ML20215M514

Requests That Comments Made by E Sternglass & R Piccioni to Citizens Advisory Panel in Harrisburg on 870325,be Accepted as Official Part of Comments on NRC Suppl to EIS

ML20215M514
Person / Time
Site:	Three Mile Island
Issue date:	05/07/1987
From:	Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA
To:	Masnik NRC
Shared Package
ML20215L984	List: ML20215M111 ML20215M129 ML20215M161 ML20215M188 ML20215M210 ML20215M227 ML20215M236 ML20215M264 ML20215M273 ML20215M287 ML20215M389 ML20215M422 ML20215M475 ML20215M495 ML20215M498 ML20215M505 ML20215M514
References
NUDOCS 8705130287
Download: ML20215M514 (10)

Text

~. .

Sus w 3 3.0.quehann2Na& oox 1012 Lancasterl)Al%04 Alliance (70) 3H-2782

Dear Dr Mannik,

At their request,please accept the comments made by Dr Ernest Sternglass and Dr Richard Piccioni to the Citizens' Advisory Panel in liarrisburg on March 25th. 1987, as an official part of their comments on the 11RC's supplement to their Environmental Impact Statement.

Thank you, u tOa.n k$tA Frances Skolnick Coordinator,SVA.

i l  ; 207 070507 jD1 HOCK 05000320

p i

PDR J

_._.----_.-,-.._~___-,,--.._..-.___._._..-,.m_ , _ _ _ _ . , , _ . - , , , _ . . , _ , - . _ - , . , . ,-...._,.r.m,_ , _ . - _ - _ - . _ , , , , . - - - _ _ _ - -

+

Sus 3 3.0.quehann2Nalk Sox 1012 Lancasterl)A11604 Alliana (717) 3H-2782 The Susquehanna Valley Alliance is a safe energy organisation whose ,

membership mostly resides in 1.ancaster County,Pa. The organisation was formed as a direct result of the accident at Three Mile Island and the threat that the radioactive water from the accident would be dumped into the Susquehanna River, drinking water source for many citizens of Lancaster County.

Below are the comments of this organisation on the NRC's supplement to their Environmental Impact Statement.

We have read the comments of Dr Michio Kaku,Dr Karl Morgan, and Dr Carl Johnnton, We accept their findings that this document is inadequate, shows major inaccuracies and displayn a lack of scientific skill in its preparation. In light of this,we are unable to accept the NRC's findings that any method of disposal of this water will have little impact on our environment.

We understand that this document is a draft.however this is no excuse for the NRC to have omitted from the table of contents of this water,a list of all radionuclides, including trannuranica. It was not until the SVA requested the lint that the NRC mentioned these elements. This appears to be an attempt to mindirect the accurate attempts to analyse thin document,and to fully determine the impact that any disposable method might have on the environment. This water covers the melted fuel and

' in therefore highly suspected of containing alpha radiation. Scme trannuranien,for exampic. plutonium,are highly toxic to man and have a lonn_ life. Plutonium in soluble in water and wan found in the water in Denver which in downwind of Rocky 1'latn. So even though thene elementu l

! may not be no abundant an ntrontium,eenium and tritium.it in ennentini that due to their toxicity to man.n1pha nensitive radiation monitoring equipment in uned to analyue the water now. Only then enn an accurate annennment of the environmental impact of any dinposal method he made.

f

_ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . . - _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ . _ . _ . _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _.a

Sus w 3 pO.quehannaT)ah Box lol2. Lancasterl)A1504 Alliance On)JH-2782 Aside from the possible transuranic content of this water, cesium, These strontium and tritium will be released into our environment.

releases will be in addition to those releases imposed upon this population by the releases of the accident,the Krypton venting,the clean-up,and operations at Unit 1. These releases from any dispoani method cannot be considered in isolation from all future releases from nucicar power plantn,and indeed as we have seen from the events at Chernobyl, it is not only releases f rom local power plants that impact upon the population,but also releases from any plant anywhere.

Tritium is of special concern since there is no scientific proof that it is not harmful to the human organism. It is easily taken into the body by inhalation or ingestion. Indeed experiments have shown that laboratory animals have suffered cancer, birth defects and It is extremely imprudent genetic mutations from exposure to tritium.

to dinperse radioactive materials into our environment without having a full understanding of their ef fects on the human organinm.

In the EIS(1981) the NRC discussed the problem that the chemicals used in the decontamination nolutionn and the oiln and grennes in the reactor venselcould clogg the Epicor and SDS nystemn and caune them to work ineffectively enpecially towardu the end of the clean-up This then would present a new problem after the fuel han been removed.

in that the water may have a different content prior to going into the evaporator. Thin problem was neglected in the supplement.

Since the evaporation method in the preferred method of dinponal by GpU Nuclear it would have been more appropriate for the NHC to give a more thorough underntanding and evaluation of the nyntem. It in unclear how long it taken for the nyntem to clone down when particulate matter beginn to enenpe into the environment,and how much will encape before the nyntem in completely cloned off to the environment.

+

Sus 3 30.9ahann2Nah Box 1012"Lancasterl)Al%04 Alliance bn)3%-2182 Furthermore,how many workers will work solely at the evaporator system and tend to it while in operation. Also.we are not informed as to the optimum temperatures needed to boil the water and prevent the particulate matter from going into the stack and hence into the environment. We have no trunt whatsoever in GPU tiuclear's ability to

• run the syntem with only the public's health and safety in mind.

t Th in document min-unen the wordn'lcmall", minimum" and "f raction" when referring to radioactive materials and their offeet. The words are f

meaninglena to un and neientista around the world who can show with ucientific p' roof that there in no safe level of radiation for the human organism. Therefore the problem in not with what the evaporator system can hold within the system but with the "small amounts" of We learn radioactivgwhichwillescapeintotheairwhichwebreathe.

that "the f raction releaned would be dependent upon the concentration in the water inputs the feed rate to the evaporator: the design of the evaporator:and the removal fraction from plate-out on the moisture

. neperator,ductn and ntack" This turns out to be an abundance of variables affecting the ponnible releane of radionuelides into our environment.

In npite of thln we are not informed by the flRC how these variablen will be controlled or how they derived their conclunion that they " concur with thin achievable level" It in obvioun to un that GPU Nuclear in being given too much liberty in controlling thin attuation. Thin in outrageoun in view of the leak rate falnification activitten prior to the aceldent in 1979.

in an The NHC nhould have clearly ntated in their document why t.here

- initial concentration of radionucliden in the accident generated water.

Doen thln mean that we enn expect a concentration of radionucliden each time the evaporator han been nhut off for one rennon and another and then ntarted up again. Furthermore,the llRC neglected to make an analynin of the impact in the event of a malfunctioning of the evaporator nyntem.  ;

+

Sus 3.0.quehann2Nathy Alliance oox lol2"Lancasterl)AIE04 (717) 3H-2781 We cannot accept the dispersal of radioactivity into our environment in light of the fact that there are other options available to contain this radioactivity. It is total insanity to sit and talk about boiling up water and allowing the radioactive waste free access to our bodies.

This population has suffered sufficient damage at the hands of GPU Nuclear. There should be no further onslaught of radiation on their immune systems.

n mcog o(NtbL Frances Skolnick Coordinator SVA.

\

a Tomte Mn.t isLAna Altar, mc, a

315 Peffor St. Nottishe's. Peens.17102 (717)233 7097 TMI A'n COMMEtit1TS TO Tile tJitC ADVISOltY PA?1EL Ot1 Tile tJRC's REVISED EIS Of1 Tile DISPOSAL, OP ltADIOACTIVE WATER In that thin in a very nennitive subject I think the Panel should not rigidly enforce time conntriantn on questionn and presentationn by the community. In addition, I hope the water disposal innue doen not become a accondary item af ter this meeting.

I appreciate the f act that GPU responded to my questions concerning Pont Defueling Monitored Storage. llowever, I'm not natinfied with a number of the renponnen, enpecially the onen dealing with decomminnioning. Itather then purnue a line of quentioning tonight, I 'l l defer until the next meeting.

I am nubmitting a lint of questionn to the tJitC concerning their revined EIS. I requent that they be made a part of the official record. I'm npeaking tonight on behalf of Three Mile Inland Alert, which in a non-profit, nafo energy group baned in lia r r in bu rg .

Iloth the tJRC and GPU have ntated that the quantition of radiation releaned during the dinponal of the contaminated water would be "innignificant." They alwayn nayn thin! We don't believe that any radiation done in nafe, especially in thin area where radiation han been vented ntendily f or t.he lant 14 yearn. I don't remember a time when the utility admitted that "nignificant" leveln of radiation have been releaned, including the 43,000 curien of Krypton-05 vented on Central Pennnylvania for 13 dayn in July 1980.

We have nerioun renerva'lonn about the dinponal optionn nanctioned by the tiltc. In f ac dinponal in an incorrect term.

There will be no actual dinponal, and no guarantee of containment. Inntead, radioactive materialn and induntrial chemicain will be dinporned in the environment. We do however, have certain objectiven we would like to noe met.

- Gur prime and overriding concern in minimzing radiation exponure t o the local population and the environment. For example, we would 1ike t o noe 100% of the water f iltered and procenned within a cloned cycle.

- Worker exponure nhould be minimized, nince many of them have human npongen for the lant 7 and 1/2 yearn.

- Done raten to populat.ionn out nido of central Pennnylvania nhould alno he minimized.

- Cont. and time nhould not. be i act orn. GPU nhould npend an much money, and take an much t ime an needed t o f ind the naf ent method of dinponal.

I

I y-Considering these objectives, niternatives such as dumping the water into the Sunquehana Itiver and on-site evaporation are cicarly unacceptable, duo to the potential harmf ul physical and psychological threat they present to our community.

We requent the following steps be taken before a final decision in made: a meteorological ntudy of the area surrounding

. TM 1; a study examining the psychological stress that would result from the planned disposal methods; an inventory of all the radioactive

'olements and chemicain that are in the water; and a review of the GPU's current propona1 and the NHC's rovined EIS by an independent agency not af filiated with the nucicar industry or the government.

At thin time I'd like to romind the panol of nomo of the past behavior of thin utility and the NitC, becauno thin in a crucial factor in understanding the built in distrust and fear of area residents.

We remember that in July of 1980, 43,000 curion of radioactivo krypton-05 and other radioactivo gannen woro vented f rom Unit-2, even though TM1-2 wan denigned to rolonso approximzately 770 curion of krypton-85 a year. The venting occurred a little over a year af ter the the accident admidut widenpread fear and concern. Later, in November the U.S Court of Appealn for the Dintrict of Columbin ruled in Sholly vs. the NHC that the krypton venting wan illegal.

We remember that in the npring of 1903, throo nonior lovel engincorn charged that GPU nnd Dochtal doliberately circumvented nafety proceeduren and haranned them f or reporting nafety violations. The NitC fined UPU and Hochtel $64,000 for intimidating and haranning Larry Parkn.

We remember the reactor head lif t between July 24 - 27, 1903, which wan delayed duo to brake failuro on the polar crano.

GPU vented radioactivo ganon into the environment, denpito pledgun by the NHC and GPU that no venting would take placo during the hond lif t operation. GPU wan lator fined $40,000 by the NHC for the brako problem.

Wo remember that on Juno 1,1984, the NitC rolonned tranncriptn of cloned NHC Comminnion mootingn. The tranneriptn revented a commitment on tho part of a Comminnion majority to rentart THI-1 an noon legally and poltically ponnible. Alno ovident wan nignificant dindnin for public viewn on the rentart innue, and a norioun lack of underntanding of the loyal and technical innuon. Thin in the name nyoney who will ultimatoly decido how the water wilI be dinpaned.

2

I J

We rememember that between February 10-12, 1985 the

- Philadolbhia Incluirer reported records at TMI demonstrated that in hundreds or casco, workern had been contaminated by radioactivo materials either on the skin or through ingention.

The result was that workern were living in a state of anxiety, fearing cancer, birth defects and possible genetic damage for

' futuro generations.

We also remember the health suita, the npilla, the finen, the leaka, the mincalibrationn, the exponuron, the criminal convictions and the ono-colled organiumn.

So when the NitC and GPU nay that vonting, dumping or burrying 2.1 million gallonn of radioactive water will have a negligible impact on our health and environment ... people junt don't believe them. Why nhould they? People live with in fear that they, and futuro generationn, have nuffored norioun health of f actn an a renult of the accident and GPU'n minmanagement. Thin fear han fostered a great deal of pnychological otrono in our community. Stroon can be translated into long term health offectn, and in a very difficult to menuuro. Yet .it in one f actor the Nite will not identif y in measuring health rinku f rom the dinponal of the water.

We are not ncientintn, and wo do not f ool that the burden of producing a nato, expedited method of dinponal nhould fall on the nhouldern of the community. The decinion on what to do with thin water nhouhl not ho made ln hanto, and nhould not be made until all ponnible attornativen are explored and exhaunted. People in thin area have boon dumped on enough. Woro tired of being the guinea pign.

e 3

O Tx:EE McLe ISLAND ALERT, MC.

m 315 Peffor St Norrieberg. Posse.17102 (717)233 7897 QUESTIOtJS CONCElttJING Tile PJRC'n ItEVISED EIS Ot1 Tile DISPOS AL

, OP ltADIOACTIVE WATER Olip.2.6 (p.3.1 & p S.6 necond pa rag raph).Second parag raph.

"There in no evidence for a nignificant concentrartion procenn for tritium in either plants and animaln". (NCRP '7 9 ) . "No apparent enrichment or concentration ef f ect for tritium han been found in aquatic or terrential f ood chains." (NCRP '79). Doen no concentration mean no adverne health of fectn? Are there are any ntudien that contradict thene findingn? Wan thin ntudy the nole banin of your reporrt concerning tritium and itu interaction with biological syntemn? If no, why?

02: p.2.ll What leveln of boric acid or baron in the water would caune you concern? Alno refer to tant pa ragraph p3.20.

01: p.2.13 When wan the EPA'n NIPDWS draf ted? Wan it ever revined? !iame 7 f or itCitA.

04: p.2.15 Since Pennnylvania in a non-Agreement ntate, and in bound by the NRC'n decinion, what recourno in loft to t t atate or citizonn who are dinnatinfled with the NitC'n decinioni. Can a decinion bo binding even if it violaton other Pennnylvania environmental lawn ? What if Pennnylvania becomen an Agreement ntate before the water innue in reolved? What bearing will that havo on the procenn?

05: P.J. l . l.1 Why not let the trannportable evaporator operate in cloned cycle? Ilow accurate han the volume reduction f igure been in 3.1.1.2 at other plantn? What if it in nkowed a few magnituden?

06: p.3.7 Do the maximum done raten annume that all plant, aquatic and human lif e are chemically and radicactively pure before their exponed to the radioactivo eminnionn i rom the water?

07: Do any of your cont breakdownn tako into account inflation, requlatory/ legal dolayn ( 3.1.1. 4 ) loqintical delayn, e t c. Ilow much of a f actor in economien when you analyze the attornativent

QH

p.3.1.2 h p 3.10 Second paragr aph. Would the NRC allow GPU to placo concreted wante in a t.rench on nito? Sixt h par agraph.

When in tho NRC going to connider long-range monitoring at TMI?

09: p.).10 What in a flypalon cap? In it any solationi to tho l

dinanteroun clay cap une I at. chomical niton in Calif or lia/

Q10: p. 3.12 Would Dl;R allow uniont rict ed uno of nit o attor 10 yearn? p. l.13 You would havo tio pr oblem w/ buil<linq or t ai minq on thin nito af ter 30 yearn? Who will monitor the nit o /

l

1 l I '

Q11: p.3.15 Last paragraph. How do you assure that no civilians are upwind?

! Q12: p3.22 First paragraph. How do you monitor the 50% tritiated water, and keep it separato f rom tho 50% that is not monitorod?

j Does this' mean that the other 50% will not be monitorod?

i Q13: Why has the NRC adopted the De Minimis Wanto impacts Analvnis Methodology? Are there methodologion that contradict or call into question the Do Minimin methodology?

~

i l Q14: p.3.24 What if no LLW burials ito wants the wante? What if

! GPU doonn't want to uno their alloted space at a site for the j disposal of thin wanto?

, 015: p3.4.1 Will the rolonne be publicized beforo disposal?

I 3.4.1.2 Ilow are you no nuro all exponuron will bo dilutod? What guarantoon exint to provent GPU f rom adding more highly radioactive water beforo dinponal? What will the NitC monitor?

And how? ,

i Q16: p. 3. 4.2. 3 Accident analynin. Why in a discharge of a batch l of accident-gonorated wator before treatment unlikely?

I

{

017: p3.31 What in meant by "ultimato dinponal"? p. 3.5.1.2 No i other expected pathwayn of exposure to public?

l Q18: p3.5.1.4 Why are no other impedimenta expected beforo liconne terminatlon?

Q19: p.5.3 The environmental, health, economic and human conto annocanted w/the no action alternativo in minimal. Why not

ondorno it?

I 020: p.5.4 Third paragraph. What in meant by "...biologica l muchaniumn that can repair damago cauned by cancor at low-levoln".

021: In thorn an ondpoint to thin proconn? Doon the proconn und

! procinoly at 2.1 million gallonn of wator? If no, what happonn to j additional wator?

l Q22: Why wan thoro no motocrologient ntudy conducted?

I l

l f

[