ML20215M161

Responds to Forwarding Draft Suppl 2 to TMI-2 Programmatic EIS for Review & Comments.Environmentally Preferred Alternative Appears to Be Onsite Evaporation. Comments Encl

ML20215M161
Person / Time
Site:	Three Mile Island
Issue date:	03/31/1987
From:	Walker M ENERGY, DEPT. OF
To:	Travers W Office of Nuclear Reactor Regulation
Shared Package
ML20215L984	List: ML20215M111 ML20215M129 ML20215M161 ML20215M188 ML20215M210 ML20215M227 ML20215M236 ML20215M264 ML20215M273 ML20215M287 ML20215M389 ML20215M422 ML20215M475 ML20215M495 ML20215M498 ML20215M505 ML20215M514
References
NUDOCS 8705130106
Download: ML20215M161 (3)

Text

. . 4 1

R Department of Energy

. Washington, DC 20585

. [, q March 31, 1987 Mr. William D. Travers Director TMI-2 Cleanup Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission P.O. Box 311 Middletown, Pennsylvania 17057

Dear Mr. Travers:

This is in response to your letter of December 29,.1986, that forwarded Draf t -Supplement 2 to the Three Mile Island Unit 2 (TMI-2) Programmatic Environmental Impact Statement for the Department of Energy's review and comments. The Draft SuppJement addresses potential environmental impacts associated with the ,

disposal of radioactively contaminated water resulting f rom the TMI accident that currently is stored at the TMI site.

The Draft Supplement includes the evaluation of 10 alternatives, summarized in Table 3.1, with respect to: (1) systems and operations required for implementation; (2) estimated environ-mental impact, including risk of radiation exposure to the public and to workers; (3) probability and consequences of accidents; (4) commitment of resources, including cost; and (5) regulatory constraints.

Based on this evaluation, the Nuclear Regulatory Commission (NRC) (

staff concludes that the accident-generated water can be disposed of without significant environmental impact, and that among the alternatives evaluated, no alternative is clearly preferable.

Estimated radiological risks to the general public are very small f ractions of estimated normal incidence of cancer f atalities and genetic disorders. The most significant potential impact is the risk of physical injury in the event of transportation accidents for those alternates involving offsite disposal. One of the alternatives, involving indefinite continuation of liquid storage at the TMI site, is. considered inappropriate because it simply defers the ultimato decision on disposal. The GPU Nuclear Corporation (GPUNC) already has proposed to the NRC the alternative involving evaporation and solidification of bottoms at the TMI site and disposal at a commercial disposal site.

Three of the alternatives evaluated involve disposal of the TMI contaminated water at a DOE facility, either Hanford or the Nevada Test Site (NTS). Of these alternatives evaporation from a specially lined pond at the NTS may be a feasible alternative; B705130106 870507 DR ADOCK05000g2O 9

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i hoUever, neither disposal by deep well injection at N.TS nor crib disposal at the Hanford site should be considered as reasonable alternatives.

DOE policy, embodied in Order 5820.2, issued February 6, 1984, states that disposal-operations involving discharges of liquid low-level waste (LLW) directly to the environment or on natural soil columns shall be replaced by other techniques, such as solidification prior to disposal or in-place immobilization,

-unless specifically approved on a case-by-case basis. In addition, the Office of Environment, Safety and Health is committed to encouraging and supporting activities related to discontinuing the practice of discharging contaminated liquids to

, the ground. Further, if liquid LLW were disposed to units such as cribs or injection wells such units would be potential sites under the Comprehensive Environmental Response, Compensation, and Liability Act, which may require characterization studies to determine the need f or remedial actions to prevent or minimize the release of hazardous substances, including radionuclides, to the environment. Consequently, the alternatives involving direct discharge to the soil through cribs at Hanford or injection wells, at NTS should be eliminated from further consideration.

As stated in the EIS, the alternatives involving of f site shipment of the water or the " solidified water" (without prior evapora-tion) would result in an estimated number of traf fic accidents much higher than the other alternatives because of the greater quantity of shipments. Moreover, the solidification-offsite shipment alternative results in a total waste volume an order of magnitude or more higher than that for the other alternatives.

For these reasons, we believe the environmentally preferred alternative appears to be onsite evaporation.

Please find enclosed a list of technical comments to assist you

in revising the draf t EIS.

t Yours truly, Mary I Walker Assis ant Secretary Environment, Safety and Health Enclosure i

l )

ENCLOSURE DOE Technical Comments f or TMI-2 EIS Related to Decontamination and Disposal of Radioactive Wastes Resulting f rom Ma' rch 28, 1979 -

Accident

1. There appear to be errors on Table 2.5 in the tritium concentration values. The correct value for both soluble and insoluble forms of tritium as taken f rom the NRC regulation 10 CFR part 20 is 3 x 10-3 m C i/m l .

2. Quantification ot air dispersion and water dilution would f urther the arguments on minimal environmental impacts associated with the evaporation and river discharge options.

I In the case of river discharge a calculation of the I concentration of the pertinent isotopes at the point (s) of water supply intake and at the tap would be most usef ul. All assumptions used in these calculations should be provided in the EIS.

3. Appropriate DOT regulations for transport of radioactive i material should be referenced and discussed in relation to l the alternatives involving transportation.

4. Similarly, the document should explain the status of agreements / consultation with DOE concerning use of DOE facilities for wa'ste disposal, to help the reader understand the extent to which these are realistic alternatives.

5. Doses and risks for an accident involving contaminated water should be quantified. Table 5.1 includes no offsite dose f or options 3.2.1 - 3. 2.3. However, a single truck accident could lead to potential exposures higher than any others in the table.

6. The format for discussing the treatment options, system and operation, estimated environmental impacts, poten-tial accidents, and regulatory constraints is excellent.

Very little was said about required environmental monitoring for each option e.g. , water table wells, establishment of background conditions at selected disposal sites, and stream and river sampling.

7. The summary should include Table 5.1. This is the alternative impact summary of the report and is tne information a decision will be based upon.

8. The " achievable" column in Table 2.2 could be accompanied by more explanation from the text.

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