid material in this condensate, deep-well disposal is made to order.
3 - Dispose of the water (condensed vapor) by shipping in 5,000 gal, tank cars to a site prepared to dispose of it by the hydrofracture method.
Cocnents on the NUREG-0683 Sup. No. 2 Report and the Two GPU Attachments These reports as well as the NCRP report underestimate throughout the dis-cussions the dose to the individual (rems) and the population dose (person rems).
The NCRP report is doubly at fault in that it uses values of c (the cancer coef-ficient = cancers (either incidence or mortality) = 10'4 cancers /personrem) which I and many others in this field believe is low at least by an order of
~3 magnitude, i.e. the value should be no less than 10 cancer deaths per person rem. (See the chapter, p. 216-229, in the Encyclopaedia Britanica, "Hazards of Iow-Level Radiation," by K.Z. Morgan. Copy attached.)
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This NUREG report gives a table No. 2.5 of the NRC concentrations in air and water (above background) that are acceptable in restricted areas. Below I re-produce the first and third columns from this table but add the EPA values I calculatethatarebasedontheEPAlimitof4mrems/ytothetotalbodyfor drinking water. Values are not given by EPA for bone so in this table I increased !
the value for bone from 4 mrem per year (for total body) to (30/5) y 4 = 24 mrem /y
- because the ICRP-2 limit for occupational exposure of bone is 30 rem /y and the limit for total body is 5 rem /y.
o f Isotope Water Activity Water Activity l Limit of NRC (uCi/cc) Limit of EPA (uCi/cc) l H-3 S-T B 3 x 10-5 2.4 x 10 I 3 x 10'5 --
Sub -- --
f 3
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Isotope Water Activity Water Activity Limit of NRC (uCi/cc) Limit of EPA (uCi/ce)
Cs-137 S-TB 2x10[f 1.6 x 10" I 4 y 10 --
Sr-90 S-B 3 x 10 -7 3.2 X 10 ~9 I 4 x 10"' --
- S = Soluble, I = Insoluble, TB = Total Body, B = Bone Here it is noted there is essential agreement for H-3 but the NRC value is 125 times the EPA value for Cs-137 and 12,500 times the equivalent value for Sr-90.
When two Government Agencies differ to such extremes in evaluating an en-vironmental risk, I believe the peoples' court, DA, in the interest of safety, should insist the more conservative agency and the one in this case established to protect man and his environment, takes precedence.
([ Next, I took a quick look at Tables 2.2 and 2.3 in NUREG-0683 Sup. No. 2 and the tables in the two GPU Attachments. The data in these tables were some-what surprising. Below in columns 2 and 3 (1st two items) I give data from these tables. Where the values in these reports differed, I entered in column 2 the value that was published last. I derived equations (see Appendix) and made a number of calculations (having available only a hand calculator) and entered i
some of the results in the above table. All the values are for the adult (standard or reference man). The doses in most cases would have been considerably larger for the child but I have not had time to make these calculations. The dose values marked (a) given in NUREG should check with my calculated values of dose marked (b) but it will be noted two of my values, 14 mrem for H-3 and 3,680 mrem for Sr-90, are larger than the NUREG values that are 7.8 mrem for H-3 and 960 mrem for Sr-90. My value of 1.6 mrem for 0s-137 is lower than the NUREG r
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value of 2.6 mrem. These differences should be investigated.
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= * *
-s q -
Radionuclide, (fg ), and Base Case Achievable Values (Effective Half-T,ife)
H-3-(fg=1) (10 days in total body)
Activity (pCi/cc) 0.13 0.13 Dose Estimates (mrem) g NUREG-0683-2 7.8 TB 7.8 mrem TB One year dose from continuous exposure 10,600 TB 70 year dose from continuous exposure 7.7 y 105 TB Dose from 1 day's intake of 103 cc water 14(b) TB Dose from 1 day's intake of 2,200 cc water / day 30 TB Cs-137 (f g=1) (70 days in total body)
Activity (pCi/ce) 3.7 y 10 -5 4.0 x 10~
Dose Estimates (mrem)
NUREG-0683-2 2.6(*}TB, 3.0 B 0.29 TB, 0.32 B One year dose from continuous exposure 947 TB v' 70 year dose from continuous exposure 90, TB Dose from 1 day's intake of 1,000 cc water 1.6 TB Dose from 1 day's intake of 2,200 cc water 3.6 TB Sr-90 (fg=0.09) (17.53 years in bone)
-5 Activity ( Ci/cc) 1.1 X 10' 1.0 X 10 Dose Estimates (mrem).
NUREG-0683-2 960 B, 19 TB 87 B, 1.8 TB One year dose from continuous exposure 57,600 B 70 year dose from continuous exposure 137,000 000 B Dose from 1 day's intake of 1,000 cc water 3,680(bj B Dose from 1 day's intake of 2,200 cc water 8,090 B
- .. peg ~
Radionuclide, (f , and Ba:e Case Achievable Values (Ef fective Half g)Li fe)
Ru-106 (f _y=0.03) (7.2 days in kidney)
Activity ( Ci/cc) < 3.1 y 10~
Dose Estimates (mrem)
NUREG-0683-2 -- --
One year dose from continuous exposure < 12 K 70 year dose from continuous exposure < 830 K Dose from 1 day's intake of 1,000 cc water < 0.015 K Dose from 1 day's intake of 2,200 cc of water < 0.032 K Dose to GIT (LLI) from 1 year's continuous exposure < 47 CIT Ce-144 (fg=3 x 10- ) (268 days in bone) j Activity (pCi/cc) < 1.8 X 10' Dose Estimates (mrem) i NUREG-0683-2 -- --
- One year dose from continuous exposure < 2.7 B o- 70 year dose from continuova exposure < 532 B
, Dose from 1 day's intake of 1,000 cc of water < 0.010 B Dose from 1 day's intake of 2,200 cc of water < 0.021 B l Dose to GIT (LLI) from 1 year's continuous exposure < 27 GIT Co-60 (E g=0.3) (9.5 days in total body)
-7
. Activity (pCi/cc) GPU 4.8 x 10 Dose Estimates (mrem)
NUREG-0683-2 -- --
! One year dose from continuous exposure 1.67 TB 70 year dose from continuous exposure 122 TB-Dose from 1 day's intake of 1,000 cc of water 0.002 TB Dose from 1 day's intake of 2,200 cc of water 0.005 TB Dose to CIT (LLI) from 1 year's continuous exposure 1.44 GIT
+
i s
1
l . .
Radionuclide, (f ,and Base Case Achievable Values (Ef fective Half g)ife)
L Pu-239 (fg=3 x 10~ ) (72,000 days in bone)
Activity ( C1/cc) GPU < 1.4 y 10~ B Dose Estimates (mrem)
NUREG-0683-2 -- --
One year dose from continuous exposure < 0.24 B 70 year dose from continuous exposure < 1,098 B t Dose from 1 day's intake of 1,000 cc of water < 0.17 B i Dose from 1 day's intake of 2,200 cc of water < 0.38 B l
Dose to GIT (LLI) from 1 year's continuous exposure < 0.07 GIT l
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! TB = total body I
B = bone K = kidney GIT (LLI) = gastro-intestinal tract (lower large intestine) i l
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These values are for an intake of 1,000 cc of the processed water. I don't know why the NRC staff used only one intake of 1,000 cc. The standard man con-sumes 2,200 cc per day, so I made these calculations obtaining 30 mrem for H-3 and 3.6 mrem to total body from Cs-137. Note that these values of one day's
, intake should be compared with the EPA limit of 4 mrem for drinking water. The equivalent EPA values for bone and kidney are (30/5) x 4 = 24 mrem and (15/5) x 4
= 12 mrem where 30 rem /y, 5 rem /y and 15 rem /y are the limiting dose rates for bone, total body and kidney, respectively, for the occupational worker.
I looked at three radionuclides, Sr-90, Ce-144 and Pu-239 for which bone is often the critical body organ. Here it is noted that the values for Sr-90 (3,680 mrem from 1 day's intake of 1,000 cc or 8,090 mrem for 1 day's intake of 2,200 cc far exceed the EPA equivalent limit of 24 mrem per year and most of this dose is in the first year after intaka. The GPU provides no data for ac-tivities of Ru-106, Ce-144 or Pu-239 but their limit of detection is adequate for a single intake of 1,000 cc or 2,200 cc (i.e. 0.015 mrem and 0.032 mrem are
< 12 mrem and 0.01 mrem, 0.021 mrem, 0.17 mrem and 0.38 mrem are less than the 24 mrem / year bone dose limit) .
It seems to me that an evaluation of the dose from one day's intake of 1,000 cc or 2,200 cc of processed water does not strike at the more meaningful evaluation of continuous intake of the processed water. For continuous intake for one year the doses are 10,600 mrem for H-3, 947 mrem for Cs-137, 57,600 mrem for Sr-90, < 12 mrem for Ru-106, < 2.7 mrem for Ce-144, < 1.67 mrem for Co-60 and < 0.24 mrem for Pu-239. Were a standard man to consume this water for 70 years at the projected level of contamination at discharge, the doses would be 770,000 mrem for H-3, 90,300 mrem for Cs-137, 137,000,000 mrem for Sr-90, < 830
( mrem for Ru-106, < 532 mrem for Ce-144, 122 mrem for 5o-60 and < 1,098 mrem for Pu-239. Thus it is seen that levels below the limit of GPU detection would be far in excess of a safe dose for consumption of the water for 70 years.
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1 Finally, I looked at the dose to the GIT from one year's consumption of Ru-106, Ce-144, Co-60 and Pu-239. The values, respectively, are < 47 mrem,
< 27 mrem, 1.44 mrem and.< 0.07 mrem. Thus in all these cases the GIT is not the organ of highest dose, l j
l In Conclusion I believe that the studies made by GPU and by the NRC staff are woefully inadequate and much more data should be provided before deciding the best way
- t to be rid of this problem, i.e. before deciding to let go of the bear we have by the tail.
j./ .
f rif.Morg k,
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Appendix Dose Rate R(mrem / year) = q(u c i) 3.7 x 10 (dis /8 Ci) EQN (MeV/ dis x rem / rad) x 1.602 x 10' (erg /MeV) 1/m (1/g) 10 (mrem / mrad) x 3,600 x 24 x 365 (S/y)
- y1 EQN q y 1/100 (grad / erg) = 1.8 mrem /y (1)
Dose from a Single Intake _
D= Re ' dt = R(1-e' )= *
- 9" 9 ( ~* ) mrem (2)
Dose from Continuous Intake h dq/dt + Aq = P q=f(1-e' )
P = A(cc/y) fgx C( Ci/cc) = 2,200 (cc/d) 365 (d/y) f gC 5
= 8.03 x 10 fC
.t 1.87 x 10 EQN y 8.03 X 10 fG g D= (1-e, g) dt =
I
-At
. D=
- 1. 50 x 10 EQNy f C (t + f
) mrem .(3)
Dose from One Day's Intake after Exposure of t Years q1 = 2,200 f gC 1.87 x 10 EQN 2,200 f yC e OU dt ~
1 .t "c 3 m A-1
4.11 x 10 EQN gf C (1-e- t)
D= "#** (4) mA 0
4.11 x 10 EQN f gG D= mrem for t= (4)
- I Dose to Lower G.T. Tract (Colon) from One Year's Continuous Exposure at ICRP-2 MPC Level 1
(MPC)168 h/w corresponds to R = 15,000 mrem /y dose rate when -
7 exposure time, t, is >> 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> C y 1,500 D mrem (5) y = (MPC)168 7
t' s
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5-26-88 SVA'S STATEMENT TO THE CITIZENS' ADVISORY PANEL CONCERNING NRC'S REVIEW OF GPU NUCLEAR'S PROPOSAL TO PLACE UNIT 2 IN PDMS PRIOR TO COMPLETION OF CLEAN-UP.
I speak for the Susquehanna Valley Alliance whose membership resides mostly ,
in lancaster County and whose mental and physical health stands to be impacted upon by any decisions made about Three Mile Island. Following is a sunmary of our ccuments on the EIS, Supplement #3. I am subnitting a list of questions which I would ask to have answered in a timely manner so that I can review the answers prior to subnitting ccuments to the NRC.
Hot on the heels of the NRC's refusal to permit the storage of the Accident Generated Water at Unit 2 until a more suitable method of disposal was found whereby the radioactivity would be retained instead of dispersed into the enviroment,ccxnes their consent to permit the placing of Unit 2 into a storage mode prior to the ecmpletion of clean-up so that more suitable methods can be found to finish the clean-up. PDMS is only a fancy name to conceal the fact that TMI will after all became a site for the storage of radiosctive waste, f Indeed PDMS closely resembles the no-action alternative since there are no l
assurances that Unit 2 will ever be cleaned up. The NRC speaks of a 20 year storage period,but provides no rationale for choosing this number. The Licensee refuses to ecumit itself! Obviously delayed clean-up solves 2 problems for the licensee
- 1) they do not have to proceed with an area of clean-up which would preclude the restart of Unit 2 and
- 2) they won't have to worry about that messy and inconvenient problem of what to do with the waste. NRC tells us that inmediate clean-up would require additional energency allocations. (EIS Page2.33)
Not so long ago,w heard of NRC's ccumitment to prevent TMI fran beccming a site for the storage of waste. This EIS clears the way for just that. This waste mind you will be in out of the way places,not imnediately available for monitoring.
We are shocked to learn that it will take at least 4 nore years,and who kncus, it could be more,to clean up Unit 2. It seems like only yesterday that we wre being accused of holding up clean-up because we had asked for hearings concerning the disposal of the radioactive accident generated water, khy generate more water when we have already acetnulated the major medium for decontamination?
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One of our major concerns with leaving Unit 2 so contaminated for so many years is based on uncertaintics abeift the amount of radioactivity in ,
7' buildings, pipes and other e mponents. We are inform d in the EIS that the nunber and quantity of the majority of radionuclides are estimated frm the !
amount present at the tin of the accident. The amount present at the time i l
of the accident is based on a emputer code,0rigen 2. A canputer code is only as accurate as the data that a person puts in,so there nust be allwance for errors. Studies have been undertaken to follow the paths of the radionuclides as they were released frm the damaged core. This is an j ongoing project and as one reads through any research reports on the accident one soon is very aware of the uncertainties which exist as to hw and to where i
the radionuclides were dispersed. The NRC recognises this develognental aspect of the clean-up. They state in the EIS, "Although predictions have been made regarding the transport and deposition of materials released as vapors and/or aerosols during core heat-up, refined modeling methods are not available for accurately analysing the transport and deposition of .the fragmentation debris,or the leaching of soluble materials from the da: raged core. " (page 2.22)
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They also state that plans to decontaminate the reactor building fo11 ming PDMS are tentative bt.cause the Licensee has "incomplete information (although currently being obtained) on the amunt and location of contamination" (page 3.10)"
Table 2.4 which shws an estimate of the maxinum amount of radionuclides left and their location,ccmes as a complete surprise in light of these two statements. We want to knw upon what information this table might be based. Fbrthernore,we want to have a complete accounting of the radionuclides present in the core at the time of the accident. looking at just two of the radionuclides, tritium (which the NRC failed to mention was an important activation product) and Krypton 85,it is impossible to account for both of these radionuclides. There were over 8000 curies of tritium and over 97,000 curies of Krypton in the reactor at accident tim . H w does the NRC end up with less than one curie of both tritiun and Krypton-85?
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The approval of MI to beccme a site for the storage of radioactive waste raises questiens about Regulatory procedures and furthermore.the acceptability of this plan to the State of Pennsylvania. If clean-up 'were to continue presently then the waste would go to out of state sites. If it is delayed, it will largely remain within the State. How does the State react to this?
Would the State site be able to acccmmodate this amount of waste? Would it also be expected to accamodate the waste if Unit 2 were to be deemmissioned.,
, How can the NRC dismiss the question of the impact of the waste disposal-by saying that it would.be the subject of an analysis elsewhere. The l
, disposal of the waste at IMI is a major issue to be dealt with at this time in keeping with the requirements of the National Enviromental Policy Act.. Obviously,the people. of Pennsylvania will be impacted upon not only by -
the possible transportation accidents when taking the waste to a site,but also by the possibility that the site will be located in smebody's backyard in Pa.-
Hcu will the NRC deal with the fact that-Unit 2_is..in the 100 year flood plain? Will it have to manoeuver the regulations in sme way that IMI will I be exempt from their requirements?Will 7MI be able to satisfy the ground water intrusion criteria? '
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The health impacts section so neatly resembles all other such sections in Supplements to the EIS. I wish to call the attention of the NRC to see i
revisions of the dosimetry of the survivors of the Japanese atmic bcabings ;
I' which together with the now increased follow-up time for epidemiological studies,are being taken into account by the United Nations Scientific Ccanittee on the Effects of Atcraic Radiation (UNSCEAR: in producing risk estimates for ionizing radiation exposure. This report will be used by ICRP in reviewing its reccomendations on the system of dose limitations. A preliminary reassessment
- , of the Hiroshima and Nagaski survivors has raised the fatal cancer risk I for the exposed population by a total factor of the order of 2. . The risk
- , e'stimates could be substantially greater depending on the form of risk model tised and the snape of the dose reponse curve when exptrapolating.to Icu doses frce observations at high doses. The most important aspect of this information to us is that standards nust continue to be changed so that the public is protected against unnecessary exposare to radiation.
s 2 ~
( One final point,which I nust address to you Mayor Morris concerns the payment c5 the $10,000 by the Licensee to the City of Lancaster for the retrieval
! and analysis of samples of water frcm the Susquehanna river. This was directed
.3. )
wt by the court. We want to' make sure that this payment will continue as long as TMI continues to be radioactive. Water will continue to be poured into
- b. the Susquehanna River. Furthermore,there is a likelihood that other solutions will be added to the water for chemical decontamination. We want to know
- what steps the city will take to monitor this,so that our drinking water will
, be provided some sort of protection.
, This concludes my ecuments on the EIS.
I wish to submit a typewritten copy of DR K.Z.&rgan's statement on EIS Supplement #2,which is related to the-disposal of the AGW. He is opposed to the disposal of the water by evaporation and dispersal of the radioactivity into our air. He views it as an unnecessary exposure to ionizing radiation for the people in this area. He also shows it capable of inflicting'nuch grater damage than the NRC/GPU would admit.
Thank you.
(
O J
B o
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. f 6N QUESTIONS RE1ATING 10 'IME EIS ON GPU NUCLEAP'S PROPOSAL FOR PDMS
(. 1. Due to the uncertainties of radionuclide dispersion and deposition following the accident,upon what infonnation is Table 2.4 based?
- 2. By the time of PDMS,will we know the condition of the containment and the damage to it caused by the accident? How will this infornution be made av?ilable to the Public?
- 3. khile Unit 2 is in PDMS,what research will continue which relates to
, the reactor?
4 Explain the rationale for delaying clean-up. Delay will have no effect on the long-lived radionuclides. Is the delay then for reasons of technological advances?
- 5. How will the number of entries be determined during PDMS?
- 6. Upon what findings and/or studies does the NRC base its assumption that the activity in the top " of the wall becomes available for resuspension?
khat allowances are made for the fa.:t that the walls might enrnble due to stress fran age and clean-up activities already undertaken?
- 7. khat is 10% of each activation product? Upon what information or 7
A studiee do you make the assuuption that 10% of the activation products will '
remain in the reactor building at the end of defueling? (EIS page 2.27,2.2.1) a
- 8. The water which will leak into the system has been detennined to be 5000 gallons per year. Explain why this amount is so much less than the in-leakage for this past 9 years. I
- 9. Page 3.31,Section 3.3.1.1 Explain those measurements which are being presently undertaken? khat is being measured? In what manner will th' results affect decisions about RCS decontamination and the future of the
, facility?
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- 10. khat would preclude the use of the AGW to clean the RCS? '
. 11. Wil'. the water used for further clean-up contain chenicals? How will these be removed fran the water before the water is released to our drinking water supply?
- 12. Page3.32,Section 3.3.1.2 khen do you expect the radiation doses to be low enough to mrmit entry into the basement for canplete clean-up? If they l are presently N. high to permit entry,does this not rule out the possibility I of inmediate clean-up as an alternative to be considered?
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- 13. How can the impact of the waste after disposal at either a regional or other site be considered outside the scope of this EIS?- Delaying clean-up
( has a najor impact on the final resting place for the waste frm 'IMI,since the State of Pa is presently in the process of developing a site. i
- 14. Page 3.19, footnote a. What are the precautions to be taken to ensure that criticality would not occur?
- 15. Between entries,hw will the Licensee kncs that criticality has not occured?
- 16. During entries,how will the workers know that criticality is not occuring? l
- 17. By what means will the Licensee determine the amount of radioactivity in the reactor prior to purging this radioactivity to the enviroment?
- 18. In the event of en incident at Unit 2,how many workers would be available !
at any one time to deal with the emergency-at a time when the workers have been i t
reduced in the first year and then in the second year and thereafter.
Is it possible or likely that erkers frcm Unit 1 would be drawn to Unit 2 to help deal with an emergency?
- 19. Does GPU Nuclear need an amendment to its license before PaiS is enacted.
- 20. Since Unit 2 is in the 100 year flood plain,how will this affeet its License prior to seeking approval for PD4S. I
- 21. Explain why the estimated occupational doses are so nuch higher for [
inrediate clean-up. j
- 22. Explain the subtle difference between the no-action alternative and the Licensee's proposal. What guarantees or laws will preclude the Licensee's PD4S proposal frcm becoming the no-action alternative?
- 23. Into what areas and how nuch money will the Licensee or the IEC put into research to develop technology for clean-up following PD4S? Will the NRC t obtain a ecnmitment frcm the Licensee to finance such develognent?
. 24. Will all of the waste generated since the on-set of clean-up and up to ;
theplacement of the plant in Pa4S be removed frcxn the island before the Unit is placed in PD4S?
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. DISTRIBUTION LIST FOR MATERIAL TO THE ADVISORY PANEL FOR THE DECONTAMINATION OF THREE MILE ISLAND UNIT 2 Chairman Zech 16 H 3 Commissioner Roberts 16 H 3 Rogers 16 H 3 Commissioner Bernthal 16 H 3 Commissioner Carr 16 H 3 H. R. Denton, NRR 17 f 2 PANE T. E. Murley 12 G 18 P.O. Box 268 M. Masnik 13 0 16 Middletown, PA 17057 F. Congel 10 E 4 J. Zerbe 2100 Mr. Frank D. Davis M. Libarkin, ACRS H-1016 200 Gettyburg Pike T. Major H-1016 Mechanicsburg, PA 17055 J. Fouchard 2G5 R. Browing, MNSS 4H3 Ms. Beverely Hess, TMI-PIRC Docket File 50-320 016 1037 Maclay Street PDR 016 Harrisburg, PA 17103 LPDR 016 DCS 016 Mr. Edward Charles F. Miraglia 12 G 18 90 Nittany Drive S. Varga 14 E 4 Mechanicsburg, PA 17055 B. Boger 14 A 2 J. Stolz 13 H 3 Mr. John H. Murdoch L. Thonus TMI Site Mail Pouch 44 Kensington Drive R. Conte TMI Site Mail Pouch Camp Hill, PA 17011 L. H. Bettenhausen RGN-1 Director TMI Alert c/o Kay Pickering Power Plant Research Program 315 Peffer Street Department of Natural Recources Harrisburg, PA 17102 Tawes Building B-3 Annaplois, MD 21401 Dr. Frank Parker School of Engineering Ms. Ruth Gentle Nashville, TN 37203 1 Virginia Circle Mechanicsburg, PA 17055 Ms. Michelle Voso Society of Nuclear Medicine Susquehanna Valley Alliance 475 Park Avenue, South P.O. Box 1012 New York, NY 10016 Lancaster, PA 17604 l Mr. Dave Janes Dr. Sid Langer Analysis and Support Division P.O. Box 1625 U.S. Environmental Protection Angency Idaho Falls, ID 83415 Washington, D.C. 20640 Mr. Kenneth L. Miller, Director Mr. E.E. Kintner Division of Health Physics and Executive Vice President Associate Professor of Radiology General Public Utilities Milton S. Hershee Medical Center Nuclear Corp.
Pennsylvania State University 100 Interpace Parkway Hershey, PA 17033 Parsippany, NJ 07054
'Mr. Bob Leyse Dr. John Luetzelschwab EPR1-NSAC Professor Physics 3412 Hillview Avenue Dickinson College Palo Alto, CA 94303 Carlisle, PA 17013-2896 Mr. David J. McGoff Mr. Thonas Gerusky, Director U.S. Department of Energy Bureau of Radiation Protection A-439GTN Dept. of Environmental Resources Washington, D.C. 20585 P.O. Box 2063 Harrisbsrg, PA 17120 F.R. Standerfer, Director Three Mile Island Unit 1 Elizabeth Marshall GPU Nuclear Corporation 736 Florida Avenue P.O. Box 480 York, PA 17404 Middletown, PA 17057 Niel Wald, M.D.
Tha Honorable Arthur E. Morris Professor and Chairman Mayor of Lancaster Department of Radiation Health P.O. Box 1559 University of Pittsburg 120 N. Duke Street A512 Crabtree Hall Lancaster, PA 17605 Pittsburg, PA 15561 Dr. Gordon Robinson Mr. Ford Knight Associate Professor of Westinghouse Electric Corp.
Nuclear Engineering P.O. Box 286 231 Sackett Building Madison, PA 15663 Unversity Park, PA 16802 Jim Detjen Dr. Henry Wagner Philadiphia Inquirer Johns Hopkins School of Hygiene 400 N. Broad Street 615 N. Wolfe Street Philiaasiphi, PA 19101 Room 2001 Baltimore, MD 21205 Mr. Glen Hoenes Pacific Northwest Laboratory Frecerick S. Rice P.O. Box 999 Personnel Financial Management Inc. Richland, WA 99352 2 Crums Lane Harrisburg, PA 17112 Mr. Joseph DiNunno 44 Carriage Lane Mr. Joel Roth Annapolis, Md 21401 RD 1, Box 411 Halifax, PA 17032 Ms. Leslie Klein Intelligencer Journal Pro-Women 8 West King Street l c/o Judy Branett Lancaster, PA 17603 l 320 Elm Court Middletown, PA 17057 Sally S. Klein, Chairperson Dauphin County Board of Commission Dauphin County Courthouse Front and Market Streets Harrisburg, PA 17101 l
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',doyce Corradi Marjorie and Norman Aamodt Concerned Mothers and Women on TMI 180 Bear Cub Road 2 South Nissley Drive P.O. Box 652 Middletown, PA 17057 lake Placid, NY 12946 Francine Taylor Jane Lee 151 Hamilton Rd. 183 Valley Rd.
Lancaster, PA 17603 Etters, PA 17319 Mr. Ad Crable Pepper, Hamilton and Sheets Lancaster New Era P.O. Box 1181 8 U. King Street Harrisburg, PA 17108 Lancaster, PA 17603 c/o Debbie June Dr. Frederick J. Shon John Kabler, Director Administrative Judge Chesapeake Division Atomic Safety and Licensing Board Pane Clean Water Action Project U.S. Nuclear Regulatory Commission 2500 N. Charles Street Washington, D.C. 20555 Baltimore, MD 21218 US Environmental Prot. Agency Debra Davenport Region III Office 1802 Market Street ATTIN: EIS Coordinator Camp Hill, PA 17011 Curtis Building (Sixth Floor) 6th and Walnut Streets Robert L. Vree Philadelphia, PA 19106 Box 72 Middletown, PA 17057 Rep. Alan Kukovich House of Representatives Harrisburg, PA 17101 Ms. Mary Osborn 4951 Highland Swatara, PA 17111 Mr. John W. Crawford, Jr.
11405 Farmland DR.
Rockville, MD 20852 i
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