NUREG-0683

iVol. 2
Appendices
NUREG-0683A-Z

Final Programmatic
Environmental Impact Statement
related to decontamination and disposalof radioactive wastes resulting fromMarch 28, 1979, accident
Three Mile Island Nuclear Station, Unit 2
Docket No. 50-320
Metropolitan Edison Company
Jersey Central Power and Light Company
Pennsylvania Electric Company

U.S. Nuclear Regulatory
Commission
Office of Nuclear Reactor Regulation
March 1981'§- pJk REG,1

0

Available fromGPO Sales Program
Division of Technical Information and Document Control
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Printed copy, price:$10.00andNational Technical Information Service
Springfield, VA 22161

-7

NUREG-0683
Vol. 2
Appendices A-Z

Final Programmatic
Environmental Impact Statement
related to decontamination and disposalof radioactive wastes resulting fromMarch 28, 1979, accident
Three Mile Island Nuclear Station, Unit'2
Docket No. 50-320
Metropolitan Edison Company
Jersey Central Power and Light Company
Pennsylvania Electric Company

U.S. Nuclear Regulatory
Commission
Office of Nuclear Reactor Regulation
March 1981~,•9This document contains copyrighted
material.

APPENDICES

Page
Appendix A. Comments on the Draft Programmatic Environmental. . . . . . . . . . . . . . . . .. .
Impact Statement.
. . ..

. . . . .
.

Appendix B. Commission's Statement of Policy and Notice of Intent to
Prepare a Programmatic Environmental Impact Statement .....
.....

A-i

......

. . .

B-I

Appendix C. "Final Environmental Assessment for Decontamination of the Three
Mile Island Unit 2 Reactor Building Atmosphere, Final NRC Staff Report,"
U.S. Nuclear Regulatory Commission, NUREG-0662, May 1980 ..........

. . .

C-1

Appendix D. "Environmental Assessment for Use of EPICOR-II at Three Mile Island,
Unit 2," U.S. Nuclear Regulatory Commission, NUREG-0591, October 3, 1979

. . .

D-1

Appendix E. Fish and Fisheries of York Haven Pond and Conowingo Pond of theSusquehanna River and Upper Chesapeake Bay .................

. . .

E-1

. . .

F-1

Appendix G. Engineering Considerations for Treatment of TMI-2 Accident-Generated
Liquid Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

G-1

Appendix H. Engineering Considerations Related to Immobilization of. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Radioactive Wastes

H-1

Appendix F.

Reuse of Accident Water ............

........................

Appendix I.

Justification for Radiation Fields Used in Section 6

Appendix K.

Economic Cost Basis ..............

.......

. . . .
. .

.........................

Appendix L. Average Individual Quarterly Dose Limits Used in Determinations..........................
of Work Force Estimates ...............
Appendix M. "Long-Term Environmental
Mile Island," U.S. Environmental

Radiation Surveillance Plan for Three
Protection Agency, 1981 .........

K-1
K-i

L-1
. . . .

M-1

. . . . . . .

N-1

Appendix N.

Occupational Radiation Exposure during Onsite Waste HandlingAppendix 0.

Decontamination Status of Auxiliary and Fuel Handling Buildings. . . .

0-1

Appendix P.

Chemical Systems for Decontamination of Primary System Components. . . .

P-1

Appendix Q.

Onsite Storage Facility ............

.......................

. . . .

Q-1

Appendix R. Proposed Additions to Technical Specifications for.
............................
TMI-2 Cleanup Program ...............

. . . .

R-1

Appendix S. Calculations of Discharge of Processed Accident Water..............................
to the Atmosphere ...............

. . . .

S-1

Appendix T. The Behavior of Sorbable Radionuclides in theSusquehanna River and Chesapeake Bay ...................

. . . .

T-1

. . . . . . . . . . . . . . . . . . . . . . . . .

U-1

Appendix U.

Decommissioning of TMI-2

Appendix V. Assessment of Groundwater Liquid Pathway from Leakage ofContainment Water at Three Mile Island, Unit 2 ..............

i. . . .

V-1

ii
APPENDICES (Continued)
Appendix W.

Page

Calculation Models and Parameters Used in Estimating

Doses,and Interpretation of Model Results. . .. .........
...

Appendix X.

Contributors to the PEIS ......

..............................

.................

W-1
X-1

Appendix Y. Scheduled Meetings for Discussion of TMI-2 Cleanup Draft................
Programmatic Environmental Impact Statement-(1980) .........

.. Y-1

Appendix Z.

... Z-1

Health Effects Estimators ..............

.........................

iii

G.19
G.20
G.21
G.22
G.23
H.1
H.2
H.3
H.4
H.5
1.1

J.1
J.2
J.3

Page

TABLES (continued)

Table

Radionuclides in Liquid Effluents from Treatment of Reactor Building
Sump Water .....................
...................................
Radionuclides in Liquid Effluents from Treatment of RCS Primary System Water
Radionuclides in Liquid Effluents from Treatment of RCS Flush andDrain Water
Radionuclides in Liquid Effluents from Treatment of
RCS Chemical Decontamination Solutions ...........................
Radionuclides in Liquid Effluents from Treatment of AFHB/Reactor Building
Decontamination Solutions. . . . . . . . . . . . . . . . . . . . . . . . . . .
Comparison of Available Radwaste Immobilization Technologies.
..........
Summary of Bitumen and Cement Immobilization System Characteristics......
Typical Cement/Radwaste Formations ...
.......................
Formulations for Solidifying Radwastes with Portland Cement-Sodium
Silicate .......
. . ... ...........................
....
Portland Cement Admixtures to Overcome Boric Acid Inhibiting Properties
Summary of Results of Gamma Exposure Rate Calculations for TMI-2 Primary
System ........................
.....................................
Analysis of Potential Dose Contribution of Radionuclides in Airborne
Effluents (due to aerosol formation) from Processing Reactor Building
Sump Water . .................
.................
Analysis of Potential Dose Contribution of Radionuclides in Airborne
Effluents (due to aerosol formation) from Processing of Primary Waterfrom the Reactor Coolant System . . . . . . . . . . . . . . . . . . . . . . . .
Analysis of Potential Dose Contribution of Radionuclides in Airborne
Effluents (due to aerosol formation) from Processing AFHB Sump Water .........

K. 1
K. 2
K. 3
K. 4
K. 5
K. 6
K. 7
K.8
K. 9
K. 10
K. 11
K. 12
K. 13
K. 14

Costs of Liquid Processing per Gallon of Influent .
Costs of Liquid Processing Facilities .......
Indirect Manpower Cost Estimates ...............
Unit Operating Cost for Disposal of TMI-2 Liquids
Transportation and Disposal Costs for TMI-2 Liquids
Facility Costs for Disposal of TMI-2 Liquids ....
Waste Conditioning--Unit Costs ............
Waste Packaging and Handling--Unit Costs .........
Process Solid Waste Volumes Considered in Costing .
Waste Facility Costs ......
.................
Decontamination Solution Immobilization Costs . . .
Estimated Unit Costs for Management of Trash ....
Low-Level Waste Transportation and Disposal Costs .
General Support Facilities ......
.............

1.

Concentrations of Major Radionuclides in Water Within the Reactor
Containment Building, 7/14/80 . . . . . . . . . . ...
. . . . . . . . . . . .
Concentrations of Major Radionculides in the Primary Reactor Coolant,
7/21/80 . . . . . . . .
. . . .
Distance and Azimuth of Sampling Locations For The Three Mile Island
Nuclear Station Offsite Emergency Radiological Environmental Monitoring
Program . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .

2.
B-i

N.1
N.2
N.3
N.4
N.5
N.6
N.7

Occupational
Occupational
Occupational
Occupational
ContaminatedOccupational
Occupational
Occupational. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .

Exposure from Handling Low-Activity Trash Drums . ...
Exposure from Handling of LSA Boxes ...............
Exposure from Handling of Spent Filter Cartridges . .
Exposure from Handling of Irradiated Hardware andEquipment ............
........................
Exposure from Handling of Immobilized Incinerator Ash
Exposure from Handling of EPICOR-II Resin Liners . .
Exposure from Handling of Zeolite Resin System Liners

G-30
G-31
G-32
G-33
G-33
H-2
H-4
H-9
H-10
H- 10
1-2

J-2
J-3
J-3
K-5
K-6
K-7
K-8
K-8
K-9
K-9
K- 10
K- 10
K-l1
K-11
K-12
K-13
K-14

M-3
M-4

.M-IO

.

N-2
N-3
N-4

.
.
.

N-4
N-5
N-5
N-7

iv

TABLES

Page
1.1
6.2-1
6.8-1
7.1
7.2
7.3
8.1
8.2
1
2

3
E.1
E.2
E.3
E.4
E.5

Environmental Impacts of Alternatives for Removing the Krypton-85 fromthe Reactor Building Atmosphere ...........
..................
........
..
Hydrogen Control Subsystem .....................................
.... ...........
Comparison of Krypton-85 Containment Techniques .............
Summary of Age-Specific Cancer Mortality Risk Estimators and AssociatedLife-Shortening................................
Summary of Lifetime Risks of Mortality Numerically Equivalent to 0.2 mrem . .
Summary of Latent Radiogenic Cancer Risks Comparable to 0.2 mrem .....
........
Three Mile Island EPA Long-Term Surveillance Stations, Air Samplers, Gamma
Rate Recorders, TLDs .................
..............................
..
Description of NRC TLD Locations ............
........................
...
Radioactive Water. Volumes for TMI Unit 2 Which Will Be Processed By EPICOR-II
Concentrations of Principal Nuclides In TMI Unit 2 Auxiliary Building Tanks
To Be Processed By EPICOR-II Corrected for Radioactive Decay to 6/15/79,
pCi/mL ......
....................
..................
Radioactive Half-Lives of Principal Nuclides ............
..................
Estimates of Recreational Fishing in Vicinity of TMI, 1974-1979 .....
Food Habits of Conowingo Pond Fishes.......................
Species Composition of Fish Kept by Anglers in Conowingo Pond.
Based
on 1973-1977 Winter Fishery Survey .....
.............................
Winter Fishing Pressure and Catch per Hour of Fishes in Conowingo Pond,
1973-1977 ......................................
Species Composition and Estimated Harvest by Anglers in Conowingo Pond,
August 1977-August 1978 ................
............................

C-9
C-15
C-29
C-32
C-32
C-33
C-37
C-37
D-15

D-16
D-16

........

E-4
E-6
E-8
E-8

... E-9F.1
F.2

Radionuclide Inventory of Processed AFHB Water in Storage............
Summary of Potential Uses of Processed Accident Water .........
.............

G.1
G.2
G.3

Treatment Alternatives Suitable for TMI Liquids .........
................
.. G-7
Estimated TMI-2 Liquid Waste Summary ......
........................
...
G-8
Estimated Concentrations of Dissolved Contaminants in Reactor Building Sump
Water as of September 1, 1980 ......................................
: '.G-8
Filterable Solids in Reactor Building Sump Water as of September 1, 1980 .....
G-9
Estimated Concentrations of Contaminants in the Reactor Coolant System
as of September 1, 1980 ....................
........
....................
G-9
Estimated Concentrations of Contaminants in Reactor Coolant System
Flush and Drain ........................................
G-10
Estimated Radioactivity Contained in Solid Debris in Reactor Coolant System
Flush and Drain Water as of September 1, 1980 ...........
.................
G-10
Summary of Liquid Waste Radionuclide Inventories ..........................
.. G-11
Process Decontamination Factors and Breakthrough Volumes
for Submerged Demineralizer-Type Systems ..............
....................
G-14
EPICOR-II Performance for Batch No. 41--AFHB Water ..........
...............
G-15
Decontamination Factors Assumed for EPICOR-II System .................
. . G-15
Decontamination Factors, Volume Reduction Factors and Breakthrough Volumes
Assumed for Zeolite/Evaporation Processing ............
...................
G-18
Decontamination Factors and Breakthrough Volume
Assumed for Zeolite/EPICOR II Process ....
.....................
G-21
Decontamination Factors and Breakthrough Volumes
Assumed for SDS/EPICOR II Process .....
.....................
...
G-23
Volume Reduction Factor and Decontamination Factors
Assumed for Evaporation/Resin Process ...........
....................
. G-24
Decontamination Factors and Volume Reduction Factors Assumed
for Bitumen/Resin Process............................
G-27
Summary of Decontamination Factors for TMI-2 Treatment System Components ....
G-28
Summary of Overall Decontamination Factors for TMI-2 Treatment Systems . . . . . G-29

G.4
G.5
G.6
G.7
G.8
G.9
G.10
G.11
G.12
G.13
G.14
G.15
G.16
G.17
G.18

F-2
F-4

v

Table
N.8

TABLES (continued)

Page

Occupational Exposure from Handling Drums of Evaporator Bottoms
and Accident Sludge...............................
Occupational Exposure from Handling Drums of Low-Activity Decontamination
Solutions...................................
Occupational Exposure from Handling Drums of Intermediate-Level
Decontamination Solutions ................
...........................

...

0.1
0.2
0.3

Decontamination Status for Elevation 281 as of September 1,1980 .......
Decontamination Status for Elevation 305 as of September 1, 1980 .....
Decontamination Status for Elevation 328 as of September 1, 1980 ...........

......
0-4........
0-9... 0-11

S.1
S.2
S.3

Mean Monthly Meteorological Data at Harrisburg Airport .... .......
. .......
HTO Releases to Air for July Ponding .....................
......
Density of 100% Saturated Water Vapor, Relative Humidity, and HTO Air
as a Function of Time ..................
...............................

N.9
N.10

U.1
U.2
U.3
U.4
U.5
U.6
U.7
U.8
U.9
U.10
U.11
U.12
U.13
U.14
U.15
U.16
U.17
U.18
U.19
U.20
U.21
U.22
U.23
U.24
U.25
U.26
U.27
U.28
U.29
U.30

N-7
N-8
N-8

S-4
S-4
S-8

Specialty Contractors for Decommissioning ...........
...................
... U-3
Essential Systems and Services for Decommissioning ......
...............
... U-5
Special Tools and Equipment for Decommissioning ...
...........
U-6
Comparison of Major Concrete Surface Removal Techniques .......
............
U-9
Estimated Specific Activities and Surface Doses from Reactor VesselInternals of TMI-2 ..................................
U-15
Estimated Volumes of Radioactive Waste Arising from DECON of TMI-2 .........
... U-21
Postulated Releases of Airborne Radioactivity to the Environment During
DECON Operations .....................
................................
U-22
Reference Radionuclide Inventory 2, Carbon Steel Activation Products Lower Vessel .............................
U-22
Reference Radionuglide Inventory 3, Concrete Activation Products Biological Shield .........
.........
...............................
... U-23
Reference Radionuclide Inventory 4, Neutron-Activated Corrosion Products
Deposited on Piping Internal Surfaces ........
................
. ....
U-23
Reference Radionuclide Inventory 5, Radioactive Surface Contaminationin the Reference PWR....................
...
. ........
U-24
Estimated Cumulative Radiation Doses Received by Workers During DECON
Operations ...................
..........................
...........
.U-25
Estimated Cumulative Radiation Doses Received by Transport Workers During
DECON Operations ..............................
.......
U-25
Estimated Doses to the Maximum-Exposed Individual from Normal Decommissioning
Activities (DECON)............................
U26
Estimated Cumulative Radiation Dose Received by the Public During Transportof Radioactive Wastes from DECON . . . ...............
.... ................
U-27
Summary of Estimated DECON Costs . ....
..........
...................
... U-28
Estimated Labor Costs for DECON .U.........................U-28
Estimated. Costs for Disposal of Radioactive Wastes from DECON .....
.........
U-29
Systems and Services Required During the Continuing Care Period .....
........
U-33
Estimated Volumes of Radioactive Waste from PreparingTMI-2 for Safe
Storage ....................
..................
.. . .......
......
U-39
Estimated Cumulative Radiation Doses Received by Workers During SAFSTOR
Operations ...............................................
U-41
Estimated Cumulative Radiation Doses Received by Transport Workers During
SAFSTOR Operations ..................................
U-42
Estimated Doses to the Maximum-Exposed Individual from Normal Decommissioning
Activities (SAFSTOR)...............................
U-43
Estimated Radiation Dose Received by the Public During Transport ofRadioactive Waste from SAFSTOR Operations ..............
...................
U-44
Summary of Estimated Costs for SAFSTOR ..........
.....................
.. U-45
Estimated Labor Costs for SAFSTOR
u.......................UEstimated Costs for Disposal of Radioactive Wastes from SAFSTOR .....
........
U-46
Comparison of DECON and Deferred Decontamination Costs from Reference
Decommissioning Studies ......................
............................
U-48
Comparison of DECON and Deferred Decontamination Costs of TMI-2 .....
........
U-48
Estimated-Volumes of Radioactive Waste Arising from ENTOMB of TMI-2 ....
......
U-52

vi
Table
U.31
U.32
U.33
U.34
U.35
U.36
U.37
U.38
U.39
W.1
W.2
W.3
W.4
W.5
W.6
W.7

Z.1
Z.2
Z.3
Z..4

Z.5
Z.6
Z.7
Z.8
Z.9
Z. 10

TABLES (continued)
Apportionment of Radioactive Waste Arising from ENTOMB of TMI-2 ........
Postulated Releases of Airborne Radioactivity to the Environment During
ENTOMB Operations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Estimated Cumulative Radiation Doses Received by Workers During ENTOMBOperations ......................................
Estimated Cumulative Radiation Doses Received by Transport Workers During
ENTOMB Operations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Dose Estimates to the Maximum-Exposed Individual from Normal Decommissioning
Activities (ENTOMB)...........................
Estimated Cumulative Radiation Dose Received by the Public During.Transportof Wastes from ENTOMB ....
Summary of Estimated Costs for ENTOMB . ....................
Estimated Labor Costs for ENTOMB ....
........................
Estimated Costs for Offsite Disposal of Radioactive Wastes from ENTOMB .......
Table Numbers of Regulatory Guide 1.109 where Input Parameters Can Be
Found, and Problem-Specific Parameters Used in the PEIS . . . . ........
Locations for Maximum Exposed Individual Dose Calculation andAtmospheric Dispersion Parameters. . . . . . . . . . . . . . . . . . . . . . .
x/Q Values Used in Population Dose Estimates (no decay - no depletion) .......
x/Q Values Used in Population Dose Estimates (2.26-day decay - nodepletion) ..............
..............................
x/Q Values Used in Population Dose Estimates (8-day decay with plume.
depletion) ............
.........
....................................
D/Q Values Used in Population Dose Estimates ..........
..................
Parameters Used in Maximum Individual Dose Calculations and Dose to
Biota Calculation for Liquid Pathways .............
...
...
.
Calculation of Expected Leukemia Deaths for External Exposure .
Calculation of Expected Lung ,Cancer Deaths for External Exposure
Calculation of Expected Stomach Cancer Deaths for External Exposure
Calculation of Expected Pancreas and Alimentary Canal Cancer Deaths
for External Exposure . . . . . . . . . . . . . . . . . . . . . . .
Calculation of Expected Breast Cancer Deaths for External Exposure
Calculation of Expected Bone Cancer Deaths for External Exposure .
Calculation of Expected Thyroid Cancer Deaths for External Exposure
Calculation of All Other Expected Deaths for External Exposure . . .
Maximum Expected Latent Cancer Deaths per Million Person-rem . ...
Comparison of Fatal Cancer Risk Estimators ......
.............

U-53
U-53
U-55
U-55
U- 56
U-56
U-57
U-58
U-58
W-2
W-3
W-4
W-5
W-6
W-7
W-8
Z-2
Z-3
Z-4
Z-5
Z-6
Z-7
Z-8
Z-9
Z-10
Z-10

vii

FIGURESPage
1

Flow Schematic of EPICOR-II Processing 'System .........

E.1

York Haven Pond of the Susquehanna River Showing the Location of Three Mile
Island and the Nuclear Station, the Generalized Flow Patterns in the Channels
and over the Dams, and the Peripheral Facilities that Contribute to Use of
the Pond by Fishermen and Boaters.......................
E-2
Generalized Categories of "Eater Groups" of Fishes in York Haven Pond of theSusquehanna River .... ...................
. ....... ...... .........
... E-3

E.2.................

... D-15

F.1
F.2

Processed Accident Water Availability .............
.....................
Potential Processed Accident Water Needs .... ...................

G.1
'G.2
G.3
G.4
G.5
G.6
G.7
G.8
G.9

Process
Process
Process
Process
Process
Process
Process
Process
Process

H.1

In-Line and In-Drum Mixing Process for Incorporating Radwaste in Cement

1

Long Term Air Monitoring (Three Mile Island) ............

0.1
0.2
0.3

Auxiliary and Fuel Handling Buildings,
Auxiliary and Fuel Handling Buildings,
Auxiliary and Fuel Handling Buildings,

S.1
S.2
S.3
S.4

HTO Concentration Versus Time for Water Ponded in July ........
.............
HTO Concentration Versus Time for Water Ponded in January ....
...........
Density of 100% Saturated Water Vapor versus Temperature .... ............
Monthly HTO Concentration above the Pond as Calculated Using Model Two ........

T.1
T.2

Fraction of Radionuclides Remaining in Dissolved State ........
Chesapeake Bay ...................
....................

.............
. .............

T-3
T-5

U.1
U.2
U.3

U-2
U-16

U.8

Simplified Decision-Point Diagram ................
.......................
Duration of DECON Activities .............................
Postulated Sequence and Schedule of Tasks for DECON of the Containment
Building ................
......................
Postulated Sequence and Schedule of Tasks for DECON of the AFH
Building .....................
....................................
Duration of Activities Preparing for Safe Storage ...........
...............
Postulated Sequence and Schedule of Tasks for SAFSTOR of the Reactor
Containment Building .....................
..............................
Postulated Sequence and Schedule of Tasks for SAFSTOR of the AFH
Building ............
..................................
............
Duration of ENTOMB Activities ....
...........
..........
..............

V.1
V.2
V.3
V.4
V.5

ReactorBuilding ...................................
Elution of Radionuclides .....
............................
Spread of Contaminated Water from Large Volume Releases .......
............
Radius of Contaminant Circle vs. Time ..............
.....................
Flux of Tritium into River ........
.............
.....................

U.4
U.5
U.6
U.7

... F-3......
F-5.

flow Diagram for Submerged Demineralizer System .......
............
Flow Diagram for Modified Submerged Demineralizer System .....
........
Flow Diagram for EPICOR II System ...........
...................
...
Flow Diagram for Modified EPICOR II System ......
...............
...
Flow Diagram for Zeolite/Evaporation System .......
..............
...
Flow Diagram for Zeolite/EPICOR II System ...........
...............
Flow Diagram for SDS/EPICOR II System.................
Flow Diagram for Evaporator/Resin System ......
................
..
Flow Diagram for Bitumen/Resin System .........
.................
...
....

.. H-7..................

281-Foot Elevation ....
305-Foot Elevation ....
328-Foot Elevation ....

............
...........
...........

G-12
G-13
G-16
G-17
G-19
G-20
G-22
G-25
G-26

M-5
.. 0-2.. 0-3.. 0-3

..
...

S-5
S-6
S-8
S-9

U-17
..

U-19
U-34
U-36
U-37
U-50
V-2
V-5
V-10
V-12
V-13

APPENDIX A.

COMMENTS RECEIVED ON THE DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT

The table on the following pages lists the sources of the comment letters in the following order:
federal government agencies; state government agencies; local government agencies; citizen groups
and businesses; individual citizens, listed in alphabetical order.
Also shown in the table are
the identification numbers which were assigned to individual letters in the order received andthe page numbers of this appendix where the first page of each letter appears.
The letter numbers
are used in Chapter 13 (Responses to Comments) in responding to the comments.
TABLE OF CONTENTS
Letter
U.S. Army, Corps of Engineers ............
...
.........................
U.S. Environmental Protection Agency .......
.....................
Federal Energy Regulatory Commission .......
.....................
Bill Goodling, U. S. House of Representatives ................
U.S. Department of Health, Education, and Welfare.. . .........
...........
U.S. Deparment of the Interior ...............
.........................
U.S. Department of the Interior, Geological Survey ..... ..............
U.S. Department of Transportation, Coast Guard ...
..............
. .
U.S. Department of Transportation, Federal Highway Administration ........

....
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...

No.

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Maryland Department of Natural Resources... ......
................
Maryland Department of State Planning ..........
....................
New Jersey Department of Enviromental Protection .........
...............
Pennsylvania Department of Environmental Resources .....
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Pennsylvania Department of Health .......................
Pennsylvania Department of Public Welfare ........
..................
Pennsylvania State Clearinghouse .........
.......................

....
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52
91
23
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55
128
...
106
....
9
131
Regional Planning Council ..............
..........................
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34
Tri-County Regional Planning Commission ..............
...................
8
Virginia Council on the Environment ...........
...... .............
...
21
Cecil County, Maryland, Commissioners ..........
....................
....
38
Cumberland County, Pennsylvania, Commissioners ..............
.........
5
Harford County, Maryland, Council ..... ....... ......................
...
42
City of Lancaster, Pennsylvania ..........
.......................
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112

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A-9
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A-292

American Society of Utility Investors ........
.....................
Anti-Nuclear Group Representing York .........
.....................
Atomic Industrial Forum, Inc ....
.........................
Catonsville Community College Student Government Asssociation ..........
Chesapeake Bay Foundation ..............
..........................
Earth Alliance ....
................................
Edison Electric Institute ........
...................
Environmental Coalition on Nuclear Power .............
...................

...
...
.
...
...

Environmental Problems Seminar, Franklin and Marshall College ..........
Friends and Family of TMI ..............
..........................
Maryland Ad Hoc Committee on Three Mile Island .... ... ...............
Maryland League of Women Voters ..... .............
...
................
Maryland Watermen's Association, Inc .......
.....................
Metrolpolitan Edison Company ...
.........................
Nuclear Information and Resource Service ...........
...
..................

...
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.

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Pennsylvania League of Women Voters ..........
Pennsylvania Social Services Union .........
Priority Environmental Action Club .........

.....................
......................
......................

A-i

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...
...
...

90
124
80
77
13
89
87
64
119
75
126
I.11
40
30
50
97
64
56
108
123

Letter
Public Interest Law Center of Philadelphia ........
..................
Public Interest Resource Center ............
.......................
RPF Ecological Associates ..............
..........................
Sierra Club ...............................
.....................
".
Susquehanna Valley Alliance ..............
.........................
Three Mile Island Alert, Inc ................
.........................
Union of Concerned Scientists ................. ........................
Watermen's Association ................
.........................
Westinghouse Electric Corporation ............
......................
Karen Adams .... . .. .............
Patricia Books..........
Irwin D. J. Bross .... ............
John and Kathryn Brougher ...........
Edwin and Mary Ann Charles .........
Edwin Charles.
.
............
Linda Cope ......................
Jeane Crumley ......
.............
Beverly Davis .... ...............
Frank Davis.
..............
David Dobbins, Conrad Miziumski, Thomas Greco, William Yurkiewicz
John Doherty ......
..............
Charles and Genevieve Emerick .......
Debbie Fetterman .................
Robert, Joane, and Jason Gingrich ..
Leo Goldberger, Adebert Jenkins, Harold Sackeim, Lloyd Silverman, James
Henry Grimm ........ ..............
Earl Gulbransen ..... ............
Lise Haager .................
Arthur W. Helton, Maryland. Senator.
Alice Herman•................ ....
George Herman .... ...............
Beverly Hess .....
...............
Charles and Helen Hocker.
Donald Hossler ..................
Alana Hunter ...... ..............
James Hurst ........
..............
Peggy Jones ........ ..............
C. Byron Kohr .....
.............
Cory La Brasca......
Jane Lee ........ ..............
Marvin Lewis .....
...............
Robert Jay Lifton
William Lochstet.
William Long...
Joyce Look. ...
Vincent Luta...
Ira May .......
Kenneth May . . .
Jonathan Morell, George Spivack .
Leo Navickis ................
Mary Osborn .... ............
Clarice Parsons .... .........
Steven Patton ...............
Dan Peffley .... ............
Joan Petrosky ..............
Richard Piccioni, Daniel Pisello
Kay Pickering ..............
K. K. S. Pillay .... .........
Walden Randall. . . . . . . . .

No.

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Ul eman

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LetterMrs. William Richardson ..........
Catherine I. Riley, George B. Adams, Jr., Will iam H. Amoss, William H. Cox,
. . .
Jr., Maryland House of Delegates
Susan Roudebush ...................
Paul S. Sarbanes, U.S. Senator .....
..............
Susan Shetrom .......
Patricia Smith . . . . . . . . . . . . .
Irving Stillman .... ...............
Steven Sylvester, Arthur Barabas ....
Nancy Tate . . .
Geraldine Trust
Edward Walsh.
A. E. Wasserbach.
Brenda Witmer
Christine Yost
Wilbert Zurliene
Comments received at September 30, 1980, meeting with Maryland citizens in............................
Annapolis, Maryland ...............
Comments received at October 6, 1980, meeting with Susquehanna Valley....................
Alliance at Lancaster, Pennsylvania .....
Comments received at October 7, 1980, meeting with Pennsylvania Farmers'
Association in Camp Hill, Pennsylvania. . . . . . . . . . . . . . . . .
Comments received at October 8, 1980, meeting with Steering Committee,.... ..................
Newberry Township, Pennsylvania ..........
Comments received at October 20, 1980, meeting with PANE, Middletown,...............................
Pennsylvania.
Comments received at October 23, 1980, meeting with Pennsylvania Medical. . . . . . . . . . . . . . . . . . .
Society, Lancaster, Pennsylvania
Comments received at October 29, 1980 meeting with Maryland citizens in. . . . . . . . . . . . . . ... . . . . . . . .
Havre de Grace, Maryland
Comments received at November 10, 1980, meeting with Pennsylvania citizens
in Harrisburg, Pennsylvania........................
Comments received at November 19, 1980, meeting with Pennsylvania citizens...
....................
in Middletown, Pennsylvania ............
Comments received at November 17, 1980, meeting with Maryland citizens in
Baltimore, Maryland . . . . . . . . . . . . . . . . . . . . . . . . . .

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1)

I

a.-

University of ?itsburgh
SCTGCL0ýECG\EENGe•:•veaeaqui-.-a -C klive,, 3

E-r-

Bernard J.
Page 2

SnyderAugust1980

ý9r'
August 27,

26,

The author strongly recommends that the NRC staff re-examine
1980

nation procedures 'of the Tmr-2 reactor core.
Very truly yours,

Mr. Bernard J. Snyder, Program Director
Three Mile Island Program Office ,U.S. Nuclear Regulatory Commission
Washington, D.C.
20553
Dear Mr.

Earl A. Cuibransen
Research Professor and

Snyder:/'s

I thank you for sending mea copy of NUREG-0683 entitled Draft Progromatic
Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from the YMarch 28, 1979, accident at Three Mile Island
Nuclear Station, Unit 2.
I have read the report with great interest and concern
since I have spent 25 years doing research on the chemical reactions of Zirconium
and Zircalow YE and IV vith oxygen, nitrogen, hydrocen and steam.
These szudies
have shown me that great care must be used in handling zirconium and its
alloys.
The following are my comments and recommendations.
The authors of NURZG-0683 should be alerted to the possibility that zirconium
hydrides CrH81 4 and ZrHI.98 may exist in the damaged T'I1-2 reactor core.
Accordfng to section 7.1.1 entitled Status and Specific Considerations it is stated that"a large fraction of the fuel rods have ruptured, and there has been oxidation of
Zircaloy in the core (about 50% of the total core inventory of Zircaloy, i.e. fuelcladding, control rod guide tubes, and instrument tubes, has oxidized)."No mention is made here or any'where in NLREG-0683 that hydrides of zirconium may beformed.
Zircaloy may form hydrides especially under the temperatures Of 25OC°F which
occurred in the accident and at the high pressures of hydrogen which exist in theearly stages of the accident.
Although oxide films may protect Zircalov from thehydrogen reaction under normal reactor operating conditions, one must not assume
that hydride formation does not occur under conditioffs of the accident at 1,11-2.
Here cracks, edges, and other defects offer easy access sites for hydrogen into the-metal. With the formation of hydride, spalling of the hydride and oxide occurs.
Rapid disintegration of the fuel rods results.
The presence of zirconium hydride in addition to highly cracked residual Zircaloy particles may change the procedures and techniques required for the removalof the damaged core materials and for the transportation and ultimate disposal.
All debris from the reactor must at all times be kept under water to protect personnel and to prevent fires.
Zirconium hydride, ZrHR.4, reacts explosively when
exposed to oxygen or air.
large quantities of heat are released to form one moleof ZrOi and 0.7 moles of H20.
Breaking of casks of debris-containing zirconium
hydride could result in dangerous fires, explosions and scattering of radioactive
material.

A-ithe deconcami--

"In~ Jfouse oil Egauu.':
90 Nittany Drive

Mechanicsburg, Pa. 17055
V.
U.S. I'uclear Regulatory Commission
Washington, D.C.
20555-

Sept. 3,
To Whom It

1980

May Concern:

Dear 'r. Snyder

These comments focus on the recent Draft Programmatic Environmental
impact Statement on TMI-2 and, specifically, on sections of that report
related to the psychological stress issue.
one which the
While the issue of psychological stress is a critical
NRC staff wishes had never been raised, it is unfair to attempt to dismiss
it as irrational.
One expects a more evenhanded discussion from the NRC.
I am disappointed at the tenor of the comments on psychological stress because
they seem to imply that residents in the flI area with misgivings about thecompetence and/or truthfulness of utility
and regulatory officials are
unreasonable.
Let me call your attention to only two typical sections:p. 3-23: in addition to being a rather poorly written discussion of
psychological stress (3..7)1 , this section seems to suggestthat persons concerned about what might happen are silly.
A strong case could be made that the regulatory officials
who refused to even consider the nuclear opponents' "what ifs"
were the arrogant, myopic and silly ones in view of theactual accident.
Who, even among the most staunch defendersof nuclear power, would now want to defend locating TMI sonear a large population center? Although the writers of thissection suggest that fear of nuclear technology is unwarranted
and even a sign of mental unbalance, their own cavalier attitudein the face of such a potentially dangerous technology seems tome the more unhealthy psychological problem.
The use of theadjective "phobic" to refer to residents' fears (p. 3-24), forexample, suggests an attitude of superiority on the part of
the writers which is hardly justified in view of the actual
events at 1NI in March, 1979.
p. 10-24:This section seems to suggest that the writers know the longrange impact of the "accident water" on human persons (just asother sections suggest the writers know the long-range impactof the krypton and other radioactive gases). is there any
scientific evidence showing that small residues of tritium inthe drinking water are completely harmless? If so, do mention
them because area residents are interested in searching themout. If not, then where does the staff find suroort for its
assertion that only "negligible health effects" will follow
accidental spills?
Another question on same section: Why use "phobic" inthe last complete paragraph of p. 10-24 unless it is meant tosuggest that the residents in the T1I area are unbalanced ifthey do not trust those in charge of TMI-2 cleanup? Does thestaff realize that this paints at least 60 percent of theresidents living within five miles of the nuclear facilities"nhobic"?
Does such arrogance serve the interests of eitherthe ýRC or the public?
There are numerous additional problems with the report which undermine
the readers' confidence. Footnote 66 on p. 3-27, for example, has no place in
I'm very disappointed at the obvious lack ofan allegedly scientific report.
objectivity and empathy for local citizens.
e.
1 .
State College, -a. 16801
720 S. Allen Street
Edward j. Walsh.

I wo dd like to :-now the answers to the followng
questions.
Questions from this letter are relc:tedtc (.-YREG 0683)Enviroir:.ental Impact otate:uent.
l.Why the change in ti.e i:ove-ent of waste material?
Page 3-30 Figure 3.2-2.
It was my understandingthat waste :::cteritl(htth or lo..)would be sent byInterstý.te 5i to Interstate 80 W. Looking at youri:ao it 'aaneper ti.at youi will transport wasteIterason tewest asde of thte Suscuehanna River
on .S 11 and 'JS 15 'iorth. of the interstate Bridget at cro :es t' e So':oe'hanna.
This route would
not ' eep with in t:e gaide lines of DOT and ;:RC.
2.

hly was t.,e so t.•ern routeon U.3 Interstate 81
to 1'D.
and then Interstate 70 W. not, included?

3.a!h t ia t e nau.ber of tr ack loads(aprox) of high level
vater4a s to be ta-en frona the clean up of th Island?
'uber of tr. c. loads of low level (ar~ro.) to leavethie isl-:nd?
4.Anyfrve yo not included an update of your Aerial
Radio -oic-i
1arvey dated Aug. 1976(A.L. Fritzsche)?
it see-'s a rood aerial survey sao'ot-ng background after
erch 1979 co ocred to 1976 would help to clear thefears of -r-ny pooDle.(see p•.ge 4 Append.x C ('PUREG-0637)
Than.i: you.,
Sincerely•=dQ-af-h ,i•ar I e s

P.S.
c41d Reu!
I obtain a copy of the 1979, and 1980
'1... -How
N;ucleartory Co:iaoion Annual Report? I
Have a copy pf' t'ue 1978 and have found it very interestig.

A-2

Irwin O.J. Bross. Ph.D
Director of Biostatistics
Roswell Park Memorial Institute666 Elm Street
Buffalo. N.Y 14263

ROr i P.. ,eI,•NlS t.

ooe
mber

September

CRITIQUE OF NUREG-0683

BY DR.

IRWIN BROSS

with the question:

What isan appropriate basis

Y Sl1t Oa0h95ealr~,.
5,1980

Let us startfor a critique of a Draft Programmatic Environmental
Richard H. Vollmer, Director
Three Mile Island Support
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

(DPES)

ofany plan for the decontamination and disposal of radioactive wastes
resulting from the March 28,
Station,Dear Mr.

Statement

Unit 2

1979 accident at Three Mile Island Nuclear(TMI-2)?

Vollmer:
The clear intent of the National Environmental Policy Act was

In conjunction with the hearings of the U.S. Nuclear Regulatory
Commission on the newly released draft Programmatic Environmental Statement(DPES), I would like to submit this critique.
Using the metatechnologicalanalysis appropriate to EIS, this critique demonstrates that, relative
to viable technological alternatives, the proposed plan is the least
feasible, the most expensive, and the most dangerous to the publichealth and safety.
It is further pointed out that NUREG-0683 is an
incompetent document from an epidemiological and biostatisticalstandpoint
and all the estimates of hazard are so remote from the real risks thatit constitutes a dangerous fraud upon the public.

to insure that the public
here,health and safety be protected.

there are alternative

then the DPES should establish that the technology
minimizes the danger to the public health,and cost-effective.

There is a much better way to do the job of disposing of theradioactive wastes at TMI-2 but there is no way to make NRC bureaucrats
listento reason when they are in complete control of the proceedings.
Very •i•c erely,/y<rrs,

Hence,isthat isproposedtechnologicallythe critique of a DPES lies infeasible,the province

now being called "metatechnology".

For a more complete

discussion

see my new paper,

A TECHNOLOGYEFFECTIVE,

AND ECONOMICAL USE OF TECHNOLOGY,A).

METATECHNOLOGY:

METAMEDICINE,

in

FOR THE SAFE,

which will be published in

February 1981(see Schedule

From this standpoint we must consider alternative courses of action(and alternative technologies)
IDJB/makEnc.

asof what is

the new British journal,
Irwin D.J. Bess, Ph.D.
Director of Biostatistics

When,

technologies for achieving the same goal,from the accident at TMI-2.
alternatives,

for disposal of the radioactive wastes

Although there are numerous technologicalfor present purposesitwill suffice to consider only

three:
1.

Inaction.

No other action beyond present maintenance
operations for an indefinite period.

A-3

-3-

-2-

The programmatic plan proposed in

DPES*.

2.

NUREG-0683

for a 5 to 7 year clean-up of TMI-2.
3.

Disposal of the radioactivity wastes by

Entombment.

immobilizing them in

concrete into the publichealth and safety.

The key

(k-l)

(k-2)

from the present haphazard configuration

completely negligible

and the choice of apurpose with minimum risks

factors in

the cost-benefit

the extent to which:the disposal oper-in

NRC exposure levels(5

rem/year)as absurd.

Radioactive materials must be transported inside

an up-to-dateequal,

risks to workers and the public by a greater amount,of TMI-2

far exceed the costs of building

the metatechnologicalchoice here hinges on the costs,

not appropriate

for TMI-2,

will be considered inWith respect to the transport of radioactive materials,

inaction,containment and transportation to other locations.

only the second and third alternatives

what follows.

However,also evaluate this alternative carefully.

the plan in

the radioactivity stays inside

to theA-4

Again,

thefrom theto implement

DPES* there must be purging of radioactive water into ariver system that serves or affects many U.S.

an official DPES should

The reassurancesThe

situation with respect to the key factors can be summarized as follows:roughly a factor ofalternative,

particularly

the clean-up and to the general public

proposed clean-up plan involves removal of these materials
consensus that a first(whereliving near TMI-2 or downwind or downstream from the installation.

will increase

4.
Since there isbyinstallation de novo.

the health costs to workers inpractical diffi-

costs of the overall project.

NUREG-0663 or

Since the benefits for the alternative technologies are about

New technologies must be developed to do the job?

culties, and operationalit

The cost of meetingby decontaminationlevels of 100 rem/hr have been reported)It'Hence,this concrete.

Earlier claims of further benefit from NUREG-0683

ations?

the key factor will at least double the complexities,

The risks become

the water used to mix with the concrete and thereactivating TMI-2 are now recognizedinvolved in

the containment.

TMI-2 can be achieved equally well by the plan proposed in
by entombment.

Humans are directlythat could produce

follows that the goal of suitable disposal of the radioactive wastes in

As a rule-of-thumb an unfavorable situation with respect toisifof the rods

involve the mobility of the rods and theradioactive materials are immobilized

the containment or removed and transported elsewhere?
(k-3)

earthquake)do not show any appreciable

The only scenarios

large amount of radioactive water in

evaluation here are the following:
What isrisk of meltdown

such a risk (e.g.,

A metatechnological evaluation involves comparison of thedisposal technology that will accomplish its

suggest that NRC calculations

and other radioactive material.

thecontainment of TMI-2.

costs and benefits of the alternative technologies

public on TM14-2

cities.

With entombment

the containment of TMI-2.

Therefore,

i

i

=

I

NNl

vml

I n m

-4-5-

with respect to. the second key

DPES*.

minimal movement of

there isbut extensive

the entombment option,

radioactive materials inof these materials

factor (k2)

NUREG-0683 concerning death and disability for workers understate
actual risks by ain(and possible dissemination into the environment)

are used in

For this reason alone NUREG-0683 should be rejected as an incompe-

key

involvement of human beings in

The combination of the first
The processes

for dealing

represent a well-known technologythat can be largely carried out bymachinery under remote control.

Inof human workers incontrast,

wastes.

The Mickey Mouse arithmetic
are called "radiological assessments"
I

agencies

culties.

addition,

August 13,

1980(Schedule C).

Association in
The net effect is

my invited presen-

Houston,Texas,

Safe operations would require new technologicalmy draft EIS for West Valley,(Schedule D).

The diffi-

tools on-siteand on-I have discussed these manageWhile a clean-up of TMI-2 isthe record of management at TMInot encouraging.

Very serious

both to the workers on the job and to the public,

NUREG-0683

from failuresdeveloped on-site and on a crash basis are

and elsewhere inentombment minimizes worker involvement

factual evidence on persons actually exposed to low-level radiation

tation to the American Statisticalcreate a2 and past failures with simple tasks isignored inDocumentation of the new(which shows 10-fold higher health risks) was given inInof untested technologies

the health effects for given exposures are consistently

underestimated by a factor of 10 or more.

(k-2)

simpler than a clean-up at West Valley,

dangers,

which explains why

exposures are consistently underestimated by factors between 10 and 100.
Inextensive use ofmaterials

attempting to develop new technologicalment problems at some length

for what

have given detailed examples at a hearing of(schedule B)

two factors,

to radioactive

the-job pose formidable management problems which compound the diffi-

involves too many scientific

the Department of Energy on West Valley

close proximity

situation for DPES*.

culties inby both low-level andfederalindevelopments that are beyond the present state of the art.

by factors of 100 or 1000.

used in(k-l)

difficult

The estimates of health effects in

NUREG-0683 underestimate the actual hazards

errors to detail here.

humansuse

DPES* makes extensive

an environment contaminatedhigh-level radioactive

no question but the DPES* involves extremely

the Mickey Mouse arithmetic of these "radiological assessments".

the use of cooling pipes and other refinements)

with concrete (including

There isa reckless endangerment of theradioactive materials,

the processing ofoption has minimal involvement.

the entombment

this represents

serious hazards to the workers that are being deliberately covered up by

the extent of(k-l),

factorWhen such unrealistic estimatesfactor of 100-1000.

a DPES,public health.

tent document by the basic principles of metatechnology.
With respect to the firstthemovement

DOE-NRC planning.

In

contrast,

and the manipulation of theradioactive wastes.

It uses familiar concrete~technologies

most (though not all)of the problems that would require new technology.

There could be added technical problems inthat avoid

cooling systems that wouldonrequire some extension of existing technology.

that the estimates in

However,

entombment

operations are orders of magnitude simpler and less fussy than theclean-up proposed in

A-5

0PES*.

-6-

From this qualitative

analysiswith quantitative metatechnological-7-(which could be supplemented

analysis),itmore than 20 years of experience and more than 20 specific instances

follows-that thewhere both kinds of assessments were made(Schedule C).

In

each case,entombment option ismuch more technologicallyfeasible than the plan in

the "radiological assessment" predicted that there would be no hazard

Again,

the rule-of-thumb on costs(and the adverse situationfrom the exposure to nuclear or medical

NUREG-0683.

of DPES* on all

three key factors)

times more than entombment.

If,means that DPES* will cost at least 8

with inflation,then DPES* will cost at least $4.0 billion.

billion,have to be paid by ratepayers

the persons exposed.

These costs will

the extra money will buy no actual benefits.

technologies will do the disposal job equally well.

each case afound evidence of serious hazard to

NRC "radiological assessments" are fake "science"

hazards.

I have further discussed the distinction between

As noted at theand "public health" assessments inBoth alternative

the Krypton purging

Moving humans into

the containment of TMI-2 and moving radioactive wastes out of itInand do nothing to protect the public health and safety from radiationand taxpayers of Pennsylvania and otherstates and perhaps by shareholders of the utility.
start,

genuine "public health assessment"

entombment costs $0.5

radiation.

(Schedule

a letterwritten in"radiological"

conjunction withE).

Any adequate "public health assessment" of the danger to theispublic health and safety

from implementation of the proposal in

NUREG-

costly and this money buys nothing but grief for both workers and the0683 would show that the "radiological assessments" have covered up the

public.

grave dangers that would occur.

DPES* isSince there isa cheaper,easier,and

The only explanation offered here for the NRC insistence onsafer way to dispose of the radioactive wastes at TMI-2--essentiallythat bureaucrats follow their own special "logic" where it

immobilizingisthem inan ideal"tomb"

easier to endanger the health and safety of thousands of human beings

be used for other purposes)--only

than to bend NRC regulations to deal sensibly with the unprecedented

plan.

there are legal problems

Ifsituation at TMI-2.

Congress would act to change the laws sinceinentombment,I

believe

However,

involved inthis will save billions of(a containment that can never again

idiots would go ahead with the NUREG

from my personal contacts with the decision-makers

this issue,

follow the NUREG-0683

I am confident that the clean-up of TMI-2 will

plan.

.dollars and perhaps hundreds of human lives.
Finally,let

us come back to the real issue here,

the choiceof an alternative technology that will minimize the risks to *the publichealth and safety.

NUREG-0683 relies on inadequate"radiological assessments"
NOTE:

instead of on more realistic"public health assessments".

We now have

A-6

THE SCHEDULES MENTIONED IN THE ABOVE COMMENTLETTER ARE NOT BEING
INCLUDED IN THIS APPENDIX SINCE THEY CONTAIN COPYRIGHTED MATERIAL.

MMM

SAMORAJ. WHITTAKEI

JOos A. MYva
NMEoN A.

PuNT

Mr. Benard J. Snyder
September 5, 1980
Page 2JOHN 14. Bntoun

RosRKIARI C. PEIFFER

WM. C. C01TOVP0L05

Because of this, we urge the Nuclear Regulatory Commission
to survey the socioeconomic composition of Cumberland County.
We further urge that any decision or action regarding the cleanup be weighed in light of its
environmental impact on Cumberland
County.

Commtz~siunaPrs of Cumharlnnb Coanta
COURT HOUSE. CARLISLE. PA.

September 5,

Any accident, leakage, or venting at Three Mile Island will
have a direct and substantial impact on Cumberland County.
Itis time that the NRC recognizes this.

17013

1980

Sincerely,
Bernard J. Snyder, Program Director
Office of Nuclear Reactor Regulation
Nuclear Regulatory Commission
Washington, D.C.
20555
Jacob A. Myers,

Chair--man

Nelson A.

Vice-Chairman

Dear Mr. Snyder:A preliminary draft of the Environmental Impact Statement
concerning the Three Mile Island clean-up was issued on August
14, 1980.
Any decisions on the method of clean-up for T.M.I.
will rely upon this statement in weighing the environmental
impact of any action to be taken.
Comments concerning thedraft will be received and used for formulating the final report.

sjb

My primary concern is the failure of the Nuclear Regulatory
Commission to include Cumberland County in the "impact study
area."The importance of this determination is that special
consideration is given to the socioeconomic composition of the"Lpact study area."
Dauphin, Lancaster, and York counties
were included with this "study area" because of their "oroximitv"
and "the probability of its experienceing the more direct Limact."
I submit that Cumberland County meets both of these criteria
andthat special consideration should be accorded to the county.
The densely populated West Shore is no further than most of
the Harrisburg area from T.M.I.
It is much closer than the cityof Lancaster.
Further, the concerns and apprehensions of our citizens are
no less than those in our sistercounties.
The threat of evacuation is-. ust as present to Cumberland County as any other counties.
Route 81 and the Pennsylvania turnpike will serve as major evacuation routes.
The western sections of Cumberland Count-; w:l±serve as a host area for any evacuation.

A-7

Punt,

September 12,

1980

Nr. Bernard J. Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Program
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

-7

Dear Sir:

9/19/20

your Environmental Impact Statement on Three Mile Island
does not guarantee to the TMI area that no risk
is involvedin the clean-up of TMI 2, nor does it solve the problem
of disposal of radioactive waste, which is extremely
important.
I,

as many others,
1.

7o the Director
As a member of the goverment

oppose:and therefor

The release of radioactive waste into theSusquehanna River or stored on site.

2.

The release of gas

3.

The storage of radioactive
or any nearby areas.

good citizens of this treat nation

intc the atmosphere.

your duty to consider theit iswaste within thissafety of the public over any
profits of a corporation.

Since TMI 2 is a laboratory for the nuclear industry in
the nation, I think it
is only proper that the Federal
Government stop shirking responsibility.

T am most definitely apposedto the release of radio -The Federal Government permits construction, licenses
and regulates these plants, therefore they are a "PARTNER".
It is obvious that they permitted this industry to becreated without knowledge of the impact of an accident
such as TMI 2.

tz

cactive~into the eyviroment air,"::ater,land or whatever.
-Yot,=s

We feel that we are being used in experimentation for the
nuclear industry and demand that these plants - TMI I and
TMI 2, also Peach Bottom Nuclear Power Plant be closed
down permanently, cleaned up completely and waste disposedof safely.

Sincerily

Cory J.-La%•asca

Yours truly,am employee of the(Mrs.) Clarice h. Parsons
899 Clearmount Road
York, Pennsylvania
17403

A-8

'TRI-COUNTY REGIONAL PLANNING COMMISSION(CUMBERLAND, DAUPHIN, and PERRY COUNTIES)
2001 NORTH FRONT STREETBLDG. #2 SUITE 221
HARRISBURG, PENNSYLVANIA 17102
Staff Telephone 234-2639
September 22,

1980
P.O. BOX 1323-

HARRISBURG, PA. 17120 -to rnmo~nwluth(7171 787-8046
783-3133

ofPlnnslylvtln

U. S. Nuclear Regulatory
Washington, D.C. 205,:3
Attn:

Director,;OVERNOR'S OFFICE-FICE OF THE BUDGET

Commission

RE:

Three Mile Island Program Office

Subject:

ImpactComments - Draft Programmatic Environmental
Statement: Three Mile Island Nuclear Station, Unit 2

Dear Mr.

Snyder:

PSC-SAI#:'-"-APPLICANT:PROJECT:r

17)
.

-

Ik

LOCATION:

Statement concerning
The Commission has received the above noted
radioactive wastes
the proposed decontamination and disposalof
to review and comment
qualified
not
is
it
feels
and
activities,
on such a technically oriented document.

Enclosed with this letter
following State Agencies relativepleasethefindthe commentsof above:theidentified
projecttoVery truly yours,
Pleaseconsider these the comments of the Pennsylvania State-..
Clearinghouseer:ec. Rti
Executive Director

at this time.

Thank-you for your cooperation-.

sincerely,

Anne G. Ketchumn
Supervisor

c~-~-~-- 67- ~

A-9

4

~

/~9 Lj1I4e. I*odilin 0

Draft-Environmental Irpact StatementDecontaedination and disposal of radioG
active wastes-Three Mile Island Nuclear
Station Unit #2.

i;*PA 17120
i. r78714W

3eo~.So`er
Cf~~of=iTer ýýeactor -Regnlatjon-,U,,:,-* R.)- iaorv Co-nmission*~C~218tiI0.C.

FIRST STAGE REVIEWPrIapplicatJon/Notification of Intent
AGENCY REVIEW COMMENTS
INSTRUCTIONS:

Tobe completed by. review agency and returned to State Clearinghouse. Check one or more appropriate boxes.
Indict comments below. Return copy 1.2 and 3 to the State Clearinghouse. Retain copy 4 for yowe
record. Attach triplicate sheets if necessary.

Tothom ito3,190Al1conh-!-ury, LarA03
H:ouston, Te-as 77021
4317..'ay Concern,'.'ULIC, 0,M2`

707iO

PART I " Declaration of Interest

I I(A4 Interest Declared - Complete Parts 11, 11, IV and V and

No Interest Declared- Complete Part V andreturn copy 1 and copy 2 to State Ctearinghouse,return copy I and copy 2 to State Clearinghouse.

4AKMt. "t-dwntificetlon of Alilecy Review Criteria (Agency plans, programs. policies and/or laws)
Deparaent of Transportation Policies and Plans.

AIN

WE4"I1S LleIcluderesulin of pseliminaer contact made with applicant and suggestions for improving project prsM
We have reviewed this eocL-ent and after consultation with the Department's
Hazardous Substances Division, me feel it necessary that tae ,eparazent
submit an adverse counent on plans to traosport ;astzs to Ltze State of
Plate 3-2-2 indicates plans to use US 15 as a way.
Washington disposal site.
This routing includes some twowest.
to reach Interstate 80 for the trip
lane roadway in Perry County which has a recent history of a high accident
The use of Interstate 81 north would appear to be a bwtter alternative
rate.
from a safety standpoint.
(All four lanes, away from population centers,etc.).
would be to use thefour-lane fact.. y
The most direct access to awould involve using tunxnels, which is
Pennsylvania Turnpike, but thisprohibitid by Turnpike rqgulatfons.

DAlecooenmefldDisapproval'W~" ~1llwon[ I

Request the opportunity to review environmental impact stateenantarsnzdAgency Sgere

I ~Agency~Department of

Date

Sept. 102, 1980

Transportation

A-iO

O'N NUREG-o633, DPEIS RELATED TO DEC.; ;TAjDISPOSAL OF RADIOACTIVE WAI39ES RESULTING FRC,
28, 1979 ACCIDENT, THREE ,'4IL7. ISLAND - II.?E
.ARCH

Co'el
oz,, h-'a-t fro<ramatic Environnental
Iaoact ]tat -- ent is in the area of health physics. .oy
As has beer pointed out by Officials of General Publid
Utilities, t e TNI-2 event provides an excellent opportunity to stu"7 various a.oects of nuclear Dower.
S'or:fore, I believe a hznalth study of lon- duratimn !nhoul1
be a nart of the re-,air and recovery events
at tiisnlant. The stu:,4 woul,-be one of recording
e:x--osou7e to workers involved in all aspects of the the
Qorition where bad ms are reguired to-record exnosure.
a 1oition to the recorledl e:xo-osure, Provision should
oc ;iade for each persons health to be followed
for thene-t 30 jears (the lona:ost period for a carcinoma todevelope fro.n exoosure). And., of course, the dataon
the co:clejisioa of the study, and for reasonable intervals throu-h the years should be studied, with thestudies released to the nublic.
This i- an e'rcellent opnortunity to study theeffectsof osure mo the radiation from an atomic unit, aid
I believe the oo;ortunit'r should not be missed.
Sincerely,
jfd#PART'IV:"Recommended State Clearinghouse Action (This action will not be honored by the State Clearinghotue unless Part II andPart III above have been completed)[I Request the opportunity to review final application.
•V:ei.re,nnd Approval

-!D

•6h
D.ohertysPlsme forward this to the proper persons if
not handling public comoents. Thank you.

NRR is2

VMaryland Ad Hoc Committee on Three Mile Islanc
Contact: John Kabler (301)

235-8808 or 235-8810
Independent scientists
queried bv the Ad 1oc Committee havecriticized
the D-PEIS on ntnmerous points. Examoles include cuestions raised about incorrect mixing projections, inaccurate andmisleading Susquehanna River flow rate figures and inadeauate andconfusing data concerning quantities of radioactivity involved in

STATEMENTOF THEMARYLAND AD H0C COMM-fITTEE ON THREE MILT ISLANDAND
CLEAN WATER ACTION PROJECTTO ThTENUCLEAR REGULATORY COCNISSION
AND TH7
MARYLAND DEPARTMENT OF NATURAL RESnURCES
September

30,

various waste products.

1980

The accident at Three Mile Island left
more than a million
gallons of radioactive water at the plant, includinR 600,000 gallons of highly radioactive water stillin the containment building.
Metrooolitan Edison has said that its
Dreferred plan for disoosingof thiswater is to treatitto remove most of the radioactivity
and then discharge the water into the SusQuehanna River, source ordrinking water for several communities dow-nstream (and a backuo sourcefor Baltimore) and potential polluter of the priceless Chesapeake Pav,
an enclosed and very fragile
ecosystem.

Some basic flaws in the PEIS which might require separate enivironnental
impact statements:
1.

The problem of how and where to disoose of the wastes resulting from the
There is no asaccident and cleanup process is inadeouatelv considered.
surance that any waste site will accept the low-level waste in the amountpostulated'by the NRC staff and ultimate disposal of high-level waste remains an unresolved question.

2.

The NRC staff dismisses the question of whether TMI-2 will be decommissioned or prepared for restart by stating that it is not within the scopeof the PEIS.
In reality the methods of cleanuo are very deoendent on thedecision to restart or to decommission the unit.
Certain processes could
severely damage the equipment, making the final disposition question essential in selecting the proper methods to be used.
Thus the question ofrestart or decommissioning of the plant must be considered in depth within
the ?EIS.

3.

There is a total lack of cost estimates in this evaluation Phase of the
PEIS.
The NRC staff has promised that the cost factors will be provided
in the final PEIS (after the period for public comment has passed).
Thelack of opportunity for public comment on economic aspects of the cleanup
provides an example of how the public is being excluded from the decisidm
making process.
In view of the precarious financial condition of Metropolitan Edison, the NRC's assertions that costs are not a limiting factor
can hardly be viewed as realistic.

4.

in the PEIS the \RC makes the assumotion that cesium and strontium fromthe olanned release Of orocessed water (which will contaminate Chesaneake
Bay seafood as far south as the Potomac river) will not effect the market-

A year and a half after
the accident the radioactive decontamination of the damaged reactor continues to threaten the health and safetyof Maryland citizens
while the government's handlina of decontamination

procedures has seriously eroded the oublic trust and confidence in
state

and

federalregulatory agencies and6overnmental

safeguards.

The Nuclear Regulatory Commission (NRC) has consistently and effectively precluded the public from ade'uate oarticioationin the analysis, and subsequent decision makinz orocess, concerning the- radioactive clean up at TMI. Examoles Include the ourchase and installationof Epicor 11, time constraints imposed in the decision makinc for thepurging of Krypton-85 and NRC's failure
to follow uo on its
Dromiseto form a citizen
advisory committee with funding for independent' scientificreview.
On. August 14,
viror-mental Impact

1980, the NRC released its
draft Proarammatic EnStatement (D-PEIS) concerning decontamination an4

disposal of radioactive wastes at TI. Under oressure fron citizen's
groups and Pennsylvania Governor
com.ent oeriod on the D-PEIS until

Thornbur-h, the YPC has eytended
November 20, 1980.

theAlthouglr we appreciate the NRC's decision to extend the comment
period, there are basic flaws in the D-PEIS which cannot be orooerlv
addressed through the public comment process and must, instead, be re-solved through further studies by the N•C, with subsecuent Dublic re-v;8-i

and comment.

_

Post Office Box 473

Other problems in the draft statement,

according to Union of Concerned Scientists
reoresentative Robert
Pollard and others, bring into question the validityof the entire
document.

Severna Park, Maryland 21146

_

A-11

abilityof the seafood.
A separate EIS that includes market research dataon radioactivity in Chesapeake Bay seafood must be performed prior to making
any determinations as to the effects of radioactive contamination of Bay
seafood on the seafood industry.

The controversy that exists today is not simply over the
D-PEIS and the proposed methods of radioactive decontamination
at TMI; It also involves serious doubt, if not suspicion, about
the government's real intentions in handling the oroblem. '.henpublic officials or citizen organizations reouest better avenues
for citizen involvement in the decontamination decision-makinR,
the NRC Dublic relations staff responds with self serving explanations of NRC policy and procedures and, tyDically, no resDonseat all to the specific request.
NRC's method of dealing with the decontamination orocess has
been both inappropriate and irresponsible. Instead of dealing directly and effectively with the cleanuo, NRC has preferred to let
things drift until a crisis occurs and then, as in the case of
Epicor 11, justify subsequent ill-considered actions by blamingthe. crisis.
NRC officials apoeared to be responding to the credibility
crisis they had created by publicly agreeing to aDooint a iitizen
advisory panel with funding for independent scientific review inMarch, 1980. Their refusal to follow up on this promise has further
alienated a skeptical public
Whereas it may be easier to make a decision with incomolete
information, it will be more difficult to live with the consequences. In our view, it is indefensible that NRC continuously
avoids the scientific and public inDut that, if properly considered, could lead to a safe, effective and politicallv acceptable cleanup at TMI.
More seriously, NRC now proposes to make a complete mockeryof the NEPA process by refusing to hold public hearings on the
PEIS. CEQ regulations call for such hearings when there is
draft"substantial environmental controversy concerning the proposed
action or substantial interest in holding the hearina."
What could be more controversial than-the radioactive decontamination of the nation's most serious nuclear accident, located at the headwaters of the world's most valuable, and ecologically sensitive, estuarine system -- the Chesaoeake Ray.
N.RC must work to restore the public's trust and confidence
in their capability and objectivity in determining the best courseof action in regard to the cleanuD at TMI. Failure to do so will
result in increasingly effective citizen action in oDDosition to
NRC plans.
In order to resolve the crisis of credibility that NRC has
created, and to restore the public trust and confidence, NRC
should agree to hold well publicized public hearings in "altimore

A- 12

and Harrisburg or Middletown, and to re-initiate its
stalled agreement to appoint a citizen advisory committeewith funding for independent scientific review.
No new actions concerning the decontamination of TN1should occur until NRC has redesigned their PEIS in response to the public's criticism and the findings of an
independent scientific panel.
Finally, no radioactive water from TIT-2 should be
released to the Susquehanna, until scientific controversy
concerning the safety of such action has been resolved,
until NRC and Metropolitan Edison can prove that such releases will not affect the marketability of Chesapeake
Bay seafood and until citizens living downstream from thedamaged reactor agree to such releases.

EM
L

M

E

..

.

.

II

III

"

-2-

First of a21,
to hold public
on the PEIS.
.of! urce the facicTr Fegulstory uos::missic:

hesrinoýs,both in:rylamc

sects to-,.e th2t-he criteria

It

Evironmental iua1itw regu•ltins,

in

40 CY

-ne

1500.7,thethe proposeIs,of iriterestinthe nronosals and the extent of public

involvementnlreýdv!enit-

ofthe issues,

would indicste

ochieved,

thet

Council

icrortance ofco,r-r'ous deficiencies.

safe.

cm see it

is

have

that pnblec hearings

the

it,

As I uml.ersemondrunnirt: thi.. cleani:p.

of :etromoliian

acosmecton thenot do

The

-'RC

'he

zmiscnarest faithmust be-c

body tothethat

lives in:,et *d

it,

need

in

it

and !Met 3d.
process

truly: indeccnde"t,-onitor the cleanup so

Is-i
Edisone0o, 't!'.

:.ar -landers who makh`.-o:lev:E='_t

en

...

toc

heath

er

se

ehV-:
-Io•1
e~v nlnecnc'o""Oe c ifse
detcr:.ý_i,

l

.

..
-:-rl:'iicr

i:

•c

i.c

n the

n"

e

.ott

:E.-: :.

uu ni1.i
'
un

-t.,

..

"v.r-

cf our citicu-.riutechnic-1

:.

e

.

r

t0ý
--no

-e

eable,.r;.

w.,ellr .

=7e~.Sfta~i

7 _

---

t~-t

,.- .

7e-C

--

,-

-:,.

e

01.00

A- 13

assuronce"L$-:'

jeoari.

financed,rs.wo drinkjeop: ra'i___

h.Ith

t<e
-so Chessme-e-ea.

recuirenc- uding

o--

.
'

zo

1:n-e-,> etheir litnZ
1ih0oosomebeing done correctly.

e-rc -e

The oc ee.u'

will

7,,o

c

crcnensec a-noh:: the -hO

in'1rn7'3.

a !aros n

50.- r!iný on t~l i-n.tThere must .e

cuec-m.ehanno mmi•.r wo.oer arc'. not -h_-vio', -hir.- C will notfe:.etrepoiita-

isthe mucl'ic d,-es not

Islend or eat the sclfocd

assura.nes

to us---et

job recuired to make the-PC must recplize that- 1-- re not h1aving Oneir-'ive.feexcellent

must develop plans to monitor the cleanup:re public that thischoose the method of the cleanup but only
hasveto over the
method :Ket toooses.
,e Miarylanders w,`ho a-tria_:
the after

mossibly releesed from Three:ith the fear

being done correctly.

•i•nlly,

Thrcr

to comment

lice

lest Ed willcleasnu

ae-reeshould ce held.
I'd

This leoves the observerand Pennsylvania,

.y

S

The
Chesapeake Bay Foundation"Citizen Representation - Environt ental Education ..Land Presemation"

162 PRINCE GEORGE STREET*"THE CHURCH"

301 268-8816.(Annapolis)

Officers
C. TROWBRIDGE STRONG
President
GODFREY A. ROCKEFELLER
t.'ice.Pr-aiden;
ROBERT 'I. HEWES, 5,dSecretary
JAMES E. TEMPLETON
Treasurer
E, Officia Trustees
GOVERNOR JOHN N. DALTON
GOVERNOR HARRY R. HUGHESt
TRACY A. GILL • Studen

September

D.'.VIF,¢30,

the following criteria

Re:

Clean up should proceed as expeditiously as possible
consistent with proper planning.
For example, we
are most anxious that the processing and removal ofsump water begin in order to avoid additional damage
to equipment essential for safe operation and controlof the reactor.

2.

Adequate planning and impact assessment must be carriedout to ensure that the safest and most effective procedures
are chosen.
This may necessitate further preparationof impact statements if unanticipated conditions occur
which require actions which have-not been addressed in
this
PEIS.

3.

The accident-generated radioactive water should be promptly
processed to remove most of its
radioactivity in order toavoid the potential accidental release of thishighlycontaminated water to the river.

4.

Decontamination procedures which would minimize theamount of liquid waste generated should be given
preference.
Processed water should be re-used as much as.
possible in the cleanup activities.

5.

The processed accident water should not be discharged
into the Susquehanna River since other alternatives areavailable and thepotential impact on the marketabilityof Bay seafood could be serious.

6.

Radioactive waste generated by the accident and subsequentcleanup activities
must be promptly removed from the island
so that
TMI does not become our nation's
first
long-termhigh level waste disposal site.
Itslocation on an islandin the middle of a river which- supplies 80% of the fresh
water of the upper Chesapeake Bay is not appropriate forsuch disposal.
We urge that the NRC work with DOE toestablish an appropriate disposal site
for this material.

7.

In anticipation of waste transportation and disposal
problems, we urge the N1RC when selecting procedures forcleantup, to choose these which generate minimum amounts ofwastes which are at the same time, in form and level ofradioactivity and most readily transportable and suitable
for long-term disposal.

8.

Methods should be chosen which would keep levels of radiation
to workers and the oublic to the lowest achievable levels.

1980

Draft Programmatic Environmental Impact
Statement related to decontamination anddisoosal of radioactive wastes resulting
from March 28, 1979 accident Three Mile
Island Nuclear Station, Unit 2 (PEIS)

Dear Mr.

Snyder:

The Chesapeake Bay Foundation is a non-profit,
private conservation organization with over 6,000
members.
Our basic purpose is the protection of
Chesapeake Bay water quality and natural resources.
The Chesapeake Bay is our nation's mostproductive body of water and its
seafood resources
are most important to thiscountry.
The Susquehanna River upon which the TMI Unit
2 is located is the single most important contributor of fresh water to the Bay, supplying 80% of the
fresh water to the upper Bay and 50-60% to theentire Bay.
Thus, the decontamination activities
at TMI are of vitalinterest
to the Chesapeake Bay
Foundation and the citizens of the State of Maryland.
The PEIS which was prepared by the Nuclear
Regulatory Commission (NRC) is important as ananalysis of theotential
impact of those decontamination
activites.
However, we believe that there areseveral deficiencies in it and also note that itpresents a series of alternatives, rather than ao.an.

In order to guide the NRC in its
review of
the various alternatives, we believe that certain
criteria
should be used.
It is our position that

AT

A- 14

are most appropriate:

1.

Mr. Bernard Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. - Nuclear Regulatory Commission
Washington, D.C. 20555

E. T. BUCHANAN - L)nnha-en Chap-t
J. PARKER CROSS. J R. • .'orfalk Chapter
HAYDEN ROSS-CLL-NIS - York Chapter
RUSSELL C. SCOTT - Richmond Chapter
Trustees
BERTHA S. ADKINSGEORGE E. BAHEN.JR.
JOHN M. BLOXONIELISABETH REED CARTERJOHN C. CLARK.SON
VICTOR L. CRAW FORD
L. EUGENE CRONIN
T. MARSHALL DVER.J R.
CLAYTON EW'ING
CHARLES S. GARLAND, J R.
ALBERT F. GOETZE. JR.
N1.GRANT GROSSEVELYN I. HAILEY
D. HEYWARO HA.I1LTON. JR.
WILLIAMIJ. HARGIS,JR.
BRUCE F. HARVEY
T. HUGHLETT HENRY. JR.
C. A. PORTER HOPKINSERNEST W.JENNES
E. POLK KELLA.MNR.
LUCIUS.I. KELLAM
CHARLES V. B. LaNIOTTEJEROME LaIDES
M. LEE MARSTONCHARLES NIcC. NIATHIASJOSEPH H. McL-AIN
PHILIP MERRILL.IAMES Is. MUILLEN,II
ItILLIAM 8. MIULLLNS
L. CLEMENT NIXONSTLRE G. OLSSON
M. LEE PAYNE
TRUMIAN T. SEAMANSARTHUR W. SHERWOODLEONIE L. SIMIMONStIILBUR E. SIMMONS. JR.
ROBERT L, STEVENSDOUGLAS h.A RLN
ER. J R.
WI','LLIANM
Wt.WARNER,'.ST
L•L.Nr..XER* ANNAPOLIS, IARYLAND 21401
269-0481 (Baltu.) 261-2350 (%ash., D.C.)

Page TwoM.r.
Bernard Snyder

Page Three,r.Bernard

Page Four
Mr. Bernard Snyder

SnyderRegardingStatement itself,

the Draft Programmatic Environmental
we have both general and specificImpactcomments.

It is of special concern to us that the PEIS presents a
number of alternatives but does not recommend a plan.
Consequently
the public has no assurance of the procedures which will befollowed or even of the criteria
which the NRC may use in consideringplans proposed by Metropolitan Edison.
We therefore request at
thistime that the public be given further opportunity to comment
when actual proposals are made by Metropolitan Edison for cleanup
and disposal activities.
A serious deficiency in the PEIS is the lack of cost estimates
for the various alternatives.
Although we don't want to havedecisions made which would provide less adequate treatment in orderto save money, there may be times when such information might help
in a choice between otherwise equal alternatives.
Particularly,
we beleive that a decision regarding the feasibilityof restarting
Unit 2 should be based to some extent on the relative
costs of "cleanup to protect all
the equipment for restart
purposes, on the
one hand, versus simpler and less expensive treatment that could be
used if the equipment were going to be scrapped.

3.

It should be noted that the average amount of tritium
released from a normal generating unit of thissize is400-500 curies/year.
if the total
amount of tritium inthe processed water is 3700 curies, it would takeapproximately nine years to release it at thatrate,
instead of the one year that is being proposed.

4.

Calculations of the expected dosages to fish
release of the processed water are presented
6.3-18.
Assumed concentration factors are:tritium
Cs137, Cs134
Sr90,Sr89

deficient or erroneous in

5.

A number of studies have been done which discuss substantial
variation in concentration factors with many values being
significantly higher than those assumed by the PEIS.
Concentrations ui.to
40,000 times for cesium in fresh xter
low in potassium- and up to 30,000 times for strontiumhave been documented.
There is even uncertainty regarding
the potential for bioaccumulation of tritium, although3/
most scientists
believe that tritium does not bioaccumulate.-

6.

The potential impact of these radionuclides is barely
mentioned in the PEIS.
Yet a recent report states,"Because a large percentage of the cesium accumulLted byfishes lodges in edible muscle tissue, spcrt and commercial
fisheries suspected to bý,contaminated by radiocesium should
be carefully monitored".-/ Strontium, on the other hand,concentrates in the bony portions.
The same report states,"Because of this bone-seeking tendency, radiostrontium isextremely dangerous."
It goes on to state
that, "fishes
such as sardines which ars consumed in their
entirety
represent the greatest risk to humans, and soft waters
contaminated by the radioisoto?
offer the optium conditions
for isotopic bioaccumulation".-" Since the Susquehanna isa drinking water source as well as an important area for
sport and commercial fisheries, including shad which areoften eaten bones and all,we feel that the disposal ofwater containing these constituents into thisriver isinappropriate and the potential impact has been underestimated in the PEIS.

several1.

Estimates of the concentration and distribution of
the constituents in the processed water are dependent on
factors which are unknown at the present time, including
the condition of the core and primary loop.
Yet nobest case and worst case conditions are presented rega;ding
this.

2.

Total radioactivity which would be released to the river
as presented in Table 10.1-2 does not correspond withdata in Table 6.3-5 regarding the volume of water andconcentration of the radioactive constituents.
In fact,
Table 10.1-2 shows a totalof 2.5 to 3 Ci of radionuclides
from the processing of reactor building sump water, whereasa calculation based on the effluent volume, concentrationand 1200 dilution factor shows a totalof nearly 3,700
curies to be released, most of which is tritium.

A-15

1:1
3000:1
500:1

yet the rationals for such factors are not presented in
A number of factors which will cause those
the PEIS.
concentration factors to vary are not even mentioned,
and presence of calcium,such as temperature, salinity
potassium, etc.

Since the Chesapeake Bay Foundation is particularly concerned
about the potential release of accident generated processed water
to the Susquehanna River,
we will confine our most detailed commentson the PEIS to that area.
We believe that the PEIS is
instances:from thein TablePage Five
Mr. Bernard Snyder
7.

8.

Page Six
Mr. Bernard Snyder

impact on the
The hydrology of the river and its
distributionof radioactive isotopes is incompletely
Estimates of concentrations in the riveraddressed.
assume complete mixing during average low flows,(p.6-19).
Yet since there are islands to the West ofThree Mile Island, the complete river is not available
for a mixing zone.
As was noted on p. 6-24, fish
could be exposed to conditions in which mixing was
not complete, causing doses up to 20 times higher
than those presented in Table 6.3-18.

In summary, we feel that the PEIS has inadequately addressedcertain areas regarding the potential impact of the release ofprocessed accident water and particularly
the impact of such
It also needs to address thean action on the seafood indsutry.
And finally, criteria
must beultimate waste disposal problem.
in the selection of appropriate decontamination
developed to assist
procedures.
Sincerely,

Sediment deposition processes within the SusquehannaRiver are quite complex, yet they are barely mentioned.
Because of dams downstream, sediments are likely to beThedeposited in certain rather concentrated areas.
tendency of cesium to be absorbed onto sediment particles
creates the likelihood of "hot spots" being createdwithin the river and on the Susquehanna Flats../We
believe that the PEIS incorrectly assumes that a fairly
large percentage of the cesium will remain in the watercolumn for some time.
Considering sediment loading in theRiver and studies that have been done on behavior ofof the cesium tý/
cesium,we would expect virtually all
have dropped out with the sediment within four days.We are concerned that large storm events would cause
a sudden release and resuspension of these contaminatedsediments.

9.

We must again stress that the release of processed water
to the river is undesirable since it could have asubstantial impact on the marketability of Bay seafood,
which is worth millions of dollars to Maryland's.economy
and provides employment for thousands of individuals.

10.

Viable alternatives exist for disposition of the water.
lie would recommend that it be immobilized in cement andfor disposal as is all
theeventually moved off-siteother low level waste.
In itsimmobilized state it would
not represent a radiclogical threat and could be assigned
disposal.
a low priority
for off-sitei1.

The apparent inabilityof the federal government to locate
a high-level radioactive waste disposal site
is a serious
problem which seems to be avoided in the PEIS.
Yet its
resolution is essential if the high level waste is to be
removed from the island.
We believe that the seriousness
solutionof thisproblem should be fully exposed.so that its
by the NRC and the Department ofis given top priority
Energy.

A- 16

Nancy G. Kelly
Senior Staff Biolo ist
NGK/kawTestimony Before NRC Public Hearings Regarding theDraft Programmatic Environmental Impact Statementfor Decontamination of ThI Nuclear Station, Unit 2

FOOTNOTES
they are unable to remove

Both the NRC and Metropolitan Edison admit that

The
1967.
and J.W.R. Dutton.
Preston, A.,D.F. Jefferies,
concentrations of cesium-137 and strontium-90 in the fleshof brown trout taken from rivers and lakes in the British
Isles between 1961 and 1966: the variables in determining
use in radiological assessments.
the concentrations and theirWater Res. 1(7): 475-496.
L.A.

2 Kromholz,

Observations

1956.

a lake contaminated byHist. 110(4): 277-368.

from the infamous accident

on the fish population ofradioactive wastes.

Bull Am.

Mus.

Nat.

water will ultimately

this tritiatedAccording to their draft

end up in

the Susquehanna River and be carried downstream into Chesapeake

Bayfhe plan is

EIS,

Evaluation of potential hazards from tritiated
Brookhaven National Laboratory, p. 287-299.

Phillips,

to release about 3,500 Ci of tritium over a period of a few

Now the average annual release of tritium from a nuclear

isonly 400-500 Ci,

which means

releasing about twenty

G.R.

that on a similar annual

power planttimes more tritium than itbasis TMI will be

would under normal

and R.C. Russo.
1978.
Metal bioaccumulation
review.
in fishes and aquatic invertebrates: A literature
Office of Research andEnvironmental Research Laboratory.
Development,. U.S. Environmental Protection Agency, p.21.

be sufficiently diluted with non-tritiatedriver water so that

Ibid.,p.

concentration of tritium shall fall

the NRC safety

Troup,

one and a halfV.P.

water.

6that occurred at Three Mile island,

water resulting

years ago.

months.

Bond,

thousand of gallons of contaminatedtritium from the hundreds ofconditions.

58,59.

B.N.

Bricker.
1975.
"Progesses affecting thetransport of materials from continents to oceans", in Marine
American Chemical
Chemistry in the Coastal Environment.
Society. o. '143-144p.

told notiswithinthe cumulative amount of tritium rather thannamely,itthat isthe significant statistic

inthis caseof tritium in

-

in

is

secondly,a slightly more scientificvernaculara more detailed

appropriatescientific presentation,

research,

that

is

forwarded at some future date.

A-17

in

now inthethousand curies
the NBC safety

dosage calculations
life.

the two reasons given

meant to amplify

to the NRC Commi~ioners and to the publicinconcentration

radiotoxicity of tritium to human

The remaining part of my testimony
above

its

to three and a half

standards for tritium are based on outdated population
the

This

good reasons;never before havetheir fishing and drinking water and,that grossly underestimate

the actual

standards.

for at least two very

people near a nuclear plant been subjected20.

water will

to be concerned because the tritiatedassurance does not assuage my concern

and O.P.

Phillips and Russo,

We areoperatingthat should be comprehensible

general.

If

the NRC isincluding documentation

the publicationinterestedof theprocess and can be

-2--1Inhomogenious Dispersion Versus Uniform Dilurion

Conventional engineering

Biological Accumulation

wisdom asserts that dissolved tritium or

tritiated water rapidly diffuses throughout any body of water,
its equilibrium concentration,body of water forever.

The toxicity of any hazardous

reachesquantity of that substance to which

and remains uniformly distributed in thatisThis rather simplistic view does not take several

additional factors into consideration such as convection

substance

the larger

noexception,

stillbirthsdand cancer.

typically,

the International Commission of RadiologicalFor example,

its

if a nuclear power plant (e.

g.,Three-Mile Island) discharges

its tritiated water into a naturally flowing river ( e.
River)

g.

Susquehanna

total volume of river water to achieve maximum dilution; but rather,

it

may

the body fluid(i.e.,

organic compartment).

assumption of the ICRP dose estimate

isthat the tritiatedUnderstandably,

regions of the river wherethermal diffusion is less vigorous,

scientific evidence demonstrating that theall of these

tritiumfor hydrogen only
real life

inis

not that simple andistritrium within the river thereby resulting in an uneven distribution of theirides,lipids,proteins and nucleic acids)

tritium.

source(HTO).

This results

In other words, parts of the river would have much higher concen-

inthe organic moleculesfrom attrations of the tritium than other parts and thus any ingestion of thisbiochemical phenomena including

more highly tritiated water by(2)

fish, animals or even humans would result ingreater irradiation of their tissues(by the beta particles) thanone

concentration

chain and(3)

The implicit

body water exchanges

there isnow considerable

tritium to hydrogen ratio (T/H)

or biopolymers
than in(suchasinorganicthe(1) isotope effects inmetabolicdistribution.

bonds which are much stronger

than the more polar hydrogen-oxygeninSince many oflong half-lives),

relatively long intervals.
1 recursers

A-18

for example,

the inorganic compartment.

stable (i.e.,pathwuys

induction Aunscheduled DNA synthesis.

The

can,

tritiumalong a foodwould anticipate by the engineering hypothesis of a totally uniform tritrium

metabolic routepolysacch-

least three distinct biological orof tritium within the organic compartment

radiation damage

neglected

a polar or ionic transfer with other molecules.

additional factors would prevent a rapid equilibration of the discardedmuch greater(T),calculated

and totally

the

its

birth defects,(ICRP)

the covalently bound tritium (i.e.,

the river bed (or its aquatic contents) or even remain within the cooler

thethat would equilibrate

the inorganic compartment)very well stay within certain currents or be adsorbed by the sediment ofRadiation

the effect of tritium

Protection

population dose based on the tritium activity

withthen that tritium does not instantaneously diffuse throughout theresulting incame to evaluating

thermal differences and different rates and strength-of physical alsorption.

exposed.

of the radioisotope

and somatic damage

When ita function of thea living organism isthe concentration

greater the risk of genetic

currents,isor Concentration

produce covalent tritium-carbon

these organic biopol'mers are quite

the tritium tends

The data also

are more easily incorporated

bonds foundto "hangsuggests thatthan simple HTO)

around"tritiatedfororganic

into organisms,

-3further along afood chain with several trophic levels.

Thus theMicrodistribution

greater chemical stability of the tritiated organic molecules and their

Affects

Relative Biological

EffectivenessThe radiotoxicity of tritium depends,

incellular and molecular

The marked differencespart,

on itsexact

tissue,concentration along the food chain results in a much greater biologicalaccumulation of tritium than one would anticipate from the oversimplified
ICRP hypothesis.

radiosensitivity

The incorporation of tritium into any biopulymer isthethe specific case of DNA,of that macromolecule in vivo.

the beta decay of tritium causes radiation

tritium has an autocatlytic effect on the synthesis of DNA.

three

come into play,steady-state

concentration

investigators

haveof tritiatedfound that thewas 3 or 4 times that

producing a greatly

found inDNA (T-DNA).

incorporation

the water(HTO),

In

however,of the radioisotope within thecell has only recently been demonstrated.

that is,thereforetissues has been well recognized,

affect of the microdistribution

the

All

A measureof that cellularIndamage to this biopolymer which increases its rate of synthesis,

phenomenaof various

in

the

clearly a function of the concentration of tritiated precursors,
rate of synthesis and the half-life

localization.

radiotoxicity

iscalledquality factor(QF)

the relative biological effectivenessand itmay be assayed invarious ways

(RBE)

or

such as thetheinhibition of erythropoiesis,killing of oocytes or spermatogonia,

of dominanttissue culture

lethal mutations;

growth rate

(e.g.,

frequency
HeI&

increased
fact,

Cells)

inhibition,

appearsthat thetoxicity ofform,

for example,

the QF of

water

(HTO)

or the numberof single strand breaks in

DNA.

It

severaltritium varies

greatly with its

molecularof tritium into DNA
tritiated

DNA(T-DNA)islargerthan tritiatedclearly demonstrating
or even other organic

molecules(e.g.

tritiated

proteins or lipids)f.

the importance of biological accumulation.
Recent studies

indicate thatratherthan theDNA isconsistent with

the RBE for tritiated-DNA is

1.7 or I designated by the ICRP.
the increased

chromosomal structural aberrations
mutagenic and carcinogenic
known capacity
been ateffects of radiation.

namely,theare introduced

repair mechanisms(byby errors in

(2)

DNA
the

radiation damage)formations of the cells into abnormal

A-19

DNA strand

breaksfor

In addition to its

that(1) beta radiation

rate and efficacy 6f DNA repair

mutationsofas being promarily responsible

least four other mechanisms identified

to 4

The greater RE forfor rupturing theDNA strand or macromolecule,radiotoxic potential,
theimportancecloser

tend

and
the
well-

-

there haveto augment its

from tritium retards

may be altered

rapid'mechanisms

so that point(3)

may also facilitate

or malignant

tritiared-

forms andinduction ofviral trans(4)synergistic

New York Untiversity

effects due to the presence of toxic chemicals

A private uaioers
dryin thepublic service

may enhance the radiotoxic

effect of the decaying tritium nuclei within the DNA.

Thus any calculation

Faculty of Arts and Science
Department of Psychology
Psychology Building

or estimate of the population dose resulting from exposure

to tritiumor tritiated water must consider both the greater concentration of

6 Washington Place, 4th Floor
New York, N.Y. 10003
Telephone: (12t2) 598-2745

16 September 1980

tritiated DNA than was previously suspected as well as its much larger
QF.

Nuclear Regulatory Commission
1717 H Street, N.W.
Washington, DC 20555

These two factors alone may represent a ten-fold increase in theradiotoxicity of tritium and must be properlyreflected by new government
Dear Sirs,

standards for the acceptablelevels of tritium" to which the public
In response to your request for public comment on the Draft Environmental
Impact Statement for the clean-up at Three Mile Island (NUREG-0683), we aresubmitting the following observations and criticisms.

may be subjected.

First, the authors of the Statement are to be commended for having included
the issue of psychological stress in assessing the environmental impact of
It was a forward-looking step, which we hope will becleanup operations.
emulated by the authors of other attempts to predict the impact of importantsocial actions, for many undertakings may be desirable in themselves and yet
may cause a great deal of avoidable human suffering if carried out without
regard to their psychological impact.
Perhaps the fact that it was a pioneer effort accounts for the amateurish
Not only is section 3.1.7
quality of the material on psychological stress.
that it appears
grasp of the issies
vague and inconclusive, it shows so little
to have been written by a well-meaning but technically untrained bureaucrat
Psychological stress is treated in arather than by a qualified professional.
zcnfused and inconsistent way, but fundamentally without understanding of theStress is not something that exists within a person andkind of concept it is.
hag "effects; it is not "created from anxiety" (p. 3-24, par. 2) or from anything,Ise. Rather, it is a convenient term for a class of phenomena, just as (forexample) perception is a general term for the fact that we take in sensory
Seeing is something studied by psycholoinformation and experience the world.
gist's under the general heading K~f perception; by the same token, the subjective
and objective effects of going tfrough upsetting experiences are studied under
It is perfectly possible to write an entire
the general heading of stress.
chapter for a book on Stress and mental disorder, as one of the major pioneers
stress, Dr. Thomas Holmes, did, without once using the wordin the study of life
In fact, as he suggests (on p. 62 of the above-mentioned 1979 book)"stress."
it is an excellent idea to avoid the use of this ambiguous term, which so readilyin the above-quoted passage fromillustrated
to the reification
lends itself
D. 3-24.

Submitted by:
Irving M. Stillman, M.D.,. Ph.D
Howard County Doctors Bldg.
9380 Baltimore National Pike
Ellicott City, md. 21043

On this matter of terminology, the relevant parts of the Statement have a regretA glaring example
into jargon instead of plain speaking.
table tendency to fallTrue, there is a
is the constant misuse of the'term "perception" for "belief."
for this usage, but it is unnecessary
certain precedent in psychological literature
Perceiving and believing are bothand positively misleading, as happened here.

A-20

3

subjective cognitive processes, but that's about as far as the similarity goes.
More specifically, perceptibn implies forming a subjective impression of the
I perceive that this paper is white,actual status of some aspect of reality:
If I know thatregardless of the amount of light actually reflected from it.
someone has written on it in invisible ink, I believe that it contains a concealed message but I cannot perceive that until the paper is heated.
In the particular case of radiation damage, this distinction happens to be
Someone who has had a 10 REM whole-body exposure perceives.
extremely important.
nothing, but if he is correctly informed that he has been so exposed, he may wellbelieve not only that he has been irradiated (true) but that he has been damaged(possibly true, possibly false).
Only when dosages become heavy enough to cause
In section
radiation sickness can a person perceive that he has been harmed,
10.6.2, perception is repeatedly misused in this way, implying to the unwary
terrifying (or stressful,that ionizing radiation is perceptible, when part of its
if you will) effect is that one can receive a severely life-shortening dose
without any perception of that fact.
But the consistent use I this inaccurate terminology actually has a much more
serious consequence; we have no way of knowing whether it was done deliberately
but lacks scientificor not.
In any case, the text masquerades as scientificobjectivity.
By blurring the distinction between false or delusional belief andrealistic
belief through calling both kinds "perceptions," the author(s) of theseover from discussing rare, pathological kinds ofsections were able to slip
reactions--like delusions and phobias--into talking about normal and adaptive
responses to threat such as apprehension about the possible danger from radiation,in such a way as to imply that any concern for the consequences of radiologicalaccidents is psychopathological.
Likewise, any mistrust of the NRC or Met Ed
fearful"-(phobic means "irrationallyis called "phobic" without any justification
Wolman's Dictionary of Behavioral Science).
We want to emphasize the danger to the NRC of this kind of apparently self-serving
misuse of scientificconcepts.
It may be temnporarily reassuring to accept thepurely speculative notion of R. L. Dupont that allfears of radiation are phobic,
True, there
hence pathological phenomena for which you have no responsibility.
are always a few severely disturbed persons who have unrealistic, unjustified,even delusional fears about almost any social institution
or major event; doubtless there are psychotic patient* in California mental hospitals who are convincedthat Love Canal is poisoning them.
But it would be a great mistake to conclude
that therefore all
fear of toxic chemical wastes is a symptom of paranoid schizophrenia!
Not only would that be fallacious scientific reasoning, it would bepoliticallysuicidal for the relevant regulatory commissions.
relies on
the staff
The NRC is in precisely the same kind of danger here, if"experts" who concoct such arguments as those presented in sections 3.1.7 andNot only is the job poorly done and immediexisting policies.
10.6.2 to justify
ately seen through by anyone with independent scientific knowledge about psychological stress;
it also hinders you from accurately assessing the probable
psychological effects of contemplated policies.

A-21

In another way, we find the discussions in the cited sections to be remarkably
deficient.
Nowhere is there any mention of a central paradox of policy here:
the dilemma of secrecy.
Since radiation and the physical harm it does is imperceptible (and in fact imperfectly known as yet), people will not become upset (orotherwise "stressed5 unless they are more or less officiallyinformed about any
release of radionuclides, or unless they have other reasons to conclude that suchreleases may have taken place.
Therefore, anyone who stands to lose in any way if
people are distressed by such information is strongly motivated to conceal or
minimize it.
A utility
would naturally want to be quite certain that the danger
was imminent or actual before giving out any information to the media about apossible release of radionuclides.
On the other hand, the public has the rightto know, and the right to have enough background information to be able to appraise
and understand the dangers of a radiological emergency as well as to know what
protective action should be taken.
That implies a program of public education-since in fact the level of public information and understanding on these matters
is now unsatisfactory--which could be expected to raise the level of anxiety insome persons even without any abnormal incidents at nearby nuclear plants.
In this respect, we are reminded of the controversy that has arisen about the
problem of informed consent in medical research.
Some scientists
argue that giving
people enough information so that they can fully understand the possible dangers
to which they may be exposed (if,for example, a patient agrees to take an experimental drug for some disease) often upsets them and the apprehension that is caused
results in more social harm than the physical side effects themselves might cause.
Yet the alternative is unacceptable--putting people unwittingly into situations ofdanger for a presumed benefit which may be outweighed by the harm, and which not
allof them would willingly risk.
In a democracy, we must in general accept therisks of having an informed citizenry while trying to minimize them by using careand prudence in the way we carry out the task of public education.
In this light, the psychological aspects of the environmental impact of cleaning
up after the TMI accident will differ greatly, depending on what is done about theso-far neglected problem of informing people about the dangers of ionizing radiation.
The NRC must face up to the facts that many citizens in the affected area ofPennsylvania distrust
the Commission and will not accept at face value information
it distributes, and that this distrust is in considerable part justified.
Unfortunately, the tendentious reasoning of the parts of NUhREG-0683 we have studiedsuggests that at least the authors of this Statement have not properly heeded thelesson of TMT--the need to change of which the Kemeny Commission spoke.

Summary
The sections on psychological stress,
tive because of the following flaws:

while a good idea,

1.

The concept of psychologicalpresented.

2.

The draft misleadingly implies
damage.

stress isare actually counterproduc-

confusedly and misleadinglythat the recipient

can perceive

radiation

3.

It falsely treats all concern about radiation damage as morbid or
pathological, failing to note that realistic concern and apprehension
is the most rational reaction to a danger of uncertain scope.

4.

It shows a shocking lack of scientific objectivity.
All of its
distortions tend to justify NRC policy and to promote the dangerous
myth that all opposition is neurotic and may be disregarded.
Hence,
NRC does not get a true picture of expectable psychological stress,
and the public distrust will grow.

5.

1536 164h St., N.W.
Washington, D.C.
20036

Septembe)

17,

1980

President Jimmy Carter
The White House
Washington, D.C.
20500

The people's right to know the full facts about radiation dangers
outweighs the desirability of not revealing facts that might upset
them.

Dear Mr. President:

Sincerely yours,

We are writing on behalf of fifteen national organizations andthirty-one Mid-Atlantic groups which are distressed about your administration's handling of the damaged Three Mile Island Nuclear power station.

/9berge
Professor ofcPsychology

As you yourself have accepted the responsibility to protect the public health and safety of the citizens in the area affected by TMI, we be'eve that it is incumbent upon your office to take steps to end the exciusion of the public in deciding how the radioactive decontamination of
TMI-2 will proceed.

Adelbert Jenkins,/'
Associate Professor of Psychology

The Nuclear Regulatory Commission (NRC) has consistently and effectively precluded the public from adequate participation in the analysis,
and subsequent decision making process, concerning the cleanup of TMI-2.
Examples include:

Harold Sackeim
Assistant Professor of Psychology.

Lloyd Silverman
Ad unct Professor of Psychology

ames Uleman
Professor of Psychology

1.

The purchase and installation of the Epicor-IT system byMetropolitan Edison before the method was approved by NRC.

2.

Time constraints imposed in the decision making for thepurging of krypton-85, in spite of a majority of comments
opposing the purging alternative.

3.

NRC's failure to follow up on its promise to form a citizen
advisory committee with funding for independent scientificreview.

On August 14, 1980, the NRC released a staff report entitled, "Draft
Programmatic Environmental Impact Statement (PETS) related to decontamination and disposal of radioactive wastes resulting from March 28, 1979,
accident Three Mile Island Nuclear Station, Unit 2 (NUREG-0683)".
This is perhaps the most important health and environment-related
document the U.S. Government has issued about decontaminating the crippled
reactor.
It is essential that a sufficient period of time be permitted forboth the public and independent scientists to examine and analyze the cleanup
options dealing with ultimate disposal of contaminated water, decontamination

A-22

PA, in Baltimore, 21D, and in Washington, D.C., and should be recorded and incorporated into the NRC's final evaluation of the PEIS.

of the facility, removal and disposal of the damaged core, and storage, processing, and transportation of radioactive wastes.
The public comment periodon this extensive draft is limited to 45 days.
In oukview, the comment
period should be extended to a minimum of 90 days to •low the public andscientific community time to respond in a meaningful manner.

We further request that funds be appropriated to enable us to hire independent scientists to review the proposed cleanup metoods.
This "critical review and public assessment" will assist the NRC in evaluating the safety and.
feasibility of the THI-2 cleanup, and will provide for'public review o4. thislengthy and difficult process.

There are basic flaws in the PEIS which cannot be properly addresed
through the public comment process and must, instead, be resolved througn further studies by the NRC with subsequent public review hod comment.

Requests Outlined:

Some basic flaws in the PEIS which might require separate environmental
impact statements:

1.

I.

2.

Extension of the public comment period on the PEIS to a minimum-of 90 days.

3.

NRC (legislative) public hearings to be held on the radioactive decontamination of TMI-2.

4.

Funds allocated for independent scientists (selected by our citizens'to review the PETS on U-fI-2.

2.

3.

4.

The problem of bow and where to dispose of the wastes resulting from the
There is no asaccident and cleanup process is inadequately considered.
surance that any waste site will accept the low-level waste in the amountpostulated by the NRC staff and ultimate disposal of high-level waste remains an unresolved question.
The NRC staff dismisses the question of whether TMI-2 will be decommissioned or prepared for restart by stating that it is not ulthin the scopeof the PEIS.
In reality the methods of cleanup are very dependent on thedecision to restart or to decommission the unit. Certain processes could
severely damage the equipment, making the final disposition question essential in selecting the proper methods to be used.
Thus the question ofrestart or decommissioning of' the plant must be considered in depth within
the PEIS.

Reeting with you to discuss your role in protecting the public during thedecontamination of THI-2.

group)

We look forward to your response.
Respectfully,
Steven C. Sholly, Director
nil-Public Interest Resource Center
Harrisburg, PA

There is a total lack of cost estimates in this evaluation phase of the
PEIS.
The NRC staff has promised that the cost factors will be provided
in the final PEIS (after the period for public comment has passed).
Thelack of opportunity for public comment on economic aspects of the cleanup
provides an example of how the public is being excluded from the decision
making process.
In view of the precarious financial condition of Metropolitan Edison, the NRC's assertions that costs are not a limiting factor
can hardly be viewed as realistic.

john Rabler
Maryland Ad Hoc Committee on TMIBaltimore, XD

Richard P. Pollock, Director
Critical Mass Energy Project
Washington, D.C.

In the PEIS the NRC makes the assumption that cesium and strontium fromthe planned release 6f processed water (which will contaminate Chesapeake
Bay seafood as far south as the Potomac river) will not effect the marketability of the seafood.
A separate EIS that includes market research dataon radioactivity in Chesapeake Bay seafood must be performed prior to making
any determinations as to the effects of radioactive contamination of Bay
seafood on the seafood industry.

Betsy Tay'lor, Director
Nuclear Information & Resource Service
Washington, D.C.
Representatives of the following
endorsers (names iattached)

The Nuclear Regulatory Commission has stated that a public hearing is not
anticipated and not indicated in this matter.
We feel that this position isindefensible and that public hearings must be held on this in accord with theCouncil on Environmental Quality Regulations, which call for such hearings when
there is "substantial environmental controversy concerning the proposed action
40 GFR 5 1506.6(c)(1).
or substantial interest in holding the hearing.
We ask that your Office of Consumer Affairs convey to the IRC the fact that
it is in the public interest to extend the public comment period and hold public
hearings in this matter.
The hearings should be held in Harrisburg or Middletown,

A-23

cc:

THI Program Office,bcc:

U.S. NRC Commissioners
U.S. Environmental Protection Agency
U.S. Department of Energy
Governor Dick-Thornburg of Pennsylvana
Governor Barry Hughes of Miaryland
Pennsylvania State Department of Environmental Resources
Maryland State Department of Natural Resources

U.S. Nuclear Regulatory Commission

IPresident Carter

September 17,

1980

FEDERAL ENERGY REGULATORY COMMISSIONWASHINGTON

20426

Endorsers or the preceding letter:

IN REPLY REFER TO:

Three Mile Island-Public Interest Resource Center, Harrisburg, PA
Three Mile Island - Legal Fund, Harrisburg, PA
Three Mile Island Alert, Harrisburg, PA
People Against Nuclear Energy, Middletown, PA-v;onmental Coalition on Nuclear Power, State College, PA
Arti-ýuclear Group Representing York, York, PA
Newberry Township TMI Steering Committee, Newberry Town, PA
Susquehanna Valley Alliance, Lancaster, PA

September 25,

Mr. Bernard a. Snyde2
Program Director, Three Mile
Island Program Office
Office of Nuclear Reactor RegulationU. S. Nuclear Regulatory Commission
Washington, D. C.
20555

Indian Point New York Public Interest Resource Group, New York, New YorkGreater New York Council on Energy, New York
General Assembly to Stop the Power Lines, Minneapolis, Minnesota
Citizens Hearings for Radiation Victims, Washington, DC

Dear Mr.

Snyder:I am replying to your request of August 14, 1980 to theFederal Energy Regulatory Commission for comments on the Draft
Environmental Impact Statement Related to the Decontamination
and Disposal of Radioactive Wastes Resulting from the 3/28/79
Accident -- Three Mile Island Nuclear Station, Unit 2 -- NRC.
comThis Draft EIS has been reviewed by appropriate FERC staff
ponents upon whose evaluation this response is based.

Chesapeake Bay Foundation, Annapolis, MD
Karylabd Conservation Council, Maryland
Maryland Watermans Association, Annapolis, MD
Baltimore Chapter of Sierra Club, Baltimore, MD
Clean Water Action Project, Baltimore, MD
Coalition of Pennisula Organizations, Baltimore, MD
Upper Chesapeake Watershed Association, Cecil County, MD
Chesapeake Energy Alliance, Baltimore, M
Bay Alliance for Safe Energy, Ann Arundal County,v M
Peachbottom Alliance, Hartford County, MD
Political Awareness Committee, Baltimore Friends School, Baltimore Maryland
Patuxent Alliance, Columbia, 2iD
Howard County Peace Action Community, Howard County, MD
Audubon Naturalist Society of the Central Atlantic States, Chevy Chase,
DC Public Interest Research Group, Washington, DC
Physicians for Social Responsibility, Washington, DC(chapteJ)
Potomac Alliance, Washington, DC
Washington, Area of Clergy and Laity Concerned, Washington, DC

1980

concentrates its review of other agencies' enThis staff
vironmental. impact statements basically on those areas of thepipeline industries forelectric
poweri natural gas, and oil
which the Commission has jurisdiction by law, or where staff
has special expertise in evaluating environmental impacts inIt does not appear that there
voled with the proposed -action.
would be any significant impacts in these areas of concern nor
shouldagency's responsibilities
serious conflicts with this

MD

this

actionbeundertaken.

Thank you for the opportunity to review this statement.
Sincerely,

Union of Concerned Scientists, Cambridge, MA
Natural Resources Defense Council, Washington, DC
Environmental Action Foundation, Washington, DC
Environmental Policy Center, Washington, DC
Friends of the Earth, Washington, DC
Citizens Energy Project, Washington, DC
Clean Water Action Project, Washington, DC
Institute for Ecological Policies, Washington, DC.
Institute for Local Self-Reliance, Washington, DC
Mobilization for Survival, Washington, DC
Karen Silkwood Fund, Washington, DC and Cnristic Institute, Washington,
Washington Peace Center, Washington, DC
Women Strike For Peace, Washington, DC
Environmentalists For Full Employment, Washington, DC

14. Heinemanný'dvisor on Environmental Quality

DC

A-24

DEPARTMENT OF THE ARMYBALTIMORE DISTRICT,

CORPS

OF

ENGINEERS

Yale University New Haven, Connectict"o Bo. I'll
BALTIMORE. MARYLAND 21203

065.19SCHOOL OF MEDICINEOFREPLITOATEPTION
25

25 September 1980

NABPL-E

Park Stret

Department of Psychiatry
September 20, 1980
Mr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
United States Nuclear Regulatory
Commission
Washington, D.C.
20555

Dear Mr.

Gentlemen:
I am writing in response to your Draft Progrsommatic Environmental Impact
Statement of July 1980, on the accident at Three Mile Island Nuclear Station
unit two. I am concerned here only with the sections on Psychological Stressand Psychological Effects.

Snyder:

While those two sections contain much that is accurate, they distort thequestion of the psychological impact of traumatic events in several ways.

This letteris in response to your Draft Environmental Impact Statement, Docket
No. 50-320, which was received in our office on 16 September 1980.
Comments
are directed toward the five alternatives, which are presently under consideration, for the decontamination and disposal of radio-active wastes.

The overall emphasis on anxiety in relationship to stress, and especiallyon the irrational qualities of anxiety, leaves out the very important questionof reasonable fear. In extensive work that I and others have done on disastersof various kinds, we have found that a certain amount of fear and tension isrelatively optimal for taking constructive action in the direction of saving
lives and helping people. Too much fear, or extreme anxiety, can of course beinmobilizing. But the inability to experience or recognize danger-the apparent
absence of fear-can be equally dangerous, and can take the form of extreme
numbing and denial, and lead to highly ineffectual behavior.

This agency's areas of concern are flood control hazard potentials, permit
requirements under Section 404 of the Clean Water Act, and other direct andindirect impacts on Corps of Engineers existing and/or proposed projects.
In
accordance with these responsibilities, our office has the following comments:a.
The Baltimore District, Corps of Engineers, maintains responsibility
for certain water resource projects in the Susquehanna River '--in. Presently,
we do not have any projects, studies, or propqsed studies in the immediate
Three Mile Island area or downstream from the plant.
The nearest study wehave underway is for local flood protection for Harrisburg.
As this is locatedapproximately 10 miles upstream from the Three Mile Island plant, no impacts
upon the local flood protection project are anticipated.

In a similar way your repeated use of the term "phobia," as in such phrases
as "nuclear phobia" and "phobic concerns," leads to a related distortion. Deep
concern about continuing danger, or about actions that may lead to renewed danger,
is associated with an irrational symptom, a "phobia." One must question this kindof association in relationship to any traumatic situation, but especially so in
relationship to nuclear accidents or threats.

b.
Another responsibility of the Baltimore District is to review the needfor permits for construction projects which might affect both wetlands andnavigable waters.
The construction that is being proposed for the plant will
not require any permits from this office.
It has also been determined that
proposed construction will be located above the determined flood plain levels.

Where there is a question of lingering radiation effects, there is inevitably
response of continuing fear. This has been true not only in Hiroshimn, but alsowith American servicemen exposed to nuclear weapons tests, miners exposed touranium, and ordinary people exposed to past weapons testing in Nevada and Utah.
Since scientific authorities on the effects of radiation themselves disagree-andin fact there is no way of determining exact effects-we cannot label continuing
fear of these effects as "irrational" or "phobic." They are in considerable degree
reasonable reactions to an abnormal situation.

The Baltimore District appreciates the opportunity to comment on your Draft
Environmental Statement and if we can be of further assistance, please do nothesitate to contact us.
Sincerely yours,

Chief,

Finally, I would emphasize-and your report is deficient in not acknowledging
this-that these reactions need not take the form of a clear-cut medical or evenpsychological "disease." Rather, they can express themselves in various combinations

Planning Division

A-25

Page 2September 20, 1980

QUESTIONS
Relatingof fear-related symptoms, impaired overall function, and difficulties in human.
In order to make a reasonable assessment of such a tratumtic
relationships.
situation, then, one needs to explore the full history of the trauma, and thesubtle forms of disturbance that may result from it.
.I hope you find these remarks of use in your deliberations on this very
important question.
Yours sincerely,

ON THE DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT (P}to decontamination and disposal of radioactive wastes atThree Mile Island,

Unit 2.

We have the right protected by the constitution
mentally and physically unimpaired.

to be born and to live

Neither the NRC nor any other governmenta

body has the authority to cause persons of the United States to develop fatal
cancers as a result of the deliberateenvironment which could otherwise

distribution of radiation into the

be avoided and which is

not related to

the needs of national security.
Robert Jay Lifton, M.D.
Foundations' Fund Research
Professor of Psychiatry

1. The Council on Environmental Quality
the national Environmental

Policy Act(CEQ)

regulations to implement(section

1506.6) and CEQ guidelines

on Preparationof an EIS (Sectionisenvironmental controversy concerning the proposed action

substantial(draft PEIS)First,or substantial

please1500.7) callinterest in

define hearings?

Isfor hearings when there

holding the hearings.

this what we might call a meeting ?

When are the public hearings scheduled?

2.

The draft PEIS proposes separate environmental

that we have yet to encounterto take into accountthe cummulative
Shouldn"tinthe effects

impact of the

on

fails

the clean-up andclean-up steps to the

Impact Statemr.ent

to bring aboutstatements on issues

This segmentation

the other steps inthe individual

an Environmental

compatable processes

the clean-up.

environment.

develop a program ofthoe F'fe ani

expedient

clean

up of

TMI 2.?

3.

How can this be consideredanAppendix B,

Commissions State.ýe:.

to-expect

the pr..!ra-::.itl

that

:..

ro:.'nta2

re.1au,

"t

is

.;,.

.

S.

:

:",.

cver

.

-

detailing each and every :--ep to
with

t.eir

sill

have gap:: and w.il

A-26

likel.

_p :tn.
no.

7he

Imp-:* Statement whencf ic.::.y,;ro7r1r..-.U;izr.

be a czr;let-

*

Ae."

unrealistica blue~rint,
mont:.:n and years:.tatem•.t

Inevitatly

4.

The PEIS,

if

it

to operate inis

National Environmental Policy Act,

9. Is it true that the use of Epicor If, a system for the clean-up ofradioactive contaminated waste water, has not eliminated any radionuclides

accordance with the purpose of thewill engage the public in

the Commissions

decision making process.
How will -he public participate inthis decision making ?

The Susquehanna River supplies domestic water to Columbia Borough, City of
Lancaster, Safe Harbor Village, Holtwood Village, city of Chester, City ofBaltimore, Conowingo Village, Bainbridge Naval Training Station including
5.

Port Deposit,

Perry Point Veterans Hospital and Havre
Please explain ?

very limited.

The draft PEIS proposes to discharge tritium containing water and venting
Krypton gas because of the renewable nature of the Susquehanna River andthe regenerative powers and vast disperive capacity of the atmosphere6.

(SectionIs

11.
Why does Met Ed continue to spend significant amounts of money andtime constructing the Submerged Demineralizer System (SDS) when the EIS
is stillin a draft form? There is no reassurance this system will beapproved as best to protect the environment and health and safety of the
public.
Will this expenditure prejudice the NRC's decisirin as to whichalternative for clean up of highly radioactive water will be best ?

10-27).

this a violation

radioactive wastes

prohibiting dischargeof the Clean Water Act,

into navigable waters and a violation

Environmental Policy Act (Section

1508.7)of

12. The public ha..boon assured that radiation doses received during clean up
operation is equivalent to or below that of a normal operating reactor.
Does this include the kryp: :,n venting and the dumping of 400,000 gallons
of radioactive water.?

of the National

concerning impact on theenvironment which results from the incremental impact of the action whenand resonable foreseeable future actions ?

added to other past,.present

The Clean Water Act prohibits discharge of radioactive wastes into
navigable waters causing further dilution and dispersal of radioactivity
Would any proposed dilution of radioactive processed
into the environment.
7.

waste

10. Section 5-36 states that Epicor IIspent resin filters will be immobilizedwith cement and packaged in 55 gallon drums.
What is the condition of thefilters today? Whatdoes your own report from Brookhaven say about cesium andthe ability of cement to immobilize it?

use as a community water supply

3-19 of draft PEIS states the Susquehanna's
isSectionde Grace.

from the nuclear plant site thus far?
Is it true that we have tritiatedwater to store and extremely radioactive resin filters that cannot be
trucked off the island?

(accident

the Susquehanna,or clean-up)

conforming to NRC standards,

violate the intent

13. Section 10-11 draft PETS, charts health effects and offsite doses fromnormal plant operations.
How can this chart be used with an accident
situation

like we have at TMI

2?

discharged intoof the Clean Water Act?
14.

Does the NRC feel that a digging clamshell, used to gouge Out andof the core is a viable alternative for reactor core removal ?

shear segments

Fuel rods are brittle

dumping of processed accident qnd clean up
the effect of tritium and other radioactive

Throughout the draft PEIS,
water isdiscussed.

What ismaterials on the plants,of the sea,

fish, benthic(plants and animals at the bottom

river) orgamisms and other wild life

stream portions of the Susquehanna River,allwhich inhabit

the downof which may enter thedue to accident heat levels,

making krypton gas

releases eminent with the destruction of the protective cladding,casing.

food chadirectly or indirectly ?

A-27

the metal

15.
Why are clean up procedures not postponed until the adoption of the
final EIS? Section 1506.1 of the National Environmental Policy Act states
until

an agency issues a record of decision,no action concerning

20.

Is

an EvacuatiomPlan a requirement

for a nuclear power plant?

the proposal

for o'taining an operating license

Do we have a working Evacuation PlaI?

shall be taken which would limit the choice of reasonable alternatives.
We've had the krypton gas venting,operation of Epicor II,

now the constructionof the SDS.

21.

Does the normal

operating license of a nuclear power plant include theuse of a deoontamination system,

currently in

use at TNI 2?

Was Metropolitan Eiison's license ammended?
16.

What storage facilities

handle spent fuel?

Will they handle thedamaged reactor core and other highly radioactive wastes,
filters,

or proposed SDS

filters

such as Epicor II?
22.

Commercial nuclear

considerations
17.

What isto happen with reactor spent fuel?

discusses reprocessing of spent fuel,on reprocessing?
is

Section 3-32,

what isdraft PEIS,

The draft PEIS,

Sectioni.!-l,the current national policy
states processing of spent fuel1-11-1-17 dPEIS)
isbirth defects,

and shortened life

span?

The

cataracts,skin lesions,

results of genetic damage isof parents

Valley Alliance

Lancaster,

PA

17604

717-394-2782--Tues-Wed-Thur--1OAM-1230

Has ionizing radiation been known

as cancer (including lukemia),

genetic mutations,the children

This should be covered under safe plant operation,

Box 1012

ionizing radiation the greatest threat to plant wovaks and area

residents during the clean up of TMI 2?

defects in(Section 1-17,DPEIS)

sterility,

loss of hairto cause birth

exposed to ionizing radiation.

A-28

why

a large sckle decontamination system not considered under commercial

Developed by the Susquehanna

reactor releases or radiation and releases from the entire fuel cycle.
How
does the Draft PEIS take into consideration the cummulative impact?
National Environmental Policy Act Section 1508.7 defines cumulative impact as
the impact of the environment which results from the incremental impact of
the action when added to other past, present and reasonable foreseeable
future actions individually minor but collectively significant action
taking place over a period of time.

to cause such human illnesses,

operations

nuclear power plant licensing requirements?

not a viable alternative.

Isdecontamination

Decontamination of various types has been necessary since the 1940s(Section

18.
Section 3-15 draft PEIS, Natural Radiation, should be interpreted tomean normal background including the effects of fallout from past nuclear
weapons detonations, past accidental releases of radiation, normal operational

19.

power plants are not designed with special

for large sclae

PM

n

a

Dr. Bernard J. Snyder
Page 2October 1, 1980

COMMON WE0 LT of V1TRQN IMA
903

r n

StREE TaFCE 8(J*L0,:i1
S73(5RICsMOO3,73215

B04 78M4,:)

October 1, 1980

low-level wares goes through Virginia to South Carolina (pages
north and west to Hanford, Washington as is now contemplated.
Thank you for the opportunity

3-28,

3-32)

to review this document.
Sincerely,

Dr. Bernard J. Snyder
Program Director, Three Mile
Island Program Office
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission
Washington, D. C. 20555
Dear Dr.

JBJr:CHE:pw
CC:

Snyder:

The Commonwealth of Virginia has completed its
review of the Draft Environmental
Impact Statement (Programmatic) related to decontamination and disposal of radioactive
wastes resulting from the Three Mile Island accident on March 28, 1979.
The Council
on the Environment is responsible for coordinating the state's
review of environmental
impact statements and responding to appropriate federal officials on behalf of theCommonwealth.
The following agencies took part in the review of this document:
Department of HealthMarine Resources Commission
State Air Pollution Control Board
State Office of Emergency and Energy Services
State Water Control Board
Virginia Institute of Marine Science.

The Commonwealth anticipates that the decontamination and disposal activities for
Three Mile Island will have no adverse effects upon Virginia's resources, provided thespecifications in the Programmatic Draft Environmental Impact Statement are followed
and the processed water is not disposed of by release into the Susquehanna River.
The release of procdssed water into the Susquehanna River would, if pursued, posesome questions that merit further discussion.
The Virginia Institute of Marine Sciencehas addressed some of the questions in the attached comments; the Commonwealth will want
additional review of the matter if this alternative is chosen.
Similarly, the Commonwealth reserves the right of further comment if the preferred transportation route for

-

A-29

The
Dr.
Mr.
Mr.

Honorable Maurice B. Rowe, Secretary of Commerce and Resources
Paul L. Zubkoff., Virginia Institute of Marine Resources
Raymond E. Bowles, State Water Control Board
A. C. McNeer, Department of Healthinstead of

8.

REVIEW ]NSTRUCTIONS:
A)

Ilease rev.iew the document carefully.
reviewed earlier(e.g., if the current
please consfider previoup coironents.

h)Prepare your agcncy's cosilents in a form which would be acceptable
for responding directly to a project sponsoring agency.

C)

Use the space below for your coUmments.
needed, please attach exfra sheets.

COMMONWEALTH of VIRGLNIASTI1 TE UI 77-Z. COAT1,'OL O1-0
RI)
2111IHlamiton Street

R. V. Davis
Executive Secretary
Post Office Box11143
lichmond, Virginia 23230(804) 257-O0%B

BOARD MEMBERS
R. Altun Wright
Chairman

~W

5 •."
.'--'
. :i:'•';-..
September 24,

1980
rVice-hairman
LJohn H. Ar64I. Jr.
Col. J.1cc Scurasca
Warren L. Braun÷• George M. Cornell
Millard B. Rice. Jr.

Return your consgentsIf
the proposal has been
document is atINAL EIS),

If

additional

space

is

to:

Charles 11. Ellis.
Il
Environiental Impact Statement Coordinator
Council on the Frnviruneeat
903 Ninth Street Office Building
Richmond, Virginia
23219

Mr. Charles H. Ellis, III
Environmental Impact Statement Coordinator
Governor's Council on the Environment
903 Ninth Street Office Building
Richmond, Virginia 23219
Dear Charlie:RE:

DEIS-Three-Mile Island Nuclear Waste Decontamination and Disposal.EN VIROrENTAIft

We have no comment regarding the above-referenced document; however,
we reserve the right to comment later should discharge to the Susquehana
River become the chosen alternative for disposal of "processed water."

CHA/RUS K,
1 E LLIS lIII
LNPA\T STATEMENTr COORDINATORCOMMENT S

Thank you for the opportunity to review this document.
Very tru

A careful review of NUREG-0683 leads us to believe that there should be
no problem for Virginia from the TMI decontamination and disposal activities
as stated in the EIS providing the specifications found in the document areused. Therefore, we find no basis for objection to the project proceeding as
expeditiously and prudently as possible.

yours,

wes, P.E.
Raymon dE
Director
Bureau of Surveillanceand Field Studies
:scc

cc:

EIS File
TITLE):AC~c)

AGENCY)A-30

N ~ fli
/L

r ZI

7a

*

/.,
___________' .'.•_•_______.,(f

a0 1 m........
S.

7

CHARTER ED 2693

COLLEGE OF WILLIAM AND MARYDraft
VIRGINIA INSTITUTE OF MARINE SCIENCESCHOOL OF MARINE SCIENCE

Programmadtic Environmental Impact Statement related
decontamination and disposal of radioactive wastes
resulting from March 28, 1979, accident

Department of Environmental Physiology
Gloucester point. Vaglaln 23062

September 30,

1980

Three Mile Island Nuclear
Docket No. 50-530

Phone (804) 61i-2111

The following comment istreatment of processed water

Ellis:

Enclosed are the comments of the Virginia InstituteofMarine Science on the Draft Programmatic EIS related to clean-upof TMI-2 (NUREG-0683).
Since speaking to you on the telephone,
we have reinterpreted Figure 3.1-5 to indicate that the intakes to
TMI-1 and TMI-2 are on the Center Channel and the combined 2 unit
discharge is into the Center Channel.
The comments of the enclosed
text take this reconsideration into account.

call

If
I may be of further assistance,
upon me.

Station, Unit 2
July 1980

Comments by Paul L. Zubkoff, Ph.D.
Virginia Instituteof Marine Science
Gloucester Point, Virginia
23062
804/642-2111
X133

Mr. Charles H. Ellis, III
Environmental Impact Statement Coordinator
Council on the Environment
903 Ninth Street Office Building
Richmond, Virginia
23219
Dear Mr.

toaddressed(pagesto the discussion of

5-6 and 5-7).

Processed water

which may potentially enter the Chesapeake Bay via discharge

into theSusquehenna by controlled or accidental means is6.3.5.4,

discussedin

Postulated Accidental Effects (6.26-6.30).
In

the discussion,2 scenarios Are identified

for thepotential of the sump containing 500,000 gallons of radionuclide

please feel free to(3H, 137Cs,

134C.,

90

Sr and8 9

Sr)contaminated water:

Sincerely,
1.

Controlled release of plant effluentsSusquehenna River at (30Paul L. Zubkoff, Ph.D.
Senior Marine Scientist

equivalent of release2.

PLZ: lithe above conditions,water

1800 gph)which issump eff]uent over a6

a 1070 fold immediate dilution of

gpm river flow rate.

Under either ofdilution of the radionuclide-contaminatedwill be effectively

the(Table 6.3-16)(Table 6.3-17)

E4ither scenario estimatesthe 500,000 gallon with 4.5x10-

for 277.78 hours

Accidental release of entire
two-hour period

Enclosure

gpa

into thedilutedupon further

flow-dowým

sump

the river.

The discussion also mentions adsorption by suspended
particles(especiallyinthe freshwaters for

137

Cs)

of trapping particles behind the dams (Safe Harbor
Conowingo Dam),

A-31

the escape of particles

inand the possibility
Dam,

Holton Dam andthe freshwater

flow,

the

entry into the Chesapeake Bay,and the subsequent entry into the foodchain (water-food chain-fish or water-food chain-shellfish).

and passage over York Haven,The

be trapped behind Conowingo Dam?

introduced and the following reasonable concentrations factors between

3.

fish or shellfish are used:

The assumption of dilution and flow are based upon the 500,000 gpm
value.

However,the flow through the Susquehenna and the Centerand West Channels is
1 34

90

Sr,

89

Sr

Cs

3000:1probably variable.

The conditions to beaddressed are the minimum flow conditions and normal flow conditions

500:1

through Center Channel.

Under the above conditions, the effects of either controlled

The conditions utilized are not explicitly

indicated for this critical first-phase dilution.

release or accidental release are of the same order of magnitude(Table 6.3.18).

and Holtwood Dams andwhat proportion of released radionuclides would be expected toassumptions of 1% equilibrium of the water-food chain-shellfish are

137Cs,

Safe Harbor,

4.

The effect to biota in the lower Susquehenna under

As has been shown elsewhere (Eaton et al., 1980),

particles

originating in the Susquehenna River basin reach as far into thesuch levels ultimately reached is minimal from technical considerations.

Chesapeake as 100 Km below the Conowingo Dam.

The above conditions also provide further estimates of

The time of transport

is unknown,

although the distribution of particles is seasonallyof(stream-flow) dependent. The duration/radionuclides in the waterradionuclide concentrations in fish of the Chesapeake Bay (Table 6.3-20).
The effects associated with fishes of the Chesapeake Bay are approximately

column is

0.1% of those associated with fishes of the Susquehenna (Table 6.3-18),

particles and released under other conditions estimated,

and are also negligible.
5.

With reference to Figures 3.1-5 and 3.1-6,
flow (10,000 cfsz4.5xl0

nor the amount adsorbed tonor thecycling of radionuclide adsorption and resuspension addressed.

Comments
1.

not clearly estimated,6

sump needs further clarification.

the assumption of rivergpm) has been stated.

to minimum flow of 10,000 cfs at Harrisburg,Pa.

the sump also contains

the assumptions of radionuclide - mineral absorption and ion-exchange

relate to the flow of the Susquehenna through the Center Channel
Figure 3.1-7 refers

Ifdetergents, oils, greases and chelators used in clean-tip operations,

Does this figure

or West Channel or over the York Haven Dam.

The question of radionuclides and other contaminants in the TMI-2

may easily break-down because of interferring suhstances .(Appendix
G, this report).

The radionuclides and their matrix should bebetter identified in order to effectively test the models proposed.2. The mention of particle absorption of radionuclides and theconcerning radionuclide release to and recycling within thesubsequent trapping of particles behind dams has been discussed.

environment.

What proportion of the release of radionuclides would be
expected to be absorbed to particles during the time of release

Eaton, A.,from the Three Mile Island-2 discharge canal into the Center Channel

V. Gross, M. G. Gross.

10:75-83.

A-32

1980.

Estuar.

Coast Marine Sci.

6.

With

respect to the conclusions listedchanges are inon pages

6-30,

the following

order because the questions of time scale and

341 N. West End Ave.
Lancaster ra 176o3
Sept. ý9, 1980

recycling are not resolved:
1.

Susquehenna Riverand Upper

Chesapeake Bay sediments would

remain contaminated with low, but measureable,

U.S. Nuclear Regulatory Commission

levels of

137Cs after either controlled or accidental discharges.

Thismight be a source of continuing public concern since radioactivity might be detectable in the sediments for decades
after the releases are completed;however,small hazzards to man or other organisms.

it

Enclosed please find my personai comments to you on NL-R32 0683.
While availing myself of the ri -ht to comment, I wish to protest
to the Commission the ineffectiveness of tnis type of procedure.

would pose very

[There are presently

I have been present at hearings, have written letters, have read
documents and so on since the Three jile island accident occurred.
Other than giving those who are concerned a chance to ineffectively"blow off steam" these procedures have no relevance to your decision
making process. Our comments are not of any visible importance.
The questions we raise are never answered, and they are left
hanging in some never-never land.

137Cs residuals in the sediments of the lower Susquehenna
either from fallout in the 1950's, associated with Peach
Bottom discharges, or some other unknotm source].
2.

Low but detectable levels of137

Cs from TMI-2 might persist

This is understandable in the sense that you are more expert
in the field than the general ipublic. It is not understandable whenyour actions limit my constitutional rights , ,ohen your decision
makes my life less im;ortant than another citizen's.

in some fish of the upper bay dependent upon the form ofradionuclides and other substances such as chelators present
in the releases of processed water.

[The time is

not indicatedI do not think th~t any of you intended this accident tobe a lesson in civil disobedience. You did not intend that publiccomment oroved to those who commented that their views were to beignored. You did not intend to convince the public th-t regulatory
agencies m.ike deiisions bosed on the interests of those pressuregroups with whom they work. You did not intend to be a violator of t
public good.

in the calculations and remains in doubt until the questionof cycling of radionuclides is3.

addressed.]

At the postulated radionuclide concentrations,radiation effects

on fish, shellfish and other biota in the Susquehetnna RiverI heard the Chairin of NRC tell a house Committee last May
you do not know what to do with the demand of the public to be invol
ved. I agree, you do not Jnow how to handle it. What we:arelearning is to distrust our government, to move away instead of reforming the jrocess, and to realize that we can not afford tohave our day in court or in an administrative he-ring.

and Chesapeake Bay would be minimal and have no impact on aquaticp o p u l a t i o n s o r o n ma n .

a j .14/_,yNo country based on the rule of iaw and the consent of the go-verned can long abide with such a situation.
Sincerely yours/

Walden 6 Randall

A-33

2.
341 North West End Ave.
Lancaster Pa.i7603
Sent. 30, 1980

On p. 2-17 Sec 2.2.3. the special nature of the wastes is noted
and we who live near it are told:" special measures may have to be taken"

U.S. Nuclear Regulatory Commission
Office of buclearheactor Regulation
Washington, D.C. 20555

what measures? when? under what guidelines? to where? who pays forit?

Subject: Draft EIS on ThI July 1980 NUREG 0683
Docket No. 50-320
Public Comment

o.2-14 Sec 2.2.2.:.,it was never anticipated that such wastes would be created.
Accordingly, the wastes resulting from TkI-2.cieanup will haveto be reviewed on a case-bv-case basis..."

Gentlemen:
The following are comments on the draft EiS on TMI.
Overall,the long complex document is very disappointing. On
most of the issues which directly affect those of us who live
near the accident site, determinations are put off, incomplete,cannot be presently solved in a satisfactory manner or are unknown. The conclusion after reading it must be that the NRC intends
to treat the cleanup as only slightly more 'involved than previous
accidents, to utilize past methods of decontamination although thescale is vastly larger and longer and to ignore their own conclusion that the island is completely inappropriate as a waste site,even a temporary one. There is no attached estimate of costs
which ignores the crucial point: is this method of electrical generation for commercial purposes rational? The potential healtheffects are segmented into unrelated pieces, so as to minimize
their effects when truly estimated over an area's total impact.
Lastly, a refusal to deal with the re-opening of Unit One as related, and the Question of the goal: decomissioning or restart,
makes the document pointless and appear to be one long exercise
in regulatory obstruction.

and how will we who live under their threat respond? do we review
each case? how will we know whet is going on? if the decisions
are beinR influenced by cost considerations, how can th-t be stooped

If the MiC feels that this type of proposal is a full environmental
impact statement of how to clean up Three ýJle Islad, I am appallec,ihet we are being asked to accent is a blind faith judgement that
someday in the future, someone will decide on a case by case basis
what tc do with the waste. Trust them.
2. While we are waiting for this decision and the money to financeit and a location to which to take it, the resins, to jick one issu(
as an example, will be stored on the island, in the current desilting basin region. p. 10-19,20, Sec. 10.5
The document then discusses a PkýF or prob ble maximum flood, determined in some unspecified way but assumedly from-the Agnes storm of1972. A description of the casing of tne containers, lids etc. ensu
with estimates of how de*>p t;e water will be and for how long.
It is confidently concluded that leakage is not possible in anv
major way because:

Specifics:
1. Although continually the aocument states that ths site iK not
approcriate for a waste site, it will continue to be one foran unknown amount of time.
Examole: p. 3-32 Sec 3.2.3. , p. 2-2 Sec 2.0 among others
too numerous to quote.
The N'J h.s continued to operate these plants without a solution.
to the waste isbue. According to this document it will now oneratea terporary waste facility in violation of its own regulations.
This site contains, and will contain in ever-increasing amo,'nts,s the resins accumulate from EPIC0i 1, II and the SDS systems
unique medium level and high level waste which cannot be acceptedby any dump now operable.

A-34,the PO' would top the station dike for only four days...'D.i0-2o Sec. 10.5.3.
and... There is no driving force for release of radionuclides
except diffusion in water, ana that would begin only when acontinuous water path were available..."D. 10-20 Sec. 10.5.3.

3.
4.
For the NRC to base its storage planning on a tlieore~tical projection that any flood in the Susquahanna River will only cover
the resins for four days is incomprehensible. To then state that th
only way leakage will oc.ur is if they are wrong, and a bigger floo:
happens and provides the "continuous water path" boggles the mind.
If NRC has assurances from the forces which determine weather cycle:that no bigger flood will occur betwecn now and when the wastes are
stored in a "permanent ueep geologiu repository", they should sodocument. All available data from other sources such as the
Lational flood Insurance 9rogram is exactly contrary. The Susquahanna River is projected to be subject- to greater and increasing
flooding problems in the future, cue to incroses in impermeablesurfaces such as parking area construction du'e to greater develonmental density in the region. Lancaster County has numerous watershL
studies underway now to diminish the floodinp problems alreadyrelated to growth. :f it i nct 'rur thct the riverfinr
blemF ara
Ir n the iza:rc:se, then why did the iPennsylvania otate aegi1
lature pass last session -ct 282 specifically demanding each countv
develop storm water management regulations to deal with the is3ueý
Are they to be designated as "phobic", or unduly concerned with the"what ifs" instead of the realities of a situation, as the document
refers to those who continue to show signs of stress related tocleanup?
To store wastes of this nature at this site at all involves jeopardizing the safety of the largest fresh water estuary on the Easternseaboard. It is unconscionable, and should be rejected by theCommission outright. Unfortunately, due to previous grievous errors
in judgement by the same Commission, they are between the devil anda hard place. They have developed this inoustry without planning foi
the waste. They have no where to rut it. This LId now documents thilfor all time if tn-t were really nedea.
3. Cumulative health efiects. Because of two factorsthere is noeasily comprehensible way to aeal with this data as presented in th,
EIS. A.l the numbers are projections, not measurements, and these
are currently under challenge by the Heidelberg Report and otherstudies, as well as serious questions about the "safety" of thecurrent standards. Funding for research is so Door that healthdata on the effects of tritium, for one, do not exist. Constantdemands for more research on low level radiation by such people as
Dr. Arthur C. Upton of National Cancer Institute have fallen ona deaf Congress, pressured by the nuclear lobby to proceed withthe business of profit'ble operazion. In the EIS the definitionof "natural background" clearly reveals the sha6by state of

A-35

affairs.

"'fatural £ackground' s;,ould be intr-rEte'a to me-n normal
Background, inclucing the effects of fallout from past nucl
weapons cetonations and the nuclear fuel cycle.."p.

3-15 Sec.

3.1.4.3.

To begin one's measurements of health effects in an already "dirty"
svstem by stating that "dirty" is clean stretches the mind's Credulity. hould it not be more valid to assume the approach that
BECAUS- irreversible damage hau already been done, MORE careand smaller ibrements are needed to be deposited into :he environment? The ELflooks at each provooed increase in environmental load
senara~telv, one at atime: spea-s of its compliance with thestandard as if there was no contami4ted bottom line but a bald sla''
Ignored are other sources of pollution, other radiation producers
such as hospitals, other plants -nd facilities on the same river.
The fact is statec that the river is already out of compliance withsafety standards in iron and sulfur content frequently: how does
C134& C137 bind to these constituents? Why does the NRC believe it
ooerates in a vacuum: that the same individual down river whose sysi
is already insulted by a variety of other burdens can without effectabsorb more? Based on what thirty year data are such estimates beiw'
made? Vihere are these "funny numbers" coming from.? Some disinteresti
qualified academic center with independent funding or Argonne
Laboratories?
The fragile agreement reached by the City of ,ancaster with iK
is shredded by an infinity of "if anproved" phrases concerning theeventual aisposal of the partially filtered water into the river.
We will rapidly be drinking huge amounts of Tritium, and otherisotopes or pay for our own replacement sources. Chesapeake Bay
will be the cesspool of the cleanup by regulation.
This EIS is a depressing illegal pa.rody of the intention of thelaw which required its development. It is to be hoped it will besummarily rejected by the NRC, and those who developed it removed f:
the staff. If it is accepted, let the Commission members knowthat the families of those who live nemr this plant will someday cathem to account for their actions.
Sincerely yours

7/
Walden S. Randall

Of& f Nem 3truM
DEPARTMENT OF ENVIRONMENTAL PROTECTIONJOHN FITCH PLAZA. P. 0. BOX 1390, TRENTON. N. J. 0825
October 9,

Oct. 10,1980

1980

Samuel J. Chilik, Secty. *of the Comrunission
Docketing and Service Branch
Nuclear Regulatory Commisijon
Washington, D. C. 20555

Dr. Bernard J. Snyder
Program Director, Three Mile Island
Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
20555
Washington, DC
Re:

RE: Comments on: Draft-Prograrnnatic
Environmental Impact Statement related
to decnntarn-Aation and disposal ofradioactive wastes resulting from March
28,1979 accident Three Mile Island Nuclear
Station Unit 2. NHJREG 0683 Aug.14180

Dear Sirs:
It seems futire for the NRC staff to attempt to give costs or human exposure to

Draft Programmatic EIS Related to Decontamination and
Disposal of Radioactive Wastes Resulting from March 28,
1979, Accident
Three Mile Island Nuclear Station, Unit 2

radioactive materials to be cleaned up at Three Mile Island Nuclear Station
Unit 2, when there is no designated repository for those materials.

Dear Mr.

Since theSnyder:Federal Government has NO permanent disposal site, you do not know how long

The above noted Draft Programmatic Environmental Impact Statement
has been reviewed by the Department of Environmental Protection's
Bureau of Radiation Protection. As a result of this review, theHowever, we do wish
Department does not have any specific comments.
to express our appreciation to the Nuclear Regulatory Commission forthe opportunity to/review this document.

the materials must be kept in temporary storage, what the transportation costsin the future wfl1 be, or how long the exposure to workers/public from temporarystorage will be, and so cannot have either a figure on either the human healthSincecosts or the monetary costs.

edt, Chief
La Iree Sc
Office of Environmental Review

With permanent inflation in the U.S.,

the future

costs must also include this inflationary factor per year added into cost ofclean-up and temporary storage, until a final repository and/or disposal of thematerials is found.
A. E. Wasserbach
BaK 2308 W. Saug. Rd.
Saugerties, N.Y.12477

New Jersey Is An Equal Opportunity Employ'r

A-36

Linra LoW

U. S. DEPARTMENT OP TRANSPORTATION
2.

FEDERAL HIGHWAY ADMINISTRATION*

PleaseWe appreciate the opportunity to review this Draft.
advise if we can provide additional informationorithe
are any questions concerning our comments.

REGIONTHREE

31 Hopkins Plaza
Baltimore, Maryland

Sincerely,
October 9, 1980
IN

EPL

P0

S

George R. Turner, Jr.

O

Deputy Regional Federal Highway
Admini strator

Mr. Bernard J. Snyder, Program Director
Three Mile island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear Mr. Snyder:Because of time constraints, our Headquarters has requested
that the FHWA Regional Office provide comments on. the Draft
Environmental Impact Statement related to decontaminationand disposal of radioactive wastes from Three Mile Island
Nuclear Station, Unit 2 (Docket Mo. 50-320) directly to youroffice.
Our review concentrated in particular on the transportation
aspects of the proposed action and our comments are as follows:1.

Page 9-17, it is indicated that three to six transport
accidents can occur for the range of shipments from T7412. It would appear this estimate is based on gross statistics for the trucking industry as a whole and does
not take into account difference between intrastate andinterstate operations which have different regulatory
requirements, nor does it recognize different levels ofdrivertraining forthe various classificationofhaulers.
.Sincethe transportation of radioactive
material is very heavily regulated compared to otherindustries, we believe the potential number of accidents
may be substantially overestimated.

2.

From our review of this document, we did not note any
discussion of regulatory requirements or proposed control
strategies to be employed in order to minimize the risks
associated with the transportation of the TMI wastematerial. A worse case scenario of radioactive material
release and contamination (pg. 9-18 and 9-19) without apresentation of proposed mitigation measures to limit
exposure does not provide a very objective analysis.
-more-

A-37

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RADIATIONPA.

OCTOBER 3,

19MO

PLEASENOTMILEI AM VERY CONCERNEDISLAND.

PROCEDURES
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A-39
I

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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICERESULTSBE.

FOOD AND DRUG ADMINISTRATIONROCKVILLE. MARYLAND

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I

Mr. Harold Denton
Office of Nuclear Reactor Regulations
U.S Nuclear Regulatory Commission
20556
Washington, D.C.

WILL
YOUR

Dear Mr.

CONSIDERATION.

Denton:The comments of the Bureau of Radiological Health on the Draft
Program•matic Environmental Impact Statement for the Three Mile Islandcleanup (NUREG-D683) apply only to potential radiological contamination
in food pathways.

SINCERELY,
SUSAN

20857

OCT 10 IqK

L ROUDESUSH

Obvioulsly, the primary food pathway would be through discharge of radioWe recommend that an
logical contaminants into the Susquehanna River.
appropriate river water and biota monitoring program be initiated tomeasure H-3, Sr-89, Sr-9O, Cs-134 and Cs-137 downriver and even into theThis should be coordinated by the EPA as part of their
Chesapeake Bay.
The
long-term State/Federal TMI environmental surveillance program.
surveillance should be carefully planned with routine sampling at predetermined sampling points principally downriver, but also a few miles
upriver, on a monthly or quarterly basis. In addition to providing
assurances to the public during periods when unplanned discharges areunlikely to occur, the monitoring effort would yield a reference background data base for use whenever a planned or unplanned discharge mightoccur.

Although accidental airborne releases (evaporation) of H-3 (as tritiatedwater) are quite unlikely to occur, efforts should be made (or continued)
to monitor off-site tritium in air levels.
We have some question about disposition of 'processed (cleaned up) water
In Chapter 5 of the document,from the Unit 2 containment building.
several alternatives for disposition of processed water from theauxiliary and fuel handling buildings are presented, such as long-term
storage in tanks on site, evaporation, chemical solidification, and(See Section 5.2.2.2, pages 5-12 and 5-13.)
discharge into the river.
However, when the fate of the processed water from the reactor is
discussed in Chapter 6, it appears the only proposed disposition is into
(See Section 6.3.4.1,
the center channel of the Susquehanna River.
If only for academic reasons, alternatives for disposition
page 6-19.)of this water, parallel to those cited in Chapter 5, should be discussed
in Chapter 6.
Sincerely yours,,

/

S

A-40

John C. Villýorth
Director
Bureau of Radiological

HealthE- lowI

NFE--

1 Woodthorne Ct. #5
CO,:ings Mills, Md. 21117
Oct.

14,

Comments on KUPEG-0683

1930

Inyi_3 rDr.
nrn-r.ymronram Director, ihree Mile Island Progrem Office7
e-u'rtiun
Cffice of 'ucleor !c-.c-or
ry Ceczis:ion
U.S. Luclcrr
C955
shin-ton, D.C.

A sizeable oortion of our economy inseafoodinBaltimore,CountyDc-r ur. Ln,-der,Fl'-> a fin

T-5I-2,ofenclose!

r colre0of

ine on til2e PEIS for-O

industry of the Chesapeake
both Daniel Beck,

Wrterman's

-i
`hery

Pay.

Maryland isthe

At the scoping hearings

president of the Baltimore

Association, rond

I testified

prodccts could be dame.ed inthat the safety

the public's eyes bydischargeof w..rstewater since many people would assume theproductsoere not safe no mntter whs; the truth is.

sloughs this concern off by sayins thrt

The PEIS"tte marketabilityof fishery products fro:.. those bodies of won..r should not beScýIrs truly,-aversely -ffeccted" lifHow.ever,1:enine-th Iey

for thisthe effects

tcr PEIS in nossacrcion,

how." cc-.sum rs will'",.'here there is-Y

are understood by consumers.

indicrtes the empiricrl basis

like a mpr'eting study, nor tes it
e educerted.

As a federal

no rrference to scientificto suniort conclusor" state meents,

requirements

court has steted,or ,bjective

d7ta-EPA's ful- disclosure

requirements hlve not been honored."'"analysis" of this inportant

indicote2Inconclusion,issue does not fulfill

the
EPA

and you should do some kind of study to determine

tho real effec't

on theseafood market of the possible durpino.of radiopctive cszewntr.
As I understardit,the engineering company th-t will do

the work on the cleanup is
l•st

A-41

echt:l Coro.3

s'er settled r sex discrimination

The Bechtel Corp.

suit brought by

-2-

FOOTNOTES

group of femnal e employees for 21.4 million and is
being

of blsc'- employees,
sued by aroup

The company has
allowed in
In 1976,• policy that female

Arcb Etates,hi-charged theft Bectcl had,boycott ws: croecial-yai:sed at Jews.

on the suit.

Casper '..ein1.sirger,

chief counselof Techtel,

on hiE bio.:ahicalrffili:tion

to 'reassure clients who may thin!
facts raise the possibility

this

trsa

that

snd Jews is

a9 a lr-rethat he is

in

the

Ibid.,

P.13

5

Ibid.,

p.

6

Ibid.

7

Ibid.

In

information
These

Jewis.7

a compzny w,,hich msy discriminate
being

employse.

inserted in

ta

Three

The posrible effect ofon the employrmnt and, bocial structures

analyzed

4

consent rgreezent

principle to a

Mile Islend

355 F.

3 The Xmerican I'.rrer,

5

end individurls blcb.ctated"

agreed inarsinst women,:blncks

Grnnt,

since 1971,

Bechtelhis Episcopalirn

2 IRDC v.

attorneys will not be

Jasuary 1977,

lists

S-11

n.

4

Sup-.

c.ould be

impact stntermt.

C-

A-42

20

230 (E.D.K.C.1

C'ctobzr,'.'einberzer at Bechtel",conspired to boycott comoenies
6

1 P1IS,for racial discrimination.

w...here Bechtel hns a numcr of projects.

the Justice Depsrtme.t

by Archb nations.

currently

p.

20

1930, ",ixEd

977)
Results for

THE
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INc.
48 Maryland Avenus, Annapolis, Md. 21401 * (301) 268-7722 * 268-723 # 28-2622

48 Maryland Avenue, Annapolis, Md. 21401 e (301) 208-7722 * 268-7723 * 269-6422

October 2,

COMMENTS OF

1980

THE MARYLAND WATERMEN'S ASSOCIATION,(PEIS), NUREG-0683
Draft Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from the March 28, 1979
Accident at Three Mile Island Nuclear Station, Unit 2

Dr. Bernard J. Snyder
Program Director
Three Mile Island 'Program Office
office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

The Maryland Watermen's Association is a non-profit trade association
working on behalf of all commercial fishermen in Maryland.
Our organization represents 1800 individual watermen, that is, independent businessmen who have chosen as their profession harvesting various sorts ofseafood from the Chesapeake Bay and delivering high quality seafood
products to consumers.
In addition to our 1800 individual members, 4ealso represent 18 regional Watermen's Associations.
We think you willagree that watermen have a definite vested interest in protection of
the Chesapeake Bay from it's
headwaters to the mouth and a definite
vested interest in people's perception and opinion of the quality of
the waters of the Bay and seafood harvested from it.

Dear Dr. Snyder:
Enclosed are comments from our organization that I understand will
be made part of the public record on the Draft Programmatic Environmental Impact Statement (NUREG-0683).
I cannot stress enough the fact that the Susquehanna River andChesapeake Bay must be protected throughout the entire clean-up process,Avoiding any further accidental or planned environmental degradationand stress to these natural resources is something we must do not only
for the hundreds of thousands of people who depend on them for theirlivelihood, but for the entire population related to and linked to theseresources in any number of ways.

Having spent a good deal of time reveiwing the PEIS we must conclude
that it is insufficient and damaging itself to the integrity of Chesapeake
Bay seafood.
This document was not submitted for the general public.
It does not address concerns of the general public.
It is not written
and prepared in terms that laymen and laywomen or consumers or thegeneral public or anyone other than a "scientist" can easily understand.

As I understand it,
the Commissioners of NRC will ultimately decide
what methods of decontamination and disposal is used. 'hen will thisdecision be made?
Also,

I would like a list

INC.-

At least one of the reasons this is so critical is addressed -VERY BRIEFLY -- in the PEIS itself.
In the Summary at the beginningof the document, page S-11, under the heading Socioecorlomic ,ffects,
it is stated..."Potential economic impacts include the effects of increased electricity rates, reduced tourism, and possibly resistance toconsumption of agricultural and fishery products that the public may
think are radioactively contaminated.
Families involved in agricultural
production are likely to be affected to the largest degree." Further inthe same section..."Low but measurable concentrations of Cs-137 would
persist in sediments in both the river and the bay for some years following
a discharge of water from TMI-2, but the levels would be so low as tohave no radiation effects on aquatic species or on man.
If these effects
are understood by consumers, the marketability of fishery products fromof the Commissioners.
Sincerely,~1,1-,..

Administrative Director

A-43

Maryland Watermen's Association,
Comments: PEIS, NUREG-0683
page two

Maryland Watermen's Association,
Comments:
PEIS, NUREG-0683
Page threeInc.

those bodies of water should not be adversely affected.
It is therefore
important that the public be properly informed if and when such releases
occur." (end quote from PEIS) As to the statement that if the effectsof the clean-up are properly understood the marketing of seafood products
should not be adversely affected,we must go back to our comment on the
PEIS itself. This is not an example of properly informing the publicof effects.
The marketing of seafood products of the Bay, and indeed of theentire nation, is a long time goal we are just now catching up on.
Potential damage that exists from this situation could be just tremendously
damaging to our overall goals and to the economy of our state. This is
not even addressed in the PEIS.
We need to have more public participation in this process.
Now.
Even if it means slowing down the overall clean-up process slightly. We
are not saying the clean-up process should be slowed excessively, but wedo need to "properly inform the public." We need a Citizen's Advisory
Council on this one, respected and recognized citizen's representatives
need to be involved in every step that occurs in the clean-up process.

Inc.

The Maryland Department of Natural Resources, Tidal Fisheries Division
recently concluded a survey of the population of shad in "the Upper Bay..
The concluded there were only between 2400 and 7500 fish (shad) present
in the entire Upper Bay.
2400 - 75001 For some time now various
finfish have not been reproducing in the Chesapeake Bay.
The onlyanswer to this, so far, the Maryland Department of NatuL:al Resources
has been able to discover is that "there is something wrong with thewater."Z )Suppose those "low but measurable" quantities of Cs-137 wereto persist in the bodies of those 2400-7500 finfish that are. in the
Bay now? We cannot condone anything so potentially dangerous to thepresently (undeclared) endangered species of the Chesapeake Bay.
The final concern we will voice here is there appears to be someconsternation and indeed disagreement within the scientific community
over some of the data that is the basis of the conclusions in this PEIS.
This must be resolved.
Because of this, we must agree with theblaryland Ad-Hoc Committee on TMI, that an independent group of scientists
needs to be appointed to either further study the processes the EIS
uses or confirm the validity of the concepts used and conclusions reached.
This group of independent scientists needs to be selected by the citizen's
group we mentioned earlier or another citizens group.

It was stated by Dr. Bernard Snyder of the TMI Program office that
25 public meetings had been held to explain and receive comments on
the PEIS and alternatives discussed in it and that he felt this was"quite sufficient".0')
We do not feel 25 meeting of this type aresufficient to properly inform the public of what is being done about
clean-up of the TMI accident.
At the Annapolis, Maryland September 30, public meeting Dr. Snyder
stated .rather emphatically several times that the release of processedwater from TMI into the Susquehanna River was only an alternative, that
the NRC was definitely open to other alternatives; that it was a "verybad assumption" to think the water would definitely go down the Susquehanna
However, all throughout the PEIS and during presentation of NRC Staff
at the public meeting we were able to attend, continually the alternativeof dumping into the Susquehanna and dilution into the Chesapeake Bay
comes up as the favored method of disposal and it is very evident thatmost of the energy invested into these alternatives focused on theSusquehanna dumping method.
We must consider this "dumping" and we can
not condone, support, understand or lend credulence to this as a viable
solution.
The Upper Chesapeake Bay fisheries are in a critical condition.
Public Meeting sponsored by MD. Department of Natural Resources
and Nuclear Regulatory Commission, Annapolis, Maryland, Sept. 30, 1980
0')

A-44

(1 Quote from W.R. Carter, Maryland Dept. Natural Resources, Tidal
Fisheries Division at a meeting of the Maryland Watermen's Assn., Inc.
Board of Directors; September 5, 1980

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A-45

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Oct 11 1980
o504 Bradford T
Phil".
191-49Chairman Carnesale

TABLE

Cover letter
Table of contents
Introduction and General Comments
Comments On Specric Items on the PETS

Samuel ChilkSec.

U S N2 Ga2
Sirs:
Please Find enclosed my comments on the Frogrammatic
Environmental Impact Statement for the Clean-up f-r
Three Mile Island ý2.

To say that the P

TI S is deficientan understatement.

To say tinat t.he N

C I

is

negligent inits

duty t,.:.

i.',l ect

fri.'
vi.

]

of the public is now merely an ctviovs
I will attempt to com.rucitete r7-d ,•e-i.t

Sfuge and inadequaecies of the P E I S by t.ies:
The PEIS makes no bones about a "faex"
the cleanup.

deatshs fromI sincerely hope that thocse "ft~w" Ceaths

refferred to in the PEIS, by some stroke of clance,
those of thle P

OF CONTENTS COMMENTS OF PEIS TMI#2

r

naý.

i

4 .iJ WS

A-46

C
I

a
/0

m

•

I

_

IMMI

There is a principle taurht at many engineerinE schoo:ls, whichstate! f)at, where calculations are used in a report, there
uhould be some means to rechleck the calculations.
This recheckof callculatIc-no car. I,e acr~ontlisi-od by scve:s",rmýrns . The
actual calculations can he put in tlv:-eoor ; i.e technicaloan.1"i1V tr:(:''u';-slnixr', t.- --he numbers ramn LE zieep;
Or a st.,-zea'ence oso(taii:,i£ e jl:i.I 1ivt:
tie c,: tilo•-lti•ns
can be included.

There is not one word in the PEIS as to how a crash of anSC •ft -.
.- l•ed ret. cffectLI-e cepnI',.
T)is Jn

I have read the PEIs draft. Numberýý s(i.a to jump out withlittleor no explanation of their derivrouon or oris'in. I readnost (f the reference'; in the reporl,.
A;'nin, A-ere was littleor7,~~ Ic- ~
eno.Jtiiln'r
1e 1'(' Cu.iWn,'- tr-u(,Z. ;.. 1.1 :( 5.1;. are clear
examples.
This particular example is repeated in chapters 6,7,8
and 9.
Tie Table 5.2-4 upon which most of thYe following material
is bhsed refer's t(- "besedon e::perience xitl malr c,,mTlex orcration".
TIre references on Fa-7e 5-22 are no more helpful. Since there apparently i-s no way to deten'mine the: numbers in that tahle 5.2-4ýfrom ti e infcrri•.tion in the PEIS, I went to the' NUIJ. 0591,
ivarious nssumttions, T could get Just about any number I wantedout of these documents.

at t:is'7 c ."''e' :1'e,
trý:I:ne. inbut especially at T M I #2.

This same criticism carries thru for similar paragraphs in
Chapters 6, 7, 8 and 9.
Th.is same criticism seems projer for every mumber in this report,
and the only reason that I am not extending this cri•icism tont.er jn tie

repo(rt,

is

I':
-te
:h -.
-""o'i,I".SLB, in

Tye
'nr'
the

t! e'ni:cleer industry

There is an air lock
A case in point is opening a door.
An air lock is.
at T711- which made t! e ntiaonal news.
-. built in t] e form of a double
cen.ly,,t
entry closet.
lost often an air lock is used to isolate
atmosohere on one side of the lock from atmosphere on theother side of the lock.
Therefore, air locks are sealed
to air.

worth.

r

EN?' raised tie quiestion of c•3-.z-.-v •,,n-the matter of an Operating License.
The aircraft crashhazard has not been investigated in this PEIS as part!r aircraft crash can affect the safetyof tie clean-np.
of l.. clear-un•r at 22 ,2. it nust be addressed in thisAll this points out that the calculations in the PEIS may as wellhave come out of .Te air.
There is no way to check them. Thereis nc -ay to duplicate then from th-e information in the PEIs.
Thre
is no "ca to fine cout. c%-:t.ey :e-oe develope'd foom the refebences.
There is no tray tin indup;ndentl-, aPscer-ain their worth or lack ofer'i:.'

APant.

ci'sh at Ti0I f?2 in tie cper'tin; lcni,til!
ract""Psl C~ntCnt.j'n lz-c."ircraftn," c "rJ'-r
1 1- t- I( Y%
ire

Normally, air locks take no more than a few minutes toner'-otiate. The air lock at T1]L #2 took about 6 weeks toenter after the first try.

tl-at I have ohly checked thesechapters 5,6,'7, 8 and 9, which. I mention above.

This excessive time is most important.
TMI is not a normal
reactor.
There will be excessive times, exposures, andunexpected occurrancesý Some rule of thumb is needed todetermine ':ow much emphasis should be given to the factthat this is an extreme!.' dninaged reactor.

A-47

Apoarently the NiC used a maximum ratio of 10 for its
This is used forcomparison of best versus worst case.
volumes and dosage in the PEIS. Fromi~the historical example
cited above, a ratio of one to 6 x 10 is appropriate.
-Justification for the comparison of worst case. versus
best case numbers crc not, fiven in the Chapters 6, 7d 8
or 9 for volumes nor in any of the Chapters for the Aosages.
My suggested ratio has thbe force or history behind it.
The PEIS must' be rewritten using uty more defensible ratio) 1:
6x 10÷. It is derived em.: i,.icaIlyý from hi t.rica] fact.

This air lock is a perfect example from which to generate
a rule of thumb.
Normally, it takes only :t few seconds to negotiqte an airt, i.tim,-st, tidy nimwals yielded no
A literatuure sonre;, oflock.
ea'm rai , n)Lot.it, , [r locks.
data on ttoas
Ten minitn.

ds•

ver'l

C1AnJ'orUtuhbj3:umullitoltime

to nerotiate

There is a very gir.ve omission in this report.
The TMI 4i restart hearings are proceeding along at this very
There is a possibility that TMI #h will be operating
minute.
This could be theduring a period or part of the cleanup.
part of the cleanup which iF most dangerous, which would be
the time during which the damaged fuel is being removed in
my profedsional opinion as a matklk4rgicql engineer. Thereis no guarantee that T M I #2 will not be subjected to another
This "other incideii
ac ident on the island during the cleanup.
The PEIS
could be the TLI #2 scenario occurring .at T M I #1.
#2 accident at TMI
mast look into the ramifications of a TLMlI"I#dUinFn the cleanup of JIMI #2.

0 weeks after thehisa air lock tl:
awever,an air lcl.
i.
,-ie can, thereby, develop a rule of thumb, forfji-nt atitempt.
what this reactor will require is what a normal woul,. require.
Wule:

What takes less than 10 minutes in a normally undamaged
reactor can take 6 weeks at TMI #2.
10 minutes is to 6 weeks
10 minuites is to 6x7x24x6i) minutes
10 minutes is to 60480 minutes
10: 604180
10: 6 x 10

Some indication of the frequency of T14I #2 accidents can be
fo:und in Classtone and Jordan Nuclear Power and its Environmental ef'ects, chapter 4, "It occurred once in approximately'80yersTof
reactor operation,.

This rule of thumb can be extended to all circumstances andoperations at T M 1 #2.

If the dan-ers are significantly increased, during the timeof cleanup, t',ere should be a prohibition against reactor
the cleanup.
operation durinm
At aninimtum, information must be developed and placed in the,iIS of cleaning up a damsged reactor near an operating
Tmis will include interactions in the case of anreactor.
occident at T,II :$•2during cleanup and TMI #1 during start u
and full power operation with special emphasis on the THI
scenario.

A-48

Ou

_E

. W

E

Several Court cases
impacts be included.

WMEN

require that cumilativeThat means that the cumulative

impacts of T M I wl operation

and accidents on the

Most oriteria andThis PEIS is a mystery wrapped in an enigma.
parameters
needed to write anddevelop a report of this type are,,'clean up of T ',1 I #2 be included in the PEIS.
Firther, some e tim te of the increased off sidedan-ers and cominrisicn -ith- the dancers spelled out
fafet% '3to(iy as far as
in the 'Psslssen ýlctor
mn-nit-oe of dan er for a single nnclear disaster mushbe answere, ;end low t:!e water supply will be affected
and Pnpcrtiuned durinf Ln accident of crises.

just unknowns.
care or reactor"The precise condition of the reactor
is not known."building"'he disposition o f the facility -- whether to decommission or
for licensed operation-,
it to a condition acceptable
restorePage S-I','!illthere be sufficient water for TKI #2 cleanup atwithin the scope of this PEIS."
isnot
which are
These are the very criteria

alltimes as well as an accident condition at T1I #1.
condNo mention of adenuacy of water supply under allitions seems to be addressed in this PEIS.

There were

The Reasons for Cleanup

not the design water supply conditions in the PSA.q.
This chan-e of water design conditions require at leasta tec'nical specification change and preferably an
evaluation to be included in the IP E I S.

most necessary.

Page S-3 state,"The cleanup operatio~nsa

will remove sources of radiatbn exposure that currently pesorisks to the health and safety to the station warkers ad those •members of the community residing in nearby communities."
theUnless there is'some indication of what the criteriaPthat/
cleanup is striving to achieve , there will be much that has
to be redone which will increase exposures.
many:

Examples are

Broken items , which are notradioactive, need net be removed for mothballing. 'hey must
be removed or replaced for restart. Mush piping , whick got
radioactive duting the accident , may have to be replaced forrestart. These pipes need not be excised for mothballing if
they are not too badly centaminatkd. Much electrical wiring
would have to be torn out and replaced for restart, but would
not need to be touched for decontamination preparatory to
decommissioning.
The following table might help compare the differences inproblems of restart versus decontamination

Complexity
Dosages,Volumes ofthefor decommissioning.

Problems Amsociated with
RestartDecoedmnissioning
Very highMedium-rem

HighVery highwaste
The point of this table is

Very highHigh:'
to show that th.e problems for decomi

ssioning and the problems for restart are not theosame.'.:'if you

don't know which one you are ghing to tackle , yOu get-Into;
having to handle the worst problems-from.both. Thisis Ourg•,U
inCrease dosages , dangers

A-49

of accidents,

andoosts.

I conclude this Introduction andGeneral Commentswith a few contemporary and timely issues.
Chairman Aherne

told a Congressional

by Representative

Eckhardt(D

Texas)

dated Marsh 20 , 1980. Gus Spaeth of tke Executive
In a letter
tke President , Council on Environmental Quality, states
Officeof
to Chairman Aherne,"The discussion In these statementsin this letterof potential accidents and their environmental impacts was foundto be largely perfunctory, remarkablý standardized, anduninformative

Panel chairedthat the shoddy

crsftmanship that forced the NRC to halt work on one
nuclear power plant andanotherS100,O00

fine antherto the public."
Tkin tradition , described by Gus Spaethi. continued In the PEIS.
scenariole'sand descriptions are'!largely
The accident
perfumctory, remarkably standardized and uninformative to theThis tradition does not inspire public &onfidenae.
public."24,80 Phila Btlletin.)

may be common.(Sept.

The plant that the NRC recently stopped work on is theSouth Texas Priject. Work and Marble Hill was temporarilysuspended for similar reasons , but recently resumed.
the same kind of workmanhip

at TMI.

No matter hew well intentioned the

may not beThis lettetkas several attachments all describing the past
deficiensies of EIS's as far as accident scenario's and descriptions.
book
I would also direct the staff to Jordan and Glasstene's latest
Environmental Effects ;ndRichard Webb's-- Nuclear Power and its
The description of
Accident Hazards of Nuclear Power Plants..
by the staff inemulatedbeshouldaccidents in these two books

that we will faceThis is

NRC may orno way to overcome shoddy licensee
I submit tht not only are, there iscontractor craftmanship.

add

no solutions to tVe problem
inthe PEIS; but alsoisnot addressedin, thisof shoddy'craftmanshipprovidedproblei of shoddy craftmanshipthe PEIS where it

EIS's'.
The cleanup will generate great'a word about the future.
quantities of waste. These wastes will have to be disposed of in
ourlifetimes. We have no right to foist this problem on future
CR MER
generations. No human being has a right to damn hisAprogeny todeadly garbage for all eternity.
safeguarding this generatioeds
Therfere, we must know what we will eventually do with all these
the preparation of all

must be so addressed.

Finally,
Poor performance must be known ai addressed in the PEIS
How deficient performance will affect the reactor must
be known for at least the following areas of concern:
1. Health and safety of the public
2.
3.

Dosages received by workers and public
Record keeping for quality assurance purposes
and maneuvers

Presently , there are a few badly overloaded low level
waste sites which have been closed te TMI wastes in the past andmay again be closed to TMI wastes in the near future.
Not only are there no high level waste sites in existence inthe USA ;but-also the Courts have ordered the NRC into
wastes.

to overcome the effects of poor

4.
performance on the health and safety of the public.
Improper practices may increase the chances of an accident.
This brings us tb the topicaf
Program in

anOn Site Emergency Preparedness
The sitewill have

due to theongoing

the event of an accident.

increased numbersof workers

on itinvestigating the question lof whether there will ever behigh level wastes sites of ahy kind, anywhere. (Docket PR 50,51)

Traffic isprogram and the TMI#2 Cleanup.
restartalso hampered by a wire fence separating #1 from #2.
from Robert W Reid
On E <pt 24 , 80 , I received aletter

These questions are not addressed inTMI#1

on the way to non-existent waste sites.
The question of where
This treatment is not adequate or prRjr.
and when these wastes will finally be/to permanent and peacefully uNitrv2ROP'fl•

to Robert C Arnold, Met, Ed., stating,"Additional
information and committments ze required before we can
NRC,

rest must be answered. Met Ed , NRC and the State of rennsylvania
have no right to endanger its own residents and the populaceof
other states with radioactive wastes until and unless the questi6n

cnnclude that your Onsite Emergency Preparedness Prgram
of NUREG 0654."
meets the eva&uation criteria
Yet Page 4-t alludes to the Emergency Plan as if it werecomplete and in working order. The Emergency Plan connot
be considered accpptable until
as effective andall

the PEIS except for transportation

accidents

of ultimate disposal of these wastes isparts are demonstrated

in-place for both reactors.

A-50

settled.

COMMENTS ON SPECIFIC ITES IN P318.
These comments are not meanto-be compgehensive , definitive, orcomplete. They merely point out errors , omissions and unexplainedcoincidences.

Correction of the referenced

PEIS meet the NEPA requirements.

.omments

pages will not make thit5

See the Intooduction and Generalfor guidance in meeting some of the NEPA requivements.

Also see the NEPA guidelines published by the Councilbn Environment
The guides published by the NRC
Quality and the NEPA Act itself.
for meeting NEPA guidelines have many flaws,isthat the NRC guidelines attempt

the least of whichof theto meet the letter

NEPA tAw without meeting the Spirit of the NEPA LAw.

Page xvi Gloseary ; The Glossary is incomplete as far as anagrams.
DW.
x/Q; Page 6ý20 OW,MW,.
This makes reading very difficult.
These are just afew examples.
The problem is

text.

Most can be figured out from thethat this lack of complete glossary slows

mast annoying.
"This information has been included to the extent

down reading and is
Page
it

1-1.

is

presently available

from the licensee." Licensee informationmust not be a prime mover inthis PEIS.

The NRC must have more

and better sources of information to call•eDendJ.ng upon, thq Ljp~ensaq as the prime moveris both unfaiP aznd Aarigerousl Tne Licensee has the financial
firsthealth of Metropolitan Edison as his
is supposed to have the Health and Safety
its

first

concern.

Therefore

concern.

The NRCof the Public as, depending upon the Licenssee

for information places the health and safety of the public ina secondary position to the financial
iscontrary to NEPA Jw

health of Met.Ed.,which

and th NRC Charter.

Pbe 1-6 Spells of out that some of the Auxbuilding water
was decontaminated.
data in

However,

there isvery little

the report from the decontamination

volumes, Furies,

usefulto date.

Iftheand other essential data were included in

thisreport for the decontamination which has been accomplished todate, some extrapolation

the volumes,Curies,of this data could be used to determine

amount of waste

expected from decontaminatingThis is, and dosages which could besome of the remainder of the wastes.

especially true for Chapter 5. The wast"e which havepresently been decoqtaminated at TMI#2 have been those from the

A-51

9,•se L-I £u of~ence 2 avaable Jhere? Ex ected costs were chnged!
--A ternative methods
alternative methods ....
Page 1-10. "Costs ofThere is noon the basis of price.
cannot be considered
cost /benefit ratio until a determination is made as to whether
this reactor will be returned to service or decommissioned.Then,
when there is a basis for a Cost /Benefit ratiol can price beconsidered.
Chapter 1.5 Total and cumulative exposures are strangely missing
from the comparidons in this chapter. Any c pnrison is uselessand counterproductive without some definition of parameters ,such as volumes , dosages, Curies anddescription of difficulty.
Chapter 2 Page 2-3. "If the existing condition contimues (leakageof 145 gallons per day ), the valves will be incapacitatedThis appears to be a major concern thatwithin about 3 months."
can lead to many accident conditions and scenario's wth increased
complexity(such as an increased leak rate as most leaks tend to do.)Some exploration of this condition is needed for completenees andhazard evaluation.
Page 2-13."No reguhtory framework was developed to specifi.ally
address the types of upique wastes that have been generated
at TYI#2 since it was never anticipated that such wastes would
be created."
This may well be the most telling sentence in this report.
Some regulatory framework must
1. "No regulatory framework"
be developed and in place befoe
any of these"unique wastes"
are extracted from the reactor.
2.
"It was never anticipated that such wastes would be created.
Anti-nuclear groups and responsible
This Is an untrue statement!
government scientists have warned of the possibility andthe
Richard Webb publishedprobahlity of major accidents for years.
The Accident Hazards of Nuclear Power in 1976. Chauncey
Kepfmrd made predictions on th NRC record long before them.
Dr Johnsrud and many nuclear groups petitioned to have "Class 9"
accidents included on the OL sfiCP hearing records at Limerick ,Berwick, and several other nukes. Contrary to the IIRC's statement
these wastes were anticipated by everybody but the NRC, thenuclear industry and the unimformed andmisguided public.

The sampling of primary coolant has not been 2r, To 30
accident 2 workers
sample. Actually during themeem duse pvr
of picking
examplean
Thisiswere overexposed getting a sample.
wai that
hand
off
the
is
problem
Anotherand.choosing statistics.
or oneeffectgeneticaof
480
inchanceoneofthe NRC talks
cancer.
chance in 950 of a fatal
guy dying
These are real andhorrifying numbers when you are thearenumbers
thse
-r,
Furn
od cancer. or raising a damaged child.
continuallyarestudiesINew
based on outdated information.
and radioactivity
showing that the dangers of low level wastes
Bross, Stewart,
using
projectionA
are highly tnderestimated.

Page 4-4.

Where Isstorage facility."
wastes?
TRU
all
take
to
contracted
Has itthis facility?
and can't
Are there anO stipulations? What i";et Ed goes bankrupt
level
pay? These same questions are ala6 apppriate for low
low level
waste , high level waste, non-radioactive waste (below

page 2-17"to a transuranic waste

disposable
but not completely non-radioactive) and aW othermateriALs generated on the Island.
Papers in the Harrisburg area reported that the
Chapter 3-8.
does
dry for ahort periods in fromt of TMI. How
run
River hasthis effect the tables

on Page 3-8 add the safety of cleanupwith an operating nuke on the same island?

and Morgans'projections"Contract with the U of P (Hospital?) for handlingIs this the U of P in Phila.? Are there
more complex cases."ambulances available able to handle radioactively contaminatedHow
Can the U of P handle contaminated People?
people?

Page 3-21

extensive

isthiscontract?

100 cases per accident

be greater than a factor"The differences would not be expectdd tolow. How about a clue
too
or
high
too
fourof
Factorof four.:"
as to what you are estimating?
eýanaced,
Where istb natural , not technologically"70 to 310 mreams"
is
This
USA?
bactriound radiation 310 mrems in the continental
which.
totellinformation
more
confusing or misleading. I needhours."
Page 5-4 Para. 5.1.3.9. "about 136,000 personWhat is the
cards?
timepunch
peopletbse
Don't
Why "about"?
this work effort fromtotal radiation exposure todate forsparsefilm badges ? Why iA regulation mandated information so? 10/?

of those responsible for these activities."in the ensuing months have done nothingactions
theThis PEIS andThis
to increase ditrust.
and an awful lot
trust
to instillwantedNRC
PEIS really is the topper. If thesad excuse for a.
not have
could
they
,
it
people feel about
to increase the distrust
more.
distrust
increased
have
would
chosen any other route which
page 3-24"a distrustand hard to get?
This is a particularly erroneous paragraph.
of fission products in this surface contamination is similar
to that of the water in the reactor building sump."
C ) -LCOLLD 3Z
by coincidence, The sump contains
true ,
This
separation or clasing of
after
loosedwere
many materials which

Para

maps
Page 3-28 One and a half pages of discussion and 3 undetailed
document on
the warning people are getting out of thisare allthe radioactive wastes from TMI. My comment
the routing of all
is obvious. This is Insufficient treatment of"Transportation

5.1.4.1.

"Miature'Iternatives and Routes that may Be Affectedl"
not show
Page 3-30 This map is particularly deceptive as it does
are a.
urban
populated
that-the route is really going thru a heavily

have acted
valves to auxiliary building. Also th sump must
like a settling basin. There is no reason to believe that thesump and the surface catamination in the AFHB is similar to
any am5 extent.
in the next paragraph been checked
Have the HEPA filters
be?
they
Will
replaced?
orin thePage 4-3 "Introduction of underborated water could result
analysetounablewas
LicenseetheYet,critical."becoming
core
summer.
the Boron content of this water for several weeks thisboron content
Apparently no attempt was made to ana~lyze thisfor these weeks.
commission
of
out
was
h
whi
at other than the lab
6summer 1980)
Report-entire
Status
Weekly(NRC TMI Program Officedemonstrates
fiasco
This
.
NRC
the
by
approvedwasThis actionbythe lack of concern for the health and safety of the public
-...
T,4
tb.
both the NRC anddata must be included for the cancer and genetir.

, repaired

this
Why is Res Guide 1.140 not rigorously applied.? Who allowed-0-ddispensation from the Gtid- ?

94 '4~W

A-52

Page 5-5 Para 5.1.4.2 "Subsequent percolation through the rock."
Would this be the only pathway to the river if

the Island is

Explain with mapping.
the past?
Whole body doses are not enough and are misleading.

submerged as it
Page 5-6

has been inorgan dgses.

Include hand andIncludqov rexposed workers

which occured after accident.
Page 5-7 Para. 51.5.2.
"North west anomaly."
Page 5-9 "The"wnw

secter at .37

actual dose is likily

mile" Epplain theto be within the rangeof 500 times greater or smaller than the estimated doseThis isan admission tht any accident described inreport can be 500 times worse than what isreport.

what does not inspire

confidence

."

this

admitted to in
and trust.

tle

There must

be a way to do a better PEIS.
Zage 5-14 Table 5-2-3 Even
within EPA requirements,
The people

in

this

area have no reason to trustor licensee numbers.

T4e cotNwTr;t)N

if the water at TMI tests
outmust not be released 'to the River.

it

any govermmental

Release of treated water would only exacerbate

traumaspill
reported?
Was tisprior to the accident"
What is th history of t&s spill?
radioactive?

Page 5-25 "spill
Was this spill

How did it happen ? When? Why wasn't ithousekeeping on a non-radioactive spillcleaned up? Did poor
now increase the complexityof cleanup from the 3-28-79 accident?

Is

non-radioactive

Page 5-27

areas? in"estimatehousekeeping poor on

safety related ar" coNsider"a"? Vl.Y

estimat dd

asis in
These estimates were made in the air. They have nofact from the information presented in the report . They areindefensible.

Either put a reasonable

akz''

K.

amount of inform-ationin the PEIS from which to develop thee numbers, put the exact
bibliography, or include some of thereference in thecalculations as an addendum.

for.5.4-3ýAFHB Solid Waste Generation
page 5-35 Table
Maximum and knimum Alternatives.
There is no justification in tVs table or in the references
Table 5.4-2 is just as
for the numbers in this table.
Answering a question with a question
much of an enigma.
may be an excellent rhetorical dexice but it does not
supply the needed infroaation.
Chapters 5, 6,S7.8and some of 9 are
My comments onessentially the same. All thse chapters are deficient in justificationof the numbers given for dosages, volumes,• man hours. They do
not base anything upon th actual historical dosages or man hours.
They use ridiculously small error bands
There are some strange coincidences tht bear mentioning:Ff(bI. On Page 8-40 Table 8.4-1
Liquids
Maximum 200,000 gallons
Reactor cotlant system
NuREG 0686 DEIS Primary Coolant System Chemical Decomtabnation
At Dresden BWR. Page 4.6 "The first rinse containing about
200,000 gallons of liquid."
Shis coincidence of numbers is very suspicious. I wonder if thisprely picked out of an advertising
200,000 gallons was notbrochure for the supplier as I was told to do by phone when
I •ALLEO.
2. There is a series of NUREGS one of which is NUREG / CR 0130
DecommisstoLing a reference
Technology , Safety and Costs of
PEIS seem to come directly out
Many of the numbers in
PWR.
Some numbers apparently are changed by aof this series.
s"mall difference insmall factor in consideration of tbe
power between the Reference PWR and the TMI#2 rating. Utherwise
the numbers ae are very similar. This might be Justified except
for one essential fact that the NRC seems to overlook':
The Referenced PWR in NUREG /CR 0130 is an umdamaged plant.
TMI#2 is a bally damaged reactor!

I cannot comment od these volume numbers without further
information which I was not able to get out qf thetext.rreferences. I have commented on this prob'em iii my in/troduction
and generalcommedts.

!

A-53

|

Regional Planning Council
2225 North Charles Street

Baltimore, Maryland 21218 (301) 383-5838

Milton H. Miller, Chairman

C. Bowie Rose. Sr., Vice Chairman

walter J. Kowalczyk, Jr.. Executive Director

October 17,

Date:

183 Valley Road
Etters, PA 17319(ctober 18, 1980

1980

Mr. Bernard J. Snyder, Program Director
Three'Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

Three Mile Island Program Office
Nuclear Regulatory Commission
Washington, D.C.
20555
Gentlemen?

RE:

In response to the Environmental Impact Study:

I

I

(

Dear Mr.

Snyder:

The attached review and referral memorandum is certification that the abovereferenced project has undergone review and comment by the Regional PlanningCouncil and a recommended action has been determined based on the Council's
findings.
Comments on this project were requested from: Anne Arundel County, Baltimore
City, Baltimore County, Carroll County, Harford County and Howard County.

Comments from the following jurisdictions are included with the Clearinghousereview: Anne Arundel County, Baltimore County, Carroll County, and Howard County.
Baltimore City

We appreciate your attention to Metropolitan Clearinghouse procedures.
you have any questions, please contact us at 383-7110.

Disrespectfully,)aeMetropolitan Clearinghouse
Review and Referral Memorandum,
Draft EIS Project: 80-364
Decontamination of Three Mile
Island Nuclear Station Unit 2

-Sinp

e

H1ir_

.Cordinat?r,.. Metropolitan Clearinghouse

AttachmentBaitýnoec

A-54

mmmArecurel
auntV BaSsrrmeCounry

CarrollCounty

Hatfc Caints

Hwara County

State of MarylanO

If

RFGIONAL PLA]NNIG COUNCZL
2225 N. Charles SCleet

S& R l•ile No. 80-364
R P C Meeting
October

Baltimore, YAryland 21218

R&R #:

8G-364-2-

October 17,

1980

17, 1980

EVIW am NEFWAL NVWU

The Coastal Zone Metropolitan Advisory Board, after review of the draft EIS,
recommends against release of the water to the Susquehanna River because of thepossibility of bioaccumulation of radioactive material and its effects on theSusquehanna River and the Chesapeake Bay.

PF3DET IDEWTIFICATION
Jurisdiction:

Baltimore Region

Project Name:

Draft EIS - Decontamination of Three Mile Island Nuclear Station, Unit 2

Applicant:U.S.

Grant Program:05.111 EISSSThe Maryland Power Plant Siting Program has found that the fear of bioaccumulationlevels have already been calculated in NRC determination of safe'release concentrations, and calculates that slight traces of radioactivity may.be distinguishable
in the northern part of the Bay, but will be so small as to be indistinguishable
from normal background levels from fallout and Peach Bottom Nuclear Plant.

Nuclear Regulatory Commission
EIS

Cost:

The Regional Planning Council, after consideration of the consequences of alternative disposal options, supports the Draft EIS findings with the following conditions:

DESCRIPTI•N

1.

that cleanup of the plant proceed as rapidly as possible;

2.

that contaminated water in the plant should be processed and the radioactive
residue removed from the plant site and the processed water should be reusedas much as possible in subsequent cleaning activities;

3.

that whereas the Draft EIS identifies the potential problem of public fearof consuming fish caught in the Susquehanna River and Chesapeake Bay, it
does not discuss how the problem might be addressed.
The final EIS should
include ways to alleviate public fears of using these waters and the NRC
should consult with EPA and Maryland agencies on this problem.
Since there
is widespread public concern abour the safety of releasing decontaminatedwater to the Bay, the NRC should make a concerted effort to respond to public fears; and4.

that if the water is released, the current federal monitoring program should
be expanded along the Susquehanna River and upper Chesapeake Bay to include
slack-water areas, and sediment where suspended material is likely to settle,
together with monitoring of fish above and below Conowingo Dam. This monitoring program should commence before an water release and continue until theend of the cleanup operation.

This programmatic environmental impact statement is an overall study of the activities
necessary for decontamination of the facility, defueling and disposition of the radioactive wastes which resulted from the accident on March28, 1979 at Unit 2 of the Three
Mile Island Nuclear Station.
The status of the contaminated facilities has been reviewed,
together with methods available to carry out cleanup operations.
It is asserted thatmethods exist or can be modified to perform these operations with minimal releases ofradioactivity to the environment.

COMMENTThe Draft Programmatic EIS for decontamination of Three Mile Island Nuclear Plant
outlines the steps proposed for cleanup of the plant, and discusses the relative
radiation exposure or risk for each step. The biggest impact on Maryland of thecleanup operation is the potential for flooding and accidental release during thelong cleanup period, and the possible release of decontaminated water to theSusquehanna River.
The NRC staff favors release of the decontaminated water tothe river. The radioactive material that is removed would be shipped by truck
to a nuclear waste disposal site in Washington State.
The water released to the river would be well within NRC operating standards at
point of discharge and EPA drinking water standards at the point of nearest inThus, the NRC sees notake.
The release could be completed in 1 - 3 years.
scientific reason why the water should not be released under a carefully controlled
release rate and proper monitoring. Although they have found some technical errors
in the EIS the Maryland Power Plan Siting Program agrees with this conclusion.
Currently, an agreement between the NRC and Lancaster, Pennsylvania prohibits
relose of any water from ThI until mid 1981.

The attached resolution was adopted by the Regional Planning Council and is affixed
as part of the Council's comments.

I HEREBY CERTIFY that at its 198th meeting, held October 17, 1980, the Regional
Planning Council concurred in this Review and Referral Memorandum and incorporated it
into the minutes of that meeting.

The other alternatives to release of the water to the Susquehanna River include:(1) storing it in liquid form on site; (2) releasing the water to the air throughforced evaporation; and (3) solidigying the water in concrete and storing it either
on or off site. Storing the water on site would make it subject t accidental
leakage and unknown possibilities of flooding. Forced evaporation would create
fog under certain situations, and qould limit disposal under specified meteorologicalconditions. Solidigying the 480,000 gallons of water in the auxiliary and fuelhandling building would create 100,000 cubic feet of concrete.
In addition,
there are 1 million gallons of water in the reactor building.
If it were solidi36,000 55 gallon drums, and require
fied, the 1 million gallons of water would fillat least 600 truck trips to move.

October 17, 1980
DATE

A-55

WALE 4.

LCZYK, J&.

Walter Kowalczyk
Executive Director

FYM:Mr. Larry Reich, Director
Department of Planning
222 E. Saratoga Street
Baltimore, Maryland 21202

REGIONAL PLANNINrG COUNCIL
2225 North Charles Street
Baltimore, Maryland 21218

DATE: August 19,
3 & P Meeting:
R P C Meeting:1980

9/5/so9/19/80

ID Joint C/C1E.A 1view Cycle .(up to 60 days)

RESOLUTIONJSBVJRCET
1wR PA1C OORDnUTORLRGING THE OPPOSITION OF THE RELEASE OF WATER USED IN THE CLEANUP OF THE THREE
MILE ISLAND NUCLEAR STATION (UNIT 2) TO THE SUSQUEHANNA RIVER.

TIW S UM R

REGIONAL PLANNING

Applicant: u.S. Nuclear Regulatory Commission
Project: Draft EIS - Decontamination of Three Mile

WHEREAS, The Coastal Zone Metropolitan Advisory Board has been appointed
by the *Regional Planning Council to serve as their advisor on coastal zone matters;
and
WHEREAS, the Coastal Zone Metropolitan Advisory Board has reviewed theDraft Prograrmmatic Environmental Impact Statement (EIS) related to decontamination and disposal of radioactive wastes resulting from the March 28, 1979 accident, Three Mile Island Nuclear Station, Unit 2; andN & R Pile No.:

80-364

Comments Should be Returned By:

OCr 17 1980

sland Nuclear Statio , Unit 2
r.4AAyLANO.R.

8/26/80

This project has been forwarded to the following local departments or agencies.Check.pp
riate blanks and attach comments from the reviewing agencies):
Planning

strontium, g9
WHEREAS, the DEIS acknowledges that radioactive tritiur,and cesium 137, as well as other radionuclides present in the water to be released
to the Susquehanna River, will be detectable in fish as far south as the Potomac
River for as long as two years; and7W.

Public Works.

Environmental Protection

___

um

b•lations

Others (specify) Baltimore City Health Department,

Bur, of Community Hygiene

WHEREAS, the DEIS states that these levels will have no impact on theseafood industry or public health, but does not address the concentration of.
these bioaccumulative radionuclides in the food chain; andJURISDlICTION' S COMMENTS
WHEREAS, the health of Maryland citizens and their economy may be endargered by the unknown effects of this bioaccumulation; andandCheck One

WHEREAS, Maryland depends heavily on the Chesapeake Bay .for both seafood
recreation; andThis jurisdiction has no comments on this particular project.
This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

WHEREAS, the Coastal Zone Metropolitan Advisory Board, considering theabove facts, has recomnmended that the Regional Planning Council oppose the releaseof water from the cleanup of the Three Mile Island Nuclear Station (Unit 2) tothe Susquehanna River.

T•hs project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civil rights issues
and a meeting with the applicant is requested (attach comments).

NOW, THEREFORE, BE IT RESOLVED that the Regional Planning Council opposes..
the release of cleanup water from the Three Mile Island Nuclear Station (Unit 2)
to-the Susquehanna River; and.
BE IT FURTHER RESOLVED that the water should be stored or removed from..
the area so that it may not endanger the public health or the health of the
Chesapeake Bay.

I HEREBY CERTIFY that the above Resolution was duly passed by the
Regional Planning Council at its
197th meeting on October 17, 1980.

October 17,

1980
Date

This project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civil rights issues,,however, a meeting with the applicant is not requested (attach comments).
ThUs project is generally consistent with local planBs
comments arenecessa.ry (attach comments).
.

IlUEN TO:
Coordinator, Metropolitan Clearinghouse
Regional Planning Council
2225 N. Charles Street
Baltimore, Maryland 21218.

WALTER .4. KOWALCZYK, JR,

Bgaue_______________
Title
AgencyDate

Walter J. Kowalczyk,ý Jr.
Executive Director

A-56

qxalifying-'

9//'~7/i~~r'D.
•Date: AugustTO:

Larry Reich,

Mr.

f

gL

Director

Department of Planning
222 E. Saratoga Street
21202
Baltimore, Maryland

19,-

FTM:Mr. Alexander Spear
Referral Coordinator
Office of Planning & Zoning
Arundel Center
Annapolis, Maryland 21401

1980

.

U.S.
Draft

Project:

F & PFile No.:

EIS - Decontaminationof Three Mile

Island Nuclear Station,

Unit 2

R & R File No.:

8/26/80(Check appropriate blanks and attach comments from the reviewing agencies):/uman Relations_

plans or intergovernmental problems and a meeting with the applicant
is requested (Specify below).
This project raises issues concerning incompatibility with local plans
or intergovernmental problem.s, however, a meeting with the applicant
is not requested (Specify below).

_F
nerallys
This pgeJe
sal,.eco~ents are necessary (Specify below).

JURISDICTION'S COMMENTS
Check One
This 1prisdiction has no comments on this particular project.

....

.

q.
C nf

This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

40 . , -,,aA

-

L e.

PC,

,plans,w-Ar/fJ,e

C>. •-I•,6/P','•,,,'/

_;

?
5 •

',v-.••-,•

4rc--w 7.

-.Mr r.1

T

,

AS,..

id

.

d/i)

£J

Title

V /40"71,3~ncr7,-".C•- C;•-r,ý",/N/'/6Ai~r, .tSplans,or intergovernmental, environmental or civil rights issues,
however, a meeting with the applicant is not requested (attach comments).
This project is generally consistent with local plcomments are necessary (attach comments).

/,

DI-,c•. • •,4,,/5"(,,•,.,/•

This project raises problems concerning incompatibility with local
or intergovernmental, environmental or civil rights issues
and a meeting with the applicant is requested (attach comments).
%Thisproject raises problems concerning incompatibility with local

•

•-~"•

,

_

"- •,,.
I

ABOVE

-

AgencyM %4

Environmental Protection
Others (specify"~,~~z/~,'~4v...

This project raises issues concerning incompatibility with local___

Public Works

Planning

Esproject is consistent with or contributes to the fulfillmentof local cociprehensive plans, goals and objectives.

___' ,--.

8/26/80

This project has been forwarded to the following local departments or agencies

This agency has no comments on this particular project.

NAý

80-364

Comments Should be Returned By:

80-364Check One

OR L 74.

U.S. Nuclear Regulatory Commission

Project: Draft EIS - Decontamination of Three Mile

Nuclear Regulatory Cosmission

Comments Should be Returned By:_

9/5/809/19/80

FERR&L COORD]2MATOR REVIEW SUMMAR

Applicant:

PROJECT NOTIFICATION REVZEW

Applicant:

B & P Meeting:
R P C Meeting:

1980

J3ointSUBJECT:

SUBJECT:DATE: August 19,;

RETURN TO:
Coordinator, Metropolitan Clearinghouse

Signature

Regional Planning Council
2225 N. Charles Street
Baltinore, Mar-land 21218

Tfitle

?/61

d

Agenc

Dat

A-57

'

lifying

,

hop

t

/_

Date:August 19,
TO:

1980

Applicant:Project:

U.S.

80-364--A

I R'EGIONAL PLANNING

Nuclear Regulatory Commission

I SEP 19 1180.

-

- -

-

-

- -

-

- -

-

-

-

-

Planning/

This agency has no comments on this particular project.

This project raises issues concerning incompatibility with local
plans or intergovernmental problems and a meeting with the applicant
is requested (Specify below).

to monitor clean-up operations

and to take

-

- -

-

-

-

- -

-

-

---

-

-

-

~Evironmental Protection_____Public Works_man Relations

This project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civil rights issues,
however, a meeting with the applicant is not requested (attach comments).
This project in generally consistent with local plans, but qualifyingcomments are necessary (attach comments).
------------- ------------ ----------------(continued on back)Signature&-* This project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civil rights issues
and a meeting with the applicant is requested (attach comments).

into the Susquehana River.

RETURN TO LOCAL PLFERRA1 COORDINATOR
1WYM ABOVE-This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

samples of any radioactive water which has been treated for possible
future discharge-* This jurisdiction haa no comments on this particular project.

the Maryland State Government be allowed to haveon site- -Check One

project is generally consistent with local plans, but qualifyingcomments are necessary (Specify below).

a representative-

JURISDICTION'S COOMI•M

This project raises issues concerning incompatibility with local plans
or intergovernmental problems, however, a meeting with the applicant-is not requested (Specify below).

Request that-

Others (specify)________________________

This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

,,r

BIl¶TlB TO:
Coordinator, Metropolitan Clearinghouse
Regional Planning Council
2225 N. Charles Street•altimore, Maryland 21218

d

Title h1,,e~-2

Agency e-,V/6

Signature

hk

Title

to Administrativa-Dflxr

Asst.

Agency Bantinpw•-e
Bate

A-58

I

8/26/80- -This project has been forwarded to the following local departments or agencies(Check appro iate blanks and attach comments from the reviewing agencies):.

8/26/80

Check One-

pc/CHS&A Review Cycle (up to 60 days)

joint

RVM

Comments Should be Returned By:

Draft EIS - Decontamination of Three Nile Island Nuclear Station, Unit 2

Comments Should be letaxned By:__This

9/5/809/19/80

U.S. Nuclear Regulatory Commission

R & E File No.:

Comments

COORDINATOR

1980

1
Project: Draft ES - Decontamination of Three Mile I land Nuclear ttion
Unit 2
B & B iFle No.: 80-364
BAL.;'R' MARYLAND

PROJECT NOTIFICATION REVIEW

Applicant:'EMRRAL

SUBJECT:

August 19,

D & p Meeting:
R P C Meeting:D

Mr. Alexander Spear
Referral Coordinator
Office of Planning and Zoning
Arundel Center
Annapolis, Maryland 21401

SUBJECT:DATE:

FM:Mr. John Seyffert
Office of Planning & Zoning
County Courts Building
401 Bosley Avenue
Towson, Maryland 21204

4(A1i-

fnnv---

FRM: Mr. Edmund Cueman
Director, Planning Commission
County Office Building
Westminster, Maryland 21157
Date: August 19,
201

1980

SUBJECT:

Project:

U.S.

Comments

Nuclear Regulatory

80-364

Comments Should be Retuxned By:

Unit 2

8/26/80(Check appropriate blanks and attach comments from the reviewing agencies):

8/26/80

Check One

Planning

jThis

Environmental Protection

agency has no comments on this particular project.

This project raises issues concerning incompatibility with local
plans or intergovernmental problems and a meeting with the applicant
is requested (Specify below).

_man Relations

JURISDICTION' S COMMENTS
Check One

This project raises issues concerning incompatibility with local plans
or intergovernmental problems, however, a meeting with the applicant
is not requested (Specify below).
generally consistent with local plans,

Public Works_

Others (specify)

project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.
_ hiscomments are necessary

80

_ A-

REFERRAL COORDINATOR RVIEW SUMMARY

60 days)This project has been forwarded to the following local departments or agencies

Should be Retuzred By:

This project is

A Il~view CyciýPNA

B & 1 File No.: 80-364

Commission

Draft EIS - Decontamination of Three Mile Island Nuclear Station, Unit 2

1 & R File No.:

9/5/80
9

Applicant: U.S. Nuclear Regulatory
Commission
fA
Project: Draft EIS - Decontamination of Three Mile Island Nuclear,

PROJECT NOTIFICATION REVIEW

Applicant:

B & P Meeting:
R P C Meeting:
Joint RPC/

Mr. John Seyffert
Office of Planning and Zoning
County Courts Building
401 Bosley Avenue
Towson, Maryland
21204

SUBJECT:DATE: August 19, 1980

4

This jurisdiction has no comments on this particular project.

but qualifying

This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

(Specify below).

This project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civil rights issues
and a meeting with the applicant is requested (attach comments).

Comments

This project raises problems concerning incompatibility with local

plans, or intergovernmental, environmental or civil rights issues,
however, a meeting with the applicant is not re ested (attach comments).
TUis project is generally consiste6l
comments are necessa~ry (attach comb n~ts)<7

BETON TO LOCAL FM'ERRAL COORDINATOR
NAM ABOVE

EC _-r

-~

....
RMIEN

TO:

Coordinator, Me tropoli tan Clearinghouse
Regional Planning Ccounil
2225 N. Charles Street
Baltimore, Maryland 21218

Title
Agency__but qualifying

_

Tit P

__S__

l e-n
Department of Planning and
AgenC Deveonmen

Date

A-59

plans,

A,,c,,r ?I

19R0

_

FRM: Mr.

Thomas G. Harris,

Director Of PlanningJr.

3430 Court House Drive
Ellicott City, Maryland

DATE: August 19,21043

B & P Meeting:
R P C Meeting.

ED2 Joint lpC

ifviewv*ycle
E

IMMMI COORDntATOR IEVIW StJnH&I

mUBJBOT:

ApplicanttU.S.
Project:

Nuclear Regulatory Commission

Draft EIS - Decontamination

1980

9/5/80Date: August 19, 1980

to 60 days)
TO:

2.18

2

of Three Mile Island Nuclear Station,

Unit 2

R& R File No.: 80-364

Mr.

Thomas.G. Harris,

SUJ'ECT:

Project:-------------------

Planning

Z.Public

Environmental Protection

-

m

U.S.

Check One

Relations

X

Others (specify)

cU"
Cu

Commissionof Three Mile Island Nuclear

Station, Unit 2

80-364

Comments Should be Retu.rned

Works

-

Or

Nuclear Regulatory

Draft EIS - Decontamination

R & R File No.:This project has been forwarded to the following local departments or agencies(Check appropriate blanks and attach comments frome reviewing agencies):

Ah.

21043

PROJECT NOTIFICATION REVIEW

Applicant:Comments Should be Returned By:
8/26/80--------------------------------------------------------

Jr.

Director of Planning3430 Court House Drive
Ellicott City, Maryland•y:8/26/80

This agency has no comments on this particular project.
This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

------------------------------------------------------------------

This project raises issues concerning incompatibility with local

plans or intergovernmental problems and a meeting with the applicant

JURISDICTION' S COMENTS

isrequested (Specify

below).

This project raises issues concerning incompatibility with local plans
iThis

or intergovernmental

jurisdiction has no oomments on this particular project.

problems,

however,

is not requested (Specify below).

This project is consistent with or contributes to the fulfillmentof local comprehensive plans, goals and objectives.

a meeting with the applicant

This project is generally consistent with local plans, but qualifyingcomments are necessary (Specify below).

This project raises problems concerning incompatibility with local
plans, or intergovernnental, environmental or civil rights issues
and a meeting with the applicant is requested (attach comments).

Comments

This project raises problems concerning incompatibility with local
plans, or intergovernmental, environmental or civilrights issues,
however, a meeting with the applicant is not requested (attach comments).

.__

PTRN'~E

TO:

This project is generally consistent with local plans,comments are necessary (attach comments).

Coordinator, Metropolitan Clearinghouse
Regional Planning Council
2225 N. Charles Street
atimore, Maryland 21218

but qualifying
..

int

Title
Agency'Title"_______________....
,

AgencyA-60

Directofr
Dearlvent ofP,,bli.

Worka

I

a'

-

M

United States Department of the Interior
2

GEOLOGICAL SURVEY
WATER RESOURCES DIVISION
P. o. Box 1107
Harrisburg, pennsylvania 17108

Page 3 - 6,

October 21,

last paragraph:

For the past several years minimum releases for Raystown Dam have been 300 cfs;
however, recent flows at the gage below the dam (01563200) have been as low as
200 cfs. We understand the pumped storage project for Stony Creek was suspended
with the State's declaration of this creek as a "Wild River".

1980

Page 3 - 8,

fourth paragraph:

The date for the minimum observed flow at Harrisburg is
Mr. Oliver Lynch, Section Leader
Environmental Review Section
TMI Program Office
U. S. Nuclear Regulatory Commission
20555
Washington, D.C.

The monthly (August - December) 100-year minimum flows reported herein appear to
be i n considerable error. USCS has not made a routing'analysis of low flows forthe lower Susquehanna River since WRI 77-12 (copy enclosed) was prepared. The
simulated post-Raystown curve of Figure 19 of that report could be extrapolated
to indicate 'the 7-day, 100-year flow (with a Raystown Dam release of 480 cfs
instead of the present 300 cfs) as about 2,900 cfs. The corresponding 30-day(or October) minimum flow would be about 15 percent greater, or 3300 cfs.
Minimum 100-year flows for August, September, November and December would be
The Susproportionally greater -- per the top illustration of Figure 3.1-7.
quehanna River Basin Commission has made additional low-flow routing analyses
for the lower Susquehanna River, to which you may wish to refer.

Lynch:

Dear Mr.

Mr. Helm of this office spoke with you, by
On, or about, September 15 last,in the Surface Water Hydrology section (3.1.4.1.)
telephone, about statistics
Impactof the recently-released NRC report "Draft Programmatic Environmental
Subsequent to receipt of a copy of this reportStatement" on the TMI accident.
from you we have reviewed section 3.1.4.1.
andThe following corrections and comments are submitted for your informationconsideration should the NRC decide to publish corrections:Page 3 -6, first

September 18, 1964.

Page 3 - 8, second table:

Figure 3.1-7. bottom illustration:
The curves in this figure, particularly'that for the 50-year recurrence interval,
analyses of daily flows for a similar
do not entirely conform to our statistical
A copy of p.283 of the report "Low-flow Characteristics of(1892-1972) period.
Pennsylvania Streams", which summarizes our frequency data for gage 01570500,
is enclosed.

table:

StreamDrainage Area,
sq. miles

Average Flow,
cfs

Conodoguinet Creek
Yellow Breeches Creek
Swatara Creek
Conewago Creek (West)

506
219
571
515

640
295
960
590

Page 3 -The cited'source for this table -- Figure 1 of PA-77-2 (copy enclosed) -- provides
A printout summary ofdata on monthly median flows, but not for average flows.
summary thereof, for the 1941-70 flow records ofmonthly flows and a statisticalgage 01570500, is enclosed.

Page 3 - 6, second table:
Characteristics

Flow

Minimum daily flow (9-18-64)
Average annual discharge
Mean annual flood
Maximum flood of record (6-24-72)

1,700
34,500260,000
1,020.000

12, table:

cfs

Please call us if

you need additional hydrologic

information.

Sincerely,Ja~r. McýCo
Acting Distric
Enclosures

NOTE:

i f
Chief

(4)

Due to their length and bulk, theenclosures mentioned in this letterare not included in this appendix.

I

A-61
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A-62~

jgannft saigrIeh
Sb sti*.tv
z J0
COMMISSIONERSROBERT C. ADAMS

4 10

Jou/s.

PRESIDENTELKTEON.MO

WILLIAM C. MANLOVEDENNIS S. CLOWERATTORNEY(edI•T(untg

ROOM 101, COUNTY OFFICE BUILDING

l.e19"aitnupance of our weiurnls".
And that 1-. the XC. word conberingD

imoloa w~asto - wee zasoe. Look. around ýu~tstromaand th•iAk of the fantastio fields andeionmtises
the arw heore (!•I surrounding
to alliubjote
being
are
whisk
meal
wmna wad(set gSesation the foautstie ehild••n,things •&E ho elroo
mostitnud what good will all theose
it
If
and
pakbago,nnnoAlOf theSon& to it It ve*at
gre food In oar fieldsIn't
if ther's qnough eloetiiltl It weare so Ignoust lie to know
peoplesumon
easstmedealt
esn't drink car late" Anto the state
therO's no wa they enn over be retwmnad%loton*$ something is sontowiin.e,
intended for its use.
of hand thatgiving up the Invention that got oat
atIS ca ust avmaso at tht logi.ot
can't ass bh" ell the evils tfar
peple
intellignt.
supposedly
I e"a't understand how
all of %be blran power wanid
tkat
bay*
tawi
I
power.
wIgt the tew benefits of melea%thin%hat
we already have soorauwrt@4, and ould
be toslnlg on bo% to control the tamt%
nOr thber huIM at
sit*
bnap
a
vat
r4lli
awnse
1C
we itontt ned one zsero mass*
thi stuff to we had better
Mountains? Ne can't got rid ofin their "eena or is teiror *% plain taxes oar
Ulevo,
atr
It taken overfigure oat a var to control It before
san that yiallU consider
in your beads, %Adhearts,'estpel•sd,
I hope I have spened up a spase who
o% this oolA-blike living her anpaepleAping viat s 'beat for us. theof nuclearoese~gfurtber
AnW
W not allowing

,'te

into

ttere

onu alr•ody..

%..2C.juo wll

15(DO an., a
thq

vent

those sonsitdrifg dumping not-ails
theirchildren,It the fish survive It?
wnst to either. t•eeor thembt•,ve

to•ver think "Oaqueboaiprhage into the S
drink

it"

or ct

the fishI hope not and hope tbay have the soe,a nothing wrong with admitting a ialaand get on the right tseok to a sofe esvIrsmmengt.l

envirto

they

could

catch,

to know no one elset down s- let',T CJSQif

A-63

DAVID T. PINDERADMINISTRATIVEASSISTANT
AND CLERKELKTON, MARYLAND 21921

EARLEVILLE. MO

4t"tlle't1l parbage (t8l. "an
I'm wrtting to 1u hoTing that we can avoid alot ofof the =Olear sit.
Anyone Who tog onI arWsftea
lovel.
sntse
essol
a
to
aet
jst
can
no possible £o0. when you l9oXst
doI'itkIIbwS.1llt
orIndustria
Uit
ation, beaxto rome tbhre's a justitfictioa for this$he final product - neIaor easteo ":Ib)
poprciou
Mal
the
e
%
oM%
,t
" power It ann prod
teueool
aglnsalpo staff with tbea
of how. tO livt withleauingaandpeopleoforwe all "a produce in the unifioation

amtntnissioners

FRANK D.RAGANCONOWINGO, MD

TO

:

FROM:

TELEPHONES: 398-0200 or 658-4041
EXTENSION 100
Nuclear Regulatory Commission
FrankD.

Ragan,

Cecil County Commissioner

REGAVC Three Mile Island
DATE:

October 27,

1980

Please accept my sincere apology for being unable to attend
your meeting regarding the Three Mile Island incident.
theI commend the Nuclear Regulatory Commission (NRC) for
It has occurred tocountless hours spent on this project.
not knowme that perhaps those persons operating the plant did
effectthe responsibilities that were bestowed upon them and theit has on the citizens.
they are discussing the 'big job'--cleaning
Now, a year later,This job could have another enormous impact on the publicup.
I sincerely hope that allas the original problem did.
justand thatmethods of clean-up have been considered by the NRC
you use the greatest discretion in making your decision.
licenseI am hereby requesting that the NRC refuse to reissue theother nuclear power plants.
to the Three Mile Island plant and all
Perhaps if more were known about the effects of nuclear
thepower and the way to use it safely without endangeringland, water, and lives of the residents in our area nightmares
We werelike the Three Mile Island incident would not occur.
thelucky with the Three Mile Island incident, but what about
next time?
go
Is the NRC prepared to take on the responsibilities that
I must remind you that the NRC sets thewith nuclear power.
must
rules that govern the nuclear power plants, but we alllive with them.

Nuclear Regulatory Commission
October 27, 1980
Page Two
STATIEMT OF SENATOR PAUL S. SARBANES¶14 DRAFT ENVIRONMFiTAL IMPACT STATEMENTNUCLEAR REGULATORY CU41SSION PUBLIC MEETINGHAVRE DE GRACE, MAKflAND
October 29, 1980

It is my opinion that the NRC shoudl hold Three Mile Island
costs of clean-up, documentation, andaccountable for all
studies regarding-the Three Mile Island incident.
Please be advised that I am also against the dumping of wastein the Susquehanna River; as it has a very large impact on
the residents in the Cecil County area.

On March 20, 1980 the Nuclear Regulatory Cormission convened apublic meeting in Baltimore to discuss the scope of its progrmastic

Should you have any questions, or desire any further comments,
please do not hesitate to contact me.

environmental impact statement on the cleanup of radioactive wastes atThree Mile Island.

Very truly yours,

At that meeting I submitted a statenent to the Com-mission urging that:no steps should be taken to release any
contaminated wastes into the SusquehannaRiver until after the completion and review
of a full Envirormental Impact Statement.

Frank D. Ragan
Cecil County Commissioner

It was my belief that no radioactive substances could be responsibly
discharged into the environment without benefit of the detailed analysis
that an envnironmental impact statement would provide.

Now that a draft

EIS has been prepared by the Connission's staff and presented to the public
for review and caomient, I would like to once again express my strong concerns
about. the cleanup process and the public's involvement in it.
Of paramount importance to. Maryland citizens is

the effect that cleanup

operations will have upon the Susquehanna River and Chesapeake Bay.
know,

As youthe Susquehanna River is a source of drinking water for many state

residents, and the Chesapeake Bay is an invaluable seafood resource. The'Comtission's draft EIS explores eight alternatives for the ultimate disposalof radioactively contaminated water currently being stored at Three Mile
Island.

They include solidification in portland cement,

long term storage

on site,. natural and forced evaporation and discharge into the river follaqing
treatment and dilution.

A-64

Thoughtful review of these alternatives

is hindered,CUJ4EhNTS rRLH:JTCD TC THE ,UCLLAR REGULATURY CGM'ISSIJN ON THE DRAFT-.
TI- E:VIR6%:,EJT' L 5TATiVE;:T FOR DECONT-, Iq•TION OF THREE NILE
IiL;dU 2.

Page 2

1

however, by the document's failure to reveal the full cost of each.

In

3y Kathy Ellett,Leagueof Women Votersof,,omenVoterstheaddition, the document offers little indication of the relative merits ofthese options beyond the conclusion that, on balance, the benefits of acleanup outweigh the costs of preserving the status quo.

Given the as yet

League

The
ment

of

Leejue

that

is

aomen

of

beneficial

th;

miht

incomplete nature of the information available, I urge the Convission tomust alwaysbeaccompanied

take no action during the cleanup of Three Mile Island that may adversely

particip:tin.

affect the quality of Maryland's drinking water or threaten the vitality

clean-upof its seafood industry.

of

A second issue that Fust be addressed is the nature of the public's
involvement in the ongoing cleanup process.

The Ccmnission staff has

the

The
of

ij

of

widespread

League

The

does

not

however,clean-updecontwein~tethat its obligation to consult with the public can be totally fulfilled bylnd c.naot

I, there-imoortantmeetings, such as this one, in the cleanup's preliminary phase.

toofficials that they will be consulted prior to and be given a chance tocomment

comnent upon any significant action which the Commission proposes topeople willtheauthorize during what apparently will be a lengthy process.

ve

Thank you for your careful consideration of these ca-Tu-nts.

this

all

A-65

and

subsequent

publicThree

Islandimoortantpublicto makesomeestimatedfacilityatconcerns
toor

acceptable

The

greatest

up

process

and

.,ile

of

credibility

ThereshouldThe

importance

of

our

the

of

middledisposal

site

the

apparently
ALeRt

be

publicis

tnis

procedurestoas wellandway theduringbe overstated.

soon

as posible.

not a suitablebasis.

radiationalong
aslimitedimportance oftemporary

eople

only

cannotRiver isto thenotnecessary

5usquehanna

exposureaninformaticn

the

the

is

will

not beasaIt

extremely

facilities

even onnon-occupationalisprovesconcern'about
disposal

itexpress:

to adequately

processThis
that

aspects
tothe wastes

beprocess.

like

hnw

Therefore,

exposurewasteroute.

ofEIS.

off-sitewill

disposehearing

express

technical

5-7 years.

about
-

publicany

the

we would

formalof the

on

take

tine.

accepttoincomnentstnis

period.

likeislandtheenvironment

end lackd-ciji:,n

ever

in

for

suspicionisstagesclean-uptransport

information

h-.ve

the

designating*

adequate-e dopreliminary

woulo

environ-governmental

ourprocess

be made

at

an

that
of

intendthethctfore, also urge the Commission to assure Maryland's citizens and public

promoted

long

believeand s.%fety,?r--zl

this undertaking, it would be unreasonable for the Comnission to consider

concurrence', ic.

~e- n-•-

Given the unprecedented and highly complex nature ofwith thehealthparticularly

th

has

dJe strongly

by

Thi

n

the Elb.

estimated that the decontamination of Three Mile Island will take at least
five to seven years.

utiliylife.

affoctrproceoures

becauseof Maryland

Voterstoof Maryland,of Pennsylvania.

from the cleantheadequate

waste disposal
regulations

provision

are's,
criv

Thiswý,stt:c.

these

Hrs

on

ear, er)

Many indiviiu-.ls•..yprorennc,

ýlr. cý

oftraining

71y noa:e is Kenneth Nay and I live in Owings K.ills, N',4d.
'-rjl~no. ..... .

ere deeply opposed.. : -r

the risks inv.l ved

inPEI'. doee
It

Cnesapkbke

bay.

.

P
f•lily.

I have one st.tenent with a relnted oue.tion to -ake.

to

.

-

. v

1

into tha 5usCuenanna Hiver, ans antcrin9 tne
...
-:.~
. •o
r<j"
: l .
=- r n:,- .-' ii£ .::•c.•iunderst~nd

local

murs.

and groops in.

andplans,

response

accident

to

information

should includefor.....-..

ctrrnsport ofand stringaE.tly enfcrced during

bh ira21:

shouldb)I.•F tc

Su-,.ot inc'ude ant,', economic Pipares.

on October 21,

to radioactive

a.fter tI:
puclicththeo r ,.

ta r cnr•--$cund tO

way c, n bT h -

i

i.si

-I

c.. ft.

' ,,teis15

t=d whtar,

dc : ii n to t h e

avoid

t: .

ccrically,uCconcern

triti-

E ny

"

ic

Th .ore.is

Ich end.

c ' -t a - n

...

is

estimated by a-tte

....

.

nnd shellfish-enerntes

totol business rotivityofand that

150 mill ion

annually. '.
The PEIS claims that possible dumping of rodionctive

ju Pin;

z
-..

"It,

extracted from the bay each yeatr exceeds $35 million,
the industryof fishs-id that,

The '-altinore

officit'Is th:.) the docl-side value of the fish

loN-level exposure•t T rr-.cciztnt

1930,

The

,..

1

vartevater

should h-e

products if

the public is pro.:.urly edue: ted.

noeffect on the m:-rr'a-, ility

I have attended

meetin,as of thisIrind in.tnnanolis,!:iddletoh-n,".Jans-, of the cecole •t these meetinraP

the PSIZ rn-ti some,Founi'-tion,-.

of the document.

.d.,Yor-,,

lancsterI hnve ",et to meet an opnonent of nuonle.rr

s.."teva-tEr is

sofa.

convince nuclear opon: nts with whom it

If

PEC

can commUnl'c::te in.cv7canolro oents Outtide the a:ý acted ored, vithwhoen'.it has never comounicated,

A-66

briefin:sthe .NYC csn't

public meetina.s of the s,-fety of the w.oter dumping,

I

reod

ver.y. well rensoned ;iou',ts about tie -ccurrcy

th!t dumnint of the.

convince ndeandlik-.e Nancy Kelly of the Chessperbe Ba-ymowor r,-ho has been convinced bt' the PEI ana theitof se-foodcnnnot predict howthat duwnpinE. is safe.

.irny people

77ill quit

,etinykary-"ndT:he redioective wpste-,.-ter isonly r drop of 2,",

COUNTY COUNCIL
OF

3

-2-

seafood if

1
2

dumped.

z conservative estimnte,

If

HARFORD COUNTY,

4

Resolution No.

5Legislative Session Day 80729

6

Introduced by Council President Hardwicke and Council
Members Risacher, Rahll, Schafer, Spry,
Kreamer, and Hutchins

there'sthat will beS3

7
a yeor.

Further;confidenceit

mey tn]'e years to id n bpck these consu erF

ro that fi.'ure

should rt

e-crrt be doubled or tripled.

I blicvc the eccmo-ic da;e.-:e would ".e much ,rerter.

I hope you will includý
efonomicthese figures

letme as,: y u cne quection.

opportunity for the public

WHEREAS,in

12

W,'ill therebe -n

to co:rment on the economic(October 21,

1980)

Harford County isa member of the Coastal Zone

10 Metropolitan Advisory Board appointed by the Regional
11
Council to serve as advisors on coastal zone matters;,.when you caelculate thecost/benefit r.Ilationrhip of various alternatives.

Finally,

63-80

8
9

In fnct,

MARYLAND13

figures14

the final EIS\

15
16
17

WHEREAS,

22

25

26
27
28
29
30
ý31

relating todecontamination and disposal of radioactive wastes resulting
the March 28,
Unit 2;

1979,

accident,from

Three Mile Island Nuclear Station,

andWHEREAS,present in

the DEIS acknowledges

that radioactive

tritium,'

as well as other radionuclides

the water to be released into the Susquehanna River,

will be detectable infish as far south as the Potomac River for

as long as two years;

and

23
24

Environmental Impact Statement(DEIS) proposed by the Nuclear Regulatory Commission

19 strontium 90 and cesium 137,

21

and

the Coastal Zone Metropolitan Advisory Board

has reviewed the Draft Programmatic

18

20

Planning

WHEREAS,the DEIS statesthat these levels will have no

impact on the seafood industry or public health,but does notaddress the concentration of these bioaccumulativeinthe food chain;
WHEREAS,andthe health of Maryland citizens and theireconomy may be endangered by the unknown
accumulation;

radionuclides

effects of this

bio-

and

WHEREAS,

Maryland depends heavily on the Chesapeake Bay

for both seafood and recreation;

and32
RESOLUTION NO. 63-80

A-67

1

WHEREAS,

the Coastal Zone Metropolitan Advisory Board,2

considering

3

release of water from the cleanup of the Three Mile Island4

the above

facts,

has recommended opposition to the
DEPARTMENT OF TRANSPORTATION

Nuclear Station

.5

NOW,

(Unit 2)
THEREFORE,

BE IT RESOLVED by the County Council of

Harford County,

7

cleanup water from the Three Mile8

into the Susquehanna
BE IT

Maryland,that the County opposes

Island Nuclear Station(Unit 2)

FURTHER RESOLVED that the water at Three Mile11

not endanger the public health or the environment on the Chesapeake

12Bay; andBE IT
shall be15

Washington,

16

Program Office.

17

Attest:Mr. Bernard J. Snyder
Three Mile Island Program
Office Director
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

River; andIsland should be stored or removed from the area so that it14

2 8 OCT ibdu

the release of

10

13

FURTHER RESOLVED that a copy of thismayDear Mr.

Attention:

Project Director,.(

Resolution
The material submitted has been reviewed by the concerned operating
administrations and staff of the Department of Transportation.
The Federal
Railroad Administration had the following comments to offer:

Three Mile Island"The document assumes that wastes will be transported by truck from
TMI-2 to Hanford, Wasington. Although rail and intermodal rail-truck
transportation are mentioned as possible shipment alternatives,
drawbacks to using rail for shipment-are noted, and truck shipment
is considered to be the most likely mode of transportation for the
majority of TMI-2 waste. If some use of rail or intermodal (rail-truck)transportation is contemplated, as mentioned in several places in the
document, the environmental effects of these alternatives should be
discussed in greater detail in the final EIS."

i~

18
19

An
Markowski
Secretary of the Council

20

ADOPTED:

October 21,

Snyder:This is in response to your letter of August 14, 1980 concerning a draftenvironmental impact statement on the decontamination and disposal ofradioactive waste resulting from the March 28, 1979 accident at Three Mile
Island Nuclear Station, Unit 2, Docket No. 50-320.

sent to the United States Nuclear Regulatory Commission,
D.C.,

T

WASIoNG O..202_1602-CZlinto the Susquehanna River;

6

9

MAILING AoDResN: G--WS/TPll
U.S. COAST GUARDUNITED STATES COAST GUARD/Johh W. Hardwicke
President of the Council

1980

22

The Department of Transportation has no other comments nor do we have any
objections to this statement. The final statement, however, should address
the concerns of the Federal Railroad Administration.

23

The opportunity to review this draft statement is appreciated.

21

Sincerely,

24
25

/W.R
26

IEýDEL

Chief, Ports and Waterways
Planning Staff

27
28
29
30
31
"tn.a law w
canUiv.wit.

32-2-

RESOLUTION NO.

63-80iA-68

/i-ttOctober 25, 1980
-A( PA',1-

Sensing the unrest and concern of the citizens at the NRC-People of Middletown area meeting

(Oct.

20),

one wonders"Does the panel really try to understand?

Do they see the agony of the people expressing their fears and concerns?"
are asking for more than professional cliches and worn-out records.
was an exampleof bureaucracy inand that creditabilityIntryingaction, it

isto present an answer to the understaff's

the assumptions leave

They

this meeting

no wonder that the thing malfunctionedof Public Relations throughout the system is

so many who attempt

Ifreports,

to express themselvesat such a low level.
itis

no wonder

SENA=E

OF MALRYLAND

ANNAPOLIS,MARYLAND

21401

DISTRICT OFPICI.

ARTHUR H. HELTONSIXTH DISTRICT

P. 0. BOX ego

SARFORD COUNTYHARFORD COMMUNITY SERVICES BUILDINGABERDEEN, MARYLAND21001

effectively~feel

LAC3OII 273-0670

so frustrated.
interests.

There isSuch arrogancealways adds to the problem!

To the observation of some nuclear vehicles spraying
privatevehicles,(leaking) liquid onother nuclear vehicles speeding at 80 MPH on public highways,

October 31, 1980etc.,

the responses varied from "Other nuclear carriers are on thn road beside those
fromTAI(assurance/reassuarance?)"function).

One again wonders -spent where the action is-might appear more relevant,ifto the old Passing The Buck syndrome (police

who isresponsible to whom?

If

families were moved to our area,

the reassurances

so that confidence lvictims could be abated.

Dear Dr. Snyder:

the statistics

might be more reassuring.

given and less public input isWhere half-truths abound,';,'henwill we louder than words?

improved and the mental stress of the public

The cunning diversionary herrings,

tensions never die.
evg

learn?

, subordinate"officials".

Unlike October 20,

November 4 waS an

Did you show your concern by voting?

SincerelyI#il

The E.I.S. acknowledges that radioactive strcntiuLn and cesium my be detectablein fish and shellfish as far south as the Potomac River for as long as two
years. It is also stated that cesium 137 will accumulate in detectable levelsin the area of the Susquehanna flats near Havre De Grace.
The half lives ofstrontium 90 and cesium 137 are 30 years and 28 years, respectively, so they
will be an influence in the Bay for quite saoe time to car•.
my reasons for opposing the dumping of the waste are not based upon misguided
fear or eoticnal stress, but upon the inadequacies and unanswered questions
not addressed in the E.I.S.
Strontium and cesium are bioacculators which
also accumulate as they move up the food chain. Food chain concentration is
not addressed by the E.I.S. The Chesapeake Bay is one of the most productive
bodies of water on the earth and must be protected frao any degradation.

Dan Peffley
R.fD.

The Draft Programmatic Envanental Impact Statement for the Decontaminaticnof the Three Mile Island Nuclear Station Unit 2 is now available for comment.
I have had the opportunity to review this document and a host of related reports, critiques and summaries and feel very strongly that the greatest weakness of the E.I.S. is the tendancy to hedge or "best guess" some of the shortand long range effects of the dumping of waste water into the SusquehannaRiver. The consequences of this cleanup are too critical to the Bay area andthe population that resides in the area, to be left to what "may" happen if
dumping is permitted in the near future.

Learn that actions s eg•

Letters to the elected officials are more effective thanmeetingaccountable day.

where more comment isreally heard, add to the travesty of the system.

the general public -Dr. Bernard J. Snyder, Director
Three Mile Island Progran Office
U.S. Nuclear Regulatory Comnission
Washington, D.C. 20555

equal time were

The grafetti of documentation expense would be better applied to the determined
solution,- 575-6759

always some arrogance amid the well-fielded (money-based)

Hummelstown

The disposition of high level wastes must also be spoken to. The resins to be
used, if filtration techniques are employed, will be highly contaminated andshould not be stored on the island for any prolonged period of tine. The
danger of flooding is great.

C~'a~~I~-.1

CIsT~~I
P--

,
.

_C.f

(ZI,;ThIlU$F-P7AIi+
kII5Z

_?
-ears

Thec~wsa-.!

,/
44-

A-69

STATE OF MARYLAND

Dr. Snyder-2-

October 31, 1980

EXECUTIVE OF-.ARTMENT
ANNAROLIS. MARYLAND

2L104

HARRY HUGHES

the United
The transporting of waste matter across the entire length ofStates appears to be a dangerous proposition, in light of the fact that
there is another alternative. I am enclosing a copy of a letter recently
requestforwarded to President Carter from Governor Harry Hughes, formallying the President's intervention with the Department of Energy regarding
the disposal of high and law level waste.

October 3,

QOVtrn.Oft

The President
The White House
Washington, D. C.

On behalf of my constituency residing in Harford County, and the unusual
threat this nuclear accident cleanup will have on everyone living in the of
the dumiping
State of Maryland and on the Bay, I oppose without question,
waste from Three Mile Island into the Susquehanna River. The people ofPennsylvania and Maryland should be exposed to as little danger as possible
and I believe the Nuclear Regulatory COrmissiom has a clear mandate to seethat the people and the Bay are so protected.

Dear Mr.

1980

20500

President:

I am writing to request your assistance in a matter of
The Nuclear Regulatory
great concern to the State of. Maryland.
Commission's draft Programmatic Environmental Impact Statement
for the Three Mile Island clean-up has failed to address any
alternatives which provide assurance that the radioactive wastes
will be removed from the island without decades of delay. All plansestablish
addressed require that the Department of Energy firsta storage facility or repository for commercial high level radioHowever, the lackactive wastes and high specific activity wastes.
of progress towards establishment of such facilities over the last
25 years renders any current schedules subject to skepticism.

Senate .of Maryland
District Six
AHH:joThere is one option which can guarantee the capability
for timely removal from the island of the high level wastes,transuranic wastes, and those high specific activity wastes
This is for DOE
unacceptable at existing commercial repositories.
to accept these wastes for storage with the similar wastes that
Although
DOE now handles from the defense-related nuclear projects.
Maryland formally suggested during the scoping process that NRC
consider this alternative, it was dismissed in the draft statementwith the simple declarations that DOE policy does not allow for
disposal of TMI low-level wastes at government facilities, and that
DOE is studying the high-level waste problems.

F•closure:As stated
cc:Honorable Harry Hughes.I am therefore requesting that you use your authority
as President to direct DOE and NRC to explicitly consider thetechnical feasibility, of this option, and to direct DOE to make an
exception to its policy by accepting these TMI clean-up wastes forwhich there is no available off-site storage facility.
The unusual nature of the accident derived wastes is
The recent decision by thereason enough for such an exception.
Pennsylvania Public Utilities Commission prohibiting use of revenue
from ratepayers for the TMI clean-up, has created a situation ofThis
institutional instability for the Metropolitan Edison Company.

A-70

The President

October 3,

-2-

1980

Mile Island Program
Director, Three
Commission
Regulatory
Nuclear
Washington, D.C. 20555

makes it imperative, to identify and confirm at this time a location
The clean-up activities should
to which the wastes can be removed.
be planned and conducted in a manner that will insure that disposal
with defense related nuclear waste remains a viable option.

To the staff:

The draft environmental impact statement reveals thatfederal agencies are following a course of action that will makeThree Mile Island a long-term storage dump for radioactive waste.
Nothing could be more dangerous to Chesapeake Bay and the people of
No responsible agency would locate a dump for radioactive
Maryland.
waste on an island in a flood plain above the water supply of amajor metropolitan area, and poised at the head of Chesapeake Bay.
Yet, because of refusal to consider any other realistic alternative,that will be the result of actions described in the draft environmental
impact statement.
Because this is an unusual situation and because of theunusual threat to people in Maryland and Chesapeake Bay, I am making
this unusual request that you intervene with the Departments ofof the radioactive wastethat allDefense and Energy and insist

Jcerely/do not feel that anyone left that auditorium feeling better or more assured
than when they arrived.
what isQuestiens were answered with neat quotable facts ofknown today.

Perhaps this is part of the problem.
Z uarantep-

for -. ' f'•! .:-.

all be-sufferinp" froe

were told it

isI, as part of the publi-,

I want to know if,ert

fifty years from now we willsome nev reaction frtum the radiationthat we are

What is really a safe low level dosage of radiation?
not known.

We

Tner what are we doing fooling around with

nuclear power with the possib ilities

I would appreciate your response at your earliest

I

I attended a public meeting on the PEIS on October 6 in Lancaster,.

receiving today.

be removed from Three Mile Island as quickly as safety will permit-even if it means disposing of them for some extended period with
waste from defense operations.
convenience.

Christine C. Yost
17 South Mary St.
Lancaster, Pa. 17603
October, 1980of such deadly consequences if

some-

'

thing goes wroag with so little

knowledge.

Of course that point is mutefor VI - unit 2 sits there damaged and daily poses danger to us.
One of the greatest concerns of mine, and MoBt of the people present at
Govrnor /that meeting, is the release of treated or diluted radiative water to theSusquehanna River.

The PEIS report did net begin to answer the questions

on the environmental impact on theoquatic life in the Suaquehanna and theChes4peake Bay not to mention human life.

The PEIS report states"Effecta

on aquatic organisms in the Susquehanna River and the Chesapeake Bay is low
but measurable concentration of Cs-137 would persist in sediments for so me
years following discharge of water."

The NRC must realize that both theSusquehanna and the Chesapeake are bodies of life.

Fish spawn, fish andotheraeuatic life live and eat there, children play, plants grow and the

A-71

3

2

am disturbed that the consequences of tritium being left in the water is notwater isused for irrigation and drinking right here in Lancaster.

How canaddressed further in this report.

What is the effect of tritium on thethe report say there will be so few effects when fish today can have traces
plants, fish, benthis organisms and ether wild life which inhabits the down-of arsenie, cadium, copper, lead, chromium plus a long listof chemicals
stream portions of the river all~which may eaterthe food chain?

and pesticides.

Will not additional concentrations like Cs-137 and tritiumcause problems.

Even though many of these amounts are suppositly notharmful to humans eating the fish, these substa:ices

With horrible incidents like Love Canal and other exposures fromchemical waste dumps can anyone give me assurances that a steel container

may kill the eggs orcovered with cement or any other container used to hold wastes will safely
result in deformed offspring that do not survive.

Can humans who make theircontain them for many years?

livelyhood in aquatic life survive a reduction in their catch?

THI is on a floed plain it must not become a waste dump.

When will

Already we see the decline of rockfish, oysters, grasses and crabs inthe Eploor II treated water, oompactib) trash, noncompactible trash,
the Chesapeake Bay.

Many of these begin their life in the mouth of thedrums of solidified chemical decontamination solution,

Susquehaine?

ion-exchange resins

The decline goes unexr3lained with vague references to chlorine

be removed from the site?

How and where will the tritium and otherand lists of the millions of chemicals that can find their way into the bay

radioactive wastes left in the water be treated and stored?
despite strict regultioil.

The Bay c&not afford any additional contaminationT

nor caL we.

he public has been assured that radiation doses received during

clean up operation is equivalent to or below that of a normal operating

How can we be told these chemicals won't have any effects on aquatic

reactor.
life wien kepone poisoning in the James River is

still

Does this include the kyrpton venting and the dumping of

taking its toll onradioactive water?
aquatic life by remining in the sediment.
and rem ains in the sediment.

equal to or below that of a normal operating reactor, how safe is a normal

For animals that are sediment dwellers thisoperating reactor?
spells deatn or g-enetic prob_•lems.
without dangerous consequences?

If the clean up operation radiation doses will be

Tritium like most chemicals settles

Also, the PEIS does not take into consideration the

Can our sediment take any more chemicals

cumulative effect of "normal" background radiation including the effects ofWhnt' happens with this se~diuent when thefallout from past nuclear weapon detonations, past accidental releases ofwater is dredged?

What new dangers could be brought in-land?
radiation, normal operational reactor releases of radiation and releases

I am against the release to the river of radioactive liquids after
from entire fuel cycle with the additional "non-normal" radiation of theobsite dilution and mixing in water.

More quertions and answers concerning
clean up operation.

Has the PEIS proposed an evacuation plan for warkers

our safety must be adequately addressed and answered.
and people in surrounding areasl
None of the chemical treatments of radioactive liquids suggested
remove tritium from tihe water.

Tritium has a half-life of 12.5 years.

What does the NRC have to say about Met ED'a employees for the clean up.
I

Are clean up workers required and assigned the clearn up or are volunteers

A-72

4
chosen.,5

Are workers given an explanation of the additional health andbirth defect hazards they face.

I want TNI cleaned up expidiously but even more importantly safely.

going to pay

The PEIS must address the clean up more thoroughly and answer ourWith new estimates of up to 5-7 years and over 200,000

questions.

p erson hours of labor estimated for only the reactor building cleanup
the cost is enormous.
near.

Met-Ed is

not out

crying foul and proclaiming bankruptcy is

Why then is Met-Ed spending Noney on-an unapproved SDS system?

stockholders receiving reduced dividends?

The public is being

state or federal,

to foot the bill for their mismanagment and mistakes.
In the PE1S report on reasonL for tht cleanup the staff recommends all
clean up operations must be performed to el)"remove sources of radiation
exposure that currently pose risks to health and safety of station workers
and public residents nearby; (2)" to remove radiation sources in fara ofairbonne contasmination, wastewater contaminated by radioactive materials,
plateout, damaged fuel. and (3) as long as water radioactive substances
allowed to occupy sumps and tanks their exists a small possibility of
To me this

implies that there are real dangers that exist at TMI with the unit justsitting there.

Yet,throughout the report and especisliy at the public

meeting we are told there is no danger,
and everytning is being examined.
TNI -2 cleanup operation isthat all radlaactive levels are low

The PFEIS did not make me feel safe.

Thea large operation with many people taking part

Human error seems to have played a large p art in the accidentvith somany new procedures,

so many unknown conditions within the reactor,

need to feel the NRC isout to fotectallso many

A-73

life

for the easiest and cheapest way to appease Met-Ed,
not concerned with life.
Thank you.

charged inor the Me.Ed customers

leakage into groundwater and subsequently into Susquehanna."Idefixnitely isArethe long run with aggravation, psychological stress and higher Met-Ed bills.
I do not want to see the government,

and so many more wastes to dispose of

can we not feel the situation exists for another error -accident.

Will they be receiving extra pay?

All of us are concerned with the question of who isfor this clean up.

additional radiation exposures,

and
which

R. D. #5
York, Pa. 17402
November 5, 1980
Bernard J.
Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission
Washington, D. C. 20555
In

Dear Mr.

re:

1214i

NUREG-0683, Docket No. 50-320
Draft Programmatic Environmental
Impact Statement

Snyder:

The best interests of the public would be served bydecontaminating Unit 2 just to the point of allowing core
removal.
Unit 2 can be sealed after the fuel has been
removed.

~~uZ4.2
A-±41

This solution to the problem of TMI Unit 2 is the mostenvironmentally and economically sound way to do it.

z~
-0

-~

By creating a minimum of additional radioactive waste
used in the cleanup and much less highly concentrated radioactive waste, the problem of shipping this radioactive waste
will be greatly reduced and the release of radioactive
particulates to the atmosphere willalso be greatly reduced.
When the unit isturbance.

sealed there will be no further disC

-There is only one reason why you would want to completely
decontaminate Unit 2 and at the same time not make a firm
commitment to decommission it.
That reason is so that you
will be able to put Unit 2 back into operation regardless ofcost. You know that and I know that. As much as theEnvironmental Impact Statement tries to avoid that fact andproclaim that the disposition of Unit 2 is not within the.
scope of the PEIS, no one is being fooled.

a i

I hope these opinions and comments that you ask for are
given more. consideration than they were the last time.
Sincerely,

cc:
cc:
cc:
cc:

;or

George A. Herman
Three Mile Island Alert
Council on Environmental Quality
Congressman Allen E. Ertel
Congressman Bill Goodling

A-74

l

&

44 -

6Z'

304 S. West Street
P. 0. Box 225
PA 17013
Carlisle,

3 X"__U. S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Washington, D. C. 20555~4ZV7L
3~

Gentlemen,I.

_

We live only 20 miles from Three Mile Island - as the crowflies, or as the wind blows, and we submit that Cumberland
County should be included in the area designated as one which
could be affected by the clean-up of the damaged reactor on TMI.

,A

4LS4

The fact that NO LOCALITY wants nuclear waste transported on
its highways or railways should be an indication of the seriousnessof the problem of nuclear waste disposal.

.-

WE BELIEVE THAT, SECOND ONLY TO SAFETY, NUCLEAR WASTE DISPOSALIS THE MOST PRESSING PROBLEMFACING THE NUCLEAR INDUSTRY - AND
THAT THEREFORE ALL PRESENT NUCLEAR POWER INSTALLATIONS SHOULD BE
PHASED OUT, AND NO NEW ONES CONSTRUCTED.

~

Our most immediate concern is,of course,

Three Mile Island.

we areWhen and if the damaged reactor is ever cleaned up,
absolutely opposed to its ever again being put into operation.
Furthermore, we recommend that the undamaged reactor be put out
of use also. Let the whole island be "cleaned up" so that there
will be no leakage into the Susquehanna river which has enoughproblems without radioactive water and/or any nuclear waste being
dumped into it.
Sincerely yours,(Mrs.

Copies to,
Council on Environmental Qi
Congressman Allen E. Ertel
Congressman Bill GoodlingThree Mile Island Alert

A-75

John F.

Brougher)I

-2Metropolitn Edison Company
PoseOffice Box 480
Middletown, Pennsylvania :7057
717 944-4041
2lev," Diot

environmental acceptability of those actions required for the cleanup where
evaluation shows that the environmental consequences of the action fall within
the bounds described in the PEIS and thus are acceptable for accomplishment.

Di•Oal.VmoorWe think it should be a source of considerable reassurance to everyone thatthe analyses conducted to support the draft PETS clearly indicate the cleanup
can be conducted with negligible releases to the environment and consequently
less radiation exposure to the public than would occur from normal plant operations.
When the potential social and economic impacts on the public are also considered,the draft PEIS demonstrates that the interests of the public and of the workers
are best served by conducting the cleanup expeditiously. We believe this result
should be a major influence in determining the processes used in providing approval
for cleanup activities.

TMIProgram Office
Attn: Dr. B. J. Snyder, Program Director
U. S. Nuclear Regulatory Commission
Washington, D.C.
20555

It is essential that all of the agencies involved not be diverted from completingthe cleanup and the removal of the core by unnecessary preoccupation with matterswhich have little,
if any, capability to improve the reliability of performanceof the cleanup, which are unnecessary, and which will delay cleanup.
We believe
the regulatory interface associated with cleanup activities can be properly conducted in the required careful manner in accordance with existing regulations
and Commission procedures, specifically including 10 CYR 20, and that additional
special requirements are not necessary.
Specifically, proposed additional
specifications R.l.3 (1), (2) and (3) set forth in Appendix R of the PETS are
unnecessary in view of the existing requirements repeated in proposed specifi-cations R.l.3 (4), (5) and (6) and with the imposition of proposed specifications
R.2.3 (1) and (2).

Dear Sir:Three Mile Island Nuclear Sta tion, Unit 2 (-11-2)
Operating License No. DPR-73
Docket No. 50-320
Programmatic Environmental Impact Statement•

In response to your letter of Aucust 14, 1980, General Public Utilities has
made an extensive review of the draft Programmatic Environmental Imract
Statement (PETS) relating to the decont--ination and disposal of radioactive
waste resulting from the March 28, 1979 accident at Three NMile island Nuclear
Station, Unit 2 (N'UREG-0683) , and is pleased to submit its comments on the.
report.

We also believe that unnecessary special requirements for cleanup of T1IX-2 would
be a disservice to the public in that they %wouldreinforce beliefs and allegations
that existing Commission regulations are deficient in areas where they are not.
Even indirect Commission support for such a position is harmful an(' tends todivert public, Commission and industry effort from more useful tasks.

Detailed comments on the PEUS are provided in Attachments A, 3, and C.
Attachment A provides specific comments on sections of the report. Attachment B provides suggested modifications to the text of the report to reflect
the comments.
Suggested revisions are identified by line markings in themargins.
Attachment C is a preliminary revised schedule for 7211-2decontaminacion and fuel removal and a preliminary assessment of additional costs
recognizing the progress to date and the impact of regulatory and financial
constraints that are anticipated to exist throughout the duration of theeffort.
Ihile we have made our best 5udgment for developing estimates ofthe schedule and costs, we believe these estimates are still
subject tosubstantial variability because of the many uncertainties that still
exist
about technical, regulator7 and financial factors.

Acceotable Alternatives
The PETS clearly indicates chat releases to the environment and potential healtheffects to the public from required cleanup activities are negligible.
The PETS
also lists a number of alternative approaches to various cleanup actions.
In a
few cases, it states that certain alternatives are unacceptable.
The PETS is,
however, in GPU's.opinion, seriously flawed in that it does not state whether
any of the various alternatives are acceptable.
To fulfill its basic purpose,
the PEIS should clearly state the environmental acceptability of the alternatives
considered so as to provide a framework within which future activities can be
judged.
Such a statement of acceptability would not, of course, relieve the
NRC staff of their responsibility for determining that the releases and public
impact of licensee proposals are, in fact, consistent with those evaluated as
acceptable in the PETS and with other established requirements such as A.LARA.

in addition to our detailed comments, we have a number of broader commentson the PEIS and its use.

These are presented in the following paragraphs.

Overall
The cleanup of 17M1-2 is a difficult task, and we realize its importance tothe health and safety of all concerned.
!,e also recognize the importanceof the PEIS which evaluates the overall .21-2 cleanup and its impact on
the environment.
In this respect, we believe the ?EIS, if properly modifted during its finalization, will fulfill the need for demonstoating the-070t0rc~alOP;sc33cý:November 7, 1980
TLL 578

2 !!-e Cop.*

A-76

Ill -----IMFýMFESHE

-

I

M1__

, ,

I

- 4 - 3-

November 7, 1980
TLL 578

November 7, 1980
TLL 578

As regards environmental release criteria,
and on site radiological issues.
this section is generally adequate but does not state that meeting the defined criteria (i.e., 10 CIR 50 Appendix 1) is sufficient.
Such a statement
should be added.

Timeliness
In February, 1980, the NRC established a Special Task Force on Three Mile
Island Cleanup.
It was chaired by Mr. Norman M. Haller.
A portion of thecover letter to Mr. Hailer's report to Mr. William J. Dircks reads as follows:

Safety criteria for design, construction and conduct of operations at TMI-2
are not addressed adequately in the draft PEIS.
The criteria remain illdefined.
Experience indicates that continual widely varying interpretations are made of what criteria are and are not applicable to these activities.
To fulfill Its purpose and preclude future problems, the PETS
should result in a clear definition that existing operating plant safety
criteria, properly applied in consideration of the short term nature ofmany of the recovery activities, are adequate for design, construction
Whether such a statement
and conduct of operations activities at TMI-2.
is made in the PETS or separately is matter for decision by the NRC. GPU
considers that such a clear articulation of requirements will go far toeliminate confusion and delay that has resulted in the past.

"The main thrust of our findings and recoomendations is that prompt
action is needed by NRC to restore forward motion of the Three Mile
Island cleanup process.
During our meetings with NRC staff, licensee
management and Pennsylvania State officials, we observed frustration
with the pace of the cleanup, the lack of criteria, the tedious decision process, and the erosion of what once was a high priority program. We have not observed strong initiatives to change these conditions."
Unfortunately, while certain actions have been taken, such as establishmentof interim criteria for radiological effluents from TMf-2 for applicationby the Deputy Program Manager, ThI Program Office and the Director, Nuclear
Reactor Regulations, the situation is not much different, and in some respects worse, than it was at the time of Mr. Hailer's report.

Unnecessarily Restrictive Sequence of Events
The draft PETS is unnecessarily restrictive in prescribing a very specificsequence of events based on conservative preliminary estimates of radiation
It is our recommendation that the PETS notlevels in the reactor building.
The sequence should be determined byconstrain the sequence of events.
actual reactor building radiation levels, data from trial use of deconThe PETS should
tamination methods, and the merits of various alternatives.
permit other alternative sequences and establish acceptable criteria forThis process would reflect the realimaking the selection of sequences.
ties of a complex program and can be done consistent with the PETS objective of defining the environmental consequences of the overall program.

To establish a proper basis for future action, the PETS should recognize therisk of deleterious impacts on health and safety of the public and the workers due to delay and should contain a clear, definitive statement affirming
the importance of expeditiously proceeding with the cleanup.
Such a clear
expression of how the public interest will be best .served is, we believe,
fully consistent with the objectives of the PETS.
We recognize, as we believe NRC does also, that resolution of the financial
situation in a timely manner is also required to permit proceeding withexpeditious cleanup.

C
off-Site Shipme ....
.naiiiuuus
orExchange Mater ial

Waste Issues

-

--

a-

I

ý

r-

anaI

-

i

11

nso

1-ifi

e

d

T

o

The draft PETS precludes the shipment of contaminated liquids offsite andmentions that EPICOR-2 expended ion exchange material must be immobilized
per the NRC order permitting operation of the EPICOR-2 system.
It should
be noted in the PETS that small quantities of contaminated liquid such isreactor coolant system and auxiliary building water samples are and willcontinueto be shipped off site. Also, it has been proposed that dewatered
EPICOR-2 extended ion exchange material be shipped off site for laboratory
examination.

The draft PETS does not adequately address disposal of wastes arising from
TMI-2 cleanup operations.
The PETS should address alternatives to disposalof wastes which, for whatever reason, can not be disposed of via shallow
land burial.
It should clearly indicate that 1) properly desigied on-sitestorage is acceptable for an interim period until ultimate disposal isdetermined and the criteria applicable to such interim storage facilities
shoul4 be set forth; 2) leaving the radioactive material in its present.
dispersed and mobile form is unacceptable; and 3) resolution of off-site
disposal questions need not and should not be a prerequisite to proceedingwith on-site cleanup activities.

The acceptability of such shipments off site for analytical and research/development purposes should be specifically affirmed in the PETS.
We appreciate the opportunity to corment on the draft PEIS and will bepleased to discuss our comments with you at your convenience.

Criteria
The draft PETS, in Section 1.6, discusses regulatory- requirements, otherconstraints, and future criteria generally as they apply to environmental

S%ýcere' v

Vice-President and Director, TMI-2
cc: J.

A-77

T. Collins

Summary
1.

Section S.3

2.

Section S.3

It is stated that no liquids that are currently contaminated or become contaminated during cleanup will beshipped offsite in liquid form. Presently we ship
liquid samples offsite for analysis of reactor coolant
activity, and for other Research and Development purposes.
- The feasible variations to ion-exchange systems fortreating radioactive liquids should include Epicor [Iand the Submerged Demineralizer System (SDS).

3. Section S.4- We suggest the conclusions in the summary Section S.4 bepresented in the first two pages of the report.
Thiswill provide the reader an immediate response as to the
expected impacts from the decontamination of THI-2.

4. Section S.4- tn discussing the occupational and offsite doses,
comparison should be made not only to naturally occuring
sources, but also to exposure from medical sources.

5.

- This section states that leakage of all the reactor
building sump water to the river would sot cause asignificant hazard, however, in the event this did
happen, NRC suggest installing a grout curtain.
This isa massive project considering the minimal consequences

Section S.4

of such an accidental spill.

Cost of alternative

methods should be available as a basis for selection
versus environmental impact.
6.
ATTACrMENT A

A-78

GeneralPEIS sunmary section should recognize the risk ofdeleterious impacts on health and safety of the public
and the workers due to delay and should contain aclear, definitive statement affirming the importanceof expeditiously proceeding with the cleanup.
Such aclear expression of how the public interest will be
best served is, we believe, fully consistent with theobjectives of the ?EIS.

-The

p

-

ý

p

CHAPTER 1

Last paragraph on Page 1-3 should be updated todescribe conditions observed in recent containment
entries.

Section 1.2-

2.

Section 1.3- First paragraph requires updating to the lastest
released cost estimate and schedule.

3.

Section 1.4- The PEIS should be modified to make it clear that the
NRC does not necessarily agree with the public
For example, weconcern as stated in the tabulation.
disagree that cost of alternative methods should not
Cost always has to be a
be a consideration.
consideration and must be considered with otherfactors.

-

I1. Table 1.6-I

Section 1.5.1

5.

Section 1.6.1.2 - The 10 Ci/ft loading for organic resins should not
be used as a-limiting factor, however, it is notexpected that organic resins will be loaded beyond
this limit.

6.

Section 1.6.1.2 - Proposed IOCFR Parts 60 and 61 are proposed regulations and should be treated as such.

7.

Section 1.6.2.2 - Change Permit 2275214 to 2275724, with amendments;change January 19, 1986 to December 31, 1986; change
December 12, 1981 to December 31, 1981.

8.

Section 1.6.3

9.

Section 1.6.3.2

10.

Section 1.6.3.2 - The PETS proposes modification to the Technical
Specifications to request the licensee to calculatepotential offsite doses for each step of the recovery
process.

a-iFm- Table title should mention this applies for unrestricted access.

12.

Fig.

1.2-1

- There is only a partial shield on one D-ring over thepressurizer.

13.

Fig.

1.2-2

- Requires updating.

14.

Fig.

1.3-I

- Requires updating.

- Requires updating to describe recent containment
entries.

4.

-

the NRC staff to generate and review thousands ofcalculations of insignificant off-site radiation
Perhaps the NRC can offer some better
effects.
guidelines for the calculation of radiation hazard to
make the exercise useful, yet minimize the need forexcessive useless calculations.

INTRODUCTION
1.

0

3

- There appears to be a printing error in the text (topof page 1-26).
The criteria stating that doses from the previous year
must be added to those estimated for a new activity
is too restrictive. The new activity doses should be
added to previous doses to make up a total 1 year
dose, not 1 year plus the new activity.

Since the draft PEIS concludes that the '"healtheffects over the period from the on-set of the accident through completion of the cleanup operation will
be non-existent," it does not appear to be a usefulutilization of the licensee's engineering staff nor
- 2 -

-3-

A-79

S

9.

Section 2.2.3

10.

Section 2.2.3.1 - This section should discuss vitrification and the useof metal low specific activity (USA) boxes.

11.

Section 2.1.2.1 - Methods for treating sump water addressed in 6.3
includes a method (direct solidifcation) that does
not involve "processing the water to remove dissolved
r-adionuclide ions."

Section 2.2.3.1 - The "onsite storage facility" is misleading in thatit implies a single facility.
Furthermore, trashboxes are not the only waste that may be stored inunshielded enclosures.
Facilities may be fenced orotherwise enclosed without shielding and only have tomeet regulatory standards for dose rate and otherrequirements.

12.

Section 2.2.3.1 - A more reasonable lower bound for incineration volume
reduction factor is 50 rather than An.

3.

Section 2.1.2.2 - Requires updating based on recent containment entries.

13.

Section 2.2.3.1 - Dry storage of spent fuel should be addressed as astorage option.

4.

Section 2.1.3.3 - Direct solidification of reactor coolant system (RCS)
inventory should be included as an option (SeeAppendix G, Section G.2.2).

14.

Section 2.2.3.1 - Research facilities will also receive portions of ourradwaste/fuel assemblies for post-mortem examination*and evaluation.

5.

Section 2.2.1

15.

Section 2.2.3.2 - The surface radiation levels on some resin beds isfrequently low enough to permit "hands on" package
handling rather, than the use of remote handlingtechniques.

16.

Section 2.2.3.2

CHAPTER 2

MAJOR DECODT.kMINATION AND WASTEDISPOSAL ALTERNATIVES
I.

2.

6.

Section 2.1.1.2 - The decay heat valves are opened.
Therefore theelectric motor operability is less important, however
the ability to operate these valves is still
a desirable operational feature.
To say that the valves mustremain operative in order to maintain safe cooling iswrong.
Safe cooling can be maintained without an
operational mini decay heat removal system (MVHRS).

is no mention of strategic nuclear material(S51) in this section with regard to waste forms.
Guidance is needed as to what concentrations Of
uranium & plutonium in wastes is classified as 5704
and therefore needs to be disposed of in a facility
with an active SIN license.

- Definition of "conditioning".
The word "imobilizaThistion" is used where "solidification" is meant.
is important because solidification will notnecessarily immobilize to a greater extent that mere
capture on ion exchange media.

-ThereSection 2.2.1.2 - The Accideht Water paragraph is misleading.
The
reactor building sump water and RCS are not unique
because they contain sodium, boron, colloids, sludge
and solids.
These were all present in the auxiliary
and fuel handling building (AFrm) water.
The sump
and RCS are more complex due to the higher
radionuclide concentration.

viable.
The PEtS
processes.

17.
7.

Section 2.2.1.4 - Disposal of Kr-85 from the reactor coolant systemshould be considered here.

S.

Section 2.2.2-

Itcis noted that there areepoxy resin combined
volume reduction and solidification processes.
Also,
calcination and vitrification has been mentioned byothers.
Processes which are not mentioned, or are
assumed.non-applicable in the PEIS, may in-fact beshould allow for unmentioned

Section 2.2.3.2 - TO state that "The destination of all shipments will
be a coomercial low-level waste disposal facility"
conflicts
with earlier
case-by-case statements.
If
in fact what is stated is a position, then 'it
shouldThe standards applied to unique wastes are nor givenin this section. The NPC should commic to establishing criteria as soon as the waste forms are identified. Based on the extensive study contained in the
PEtS on waste forms (Chapters 5,6,7 & 8) the NRC
should be developing -some criteria now. To the extent
possible, the case-by-case approach should be avoided
by establishing special categorizacion in the PEIS
and assessing the impact of intermediate depth burial
or other options.

beorestated in
18.

Table

2.2-1

Section.12.

Metal LSA boxes are not mentioned as an alternative.
Vitrification
should be included as a option.
Include~note that discharge of accident water isprohibited at the present time.

-5- 4-A-80

1

CHAPTER 3
19.

Table 2.2-3- Use of bitumen co immobilize incinerator ash should
be included (See Appendix H, Section 4.3.2).

20.

Table 2.2-3- Acid digestion of organic material should be included
as a treatment alternative.

THE ENVIRONMENTANDPOPULATION WHICH MAYBE AFFECTED
1.

Section.3.1.3.2 - Mention should be made that Met-Ed has been collecting meteorological data from its on-site weather
station since May 1967.

2.

used for agriculSection 3.1.5.2 - Parts of Shelley Island are stillture (see Figure 3.1-8). The southern third of TMI
is not all forested but rather only the eastern half
and the western periphery of this lower third is
The rest of this third is mostly grasaes
forested.
and-low shrubs.

3.

Section 3.2- Discussion as to why Beatty and Barnwell burial sites
Typicalare not being used should be provided.
routes to these sites should be shown.

4.

Section 3.2.2- Specific state and municipality transportation
requirements should be discussed if they have an
impact on the technical shipping requirements.

-7
-6

-

A-81

-

. lH

-I-

CHAPTER 4

CHAPTER 5

MAINTENANCE OF THE REACTOR IN SAFE CONDITION
1.

2.

3.

Section 4.1

Section 4.3.3

Section 4.5.1

DECONTAMINATION OF THE AUXILIARY AND FUEL SANDLING- The option of using NDHRS as just a backup for decay
heat removal and using heat loss to the reactor
building ambient as a long term cooling mode shouldbe mentioned.
- The MDHRSmay not be the primary method of transferring decay heat.
It is a method.
-

BUILDINGS

to read, "As of- Change the sentence "as of Nay l,"
Sept. I, the only remaining contaminated water in the
AFIM is primary coolant."

1.

Section 5.1.1

2.

Section 5.1.4.2 - Credit for REPA filters is assumed for the fire
analysis here and inother sections.

Iffilters are normally out of the flow path,for

The 390 mrem dose for the quarter is based on asampling frequency of once per week.
The text fails
to mention this.

theirremovalof radionuclides

the HEPA

no credit

should be assumed.

8

3.

Section 5.1.4.2 - 3 x 10- uCi should be changed to 3 x 10-10 Ci.

4.

Section 5.2-

tn the third paragraph thefirst sentence should bechanged to statethat
allof the initial
AFB water
has been processed.
The last
sentence is not totallycorrect.
Epicor II processing of AFHB water has added approximately 20,000 gallons to the total
inventory due to seal water, flush water and tank farmsteam educator usage.

5.

Section 5.2-

The footnote is incorrect.
transferred to Unit-2.

6.

Section 5.2.1-

This section needs to be updated to reflect
completion of initial
AFIB water.
Also, the storage locations need updating.
In addition to the 330,000

Epicor I will

not begallons stored in the BWST,over 182,000 gallons of
Epicor tI processed water isstored in the 'A'
condensate storage tank which was modified andisolated for thispurpose.

-8-

7.

Section 5.2.2.2 -The decay of tritium
should be well established thus
eliminating the need for error
bounds in estimating
the time required -to reduce tritium
concentrations to
specified levels.

B.

Section 5.2.3.1-

Paragraph 4 states
the chemical cleaning building iswatertight up to a height of 13.5 feet above the basement floor.
This statement isin error.
The description of the building used in Appendix D of the PEIS
should be used for a proper description.

9.

Section 5.2.3.1-

The description of Epicor tI is inaccurate.
The prefilter/demineralicer
and the two demineralizers eachcan contain any or all of the following materials;
anion, cation, or mixed resin,zeolitesor precoars.

- 9

A-82

-

10.

Section 5.2.3.2 - It is not clear why an additional I million gallons
The tritium decayof storage will be required.
quoted in this paragraph is inconsistent with the
5.2.2.2.
Sectionin
decay
tritium11.

=ot likely be disSection 5.2.3.2 - Epicor II processed water would
charged from the evaporator condensate test tanks(WDLT-SA & B), therefore, the Epicor II processing)rate and the rate of release to the river are not
Also, if these tanks are used, releaseinterrelated.
rates of 0.8 gpm cannot be achieved with the currently installed equipment.

12.

Section 5.2.4

13.

Section 5.2.5.1 - "four 8-hours shifts per day"?

14.

Section 5.3.3

15.

Section 5.4

16.

-

-

The Kr-85 remaining in
addressed.

the processed water

19.

Section 5.4.2.2 - As stated in Appendix H, by today's metnods to use apolymeni process, the waste must first be mixed with
Therefore to use this binder it
the organic polymer.
is necessary to transfer waste from its present
container by sluicing. The water uaed'to sluice theresin will add to the volume of the waste resulting
in a volume increase factor larger than 1.5.
Further, satisfactory solidification with cement may
be achieved with a volume increase factor of less
It has not been demonstrated thatthan 2.0.
solidification with vinyl ester styrene wouldin less disposal waste volume thanresultactually
The text should be revised accordingly.
cement.
-Also, this section should indicate uncertainty forthe stability of vinyl ester styrene with waste ofhigh specific activity.

20.

It should read 6.7
as written.
Section 5.4.5.2 - The X/Q is incorrect3
3
x 10-6 sec/m not 6.7 x 10-7 sec/m .

2i.

Table 5.1-Ishould be

Sludge in the reactor coolant bleed tanks (RCBT) has
already been processed by Epicor II.

Accident water and tritiated water are essentiallythe same now that AFHB water clean-up is complete.
Section 5.4.1.2 - The Epicor II administrative limits on maximum-

The concentration of- The Sr-89 value is incorrect.
release value should be 1.0 x i0-24 not 3 x 10-25.
Conc. of Releaseas follows:This was calculated
89(65000 CFM)
- (I x 10-9 au Ci)(u Ci/ml) of Sr-

specifiý activity per liner is:
1st stage liners -,1300

1300 curies

3rd stage liners -20 curies

22.

Table 5.1-2

Section 5.4.1.Z - The 1300 curie limit is self imposed based on two
If another cask is chosen,shipping cask designs.
curie loading could go much higher.

18.

Section 5.4.2.2 - This section states the requirement for solidification
There has been a request to sendof all liners.
several dewatered liners to a DOE facility for
Further, all questions concerning disposal
research.
ifof these liners have not yet been fully resolved.
long time storage on site is required, dewateredresin may be preferable to solidified resin.
Therefore, the dewatering option should be addressedby the PFIS.

Concentrations ofRelease CuCi/ml)
1.2 x 10-10
1.1 a 10-13
1.4 x 10-14
1.8 . 10-15
5.1 a 10-16

H-3
Ce-1374
C3-13
Sr-909Sr-8
23.

-

I x 10-24 u Ci/ml.
1(28318 ml )ft3

The values for the concentration of release are
They should read as follows:
juxtaposed.

-

Using the resin volumes supplied in Footnote c, themaximum specific activities listed in Table 5.4-2 areincorrect.
17.

(365 days)(1440 Min/day)curies

2nd stage liners --Table 5.2-i-

The most recent analysis
This table needs updating.
of RCBT 'C' and tank farm water is as follows:
4

H-3

Cs-IL7

Cs-13

RCBT 'C'

56

9.2

0.29

Tank Farms

13

2.2

0.05

Footnote b, should state that AFHB water processing
Footnote e, should be corrected tois completed.
state that the Tank Farm is located in the "A" spent
fuel pool.

10 -

-

A-83

II -

-

,

m

I

24.

Table 5.2-230.

- This table needs to be updated as follows:
Month

Processed(Gals.)

Table 5.4-5-

Cumulative Liners Used
4 ft x 4 ft 6 ft'x 6 ft

February

125,000

24

4

March

164,000

29

5

April

255,000

38b

5b

May

310,000

52

6

June

360,000

58

6

July

435,000

62

6

August500o,000636September

510,000c

65

7October

5 20 , 00 0c

66

7

November

530,000'

68

7

December

540,000c

70

7

The number of packages listed does
not include theempty Epicor liners that will result if resinissluiced into drums or liners for solidification.
Further,footnotes a and e should be deleted
since itis not clear that vinyl ester styrene
would result inless overall volume than cement (See comment
19
above).

31.

Table 5.4-7
5.4-8
5 . 4-9
5.4-1132.

Table 5.4-12-

The Ba-137m reference should be eliminated.
Oa-137m
and Co-137 are in equilibrium andthe reference toCs-137 is sufficient for curie inventories.

-Presumably
the occupational dose for packaging
II resins, sludge, and decontamination solutionsEpicor
does
not include solidification.
For example, each package of solidified resin would add
500 - 1000 m-mRem.

Footnote b is incorrect.
The cumulative liners used
are Epicor I1 liners only.
25.

Table 5.2-4- This table should also list

Kr-85.

26.

Table 5.2-4- Throughout the report when water processing is discussed mention is made of particulate releases.
This
table is one such reference.
To date, in connection
with contaminated water processing, there has been no
detectable particulate releases.
To be consistent
with the text, the wording in the table should be
revised to make it clear that the figures cited are aconservative estimate of releases.

27.

Table 5.4-I- The listing of 1000R/hr maximum surface radiationlevel for Epicor first stage liners is too low.

28.

Table 5.4-1- If 1300 Ci on a 4 x 4 liner gives a radiation fieldof 1000 R/hr, then 60 Ci will not give a 75 R/hrreading.
Column labeled 'Volume" should be
Another column should
re-labeled "Container Volume".
be added labeled '"Waste Volume Per Container."

29.

Table 5.4-3- The volume reduction factor for incineration would be
reduced if solidification of this waste is required.
Spent filter cartridges can be packaged in a 4 x 4liner as well as the 55 gallon drum.
- 12 -

A-84

13 -I-:--

•I

.inEm

8.

Section 6.3.1

CHAPTER 6
DECONTAMINATION
OF THE REACTOR BUILDING AND EQUIP.2NT
1.

2.

-

3. Section 6.2.1

Add a new paragraph which states:"The two initial
entries into the reactor building on July 23 andAugust 15 revealed little damage from the hydrogenburn and pressure pulse. The door to the enclosed
stairwell on the 305' elevation indicated damage dueto the pressure pulse. A telephone and some wiringon the 347'6" elevation indicated some damage due tothe hydrogen burn. Some 55 gallon drums were damaged
due to the pressure pulse.

Section 6.2.1-

The last
sentence indicates that there in no lightsource inside containment.
This statement is bothincorrect and insignificant to the PEIS.

S. Section 6.2.1-

In the last sentence of the first paragraph after
Table 6.2.1, add the words "and equipment" after"intervening concrete floor."

6.

Section 6.2.2- In the last paragraph, the use of robots is rejectedby the NRC as an alternative.
The wording should be
revised so that their use is not precluded fromfuture consideration.

7.

Section 6.2.3- Tn the third paragraph, it should be noted that thesump draining operation and reactor building decontamination operations may overlap.

- Epicor It should be addressed as an alternative for
A very realprocessing reactor building sump water.
possibility is the concept of removing the grossactivity with the SDS zeolite and then further polishing the water with Epicor 1I. For this reason,
the PEtS should not make the statement the Epicor TI
will not (or can not) be used to process reactor
building sump water.

9.

Section 6.3.2

10.

Section 6.3.3.1 - The process configuration of the zeolite/resin system
as shown in the various sections of the PEIS should
be clearly characterized as a typical system, and not
the one and only zeolite/resin system which might be
In application the actual configuration
employed.
will depend on the results of continuing evaluations
and tests and will probably continue to be refined
As an example, it may beafter going into operation.
desirable to use the SDS system for initial processing and EPICOR II for polishing and recalcitrant
The PEIS should clearly state that.
species removal.
the configuration presented is not to be considered
the only one and that there are many ways in whichfilters and demineralization beds can be configured
in order to achieve efficient processing.

The fifth paragraph, last sentence should be changed
to read, "The extent of any damage this may havecaused is not completely known."

levelsentries indicated radiation"The two initialof 500-700 erem/hour gamma and 250-1000 mrad/hourbeta on the 305' elevation.
On the 347'6" elevation,levels were 100-200 mrem/hour gamma and 250-1000
mrad/hour beta."
4.

In the second paragraph, second sentence, change
It should also be noted that the"will" to "may".
additional 330,000 gallons will most likely be reThe text implies this is an added water
cylce water.
volume.
In paragraph three, 2.4 mg/ml is about 9360 kg of oil
This estimate appears high and aor 2700 gallons.
In the third
technical basis should be provided.
to "may".
"will"
changesentence,

Section 6.1.5.2 - Cancer risk numbers should not be rounded off.
For
example, 0.76 person-rem x 1.4 x l0-7 cancer deeth/mrem equals .00017.
This equates to 2 chances in
12,000.
The staff rounded .00017 to .0002 which gives
them 2 chances in 10,000.
In other words, by rounding
off the number they increased probability of cancer
mortality by 202.
Section 6.2.1-

This section should be updated to reflect the mostrecent consideration of Zeolite/resin. systems.
It is further noted that assumption of DF's
(decontamination factor) in the PEIS for thezeolite/resin system may be optimistic and in actual
operation the system could generate more volume of
The demineraliwastes than assumed in the PEIS.
Cation characteristics of the reactor building sump
water will not be fully understood until actual
Furthermore, EPICOR II
processing has begun.
experience suggests that variations can be expected
we could eventually be making
andduring processing;individual batch decisions as to processing optimizaThe PEIS
tion by filter/SDS/EPICOR 1I combinations.
should state that if the assumed DF's are not- 15 -- 14 -

A-85

achieved, one should not infer that system performance is unsatisfactory and that new environment
impact evaluations would be required.

13. Section 6.3.3.4 - Comment Deleted.
16.

Section 6.3.3.4 - Comment Deleted.

The PEtS should state that there are many possible
ways of configuring demineralization media for processing reactor coolant system water in order to optimize processing efficiency.
The configuration andparameters assumed in the PEIS should not be interpreted by the reader to be a requirement.

17.

Section 6.3.4.1 -18.

Section 6.3.4.2 - The analysis of leakage of reactor building sump
water into the groundwater and subsequent percolation
into the river is not discussed'in sufficient detail.
The leakage of the sump in one to two days is very
conservative.
The 1.6 year transit time is not
explained as to its basis.

11.

Section 6.3.3.1 - In the second paragraph it should be noted that the
SDS system is under construction (not design).
Alsoa mixed resin bed is to remove radioactive anionicspecies rather than just 1-129.

12.

Section 6.3.3.1 - In paragraph two, logically, water should passthrough the ceolite beds before the cation resin.
The sentence "The relatively high sodium content of
the sump liquids..." appears to be out of place.

13.

Section 6.3.3.1 - In the last paragraph add the word "normal" prior to"dilution".

14.

Section 6.3.3.2 - The DF for iodine (and other volatile chemicals) andthe DF for non-volatiles is typical of the 1973
generation of evaporators.
Present generation
evaporators achieve DF's of l04 and 105 forvolatiles and non-volatiles respectively.
The volume
reduction factor of 30 is also low now that forced
circulation crystallizers are available.
With
present technology, this factor can approach 120.
For these reasons, the volumes of mixed resin,
evaporator bottoms and filters are too high.
The
cation resin bed is eliminated altogether.

-In the last paragraph, the tritium release rate'fromtank venting is stated as 0.49 uCi/min and 0.017 Ci
total.
Using the assumptions stated, the values
should be 3.7 uCi/min and 0.12 Ci.

The analysis needs to be explained in greater detailsince it leads to the conclusion that there is little
incentive to proceed deliberately with cleaning up
the sump.
This analysis could be used to justify
prolonged delays in the sump cleanup effort.
Therisk of maintaining 500,000 curies in mobile form
would appear to be greater than indicated in thissection.
19.

Section 6.3.4.2 - The last sentence is incorrect.
The 13 cfs is not
the-flow rate into the east channel, but rather theflow rate over the Red Hill Dam for case i.

20.

Section 5.3.4.2 - Cs-137 concentration at Brunner Island (2.8 x 10-16
uCi/ml) appears to have taken credit for ion exchange
in the ground.
NRC should check for a typographicalerror here.

21.

Section 5.3.5.1- In the first paragraph it is stated:"Based on adose range of 0.3 to 0.6 person-mrem per curie . . .".
Data has been processed which shows that the 500,000
gallons of AFHBwater, containing 55,000 curies, wasprocessed with an operations and maintenance total
exposure of 15 Rem which equates to 0.27 person-mrem/
Ci.
With this value as a base, the cumulative occupational dose for the processing of the 500,000
curies in the Reactor Building sump water would be
135 person-rem.

- 17 -

16 -

A-86

I

i-F

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no

22.

Section 6.3.5.2 - The doses listed in Table 6.3-12 appear to be low.
For example, for tritium from the zeolite/resin
option:2400 pCi x 4 ,e!/or
20,000 "Zi/44*From EPA National
Regulations

23.

lm

25.

Section 6.4.2.1 - A fourth option of removing the sump water should beThis option is to remove the sump water
included.
via WC-P-l which is already installed.

26.

Section 6.4.2.1 - This section would appear to make containment decontamination prior to removal of the sump waterThis alternative should remain.
unacceptable.

27.

Section 6.4.2.1 - Semiremote decontamination methods should also
include ice blasting and foam.

28.

Section 6.4.3.4 - The plausible decontamination sequence mentioned inthis section should not preclude other sequences.

.48 m*
rem/yearInterim Primary Drinking Water

Table IV-2A

Section 6.3.5.3 - An adult consuming 20 litersof thisaccident waterfrom the river would receive a whole body dose of 8
mrem (Case 1) and 2.7 mrem (Case 2) and not 4 mrem
(Case 1) and 1.6 mrem (Case 2).

Calculational Basis:

As noted in the plet.ning study for Phase II, reactor
coolant system inspection and disassembly may begin
as soon as reactor building decontamination at the305' elevation and above is complete to the point
where exposure levels are sufficiently low. The sump
water was assumed to have been processed and replaced
The containment sump maywith water for shielding.
not require decontamination until after defueling iscomplete.

EPA National Interim Primary

Drinking Water Regulations, Table IV-ZA states
thatan adult drinking 730 liters
per year of watercontaining 20,000 pCi/i of H-3 would receive a wholebody drse of 4 mrem.
Therefore:

4 mrem-(730Z) (20,000

pCi/

1

)

For Case 1:

Adult•whole body dose

(20

1)(.4

'

(730

4 )120,000

Another potential alternate sequence is to shield thesump from the 347' elevation and proceed with deconIt may
tamination of the 347' elevation and above.
be possible to reach some point in the RCS defuelingsequence prior to actual completion of sump draining.

105 pCil-)(4mrem)
pCi/i)

it is our recosmmendetion that the decision concerning
sequence of recovery events not be made in the PEIS.

For Case 2:
Adult whole body dose

(20

)(

20

pCi/)(rem)29.

- 2.7 mrem

24.

Section 6.4.1.1--

Table 6.4-I provides a gross estimate of gnamm exposure rates of allelevations in the reactor building
with water in the sump.
Data from the initial
entries
provides much more useful data; however, thedata does not lend itself
to presentation in the same
form as Table 6.4-1.
It is suggested that radiation
surveys be used in lieu of Table 6.4-1.

Section 6.4.4.2 - If the logic in Section 5.1.4 for the analysis of afire is followed, the release to the building ventilation system would be 8 x 10-7 of the total actiUsing the 3000 curie estimate ofvity processed.
plateout activity in the reactor building as theassumed source term, the release to the RVAC filters
This compares to a value of 52
would be about 3 mCi.
Should theuCi stated in paragraph two of 6.4.4.2.
outsideabuilding
in a storage ares, nofire occur
Thiscredit for HOPA filters would be available.
accident should be analyzed in the PEIS.

For Table 6.4-2, the radiation surveys from the initial
entries should be sufficientat the 347-ft. and305-ft. elevations since radiation through the floor
from the sump in a drained condition is negligible.
No data is available from the entries to indicate theexposure rate at the 282-ft. elevation with the sumpdrained.

-

-

IS -

A-87

19 -

40.
30.

Section 6.5.2- Considering the amount of oil and grease film thatwill need to be removed, 20,000 gallons of decontamination fluids appears low.

31.

Section 6.5.2- Volume of decontamination liquids (i.e. 14,000 to
Likewise, the number
20,000) appears to be very low.
The Phase I Study (Pageof solidified drums (470).
9-29) indicated about 600,000 gallons of liquid which
would be approximately 14,000 drums using the NRC
solidification assumptions.

32.

33.

34.

Section 6.5.2.

3

See
This comment also applies to Table 6.6-9.
comment 19 on chapter 5 section 5.4.2.2 concerningsolidification
relative waste volumes resulting fromof organic resin with vinyl ester styrene or cement.
The text of 6.6.3.1 and table 6.6.-9 should be
revised accordingly.

Section 6.5.5.1 - The second paragraph indicates that 0.7 to 2.0 additional cancer deaths will occur from exposure to 0.7
This is an error and should be
to 2.0 person rem.
corrected in the final PETS.
the gaseous release
Section 6.5.5.2 - Table 6.5-4 is intended to list
from the cement immobilization process over a three
Table 6.5-1 is also for a three month.
month period.
The two tables should
period for the same evolution.
agree.
Also the data in Tables 6.5-2.and 6.5-5 should
Tables,6.5-3 and 6.5-6 should also agree.
agree.

36.

Section 6.6.2.2 - Shallow land burial should not be ruled out without
further investigation.

37.

Section 6.6.2.2 - The difference in assumption leading to the NRC
staff's and License$'s estimates on number of zeolite/resin containers should be explained in the last
The paragraph makes it appear that no one
paragraph.
has an understanding of these systems.

-

38.

Section 6.6.2.2 - The comments made on Section 6.3.3.2 also apply toTable 6.6-3.

39.

Section 6.6.2.3 - In Table .6.6-5,
3
be 10 ft. .

-41.

Section 6.6.3.4 - It is not clear how contamination would be controlled
at the baling station while compressing sheet metal
and mirror insulation.

42.

Section 6.6.3.5- It is not clear how the 2,500 to 5,000 drums mentioned relate to the 14,000 to 20,000 gallons of decontamination solution mentioned in earlier sections.

43.

Table 6.2-1- Revise the table to read as follows:

Location and Source

The proposed zeolite/resin system is a new idea which
Based on the SDS system test
has not been proven.
results, the waste volumes listed in this section
appear unrealistic.

Section.6.6

if solidification of the zeolite and cation resin 3is
not required, these beds can be loaded with 10 ft.
of resin.
The mixed bed vessel has a volume of 195 3ft. andwill be loaded with approximately 151 ft. resin.

If a water based- Con exchange should be considered.
decontamination solution is used (such as can-decon)
ion exchange is a very viable method..

35.

Section 6.6.3.1 -Whole-Body Dose
Rates from Gamma
Radiation (rad/hr)

Skin Dose Rates
from Beta
Radiationb(rad/hr)

347-ft. Elevation
Plateout
Dump Water

0.1 to 0.20
00.2 to 1.00305-ft. Elevation
Plateout
Sump Water•"

0.1 to 0.2
0.4 to 0.5

0.2 to 1.00Stairs No. I and 2
Plateout
Bump Water

0.1 to0 . 2d

0.2 to 10d

Notes to the table should be changed as follows:b

The skin dose rates are for workers not wearing
Clothing with a thickness ofprotective2 clothing.
500 mg/cm is sufficient to stop beta radiationfrom all "of the major plateout sources except
Y-90, for which only 95 percent of the beta
radiation is stopped.

c

From measurement made by licensee on August 15,
1980.

d

The staff assumed that plateout on the stairs was
about the same as the plateout on the 305-ft.
elevation.

the resin volume for zeolite should

20 -- 21 -A-88

44.

Table 6.3-16-

This table lists concentrations of radinuclides in
the processed water flow which are significantly
different than those allowed in the NRC letter of
2/1/80.

45.

Table 6.4-I
Table 6.4-2-

These should be revised to reflect current data fromcontainment entries.
This statement applies throughout the PETS.

46.

Table 6.4-3-

The number of curies removed seems to greatly overestimate the total number of curies expected in thecontainment, based on current data.

47.

Figure 6.3-3- Effluent is greater than feed volume.
asterisk is in the wrong place.

48.

Figure 6.3-4- A key should be added as follows:

Also,

CHAPTER 7

REACTORSYSTEM INSPECTION AND PRIMARYWATERPROCESSING
1.

Section 7.1- A significant amount of inspection and examination is
Examinations of this nature
to support R&Drequests.
that do not also contribute to direct plant decontamination and defueling are optional.

2.

Section 7.1- The conditions of the reactor vessel-will also be
determined with respect to its design structuralcharacteristics; for example, the surveillance specimens may provide information regarding material
properties.

3.

Section 7.1-

The PEIS identifies a need for special equipment forfuel accountability without describing the requirements for the fuel accountability program. In particular, any fuel accountability program must be
Care must be taken tooriented toward cleanup goals.
not confuse this with the goals of other accountability programs which are theft related.

4.

Section 7.1.1-

In addition to the damage modes noted, fuel assemblies/rods will be distorted and/or bowed.

5.

Section 7.1.2-

The sequence shown assumes the containment building
is decontaminated before primary system breach.
This

the

OW - Observation Well (dipped samples)
MW- Monitoring Well (pumped
49.

Figure 6.4-1
Figure 6.4-2

samples)

The inclusion of these figures should not preclude
alternative designs.
The reference to "air tight'
doors on the figures should be deleted.

An optional path should be
may not be the case.
shown for partial containment building decon.
It naybe possible to remove the fuel sooner the optionalway.
2- 22 -

6.

Section 7.1.2- Sequence of stages - an item indicating that the fuelwill be encapsulated in some form prior to removal to
the spent fuel pool should be included.

7.

Section 7.1.3-

8.

Section 7.1.3.1 - Wastes generated should also include reactor systemitems such as gaskets, control rod drive mechanism(CRDX) parts, recovered debris, etc.

9.

Section 7.1.3.1 - The worst case numbers in Table 7.1-2 appear high fordirect work in head removal, plenum removal andreactor defueling.
They certainly represent a conservative estimate for worst case condition.

Experience at other plants has shown that due toprotective clothing, respirators, high ambient temperatures, work-breaks, etc., the worker productivity
can. be as low as 25%.

- 23 -

A-89

I

10.

removal system for several reasons.
For example,
cleanup of the RCS will permit access to additional
areas of the AFHB. Also earlier clean-up would
result in less contamination to the decay heat removal system.
In any event, a feed-and-bleed alternative should not be rejected as it has distinct
operational advantages over drain down.

Section 7.1.3.1 - Radiation Levels - The lOmR/hr assumption is opti7.1.3.2
mistic as is 25mR/hr for worst case.
The estimatesof occupation exposure for the worst case condition
appear reasonable.
The PEIS uses 10 mA/hr as anaverage dose rate.
This may be low.
The combinationof conservative manhour expenditures and low dose
rate result in a somewhat realistic estimate of the

In a study under review, it is proposed that, for RCS
cleanup via EPICOR II, the prefilter be loaded
exclusively with zeolite.
The mixed bed polishing
liner would be eliminated.
This would permit EPICOR
Operating
II to function as a teolice/Resin system.
EPICOR IT in this mode permits a higher curies loading in the prefilter and reduces overall waste
generation to 20 prefilters and 7 cation beds.

worst case condition.

11.

Section 7.2- "to the extent possible there will be no new (uncontaminated) water added.....'
It is immaterial(environmentally) whether or not new water is added.
The cleanup systems remove fission
products to very
low concentrations and thus whether processed waterisrecycled or released should be left
as a water
management option.
Note that Section 12 conclusions
support the acceptability of release.

12.

13.

14.

Section 7.2.2

EPICOR II does not always 'remove boron as stated in
the paragraph.
More water has been processed by
EPICOR 11 without boron removal than with boron
removal.
The concern about radioisotope leachingfrom the core applies to any reactor coolant
processing system.

The first
sentence is misleading in its
potential
technical interpretation.
We have no hard information that permits us to say that we can use any partor all'the spent fuel purificationor the makeup
purification
system with only minor modification.
This sentence should be specificallyworded to be
conjecture so that the public is not led to believethat we are creating new clean-up systems when wealready have installedsystems which could otherwise
be used.

17.

Section 7.2.2.1 - Filter/Zeolite/Resin Process: This paragraph is too
For example, a mixed resin bed might provespecific.
to be more efficient than a pure anion bed.

18.

Section 7.2.2.1 - Processed RCS water could be returned to the RCS via
the standby pressure control (SPC) system.
Thiswould avoid dependence on the makeup pumps which
could overpressuriae the MDER.S.

Section 7.2.2.1 - Evaporator/Resin Process: The last sentence should
be changed to read, "An Evaporator System.... is being
considered.

19.

The last
Section 7.2.2.3 - Maximum Concentration Level Alternatives:
There are too many
sentence is far too generalized.
variables in the curies estimate, the waste. estimates, etc., to make such a sweeping statement.

20.

Section 7.2.2.4 - To assume that RCS processing residues will be solidified is contrary to NRC indications that it should
not be solidified until disposal method is settled
upon. This inconsistency is further reason why the
PETS should designate categories of waste and disposal alternatives.

21.

EPICOR IT can take its
Section 7.2.3.1 - Prefilter/Resin Process:supply from RCBTs and tank farm in addition to themakeup water holding tank (NWT). The effluent canbe returned to the RCS via the SPC as well as theothers mentioned.

22.

Section 7.2.5.1 - The most recent calculation over a three month period
indicates 0.19 person - men per curies processed.

-

Section 7.2.2.1 - Normal RCS Purification System: The ability to use
the RCS makeup purification system is speculative at
this time.
There are many considerations other than
the normal operating mode specifications.
If in fact
it could be operated, water as high as I uCi/ml canbe processed with it.
The same limit applies to thespent fuel pool (SFP) cleanup system.

15.

Section 7.2.2.1 - EPICOR I System: The EPICOR I System has not beentransferred to Unit 2.

16.

Section 7.2.2.1 - EPICOR 1i System:
The RCS must be in a decay heatcooling mode before it can be drained to 26,000
gallons.
It may be advisable to reduce the activityof the RCS before going on to the decay heat

-24-

A-90

25 -

N

I .... =23.

Section 7.3.2.I-

I .III

I-.I

If the 41 uCi/mi- Alternate Methods Considered:
used forin Table 7.2-2isCs-137 level listed
calculations, the RCS now contains 15,000 Ci of
Ca-137 in solution not 40,000 Ci as stated in thesecond paragraph.
cartridges -ill
The spent filter
form if the ORNL precoat idea is

not be inadopted.

Section 7.3.2

25.

Section 7.3.3.1 - See comment 19 on chapter 15 section 5.4.2.2-

CHA.PTER8
REACTORDEFUELINGAND?RIMARya solid

24.

WI

1

waste volume resulting fromconcerning relative
solidificationof organic resins with vinyl ester
styrene or cement.
The text of sections 7.3.2,
7.3.3.1 7.3.3.2 and tables 7.3-4 and 7.3-5 should bechanged accordingly.

SYSTEM DECONTYAMINATION

1.

Section 8.1.1.1 - The current rate of heat production
is about 85 td
compared with 2,700,000 KW during normal operation or.003Z of normal power.
Thus, heat load is not asignificant factor in planning thase operations.

2,

Section3.

Section 8.1.2.1 - The PEIS indicates 3.5 ft. 3 as
the maximum container size. The maximum volume is a functionofgeometry.
Fuel assembly shaped containers should
permit larger volumes for the debris containers.

-

Wo actempt has been made to move either the control
N.o.i.1
rods or axial power shaping rods (APSR).
It is
therefore not known which rods are movable.

26.

Section 7.3.3.4 - Last sentence - long-term onsite storage conflicts
with next to last paragraph on page 12-2.

27.

Section 7.3.4.2 - What justification

28.

Table 7.1-1-

Pressure Control Mode, should read, System filledwith water, makeup and pressure controlled via Standby Pressure Control System.

29.

Table 7.3-1-

The 1300 Ci limit was based on two shipping cask

4.

designs.
If a different shipping cask is used, theEPICOR liners could be more heavily loaded resulting
in less radwaste.

Section 8.1.2.1 - The option of using dry
fuel storage containers
should also be included.

5.

Section 8.L.3.1 - The reactor pressure
vessel head (RPVH) insulation
aod CRDMcabling may not necessarily
be wastes.

30.

31.

EPICOR It acci-is used to base andent on 600 Ci instead of 1300 Ci?

Figure 7.2-1

Figure 7.2-2--

The A and B spent fuel pools do not,contained High Density fuel racks.

The decay heat load of the fuel debris is so
low nhata '"mesh screen for circulation" is probably
not required.
We may be able to seal the containers andplace them in storage with decay heat removal
thru
the container walls to the storage pool water.

and have not- The need to seal weld the seal plate
has not been
established.

The storage racks pictured in the deep end of thetransfer canal were removed, and the internal storage
shown in this figure
stand was moved from where it isto the deep end of the transfer canal prior to theaccident.

32.

Figure 7.2-3- This seems to be a preaccident
SPC and MDHRS are not shown.

33.

Table 7.3-2- Statement

footnote b thatindiagram,"EPICOR It

becausein

Section 8.1.3.1 - The stuck studs may
be stripped for removal to avoid
the need to cut the studs.

7.

Section 3.L.3.1 - The text indicateslead screws will be placed in the'park" position. Current plants are
to remove theselead screws to minimice radiationlevels in the headarea and to improve access for decontaminationof theunderside of ehe head prior to head removal.
Section 8.1.3.1 - It may noa benecessary to remove the RPVH service
structure to handle the CRDM's that cannot
be uncoupled.
An option to cut a "working access"thru
the service structure is bhie considered.

theprefilterA.

materials will not be immobilized is not consistent
with other statements

6.

the PEIS.

Alternate methods are being evaluated to cut
the CRDM
leadscrew extensions inside the RPVH
without cuttin.g
the Ca0M housing.

-

26

-

-

A-91

27

9.

Section 8.1.3.1-

The best-case does not represent a bounding lower
estimate in that estimates for working time are conSome ofservative compared with "normal" conditions.
the operations may be carried out with substantially.less working time than the best-case estimates.

10.

Section 8.1.3.2-

11.

Section 8.1.5.2 - The PEIS concludes that offsite health effects areThe
non-existent for the reactor cleanup operations.
NRC staff should utilize this conclusion to simplify
the NRC review process for these operations anddecrease the need for extensive insignificant
environmental effects calculations for each step of
the program.

12.

Removal of internal plateout may not be necessary if
the plant is to be placed in operation again.

The worst case scenerio for removal of the plenum
assumes cutting the plenum into approximately 150
Inpieces inside the reactor pressure vessel (RPV).
our judgement, this is a low probability event sincealternate methods can be developed to free the plenum
from the RPV and core support structure (CSS) without
the need for complete disassembly inside the
It is, however, an option and represents areactor.
bounding case.

Section 8.2.3.2 - The specific tooling for handling core debris has not
The types of tools described in the
been designed.
PEIS are represenative of the types of tools thatwill be used during the fuel removal operations.

14.

Section 8.2.4.2 - A calculation should be made to estimate the amountof Kr-85 removed from the core (via venting, accident release, etc.) compared with the amount of Kr-85
produced by the fission process during TMI-2 power
operation.

Section 8.2.5.2 - The PEIS estimaced that the best-case defueling time
This may not be the lower bound on
is 10 months.
defueling depending upon the final procedures
selected.

16.

Section 8.3.1

18.

Section 8.3.2.2 -19.

Section 8.3.3.1

20.

"coolant"
In the line after
add, the word "pumps".

the third paragraph

The radiation level of 10 mR/hr nominal to 30 mR/hr
maximum are potentially gross under-estimates of theactual radiation levels that could be experienced
This number should be treatedwith these filters.
with caution.

-same comment applies throughout

Section R.3.3.1.

Section 8.3.3.2 - The entries regarding radiation levels

for RCS, forcomment as above

A-92

Section 8.3.3.2.

Section

8.3.3.4 -

Same

22.

Section

8.3.5.1 -If you take the occupational doses listed in Table
8.3-2 and adding the appropriate values to give acumulative dose and multiplying by probability ofhealth effects given in Table 4.5-1, page 4-5 you get
the expected number of additional cancer mortalities
The
to range from 0.057 to 0.25 not 0.068 to 0.13.
would range fromnumber of additional genetic effects
0.11 to 0.47 and not 0.51 to 1.0.

23.

Section 8.4.2.3-

Under the entry "Material" in Table 8.4-2 include
rods, control rods,
neutron sources with orificeburnable poison rods and axial power shaping rods.

24.

Section 8.4.3-

Removal of fuel via theexcluded.

25.

Section 8.4.3.1 -It is estimated that 50 of the 177 fuel assemblies
This number
will require failed fuel containers.
appears low and would approach 177 for the worst case.

26.

Section 8.4.3.2 -It is indicated that the CRUM pressure housings will
This is not planned except, possibly, forbe cut.
one removed.
the first- 29 -

28 -

for

21.

- The assumptions analyzed should not preclude theoption of using a non-chemical decontamination withspot applications of chemicals.

-in

RC drain tank and for reactor coolant pump and motor
These numbers
decontamination appear to be low.
should be treated with caution.

The assumed 320 cureis/per assembly maximum residual
may be high when all Kr-85 removal paths have been
evaluated.
15.

Section 8.3.2.1

This

Section 8.2.2.2 - Cutting the CSS baffle plates to remove the first
fuel assembly is a very low probability approach.
The most likely approach is to destructively disassemble the first assembly to create the initialcavity for subsequent assembly removal operation.

13.

will be a delicate operation
Using a core filter
iq each loop
because using one pump (alternately)
willback-flow the opposite loop and may "wash out"
is trapped-on the filter.
whatever filtrate-17.

equipment hatch should not be

--

M-"

I-

I-

'M

I -M-

J

-

CHAPTER 9

3

27.

23.

read 6.7x 10-6 sec/m notshouldSection 8.4.5.2 - The X/Q value
37
6.7 x 1O" sec/m . Consequently, the total bodydose is 2.0 x lO9 ore. not 2.3 x 10-10 orem.
consumption is 3.8 x
The exposure from vegetable
9
From these cor1O-8 mrem not 4.4 xlO- mrem.
rected doses the probability of either an adult canless than 10l-4 andiscer death or 5enetic effectnot 2.6 a 10 -2 and u.6 x 10l-2 respectively.
Table 3.1-1

STORAGE, TRANSPORTATION,- Present plans do not include the use of the internals
indexing fixture.
- Thermal insulation, seal plate, studs, nuts, electric
cable, coolant lines, and CRDM's should be considered
contaiminated, not irradiated.

29.

Table d.4-230.

Table 8.4-6- Volumes of compactible trash are less than half ofestimates provided in Phase I Study (Page 9-30 and
Figure 4-14).

31.

Figure 8.1,1- This Lp not a representative figure of the RPV andinternals for Tt-2.

AND DISPOSAL OF FUEL AND SOLID WASTE

In this section the PEIS refers to the interim storage facility. On site, we refer to this same facilWe call the iniity as the long term staging area.
tial inground storage area the interim storage area.

1.

Section 9.1.1-

2.

Section 9.1.1- Epicor I liners have also been shipped.

3.

Section 9.1.2- The PEIS states here that all drums reading greatertham 200mR/hr on contact will be shipped in a shieldIt is possible Co
This is not correct.
ed cask.
ship drums greater than 20OmR/hr in a normal shipmentof LSA by positioning the drums where they will be
Also, shieldedshielded by the lower level drums.
vans are available which can transport more drums
than a shielded shipping cask.

Section 9.1.3.1 - Reference is made to logistical constraints due tothe number of available Type A or Type B certified
As we may purchase or lease casks nou curcasks.
renctly available, the restriction to using available
casks should be removed. 5.

Section 9.1.3.2 - Dose limit 2 should read 200mA/hr at any point on theexternal surface of the vehicle.

6.

Section 9.1.3.2 - Contrary to the first statement, we have made overweight shipments.
Paragraph 4: This paragraph states that legal weightThis is in
shipments are limited to 38,000 lbs.
error; we normally load to 42,000 lbs. as our maximum
weight.
Section 9.2.1.1 -Change 700 to 800, 25 to 60,
0.5mR/hr to O.6mR/hr.

8.

Section 9.5.1.1 - The worst case transport distance is listed as 2,300
miles. The actual distance is 2,570 miles which will
increase the PEIS estimates of exposure to thedrivers.

9.

Table 9.1-1

Our estimates are close to the best case conditions
listed in the table, if only containment building
The additional work that will
work is considered.
continue outside of containment yields a total somewhere between the best and worst cases.

- 31 - 30 -A-93

50OR/hr to 500m1/hr and7.

Footnote a: PEIS uses 88 drums as the average load.
It is difficult to determine the accuracy of thisOur normal LSA drum shipment is 145-155
estimate.
The estimate ofdrums, dependent upon total weight.
88 drums/shipment probably assumes a percentage ofType B waste in the total number of drums.

CHAPTER 10

SUmMARY OF ENVIRONHENTAL
1.

Section 10.2.2-

factors they are
The NRC is inconsistent in the risk
Here they use ausing in determining health effects.
cancers in exposed workers per one
value of i31 fatal
million person-rem whereas in Chapter 4, Table 4.5-1,
page 4.5 they use 147 cancer deaths per million
They should use only one of these
person rem.
report.
factors throughout their

2.

Section 10.4.1-

There are two typos, one in the penetration factor
3 x 10-4) and one in Table 10.4.1 (H-3 value(i.e.
should read 1.5 x 10-4).

3.

Section 10.4.2-

Add the word

4.

Section 10.5-

Releases due to aircraft
impact on the containment
recovery service building or a tornado going throughand other
the interim solid waste staging facility
similar events should be discussed in a manner

Footnote b: Same as above except that normal load
If we compact into the LSA
will be 14 - 18 boxes.
boxes, we will be limited to about 10 boxes per
shipment.
The number of shielded drum shipFootnote c & d:ments will probably be higher than these estimtes if
The PEIS estithe compactable waste is incinerated.
mate is based on 14 drums per shipment, a more realistic number is probably 8 drums per shipment.
10.

Table 9.1-6-

The worst-case number of shipments is slightly lessthan current estimates as published in the Phase I
For purposes of worst case
Study (Figure 4-4).
estimates therefore this number should be increased.
3

I1. Table 9.1-7- This chart omits the l0ft

Table 9.1-9- This is only a partial list
such.

12.

SDS zeolite/resin liners.

DQACTS OF THE PROPOSED ACTIVITIES"not" before "support

combustion".

similar to that used in Section 10.5 on flooding.
and should be labeled as- 33 -- 32 -A-94

CHAPTER 12*

CHAPTER 11
CONCLUSIONSE£IRONMENTAL RADIOLOGICAL MONITORING

1.

in item 1 reword paragraph such that "1.7 in 10 million" value iscompared with "2 million in LO million" (vs one in five) to make thecomparison more apparent.
This should be adhered to thioughout thereport.

Air particulate samples are analyzed weekly for grossbeta activity and gamma spectral analyses are also
performed monthly.

2.

In

3.

Comment

We now collect milk samples semimonthly.

4.

According to a study compiled by the Pennsylvania Economy League,
thevalue of property assessed in 50 school districtsin Dauphin Cumberland, Lancaster, and York counties increased $76.2 million between 1979
and this year.
This is contrary to the statement in Item 6 concerning
reduced property value.

5.

No assessment has been made to determine the impact of the increased
construction workforce on the surrounding communities and the local
economy.

6.

The conclusion that "long-term or
is not appropriate at the TXt site"

I.

Section 11.2

- Our monitoring program extends out to 21 miles not 15
miles.

2.

Section 11.2-

3.

Section 11.2-

4.-

Section 11.2

- Fifth paragraph should be rewritten as follows:
Water samples from Met-Ed's off-site water sampling
network are collected from 8 stations. These samples
are composited hourly over a two week period utilizing automatic water samplers.
These semimonthly
samples are analyzed for iodine (semimonthly), gamma
scan and gross beta analyses on monthly composite,
tritium on a monthly and quarterly composite, andSr-89 and Sr-90 on a quarterly composite.
In addition, grab samples are taken weekly at two surface
water stations.
These are composited and the above
analyses are performed.
Daily grab samples are also
taken from the plant discharge and composited for theabove analyses.

5.

Section 11.2

Item 4, at what

point downstream

from T11

Section 11.2

calculated?

permanent storage of high-level waste
is not supported by the conclusion

in Item 8, which states, "No significant environmental effects are
as to the reasons why
expected".
The PEITS should be more explicit
would not be appropriate to utilize
TNT as a waste repository.

- Change last sentence in seventh paragraph to read:-the doses

Deleted.

These dosimeters are exchanged on a monthly (20stations) and a quarterly (53 stations) basis.
6.

are

A new paragraph should be added as follows:
Met-Ed has a groundwater montioring program (seeFigure 6.3-4,page 6-20) that presently samples from
fifteen observation and monitoring wells. Tritium
analysis and gamma scans are performed on the samples
taken.

- 35 - 34 -

A-95

it

APPENDIX L
APPENDIX FAVERAGEINDIVIDUAL QUARTERLYDOSE LIMITS USED IN DETERMINATIONS OF WORKFORCE ESTIMATESDESCRIPTION INFORMATION FOR SOCIOCULTURAL PROFILE
1.

Table F-I

1.

- The number of people serviced by Lancaster Water
Works alone is approximately 130,000 which
represented 36Z of the total population (1980
projection of 359,000 people).
APPENDIX C

Appendix L indicates that certain administrative check points used at
TMI to control radiological exposures are limits and conceivably
implies a quarterly dose of one rem may be established as a working
requirement.
This section should be reworded to clearly indicate thatthe requirements of 10CFR20 will be observed, that the company uses
administrative check points to ensure personnel do not exceed IOCFRDO
guidelines and to indicate that the company will at the same time
maintain personnel and total man-rem exposures as low as is reasonably
achievable.

ENGINEERING CONSIDERATIONS RELATEDTO PROCESSING OF DECONTAMINATION LIQUIDS
1.

Section 0.I.

AppendixR- Flushing with nontritiated water prior to mnual
decon is not necessarily valid.
Tritiated water may
be used.

2.

Section G.1.

- The volume of decon liquids (i.e.
appearp to be very low.

3.

Section G.2.

- The vinyl ester styrene solidification system should
also be included as an option.

4.

Table G.3.

- The basis for the factor of 1.44 increase should be
developed.

Note:

14,000 gallons)

PROPOSED ADDITIONS TO TECHNICAL SPECIFICATIONS FOR TNI-Z CLEANUP PROGRAM
Recommend modification of the wording as follows:
R.1.3 - Specification(i)

The licensee most submit a plan of operations for the cleanup steps in
the Recovery Program to the Deputy Program Director of TMt-2 Cleanup.
This plan should reference appropriate sections of the PEIS.

(2)

Procedures shall be developed for each operation of the proposed planand submitted to the Deputy Director.
These procedures must contain.... (as presently worded).

(3)

Delete or modify the paragraph for the following reasons:

Appendix N
ENGINEERING CONSIDERATIONS RELATEDTO 11OROBILIZATION OF RADIOACTIVE WASTES
i.

vitrification should also be addressed as a processing technique.

2.

It appears that the terminology in table H.4 for '"olume Increase
Factor" is inconsistent with that used in other sections of thisdocument.

Since the PEIS has concluded that the potential for off-site
hazard is negligible, the procedure should only have to illustratethat the proposal procedure is bounded by the Analysis of the PETS.

Appendix I

To carry out the calculations illustrated for each operation
appears to be an unnecessary burden on the licensee since the NRC
Staff has already concluded that the off-site safety
considerations are negligible if the operations carried out havebeen bounded by 'analyses in the PEIS. These submittals should
only be necessary if the analysis shows that the release potential
is considerably greater than that shown in the PEIS.

fUSTIFICATION FOR RADIATION FIELDS USED IN SECTION 7 AND 8
1.

Our experience indicates that radiation levels above the pool will bewell above the 2 to 3 mR/hr assumed by the NRC.

2.

The assumption of zero contribution to general area radiation levels
from residual reactor-produced radioactivity inside the building is
unrealistic.

3.

The Surry pump decontamination experience cited in Section 1.5.2.3 3i
the PEIS should be considered in Appendix I and the analyses based an
this Appendix.
The small decontamintion factor experienced indecontaminating the Sorry pump (2 R/hr to 500 mR/hr) indicates that
achieving a general area background radiation leveL of .0 mR/hr may bevery difficult.
- 36 -

The forwarding letter makes recommendations concerning
Appendix R. These modifications are proposed if therecommendations in the cover letter regarding deletion ofcertain proposed technical specifications are not adopted.

-

A-96

37 -

S-6
Ihese experiences i1lustrate that available techniques can be modified to suit the condition.
Apolinable esperience in removing daged fueland core Cno.onents is limited, hence
at .ii-d.
be required.
develooment of specific tecwnigues vill
Treatment of Radioactive

Licids

Large quantities of voter -ere contaminated with fuel deoris as a result of the March20, 1979.
att.oent. Aomitional mater. as much as 330.000 gallons, nay become contaminated if remotecashing of the reactor building internal surfaces is aemiyca. Aboul 14.300 to 20.000 gallons
on decontamination liquids, only a snall fraction uf the sus liguidcolu.. would be genaratea
Hocever, theduring the nemiremOte and hands-on aecont•mination of the reactor building.
in addition,
concentration of voliS in the wash cater mill be higher than in the ste figuids.
the presence of detergents. coop-omingagents, and organic soivente will complicate the tretement
Dependingdefueling.
duringbe circulated through the damaged core
Water vill
Of these liquids.
upon the extent of damage to the core,up to 300,000 additional Ci could be relenased to the
Circulating cater. either during dofumlingor during toe subsequent flush of the coolant system.

ATTACHMENT

None of the liquids that are currently contaminated or beome contaminatedBduring cleanup vif

The safety-related prohlmes involved in shipping the conbe shipped offsite in liquid form.
taminatad liguids ofisite Pefore treatment and the fact that the cometial 1mm-level waste
burial grocuds mill not accept liuq id astoe for burialeliminate this as a feasible alternative.
On the Other hand, if storage of highly contaminated lguids on the island were allowedas a
the liquids wouldbe a source of direct radiation exposure to the workers.
long-term solutiom,(1) direct solidification
lquc
gids can be treated by one of two general approaches:
FadioactiF
with a resultant increaseof radionuclides in the liquids
or 121 reduction of the concentration
remom tse
hereof tIe checicol treatFents
solid material,of radioactivity in a secondary
portland cement proteolymould be thetrttlue is maste. Solidification mf the liguimsin
effluentnoliguidsimplest treatment alternative to put into effect. While there would befrom this method of .aidifimation, about 10.000cumicyars of concrete ceigming 10.000tonm
Therefore, the staff does not rgard soiidificat.sn
mould reguire transportation and disposal.
It may be a reasonahle alternatiue
the liquids.
with cement a reasonable alternative for all(limhumored ouId ycIt abuilding decontamination liquids
for snal gumntlties, such as theion exchange, anmevcporeLiquid treatment steps considered can be classified into filtration,
tivo processes, Fiftrmtivn alone mould result in renOval of solids, oils, and greases from thebe highly radioactive and cpuled ot be
would still
liquids, but the resulting liquid (filtrate)
Providing edequately shielded, corrosion-rnmistamt storage
to the air or the ricer.
releasinfacilities for temorary storage before further treatment coplicates the cleanup operation
without markedly contributing to its end goals.
A procems analogous to that used In household cater softeners ia camInly used in the nu;cearlyemater is yessedthrough a column of speial
industr
to reyncedissoluem raaioncclies.
porous solid (on ion exchangeror demineralizer) and the material to be renoaved from solution
yr plastics
Ionexchanger Icanbe made of minerals (.emlices)
is collected in the solid.
The aemltes are mars stable in the presence of highradiation fields than(organic resins),
consmderasly m•re radionuclides par umit uolume. rhe Zeelites andorganic resins and rroe
resins arm often

used Incoseinationfor otimuamresults.

An evaporation and condensation step
TP feasible variations to the ino-excoange system emist,
prior to treatmnt oy r-sins mould reduce the origisal volume of liquid by about 30 times ang
Most mf the radin
the concentration of radionuclides (except tritlum) by about 1000 times.
borates o(frm the ¢Crtitality-conthrl borcn) would be left in the precipitate
nuclimessludge at andthe bottom of the eaporetor.
Further processing of the sludge would be required.
and the evaporation process coo handle
Considerable emperience emists mith evaporator systes,
Wontiningsuspended solids.
soiutioms
asphalt materiel
In another variation of the evaporator and ion-mchange systems, a flaaole
in a rather
and the resu toot, miture mould be ecaporated(bitumen) mould be added to the maotr
The resultant soI-d mould be ready for shipment offsite. but the resu tantcooplex operatIon.
haov aout the sae volume and about dna-thousandth of the radiomater contensmte eculdstill
system would
ucliions of th•e originol eater, further treooent mf this oater with a -on
be necessary, and operating difficulties mould likely prove greatersystems thom for the evaporation system.

still

for the asphalt

The abooe treatmnt procesaes con be designed succ boat the concentration of radionuciides intoeresultant mater mill meat proposed Ad limitations (SIC. 1.6.3.2)at the station discharge.
of the procsSed mater are:
Alternatives consilered for disposition

A-97

3-28
3.2 TRANSPORTATIONALTERNATIVESAMC ROUTESTHATMAYBE AFFECTED
Only the lo-len-l waste disposal site operated by theNuclearEngineering Coapany(NECO)near
Oichtand.Washington. currently Is being used for disposal of MT--2-astes. Hvoaever, sincesomeof the castes resulting from the cleanup activities aill not be acceptable for burial at thissite (e.g.. failed fuel aeellnies and certainhigh-spacflc-actioitychoice
nestes,it is storoge
necessaryandof casteultinate
to consider other sites for disposal of those castes. Tie
disposal sites for TMi-Z wastes will be influenced by political and institutional as wall as
tachnical constraints.
The general considerations and requirements for naste disposal and transportation and their
Ieplication in the Snip.ent of Th1-2wastes are given in :his section. The discussion includes
sethod of shipeont, transportation routes, and storage and disposal sites.
The environmental
impacts associated with transportation of the wastes are discussed in Section 9.

4.

MAINTENAN•CE
OF THE REACTCRTN SAFE CCNOITION

3.2.1 Method of Shipment

0.1 OBJECTIVESANv ACTIONS

The available transportation methods for shipment of the ThI-2 aaste are:

The objectives of maintaining the TMI-2 reactor in a safe condition can be suissarized
as follows:acniene"ent of a termally stableprinary system in onich the decay neat from fission products
is continually being emeved;caintenance of suecriticality of the reactor core; and confinementof the radioactivity within the reactor building.

* Truck shipment from TM4-2 to the storage or disposal site.
gail shipment fros TIl-2to the storage or disposal site.
R

Since early April 1979.natural recirnulation has been used to renove the decay heat froe theby the secondary ater transfers
reactor corn to steae qenerator "A, ohere subsequent toolingnoted that as. decay cover continues to decrease,
the neat to the atmosphere.. Hoaver, act-Ed has
thenaturalrnvirculatlonhasbecomesusceptible
tohydraulic
Therefore,
a newforced circulation system, the cini-decay-heat-removal system, fluctuations.
has been proposed
by Net-Ed
for

SInte*rodal rail and truck shipment (railshipment for the entire route may not be possible
since SOm"storage and disposal locations do not have rail spurs).
The waste oackaga ciii be shipped in a transport vehicle consigned for eaclusive use for Til-2
caste shipments.
The following 'doe feaces apply to shipment of all radioactive materials andwould apply to the transport of raioactivesmtorials fromTHi-2.'
I.

1.000 illirem per hour at 3 ft from the esternal surface of the package (closed transport vehicle only).

2.

000 1tllirom per hour at any point on the external surface of the car or vehicle(closed transport vehicle only).

3.

10 ai'1'per
Q hour at any point B ft fr the aertical plnes projected by the outer
lateral surfacas of the car or vehicla; or if the iced is transportad in an opentransport vehicle, at any point B ft from tie vertical plansa projectad from the outeredges of tilevehicle.

focedctalIthat thisprovision does not apply to private satorcarriers.

yoh_eoucoI bu•ctsd

otc
neoucan fan

tos

ffy
uoc ad novlers,dAc aenvevo

ono avac.

I

be coed.

The r9I1-2
reactor building is ieing kept at a slightly negative pressure"-4"a ^ "with,respect to theatmosphere.
IotsideThe pressure differential is naintaineg oy the operation of
the builoing' s air cooling system to 'oar the building air temperature. This leads to alessening of reactor building pressure and consequently prenents leacage cf the reactor tuilding
atmosphere to the environment.
The fans for the hoiloin's coolring syotm'e cc oherated continuously
since March -8, 1979; hovever, they cere designed to oderoceunder 100. hu'idity,0
Eventual failure can be
28k F and 60 psi conditions without caintenance for only 3 to 4 hours.
eopected If maintenance is not performed.

Transportation Routes

For the purpose of evaluating the ennIronnental inpact of transporting the TM!-! wastes tostorage and disposal sites. t weastes are assuMed to Ib transported by truck frue Ti-i to
Hanford, Washington. A distance of about 2300 roadailes. The
route to3.2-2,
this disposal
and thesite in Figure
Tilcoenletesite is shewn in Figure 3.2-1. the lcal routing around theruting leading to the Hafor site in Figure 3.2-3. This route sakes use of the Federal Inter
state h.gh1ay system eacept far short distances near the starting and temination points where
local, Ctngean lts of Pennsylvania. and State of Washington roadsaroused. In the process of
selecting this route, Met-Ed consulted the states and municipalities through ohich the castes
are being transported for specific requirements. These requirements are-being satisfied at thtis
time.

4.2

ANh REACTORi
EBUILDINGOF REACTOR
1e0NITORING

The reactor and the reactor building are being monitor"d by Instruments measuring the reactor
and pressure&and te sater level in the sc inside the building.
and building tenpereture
Experidctve have been peoxodoncd chiooShwhchL a eslet •co ame
cceod nadcov decebane
beseontcalledchrocamapenesnattosn niletoaon Stlados.

Ay..
ca
The teucun Cootactl

oacedovvovetLuouc ladtcvclon ad cha
mesitonedand peontdac ateLesaks
ca.coadovoauelpheac•ae-c htan.
It ace1,sonsope. TRhechv7iley ad tvecory
candiuadsof tie ES.coortgvie
ohacoatcc cecl functionat fc.oetnmva•checked oeeAkly. One
ctr ens
lam necoos fluolevel .

Additional sites suitable for caste disposal are discussed belol.

-to-nsuheomucuplec ac ve~l ac hoc-losand cold-ths

t:operaturedevicee one a. ttab1a to menI=
voscepenatuca
Iysce. cnside the cedos

For .he shipment of Irradiatedfuel, consideration oust l4b
be given
to January
the propose0
regulotion
the9g801.
01, TOTFR 7140,
cterialsrogarolng the higny ruting of radioactive
p'sical protection of shipents of irradiated fuel (10 CFR 73.37) ana theInterie guidance furphysical protection of such shipmenta (NUREG-0581, Ree. i, June 1980).

I

sa1cc

co.luct

4.3 OtCtO HACAMO
tfLnn
The ce"dcsydheat" refdoe to ihlnal ancnfl Sueated by rodn.oe:vo fhtsiton-pecduce- andaebec toD-coneaetenata a oarev~a choudoo od a n1caov.cn.,Theaaay heat pawn od tile fl-b ceo
Maco 28. 1919,.=.
ecu edoon G_vneauaon as tlhe hne ut .ea first ch.c doaa-a •fe•ehood had oeTed cv appeoccocoely
11, 1P0A;the d..a.boa aevenoa
160,000 kW. 3y Jacuay
200 k add chi te at bLeaarcdcoc
cotccuca h.odolalh.

Storage and Disposal Sites

In detereining acceptade storage or disposal sites for the N1-2 wastes. it
consider the various types of wastas from the dacontminatian activities.

cofcotheThe probability of recriticality under various hiyothetlcal ircumstances has been eamined
Independently by several groups.'-' Basedon these analyses it can be concluded that withb.00ppe of boron in the primary coolant, the reactorcan be maintained in a-subcriticalstateeven in the total absenceof other control aterials. The post proeonle cause of racritialllty
was found to be baron dilution, whicn, however, is perceived as a sloe enough process that any
approach to criticality can be detected and ried:

On the basis of these criteria somewastes can he shipped in unshielded vehicles, and others(e.g.. high-spelfic'-ctivity
castesand failed fuel) will reguirs shielded shipping casks tolevels.
reduce the radiation

3.2.3

uc the namenal od het.

Subcriticality of the reactor is being ensure by the maintenance of sufficient boron in solution in the reactor primary coolant; The one operable source range neutron detector it used to
Sonitor suAcriticalicy.
0 small amount of controlrod eaterial is believed to have naited duris estimated to be aobout
ing the accident. The uh-tdowneargin available. at -IlI-i
15% 6k/k.1. ,a. 2 aillirem per hour in any noncally occupied position In the car or vehicle, except

3.2.2

ce

ao:h:d. amptoy

is necessary to--amtchati
IT~n

one eppccoweeealfi 151 eca Ion -meano

,4-1

A-98

to eusaclo nocleac costa ceaoaLu

I

I

I

u

a

I

r-

4-2
4.3.1

Decay Heat Reeoval MechanismsEmpadved Since the Accident

From tle onset of the accident until 8:00 p.m. torch28. 1379, when reactor coolant pummIA wasrestarted, neat renoval froi the reactor cone as inadequate and .eeffected oricarily by
neieasee of prlmary water to the reactor building through the pressurizer reienf vilethat 00s
stuck open. Between 8:00 p.m. no March28, 1979, and April 27, 1379, decay heat was relodwith a reactor coolant puoo (see Fig. 2.2-1).3
through stem generator "Au by forced circulation
SuoSeQuent to April 27. 1979,decay neat has besn reeoved by natural convetion circulation at
aoda. This Is expected to continue
the primary water through steam generator "A0 in a steering
val system (40995) 1 i
until the operational cagoaility of the oroposed mi-decay-heat-r
Tmc
h0 tlc oy ha voed to nh
a sySteapproved.
t
ctopieely destetnated a.d ohs se ofcon.
-n-avoce0• o(latsineheat belts sos.rtedhr the core IW addition no sportoethe
_ooal
cov
orooosln comt-"osed.
In oodltoc so the het
decoy bets system i.clAtscm
t:otloesubOne. hear to lootfeem tile primary system ily heat nrnsfter to theto the total decay heat rem.oval Capability.
neacnto bhuildbin, uhoh contributes
4.3.2

3arkuoDecaylees Ieecl

S s....

through ste.e
semeade for lone-tern decoy heat nvlthe acn.dec. provontloar
FollooIfe.ae o.. coolda na be acCotpLihed by uv.a5 the "0"ln team
Th!
ool o
'. .
iaserasor
no ovor•al oorc•oltdao.
Bysyvste, doWrecersioa
eyIeom the normal ic-plact decay het
Ma..th1901 abade..y he.t tote should decrease to berceeM 1."•d 70 kl. Au this Low decay•llds., should bepee,coIC.IcnOs heat Iestrsfero the primarysyscam to the reactord!
cpyabloof •aintabinin
the coolantbeloa 200-o
without att.cs coolioo.
4.3.3

i4jdt-oecan-reemc-evnal Ivece

deary heat
road
irool
has boo. intaalled.
a 1• c-aegda1ed a method of ....
ThaSyCool co tot•roesor t tiler
the betoCO ooln
heat froe the foslt,
rasa lo 50=tocoooo-pedsroed carllol
Th 90erheat so t•hbuet
y be ueed bath for Ioag-tsr. decay heat neanaa Lveils.s during daivlren
operz lnomeTe
cv olaocn,.
Cola
Sytevt Condigured to macstaile
ha tho octor
tat 'oCil
porultand theot e-Ichansen
erneased i1n a eaer
ayem cacluda• to psaltach hnse
1 capabilbty.
ed4dact denoy hfeat re:and thus provide
tdend"eaoperatioa of icy 1. 1900. 955eonI
the Iotal daendy he•aeothaeaer hae the capab•lity t
apillraobOt.
0
nondvcted sn the systam psea helnoporatlocal t"eti
TO THE ENVIRONMlaENT
4.4 EFFLUENTS
0AN RELEASES
4.4.1

I

I

eossvabla nontaminetlas is less then b00 doe 9-y/100 c.1,I
Airiorne containation is less than the 10 CF Part ZO lemst for restricted areas.2
andnt-design values--generally 0.4 nR/hr.
General radiation levels are at pla
5.1

EQUIPMENTOF BUILDINGSURFACES
AlNDDECONTAMINATIONt

S.1.1.

Oeocrlptionof Efforts to oate

and Statusof Those to is

Cooleted A

ten and skao decontamination, which began in April 1979 and is continuing
The initial generalvs 1iown in Figure 5.1-1. Is waracted to continue at a tubstantiol level of effort unti
JSol191.
Low-rdliation areas mere treated first.
The decontamination teas
aft oony highradiationareas, such as tie reactorcoolant bleed tank cubicles, until later leceosait isOnce t1h eguipfirst necessary to remove highly radioactive sources free the tanks and piping.
onanged, the radiation Is'elsore much ower ono it becomesend tlhe filters
pset has toen fluseo
possible to proceed vith the decontamination witih •ch less radiation exposure to personnel.
fhegeneralareashad been decontesinated by April 1980;nhener, eon of thass arehave to heretreaneg periodically necause of recontamination.
Construction related to the instoalltion of
sipicrent. like the eini-decay-he.t-removal system (P0HRS). hal resulted in some additionalneodeontonation efforts because contaminated material is tracked into previously decontaminatedartas.
Leakage of barrels containing contaminated induotrial detergent, onich has now beenoorrected, caused sisilar
nrotless.
theuovementof contamination las requlred the routine
monitoring of preciously decontaminated areas and repeated decontamination when smear sevels areabaseS0d dye/IC0 c20.

Scenarios and Associatd Releases

There air tt broad categories of corprrlated accidents that could result in the release of
The firetadditional radloactive fission products from the damaged fuel in the reactor core.
sags to the escas e of sone ofis sufficient overheating or mechanical dmage (fracturing) t.ot
Maosof the rInaining fission
held .,thin fheCore.
toe redfoacclne fission products still
products are still
trapped within the fuel particles in the core and nould require very hightes..eratorts (on the order of those reached during the original arcidantl to be released line
the fuel.
Ho.ever, then may be s'all packets of sore readily relesed fistion products (e.g.
by,ecnanicai
dacmge.
The second broog
Kr-8S in a small gds bubble) that covidOs in:isesed
category of coreclate accidents it a5 inadoertent restart of the reactor with the associatedThis latter cotegory is reirered to as a recrltigenerCtlon of ne, fission productsand heat.
ca ityaccideet.
Recriticolity and accidents related to overheating of the snola core are
7
discussed in the sections that folIos.

4.4.2.1

The auoiliary and fuel handling buildings (1FHB) house equipmaet for treatment of radioactive
wastes and for fuel handling.
The general layout of tilcuilaings for three elevations isshoo in Figures 0.1 througil 0.3 of Appendia 0.

surveys of the general access areas (corridors and normally nonrestricted areas) shortly after
the occident shnwed radiation levels of 15g to SI0 nR/hr in the fuel hacoling ouilding and il to
100aA/hr in the auxiliary building.The cuelcieareas, containing contaminated filters,
tanks,
Levels excesseded 1d R/hr in som
and Pumns, in the AFOS had mch higher ragiation levels.
amee, such as tba reactor Coolant cleea holdup tane cubicles.4

Normal Releases

Accident

BUILDINGSANnFUEL HANDLINGOF THEAUXILIARY
IECC¢.TAMINATION

because of
rtstriction,it-out
The objectives of the AFy8 dacontamination are to allima &ccss
surface or airborne concamination, to minimize radiationT enposure froe goca.sources, and toprevent rcontaminacion in the event of system leaks.
he holwsoing guidelines and criteria areapplied to detemine whether these oajectltve hveo bean satisfied:

From the time wnen stem generator "A' started operating in tile steaming mode(April 27. .979)
dnttil July 11, 1980,seen the reactor building atmosphelre sas vented, about 66 to 80 C1 of
In the steaming node of
rP-65had itn saking out of the 3I2-Z Macnor building every onth.nsteam generator operation, the turOie side of tie ttee generator Is.aintainedin a partial
vacuam by the plant air ejectors.
Consequently, the pressure difference betueen the reactor
boilding voopere vod the torhine side of the steam generator enhanced leakage of Xr-8h freeThetie reactor building through the picking of various steam relies to the seCOndary system.
.
nonreoiooctlve) oars subseen-atly discharged from the secondary
Kr-Sb gas and other gases
Tfllsmounted tosystem through the auxiliary building ventilation tyStee to tie ensiron.nent.
about20% of the radloactivity release permitted in the technical spec.icetions.
4.4.2

5.

Another factor affecting decontamination efforts is the incressed potentlal of leaks fIron systtems
because of lack cf maintenancefor neorlyone year.
This problem will become core acute withtime ando-sIccblJ
tonor...i.rascctlAosduring deocstamlit.."In Deceober 1979 individual arte (cubicle) decontamination began and iS expected to Cnntinue
yntie
Joly 1981. .
The cubicleareas tend to be more difficult
to decontaminate because they
contain nouioment and sav regunre special shielding to protect workers from raoioactivo
eguipment
noUvr.s.As of htsohber 1, 1980, vay of ba tbe
foioset . -d ouvh of nhe pbph-n sillco.taIIeI
5-aao 05 poroIa Yo-vL-oI ;oomc•aes
utsh c•doanucltdes.
The final: utoroal reaucauAlHi,da•-caaminoA. -oeated 1. cake odors through July 1901, afterwhich0h.0shouldbeeAtszomptole radiationI. Iesl.

Recritic&ltty

The decontamination schedule is contingent upon there not being any unforeseen problems
dtcontsminating the remaining high-radiation areas.

Some neutrons, frge e.traneous sources and the soontaneous fission of uraniue, are present in
the core eveen.en the reactor is shut d-on. These neutrons do cause sode uraniam atv0s toin

A nore detailed outline of the initial and current las of May 1. 1980) decontamination status ofthie AFH is given in Tables 0.1 thrrugn 0.3 of Appendix 0. The areas described in those toles

5-1

A-99

-

V-2
5-3
. .
a

3

.l..

.. .

. .j"

As

I

5.1.3.2

Dry Vacuuming of Dry Floors and Eqolpment
In many areas where dry, contaminateo dust has accumulated. dry vacuuning has been effective.
Dry oacuom=g does not work well on crusted deposits;therefore, it is used primarily in areasuhere dust has not beam -atted or cru•sted.
The vacuuming involves the use'of a speciallyequipbped achine aith a HEPAfilter in the echaust streIe.
Radioautiue particles are retainedin the filters. Worker exposure from airborne activity may be increased by the vacuuming activity
even thougI most of the particles are picked up by suction.

s"

5.1.3.3

Figure 5.1-1.

Auxiliary and Fuel Handling Building Decontamination Schedule.

are identified by laies keyed to the layouts In Figures 0.I through 0.3.
Of :he 56 areas
requiring decontamination (not Includinqlhe general area). H areas were completely oecontanfnoted (exccpt for fluid transfer and filter changes in 2 of the 6 areas). ,I reguired only lignt
decontoaination. 26 were oartially decontaminated, and 7 ladreceived no decontamination.
Transfer of fluids, changing of filters, and/or flushing of lines were still needed in I8 of tne
h6 treas. It is expentho that some aaditional decontamination also will be needed periodica&ly
in tne general access areas (corridors. stairsells, etc.) because of airtorne dispersion andtracking by workers from cubicles that are stillundergoing decontamination.
5.1.2

5.1.3.4

5.1.3.5* Remnoal of all nonessential items, such as aood, tools, hoses, cords, loose eculoient.
* Dry vacuuming of dry floors and egul•pont
exhaust. caia trays, etc.) with highvacuumvasves,
filter on(piping,efficie ncy partlculate air (HEPA)
Wet vacuumnmg of industrial detergent after hand scrubbing.
Manualpino with disposable towels or oil-impregnated sipes.
ton pe.soelt nosan .00 and aulhiabo&ning strippable coatings on floors, -Walls. mortsble shields, and other surfaces.
Eletroct!ineitl decontamination of tools and small equipment.
Freon cleaning" and Freon ultrasonic cleaning of electrical naoutment and tools.
High-pressure water jet use oanfloors, tanks. piping, Ana valves.

I
I

These methods arm discussnd in mcre detail below. All of these met.iods. ecept erhaos theaaer jet, readjre the decontamiinhtfon crew to be relatively close to ohecontamination.
inareas of nigh concentrations of airborne radioactive particulates, oersonnel most be equippedaith a respiratory protector, such as an air pack or filter resoiretors.
Protective clotning
also is used to protect workers and to control the spread of contaminacion.

Details oftlectrochmicals decontamination is an electropolishing procedure used on netal Objects to remove
a thin layer of the exterior surface and attached contamination. The method employsa tankcontaining an acid solution and a oc-voltage, high-current source. At TMI this method can beused only for small objects because the electrochemical decontamination tank is about 3 ft by
3 ft by 2 ft.deeo.
,malitools and parts can be cleaned in a very short time.

The electrochemical decontamination apparatus is set up in a facility removed from the 'FhS.
Vapors from the- facility are circulated through HEPAfilterS to limit radioactive releases tonegligible amounts.
5.1.3.7 FreonCleaning and Freon Ultrasonic CleaningThis decontaomination nethod involves the use of Freon, either by spray, brush, or ultrasonicbath, to clean electrical tools and small, intricate parts. The ultrasonic bath using Freon asa fluid will remove ast contaminants, but only small parts con be cleaned in this manner.
Larger eiectrical components, such as motors and switchgear, can be decontaminated by spraycleaning with Freon. Precautions are taken to ensure adequate ventilation Ic order to miniie
inhalation of Freon vapor by workers. About flev gallons-Perrwes in the form ofcvapors arernemvadhr she Taclunywemclasdoo system. Theafhoa olaoni and.tamonafocleaoinaaqoupuns lx locuca iv ohe auaataculcoy a. s-laatna uv avuuldecocoanuua..- uaov"pomac,aod us.e she aaaela-baetos syete.
,.1.3.5 lie of ouao-Paee Wiee Jet
A hign-pressure. low-nlow-rate, mater-jet spray systemcan he used to remove surface contamisacs.. ma Sniesa Sc adaetm¢=vaad faxe On mensnio Cocaselaomm and• nodooduapamaomall,"azpoaxeaeul.
axd shoeboeaeaee oa be cl, ae.4 go"kok aca ohoeaughly..

'MethodsSelected and Associated Facilities

The details of the methodsused and any supportfacilities required for their use are described'
Alsodiscussed are limitations and concerns regarding their use. A breakdown
in this section.
of the work effort (peraon-nours) and average exposures for each An the tasks uescribed be!o"is not sasilable; howener, the overall level of effort and worker doses are given In lettlons ~.1.D.Aand 5.1.5.1. Unless otherwise stated, cornerexposure comes Prtrarnly rm,
rouloc/u froi the contamonated emniroloent-mnearby contaminated equipment and building surfoaCs
and airoorne particulates.
.
5.1.3.1 onloaa~t~ka
The decontamination crews have found tools, loose esolpment, barrels, oxces, staging, cahles,
gather than decontxminat.
hoses. w000 pallets, and other miscellaneous itemsin manyareas,
theseitems is place, the crews have moved thenito staging areas for aleaming andeventual
afdf(ijd
A d " jSala
goodme..of she C.1 hb bashe
dPe.sad xd aa U.. cIesa.
of
foat
cbs
cen
a ehobdhnsamcos
ca clanstm=s lvosbme "luu
Itaosva
iv asaoa

Removong Strippable Coatings

This method involves the application and subSequent removal of a strippable coating. As thecoating is removed. it takes with it the surface contamination. Strippasle coatings are usefulon portable shielding, making it easy to deccctaminate.
It involves close marker proximity tocontamination, but there Is less likelihood of th. contamination being spread to other surfaces,such as clothing or gloves, than for manual miping. Strippable coatings are commonly app ied todecontaminated areas to facilitate subsequent decontamination if recontamination should octr.
5.1.3.5 Electrocherial Decontamination

The phosphoric acd In the decomtaoination tanks is recirculated through a filter that accumulates much of the contaminated solidsremoved from the surface. The major limitations of thismethodare. that the objects must be metal, they must be small, and they must oe renovaole.

Various combinations of the decontamination methodds are sale cted by decontamination personnel tominimiee exposure and maximize effectiveness. The cecontilnatiol. personnel rely on theirex;erience and testing in somie cases to determine the best ,ethod to use for each particular
task.
S.1.3

Manual Wlping

Manual wiping, a worker-intnnsiue techniqxe. nay be used to remeve dust and accumulated contamination that cannot be vacuumed. Disposable towels or ail-impregnated wioes ordinarily ore used.
This taunnique recuires morkers to te close to contaminated areals thus the exposure may behigher than for semiremote techniques, such as macuuming.for a given level of contamination.
Manual wiping is normally used only after radiation levels have been reduced by gross Jncontnmination uSind other methods. Thi. coshodU
On .1..
also ..use
ad to.ooacOn
L.apsanuuiy daxont•ucaad

Methods Used

Aoprooriate combinations of standard methods have been used in the decontamination of the AFHf.
The following metthods havu seen at least limeted use, with the first ts.vausedOrnootnimntlyl

Wet Vacuuming

Wet vacuuming has been the primary method for decontaminating areas where contaminant$ adhere
tightly to surfaces.
The method involves scrubbing with water and industrial oeterments andthe n cetuccuuming the resulting solution. The easo solution is stored in barrels until it cam
be solidified for disposal.
There have been limitations on the types of cleaning compOonds usedsince their effect on the solidification process has not teen fully,evaluated.
TO cate, only
one co""'ercial
detergent has been ,pproved. The scrubbing is a sxow and tedious process thatbrings woroers into close conact with contaminatad wash solution.

Itane chin oaoucoadcotenfo.

A-100

I

7

on EW

0 an 0-0

1 E

N 'A E

-NEN"

5-4
5-23
two eater-jet units are Available unsite at ml,1.2for eoontalnhating the -FHS. One operates at
And the Other at 10.300 osi. The .ater flow is relatively Ion,
A nominal Pressure of 1200psi
for one 120 051 unit.
About 7 OenI

5.3

The purpose of desludging and deeontamination of the auxiliary building sUMe and tanks Is todisoose of the contaminated wasta solids and sludge and to decontaminate inner sAee ad taootosurfaces, to dc a eaddatos lInits. rhe objectivo is ta rescore Etn Sinop anoonacasks.
a condbolve 15~' hluh they cna be -oe for subsequest decvrse

Use of tne water jet was limited odror to 4arch 1980because of restricted water usage.
It isnow.Sng used enensively vitnwater proress. d by EOICOR:t. Use if this processed later,
rather than udwitional uwter neuwedinto the facility, hes reduced the water inventory buildus
and ermite eweensive
use of the outer jet. Tests Of the Itesoheric contamination caused Oy
use wf processed wooerhavebeen conducted with the water jet In closed ouarters.
At saturation
conditions roetritlun level vas aporoxlimtely 10 Percent of the 10 C7R Part 20 liito.

5.3.1

Work Effostfer Ot

amloa

of the inlet and
The prncedure now in use for tank and filter desludging starts with replacemmot
outlet filters, as required. The tank then is flusned seneral timhs and that portion of thewith a portable recirculating vacuum filter
tank sludge entrained with the ater Is collectedof the tink
the
walls
caked
to
that
Is
SludgeSystem (ROPS) with dilsosacle filter cartridges.
can be dislodged with a high-pressure water jet and then collacted
in thethe desludging
RVFS. Standpipes
effort.
(drain pipes that extend above t•e bottom of the tank) may coaplicata
Pumps, valves, and lines need to be dr.onteminated.

of the AuwtltYansod uel Haendling Butldings

Dosin the peatod free Apr01 13, 197, tbhrough .voemhr 1. 1979, ehe.e care SO I-sov- dolog
dstcosamutont
wck losi.dthe awodlusry as? duel hendllng h•uiding,on a schedule of a
Il-bowsaboes per uy; tram iloveaser 1. 1979, throsh Siepteaber1, 1900.tie work Earns
LOa redoued ta 50 persons dolng decontanodsam
twook iasde the Allis ow evoedeulewo ion
10 vows sho:sa pee day.

asd cwontooced drain colks hb•dbees
tros taonos
usof leptesses L, 1•80, the vmdsJsa•sec•lesed. The cI¢eaut wodek,eeue.c- far deelosdgo oa 'te ranks a•d aesooo eqolpeast
ATos.31
is ahaa IA
The following Systems in the auxiliary and fuel handling buildings (AFHi) may be required for
primiary coolant system and reactor building decontamination:

Completion of ties Joe deossaUottascon efoo.t Is scheduled by lis-c? losJuly 1.981. wiha Jeateseed affort through deme 1981. The -etk from•SOpe-es 15. 1980 tliough
1-ce4e2r L981 sle be o ew by a .eoal of 13 POp..ea.
d.1.4 Effluents snd Releases to the Envirornent
5.1.4.1:escriation of Efforts to Oate and Status of Those to ce Comeletedof theentaminiatedwoter and sludge were pumped through mny
after inthetheaccident.
end
turing sod
susiliory tuilding. Filters In sopee of the lines became clogged and were
tanks
pipes
ost of this contaminated material is in thesuesa.uentI bypassed in order to maintain flows.s
ausiliary buil wingsoue,the suoatank, and the miscellanetus 'sste holdup tank (see Figs. 0.1
through 0.3, Appendix 0 for the locations of these tanks).

A los Pressure has votes `mSi
aso .ehlns
Owused to djssolve ehelneols Is the walls,
floor., sod iO=pons:eo. ThIa system n effecot-t to dissolving dried eornn deposlta sod
voetro.il•orarboe ownsttono.
This -shod l" used priot vo high proeaw.e vaoer-je
spray.
,.1.2.18

OF AUXILIARYBUILOIhGSSMPANDTANsSANDOECONTA141NATIONtESLUDdING

hyoral Operations

Reactor bleed holdup tanks and associated equipemnt
Reactor coolant pump water cooilng and seal eatersystems
Miscellaneous wante holdup tanks end associated equipment
Coolant evaporator system

Planned operating procedures fardecontamination of the AFHBwall not result in initial liouid
releases tO .the environennt. However, depending on the irocess alternatives used, the resulting
lwlAuds ultieately Oy ae released tothe river or to the atnosohere, or they ny be solidified
ano snitped offslte. Whensteam or clean voter Is used as the decontamnation cedlue,theresulting solutions will be treated along wsth the radioactive
oaterIn the auxiliary building us
descrIbeo in SectIon 5.2. ResultIng releases to the river, Should this option be authorized,ar, viecussed in that section.

Oegasification systm
Fuel trensfer ports and eachines
Fuel storage pool and handling cranes
Canml cooling and purification systeps
Other handling eguipment.such as cranes

The estim etdairoorne releases from decantaminatloc activities are listed in Table .1-I.
The surface area inside toe APSI that had not let been decontaminated as of May 1, 1980, waseseinito by the styff to Oe about 40,000 fto, and the average level of contaminatlon of thisarea was estimates to be About ýO,00 den/LOO =2 (see Tables 0.1 through 0.3, Appendil 0).
these values lead to an estimate of 0.203 Ci for the surface contaiienatlon remaining In thebuilding as of lsay1, 1980. The-staff assumes toatthe mixture of fission products In thissurface contaninatlon is similar to that of the water in the resctor building sump (see1ev.8.3,1 According to the licensee's
Iesimate(Fig. 5.1-l), thetIme required to complete
the deconcaninatian would be scoutnine months.

sll bh used In the boeLldm oa processed voete, aus other liqgde. they w0l1
hexeseyse
require oddltlosrldecnrraAUmmtln followlug sesoar d.fouloe us?decvmtalwulv of cbs
lanning probono
3doag. A. the dSfUelbag wnddePonramuooc
primasy eyet
adSectrt aa .le sscLAass
w foedesy stemvnIll be
are esm. . it pa• be date r So'd shas o cherIf so, the additlonas syst an c.sbe deonteminated and dasiudged also.

Too oathcays of release to the building ato•asoere are possible during dry vacuuminge (1) dlsturoance of contaminatdo surfaces In which case it Is estle-oed that 0.1% of the naterial
becpmeshirtorne), and (2S the effluent from the single-stage HEPAfilter (penetration fraction
0.001) Attached to the vacuuming device. The -sternal released to the buildlng wo.ld pass to tce
air-cleanIng system, consisting of two stages of iErA filtration naving a penetration rating of
ta-0i
m TThis is based on a penetration of 3 10-" per HEPAstage, which is considered to bereadil y acinvoaole.

5.3.2

It should be nohesized tat for safety evaluation. 8RCRegulatory Guide 1.140 allows only anuitraconservo e penetration factor of I0-& for tie entire exhaust system and then only If the
HlPA filters test In-place to an efficiency of 99.058 or rester. Thus,the guidegioeen
additional credit for AEPAstaoes in series.
iqgorous apnllcation of the guide woulo result in
an increase of toecaues In 7aw)e i.1-1 of aoout 1.1 - O0 .

Criteria for Selecting acceptable alternatives
for sludge remmovalare:

Alteroative Methods Considered

The deslunging And drcontaminetlon operations mey be broken do-c into the following tasks:(I) removal of the sludge deposits and decontaminato.. of the aroas from which the sludge Is
ronaved, and (2) inmrool!ization of the sludge in a fore suitable for disposAl.
5.3.2.1 Removal of Sludge Deposits end
Aecontmaination of Underlying Areas

The procedure Should not have a destrctle effect on the surfaces from which thesludge is removed.
Radiation exposure to rhe workers shouldbe as low as is reasonaoly acilevable.
Standard sgulcenetshould be used, unless such equipment is not available or large
overall reductions in worker exposure can be attained ,ith special equiorent.
In apolying the last criterime, the impact of the delays that would be involved in designing,"Atitractlng.
one testingnew equipent Is an ieportant consideration.

A-101

IrazT

5-25
5-26
The alternatives for sludge removal may be divided into the followlng categories:

The Sump. :4 ft side by 20 ft long. is 3 ft deep at one end and 0 ft deep at tthe other.

Dissolve the sludge so that It can be removed as liquid casts,* Remove the Sludge by mehanical means (scooping and scraping), or- Resustend the sludge as a slurry that can be reserved as a liquid.
- FThte the sludge through a fill-_I., sys*a- deca-ting the.oter back to she tank. a4 usmps.
Dlssolution of the sluoge, Which Consists largely of calcium sulfate and various silicates,
muid require strong reagents that aould damage the underlying surfaces and the drain naroware.
This alternative would be, therefore, reasonable only In the circumstance of a prior decision todecommission, which is beyond the scope of teis document (see Sec. 2); hence. it aill not be
considered further herein.

I

The Amountof sludge present in the sane tank also Is quite uncertain because
tle interior Ist
not visiole; It is a5ssOa by the licensee to be on the order of S to :oft . The radiationlevel at one end of the tank IS about 20 R/hr.

The following alternative methods for removal of the sludge by resuspension have been considered:

The total sludge in the remainingtanks Is assumed by the licensee to te about 10 ft, om less.
These tankS include the reactor coolant bleed tanks, snich constitute About three-quarters of
the total liquid storage capacity in the auxialaryilldieg.the spent resin tank, the concentrated waste teak. end otler tanks Identified In Figure 5.3-1.Table 5.2-1,any Figures 0.1
througn 0.3 of Appendi1 0. Desnudglng of a tank cannot begin until most of the liquid etehin
the tank has been processed or rmoved.
Liquid foteac
iutotn.ooac
hinad csk.e u,
A 5, andhaa.eoseecd
luedgtecoses prooeemd ester ha. deoreesedthe raianiam lends
andeesothe elude
ban otheeauidiasuma
auxiinr
Istd0
The estimated total volaur of sludge In the tanks and thet suep in the auolliry building is 255
to 250 ftc. For a sludge density of 1.6 g/mL- (120 lb/ft ), the total maignt ofaet sludge to be
removed, fixed, ano stored is onatne order of 20.000 to 25,000 pounds.

ResuspensIon and removel of the sludge by means of a portable recirculating vacuum
filter system,
Resuspension by flushing and/or backflushing and entralment of the sludge on tile
Inlinefilters using existing piping and pumps.

The second alternativeis very efietlva for those tanks containing small fractions of sludges.
The mrker radiation dose that wmuldbe required to CanAge the inline filters-on mhichthesludge "asCollected would be essentially the same as for the underwter vacuum system. The
agltstios wouldbe less thian for the first alternative, so that the sludge renoval would be lesseffective, and ther woauld be a greater likelihood of spreading the sludge to other parts of tle
system. 0 eign-pressure caterjet also could be used to loosen and remove caked sludge froesurfaces and, if necessary. to assist In resaspending the sludge ohen agitation from rcirculation or fromthe vacuum system is Insufficient for this purpose.

Estimates of the suspended solids, oil and grease, and radionuclides In the auxiliary building
sumn snd somp tank and reactor coolant bleed tanks are given Is Table 5.3-1. The concentrationof radlonuclides in the filtered slids IS assumed to be the sea as for the sludge, which isforeed by settling out of the suspended solids. The vessels could not me stirred for sampling;
nevertheless, the sump liquid contained about 300 9/L of suspended splois and the sump tank*liquid about 10 g/L. The major elements in the solids mare Ca, Pg Fe. SI. and S. The latter
prv...ly
J, s sulfate fi-nthe thilosulphate used as a wash In the auxiliary building to Suppress
colatilization of iodine after the accident. The other constituents are representative of
tenant and perhaps corrosion of steel.
Lesser constituents mere K. 1AS,Al and some d' (perhaps
froim
galvanized surfaces).

The staff did mat consider methods that mould require the design and development of ntl equipment because they arm not Awareof any such methods that would lead to a large reduction inworker radiation exposure compared to the aOove-described methods (for which corenercial equipment iS available).
If, during the course of desludging and vedontamination. now nthads thatwould allow large reductions in morker exposure became known, they could be considered for use;
5.3.Z.Z

Decontamination of Desludged Areas

Oece tee sludge has been removed. the deconta•lnation procedures that must he used en thedesludged euionent are essentially the sam as for any other surface. Alternatives for surface
decontamination are considered In Section 5.1.
5.3.2.3

Table S.3-S.

Stabilization or Encapsulation of Sludge

Concentration of Suspended Solids, 0l,
Grease, and Radioactive Materials
in Auxiliary Building Sump as Determined from Liquid Samples
Taken on January 2. 1980

The alternatives coosdered for stubllizationor encapsulation of the sludge in a fore suitablefor disonsai are:SampleCnct immobilization,
Bitumen mmobilizatlon.
andProprietary vinyl ester styene systems.
These alternatives also mas considered for processing of sume liquids frem the reactor containment building amo reactor coolant system (see Sets. 6.3, 7.2, and Appendices K and H).
5.3.3

Details of Pioposed 4ethods and Associated Facilities

The sludge in tieauxiliary building sues Is largely tenentresidue from an unfinished cart of
the flooeand in she floor draina noddrain piping eith a admoscurs o usn-ooahsnaa
rests
beada from a spill prior ch the accideao. Theaccident c uaed anding noadepso ad abaun
6 L-u•heT: largus pAocs n"of the saudge was ashed into the 90O0-11ilcocep
the,eceIbantou
I by
Oloading. inoe here she eiudrr _ea pumped Intoboth she usm tank sa tha
was.t holdup toAk.'Swaller

anndJarY building.

Amiungsaslug
Ai

wy he present

ther

boa thie hae wc beam asndli ed by dirSet. eual auttSo.

ckaI

It is assumed, on tie basis of testimates by the licensee, that the iiscellanecus waste holdup
tank contains Aouot 12 to 15 ft of sludge.
This tank is being used as a rend tank for the
EPICCRI, operations. The continuing need to use the tank for this operativn my celay Cesludging and decontamination. During the period fromAugust 1979 to April 1980 the rodlatien levelnear tie tank rose from about 5 a/hr to about 30 R/hr as a result of sludge stiunssation due toliquid transfer in and out of the tank.

If echanical rermval were done by hand, using shovels and scrspers. the radiation exposure to
the workers would be much higher than for the other alternatives. Mechanical devices for
scooping and scraping that would permt semirenote or remote operations are not avaole asstandard equipeent and would. therefore, have to be designed, constructed, and tested.
On thebasis of these consideratione and the criteria listed aOove. whanicoal removal also was deemedunacceptable and not considered further.

*

The
Sotteeslopes toaarw an outlet yipe at one end, ehere the sludge is Z to 3 inches deep; at theother end tee sluoge cuses up to a depth of 12 to 14 inchles.
The totalvolurmeof sludge in thesemd is estimatea to be on the order of 200 ftl. This volune of mat sludge vill yield About 40
to ho fti of deeatered Sludge. lenrin also are present in :hesusn. A i-incn nose. a li.-inch
Oadiacicl levels vary io=
Raced."
iodeanoi a ce:porery sumg pumpmvan-beestoreao"e,2 0/hrtocm Ve
ht
didereot Incluotna in the wvivu ty ad the e-mp.

I

In seeA-102

Suspended
Solids(gg/(L

511,
IreaseCa-13dSump as receivedo

290

2.4

Sump. Supernateb--

Sumb. filtered solidsb
0
Sump tank, as received

9

Sumptank, superstec
Sun tank, filtered solidsReactor coolant bleed tanks,
as receivedo

..

0.24
..

28

qsdionuclloesa
Cs-13
Srn-di Sr-O0

Pu

140

2.6

13

170
0.7

8f 0
3.7

120
-

so

1

0.8
230

4
1180

0.14
300

0.1
260

1.5

2.2

0.2

S
0.003
S
27
1.7
0.7
0.01
'Jnits are CIj/mL for liquids as received and supernate and uCl/g for filtered solids. except Pu
is given in parts per billion.
boak Ridge National ILaboratory Intralaboratory nsa from 4.D. Shultz and J.A. Carter tot R.E. Brooksbank, January 10. lO9.
.etter from J.H. Carter, Oak Ridge National Laboratory, to R.J. Mctoey, Me-•raolitan Edison.
March 10. 1980.

I

0

Table A.l.

Continued
Initial tevels

Locationa

Area D

rpton

E4

Makeup PuoqC

Ft

Neutraiiaer
Tanks

Ft
f3

econtmination Efforts/Status
Respirators used.

initialpass

Surface

RdiationContaminationePresent Levels
Surface b
Radiation
Continaton(see<h .0i 0

1.2.4

150d

3.000

1,2

tio

reduced swears to 5-10 . Lightdecon needed.
Water was cycled in and out of

RevanInngEffortsefootnotes)

Itanks reducing dose rate At doorto 45 mR/hr.

Meatrflizer
Filters
Aeutraluzer
Pump Ra.n

150'1.000

uiO-

I0A

1.000

c40

h5.00A

Oecontaminetion coumplete.
lhis room decontaminated severaltines, stiil
requires additLo.aleffort.
PipIngneeds flushing.

Reactor uolat
Waste Evapura tor

Further light decon required.

MI

Reclaini
Acid lank

decontuminatliu
completedaith supplied air.
Subsequcet
passes reduced ievuls further.
Maintenance iv progress.

,iO,

IZ

ReclimsedBorlc
Acid Pa,
5

Sane status

10u

50

.S..000

Ji

Spent esinlank A

Seven decontamination passes redoced irees to about 2X DPM.
Final decun to be completed priorto addition of cleanup resin.

.Ig-

12h

uiAAA

J2

Spent Resin
Tank 0Six decontamination passes induced lenels to 2K liPH. Finia
devon to be copleted prior toaddition of cleanup resin.

'106

30

4.000

J3

Spent Menlo
Pop R.•u

Seven decontanination passes reduced levels to I1.K OPM. This
area used for Radiac aash drum
stvrage--total decon required
prior to transfer of cleanup resin.

,to06

5

,l.O(0J

as "i.

,1.

-5,000G

runsrc Initial

6
40

'24

2

'iR

2

3

6

!'

TabieAt1. Decontamination
Status fortlavation201 AS Of naS.VaEV"r080iot
I

LocationaA

Area Description
Liquid Waste

Initial entry made with Scott Air

Irancsfer Pap
Entrance Way

Packs.
Radiacna1h.decontaminatedTo door.

R.pinerandClianualiae,
filter52

Cleanup deineriii er andfilteraDecon niI require disposal of spentresin In spent resin tank, transfer
of cleanup dem.n resin, change
filter.
No action taken yet.

C

Liquid Waste
Transfer
Poppa
7, fPo.

as ham beenbd.111-lo-~A~
or.ssdA-v
toe
matenu~asnc.

t
Evaporator
Cuodensate lest
Tanks

Floor drain removed. Radlan nashused.
Meconcomplete except for
filters
and moturs.

El

Makeup Pamps
Entrance Way

Entrance ways to all MP cublones
have been decontaminated but
require additional mork.

Et

Makeup Pump A

Respirators used. Gross deconcompleted; light decon need.
except for atrain-, andor.

-'See figures

Makeup Pump M

0.1 throughC~l/hr.

At cubicle door.
'At entrance to vault.

0.3.

0

vi 1
5.0Q

Macsocomplete except ftr deIinerallcer resin.
First persoenel
respiraentry mitk supplied air,torn later. ,ydrolaser
used.

RI

E3

4

Decontaefiation Efforts/Stanus[It TATLevels_
OurfatA
Radiation
LeueitCoenamlnat meD

65.000_&Present levels
Surface
Radiation
I
Level'
Containinatlen
5.0CR

2.4

'i.0001O.00d

P2,3

250

I

50.000

I

2.4

sio'

x104

G..e. d..uanempilt.

I. Further decontamination required.
2. Transfer of feluds, ehanginA filters,
flushing lines, etc.
3. Complete decvntaeination required-not yet started.

Rniingn fforts(see fuotnotes)

10.0003,000

10.000u5.000iOA0.OR

ntS.ORA4
sS.O004.

Light decontamlnation5.

Debris removal.

6.

Recontamlnation coexplete.

required.

t.2

II. 1g9o
Table 0.2. Oecontamination Status for Elevation 305 as of Sepsnnibne

Locationa

Area Oescriptlon

A

Intencite
Cooling Pumps/
Seal Retoin
Valve Rocu
Makeup flonter-

ST

Oeconatednatlon

Initial levels
Radiation
A
Level

Surfacealon
contla tia

Efforts/Statco

2.500<S.,o0Hi1h level decont, nsloatlone e,plete. Filters cihanged.

S000,•i00'5.000< A

ho entry to date.

10.00

'10'

High level deConutavinationdone.
Spill area and ho t spots require
Iters Changed.
further work. FIl

I

Present Levels
Radiation
torfaceLevencConta_ i Iation

No entry to date

ReLion nyEffortn(see footnotes)

n3O

I

5,000d

2.3

'302

2,4

10.000d

2.3

alianroGas Anolyavr
Ron
Makeup Tank
and Filters
Spent FocI
Cooler Area

C
D
E

Fl

Spent F"elDOu-inecaiiaer

f2

Spent Focl

<I,000100

oopleted. Used
Decontainatloo cc
dlIac wash drums.
for storage of hac
Construction area.
Previous Radlac
Oecoetamlnated.
droo,storage area * Filters needchangeout.
D.contai.inated. Aliters changed.

o4,100001.000filtersGI
G2
G3

Waste Gus
Tecay
Snk
haste Ga- Filter

floor deco9 compl, ete.tank
Inspected.
ink Inspected.
Decon cooplete.ta

10.000WasteGas Decaytank

ear coapletion.
OecootauInation nc
Aaiting final inst pection.

2,020

1.

Further aIecontamination required.

0 con
bhWM//
15

2.

Transfer of fluids, changingfilters.
flushing lines, etc.
Complete decontmielatlon required-oat yet started.

cihtrai:cc

eat

to

3.
aoit.

4
4

'1.000iSee Figures 0.1 thrrugh 0.3.

cmw/ hcr.
d't cubicle door.

o4

0t,00001,0004. Lighti decontamination
S. Oebris rocunat.

required.

Decontamination complete.

6.

IC
-e

Continued

Table 0.1.

Present Reve!s_Initialevis
tocationahiAa Description
Orue, Storage

Decontamination EfIorts/StosOillliakeup "atnSReoons[itrance

Area cleaned And decontamiinated2.
Construction overhead, some finalWay

dec-o may he needed.
Hydrolaser has been used on flooraith good results.

"Makeap Valve
RocAs Acoess

L3

CorridorEast VOlAe

L4West Val..

Radiation
teleicvIS.000
020,00'10,000

3

<10'

'250

e30,002>106

100'20,000

M2

Entry Way

Sone decontamination comipleted

RI,
12

ileed Holdup
tanks.o.p.eca.
Gnoand.consa.hitvton

01

Auxiliary SOO

Sump needs desludge, total clean
Priorities being estaband decon.
lished on shielding. desludge, andFilter,decce.
iiydrlaodser used.
changed.

02

AuxRniiry Suon
taick

Trvosfer of oater frAl sonP tank
Uidrolaser
reduced dose rate 400.
to be used for final decon resultIng in low exposure. Tank dovician conenced

03

Auxiliary Soup
Val ooo

Hiiit level

decontamination done.

ReengEfforts
soe Icotctev)
6x1.0002,.000Iydrolaser has been used on floor
with good results.
0igh level decontamination has
been doii. icydrolaser used.

Radiation
Lovelc4

Itydrotaser "as been used on floor
wlth good reuoits.

Roomb
Surface
Contamination

702

Aoun Is beingused to store Radiac
wash drums and floor dralis straihers.
Storage shelves and unldentilied
Room sched.
bones located in room.
drians.
transuied for decon alter
ferred to solidification.

K

t2

Surface
ContalnatIon

.1

:i

00

3,300

3'

1,202

-

'200

1

'200

1

0
<200

I
5,000

I

2,000

1.2

'50OAOQ
1.5!1ATTAC-MOENTCPEIS - PRELIMINARY RECOVERYSCHEDULE
AND ASSESSMENT OF COSTS

f' f

The preliminary revision to the schedule for TMI-2 decontamination and
- C
-o
C

fuel removal reflects the impact of regulatory constraints,
PETS approvals and the processes described'ability of funds for cleanup.

2in

It

r

C

o
C

CO

-

a

.

our baseline schedule issued in August 1980 with the Project Estimate.
isconsidered reasonable to anticipate that the schedule extension offinancial constraints.

opreliminary assessment of the costs associated with the scheduleCA•extension0

and future funding constraints is expected to increase theIoThe effects of these developments resultsmonths may be conservative because of the continuing regulatory anda228
5

including theand the avail-a projected removal of fuel in August 1985 versus April 1983 as depicted
in

.-

S98

in NUREG-0698,

baseline estimate by about $150 million.

The Project Estimate ofAugust 1, 1980 projected a cost of about $400 million from 1981 to1985.

Added to this cost is 1979 and 1980 costs of about 200 million

and now an estimated schedule extension cost of $150 million.

U,

Z

This

results in a preliminary estimate for cleanup cost of about $750 million, in 1980 dollars.
If the inflation rate is assumed to be 10 perent per year, this would add about $250 million and bring the total

K116-2 cleanup coats to approximately $1 billion .
the $300 million of insurance coverage.

01-A

A1-105This is $700 million over

Metropolitn Edison Company
Post Office Box 480
Middletown, Pennsylvania 17057
Writers Direct Mal Number
November
TLL 594

14,

1980

TMI Program Office
Mr. Bernard J. Snyder
Attn:
U. S. Nuclear Regulatory Commission
20555
Washington, D.C.
Dear Sir:Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73
Docket No. 50-320
Programmatic Environmental Impact Statement Comments
Please replace page 2 of Attachment 2 to our TLL 578,
with the attached page..

dated November

7,

Also, the notes on-the PEIS Recovery Schedule on Attachment C to TLL 578
should be replaced with the following:1.

Studies are underway to re-examine the schedule logic
and alternate approaches to or sequencing of cleanup
Such studies, along with anand defueling activities.
increased understanding of conditions in the reactor
building, may result in future changes to this schedule.
Sincerely,

G. K. Hovey
Vice-President andDirector, TMI-2
GKH:EDF:dad
cc:John T.

Collins

Enclosure

Metropolitan Edison Company is a Member of the General Public UtilitiesSystem

A-106

1980,

CHAPTER 1
P,
INTRODUCTION

Metropolitan Edison Company
Post Office Box 480
Middletown, Pennsyleania 17057

MT?ýy

Writer's Direct Dial Number

1.

Section 1.2-

Last paragraph on Page 1-3 should be updated todescribe conditions observed in recent containment
entries.

2.

Section

1.3-

First paragraph requires updating to the latest
released cost estimate and schedule.

3.

Section 1.4-

The PEIS should be modified to make it clear that the
NRC does not necessarily agree with the publicconcern as stated in the tabulation.
For example, wedisagree that cost of alternative methods should not
be a consideration.
Cost always has to be aconsideration and must be considered with otherfactors.

4.

Section 1.5.1

November 26,
TLL 627

TMI Program Office
Attn:
Mr. Bernard J. S
U. S. Nuclear Regulato'
20
Washington, D.C.

.d Nuclear Station, Unit 2 (TMI-2)
iting License No. DPR-73
Docket No. 50-320
Programmatic E:svironmental Impact Statement Comments
Three Mile I
Op- Requires updating to describe recent containment

6.

Section 1.6.1.2 - The 10 Ci/ft

sion

Dear Sir:entries.

5.

1980

3

loading for organic resins should not
be used as a limiting factor.

Please replace page 21 of Attachment A to our TLL 578,
1980, with the attached page.

dated November

Section 1.6.1.2 - Proposed 10CFR Parts 60 and 61 are proposed regulations and should be treated as such.

7.

Section 1.6.2.2 - Change Permit 2275214 to 2275724, with amendments;change January 19, 1986 to December 31, 1986; change
December 12,

8.
9.

10.

Section 1.6.3

1981

to December

31,

Vice-President andDirector, TMI-2

1981.

- There appears to be a printing error in the text (topof page 1-26).

GKH:CJM:dad
cc:

Section 1.6.3.2 - The criteria stating that doses from the previous year
must be added to those estimated for a new activity
is too restrictive.
The new activity doses should be
added to previous doses to-make up a total 1 year
dose, not 1 year plus the new activity.

John T.

Collins

Enclosure

Section 1.6.3.2 - The PEIS proposes modification to the Technical
Specifications to request the licensee to calculatepotential offsite doses for each step of the recovery
process.
Since the draft PEIS concludes that the "healtheffects over the period from the on-set of the accident through completion of the cleanup operation will
be non-existent," it does not appear to be a usefulutilization of the licensee's engineering staff nor-2Metropolitan Edison Company is a t,•mter of the General Public Utilites System

A-107

7,

40.

Section 6.6.3.1-

If solidification of the zeolite and cation resin is
not required, these beds can be loaded with 10 ft.3
of resin.
3

The mixed bed vessel has a volume of 195 ft.
and3will be loaded with approximately 155 ft.
resin.

November 4, 1980

This comment also applies to Table 6.6-9.
See
comment 19 on chapter 5 section 5.4.2.2 concerning
relative waste volumes resulting from solidificationof organic resin with vinyl ester styrene or cement.
The text of 6.6.3.1 and table 6.6.-9 should be
revised accordingly.
41.

42.

43.

Section

6.6.3.4--

Section 6.6.3.5

Table 6.2-1--

Dr. Bernard J. Snyder, Program Director.....Three Mile Island Program Office
U.S. Nuclear Regulatory Commission

Washington,
Dear Mr.

It is not clear how contamination would be controlled
at the baling station while compressing sheet metal
and mirror insulation.

Location and Source
347-ft.

305-ft.

Elevation
Plateout
Sump Water
Elevation
Plateout
Sump Water

Stairs No. 1 and 2
Plateout
Sump Water
Notes to theb0.1

to 0 . 2 c
0

0.2 to 1.000.2 to 1.000.1 to 0.2d

0 ,2-to2. Where will the high and low level waste materials
It is general Znowledge
from the Unit II cleanup be sent?
that the Hanford Washingtcn will probably not be available
after 1981 for nuclear plant waste. (NFUREG 0732)
I was glad to see that you had a new map for the route
to be used for waste transportation. (Question 110)
However,
I do not like your answer, "Currently the truck goes...".
What about future use? Will you use the route shown in
the EIS draft?
On page 2-1 you state, "Itis unlikely that the site
could be qualified as a candidate high-level waste repositorysite because of such factors as nearby population densities

1. 0dtable should be changed as follows:

The skin dose rates are for workers not wearing
protective clothing.
Clothing with a thickness of
2
500 mg/cm is sufficient to stop beta radiation'from all of the major plateout sources except
Y-90, for which only 95 percent of the beta
radiation is stopped.

c

From measurement
1980.

d

The staff assumed
about the same aselevation.
- 21 -

made byand hydrology.".

TJL~schardisturbed many of us.

What isthe difference between site selection for high level waste
and site selection for a nuclear power plant? At a meetingin Swarata Township John Collins stated that it is possiblethat we could have nuclear waste at Tlii for 50 to 60 years.
To my children and I this represents a rather permanentstorage site.

licensee on August 15,

that plateout on the stairs
the plateout on the 305-ft.

Snyder,1. Why has Cumberland County been left
out of the total
You have given no information on the population,
Please use
geograohy,etc. is given for Cumberland County.
the 1980 census statistics
instead of 1970 census statistics
for the final EIS.
11o mention is made of two major military installationsin the area - New Cumberland Army Depot and the Mechanicsburg
Navy Depot.
What would happen if these facilities
were forced
to close because of another accident at TII Unit II? Many
employees of these depots did leave the area during Ž'arch 1979.
It seems strange to me that you discuss Lancaster and even
Gettysburg, but do not give any consideration to these military
installations.

Skin Dose Rates
from Beta
Radiationb(rad/hr)

0.1 to 0.2
0.4 to 0.5.

EIS (3-191?

follows:

Whole-Body Dose
Rates from Camma
Radiation (rad/hr)

20555

I _'now that the NRC is interested in our comnents andAfter reading
questions on the Environmental Impact Statement.
the EIS, I have the following questions and/or comnents.

It is not clear how the 2,500 to 5,000 drums mentioned relate to the 14,000 to 20,000 gallons of decontamination solution mentioned in earlier sections.
Revise the table to read as

D.C.

..

was

A- 108I2

3
is the waste that is stored on the island considered tobe safe from air
traffic
accidents?
The i[RC said that thereactor buildings were safe fror. air
collision, how about
the waste materials and the pools of water in which the rods
are to be kept?
The Harrisburg International Airport was
not mentioned in the ZIS draft.

I have the aerial photographs of Three Mile Island
during the flood of June 1972.
On the photographs it appears
as if most of the island was covered.
Is this true. Is ittrue that thebridges and access to the plant were inundated?
8.On page 3 -24 you state that "The continuing tension seems
related to two issues: future decomination plans for TMI-2,
and a distrust of those responsible for these activities."
I think that you have neglected to mention another sourceof tension and that is the prospect of Unit 1 being-allowed
to restart.
Living in the shadow of the TEY towers is badenough at the present ti.ne without having the additional
threat of another accident at the plant being a part of ourlives. The estimated time for cleanup is 7 to 10 years thisalone is enough to cause stress for many of us.

3- Met-Ed has slowed clean up operations and reduced
staff
because of financial problems.
'.'Jhen does the NRC stepin to zeep the clean up operatlons going and to maintain aoace the NRC has considered to be so important?
What will
happen to the clean up and the plant if ret-Ed goes ban-rupt?
'. What ever happened to the evacuation plans? It has
been over 18 months since the accident and the public has
still
not been informed or issued evacuation plans. Why wasn't
an evacuation plan part of the EIS? At no place in the EIS
is the possibility of evacuation due to problems during clean
up mentioned?

9. Where are the containers holding resins from the Epicor
RC thatI have recently read from Inside -.
Il being stored?
radioactive decay of isotopes stored in some of the containers
on site may be causing the resins to degrade into a jelly-likematter that could emit gases and cause the canisters to corrode.
The possible solution to this dilema was said to be onsite
Would this incineration release additional
incineration.
radiation into the atmosphere?
Now that we have lived through the week long venting of
to live with the almost weekly ventinds
krypton, and continueof additioral kyrpton do we have yet another large emniissionof radioactive gas to look forward to?

5.Can Unit I be used to help in the cleanup o; Unit II?
For example, could Unit I be used to store waste water, could
storage pools be used, or could it help provide better security?
Is it hazardous to have Unit I go back on line prior to having
Unit II cleaned-up?
Should information on Unit I be includedin the final EIS?
It seems that public officials do not want
to discuss Unit I bacause of the hearings on Unit I restart.
6. Figure 3.1-2.
Cumberland County and its
cotunty seat,
Carlisle are not on the map.
Neither is hechanicsburg, where
the Aaval Supply Depot is located or New Cumberland, where
the Army Depot is located.
The corrected map on page 2 4 of
the Question and Answer Booklet should be corrected to show
TNI in Dauphin and not Lebanon County.

Sincerely yours
7. Many of your references are secondary references.
For example, in References--Sec. 3.1, reference 3 is a geology
text book, "Structural Geology of North America."
Pleaseinclude the state, federal, and contracted studies in yourreference list.
Use original sources.
Much of what you use from Reference 1, is outdated
material and should be checied before being used.
What isthe geology 1000 feet down? Should you know this information
if you areoeing to store waste in the area?
I was also concerned about you references for weather
and hydrology.
I hope your weather information is based on
more than Reference 9 - Local Climatological Data.
Shouldn't
you have additional weather data if you are to release krypton,
etc.? What are the upper winds aloof, etc.?
Concerning hydrology (3-6) I think you should check yourinformation on the pump storage facility
consisting of two
reservoirs and dams scheduled for completion in 1990-198W.
Please update the Stony Creek Project.
Will this change yourflood forecast for TKI? 'What is the height of the dihe orflood wall around the island'and the waste storage areas?

Edwin and Kary Ann Charles
cc:

Gus Speth
Allen Ertel
Bill Goodling
Governor Thornburg

I

A-109
I

Page TwoDr. Bernard J. Snyder
November 20, 1980
lUREAU OF MINISENERGY OFPICEJAMES N. COUJLTER

POWER PLANT SITINO PROGRAM

STATE OF MARYLANDDEPARTMENT OF NATURAL RESOURCES
ENERGY ADMINISTRATIONTAWES STATE OFFICE BUILDING
ANNAPOLIS 21401

13011U0~2S.

November 20,

1980

Dr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
U.S. Nuclear Regulatory Commission
Washington, DC 20555
RE:

Three serious deficiencies in the current draft of the
document make it insufficient for programmatic planning, however.
No viable option has been presented for prompt removal of theradioactive wastes from the island. There are no data presented
on the costs of the various options for each step. There is noserious attempt to evaluate the economic impacts to the Marylandfishing and hunting related industries in the Chesapeake Bay thatmight be caused by highly publicized releases of decontaminatedwater to the Susquehanna River.
Consequently, the document issubstantially incomplete and provides insufficient basis forcomprehensive public input to NRC's decision making process.
Inorder to keep the decision process moving as quickly as possible,
we have provided policy choices and technical opinions where it
was possible to do so on the basis of the information contained in
the document.
A set of detailed technical comments is attached as Appendix B.
It has been divided into three sections:deficiencies, errors andcomments.
In addition, we wish to make and discuss several recommendations.

Draft Programmatic Environmental
Impact Statement related to decontamination and disposal ofradioactive wastes resulting fromMarch 28, 1979 accident at Three
Mile Island Nuclear Station Unit
2 (NUREG-0683)

Dear Dr. Snyder:
The subject document has been carefully reviewed by Maryland's
Department of Health and Mental Hygiene, Department of Natural
Resources and the Governor's Committee of Three Mile Island.
These comments are submitted on behalf of the State of Marylandby the Power Plant Siting Program, which has been designated aslead agency for Maryland's TMI related activities.
The
recommendations made to the Governor by his Committee are attached
as Appendix A.
Maryland concurs completely in the only decision recommended
by the document: that the 'no action' alternatives be given no
further consideration.
It is our position that the TMI Unit 2
should be decontaminated to normal levels as rapidly as is consistent
with careful planning.
The draft document is a compilation ofmuch useful information and is thus one step forward in this planning
effort. In providing comments on the document, it is necessary
to bring out its weaknesses and errors so that the document can be
improved.
On balance we believe the document reveals considerable
progress on the part of the NRC in evaluating the options available
for the cleanup at Three Mile Island.

A-11O

With regard to the difficulties involved in the planning forremoval of radioactive wastes from the island, the draft document
fails to substantively address the option recommended by Maryland
during the scoping process, that DOE accept all wastes unsuitablefor operating commercial burial sites and store them with similar
wastes that Department obtains from defense related projects. The
draft document simply dismissed this option as being contrary to DOE
policy.
Governor Hughes has written the President asking that an
exception be made to this policy for TMI accident-generated solid
wastes.
A copy of this letter is attached as Appendix C.
The NRCshould evaluate this option from a technical perspective.
If there
are any technical constraints on the physical forms of waste that
could be handled by DOE, these should be identified by NRC, now.
The choice of the various decontamination options and the design of
the actual systems must be made in such a manner that the waste forms
are readily acceptable by DOE.
If the decontamination processes
were to be conducted in some-other manner, such that DOE was required
to establish new facilities or processes before accepting TMI wates,
the wastes would probably be stranded on the island for decades.
The lack of cost data in the draft document makes it
impossible to recommend among many of the variousloptions.
Should the cost of the cleanup process bankrupt the Metropolitan
Edison Company, environmental protection is not assured andRecent rulings
decontamination would be long delayed, at best.

0Page Three
Dr. Bernard J. Snyder
November 20, 1980

Page FourDr. Bernard J. Snyder
November 20, 1980

by the Pennsylvania Public Utilities Commission, restricting thefinances available to the Metropolitan Edison Company for thedecontamination process, serve to illustrate that cost is an
The NRC must carefully weigh the costs
important consideration.
of systems and the cost of delays for procurement and installation
The public should also have available to it theof systems.
costs of the options before it is expected to make its recommendations
to the NRC.

In comparing the potential discharge of decontaminatedwater from TMI to the discharges from a normally operating
reactor, it is clear that the accident at TMI has decreased
the dose to Maryland's citizens compared to what would have
Our conservative estimates ofoccurred without the accidents.
the dose due to discharge of all the decontaminated TMI water is
0.9 mrem, about one fifth the dose associated with a single year's
discharges of water from a reactor in normal operation, and about
one thirtieth of the permitted annual dose from water discharged
by a single reactor in normal operation.
The discharge would
be well within the TMI Operating License limitations.

With regard to the option of discharging decontaminated water
to the Susquehanna River, the draft document fails to consider
the economic impact that may occur to Maryland's fishing and'aterfowl hunting related industries due to the public reaction.
Without any quantification of the impact, nor of the costs of
no-discharge alternatives, we have no sound basis for choosing
among the options.

However, it has been frequently demonstrated over the last
19 months that some persons will insist upon making incorrectand disturbing statements regarding the impacts of any releasefrom TMI Unit 2, and that the news media will constantly bring
Since the public has
these statements to the public's attention.
littlefactual knowledge of environmental radiation, it lacks
the context for putting such pronouncements into proper
This makes it very easy to generate fear in theperspective.
public's mind, but very difficult to create sufficient public
Consequently, it isunderstanding to allay unnecessary fears.
very likely that any discharge of decontaminated TMI water will
have associated with it some avoidance reaction, which is
proportional to the intensity of the assertions by various pressuregroups, rather than proportional to the magnitude of the release.

We wish to be absolutely clear on one point: we concurwith the NRC's conclusion that the radiological impact ofThis isreleasing the decontaminated water would be trivial.
based upon our own analyses of the impacts of much greater
quantities of the same materials that are routinely released
to the same river by the normal operations of Three Mile Island
Thus, the dispersion and bioaccumulation
and Peach Bottom.
mechanisms actually at work in this ecosystem have been taken
A summary of our
into account empirically in our calculations.
approach is attached as Appendix D. We do wish to stress two areas
where our conclusions differ from those in the draft document.
First, the bioaccumulatable radioisotopes of cesium and strontium
will be trapped mainly in the Susquehanna Flats, not distributed(The tritium will not be
down the Bay as far as the Potomac.
trapped anywhere; it will follow the normal course of water as
The detectability of the TMIpart of the hydrologic cycle.)
discharges in Maryland is also overstated-by the draft document.
The amounts of cesium and strontium proposed for release aresmall enough, in absolute terms, that they would be barely detectable
However, the Susquehanna River andin a pristine environment.
Chesapeake Bay have concentrations of the same isotopes from
Since
fallout and from releases of normally operating reactors.
these other inputs far exceed that associated with the TMI
decontaminated water, the incremental concentrations in Maryland's
environment due to TMI releases would not be distinguishable
from fluctuations in the totals caused by variability of Peach
Bottom discharges and environmental dispersion factors.

We are concerned that the fear created by the misleading
assertions will.cause the public to avoid fishing or huntingJ
on Maryland waters, and will cause a loss of markets for our
There are three mechanisms
commercial fisheries harvest.
The first
for economic impacts to various Maryland industries.
mechanism involves a general decline in the volume of sales
because individual consumers choose not to buy seafoods at
Seafood is generally considered a luxury
markets or restaurants.
item in these situations, and is very susceptible to replacement
The second mechanism involves the loss ofby other foods.
Marylandwholesale customers for our commercial wholesalers.
commercial wholesalers must compete with those from other areas,
and they have found in the past that their competitors are willingto capitalize upon any unfavorable publicity that can be used toThetaint Maryland products in the minds of commercial buyers.
third mechanism involves the avoidance of the area itself byThis reduces the business of
individual hunters and fishermen.
the sporting goods stores, boat captains and others catering to thesportsmen.

A-IllPage Five
Dr. Bernard J. Snyder
November 20, 1980

Page Six
Dr. Bernard J. Snyder
November 20, 1980

We have indications from past experiences that these impacts
may not be trivial.
However, we do not have the necessary,quantification to support a cost/benefit comparison with otheralternatives for handling the TMI decontaminated water.

without providing the actual values, tends to destroy the readers'confidence by suggesting that the actual values are being kept
from them unless they have the expertise to read the eomplete
document.

Under these circumstances, we recommed that NRC proceed with
its licensing of the Metropolitan Edison Company to decontaminate theaccident-related water, and that the Company store all theprocessed water on-site, in the tanks now being constructed, until
the necessary economic data has been made available by the NRC
for public comment.
The decision on ultimate disposal can thus
be delayed without further cost or delay of the overall cleanup
process.

The draft document also suffers from the computational andanalytical errors noted, most of which appear in the summaries.
Although many did not seriously affect the actual analyses, theircorrection will be necessary before the public can be expected
to gain a realistic appreciation of the situation and the options
for its resolution.

The resin/zeolite type system, of which the Company's
proposed Submerged Demineralizer System is an example, appears
to be the best choice for treating the water.
Our own samplingof the output from the EPICOR II system, another example of thistype of decontamination process, assures us that such a system
can be designed to adequately decontaminate the water. We
consider the residual radioactivity levels in the draft documents
to be good estimates of expected performance.
However, because
the actual performance of such decontamination systems depends
as much upon the judgment and care of the operators as it does
upon the system design, we still
desire to check the actual levelsin the processed water before taking a position on the suitability
for discharge to the Susquehanna without further processing.
Our final comment has to do with the clarity of the draft
document.
It suffers from several editorial shortcomings thathave caused serious misunderstandings in the public's perceptionof the issues. The principal problem is with the summaries; they
are not informative enough.
Such a large and necessarily
redundant document needs a single comprehensive summary whichis short enough to be read by everyone.
The summary should
include precise numerical information on such things as the actual
volumes of water, total activities, residual activities,, costs
in dollars and the doses resulting from various alternative
actions.
The summary should also include the necessary
information to provide context.
Comparisons with values fornormally operating reactors, license limitations, regulatory
discharge standards drinking water standards and natural backgrounds
should be made, as pertinent.
The use of comparisons alone,

Another common failing throughout the draft document is
the lack of explicit explanation of what was and what was not
For instance, many readers have apparently
included in the analysis.
failed to recognize that bioaccumulation was included in the NRC's
Also, the wording of several sections implies,
impact analysis.
incorrectly, that the output from a contaminated water processing
system goes directly to the plant discharge at the rate of 30 gpm.
The statement on page 3-15, that natural background should beinterpreted to include the doses from fallout and other nuclear
fuel cycle discharges, has been used to convince many readersthat the NRC uses a floating standard for comparison with newdose increments, despite the fact that these man-made contributions
are an insignificant increment to the natural levels being discussed.
In order for the public to have a valid basis for making
input to the NRC's decision process, we believe it is necessary
for the NRC to correct these errors and deficiencies, clarify
these editorial misimplications, provide an adequate summary,The compilation ofand circulate the corrected document.
the basic information in the document is a positive accomplishment,
providing confidence that the Three Mile Island Unit 2 can be
decontaminated safely without significant environmental impacts.
However, because of its shortcomings, combined with the NRC's
overestimations of radiological impacts to the Chesapeake Bay,
this draft of the PEIS has served to cause unnecessary worry forThis situation can only increase the potential
the public.
economic impact on Maryland associated with any options involving
discharges to the Susquehanna River. Circulation of the corrected
document is one step towards diminishing this problem.
Sincerely,

Steven M. Long, Ph.D.
Director, Power Plant Siting Program
SML:phA-112

I

APPENDIX A

THE JOHNS HOPKINS MEDICAL INSTITUTIONSDIVISIONS OF NUCLEAR MEDICINE AND RADIATION HEALTH SCIENCES

The Hon. Harry R. Hughes
November 14, 1980
Continued

page two'J NORTH WOLFE STREET

4LTIMORE, MARYLAND 21205

Telephone 301; 935-3350

November 14, 1980
The Honorable Harry R. Hughes
Governor, State of Maryland
Executive Department
Annapolis, Maryland 21404
Dear Governor Hughes:
The members of your Committee on Three Mile Island have examined the Draft of
the Programmatic Environmental Impact Statement (PEIS), designated NUREG-0683,
published July, 1980 by the Nuclear Regulatory Commission (NRC).
We have reviewed the data and conclusions of Dr. Steven Long and Mr. Richard
McLean of the Maryland Power Plant Siting Program, described in their draft accompanying letter to the NRC and in two memoranda entitled: (1) Projecting effectsof Three Mile Island discharges based on Peach Bottom's Measured Radiological
Impacts, and (2) Briefing paper on the effects in Maryland from potential releasesof decontaminated-water at Three Mile Island.
We wish to emphasize our concurrence in your charge to our Committee that it is in
the best interest of the citizens of Maryland to proceed expeditiously with theclean-up. It is unacceptable to take any course of action or inaction that would
have the effect of making the Three Mile Island site a permanent or even a longterm radioactive waste storage facility.
The following are our conclusions with respect to the PEIS:(1) A major deficiency of the statement is that it does not address the question*of the ultimate disposal of the high level radioactive waste (chiefly but not
exclusively the damaged fuel elements). We believe that this problem should be
addressed now.

public health or the biota of the Susquehanna River or the Bay would result fromrelease of the decontaminated water under the conditions described In the PEIS.
We believe that the socio-economic impact of the release of the decontaminatedwater on the seafood, recreational and other regional industries, which could bequite serious, has been inadequately addressed in the PEIS. Until studies ofradioactivity content In stored water and the potential socio-economic impact of
the release of.decontaminated water are completed, we believe the NRC would haveinadequate data on which to make an informed decision on the release of that water
into the Susquehanna River. We believe that the decision should be delayed until
completion of such studies and appropriate public review and comment. Deferral ofthe decision regarding ultimate disposal of the water for a period of approximately
three years will not delay the decontamination process or itself result in any
significant hazards. Storage tanks are now being prepared at the TMI site. With
the help of their political leaders and scientific advisors, the public should
again participate in the decision-making process at the time when a decision
regarding the ultimate disposal of the water will need to be made.
(3) We agree with recent statements by the Chesapeake Bay Foundation that Uthe
Chesapeake Bay is our nation's most productive body of water and its seafood
resources are most important to this country."Yours

incerely,

Henry N.
gner, Jr., M.D.
Chairman, Maryland Governor'sCommittee on Three Mile Islandnlm
CC:

We recommend that the Department of Energy be instructed by the President toexpedite the selection and utilization of a site for long-term storage of highlevel radioactive wastes from Three Mile Island, in order that the site beavailable for use within a period of seven years.
(2) We recommend that the approximately one million gallons of decontaminatedwater associated with the clean-up of Three Mile Island Unit #2 be stored initiallyin tanks to permit accurate assessment of its residual content of radioactivity
prior to a decision regarding ultimate disposal.
Our review of the projectedlevels of radioactivity in the processed water, as calculated by the NRC and by
Dr. S. Long and Mr. R. McLean, indicates that, no significant hazards to either

A-113

Secretary Charles R. Buck, Jr.
Secretary James B. Coulter
Dr. Steven LongIAPPENDIX B
Past experience with other contaminationwaterfowl hunters.
scares suggests that these effects may cause significant
The discussion of such effects on
economic penalties.
p. S-11 misses the point by assuming the public could 'underThe NRC's own study (Appendix E to thestand" the releases.
PEIS) demonstrated such aversion in resident fishermen in theSusquehanna near TMI at a time when the radioactivity levels
The lessons learned in thishad been reduced by the accident.
study have been improperly extrapolated to an area that has
The NRC's study clearly
many tourist fishermen and hunters.
shows aversion to eating fish caught, yet the document
incorrectly concludes that marketability of commercial catch
These impacts must be properly
need not be impaired.
addressed before there is sufficient basis for evaluating
the discharge option.

Power Plant Siting Program Staff Review of
TMI Draft PEIS

Deficiencies

1.

The level of planning in the document is not sufficent toensure whether wastes will ever leave the island. High level
waste disposal depends upon planned future federal actions
on a repository.
The Federal government has failed to makeany progress in establishing a repository for 20 years, despite
copious announcements and bureaucratic activity.
Therefore,
there must be established a mechanism for removing the highand low level wastes from the Island that is practicalnow.
The Commission should set a date by which all accident
related wastes will be removed from the island. A cut-off
date should be established on which the aforementioned
mechanism will be started if no other preferred mechanism
has already been implemented.

2.

The PEIS does not address the option of DOE storing TMI
accident related wastes with defense wastes, as requested
by Maryland during the scoping process.
It is importantthat this option be protected, since it is the only currently
viable one for promptly removing the wastes from the island.
The NRC must be careful not to preclude this option bylicensing a decontamination process which produces a solid
waste form physically unsuitable for DOE's existing
facilities or processes.

3.

No costs are provided for any of the options considered.
It is essential that costs be considered in selecting *options, since the company is not endowed with limitlessfinancial resources.
Risks associated with each option
must include the risk that the price of the option willcontribute to the bankruptcy of Met. Ed. and the inability
to complete the cleanup.

4.

No attempt was made to quantify the socioeconomic impactsof various options.
Release of decontaminated accidentgenerated water to the Susquehanna River is certain to
be accompanied by press coverage of misleading and disturbing
statements from some of the opposition groups., The public
fear thus created will tend to cause a decrease in the marketabilityof Maryland's commercial seafood harvest, and an avoidanceof the area thought to be affected by sport fishermen and

A-114

Comments

Errors
1.

1. Comparison of "water's edge" elevation of 280 ft. MSL
on p. 3-1 with the "average elevation" of the islandof 277 ft. MSL on p. 3-5 leads to the obvious conclusionthat TMI is 3 ft. under water.
2.

Table 3.1-1 (p. 3-4) The "Anions" listed are all cations
and the "Cations" listed are all anions.

3.

Section 4.5.3 (p. 4-5) states, "No accident having off-site
consequences is postulated", but Section 4.4.2.2 (p. 4-4) states,"However, if overheating is assumed to occur and all theremaining Kr-85 and cesium were released to the reactor
building, the total activity from this hypothetical releasewould be about the same as the activity inside the reactor
building prior to purging".
This means that the environmental
effects would eventually be the same as the purge alreadyconducted, since another purge would be required.

4.

Correspondence between tables 6.5-2 and 6.5-5 and between
tables 6.5-3 and 6.5-6 is unclear with regard to total
release to the river for the entire process.
From Appendix G,
table 6.6-7 appears correct, and table 6.5-5 appears to be
low by a factor of 1,667.

5.

Table 10.1-2 is obviously in error for sump water releases.
Apparently concentrations in table 6.3-5 were multipliedby the value at top of each column, neglecting the factor of
1200

(3600

)

dillutioninthe concentrations.

Not true, especially if the NRC intends to interpret 10CFRSO
App. I to mean 10 Ci/quarter or 40 Ci/year, instead of
1.25 Ci/quarter.
The Commission should announce specificnumerical limites for aqueous discharges applicable to TMI
unit 2 cleanup, as requested by Maryland during the scoping
process.
The PEIS is ambiguous.
Normal discharges from an
operating reactor typically give doses on the order of several
tenths of a millirem annually to a maximally exposed
individual, while Appendix I sets 3 mrem/yr. as the"achievable" level for a single reactor.
2.

p. 1-26 Stating that the doses from the whole TMI event
come to less than 25 mrem/yr for the maximally exposed
individual is simply another way of stating that the cleanup
will last well over 4 years, since the NRC is assuming the
maximum public dose during-the first weeks of the accident
was. somewhat less than 100 mrem.
It masks the doses that will
result from future, controllable events.
State clearly what
the doses will be from now forward.
As now stated, thepublic does not have any opportunity to comment on thecriteria the NRC staff will use "to make an informed decision
should it be necessary to terminate or modify an operation".

3.

Two of the "major options" on p. 2-1 are unacceptable to
Maryland.
These are "(c) use of the TMI-2 buildings andsite as permanent waste repositories" and "(d) use the
TMI-2 building and site as temporary waste repositories until
a final decision is made."
We concur that the island could
not be qualified as a waste disposal or storage site. We
disagree that the site is suitable for "interim storage"
because there will be no distinguishable difference between
the NRC's use of the term "interim storage" and permanentstorage, unless and until DOE actually implements a permanent
disposal facility.

4.

p. 2-2 Maryland concurs that options involving core fixation
are unacceptable, as are any other measures that would
significantly increase the effort necessary to remove any
radioactive wastes from the island.

5.

p. 2-2 Maryland concurs that "no action" is dn unnacceptable
alternative.

Correct

values can he obtained from tables in Appendix K, where boththe volumes and the concentrations of effluents are given
prior to dilution by blowdown.
6.

p. 1-26 "Requiring that the numerical design objectives ofAppendix I to 10CFR50 are met will assure that the radiationdose received by the public during the cleanup operation isequivalent to or below that of a normal operating reactor'.

tb}jj 5.2-6 p. 5-16 and all later tables have incorrect
Cs-137 ratios.
The decontamination process cannot change thecesium ratio from that shown in Table 5.2-5 for the
unprocessed water.

A-115
I

6.

p. 2-4 Maryland concurs with the staff's criterion "thatno unprocessed accident water should remain after cleanup
activities have been terminated or suspended for anindefinite period of time'.

7.

p. 2-6 Maryland concurs that the decision between
decommissioning and rebuilding need not be made prior.tocommencement of cleanup.
The time lost in reachingsuch a decision is not justified by the savings incomponent decontamination that could be obtained byscrapping instead of salvaging equipment.

8.

Section 2.1.3.1 For the core fixation option, stating theweight and diameter of the "fixed" core plus the necessary
shielding for transportation through public areas would
make a stronger argument against this option in a lay person's
mind.

9.

p. 2-14 Section 2.2.2 indicates that many "low level
wastes" will be peculiar to TMI and not necessarily suitablefor existing commercial waste disposal mechanisms.
Theseshould have a specific mechanism for disposal or off-sitestorage ready before they are created.
p. 3-28 statesthat some high-specific
activity, "low-level" wastes
other than fuel are not acceptable at Richland.

10.

p. 2-14 "Interim" storage of "several months" is recognized
as necessary to cleanup operations.
However, "long-term"
storage of "10 to 20 years" on site is recognized as
evasion of the issue and is unacceptable to Maryland.

11.

p. 3-13 did not include Perryville, Havre de Grace andPort Deposit water intakes in Maryland.
Why stop at "50 miles"
when the river flows just 10 more miles and passes 3 more
public water supply intakes before entering the brackish water
regime?
(These intakes are shown on Fig. 3.1-6.)

12.

13.

p. 3-32 states "Present DOE policy does not allow disposalof TMI-2 low-level wastes at government facilities".
Sucha policy should not stop evaluation of this alternative, since
DOE can be commanded by the President.
The PEIS should
evaluate the technical feasibility of DOE's immediate ,acceptance of the TMI wastes when they are ready for shipment.
DOE could store TMI wastes with those from the military
nuclear programs until its disposal facilities are completed.
A fee could be charged, if necessary.

14.

p. 5-13 The statement that solidification of processed waterrequires TMI to be classified as a low-level repository isa semantic delusion.
If the processed water is acceptable fordischarge in a fixed period of time, and could not leach fromthe block in a shorter time, then this argument is useless to alogical technical analysis.
Is there a legal barrier
to this option? Must the island be licensed for storageof other radioactive wastes in order to pursue- this option?

15.

p. 5-14 "Local Release to the River" compares the process
flow rate of EPICOR II with the cooling tower blow-down rate andcalculates a dilution factor, implying direct discharge
to the river after processing.
This procedure is unacceptable
to Maryland.
All materials to be discharged must be heldon site for batch sampling and approval prior to any discharge.
Continuous stream discharges are too susceptible to accidental
spillage.
We believe that the implication was not intended,
but feel it must be corrected.

16.

Forced evaporation options are not adequately addressed.
Heated ponds leave some of the cesium isotopes behind in themud, eventually to wash off site.
Sprays in ponds cause
drift, as do cooling towers, carrying some cesium off-site.
Other option should be addressed.
Forced evaporation in acontainer, with filtered vapor venting, would allow releaseof essentially nothing but tritium, and would allow nonvolatiles in the bottom water to be solidified in a physicallysmall volume.

17.

p. 5-37 The firstparagraph indicates that accident sludges
will be packed in 55 gallon drums and held, pending a decisionon how to handli them.
Since this is high specific activity
waste (65 Ci/ft ), it appeas that this material may becontemplated for "long-term storage" at the site. Dewateredsludge of such high activity in steel drums is not acceptablefor indefinite storage.
A fixation process must be settled
upon now.

p. 3-15 "'Natural background' should be interpreted to mean
normal background, including the effects of fallout frompast nuclear weapons detonations and from the nuclear fuelcycle".
There is no reason to call fallout and nuclear fuel cycle
emissions "natural".
To do so may cause the public tobelieve the NRC is attempting to inflate the basis ofcomparison for TMI created doses so as to make the TMI
doses appear less significant.
Since the dose rates fromfallout and normal fuel cycle emissions are less than thelocal variations in the natural dose rate, there is noneed to use them for comparisons.

A-116

I -

ME

I

18.

Section 6.3.2 P. 6-14 The arguments presented against
direct solidification of sump water with cement seem weak.
Transport in 600 or 1,200 truckloads is not an insurmountabletask.
(How many truckloads of cement were brought to TMI
during construction?)
The necessity for shielding shouldhave been calculated.
The acceptability of the resulting
drums for disposal at Richland and the available space atRichland should have been checked in further considerationof this option.
Specific activity would be . 15 Ci/drum.
Is this acceptable for low level disposal sites?

19.

p. 6-15 Indefinite storage of the "high activity,
coreosive filtrate" at TMI is unacceptable to Maryland.

20.

p. 6-19 The "staff analysis", referred to in Section 6.3.4.2
for effects of a leak to the river, should have been included
for review in the draft PEIS.
Assuming the whole 700,000
gallons (500,000 Ci) leaks to the river in "one to twodays", and using the previously applied river flow rateof 1700 cfs, the concentration downstream would be.00012 Ci/l = 0.12 p Ci/ml.
The staff analysis showing
mCi/ml Sr-90
only 2.8 x 10-16PCi/ml Cs-137 and 2.3 x 10downstream thus has a very large mitigating factor in ionexchange with the soil plus additional dilution due to the
protracted release period from the soil to the river.
Given
the statements on p.3-5 regarding drilling water loss andthe suggestion of open fractures in the underlying geologic
structure, and given the statements on p.3-1 that stratified
sand and gravel with some "clean sand" underlie the site, such
mitigating assumptions seem unsupportable with present
knowledge.
The idea that the water could even be lost in"one or two days" would require an underground flow
channel to be feasible, which is inconsistent with thepostulated 1.6 yr. soil retention time.
We therefore feelthat the effects of the maximum possible leak have been
drastically understated.
This tends to improperly lend support
to the "no action" options and detract from the immediacyof the present problem.

21.

22.

p. 6-24 LosS of sump water to the river through soil gives
See comment *18.
This seems entirely too low.
59 mrem/yr.

23.

p. 6-28 states "... it is probable that some residual
radioactivity from TMI-2 could be found as far south asThis conclusion by the NRC
the mouth of the Potomac River".
staff is based upon faulty analysis of the literature, and iscontradicted by Maryland's radiological sampling of thd Bay
to determine the distribution of the same radionuclides thatare released from the Peach Bottom Atomic Generating Station
The NRC analysis rests upon a paper
during normal operations.
in Estuarine and Coastal Marine Science by Eaton, Grant
and Gross (Oct. 1980) purporting to shown that sediment in the
Bay as far south as the mouth of the Potomac is principally
Even if this is true,
derived from the Susquehanna River.
and it is disputed by many, the sediment has had at least
tens of thousands of years to get this far. Maryland'sradiological monitoring data from the head of the Bay indicatesthat Peach Bottom discharges give maximum concentrationsof Cs-137 in fish in the vicinity of Conowingo Dam, andmaximum concentrations in sediments at the river mouth.
Concentrations in all media have declined by two orders ofmagnitude by the mouth of the Sassafrass River, becoming
Since Peach Bottom releases about 10 times
undetectable beyond.
more Cs-137 annually than is contemplated for the entire
TMI cleanup, release of the treated TMI water over an extended
period makes detection of the TMI effects unlikely at any
location in Maryland waters, and dubious in the Holtwood
upstream station unaffected by Peach Bottom.
Reservoir, the first24.

p. 6-28 also states, "Once in the flats, the radionuclides will
be diluted by a factor of one thousand within 30 days, andThis statement is obviously
more rapidly further into the Bay".
false for a continuous discharge situation, including any
discharge with a duration approaching the flushing time of
Virtually all the fresh water
the Bay, which is about I year.
The Susquehannaon the flats comes from the Susquehanna River.
provides about 80% of the freshwater input to the Bay above
Consequently, dilution
the confluence with the Potomac River.
is principally by the seawater transported up the estuary,and steady state dilution can be estimated from the local
In the steady state, even a factor of 2 dilution
salinity.
will not occur until a salinity of 15 ppt is reached (downnear Calvert Cliffs). For short term releases, the dilution
will depend upon the duration of release,.the volume of wateron the flats, and the extant mixing conditions on the flats,
which are strongly affected by river flow rate, astronomicalConsequently, the analysis of thetides and wind patterns.
behavior of radionuclides in the upper Bay cannot be treatedin the same manner for controlled releases and accidental
The physical mechanisms
releases, as was done in the PEIS.
for removal of radionuclides from the water column to thesediments appear to be much more important factors thandillution in determining the distribution of any isotope but
tritium.

p. 6-22 Tables 6.3-7 and 8 show release of 75 mCi of cesium
isotopes due to the loss of a HEPA filter.
p. 6-21 states"HEPA filter
failures not related to fire are assumed tooccur".
If this means that such failures are expected during
cleanup operations, then redundant filters, with detection
devices between them, should be employed, and testing of theouter filter should be conducted to be sure it does not failfirst.
p. 6-26 gives 1.1 mrem/accident, mainly due to ingestion.
This assumes 6.7 x 10-6 m/sec 2 for X/Q.
Dispersion could
be much worse.
This is not adequate for accident analysis.
p. 6-26 states hourly X/Q values may be within a factor of
500 times this value.
That means possibly 4.4 mrem inhalationand 550 mrem ingestion doses. The latter figure indicatesthat farm crops may be lost, rather then that somebody would
actually suffer the dose.

A-II7

AL-

APPENDIX C

25.

26.

27.

28.

Section 9.1.1 (p. 9-1) states that EPICOR I wastes will
be stored at the on-site interim storage facility. Why
aren't EPICOR I resins shipped off-site as in normal operation?
This system should not be used for creating such high specificactivity wastes that they aren't acceptable at the operating
repositories.
Section 9.5.1.2 (p. 9-15) states, "... maximum radiationlevels at the fence surrounding the facility from the interim
storage and staging facility will be less than 0.5 mR/hr".
We assume this is at the fence surrounding the storage
What is the maximum off-sitefacility, not the site boundary.
(boundary) dose rate?
Section 10.5.3 neglects to discuss the integrity of the interim
storage facility and the concrete storage facility during theHas this been investigated? Wereprobable maximum flood.
the buoyant forces of the cells, the side forces of any
currents and the relationship of the center of gravity to thecenter of buoyancy for individual modules evaluated? What
were the conclusions?
The analysis presented in the PEIS
assumes structural integrity, but this could be questioned,
expecially for the interim storage facility, which is mostly
dirt fill.
The PEIS sections and appendices all treat the various cleanup
systems for sump water, primary loop water and decontaminationwater as if they are deterministic devices whose performances
do not depend upon the care and judgment of their operators.
In fact, the effluent numbers for the various options are
only the NRC staff's assessment of how these systems might
perform; the Metropolitan Edison Company is currently free
Given the existing operating license,
to do better or worse.
the Company could conceivably do about 160 times worse andbe considered by the NRC to have complied with theirstill
limit of 10 curies/quarter/reactor for the discharge of
bioaccumulatable radionuclides to the river for one year.
The statement should, with proper consideration of cost,
determine what performance is "practicable' with each of thesesystems to meet the criterion of 10CFR5O App. I thatradioactivity releases to the environment be kept "as low
These performance standards, for theas practicable'.
system implemented, should then be made binding upon the
If the NRC does not chose to proceed in this manner,
Company.
then the PEIS is deficient in that there is no consideration of
the probable range of performance of each system (as was donefor volumes of solid waste), and those following environmental
impact analyses are improperly founded.

STATE OF MARYLANDEXECUTIVE DEPARTMENT
ANNAPOLIS. MARYLAND ZIA04
HARRY HUGHES

October 3,

O0ý.ftof

The President
The White House
Washington, D. C.

1980

20500

Dear Mr. President:
I am writing to request your assistance in a matter of
The Nuclear Regulatory
great concern to the State of Maryland.
Commission's draft Programmatic Environmental Impact Statement
for the Three Mile Island clean-up has failed to address any
alternatives which provide assurance that the radioactive wastes
All plans
will be removed from the island without decades of delay.
establish
addressed require that the Department of Energy firsta storage facility or repository for commercial high level radioHowever, the lackactive wastes and high specific activity wastes.
over the lastof progress towards establishment of such facilities
25 years renders any current schedules subject to skepticism.
There is one option which can guarantee the capability
for timely removal from the island of the high level wastes,transuranic wastes, and those high specific activity wastes
This is for DOE
unacceptable at existing commercial repositories.
to accept these wastes for storage with the similar wastes that
Although
DOE now handles from the defense-related nuclear projects.
Maryland formally suggested-during the scoping process that NRC
consider this alternative, it was dismissed in the draft statementwith the simple declarations that DOE policy does not allow for•and thatdisposal of TMI low-level wastes at government facilities,
DOE is studying the high-level waste problems.
I am therefore requesting that you use your authority
as President to direct DOE and NRC to explicitly consider thetechnical feasibility of this option, and to direct DOE to make anpolicy by accepting these TMI clean-up wastes for
exception to its
which there is no available off-site storage facility.
The unusual nature of the accident derived wastes is
The recent decision by thereason enough for such an exception.
Pennsylvania Public Utilities Commission prohibiting use of revenue
from ratepayers for the TMI clean-up, has created a situation ofThis
institutional instability for the Metropolitan Edison Company.

A-118

APPENDIX D
The President-2-

October 3,

1980
a.

makes it imperative, to identify and confirm at this time a location
The clean-up activities should
to which the wastes can be removed.
be planned and conducted in a manner that will insure that disposal
with defense related nuclear waste remains a viable option.

STATE OF MARYLAND

The draft environmental impact statement reveals thatfederal agencies are following a course of action that will makeThree Mile Island a long-term storage dump for radioactive waste.
Nothing could be more dangerous to Chesapeake Bay and the people of
No responsible agency would locate a dump for radioactive
Maryland.
waste on an island in a flood plain above the water supply of amajor metropolitan area, and poised at the head of Chesapeake Bay.
Yet, because of refusal to consider any other realistic alternative,that will be the result of actions described in the draft environment
impact statement.
Because this is an unusual situation-and because of theunusual threat to people in Maryland and Chesapeake Bay, I am making
this unusual request that you intervene with the Departments of
Defense and Energy and insist that all of the radioactive waste
be removed from Three Mile Island as quickly as safety will permit-even if it means disposing of them for some extended period with
waste from defense operations.
I

convenience.

BURRAU OP NINES
a.NEBGayOFFICEPOWERPLANT SITING PROGRAM

coULnaDEPARTMENT OF NATURAL RESOURCES
ENERGY ADMINISTRATIONTAWES STATE OFFICE BUILDING
ANNAPOLIS 21401?0)125-2201

October 14, 1980.
MORANDUM

TO:
T
FROM:
SUBa:

Ste

ve Long

Ric hard McLean
Jecting Effects of THI Discharges
BasePro
ed on Peach Bottom's Calculated
Rod iological Impact

our assessment of Peach Bottom radioecological impact has provided
exteenlive data on radionuclide concentrations in biota and sedimentsof t:he Susquehanna River and Upper Chesapeake Bay. Both Peach Bottom

would appreciate your response at your earliest/
cerel '
land weapons-testing fallout have contributed Cs-137 to the ecosystem,a fa act which complicates the process of estimating the power plantincr:ement to environmental Cs-137 levels. Cs-134 concentrations are,howeever, attributable solely to Peach Bottom effluents.
For thisrea: son I have used Cs-134 environmental values and Peach Bottom Cs-134
rele ass data to estimate radiocesium concentration increments infinf ish and sediments which would result from a controlled release ofproc eased water at Three Mile Island. Also provided are estimatesof r adiocesium and tritium concentrations in Conowingo Pond which would
resuLlt from a controlled release of processed water assuming a mean
rive,r flow of 34,000 cfs. Estimated dose commitments to adultindi viduals consuming the finfish and water are included.
These
esti mates are based on the following assumptions:

Gov7rnor ?.

A-119

1.

The radiological effects seen in the Conowingo Pond, SusquehannaRiver and Chesapeake Bay resulting from a controlled releasefrom Three Mile Island are equivalent to the radiologicaleffects resulting from a controlled release of the same amountof radioactivity from Peach Bottom.

2.

The environmental concentrations of Cs-134 in our sediment andfinfish samples are effected solely by the 1.62 Ci of that isotope
discharged from Peach Bottom during the second quarter of 1979.

3.

Similarly, the activity from TMI which results in the estimatedconcentrations in finfish and sediments is released over a periodof one quarter.

Steve Long
October 14. 1980
Page Two

4.

Quantities of radionuclides (activity) released from TMI
correspond to those given in PEIS Table 5.2-11 for EPICOR
processed water and those derived from PEIS Table 6.3-5
for Submerged Demineralizer System (SDS) processed water.

5.

The decay of Cs-134 is not considered.

6.

The behavior and ratios of release activity to sample concentrations
are the same for Cs-137 and Cs-134.

RESULTS:A.

This table gives estimates of the Cs-137 and Cs-134 concentration increments
in finfish flesh and the dose commitment to an adult consuming 21 kg of such
fish for TMI processed water releases.. Fallout and Peach Bottom-derived cancentrations are included for perspective.

1.

Radionuclide

Activity
Released(Ci)

Cs-137
Cs-134

.0079
.0013

Concentraiionin Finfish(pCi/kg)

Total Body
Dose (mrem)

THI Discharges
EPICOReThe values used in these calculations are the maximum detected concentrations in our finfish and sediment samples. The estimates ofconcentrations resulting from a release at THI therefore represent
upper bounds based upon our sampling program. Additionally, assumptions
1 and 2 provide some measure of overestimation by not accounting for someloss of radioactivity above Conowingo Pond (1), and assuming that Cs-134
environmental concentrations result from only the previous quarter'sdischarge (2).
To provide some perspective on the TMI-related concentration estimates,
fallout-derived levels (based upon our analysis of remote Chesapeake
Bay samples), and Peach Bottom associated concentrations are included.

Finfish

1.1
0.2' .00165.00047.00212

SDSb

Cs-137
Cs-134.215-. 037

30.5
5.3

.0457
.0135
.0592

2.

Falloutc,,,12.0
0.0

Cs-137
Cs-134

.018
0.0
.018

RIM: ldn
attachments
3.

Peach Bottomc

Cs-137
Cs-1341.3
1.62

2300.0d
230.0

.45
.59
1.04

aTable 5.2-11
bTable 6.3-5
CpPSP DatadMedian Cs-137 concentrations in finfish within the influence of Peach Bottom
effluents are essentially indistinguishable from fallout-attributable levels,
although the presence of Cs-134 in many indicates a Peach Bottom supplied
Cs-137 increment as well. This sample of White Crappie which contained the
maximum detected Cs-134 concentration represents the only finfish collection
where a Peach Bottom Cs-137 increment is assignable.

A-120

I

100 1

IME

B.

0

M !

0

0

C.

Sediments

This table gives estimates of the Cs-137 and Cs-134 concentration increments
in sediments which would result from the release of TKI processed water.. Fallout
and Peach Bottom-derived concentrations are included for perspective.

Water

Because radionuclide concentrations are generally undetectable In Conowingo
Pond, estimates of concentrations relative to Peach Bottom diichargea are notpossible. The calculations are for an integrated discharge of one year's
duration and assume a mean river flow of 34,000 cfe. Dose commitments andamounts of activity ingested are annual and calculated-assuminga water consumption rate of 21/day.

Concentrations
Sediment. (pCi/dry inkg)

Radionuclide
1.

2.

3.

Activity
Released(CO)

Conowingo
Pond

River
Mouth

Susq.
Flats

Upper
Bay

Redionuclide
1.

ThI Discharges
Cs-137
Cs-134

.0079
.0013

1
<1

3
'1

'1
'1

<1
'1

SDSb

Cs-137
Cs-134

.l1
.037

<27
4

85
15

<27
3

< 27
<1

Falloutc

Cs-137
Cs-134

0

e

0

e
0

e

0

e
0

Cs-137
Cs-134

1.3
1.62

d
165

d
640

d
134

d
28

Peach Bottomc

H-3
Cs-137
Cs-134

347
.0079
.0013

8345
0.19
0.03

.00088
1.4 x 10-56
3.6 x 1D-

H-3
Cs-137
Cs-134

3697
.215
0.37

88900
5.17
0.91

.0093
.0004
.0001
.0098

2.

Falloutc

H-3

daTable 5.2-11
aTable 5.2-11

bTable 6.3-5

bTable 6.3-3
cpPSP Data

CPPSP DatadPeach Bottom increment to Cs-137 in sediments unassessable due to fallout
contributions.
sand) to '700

Total Body
'Dose to
Adult (mram).00089SDSb

eConcentrations range from < 27 pCi/kg (inActivity Ingested
from Water
Consumption (pCi)

THI Discharges
EPICORaEPICORa

Activity
Released(Ci)

dTritium concentration in water is 1-0.3 nCi/1

pCi/kg (in clay).

A-121

219000.022

THE PENNSYLVANIA STATE UNIVERSITY
UNIVERSITY PARK, PENNSYLVANIA

College of Engineering
BMraale Nuclear Reactor

16802

U.S. Nuclear Regulatory Commission
November 11, 1980
Page 2

Area Code 814

11 November 1980

865-6351

seems that some of the well known publications on this topic havenot been identified by the group preparing this document.
Furthermore, there is no mention anywhere in the document about the genericnature of process materials used in waste consolidation and management.
This makes the task of predicting potential problems extremely
difficult, if not impossible.
There is considerable experience inthe U.S. and adequate knowledge internationally to recognize thatradiation damages to ion exchangers can have catastrophic consequences
if the wastes are not properly managed using well established scientificprinciples.

U.S. Nuclear Regulatory Commissione
Washington, D. C. 20555
ATTENTION:SUBJECT:

Director, TMI Program OfficeComments on Draft PEIS (NUREG-0683)

Gentlemen:

5.

The PEIS often refers to "proprietory" and secret formulas for waste
removal techniques and materials used in waste processing.
It is very
important to recognize that the peddlers of these remedies know nothing
about the overall consequences of the use of these materials in thewaste management system.
It is also necessary that responsible
scientists and regulatory agencies should have the full benefit of thegeneric nature of the materials and processes used in waste management
at TMI-2.
If this cannot be achieved very soon serious consequences.can result from the misuse of these materials and techniques in thedecontamination efforts at TMI-2.

6.

There is a distinct lack of participation by the Commonwealth ofPennsylvania in developing pragmatic solutions to the TMI waste management problems. The wishful thinking on the part of the Commonwealththat all these wastes generated in.Pennsylvania can be dumped insomeone's backyard is a bit naive.
It is- time for the responsible
agencies of the Commonwealth to wake up to the situation and develop
sound orograms to manage the wastes in the interim period and toseriously consider the necessity to dispose of some of these wastes
within the boundaries of the Commonwealth.

7.

The schedules proposed in the document are often unrealistic and some
pragmatists ought to get involved in revising this document.

I am pleased to note that NUREG-0683 has made an attempt to study the.activities necessary to decontaminate and manage the wastes from the accident
at Three Mile Island-Unit 2 Nuclear Station. While there are many positive
aspects to this document, I wish to point out here some of the areas which I
consider as the deficiencies of the document, with the hope that these comments
would help improve the overall approach to the problems of decontamination andwaste management at TMI-2.
1.

2.

Several of the scenarios considered for the interim and long-term
managemenit of wastes resulting from TMI-2 cleanup operations areover optimistic.
First of all, it is rather unrealistic to expectthat all the wastes from TMI-2 can be shipped to the State ofWashington.
Recent responses to a referundum'must have convinced
the futility of such planning.
Second, transportation of wastes from one end of the country to the other is not the best approachto the problem because accident probabilities in waste management
are a maximum in the transportation phase.
This attempted study (NUREG-0683) does not seem to have the benefitof good safety analyses especially in the interim management of wastes.
Specifically, the document does not address the consequences ofchemical and radiolytic effects on waste forms during the interim
management period and during subsequent handling and processing.
The waste "staging area" at TMI is hound to be in business for a very
long time and the hazards of interim storage need to be assessed
immediately and corrective and preventive actions need to be instituted.

3.

It is too simplistic to consider the wastes from TMI-2 cleanup
operations as "low level wastes" and to consider shallow land burialof the ion exchange beds as a viable alternate.

4.

The waste loadings of ion exchange liners considered (and some ofthem already performed) are far in excess of the quantities withwhich there is process experience.
However, this document does notgive adequate consideration to the problems and consequences ofradiation damages to ion exchangers.
There is an almost apologetic
passing reference to the problem and no serious discussions.
It

It is my considered opinion that there are significant gaps in our
understanding of many areas of waste management efforts proposed in NUREG-0683.
The recognition of these uncertainties would be a major step in solving theoverall problem of decontamination-and waste management.
Parallel efforts
should be directed at developing, verifying and confirming technologicaluncertainties.
While an ideal solution to the decontamination and waste
management problems at TMI-2 is not achievable in the near term, present
knowledge can be used to develop acceptable solutions for the decontamination
and waste management at the Three Mile Island Nuclear Station, Unit 2.
If I can elaborate on any of the points made,please let me hear fromyou.
Sincerely yours,/^
K.K.S. Pillay

AN EQUALOPPORTUNITY UNIVERSITYKKSP/r

A-122

LM

-

United States Department of the Interior
OFFICE OF THE SECRETARYWASHINGTON, D.C. 20240
The

OCTr
8 198

ER 80/899

SnyderMr. Bernard J.
Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
20555
Washington, D.C.
Dear Mr.

cousiderationofa potential

accidentsuch asdroppinga Contami.nated deaincralizer liner from the monorail systemD-b, col. 1, par. 3) did not take into account the(p.
If thispossibility of this occurring during rainfall.
transfer operation would be taking place within an .enclosure
Bowever, if it is occurring outside
we foresee no problems.
a potential new source of contaminated runoff
witii rainfall,is created.
We

hope theaeto you.

comments will be of assistance
Sincerely,

Snyder:James H. RathlesbSrger

The Department of the Interior has reviewed the draft
programmatic environmental statement on the decontaminationand disposal of radioactive wastes at Three Mile Island
We have the following
Nuclear Station, Unit 2, Pennsylvania.
comments.

Speoial Assis£AsiStbjtSECRETARYcc:

We concur with the staff position expressed in the Conclusions
that "long-term or prominent storage of high-level waste is
Else12-2, par. 10).
(p.
not appropriate at the TMI site"where in the statement, however, the possibility of long-term
onsite storage of damaged irradiated fuel is not ruled out
9-11,
are not available (p.
if long-term offsite facilities
We recommend that plans for appropriate offsite
par. 3).
be coordinated with decontamination plansstorage facilities
for Three Mile Island to ensure that long-term storage ofthe damaged core on the island can be precluded.

Copy
File
Secretary's
Reading File
Secretary's
PEP
AS/PBA (2)Kallman
OPA/Mr.
REO-BOSBM
NPS/ GS/FWS/
HCR5/
PEP/Martin

PEP:TMartin:sjm:10/3/80:X6128

Staff analyses of leakage of water into the ground from the
5-17, par. 2) and theauxiliary fuel-handling building (p.
6-19, par. 3 and 4) are referred to, but
reactor building (p.
in terms of time to reach the river and cononly results
centrations in the river at the nearest water supply intake
The assumptions and data used in this analysis
are given.
are not given except for the assumption that for the reactor
the sump water would leak out in one or twobuilding all
No indication is given as to how
6-19, par. 3).
asys (p.
suchan accident would be, but the impression isprobablemeasures the consequences
mitigatingeven
without
thatleft
However, in the absence of the details
would not be serious.
analysis, this impression must be questioned.
of the staff
If there is a significant probability for the occurrence ofsuch leaks involving very large quantities of radionuclides,a very rigorous analysis of consequences is warranted.

A-123

(2)

t

an

t

to

Secretary

NUREG 0683, "DraftProgrammatic Environmentallmpact
Disposal of Statement
Relating to Decontaminationand
Radioactive Wastes Resulting from the March 28, 1979 Accident
at Three Mile Island Nuclear Station Unit II"

COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
P. 0. Box 2063
Harrisburg, PA 17120
November 13, 1980

The specific comments on the Draft Programmatic Environmental Impact
Statement by indicated sections are as follows:
Section S.2 - The statement concerning accidental recriticality of
the core leading to a release of additional radioactivity does not appear
justified by or consistent with the detailed discussion which is containedin Section 4.

Dr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
U.S. Nuclear Regulatory Commission
Washington, DC 20555

Page S-9 - Any mention of disposal alternatives for the waste appears
to be absent from the summary discussion. Disposal is an integral and very
important part of the clean-up process and should be discussed in detail in
the Final Environmental Impact Statement.

Dear Dr. Snyder:
The Pennsylvania Department of Environmental Resources appreciates
this opportunity to-comment on NUREG 0683, "Draft Programmatic Environmental
Impact Statement relating to decontamination and disposal of radioactive wastes
resulting from the March 28, 1979 accident at Three Mile Island Nuclear Station
Unit II". Our comments on this report are first of a general nature followed by
specific comments prepared by William Dornsife of our staff. Mr. Dornsife's
comments are attached.

Page S-12 - It should be indicated that gross alpha measurements are
periodically taken on certain selected samples.

Due in part to the nature of the subject, the document was very lengthy
and difficult to review, especially for the lay public. However, the subject
matter could have been better organized to allow for a more fluent and, therefore,
useful review. As examples, much of the information that is repeated in eachchapter could have been covered in one chapter or moved to an appendix, andmore of the background technical information which is contained in the chaptersshould be included as an appendix.

Section i.6.3.1 (page 1.25 at the bottom)
appear to be complete.

Section 1.6.3.1 - No mention is made of NRC's on-going development of
a waste classification system. This waste classification system is a very
important part of determining the final disposition of and management requirements for TMI wastes.
I-

The paragraph does not

Section 1.6.3.2 - The paragraph, which places into perspective thepublic exposures by comparing them with natural background exposures and isrestated in each section dealing with that subject, is important from a public
perspective standpoint and should be expanded. A much more complete anddescriptive discussion of natural background and other comparative exposures
should be included in the document, such as was included in the Final Environmental Assessment for Reactor Building Atmosphere Clean-up.

We again appreciate the opportunity to comment on this Programmatic
Environmental Impact Statement and trust that our comments will be given due
consideration. We would, furthermore, expect that we would be consulted for our
input prior to a final decision being made on the implementation of the various
alternatives.

Section 2.0 - The statements concerning the importance of an early
decision on decommissioning versus reuse of the plant needs to be expanded andclarified. In this context, a summary discussion should be given of the possible
effects on the health and safety of the public and effects on the alternatives
for clean-up between an early decision on decommissioning or reuse of the plant.
For example, from a waste disposal standpoint, it would appear to make more
sense to decontaminate the plant rather than dispose of plant materials prior
to this decontamination effort.

Sincerely,

Section 2.1 - The statement that it is the staff's position that
TMI should not become a permanent waste repository site is indeed a very
important conclusion and should be given much more prominence than an isolated
sentence in this particular paragraph.

Attachment

A-124

Section 5.2.4.1 - Itis stated the amount of airborne particulate
activity from the various processing alternatives has been estimated based on
experience with the more complex chemical reprocessing operations. Has
experience with processing at ThI using EPICOR IIbeen included In this estimate,and how would this affect the estimates which are used for all succeeding dose
assessments?

Section 2.1.1.2 - The motor operators on the two valves that are
discussed inthis section must remain operative to provide for long-term forced
cooling of the core, rather than to maintain the present safe cooling mode of
the reactor.
Section 2.1.3.1 - The statement ismade that a dry core could become
physically unstable in some regions and criticality might occur. This statement
appears to be inaccurate, since the low enrichment of the 1711
core ina dry
state prevents criticality regardless of the configuration. It has been determined that enrichment inexcess of 6%would be required for criticality to occur
inany dry configuration, even ifa reflector-were surrounding the configuration.

In the description of Table 5.2-4 and all subsequent similar discussions,itshould be stressed that the factor of conservatism only applies to particulates
and not to tritium. Therefore, all except the tritium values would be increased
by a factor of 105 if regulatory guide assumptions were used.
Section 5.2.5.2 - The doses which were calculated for the consumptionof drinking water appear unduly conservative. Rather than assume the low flowof record for dilution inthe river, the more appropriate assumption shouldbe the average river flow, since discharge would occur for a long period oftime and, inmost cases, the discharge iscontrollable. This comment also
applies to other dose estimates using similar assumptions.

Section 2.2 - The title of this section should more appropriately beManagement of Radioactive Wastes since disposal appears to receive very little
mention.
Figure 3.2-2 -It is understood that the route for radioactive waste
shipments inthe vicinity of the TMIlsite isinerror inthis figure. The
correct route should be north on Interstate 81 rather than south and then northon Route 15.

Section 6.3.3.1 - It isstated that small quantities of dissolved
radioactive gases would be released during the processing, but existingprocessing equipment could readily handle this gas. What existing processing
equipment justifies this statement?

Section 4.3.1 - It isstated that the mini-decay removal system will
be used to spare the normal in-plant decay heat system from becoming grossly
contaminated. A more important reason for not using the normal decay heatremoval system appears to be the fact that it has a relatively high design
leak rate and, therefore, could cause additional contamination of the auxiliarybuilding with a potential for small additional releases of radioactive material
to the environment.
Section 5.1.4.1 - NRC Regulatory Guide 1.140 is stated to have aconservative factor of about 1 x 10+5 above more realistic assumptions. This
amount of conservatism appears to be excessive and requires an explanation of
the assumptions.

Section 6.3.4.1. - The assumption that 0.1% of the amount of radioactive material process could become airborne appears to be conservative inthis particular example because the system, as designed, will be an underwater
system and, therefore, particulate releases should be minimized. A potential
problem with this assumption appears in Table 6.6.3. Using the concentrations
which are given in this table, it appears that-the maximum concentration in
the buj1 1~ing could be as high as 40 times the maximum permissible concentration
for Cs ,.In addition, no discussion is given of the possibility of dissolved
Krypton in the reactor building sump water which-.could be released as gas during
processing.

Section 5.1.5.2 - The location for the largest average annual dispersion
factor isassumed to be in a west-northwest sector at 0.37 miles from the plant.
This location appears to be on an island inthe Susquehanna River which is not
occupied year round. A more apprSpriate dispersion factor which isused in thereference may be 1.4 x 104 sec/in

Inthe same section, under liquid releases, it isassumed that a
30-gallon per minute discharge occurs into the cooling tower blowdown. This
is inconsistent with the previous assumption of AFHB liquid releases in Section
5.2.3.2 which indicates that the allowable discharge rates would be limited byboron concentrations to a much lower value.

Section 5.1.5.3 - (This comment applies to all supplemental accident
analyses.) An annual average dispersion factor isassumed for this particular
accident. This and most subsequently assumed accident releases appear to occur
over a very short period of time; and, therefore, itwould appear to be more
appropriate to use a short-term dispersion factor to get a realistic dose
assessment for accident analysis. The disclaimer that states that the dose
will be 500 times greater or smaller is not very reassuring and could be
eliminated for most of the subsequent analysis.

Section 6.3.4.2 - The accident analysis for leakage of reactor building
sump water should state the assumed river flow which will give this particularconcentration at the nearest potable water supply intake. Ingeneral , there
is a need for a better description of the assumptions that are used for allthe various accident scenarios, which could be included as an appendix.

3
2

A-125

of total body dose, a discussion should be given of how this is reflected in
the calculation of probability of cancer death over the lifetime of the individual,
since individual organ doses have a lower potential for causing cancer fatalities
than whole body doses.,

Section-6.3.5.4 - The discussion of behavior of radionuclides in
the Susquehanna River and Chesapeake Bay should include an estimated radiation
exposure to the public from eating the shellfish and fish from these waters.

Section 10.4.5 - A hypothetical two-inch diameter hole in the bottomof the pressure vessel appears to be an incredible accident. A more likely
accident which should be discussed is a small break in the reactor coolant system
without makeup.
In any event, it appears that the approximately 115 kilowattsof thermal energy which is being generated by the core at this time is insufficient
to cause a melting of the fuel using reasonable assumptions.

Section 6.6.3.1 - It appears that only cement and vinyl ester styrene
are assumed to be immobilization agents for the zeolite/resins systems. Oneof the more promising possibilities for solidification that should be discussed
is vitification in glass.
Section 7.M.2.1 - The EPICOR I system is listed as an alternative for
initial processing of primary system water. It should be noted that no environmental assessment was done for this sytem and, therefore, prior to use anenvironmental assessment would be necessary.

The following comments are related to NUREG 0698 entitled, "NRC Plan
for Clean-Up Operations at Three Mile Island Unit II."

Section 8.1.4.2 - It is stated that the inventory of Krypton-85 ina single fuel element is about 1.5 curies. This appears to be a misstatement
since total core inventory of Krypton-85 is estimated to be about 105 curies.
This would give about 565.curies per element.

Page 3 - It is not discussed how the TMI-2 Advisory Panel, which is
mentioned in the footnote, will interact with the Three Mile Island Program
Office. In order to provide a significant role they should have early andcontinuing involvement in the process.

Section 9 - This discussion concerning temporary storage and transportation of fuel and solid waste appears to be adequate. However, thediscussion concerning disposal of these materials is totally inadequate. A
discussion is needed of the alternatives for off-site storage and disposal of
the radioactive wastes along with possible contingency plans which may benecessary if disposal sites are not immediately available. This discussion should
include an analysis of environmental, public and occupational health impacts.

Page 6 - A discussion is given of the decision-making process which
is followed for alternatives which are within the scope of the PEIS and also
those not covered by the PEIS. However, it is not indicated what, if any,
input the public and State will have in the final decision-making process ofdetermining which alternative is the most appropriate.

In addition, this section should include a discussion of the treatment
and disposal of non-radioactive wastes such as water treatment sludges. This
would provide information to the public as to the existence of these wastes andalleviate concerns when these wastes are disposed of at acceptable facilities.
Section 9.5.2 - An analysis should be made for potential accidents
during storage of radioactive material which could be caused by tornados orfloods which may impact buildings which are not qualified for these particular
design basis events.
Section 9.5.2.2 - An accident dispersion factor of 5 x 10-3 sec/m3
is used for this particular accident. A similar dispersion factor should be
used for all accident analyses which involve short-term releases.
Table 10.1-2 - The amounts of radionuclides which are summarized as
being released to the ri.ver (if approved) appear to be very low for theprocessing of a reactor building sump water.
Table 10.3-1 - All doses, in this table and in the supporting sections,appear to be total body doses to the maximum exposed individual.
There needs
to be a discussion of total body doses and how individual organ doses are taken
into account. If individual organ doses are taken into account in the definition

4

A-126

LEAGUE OF WOM-EN VOTERS OF PENNSYLVANIA
SrTRwBRIDGE & CLOTHIER

8:/h & MarkAe Streets*

Philadelphia, Pennsylvania 19105
November 10,*(215) 627-7937

1980

League of Women Voters of Pennsylvania
Statement to NRC - page 2
available or if operations need significant change, it is vita2
that the committee remain in place during the entire projected
five to seven year clean-up period.
The League is critically concerned about the storing of nuclear
and hazardous waste material on Three Mile Island because thefragile land area and the Susquehanna River a drinkin
island is'aDuring this period of temporary waste storage, thewater source.
League believes that it is of utmost importance to maintain vigilant on and off site monitoring for contamination of the soil andRegular inspections of the storage
ground and surface water.
,containers for leakage should be a part of the monitoring.
Citizens should continue to be part of this monitoring process.

STATEMENT TO THE NUCLEAR REGULATORY COMMISSION ON THE PROGRAMMATIC
ENVIRONMENTAL STATEMENT FOR DECONTAMINATION OF THREE MILE ISLAND II

I am Anne Valsing of the League of Women Voters of Pennsylvania
The League
representing 66 local Leagues throughout the state.
of Women Voters of Maryland concurs in this statement. Thank you
ImpactEnvironmentalonthefor this opportunity to comment
Statement for the decontamination and clean-up procedures of
The League, on theThree Mile Island Unit II nuclear power plant.
national, state and local levels, has watched developments at TMIwith great concern since the accident there in March 1979.

The decisions being made by the NRC during the clean-up of TMI areof precedent-setting nature. Citizens around other nuclear plants
and in other countries are watching the degree of concern-shown by
Public health and environmental
the NRC to the clean-up process.
We urge the NRC toissues here have world wide ramifications.
monitor not only for immediate safety reasons but also to continue
long range monitoring and evaluation programs which include studyof human, water, animal, and aquatic life and of vegetation.
Studies designed and carried out during the process of the deconThetamination of TMI should be beneficial to future generations.
League urges the NRC to do no less.

The League of Women Voters commends the Nuclear Regulatory Commission (NRC) for creating the citizen advisory committee of government officials and concerned ctiziens, for the purpose of following carefully and commenting on the Environmental Impact Statement
The participation of this committee(EIS) and clean-up procedures.
in the ongoing process of considering the best methods for clean-up
and the possible effects of the alternatives appears to be a concrete step toward allaying the fears of the population surrounding
Three Mile Island. Because of concern for the health and safety of
the citizens and environment of central Pennsylvania and parts ofMaryland, it is very important that the people of the region know
about the problems engendered by the accident and understand thepros and cons of available options as the clean-up proceeds.
The League of Women Voters strongly believes that citizens have abasic right to know about governmental actions and decisions thatwill affect them. We think that governmental bodies must protect
the citizens' right to know by giving adequate notice of proposed
action, holding open meetings and making public records accessible.
Citizens must be able to fully participate in and truly influence
the decision-making process.
The League believes that the advisory committee must have access to
all relevant information concerning the clean-up process, withfreedom to express to the public and those involved in the clean-up
The committee must also havethe results of their investigations.
adequate funding for clerical work and for the hiring of experts inorder to understand the extremely technical data which may be the
Because of the unknown conditions
key to making wise decisions.
which may be encountered during the clean-up process, and because
statements in the EIS have indicated that supplements to thisoriginal statement will be issued when more information becomes

A-127

ur. 3ernard J. inyder,
Progrv±m office,Pro7rarn Director, til
Office of Iuclear deactor i-egulazlon
501 Vine Street
17057
Middletown, PA
November 15, 1930the ýoamissioners,
the Auclear negulatory Comamisslon,
Washington, D.C. 20555

32 dalley Drive, ID3,
Anfl.ville, gi, 17003,
Uove::iber 1), 19-3D.
Ae: Com2ment on NU•ii
Z;:X',2.L

063

This letteris written to give the commission some reactions to
the 4Uigf-0683. oraft Frogeamn-latlc dnvlronmental itatement,
physicist and electronics
Docket i4c. 50-320. 1 am a retired
We are customers of electricengineer living 12 miles form tii.
power delivered by the -et-&d system. We were here on the day of
the accident and almost every day since that event.

Director
TMI Program Office
U.S. Nuclear Regulatory Commission
Washington, DC 20555

This comment is primarily about the disposal of the treated liquid
5 sections
wastes resulting from this accident. I have read the firstsuim-ary sections. It looks
of aU:ti,-0683 and some of the later
like a good job.

Dear Director:
I'm writing in response to the draft PEIS on TMI #2 clean-up. Most of
my commentsare on record at a November 10, 1980 meeting held in Harrisburgwith the NRC.

It appears to me that it could be improved by generating a table
which directly compares the present nuclides concentrations in the
6usquehannariver water with the expected concentrationsrin thedecontaminated liquids.Ito be discharged into the river. You can
is not easy.
dig that out of xaEa;-0683, but it

There is no doubt that all citizens of the area want TMI #2 cleaned assafely as possible in terms of worker and off-site population radiation
exposures and "disposal" of wastes.

if it has not already done so, the .ACC should set a policy about
the concentrations of the nuclides in the decontaminated water.
power, I would object
As a knowledgable customer for electricalto carrying out procedures which will reduce the concentration
the nuclides to values less than that in the upstream riverof allthe nuclides
water, say at Harrisburg. If the concentrations of allin the decontaminated TI accident water are reduced to values lessthan the upstream river water, this would amount to trying todilute the contaminated river water flow immediately upstream of
Zul by adding the less concentrated fl:I accident water. It would be
unconscionable to expect customaers and taxpayers to have to support
such a procedure.

I feel my comments will be more helpful in tne future as various specificstages of the clean-up are publicized and open to public comment.
It is my hope that EPA will be able to assemble a reasonable array of"independent" specialists to be utilized throughout the clean-up.
Tne
I'm encouraged by tee formation of tue Citizen Advisory Committee.
meeting on November 12 was a very positive and open session. My main concern
is that all those on the committee really care about tnis clean-up and affected
populations.
Those that are not committed or have poor attendence should be
replaced by consulting directly with the leadership of local organizations.
Sincerely,

I know.
nuclide in this situation,
Tritium is the most difficult
however, if a supply of water-having tritium content less thanthe upstream river water can be found locally, it would be possible
to finish the dilution with that. This procedure should not be
carried much past the point where the tritium concentration isequal to that in the upstream river. Then the purified TI' accident
water should be put into the river, with an explanation to the public,
no equivocation on the matter, and no apologies to anyone.

&oal . Hoser

Carrying this approach one stepof low tritium
the availability
the final dilution. ýuppose low
from an aquifer which would not

A-128

farther, have you investigatedwater from nearby wells to perform
tritiumu water can be withdrawn
be utilized in the period of ten

-U2

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c.:then tr used
to CO.nietieLe L,u. iolnof o- acciaent ito thu river%ater concentrations. if necessary, sojie hiher
Dritlur• level"'tc.
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river water value6 tInJ no

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1. D. #5
York, Pa. 17402
November 15, 1980

/ /~•J~..A.2,A~'~

Bernard J. Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission~

Washington, D. C. 20555
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Dear Mr.
- ,--,,41 aL~'NUREG-0683, Docket No. 50-520
Draft Programmatic Environmental
Impact Statement

Snyder:

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Once again you are asking the public for comments on thedecontamination and disposal of radioactive wastes from Three
Mile Island.

-

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re:

~

The public made their comments on the disposal of thekrypton gas and, in spite of the fact that the majority of thecomments opposed the venting of the krypton, the NRO allowed
the venting to be done.

~I,.

The majority of the meetings held in the area to discuss
the PEIS were with groups having financial interests, not withthe general public who has a more important interest --healtheffects!

Both NRC and TMI officials have repeatedly said that they
do not intend to turn TMI into a high level radioactive waste
dump. There is no such thing as an interim storage facility.
An interim storage facility turns into a permanent storage
facility.

To suggest the storage of radioactive waste on an islandon any river is an irresponsible suggestion.
We now have a severely damaged reactor and an unntiiatedamount of nuclear waste in our area, along with an id1in,, fly
fueled reactor.
During the cleanup (with an admitted possibilityof a serious accident) it is not a good policy to have the fuelin Unit 1.
The fuel MUST be removed from Unit 1 while it isstill possible to remove it

safely.

Concerning the accident water, you have stated that the
NRC will not base its evaluation of the SDS on cost considerations to the utility. The "cheaper" method of disposing of
the krypton gas was used even though releasing more radiation
into the atmosphere is

A-133

detrimental to the environment.

IBernard J. Sn.der, Program Director
November 15, 1980
Page 2.
You have stated that other methods of treating the water
were considered by the NRC, and that diluting and releasing it
into the Susquehanna River would have no adverse health effects,
according to staff conclusions.
Why are you minimiuing theseriousness of the effects of the radiation that we, who live
nearby the plant, have received already and will be exposed toduring this cleanup operation?

Susan ShetromBox 629 RD 1
Etters, PA 17319

Bernard J. Snyder, Program Director
Three Mile Island Program Office
Nuclear Regulatory Commission
20555
Washington, DC

Paragraph 10.7.3 of the PEIS concerning water and air
resources is

not valid because of unknown factors.

Time hasshown that calculations by self-proclaimed experts on theeffects of radiation hazards to the environment being "insignificant" are false.
We can't see the effects of the radiation right awaythat will take time.
But we can see the effects of thepsychologicalstress--Dear Dr.

Some basic flaws in the Programmatic Environmental Impact
Statement that will require further study and evaluation are:

You will have to admit thatno one (not even the NRC)
knows just
how much radiation has been released from Three
Mile Island since the accident occurred on March 28, 1979.

1.

The evaluation of psychological stress is inadequate
and faulty. Current stress is not caused by perceived
stress but by the reality of a cleanup delayed by the
incompetence of Metropolitan Edison and the Nuclear
Regulatory Commission.
The stress is further
heightened by increased rates and the possibility of
the insane restart of Unit 1. High levels of stresscontinue for some members of the community and longterm psychological effects on the great majority ofthe people can be expected for many years.

2.

The problem of how and where to dispose of the wastes
resulting from the accident and cleanup process isinadequately considered.
There is no assurance thatany waste site will accept the low-level waste in theamount postulated by the NRC staff and ultimate disposalof high-level waste remains an unresolved question.

3.

The NRC staff dismisses the question of whether TMI
Unit 2 will be decommissioned or prepared for restartby stating that it is not within the scope of the
PEIS.
In reality the methods of cleanup Pre very
dependent on the decision to restart or to decommission
the unit. Certain processes could severely demage theequipment, making the final disposition question
essential in selecting the proper methods to be used.
Thus the question of restart or decommissioning of theplant must be considered in depth within the PEIS.

The studies cover a fifty
mile radius from the plantwith a large population.
That makes the average dose received
average radiation!
You can'tmuch smaller.
NUREG-0683 mentions the large number of truck shipments
will be made(660 to 1700) carrying waste to disposal sites
over a long period of time and should cause little
trafficcongestion.
I am not worried about traffic
congestion, but I
am worried that
there could be accidents involving these shipments and thatradiation would be released.
If something canhappen --

it

will!

The whole PEIS is slanted toward the eventual restartof Unit 2 aid not toward the most important factor -- minimizing the total amount of radiation exposure to the public.
Sincerely,

Alice A.

CC:
cc.
cc:
cc:
cc-

cc;
cc:

Snyder:NOWI

HermanJohn F. Ahearne, Chairman
Peter A.' Bradford, Commissioner
Victor Gilinsky, Commissioner
Joseph W. Hendrie, Commissioner
The Honorable H. John Heinz III
Congressman Bill Goodling
Congressman Allen E. Ertel

-1-

A-134

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4.

lack of cost estimates in this
There is a total
has
The NRC staff
evaluation phase of the PEIS.
promised that the cost factors will be provided in
the period for public comment
the final
PEIS (after
has passed).
In view of the precarious financial
condition of Metropolitan Edison, the NRC's assertions
that costs are not a limiting factor can hardly beviewed as realistic.

5.

In the PEIS the NRC makes the assumption that cesium
and strontium from the planned release of processedwater (which will contaminate Chesapeake Bay seafood
as far south as the Potomac River) will not effectA separate EIS thatthe marketability of the seafood.
includes market research data on radioactivity in
Chesapeake Bay seafood must be performed prior to
making determinations as to the effects of radioactive
contamination of Bay seafood on the seafood industry.

Ct--

Very concerned.

Susan Shetrom

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RPF Ecolo ical Associates
727 Reba %lace
Evanston, Illinois 60202
November 12,

Nuclear Information and Resource Service
1536 Sixteenth Street NW, Washington, D.C. 20036

November 14,

1980

1980.

Bernard J. Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D. C. 20555

Matthew Bills
Environmental Protection Agency
Associate Deputy, Assaitant Administrator
For Office of Monitoring andTechnical Support
401 M. St. S.W.
Washington. D.C.
20460

Dear Sir:I have reviewed the Draft Programmatic EIS relating to decontamination anddisposal of' radioactive wastes resulting from March 28, 1979 accident Three
Mile Island Nuclear Station, Unit 2.
I have only one comment which issummarized below.

Dear Hr. Bills:
We are very pleased that Environmental Protection Agency (EPA) is sponsoring an
independent scientific review of the Draft PEIS on TMI-2.
We are looking forward to
the information it will supply to answer questions raised by unresolved problems
identified in the Draft.

Page 3-18 suggests that the bald, eagle and osprey are likely to take foodfrom the Susquehanna River below Three Mile Island. The bald eagle is an
The analysis on pages 6-26 to 6-30 should include an
endangered species.
analysis of radionuclide concentration and absorbed radiation dose inbald eagles or ospreys that might feed on fish for several months in theSusquehanna River or Chesapeake Bay following controlled or accidental
releases of processed water. Because compounds such as cesium orstrontium become concentrated many-fold times more in fish-eating birds,
would such concentrations harm individual birds or affect their reproductionin the following year(s)?
Thank you for the opportunity to comment on this EIS.
copy of the Final UIS when it becomes available.

(202) 483-0045

Some processes described in the Draft PEIS which are greatly deficient and needmore research done, in order to be useful for decision making are:Need to identify current restrictions as set out by present license requirements inorder to determine what other radiation standards are needed to be set for the cleanup process itself.
Need a description of costs for all suggested processes to be used in the cleanup.

Please send me a

Need a definition of high-level waste.

Respectfully yours,

Need to identify disposal methods suggested for high specific activity wastes andresins.

Robert W. Guth, Ph.D.
Ecologist

Need a description of on-site wastes and eventual disposal of that waste.
Need more alternative processes described especially for disposal of high level
wastes and water.
Need to do a study on the marketability of fish in the Chesapeake Bay if radioactive
water is dumped into the Susquehanna River.
Need to monitor river water in light of expected variation in the amount of radionuclide charged clays suspended in the river at any one time.
The amount of suspended
material will vary widely due to variation in river turbulence. Please see thecomments by Steven Sylvester which are attached.
Need to monitor worker exposure to radiation by recording cumulative doses from

A-136

0

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100

1

2
medical and ocupational exposure. 'Need to keep records for 20 to 30 years on all
workers involved in the accident and the cleanup (regular and transient workers).

STEVEN SYLVESTER'S COMMENTS TO THE E.P.A. AT NOVEMBER 6. 1980 MEETING
RE: DRAFT P.E.I.S. FOR THREE MILE ISLAID UNIT 2

Need to monitor health effects as a part of the cleanup process.
It will provide
valuable documentation in studying the effects of low-level radiation from a nuclear
power plant accident rather than extrapolating information from nuclear weapons
testing.
Monitor infants born during and after the accident within 30 miles of TMI toevaluate respiratory diseases, immunological defects, congenital defects, genetic
defects, Down's Syndrome, Leukemia and other cancers.
Select a population of young children who were within 30 miles of TMI at thetime of the accident and follow them for health effects for 20 to 30 years.

Models presented for the behavior of radionuclides discharged via plant
effluents into the Susquehanna River and upper Chesapeake Bay are notsupported by existing scientific data.

Estimates of resulting radionuclidebuildup in river sediments (6.3.5.4.) are unreasonably low.

Do case studies on women who were pregnant at the time of the accident March 28,
1979, and women who become pregnant throughout the cleanup process.
Do case studies on a random population of women of child-bearing age, who live
This study should be carried out over the entire
within a 30 mile range of TMI.
It should be done to study reproductive history such as: ability
cleanup years.
births, labor
to conceive, irregularities of menstrual cycle, miscarriage, stilland delivery, C-section, genetic defects and births resulting in congenital defects.
Do extensive follow-up on infants with hypothyroidism (including the Amish population) within a 30 mile range of TMI.
Infants should be studied who were in utero
at the time of the accident.
Do studies in great depth and over a long period of time studying the effects of
Cows should be especially studied because of theirradiation on the animals.
rate of reproduction and ability to study the genetic effects on generation to
generation. Animals should be studied for miscarriages, stillbirths, c-sections,and delivery of offspring with congenital defects.
Due to the deficiencies that we have noted, cost factors omitted and alternatives
yet to be presented, we request that a Revised Draft PEIS be issued at this time in
It is imperative that the public have an opportunity to replace of a Final PEIS.
view the new information to be presented.
We are in hopes that EPA will also make these recommendations to the Nuclear
Regulatory Commission.

NUREG-0638 (p.6-27) recognizes that isotopes of cesium have an appreciable

tendency to combine with clay particles suspended in river water.

on an estimate of 10 to 20 mg/1 suspended clays during normal flow and
40 mg/i during storms, NUREG-0638 concludes the bulk of the cesium (75 to 100%)
will remain attached to the suspended clays and only a small percentage will
be deposited in river sediment (Gross, et. al.(1978) is

We are pleased for your attention to these matters of grave importance to the
public in the cleanup of Three Mile Island.

These predictions are wrong for the following reasons:(1)

Gross et. al. (1978)

found that under normal circumstances between

one-half and two-thirds of the suspended material that passes Harrisburg,
PA isdeposited before Conowingo,(2)

Schubel (1968,

Fig.

MD.

1B) provides data showing the suspended load at
These data indicatethat the bulk of the cesium (as well as other radionuclides that tend to
attach to clay particles) will be deposited in the Susquehanna Riversediments.
still

(3)

Since clays settle out of river water only in areas of calm or

water, most of the cesium charged clays will be deposited in selectareas,
Coral Ryan
For the Nuclear Information and-Resource
Service, Staff

cited, reference 13,

by the document.)

Conowingo, MD to be less than 10 mg/1 65% of the year.

Attached also are comments made by Nancy Kelly, Senior Staff Biologist for the
Chesapeake Bay Foundation.
Please also refer to comment being submitted in conjunction.with these comments by Judith. Johnsrud and Chauncey Kepford.

Based

resulting in appreciable reconcentration of radionuclides.

Predictions for the behavior of cesium charged clays reaching the upper

Chesapeake Bay do not consider that the clays will undergo flocculation
when encountering salt water.

A-137

Flocculation results in rapid deposition

Syivester page z
Sylvester page 3of clays,suggesting that the remaining cesium loaded clays will be depositedthe period over which that samples are composited.

Contaminated samples

and reconcentrated in a select area of the Bay.
should not be composited with any samples collected prior to any
uncontrolled releases.
NUREG-0683's Environmental Radiological Monitoring Plan isinadequate forthe following reasons:
References(1)

Most monitoring efforts involve air sampling while most remaining

clean up activities involve the clean up of liquid effluent.
(2)

M.G. Gross, et. al., "Suspended Sediment Discharge of the Susquehanna River
to Northern Chesapeake Bay, 1966-76".
Estuaries 1(2): 106-110, 1978.

The monitoring consists of six different plans with differing goals

and areas of concern.

A single, coherent plan

J.R. Schubel, "Suspended-Sediment Discharges of the Susquehanna River at
Chesapeake Science, 13(1), 52-58.
Havre de Grace, Md."using the resources of thesix monitoring groups in a coordinated manner should be developed.
(3)

Monitoring of the Susquehanna River's bottom sediments and invertebrates

is not detailed or extensive enough to detect any reconcentration ofradionuclides in select areas.

Analysis of bottom samples should include

the physical characteristics of the sediments to determine if

Steven Sylvester
Department of Geology
Franklin and Marshall College
Lancaster, PA 17604

the sample

includes recently deposited clays.
(4)

Monitoring of river water is

not detailed or extensive enough in lightof expected variation in the amount of radionuclide charged clays suspended
in the river at any one time.

The amount of suspended material will vary

widely due to variation in river turbulence.
(5)

Contingency Surveillance Procedures (11.8)

are inadequate to monitor

the dispersion of radiation resulting from any uncontrolled releases.

Themaximim two hour response time for a mobile laboratory and six hours for
airborne monitoring do little

to monitor a short, intense airborne release.

Four mobile laboratories should be positioned around the plant (two on eachside of the river) at all times.

The monitoring aircraft should be

hangered locally.
Using composite sample analysis for monitoring uncontrolled releases
in the Susquehanna River results in as much as a week's delay since that is

A-138

ENVIRONMENTAL COALITION ON NUCLEAR POWER

ADDITIONAL SUMMARY CITIZENS' COMMENTS ON THE
DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENTELATED TO DECONTAMINATION AND DISPOSAL OF RADIOACTIVE
WASTES RESULTING FROM THE MARCH 28, 1979, ACCIDENT AT
THREE MILE ISLAND NUCLEAR STATION, UNIT 2 (NUREG-0683)

C•DiOrectr: Mr. Qeorge BoStettm -R.n. el, Peawh Botto.m, Pa. 17663 717-548-2836
Dr. Judith Johnermd-433 Orlando Avenue, State Collage, PG. 16801 814-237-3900

General Comments on Format and Content:
The flaws, errors, and omtssions in NUREG-0683 are sufficiently
fundamental and pervasive to mandate the withdrawal of this draet
document and a complete revision of its contents. The information
included in the draft, while voluminous,

is so poorly organized andpresented as to render the document virtually unreadable for anyoneof reasonable intelligence. In order for proper and meaningful conments to be submitted, the incomplete and erroneous data must be fully
supplemented and corrected, units of measure brought into conformanceto allow for accurate assessment, and the entire text rewritten in
intelligible, logical, coherent language and order.
Although many "public meetings" have taken place and the time
for public comment extended from 45 to 90 days, the Nuclear Regulatory
Commission has failed to provide for proper and full hearings to fulfill the spirit and purpose of the National Environmental Policy Act
of 1969 and the NEPA Regulations of the President's Council on En-

7_1

vironmental Quality.
Under no circumstances should the NRC Staff be allowed by theCommissioners to issue a Final PEIS accompanied merely by the Staff's
promises to produce subsequent Supplements in which any still-unresolved
issues might be addressed. All inadequacies identified by commentersmust be addressed in a revised draft, and the Commission must require
its Staff to correct all errors and deficiencies prior to issuance of
the Final PEIS and the Commission's approval of the decontaminationplans and procedures.
Major Deficiencies of the Draft and Recommendations:I. The Draft PEIS fails to address appropriately the long-term
disposal of TMI-2 accident-generated high-level radioactive waste. We
draw the Commissioners' attention to the fact that the NRC in its supposedly generic rulemaking proceeding on the Reassessment of Confidence

A-139

-3-

-2in the Availability of Radioactive Waste Disposal and Spent Fuel
Storage (Docket PR 50, 51) has failed totally to consider these ThI-2
wastes. Because of the propensity of the Susquehanna River to flood,

6. The Revised Draft PEIS must contain full analysis of themultiple options for decontamination for the entirety of the cleanup.
Where uncertainties or lack of operating experience with techniques

interim storage of radioactive wastes on this island until the Year
2000 and beyond, the time period being considered in the Waste Confi-

exist, they should be clearly identified.as unknowrs. No optimistic
assumptions that experimental methods will succeed should be permitteddence proceeding, is not acceptable.

in the Revised Draft.

Hence,

the PEIS fails utterly

2.

The present Draft lacks sufficient depth of In-

formation and analysis of alternative methods for cleanup. This deficiency must be corrected, and the methodological equivalent of event

to fulfill its basic purpose under NEPA.
The fundamental decision of whether TMI-2 is to be decommis-

tree analysis applied to all options. From the revised and expandeddiscussion of decontamination options the Staff must develop and clearlysioned or ultimately restarted must'be addressed and resolved before
a properly developed programnatic cleanup plan can be approved by theCommission and before realistic cost estimates are available. The
Draft PEIS fails to do so.

delineate a full programmatic plan; such a plan Is missing from the Draft.
7. The discussion and quantification of health effects must be
revised in accordance with the state of knowledge on the health and3. The Draft PEIS does not fully address the management anddisposition of all radioactive wastes generated by the TMI accident

genetic consequences of radiation exposure, rather than policy.

Thissection must reflect the fact that there is a substantial controversy
concerning the effects of low dose and low dose rate irradiation, as

and associated with the decontamination and repair or decommissioningof the plant. The condition of the Epicor-IT resins, for example, has
deteriorated markedly since the publication of this document. Mitiga-

well as large areas of Ignorance, as was elucidated by the National
Institutes of Health, March, 1980. The Revised Draft PEIS must include
the full range of views of scientists who are independent of governmental
and nuclear industry programs and policies and who reach different, moretion strategies for unsuccessful or inadequate cleanup activities mustbe fully examined. The passage of the referendum in the state ofWashington on November 4, 1980, may prohibit the use of low-level waste

conservative conclusions concerning the health and genetic consequences

facilities at Hanford; delays in approval of either regional or Intrastate low-level waste disposal sites must be reckoned with. These issues
and attendant costs must be more fully considered.

of radiation exposure.

Again, the revision should clearly state theuncertainties.
8. ILong-term studies of health and other impacts on the affected
populations of the TMI area and animal studies must be designed to Include control populations that are indisputably beyond the range of theeffects of the accident in question. The Revised Draft PEIS must address the plans for such studies.

4. The Draft PETS fails to.provide a believable mass balanceaccounting for isotopes originally in the core. NRC Staff must revise
the mass balance to provide a complete and credible accounting.
5. The Draft PEIS lacks a proper discussion of how TMI-2 reached
its present condition and lacks adequate current factual informationon the actual, as opposed to theorized or assumed, status of the plant.
The Revised Draft PEUS must include a locational inventory of all radio-

9. The socio-economic impacts of the decontamination and waste
disposal are inadequately addressed. The escalation of TMI-2 cleanup
Costs to the one billion dollar level during the four months since releaseactive materials, identifying clearly where all isotopes are presently
on the site. This discussion should also account fully and in detail forall shipments of contaminated materials and their disposition upon arrival
at destination. Concern has been expressed in the TMI area that somewastes are being illegally removed from the island and disposed of.

of NUREG-0683 is indicative of the total inadequacy of the discussion ofthis Issue in the present Draft. The Revised Draft PEIS must include
a fuller discussion of the comparative costs of all alternative means

A-140

-4of plant decontamination and disposal of all accidentand cleanupgenerated radioactive, and other, wastes. The costs
and benefits ofstrategies of fully deconissioning ThI-Z and of substituting
conservation must be incorporated into the Revised Draft PEIS.

"-/or

10. Those costs which are less amenable to strict quantification
but nonetheless are real costs to the social, economic,
and psychologicalwell-being of the residents of the TMI area, the lower
reaches of theSusquehanna River, and Chesapeake Bay mrust be fully assessed
for theentire period of cleanup activities.

_o-cc..ciz•" v__-- - •- ei_ . .....<_,_+ re-pConclusion:
The Draft Programmatic Environmental Impact Statement does
notsatisfy NEPA requirements. It should be withdrawn.
A fully revised
Draft PEIS must be produced to respond to the deficiencies
identified
by public and agency commenters and the Revised Draft PEIS
must gothrough a complete public review procedure, culminatingin NEPA public
hearings.

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Comsents Received at September 30, 1980, Meeting with Maryland Citizens inAnnapolis, Maryland

going to be deadly for a quarter of a million years and we have no feasible,
foreseeable technology to contain this waste, and we don't really have-any guarantee that it's going to be contained and it just appears to me that we haveinadequate technology and inadequate guarantees that deal with the. whole situation.
And I think in light of this, the best possible thing to do is to shut down all
nuclear power plants and employ the best available technology to get out of themess we have now and realize that even employing the best available technology,
whatever it costs, it's not going to be satisfactory but it's the only alternativethat we have.

JOHN CAMPBELL CTr 25): What happens if you decide to dump the water into theSusquehanna River but the river flow is lower then you are now anticipating?
JOHN EABLER (Tr 29): My feeling is that you are making a mockery of the NEPA
process by your intention not to hold a public hearing designed to maximize
public participation in Baltimore and Harrisburg as was requested by manygroups. I don't believe that NTRCdoes have a real interest in conforming tothose NEPA regulations and considering the public concern in getting the bestsolutions to the cleanup, and hearing from independent scientists, requesting
the claculations and assurances that you give us. I feel you can reverse thatproblem by having the public hearings that so many people want, by funding independent scientists as you promised to do, chosen by a citizen advisory committee,
or at least talking to us about it, taking no more cleanup actions until thesequestions have been resolved, and by not dumping water into the SusquehannaRiver until the scientific controversy about the posaible effects of that havebeen resolved and until you can prove that the marketability of the seafood
downstream won't be affected.

DEBBIE GEORGE (Tr 53): First of all, I would just like to say that the document
is very poorly done as far as assuring the public that there is no problem.
There are things that are said in the document about the seafood industry, that
it is taken into account. One thing in particular, there is a statement that
there will be low, but measurable, amounts of cesium-137 that will be detectable
for some amount of time, approximately 18 to 24 months in the Upper Bay. Thatis a really critical consideration. The Upper Bay is in a very critical condition. The finfish in the Upper Bay have been decreasing. There are no shellfish
up there so we don't have to be concerned about that, but the flepartment of
Natural Resources reached the conclusion in a report that's used as reference inthe EIS that there is "something wrong with the water" and they don't know what
it is. So, that is one thing that we are concerned about, that the ESE says that,is the public is properly informed there should be no problem. But this is not,an example of properly informing the public. And I don't think 25 meetings in
the area of the Chesapeake Bay and Susquehanna River is properly informing the
public. I don't think you are letting us do that. I think that so far everyone
is saying that the Susquehanna River alternative is just an alternative -- youare open to other alternatives. And yet, the Susquehanna River alternative isconstantly brought up. There were graphs and charts and maps on in tonight andI have heard people say that it is just going to get dumped sometime. They talkabout accidental releases in the EIS. There is going to be a big accidental
release, so we are very suspicious and very unwary. We also feel that there needs
to be independent scientific review. And again, to reassure the public, ourefforts at seafood marketing which have really just begun to pay off will be justannihilated if the public is not properly informed and, again, this is not an examthat inple of that. So, I guess really I can sum up my whole statement in saying
order for me to really represent Watermen just to say that we could not at all
support in any way, shape, or form any kind of dumping or dilution of any kind ofwastes into the headwaters of the Chesapeake Bay or into the Susquehanna River.-

CORAL RYAN~ CTr 40): That input is this draft going to have in the actual
decisioumaking? How does the public get involved in those specific decisions
on the cleanup process? When you ask a government agency such as EPA to evaluate.the document, their scientists are being paid. When an independent scientist has to evaluate this draft, he is working fulltime at some other job andwe as citizens have no funds to pay them to look at this issue.
STEVE SORRELL CTr 51): 1 think that there should not be any tritium dumping
at all under any circumstances for two reasons. The first being that the effectsof tritium have not been fully evaluated and, secondly, even if after evaluations
tritium is believed to be safe, which I find highly unlikely, it is going to be
the EPICOR II system or ion exchange resin or whatever you decide to use inundoubtedly going to let some radioisotopes get released into the environment
which was addressed to earlier as far as cesium and strontium and T don't want
to denounce the value of these machines and using them, but T think that weshould respect their limitations and that no system is going to be 100% effective. And no matter how many tines we recycle the water through these machines,
there is still going to be some radioactive material that gets released, otherthan tritium. And this is if the EPICOR II system or whatever we use is operated properly. The nuclear industry and its regulatory agencies have had along history of turning valves the wrong way, of turning off systems that shouldhave been left on, and claiming malfunctions when, in fact, radiation leaks
were occurring. I think that we needesome kind of assurances that only trained,
highly skilled workers are going to handle this cleanup and not just any personthat comes along that's willing to get irradiated to make a couple of bucks. And
finally I think that we should use the best available technology throughout thiscleanup and assure the best possible implementation of it. T think that weshould try to come about bringing economic cost of nuclear power that starts toapproximate its social cost. And what T mean by the social coat is, to really
understand the magnitude of it I think we have to be aware that as sophisticatedand complex as this environmental impact statement is that it is only dealing
with the tip of an iceberg and that the radioactive poisons that we have here are

LOUISE BEAUREGARD (Tr 57): I am dismayed that anything as acute as this would
be kept on the level of printing and meetings and meetings and printings. And I
am wondering if it's because you are not educating us as to how this really,affects us in an acute way., The concern of the route that you showed on yourmap, that's not because of the Army-Navy, game that we're a logical nuclear target, it is because *the President takes that route to Camp David, that heavy
trucking route from Washington to that point of Maryland where Camp David is,
and it would jeopardize our first family of our country and the countries thatare our enemies would certainly make that a natural target area with the heavytrucks, and I think that has not been brought out. The second thing is thecold war psychology and the repercussions from the nuclear blast in 1940 to

A-144

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on

0

___

-- 4 -3doing it.
And I don't think that the underground water supply, maybe it isof sight and out of taste a little
more than dumping it in the river, but I
think that is any safer at all,and I am particularly concerned about it.

time, while the first thing on Threethe country of Japan. And I think it'sMile Island may have been an accident, and we praise the Lord that it was anaccident, but only four weeks ago they showed clams one inch to an inch and ahalf growing inside of nuclear pipes. Now those clams had to be placed asseeds, so how long ago did that frame take place? And, therefore, I have aright to ask you, with the generation coming up, if we are being done tobecause someone did it to them? Will you alert us and why should we stop at
Congress from keeping you from protecting us if infiltration of enemy sources
are there now? I think that should be taken to the President of our country.
Our ducks on Route 2 now have thyroid goiters from the chemicals that are in
the water and the tomatoes that are grown cannot be eaten. You are not eating
the crabs that come from Maryland waters; they taste of kerosene gasoline andother chemicals.

out
don't

PHILIP CAHROOM (Tr 73):
i would like to raise three basic questions that are on
my mind.
The first
one and most specific is to agree with Miss Kelly and someother speakers that we really can hardly accept as any kind of environmental
evaluation the statements which appear a couple of places, such as, page 10-29
and page S-11 in the statement as it now stands to the effect that if the effectsof radioactive releases in the Susquehanna are properly understood by consumers
that the marketability of fishery products from the affected body of waters would

not suffer.

I have seen, in attempting to do a thorough reading of the EIS, noform of study whatsoever as to public acceptance of supposedly low levels ofradioactivity, particularly in light of scientific controversy as to what thoselevels may be and what the effects of those levels, particularly if there were
bioaccumulation or certain hot spots which might cause limited variances in contamination of seafood, what kind of public reaction there really would. be.
I
don't know, if I had not seen any comparison to the actual reaction to agricultural problems in the TMI area at the time of the accident.
I haven't seen any
comparison with other seafood contamination scares in the actual history of theBay.
There is no foundation whatsoever which I have seen for that support.
And
I don't think it'sa fairstatement lacking any support, it's
just
someone's
opinion.
Second, I would like to agree with some other speakers and point out
that the regulations as to the EIS 10 CFR Section 51.23 specifically require that
there be a cost-benefit analysis which to the fullest
extent practicable, should
quantify the various factors considered.
I think that it is also a disservice.
to the public that no effort was made or at least no effort was made to include

EDITH MAY (Tr 59): I've noticed this evening and also in the environmental
There is very
impact statement that economics has been left out pretty much.
cost-benefit analysis. You talk about the benefits of the cleanup being
littleso great over the risks of environmental factors, what could happen to theenvironment, and I don't see any economic analysis going on. I know that the
Department of Energy has economists; I assume that the NRC has economists on
I also would like to know why only the headwaters of the
your staff also.
Has anyone considered the economic impact
Chesapeake Bay are being considered.
on the thousands of fishermen in the Chesapeake Bay, the fishing Industry?
Has anyone considered what the economic impact is on Metropolitan Edison? I
have heard a lot of talk in these meetings before about the EPICOR system andhow Metropolitan Edison went ahead and spent millions of dollars and now the
NRC of going to bail Metropolitan Edison out. Has anyone analyzed what are
the various net present values of Metropolitan Edison's investments in the various techniques of processing the water, of cleaning up the plant? What is theimpact on Metropolitan Edison's current stock price? What will the stockholders
want to do? What will the Board want to do? Are you people bailing them out?
My question is not, is the NRC going to spend the money, but is the NRC goingto make it the easiest and the cheapest way for Metropolitan Edison to spend its
money? How long will it take you to put out the final? You said it took you 8
months to put out the preliminary -- from the end of November to the end of
If you couldn't come up with costs in 8 months, how are you
March is 4 months.
going to do it in 4 months?

even provisional dollar figures in the EIS.

I think that the cost of the cleanup

itselfis an environmental impact because I don't think anyone could deny that thefullcost of that is going to be passed down to the consumers in this area, whether exclusively limited to the Harrisburg area of whether passed along by theutilities
consortium to consumers up and down.the east coast, so that the dollar
figure is something that should be-included and I would hope that a supplemental
draft EIS would include dollar figures so that that might be considered.
Relatedto that, the third and final-point I have is that I suspect an assumption is
being made here or that there are underlying assumptions which depending on how
they go, would affect the cleanup decision of whether or not TMI-2 would ever berestarted or whether it is to be permanently shut down and the kind of costs thatwould result from those decisions are things that should be considered also.

It'sthose decisions as to whether it should be permanently shut down or whether a fullcleanup would result in starting up or salvaging any of the plant should -be fully
disclosed ahd the public should not be made to .pay more either economically or
environmentally to maximize the salvage value of that plant in any way,

PATRICIA CLAGGETT (Tr 72): I'd like to address my concerns to the alternative
Some of the people here tonightmay.beof disposing of the waters underground.
aware that the House Government Operations Committee today released a reportthat is concerned with toxic waste residues in our drinking water supplies inthis country - that they are very seriously in trouble and if we don't addressthat concern Immediately, we are not going to have enough water by the end of
the century. The whole debate of nuclear waste disposal has been goingon forsome time and some of the most capable minds in-the country have been addressing
I'd hate to think that we are going to
the issue and it has not been resolved.
attempt to resolve it at Three Mile Island with the Chesapeake Bay and the'surrounding communities as a ricipient of that resolution, in whatever form, sometime in the next year or two, because I just don't think that we are capable of

KENNETH MAHAN (Tr 76):ihave a prepared statement which I will excerpt later,

but there is one point that I would like to bring out and get clarified, perhaps
which came up tonight.
When Dr. Snyder was asked about the economic impact andwhy we don't have cost figures now, he said'that the cost of the various cleanup,methods is "of secondary Importance-"
I attended a meeting similar to this in
York, Pennsylvania, on September 18, 1980, and John Collins filled
the same rolethat Dr. Snyder does-here and when he was asked the same question he said that
it was of no import at all,that the only consideration would be to do it in a

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BILL AMOS (It 82): I am a delegate that represents the area that is most affectedThat is a single member district so it just leaves it up to me
in Harford County.
as that delegate to express how the citizens of that district feel about the posI want to thank you for the "seem-like" decision to say itsibility of dumping.
I believe that is necessary and I appreciate that veryneeds to be cleaned up.
much.
However, you can:see how I would strongly object to the dumping and I
think we that live there realize a few other things about the river, and I can't
help but what you said about the flow in the area of Three Mile Island - itjust doesn't exist at the Conowingo Dam. You probably are privy to all the Susquehanna River Basin information. That information will lead you to the conclusion that they have been worried about the flow in the dam ever since the last
dry spell. And, here we come into another dry area, and this summer we-had afish kill below the dam which meant, in the end, it proved that they had it
shut off for almost 72 hours.
Now, they can shut the dam down for 72 hours,
can you imagine what that does to the flushing effect of the Conowingo reservoir.
In taking dumping into consideration, you've stated what that would do to the
However, you remember
environment'if that amount of water there was dumped.
that, just remember that, something could happen to Peach Bottom, and if it did,
you would have no alternatives if you don't, what I call, clean up completely
and get it away from the river -- this strong possibility of something else
happening. Not only do you have that at the upper end of the Bay, you have
Calvert Cliffs to the bottom. Of course, flushing effect is much more there
But a combination of two accidents or evenbecause the ocean's a lot closer.
ofa large spill at Peach Bottom could aggravate the problem if you go towards
dumping. We also, in Harford County, depend of course upon the water supply.
I'm not sure that anybody sits there and drinks two liters each day of waterand I'm not sure that a lot of it wouldn't be filtered out. However, there isa bottling plant there for Coca Cola, and there's other industries there thatwould be affected because that whole corridor of Route 40 is hoped to be supplied
You go across the river and you have Perryfrom the Havre de Crace water works.
ville which can have the same problem, especially if any of these expand commercially.
I guess the final thing I'd like to say is that in this final proposal,I
I feel that there should be some more input. You're going to make a decision.
Evidently several regulatory agencies of the U.S. governfind input no problem.
One is the one in charge of licensing the Conowingo Dam. In thatment do.
I find the more input
process, it's
been very difficult to put input into it.
you get, the better off you are.

manner which is the lowest possible radiation exposure and I think that deserves.
a clarification somewhere along the line as to which is the real considerations,the secondary or no consideration-at all. Let.me just read a little
bit from mystatement in the interest of time, Itwill cut it off.
I would like to comment
also on the prospect of Metropolitan Edison running this cleanup. As I understand it, the NRC will-not choose the method of cleanup but only has a veto overthe method Met Ed chooses. We Marylanders who may drink the water possibly
released from Three Mile Island, or eat the-seafood that lives in it, need assurances that the NRC will require-Met Ed to use the safest method/for the cleanup.
Metropolitan Edison is in bad shape financially. - Two weeks ago, it laid off alarge number of workers, including 500 working on the cleanup.
The NRC should
devise plans to continue the cleanup should Met Ed go bankrupt and should devise
plans to determine if Met Ed is scrimping on cleanup to save money in a manner
which could jeopardize the health and safety of our citizens.
The cleanup is aunique and difficult technical problem.
Met Ed does not have a reputation fortechnical excellence. Saturday's Baltimore Sun notes that NRC's study found 37
serious deficiencies at the TMI-l control room and 50 less serious deficiencies.
This leaves the observer with the -fear that Met Ed-will not do the excellent job
required to make the cleanup safe. The NRC should develop plans to monitor thecleanup to see that it is being done correctly. Finally, the NRC must realizethat the public does not have great faith in it and Met Ed. There-must be someassurance for the public that this process is being done correctly. It should
be a truly independent, knowledgeable, well-financed body to monitor the cleanup
so that we Marylanders who drink Susquehanna River water are not having ourhealth jeopardized and we Marylanders who make their living from the Chesapeake
Bay are not having our livelihoods jeopardized.
JOHN ECHENROAD (Ir 78): I wouldjlike to, as a member of the Chesapeake
Energy Alliance, endorse the view that has been taked~by Marylanders here
tonight - that the radioactive discharges into the Susquehanna, into our waterw!vs would be considered unacceptabl1
CATHY RILEY (Tr 80): I am a delegate representing Harford County and chair the
Joint Energy Commi-tee in Annapolis. -lam getting the impression from what you
all have said and from some of the comments and questions that have been directed
to you that this is our bite at the apple. That we're talking about a 5- to 7year process of the cleanup and maybe I am incorrect and maybe I have been misled
but it seems to me that I am hearing that this is our one Chance as public officials and as citizens to have an input, and I find the statement deficient fora lot of reasons, some of which have already been pointed out. And I would liketo clarify whether or not when it comes time to make the various decisions andto determine alternative after alternative, whether or not you are going to havepublic hearings, whether or not you are going to give the people and the elected
officials the opportunity to comment at that time. I think it's
terribly important. You said earlier that In a decision-that the NRC was trying to make thatthey were breaking new ground. And I think we've all broken new ground with thewhole TMIQissue
The track record of NRC in the last 18 months has not been one
to be terribly proud of as far as I am concerned and I think we are all.in theprocess right now of trying to expand credibility and to-expand public knowledge
and I would hope that you are going to give us the opportunity to comment pieceby piece.

CRISTIE FIEDLER (Tr 85): Several months ago I received the NRC Draft Programmatic
EIS related to the decontamination and disposal of radioactive waste generated
from TMI accident. Accompanying the document were six pages of corrections,
including Section 10.3, "Offiste Doses and Health Effects from Normal Operation."
I would point out with strongest emphasis that the qualifying word in this phase
Section 10.3 contains tables and descriptions correlating expected
is "normal."releases of radiation during transporation of wastes to the probability of cancer
or genetic damage in the general population. -As an example I cite the conjecturethat a person exposed for 3 minutes at an average distance of 3 feet from atruck leaded with radwaste as at a highway facility might receive up to 1.3
The risk of cancer from that dose is 1.7 x 10-7.. The risk of genetic
millirems.
damage, about 3.4 x 7-7. What this data and all similar conjectures that the NRC

A-146

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7 Comments Received at October 6, 1980, Meeting with Susquehanna Valley
Alliance at Lancaster, Pennsylvania
failed to account for is the likelihood of a major accident during radwaste
shipments - a likelihood that must be considered as possible as a likelihoodof similar TMI-type accidents at qther nuclear plants. A worst-case accident
would result in exposures during shipment that would exceed those of a person
at 3 feet for 3 minutes. Furthermore, this Section 10.3 is merely an example
of what is missing from the entire PETS -- an overall failure on the part of the
NRC to consider the factor of human failure inherent in the nuclear program asa whole. The NRC is to be credited for the clarity of their tables, research,data, statistics, and other raw information made available to the public. However, it is a discredit to the NRC and a disgrace to the public that the Commission does not regard the public health, welfare, and safety above all otherconsiderations. In order to restore public trust in the NRC's decisionmaking
you must demand the highest safety standards possible from Metropolitan Edison
and all other of these licensees regardless of economic impact.

MRS. HYATT (Tr 25): My home is near Three Mile Island, but because ofpsychological trauma I have had to leave there a year ago and, cannot makemyself go back. Nlow what I want to know is, I have been through a lot of
traumatic exoerience and know some facts on TMI that haven't been told by
the NRC or Met Ed.
What I want to know is, I'd like to go back to myhome; but if the course of cleanup is going to be as bad as what I think
it is, and have found out it to be a fact, I would like the panel to comeright out tonight and be honest about it.
I have a home and a husband
back there at Three Mile Island that I cannot force myself to go backthere.
And if you could just be honest about the cleanup and say how muchradiation I am going to be exposed to if I go back, and the constantrelease of the Krypton.
I know for a fact it'sa heavy noble gas, anddepending upon and wind, which way I'm going to get it directly.
So what I would
like to know is, just exactly how harmful will it be if I go back -- not counting the psychological stress that I'm under.
VINCENT R. LUDER (Tr 29):
I have one comment before I ask my questions.
Perta ining to the woman that was just up, the answers that she received imnliedthat the radiation from the artificial elenents that are created in nuclear
plants are identical in effect on human beings as are natural background radiation levels, assuming that we consume and ingest all the natural backgroundlevels in the same way -- which I'm not really certain of, from my background,being able to discern that that is actually true, but I'll continue with myquestion. On one of the very first slides that was shown, one of the purposesof the EIS was to focus on environmental issues and alternatives before
commitments to specific choices were made to cleanup. To that sentence, I
would like to ask why Metropolitan Edison is squandering the limited resources
they have in building a submerged demineralizer system which has had no okay
at all, and could potentially be actually not okayed for use.
This could bea tremendous waste of the new small resources they have.

Comments made by NANCY KELLY appear as comsent number 13 in this appendix.
Comments made by DR. IRVING STILLMAN appear as comment number 14 in this appendix.

TOMSMITHFALL (Tr 34): It states in there that you will focus on environmental issues and alternatives before commitments to specific cleanup choices
are made.
It appears that EPICORE-Il, the SOS system, and the constructionof the rad waste staging facilities are not "specific cleanup choices."
My question is: I think there is a discrepancy in your introduction and whatis actually occurring at the plant.
Section 1.3 of the PEIS states a summaryof Metropolitan Edison's objectives, proposed actions, and schedule.
When
the licensee presented their schedule for Phase I and I,
which are containment entry and decontamination and fuel removal and coolant decontamination, did they at that time present to you a third phase which would, I
presume, have dealt with the reconstruction for operation at that time? How
can the NRC approve Phases I and il without knowing the ultimate dispositionof the plant?

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WALDEN RANDALL (Tr 39): Before I begin, I would like to comment.
I havebeen to many meetings with the Nuclear Regulatory Commission, and I
appreciate you being here this evening.
However, I am becoming increasingly
concerned that these meetings are an opportunity for us to ask questions,but if we do not feel that a full explanation has been offered, or if we still
have more questions -- such as this crowd which has now grown to probably
over 300 -- it's
not a satisfactory way to allow the public to comment.
My
first question would be to Mayor Morris: Mr. Collins says the decision has
not been made whether or not to dump the water into the river. All theway through the document is"ifapproved."
Lancaster City under Mayor
Wolten (phonetic) has an agreement that no water -that is accident-generated
or cleanup water will be allowed to enter the river -- God help us -- from an
accident or a mistake, be allowed to enter the river until the Final Environmental Impact Statement is completed.
That will be March, 1981.
Am I correct.
I had one other question which I wanted to raise on Section 10 which deals
with the desilting basin at the site which will be used to store thecannisters containing the resins from the EPICORE procedure and, if approved, I assume the SDS resins.
Is that correct? The high-activity waste in
the canisters in the shallow burial site in the desilting basin are projected,
according to your document, to be covered by a probable maximum flood for
only four days.
Could you please tell me where you get the figure that if
there is to be another Agnes, or another flood on the Susquehanna River, thatyour high-level activity wastes inside the canisters would only be exposed
to a continuous water path for four days? It is now 1980, and- every official
government document -- the National Flood Insurance, Watershed Basin•
Studies, Pennsylvania Act 282, Storm Water Management, passed by the:legislature last year -- the volume of a flood on this river is increasing-yearly.
It will continue to increase as various areas are paved over and become
impermeable, which means that as -the rain falls, the water hits the river
faster; it doesn't have time to be absorbed by the ground because the ground is covered by asphalt.
I question the storage of any high radioactive
waste on an island based on a design-basis flood which was prior to the probable maximum flood, and then a probable maximum flood that is eight-years
old.
I think that you may in fact be placing the canisters of high-level
waste -- high-activity waste in a shallow burial site where there could be
an extremely serious flooding problem.
Those canisters could then be -the contamination within the canisters would then be spread all the way
down the river and into the Bay.. I think that is terribly alarming, andI would like your reaction.
Is there no burial -site available in the country that can take those canisters, other than- leaving- them on the islandat this time? If. they were solidified, is there a site available- in the
United States tol which they can be sent? Or must we await the developmentof a deep geological repository somewhere else in the country; approved by
the Department of Energy, which no one has been able to -find since 1941?

JOHN ADAMS (Tr 46): The Clean Water Act prohibits discharge of radioactive
waste into navigable waters causing further dilution and dispersal ofradioactivity into the environment.
Would any proposed dilvtion of radioactive processed waste -- accident or cleanup -- conforming to NRC standards
discharged into the Susquehanna violate the intent of the Clean Water Act?
I feel it is somewhat contradictory to call the workers, or mention thatthey're "apart from the general public"; yet, their genetic effects are
increased over the general public, and they-will continue to father andmother the children that will become part of the "general public."Now
I feel that that is an erroneous statement to claim that they're "apart fromthe general public."-

DAVID DOBBINS (Tr 49): This PEIS Statement gives alternatives to thedisposal of the radioactive water -- or processed radioactive water.
Who is responsible for choosing the alterantive to be used of the many
that-are listed in this document? Secondly, once that choice has been
made, will the public be allowed to have comment and review on that?
Will the comments given at this meeting and the meetings like this, alongwith the comments that are requested by November 20th -- How will thesecomments be incorporated into the final draft, or the final copy of thedraft? I was interested in actually if the public would have a comment on-thechoice of the alternative chosen.
What kind of forum, as you mentioned.
Or would there be public input? In other words, do we have any
kind of commentary on the choice chosen? Because one of the choices is
dumping the water into the River.
DEBORAH THOMPSON (Tr 54): The scope.of the Programmatic Environmental-Impact Statement, as it-stands, is inadequate.
Before any cleanup actions
proceed, the following factors should be more fully addressed by the NPC.
First, the decision whether to commission or decommission Unit 2 must be
fully addressed to make an intelligent cleanup decision and, by doing-as
littlecleanup as is necessary, forestall the possibility of more environmental contamination. Secondly, the disposition of high-level wastes
must be fully addressed before a decision to produce more wastes is made.
TMI cannot function as a waste repository without endangering the healthof our community.
Thirdly, public safety and health factors are notadequately considered in the PEIS.
Stress will not be alleviated by the-speed of cleanupas is suggested in the.Environmental Impact Statement;-but, -rather, by competent decisions based on concern for health and safety-of the community in proportion to concerns for Metropolitan Edison's
financial viability;
Fourthly, radiological effluent criteria for thecommunity during the cleanup proCess must consider the accident-generated
releases.- Only in this way would the total effects of TMI and the acci-.
dent on the community be accurately addressed.
In setting these radiological effluent-criteria, the accident releases must be honestly andopenly reflected.
Fifthly, the dilution of contaminated water to Federal
DrinkingWater-Standards is not an acceptable method of cleanup for persons-who drink, bathe in, and use theSusquehanna River for recreational purposes.
-. In conclusion,
I would urge the NRC to be more responsive to the publiccomments you hear ton'ight and you will receive in writing than you were-vis-a-vis the public comments you received concerning the venting of
krypton-85.
-.-

A-148

-4-5DONALD CRYDER (Tr 62): The first conclusion that was in the slide statedthat total whole-body dose to individuals offsite should not exceed 1.6
millirem.
Now what does that mean? Does that mean, as a result of the
proposed cleanup the offsite exposure to the radioactivity? Is this the
projected from any method of cleanup and disposition of the waste?
Then further in that same conclusion you state: The risk of cancer, deathcancer, is -- 2.2 in 10 million -- Do you mean that a certain number ofpeople exposed to that amount of 1.6 millirems of 1.6 millirems of radiation, 2.2 in 10 million of those -- if there were 10 million there -- will
get cancer as a result? Now let's say that this projection is wrong.
Suppose, instead of 1.6 millirems, people just offsite of the reactnr
building are exposed to 3.2 millirems.
Now would the risk of cancer
increase linear to that? Would it double if the exposure is doubled?
Or would it be exponential? In other words, like 10 percent -- that
there is a 10 percent risk of cancer?

the fact that you've answered every question here in a great detail ofdetail, and you've told us over and over: We know what we're doing.
We
have experience.
It seems that tonight what I hear more and more is: The
All of a sudden
cleanup process is becoming, time-wise, more open-ended.
you're telling us: Well, it may take longer now.
Met Ed said three
years; now we think it's
seven; we think it may even be longer.
If youwant to settle this thing with the public, if you want to somehow win the
public over, to cooperate with you and to listen to you, you'd bettercome up with these answers, fast. And if you tell me you don't know,
you shouldn't be sitting up there.
You should be sitting down here andsomebody with the answers should be sitting up there. I have read in thenewspapers that Met Ed is asking for money, or is about to ask for money,or is looking around for money from the Federal Government to help withthe cleanup.
Part of their rationale is that the regulatory process didn't
protect them from this accident.
Could you, 'in your position working for
the NRC, comment on this? Did the NRC do a good job? Was there any malfeasance?
Is there any sort of, in your mind, liability that the NRC has from this accident and thereby committing the public Treasury to clean this up?

BEVERLY HESS (Tr 68): Is NRC operating under National Environmental Policy
Act considerations in the cleanup process as outlined in the EIS? I
read that the National Environmental Policy Act does not require that anagency select the most environmentally beneficial alternative; but onlythat it understand the environmental consequences of its actions and consider them in its decision-making.
An agency may proceed with an actionthat involves environmental damage if it is convinced that there are
economic and technical benefits that override the environmental drawbacks.
I am very concerned, as I understand what is being said here today, that
there will not be an opportunity for the public to do anything more thancomment on what we consider to be the environmental consequences of thealternatives that are being outlined, and which will be chosen. At thetime of the elections in the spring, President Carter said that he would makethe health and safety of the people of the Three Mile Island area theprimary consideration in the cleanup. As I understand these regulations, thatis not being said; that that primary consideration has to be the overriding
concern.
And I would like to know, what -- I,mean, other than the publiccomments, and I understand that this is being reported, and I understandthat there will be opportunities for public comment to be taken again -but since the Staff recommends to the Commission, and the licensee recommends
what shall be done, at what point -- or does, or will -- the public ever
have an opportunity to say what they consider must be done in this instancethat affects our lives? Is there anything short of the legal route, where
citizens have to sue the NRC to see to it that the water doesn't get dumped
into the river.
Is there anything short of that legal procedure by whichcitizens can have a real effect other than just public comment?

KENNETH MAY(Tr 74): One of the thing that was striking to me, as alawyer, about this PEIS was that there were no cost figures, financial
figures as to the cost of the various alternatives which I thought would
have been in the PEIS. On September 18th in a meeting in York, you,
Mr. Collins, said that the only criteria is something along the line of"as low as reasonably achievable," and the costs of the various methods
would not be a consideration.
Now on September 30th at a meeting in
Annapolis, the same question was asked of Dr. Bernard Snyder, and he said
that cost would be a "secondary consideration," which seems to be different.
I was wondering if the two of you have discussed which one of you is right?
MARCIA WEISS (Tr 76): One of the concerns that I have -- or a comment, isthat, if you would, to talk to the local water companies and find out what
their sales were before the accidenti and what their sales were after theaccident.
I think you would be quite surprised.
I know many people
through employment and through my church activities, and I think that mostpeople switched over, or a lot of people have switched over to the Diamond
Springs Water.
Now if a survey went out to those people, I think that,an underlying reason would be fear of the drinking water.
We can't get awayfrom it.
Our children brush their teeth in it, and they take their baths,
and We wash our.clothes in it.
I know you have good scientific reasons as towhy we are safe, but there are a lot of people that are still afraid; andthere are people that just cannot forget it.
We don't have a packed housetonight, but there are people here who care and people who read the papers.
And there are many more people that care about it than I think you people
realize, and that is one way of showing it.
Now one of my questions is:
In your statements concerning the low-level dose rate, the rems that aperson can receive per year, that safe average, are people included in
the statistic?

STEPHEN SYLVESTER (Tr 71):
I have read almost all of the statement, andI have listened here tonight, and I must say that you've gone into a goodnore detail in the past. This both puzzles me and concerns me.
I think
what most people in this room really wnat to hear is: When is the cleanup
going to be finished? And what are you going to do with the waste? When
are you going to truck them out of south central Pennsylvania? And despite

A-149

6

-7-

RICHARD DRENNEN (Tr 103): What I am worried about, more than this low-level
radiation and so forth, God has a way of doing things with the earth.
You
can have earthquakes, typhoons, floods bigger than you have ever seen or I
have ever seen.
What happens to my home? What happens to all our homes when
this place is under water, when the rock splits because of earth problems andthis radiation goes down this river? Can you guarantee me that in my lifetime I can come back to my home and drink my water because you have permitted
something like that to be this close to this many people in a waterflow area?

JOYCE NETKE (Tr 80): One experiences a considerable amount of psychologicalstress just sitting here and listening to what you say, and reading yourslides.
These
STAN KOHLER (Tr B6): I have some questions pertinent to Section 6.
relate to some of the biglogical concentrations-that you're indicatingin the report. There are a couple of things I would like to make clear,first. Number one is that, when you talk about 1.6 -- 1.7 cancers in
10 million due to exposure to the 1.2 to 1.3 millirems, these are wholebody exposures that these are based on; correct? So this is assumingthat the 1.2 to 1.3 millirems are exposed over the whole body.
Now twoof the more potent radioisotopes that we're talking about, or radionuclides,
are cesium-137 and strontium-90.
Both of these are fairly strong bioaccumulators, and not just bioaccumulators but also ecosystem concentrators -- whichmeans that they concentrate as they move up the food chain.
You said anumber of different things in your report. You said that if there was anaccident, that somebody who consumes a grand total of, I believe it was, 2liters of water a day and 21 kilograms of fish could get a total of 31 milliAnd if you total that up, if somebody hapreins and 21 millirems respectively.
pens to be somebody who likes to drink a lot of water and they drink 2 litersof water a day and they also eat a lot of fish, that means a total of 58
millirems.
Does this include the overall effects of accumulation and concentration in the body? In other words, does that include the fact that it isgoing to stay there for awhile? Or does it mean a one-time-only deal?
In the inMy last comment, though, is that the standards are being contested.
terest of everyone concerned, I would vote that the water not be released.
And
it seems to me that solidifcation on-site has a very, very good potential.
I think that it can be done in such a way that worke-s are not exposed, andI think that having it there onsite -- and I'm talking about fairly low concentrations, as you indicate they are here -- in cement are going to staythere for a long time. And if they build a wall around it, so muchthe better.

SYLVIA BUYAN (Tr 106): From the way I understand your Environmental
Impact Statement, these environmental impacts would occur over a periodof what you now estimate to be five to seven years.
However, you mentioned
tonight that this may have to be extended out.
Now my question is, because
you have no control over how quickly this will be done because it's a question
of-money; time, and all this other kind of things, that there is a possibility that this could go on for 10 or 15 years.
However, if this were to
drag on for whatever reason, how would this change the Environmental Impact
Statement? Would you then have to do another survey? Would it changethese statistics? Because I understand the plant is, I don't know, decomposing, or it has a life
BYRON CORE (Tr 109): 1 read in the EIS, Section 10.1, "The processed water
would be diluted and then discharged to the river at controlled rates.
Such concentration of radionuclides in the river would be well below thethreshold level for deleterious effects in aquatic species of humans."
Now this suggests to me that there is some sort of threshold level thatis also being considered.
What is that threshold level, if there is one?
CARL HUIER (Tr 111): I, too, am opposed to the dumping of the water into
the Susquehanna River, because I live right on the Bay.
I'm a little
closerto the Bay than I am to Bel Air.
I used to like crabs.
I don't eat crabs
and shellfish from the Bay anymore.
I do have some questions.
One of themrefers back to Mr. Congel , and he opened it up by what he said there.
Theamount of radiation that's taken into the body as a child, the infant at one
year, no matter what level we're talking about, is considerably growthrelated to the child.
Not that the child gets older from the time of one
year to fifty years, that way.
But if the child is there in an area where
there is radiation, year two, how much radiation does that child receive
as whole-body radiationrand how much does it retain, year three, year
four, year five? The cumulative effects on that infant, or unborn fetus,
or fetus, will continue to grow as a cancer if the dancer is there.
Nowgetting back to this BEIR Report, as expected over a year, what period oftime are we talking about in the experiments or the data that was extrapolated
on giving doses of radiation to mice at 100 millirems, or to hampsters or
guinea pigs are we considering that you extrapolate to a year? Is it aday? Was it five hours? Did you observe the animal through its lifetime,
as we're doing with human beings? The other thing, why does cesium or strontium have to be released? Why can't it be superfiltered, or continuallyheavily filtered to get it out of the contaminated water?

JIM BRESFLOWER (Tr 96): My question to you is: Do you have any plans to
do so? To involve the Union of Concerned Scientists and other independent,
nongovernmental and nonindustry groups in the decision-making process?
LUCILLE WRIGHT (Tr 99): First of all I would like to say that I really dofeel as though the Nuclear Regulatory Commission has a pretty big job. So
I think it is healthy that the opinions and views of people who have
But I also feel that -expertise -- local people -- should be expressed.
this is the-first time I have ever attended a meeting like this, and there
are not many of us here from the area.
I feel as though we need to havesome kind of an expression.
And- I am wondering if there are any plans or
any consideration of a local referendum that would include the people inthe counties here that are directly involved in this issue.
I feel as
though we should have something to say, a chance to say how we feel about
the release of water into the Susquehanna.
I feel as though we ought to beable to say something about how we feel about the disposal of the solid
waste.
And I also feel as though the general public ought to have some
input into the reopening of Three Mile Island.

A-150

-8-

Comments Received on October 7, 1980, Meeting withCamp Hill, Pennslyvania

BARNEY*EPSTEIN (Tr 119): You mentioned the fact that the scientific community
has been searching for a burial ground for years for the high-level waste.
I would like to know what constitutes "temporary"? Because in your statement, you mentioned the fact that the waste will be left on the Island
Also in conjunction with that: How long after the time
"temporarily."limit "temporary," does it become a waste ground, a permanent waste ground?

Pa. Farmers'

Assoc.

WAYNEBESHORE (Tr 27): The material which you're going to be disposing of,is that a solid matter? Or what is it? You've talked about water, which I
can understand; but what is this?
CHRIS ALLEN (Tr 29):

Since that waste may be stored on there for sometime, what sort of storage facility does Met Ed have?

KITTY LOVINGSHANK (Tr 122): Now my question is: Sitting here tonight, I
am really confused about how much authority the Nuclear Regulatory
Commission has over the decisions that are made by Metropolitan Edison.
If I understood you correctly, you very early this evening talked about an
installation that is being put in at TMI that you people do not agreewith; and that it's costing $35 million, but you told them to go ahead,
And on top of the fact that the lack of Nuclear
their problem.
that it's
Regulatory inspections of these plants is what made this accident possible
in the first place. Now I would like some clarification about just whatkind of a watchdog you really are.

WAYNEBESHORE (Tr 35):

Is there any economic data involved in this?

LOU WAMBAUGH(Tr 40): Going back even before the accident at TMI, yourdaily records had one reporter that had quite a series of writeups citing
the faults of nuclear power, the dangers.
That went on for a couple ofweeks.
Could this accident have been planned?
CHRIS ALLEN (Tr 44): Two questions, really. At the beginning of theslide show,
you showed some conclusions that you reachedabout how
possible doses from the cleanup would affect people, and they comparedfavorably with background doses.
Have you ever made the same kind of
judgments on livestock in the area? And I guess this may be a question
for DER:Can farmers along that transportation route look forward to
more frequent testing of milk for radiation and subsequent publicityof that?

BETTY TOMPKINS (Tr 124): On what basis did you make the statement that there
will be no long-term psychological effects from Three Mile Island? I would"99 percent
like you to revise your estimate at least to say that it'ssure," because here is one person -- and I've told you before, at the time
Hes'now a year-and-a-half old,of TMI, that my grandson was two weeks old.
and we will have psychological concerns about him, and we will suffer stress
So I don't know
as long as I live, and until at least 20 years from now.
how you can say that there will be no long-term psychological stress.

CHRIS ALLEN (Tr 50):
If accidents on the scale of TMI haven't happened,
where does the training come from? Is it simulation training that thesepeople have had?
WAYNEBESHORE (Tr 54): You infer that there is no possibility of contaminantion on the part of milk, and I guess you're saying other foodsalso.
Has all sampling been discontinued?
MR. DEHOFF (Tr 58):

Aren't some of the foreign countries reusing the wastes.

JIM HESS (Tr 67): Is there a danger that radiation would get in thecrops, in the ground, and cause problems in the future? And is this danger
actually -- does it really exist? And how serious is it? Okay, now let's
explore the unforeseen.
What happens? What is the probability? What isthe cause? What does radiation do to crops, and animals, and so on?
MR. MUSSELLMAN (Tr 82): I would like to make one statement for the record.
It appears to me, according to your presentation here, that there seems to
be a procedure of experiment -- not "experiment," entirely -- but procedural
arrangements here for cleanup that are not feasible from the standpoint ofevaluating the cost of it.
In other words, we don't know exactly how much-it is going to cost to clean up the reactor, and everything else.
The statement I would like to make is: I don't think the consumer is served, if Met
Ed should be the sole persons to stand that expense.
Since this informationis going to be used by the NRC in other possible accidents which would occur,
the procedures which you all are enacting will be to the benefit of future
problems, and therefore I think the cost should be borne at a federal level,
the expense of partially this cleanup.

A-151

-2-

Comments Received on October 8, 1980, Meeting with Steering Committee
Newberry Township, Pennsylvania

MS. STRICKHOUSER (Tr 53): I feel, like 90 percent of the people that the
Therelonger it takes to clean this up there might be more danger to it.
might be an unknown danger that might happen to the public the longer they
What I
hold off to clean it or decide how they are going to clean it.
mean is you are pussyfooting around deciding what to do, how to do it andanything can happen in between until it is accomplished, the clean-up
You would -be surprised
There is fear in the public.
is accomplished.
how much fear there is in the public where they won't talk up until this
It is really fear.
is cleaned up.

BRIAN MCKAY(Tr 36): You keep telling us about the water problem down there
and every once in a while we understand that Met-Ed makes another test welland finds some more tritium and of course everybody keeps telling us we
can't find out where it is coming from and that that is a process ofWhat is going to be done
nuclear fission. That stuff can't ever be filtered.
to alleviate that problem and find out exactly where the tritium leaking
from from damage due to No. 2 of Unit I?
DIANA WELLS (Tr 38): One is that you stated that No. 3, the partial cleanup and defueling is not what you would consider a reasonable alterantive
and I would like for you to elaborate on that, please, and give a little
bit of your reasoning because it seemed to me that an awful lot of waste
water is going to be generated in that clean-up process and it seemed.tome that the study did indicate that it would be a lot lengthier process
and a lot more closely process to deal with all this excess waste waterand the other materials that would be involved in cleaning up the plant
and the total clean-up versus just getting rid of the core. So if thecore was out and if the waste water was solidified with cement or whateveralternative you have, are you saying that would eventually leak throughthe cement walls and into the environment? I think one of the things
that concerns me is it seems the desire to toally cleanit up which added
several million dollars and the refueling, in the paper they listed thecost for the clean-up and in that cost was added the cost of the refuelingthe plant, and it seems to me that the big desire is to clean up that plantso that it can be refueled and reutilized rather than what would be the
They have added a lot of costs and a lot
safest way of cleaning it up.
of time in there for completely washing down the walls with hundredsof thousand more gallons of waste water.

MS. UMHOLTZ (Tr 57): Throughout the 18 months I have been basicallyconcerned about my exposure to this radiation but throughout these months
I have been told by various people that it is either a comparison to an X-ray or
it is within normal background levels or it is slightly above background levels
On the otherwhich is not harmful or any cause for concern for public health.
hand, they are coming up with risks, 2.2 in 10 million and 4.2 in 10 million
can
you
way
by
this
how
affectedinany
If I am not getting
for genetic.
There should be nocome up with risks? It doesn't make any sense to me.
risks then, but you are coming up with risks.

Have there ever been
MR. MCHENRY (Tr 43): Just a question of interest.
any plants in the United States decommissioned and the environment restored?
Ijust
wanted to further my I guess comment more than anything else, thefact that we seem to be doing a lot of experimentation on Unit II in termsof developing systems that can handle the larger commercial nuclear reactors
and the fact that, you know, some possible alternatives might be to go so
far and continue making some experimentation in other areas with anotherreactor and the decommissioning process, you know, that you at least know what
you have to work with. The comments have been that work has been
From what I understand, youdone with small systems, experimental reactors.
know, I don't think it is a matter of just taking a system and building theThat is being oversimplistic.
parts ten times larger and using that TMI-2.

MS. HERMAN (Tr 70): You asked for public comment on the venting of the krypton.
I know before most of
Now you are asking for comments from the public again.
the comments opposed the venting and you went ahead and vented the krypton.
What will these meetings and the comments made by the people, what effect do they
have upon the decision that will be made?

MR. MCKAY (Tr 68): You gave the example that you are reusing the water fromthe auxiliary building in the clean-up process. What I would like to know is
if it is going to take five to seven years for the total decontamination of
the plant what is it going to be the volume of waste produced that has to be
stored on site or removed? Now, what about the high radioactive waste on
the resins which are being stored down here on the island at the present
time? What is the estimated time in effect for leaching to occur with the storageof that type of resin? What is the minimum time expected that damage will be
incurred by the leaching effect of the type of resin storage that is containedat Three Mile Island?

MS. REHM (Tr 46): I would like to read you something that you have in yourIt says here "Commercial nuclear power
environmental impact statement.
plants are not designed with special considerations for large-scale contamination operations." So, in other words, this is an experiment? Also
according to here it said you have had two major differences than they haveThat is, one, the krypton, andhad at any other accident or other plant.
then also the amount of containment in the water.

A-152

-2Comments Received on October 20, 1980, Meeting with
Middletown, Pennsylvania

PANE

tion of engineers and technicians.
In other words, if they don't do what
they're told, they don't have a job tomorrow morning.
I'm a human scientist,
I'm allergic to tradition, superstition, and diplomacy, the ability tochange the subject if you can't change the people's minds. Now the question
I have is this: Number one, what is the capacity of the spent fuel storage
cells on Three Mile Island, number one? And number two, to what degree ofcontamination is the emergency waste landfill, nonoperational at TMI, theonsite landfill, dangerous,
concerning the leach chain and toxic emissionsof the material that's disposed there into the soil, and eventually into
the water, as far as the water is concerned?

JEAN CRUMLEY (Tr 32): I live in Summerdale, which is very near that Route11 and 15, and I wondered, could you tell me if any radioactive waste
has actually gone the 11 and 15 route? I'd like to put in a word forsuggesting that it never be used again, because it has some of the mostdangerous driving in the whole area, and there is a,place where it is just
impossible to widen the highway, and they do all the corrections they can,but it is extremely dangerous for the residents who live there. They taketheir lives in their hands to get out and make a right-hand turn, andcertainly to -- I would like to make that a very strong recommendation.
MS. THOMPSON (Tr 33):

KEN CHASTAIN (Tr 78): My comment is, we don't trust you.
You have mademistakes in the past, you are going to make them in the future.
In yourcorrected version, on page 24, you have Three Mile Island in anothercounty, instead of Dauphin County, and if you don't even know what it's
at, how are you going to clean it up?

Has the disposal site in Washington been closed?

DORIS ROBB (Tr 35): Are the wastes from the EPICOR system are low level
wastes? I have another question.
There is a possibility that the submerged demineralization system will be put into effect.
I understand that's
the same type of system as the EPICOR.
What do you plan to do with thewastes from that, should that indeed be implemented?

JOHN GOFLICK (Tr 79): I'd like to make a comment and finish up with athree-part question.
The nuclear industry and the NRC have yet to learn
the thrust of the people in this area, because the safety of the people
is not their primary concern.
In 1979, I predicted that Three Mile Island
was our greatest tragedy.
Subsequent event have confirmed that. There isan established historical pattern of deceit and concealment of informationfrom the people, based on the pretext that the truth would only cause panic.
When a chemical-filled truck or train accident occurs, the local populace
is warned and/or evacuated upwind from the scene of the accident.
When anuclear plant accident occurs, North Carolire, Three Mile Island, Florida,
anywhere you can find one, the plant personnel try to conceal its existence.
But when the outside news sources pry, the plant spokesman and/or the NRC
will minimize the incident, such as TMI, such as the experience at TMI,
and give false assurances that the radiation levels are far below background or NRC limits.
And the disturbing assurance that NRC provides isthat only two of our neighbors will get cancer.
This occurs with eachaccidental release of radiation and/or krypton gas. We have a cumulative
effect on this area, because 365 days a year, 24 hours a day, we have a
byproduct while TMI was operating that produced electric, radiationand cancer.
It is not producing electric today, but it is still producing radiation and cancer. The clean-up at TM! will pose continual radiation releases, and I believe your rates are minimal.
I would also liketo raise the question, the PEIS does not address the formation of zirconium
hydrites in the core.
Why was not the NRC aware of the fact of the chemical
reaction of zirconium and zircaloy 204 combined, with oxygen, nitrogen,hydrogen and steam could cause an explosion when exposed to air? Will the
NRC warn the people of this possibility before the reactor core is removed?
Will the area be evacuated as a precaution?

MS. LIGHT (Tr 60): I wanted to respond or to ask -- well, I suppose
because I live here, I'm a resident here, I was particularly sensitive
to some of the descriptive terms used in the PEIS.
I was interested in theway the terms were used.
I was interested in the way the term "exception"
was used, and I am interested in the way the term "phobic" is used.
MR. PEFFLEY (Tr 70): My concern is the disposal of hazardous waste materials.
I do not represent opposition to progress, but to progress predicated on
calculated risks primarily satisfying ones in lieu of needed services or
products or natural resources.
Man is an overspecialized beast by reason of
his brain.
It adds overspecialization that leads to his ultimate doom.
In
my 58 years on this earth, I have learned one thing: These people, andpeople in general, are neither for you nor against you.
We are all for ourselves.
It's a matter of survival.
And you hear of people -- I mean becauseof various factors.
But they themselves are protective of their party, thesame as you are.
I am subject to the hammer.
I may, you know, be looking
for a job or be jobless as a result of standing up and speaking out, as I
have in the past, but it doesn't make any difference at this point.
There
are apparent safety measures built into all regulated industry.
I work in
the construction industry.
I worked on the power plant down here at
Peach Bottom, and various others.
I understand a little
bit about a lotof things, but not a hell of a lot about anything.
I am familiar with acidfallout due to working on coal-fired plants.
I am a little
bit familiar
with the disposal. of waste in emergency situations, having worked underthose situations.
On these plants that have fuel storage tanks, in casethere is a spill, they have safety valves and pressure systems.
When theygenerate steam, regardless of the source of energy, they generate thesteam from the water that they use, and the whole system is no safer thanthe human element. The human element is often times subject to the direc-

BARBARA PYLON (Tr 87):
I wanted to refer to the entry, not the mostrecent entry of the five men, but the planned entry before, which happened
to coincide with the PUC decision on the ratepayers not being held liable
for the clean-up costs. And as I remember at that point in time, the

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licensee said, "Hey, we need the money to go in there.
If you can't
give us the money, we can't go in there." But what I have seen is a very
slow process of getting in there.
Now I don't have the technical expertiseto know why you can't get in there, and for what reason 18 months later you've
only been in there a few times.
I'd like to know why it has taken so long.
When you go in.there, are you doing other than the usual things and checking
out of the principal containment? What are you doing to get closer to theclean-up process? Because I don't want that sitting there for another 10
years.
I want it cleaned up as soon as possible.

Can I ask one more question? The other question I have is in the PEIS,
there aren't any indications of the economic costs of a lot of these steps,
so I understand that will come out in the EIS.
In answer to questions
about clean-up, you say No. 24, will any clean-up alternatives bechosen solely on the basis of cost? And you said reviews will be based
a little
on the safety and environmental impacts, which isn't -- it's
deceptive because, as you said, in the past, costs will be a secondary
consideration.
My question is, will there be any opportunity for the public
to comment on your estimates?

VOICE (Tr 91): On page 125 in the PEIS, there has obviously been somethingomitted, because my page 125 ends with a period at the end of a sentence,and the start of page 126 starts in the middle of a sentence, and there
is nothing in between.
I noticed in the presentatlon you gave earlier,talking about total exposure from the clean-up over a seven-year period of
1.6 millirem, and then later in the presentation you talk about transportation of waste, and if somebody was to be three feet from a certain
given shipment for three minutes, they could get 1.3 millirem, and I'msure you're aware that Met Ed or whoever the contractor is that does their
hauling, already had one truck come undone coming out of Middletown., I'msure it took them longer than three minutes to hook it back up.
So how
can you say 1.6 millirem, when -- in 1700 shipments of waste you have atremendous potential for 1.3 millirem exposure for three minutes.
These
are just a few observations.
Page 112, reference of the building interior
surface. Quote.
Experience is limited.
Page 114, dealing with significant
core damage.
Quote.
Experience is limited.
As are as chemical decontamination, experience to remove fuel, quote, very limited experience.
That's on
page 114. Removing fuel debris from reactors.
Quote.
Little experience..
That's on page 114.
Removing damaged fuel and core components.
Quote.
Experience rather limited.
Much experience not directly applicable to TMI 2.
That's on page 116. On page 117, TMI fuel, quote, quite different, more
susceptible to oxidation and embrittlement.
Page 119, there are many
uncertainties regarding characteristics of TMI 2 waste.
Large scale decontamination activities -- this is quote -- much less -- this is on page
126, in dealing with the waste, as far as fuel centers are concerned,
the word "unique," that is on page 210. Structural hardware, as far
as waste is concerned, how do you deal with them.
Unique.
That's on
Quote, Unit contaminant. That's
page 210.
Filter cartridge assemblies.
on page 212.
Accidents, large, quote, not directly comparable tospecific activity -- loaded ion exchange materials.
Quote. Waste well
above those normally generated by light water reactors.
Unique to TMI 2.
That's on page 213.
Quote.
It was never anticipated that such wastes
That's on page 213.
In view of all these things, howwould be created.
can you tell us that you are going to clean that place up safely andwith minimal exposure to the public? Back in January, the outside that washanded out for the hearings, it was pretty clear that the PEIS was expected
to take positions on various clean-up alternatives somewhere between
January and August.
There was a fundamental change there to the point where
now we are not talking about specific alternatives.
When can we expect
the Staff to take a position on any given alternative?

JAN EMERICK (Tr 105): I have several short questions.
Page 715 andpage G-4, among other places, mentioned evaporation and it sayt only
minute amounts of gas are released -- radioactivity are released asgas. How is this controlled? That's the first question. So how do you
make sure that only this small amount stated there-is given off? On page
What do they
843, Table 8.4.1, plus incineration of combustible wastes.
mean by this? How is this incineration -- how is this burning going to
be done?
ELIZABETH CHEVAIN (Tr 107): What I would like to know, since the NRC
did not have the wisdom to foresee the need for a large scale monitoring
before the accident, and since you do not know the level of radiation
to which we were exposed during the accident, since there was no monitoring, how can you possibly sit there and give us such precise figures on
the cancer rate statistics, when you do not know the initial dosage ofradiation received? That is our big hang-up.
VOICE (Tr 109): Will there be any political considerations given in the
final report that you give to the NRC Commissioners when they make their
final decision? In the sense that if it's
politically expedient to
do it in a iay other than you recommend it should be done, that there could
be some changing of decision-making or decisions that would affect how
the clean-up would be done, and whether or not it would be to our advantage,
to the people who are living here, to be done one way or the other.
Is there
any consideration given to that?

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-2Comments Received on October 23, 1980, Meeting with Pa. Medical Society
Lancaster, Pennsylvania
water in my mind, I've got the scrubbed resins and the bunker down.
Now
you have got damaged fuel rods.
How did you report? What are you saying
you'are going to do with the damaged fuel -rods? Do they do in the bunker
too?

JOHN RANDALL (Tr 22): The first comment I'would make is that it is' very
difficult to get an overall picture of what the occupational hazards are
As you know, the occupational is broken up into manyto the workers.
It is very hard tosettings, and you clearly have a hazard to your workers.
The
get an idea of what the overall hazard is, as I am sure it is for you.
What I would besecond is that I think you led off with the cost question.
very interested to know is, when you did your EIS for the krypton venting
there was a cost analysis, and I didn't see anywhere where you reallybroke down the costs and what the public can expect as far as Met Ed's
What I was saying is that a breakdown of each operation
physical survival.
and then the potential hazard for a worker, the bottom line, and then theThat is what I
top line for each operation that is to be performed.
Frankly, after reading it, I will tell you why I am interested
was saying.
in the occupational health, because with the low level stuff that we are
dealing with, we are dealing with a controversy that can't even be solved
We can sit here all night and discussby the National Academy of Sciencies.
the low level stuff. As far as I can see in the document, there are two
One is to the workers that are going in there, andreal health hazards.
the second is this business of storing the high level waste on site andnot having or being able to process through DOE or anyone that will accept
As long as you have the cleanup, you are going to have to accept
the waste.
I want to deal with this high level
some occupational risk, I suspect.
I saw a report from Brookhaven Laboratories
more.
waste question a little
which I think was done for your office in May, which had to deal specificallywith the canisters in which you are storing the resins. There are two
One is that it looks like theheartburn.
things that give me a little
resins themselves hold the isotopes for a period of a month and then leachIs that your understanding of how these resins function? What will theout.
heat be in these canisters? The only other question I have is, you know, youYou
derived your water levels from the Agnes flood, I assume, and --.
estimated it to be a four-day maximum flood period over these canisters?

DR. RANDALL (Tr 46): I have a couple more comments to make.
I am very
pleased to see how you dealt with the psychological question in the EIS
because I think that is very important, and in your small statement thatcommented about the fears people are going to have In terms of productivity,of wine, which is about three miles, of corn, chocolate, and then lower down
the Chesapeake, the fish and the oyster industry.
Regarldess of what thefacts are about the low level releases, there is still a lot of angst regarding-release into the river.
You know, you may have the scientific facts that you
feel that it is safe, but there is still a marketing question of produce andthere is still the same kind of angst that generated a law suit a year ago
from the City of Lancaster.
I am not sure that there is the physical basis
for that anymore, but I have a feeling that when February comes and thatagreement -- or whenever it is -- that agreement expires, I think you aregoing to feel more community pressure regarding the low level releases into
the Susquehanna.
So I would urge you strongly to consider other ways, noton a scientific basis but more on the psycho-social basis.
The question I
had which is a technical one has to deal with the water and its effects
on the cement in the building itself. I understand there was a cleanup
up in Canada somewhere.
Chalk River, okay. And they had to go in withjackhammers and take about three feet of cement out all the way around.
Do you anticipate that occurring here? Apparently they didn't have aliner in this unit that would prevent that.
.

DR. WHITELY (Tr 33): First of all, could you give some indication as to why
the very long period of time for this cleanup operation, five to sevenyears? My second question is why have you decided to keep the other reactor
inactive?
DR. DEARDOFF (Tr 37): In your opening statement you said, of course we are notsatisfied with this, we want to move this out of here someday because the middle
That is my next quesof the river is not a good place to have this bunker.
Let's
tion.
Let's say we are stuck. Let's say nobody can take our stuff.
say we have got this stuff for 50 years.
How safe is your bunker over the
Is there anywhere else in this eastern megopolis
years? My last question.
that has a dump or a bunker like this, not stuff in action, disposal solid
waste stuff buried in a bunker near cities like that? I am working my way
bit. I have got theslowly to understand this, so bear with me a little

A-155

-2Comments Received at October 29, 1980, Meeting with Maryland Citizens inHarve De Grace, Marylandeach one was just that little
bit of contaminant that each operation added
bit each time, and that is what they died of.
to it.
It was just a little
I do not think we can keep our rivers or our bay healthful amd clean byadding any of those. I think we can do it by only removing whatever contaminants are there insofar as we possibly can, not by starting that
deadly snowball going again, adding anything at all.
I feel it is an
unconscionable act and a grave offense to the human race to justify any
degradation of human life or of the natural world by the juggling ofstatistics or by making such rash unverifiable statements as the psychological stress occasioned by such an operation will have no long-term effects.
There is no way anybody can possibly *know that, and all indications would
be to the contrary.- To put it in a positive way, I feel there is a moral
imperative to dispose of the poison already created there in a way that does
not further poison our environment in any way at all.

CONGRESSMAN BAUMAN(Tr 38):I am a member of Congress representing theFirst Congressional District of Maryland, including Hanford and Cecil
Counties which border on the Bay and the Susquehanna, as well as elevenother counties, nine of which border on the Chesapeake Bay.
I appreciate
the Nuclear Regulatory Commission's public hearing or public informational
meeting tonight so that not only public citizenry but those of the official
governments involved, both municipal and county, can have a chance to havean explanation of the information that you have made available tous in thepast. As a member of the Subcommittee on Energy and the Environment of
the Interior Committee for five years until two years ago, I served.on
the subcommittee that had jurisdiction over nuclear-power when the Joint
Committee on Atomic Energy was abolished, and some 18 months ago at thetime of the TMI incident, I had contacted then Acting Chairman of the NRC,
Joseph Hendrie, when I read reports of the intention to possibly disposeof waste water that was contaminated into the Susquehanna River.
Of course,
we have come a long way since then in both knowledge of the incident, its
scope and the need for cleanup, and I feel very strongly that we must indeed meet soon the disposal problem because of the many problems that itpresents, even so great that a layman like myself can understand them.
I
would also say a word of praise for Delegate Katherine Riley and theothers in the delegation who have consistently been in contact with youragency on behalf of these public meetings which I think go a long way todispel the concerns that exist in the public mind.
For my own part as one who has worked with my staff members who are particularly interested
in this, I would say that I would oppose any alternative that would
result in the disposal of waste water dumping into the Susquehanna River.
There are otheralternatives, and I can tell you that those of us who liveon the lower end of that great river have a great deal of apprehension
about what incidents or what impact this might have, and I am sure thatyou know that no matter how much scientific explanation is provided, it
certainly will not allay the fears'that exist, and if there are otheralternatives that can be pursued, as you indicate there may, I would hope
you would look at those various alternatives.
Lastly, I would like torequest of the agency that you allowat least another public hearing at
a time when a final decision is made so that comment can be made bygovernmental officials and private citizens and interested groups onwhatever decision is finally made; and I thank you very much for hearing
me tonight.

HOWARDSEXTON (Tr 45): You come. up here, you run a whole lot of stuff
under the bridge, you run all this stuff by about the drinking water andhow many thousands of millimeters are supposed to be in the water and all
this and that, and yet you show us on the chart where it is going to show
up on our bay and on our flats, clean down to the Sassafras River. Well,see, you are showing stuff right there where a lot of people around thiscommunity are trying to make a living, are trying to make a go ofcommercial work around here.
This upper bay has been shut off from thelower bay for years, which is a lot of guys around here like me now are
striving to make this bay and our community around here more of a place
to go for seafood and stuff like that, like the lower bay.
We don't needthis contamination.
We already have enough problems.
I have been cleaning
the bay for 25 years and I have had junk that you would not believe, fromall the way up from upstate New York.
We don't need no more headaches.
And as far as you coming out with these figures that this water
would be so pure and everything, I want to see him drink some of it andthen I will be ready to drink some of it or turn it loose into theSusquehanna River. But until then, I say tomb it up just like they did
the nuclear bomb down in the Pacific, down there where they could not get
those islands cleaned up, tomb it up and leave it there.
Who needs thatisland.
All it is is a rock'pile. Why put our life and our kids and our
citizens and health in danger for a rockpile?
JEFF KATZ (Tr 47): I have two questions.
One is, assuming that the radioactive
materials are released either to the air or'to the river, can you absolutely
indicate at what threshold of activity we could see a biological effect onplants, fish or man? That is the first question. The second"question is,
if acceptance of the licensee's cleanup proposals will be based on theirsafety and environmental impacts instead of solely on cost, and since NRC
agrees that solidifying the waste in Portland cement is the simplest methodfor disposing of the waste, why does NRC label this not a valid alternative?
Specifically, why is the alternative invalid? Assuming that the activity
is released to'the airor to the'water, to the 'Susquehanna or through some
evaporation technology, can you absolutely indicate at what threshold ofactivity we could expect the biological effect in fish, plants or man?

LOUISE MASSINGER (Tr 41): What.I would ask this agency is that you really
no longer ignore the lessons of history and the problems that are alreadywritten on the face of the earth.
Historically one of the greatest
tragedies of modern times has been brought about by just the kind ofprocess you are proposing, and I am talking about the destruction, thepollution and the death of some of greatest rivers. The tragic flaw for

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-4ANNA MCMULLEN (Tr 55): If you would add up the radiation released from the
China bomb, Peachbottom, Calvert Cliffs, accidental exhaust and otherrecent X-rays for medical reasons, the drinking water at the present timethat there was probably or still will be, and accidental releases that we
don't know about that is in our water at the present time, In our
seafood consumption -- I would like to know if these were added to thestatistics that you have given us tonight -- will we still be as safe as
you try to make us believe we will be?

we get from the granite and the rocks and the rest plus the bombs plus theactions that have been licensed by the Nuclear Regulatory Commission, thenclean is dirty. That is no more natural than flying down the road in a
I wish you would take the first word out and sayhelicopter is natural.
background radiation, because I think to call that natural is stretching
the truth, and it proves what some of the people have been saying here
tonight, that you are going to keep saying that now we have natural background for 1980, then we have natural background for 1990, then we havenatural background for the year 2000, and at each point with no safe threshold, and even Dr. Upton from the National Cancer Institute saying there
This natural background with all of the additions
is no safe threshold.
of the nuclear industry is going to keep being quoted as being this backMy quesground level, which it is not, not with the interference of man.
tion basically has to do with why did the NRC approve the installation of the
EPICORE system without requiring. solidifcation of the resins before thatsystem was alloed to operate if you now have a hassle with trying to solidify
the waste so you can get it off-site? Why did you license them to go ahead
and run a system when you did not have the solidifcation procedure in place
which would allow those wastes to then be removed and taken to a storage
dump? When the resins that are now in the canister that are going into
the desilting basin are taken from the site, where are they going?

LEWIS FOSTER (Tr 57): 1 think there is a problem, and my request, my plea
to members of the Commission is to really look into this matter completely
and look into your own hearts and find out within yourself like what you
really think is going on. Do you really believe what you see? Do you
really think it is true? If you have any doubts as all deep inside, you
should really look into it much more closely. We should completely discover what is going on before we dump anything into the river and subsequently into the Bay.
There are a lot of other problems, but this is
one I want to address to this particular Commission.
In the slide presentation I noticed you madeSTANLEY KEENE (Tr 62):
I think this was to the Statereference to a truck route of 2600 miles.
I also noticed that you had some time limits for peopleof Washington.
that would be exposed to those truckloads of material.
Now, I do not think
we should endanger all of the people from here all the way across thecountry to exposure to this type of thing.
Now, I know this has nothing
to do with the water that is here.
In the gentleman's presentation about
the-amounts of material in the fish, in a controlled release, which I believe
is 30 gallons per minute, the amount of material in that compared to theamounts of material in an uncontrolled accidental release, which would havebeen 500,000 gallons, in only 2 to 1. Now, it is not going to take thepeople at Three Mile Island long to figure out the same thing I did.
If
you are only going to double it and you are talking about it being very small
to start off with, they are going to get the same idea and they are going to
let it go.
Now, is there a way to decompose'your water into your hydrogenand oxygen? I am not a chemist.
I don't know what you would have left,
whether it would be more dangerous or not.
We speak about.how much we getfrom normal living, how much radiation we get from it.
We want to add more
to it now. Something else will come along, we will want to add some more
You are just going to bust the camel 's back by doing theseto it again.
type of things. This you consider to be a week small bit. Someone elseis going to add a wee small bit and a wee small bit, and they are notgoing to take into consideration the whole thing that we get. So it is
all cumulative.

GEORGIA ANN GAITH (Tr 69): I received a letter that the writer wishes"I am opposed to the dumping of any waste
to have read into the record.
Thank you for your help and cooperation in
into the Susquehanna River.
Very truly yours, William Menloav, Cecil County
this matter.
I also have a question of my own, and that is: If
Commissioners."
solidification of the waste can be maintained on the island in the form ofa concrete slab, then why are we even here talking about biological impact
in the Bay? Is it an economical factor? That is not addressed in theenvironmental impact statement.
Is it cheapter, or course, to dump it
than it is to solidify it and maintain it?
ROBERTA SCOVILLE (TR 72): I am speaking on behalf of the League of
Women Voters of Maryland and with concurrence of the League of. Women
I will give you my written comments, but I would
Voters of Pennsylvania.
just like to point out one thing that has not been addressed, and that
It is anis that the cleanup process will take five to seven years.
experimental process even though you say that most of the procedures
are technically known and all decisions about how to adequately decontaminate the facility and dispose of the waste will not and cannot be
Therefore, we feel it is extremely important thatmade at this time.
the formal public hearing process not be limited to this preliminary EIS.
There should be public information and comment at all stages of the process.
We realize that this is not normal procedure; however, there should be public information and comment at all stages because this is the only way people
will ever accept any exposure that proves necessary during the cleanup period.

MS. RANDALL (Tr 64): There is a definition that reads as follows: Natural
background should be interpreted to mean normal background including theeffects of fallout from past nuclear weapons destination and from thenuclear field cycle.
The observed radioactivity in the Susquehanna Riverand so forth and so forth and so forth, exactly what the gentleman said,
that now this is called natural background.
If natural background is what

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-6The importance of this cannot be overstated.
In addition, I will justsummarize by saying that the League is very concerned about designating
off-site waste disposal facilities as soon as possible, about very
strict and adequate regulations on the transportation of materials fromThree Mile Island, and finally, we suggest very strongly that you consider
not releasing the water simply because there are many, many people who are
deeply opposed to releasing the water.
It is very difficult for nonscientifically trained people to evaluate the risks involved in low level
exposure when there is disagreement among scientific personnel on theeffects of such low level radiation exposure.
Therefore, we hope thatyou will avoid dumping if you can.

I don't think that there are -- there is anybody around that is willing to
say that background radiation causes no cancers, no genetic effects becauseradiation, because of the type of animal it is, it does break chromosomes,
it does cause damage, it does cause cancer, it does cause genetic effects,
whether it is natural background or whether it is induced from fallout or
whatever the reason.
So even a natural background, it is known, does cause
And the point is no radiation is good radiation, and the moresome problems.
you keep it to a minimum, the safer the levels are.
I would hate to see thestraw that breaks the camel's back in this case.
It may or may not be, but
we should never let ourselves get to the point where we even approximatethat kind of situation.
Ifear that we are, from things like fallout,
things like nuclear power plants, from. Peachbottom, from Calvert Cliffs,
all accumulating more and more of the dose to the individual.
And it istrue we do have a high cancer rate and it is getting higher, and it isbecause of things like this that should be controlled more strictly thanthey are.

STAN KOHLER (Tr 73):
I am concerned about the dumping of the water.
I would
prefer that it not be dumped for a number of reasons, among them theisotopes of strontium and cesium, which are known bioaccumulators, which is
not addressed in this, although bioconcentration is.
I think that does
need to be addressed.
In addition to that, the levels of tritium that you
are releasing are in the neighborhood, I believe, of six to seven times
what a normally operating nuclear power plant would discharge.
I would
like to speak in solidification in concrete, though not necessarily theway you have addressed it in here.
The way.you have addressed solidification in concrete is by saying that you-are going to take all of the waste
water and solidify it en masse rather than subjecting it to the demineralization or SDS process first. Can you tell me, please, why you would not consider doing something like demineralizing it first and then taking that 'water and, after it has been recycled a number of times in the plant, thensubjecting it to concretion and then that would be basically low level
waste which could potentially be made into very large blocks and placedon the island rather than being transported.
Can you tell me what section
you address that in, please, specifically, because what I saw was what someof the other people have alluded to. A few other things I would like topointout.
In Table 6.5-7 you have a summary of helath effects for eachdecontamination, liquids, processing, alternative, and you have probabilityof occurrence for maximum-exposed individuals.
That is probability of occurrence
for cancers and genetic defects, and in that you have solidifcation in concrete, evaporated resin system, and bituminization system.
According to that,you have solidification in concrete as by far. posing the minimal risk to the
maximally-exposed individual.
That would account for. anybody in the generalpublic as opposed *to any worker, is that correct? I would also like to
speak against evaporation because evaporation is going to do essentiallythe same thing that dumping in theriver' is goingto do.
It is going todisperse it out amongst the general population.
It is going'to exposure
people to levels above background.
Now, one thing that I always comehere prepared to say is something which is more or less intelligible andsomething that is scientifically based, at least according to a report here,
but I cannot help but get angry at some of the erroneous statements made,*such as a fish living in normal background radiation' is not suffering any
ill effects whatsoever.
I don't see how you can make that statement because

SIMON GRAYSON (Tr 78): My daughter has leukemia, whether she got it fromnatural causes or from something else. But I have seen here'- thanks be
to God, she is with us and thanks also to Johns Hopkins and to thedoctors... She was hospitalized, for four months, and during that time I'saw her drowning in her-own, blood for almost 48 hours while they looked.
for where she was bleeding.
We prayed for every breath that she took for
24 hours. 'Again, thanks be to God she is still with us. So when you takethese figures of two in 10 million or four in 10 million, I want you tothink of you son or your daughter.
.CONNIE BINES (Tr 79).:.. I am opposed as a private citizen to the dumpingof this water in any form into the Bay, into the Susqheanna River andinto the Bay, I should say.
It centersaround the
JOHN MCNALLY (Tr 81): I have a brief question.
•fact that the NRC seems to be very reliant upon EPA's drinking water
standards in concluding that this discharge into the river would leadto minor '- if detectable at ali -- health problems at the'North Haven'intake and below.
I would like to point out or ask you if you have taken
into account the fact that there are numerous experts that feel that the"current standards are far too weak.
I guess the comment I want to conclude with is that the drinking water standards under the Safe Drinking
ýWater Act that EPA is now trying to enforce, the standards are basically.a political compromise in many cases.
EPA wanted to go for somethingharder.. It was not possibl.e because they got flack from different'industries or different interests that are trying to post the standards
as weak as possible, and basically what they have is the best they could
safe.' Thatdoes not mean they do not
get. That does not mean it'iswant something stronger.'in the future. This is what they were able toachieve in the -political comment'from 1974 onwards.

A-158

NL_a0p-7-8JOHNPEGNAYJR.(Tr 83): 1 would advise you to try and save Your contnnal shelf very much, and you may look at infrared radiation
photography in a $15 book that would give you some pollution records from1973 on at the area around the capital and here, and for your own home
you might be able to purchase for $8 to $15 a photograph on a daily or monthly
basis for each one, pictures that have a capability of heat sensitivity.
Programs that should be included are some kind of free legal aid system tomake sure the citizens get what they want in the event that federal fundingfor cleanlup is a difficulty. There should be some children's medical monitoring program and adult coverage program, a job loss medical compensation
program. These are all very long-range programs. So that the information
does not die out from the nation, there should be some kind of forced
national media coverage, monthly for a few years after the completion of
the disposal operation. And there should be long-range environmental
tests and there should be published a~ndannounced wind patterns andother local area safety precautions, and there should also be microscopic
photography, cell structure change information offered to the people. There
should be some awareness that if the waste is dumped onto the eastern continental shelf, large industries may use this as a precedent to enforce andallow their advances there.

.BILL TOWNSEND (Tr 90): You are going to make the decision whether to dump
this water or not into the river. You have a lot of impressive figures
it is not going to hurt us, but how come ever since this has happened, there
has not been one single person that has anything to do with the nuclear
industry say that low level radiation long term isn't going to hurt you?
You are talking about 400,000 to 500,000 gallons plus approximately another
90,000 gallons of water. That works out to 80 more truckloads in tanktrucks, 5 to 12 percent increase in transporting stuff to a suitabledisposal site. The alternative is dumping it in the river. We've got
enough stuff in there already. We know what is up there now. How do weknow how much they have let loose already that they have no told us about?
Are you going to aggravate the problem by letting more out? It does not makesense. Eighty truckloads. It is going to cost a bundle to move the rest of
the stuff. You are talking 660 to 1700 truckloads. That was the figure you
used for solid waste. What is another 80?
RONALD SWATHKE (Tr 95): I would like to know if some people have madereference to this before. The electrolytic enrichment of tritium is used
on a laboratory scale for low-level analysis of tritium, and I wondered
if that was considered and whether that process could be scaled up to
concentrate the tritiated water and then solidify it. Let me ask anotherquestion. Maybe my questions are too technical. If you don't want toaddress them here -- there was a lot of krypton gas up there, and anotherquestion I had was it seemed like you have a public relations problem aswell as a technical problem up there. I could not understand why -- had thethought been given to instead of releasing it as a gas into the air andcreating a fear factor among all the people, whether that gas could
have been liquefied and removed off site and then released. That is
technically feasible. If you do release this water into the river andthat is in a fresh water environment, and then it goes into the bay, which
is a saline environment, do you anticipate very large concentration effects
there, precipitation effects, concentration in the sediment of the cesium
and strontium? As far as concentration in fish and organisms, I have seen
conflicting reports as to whether fish and organisms concentrate isotopes
like cesium and strontium and as to what degree they do. Could you giveme a number: fish is how much -- how much cesium it would concentrateover what it i-sin the water? Would it be a like a factor of 10 or --KENNETH MAY (Tr 85): Also, one related statement or question. The PEIS
does -notinclude any economic figures. The Baltimore Sun on October 21,
1980 said that, "It is estimated by state officials that the dockside valueof the fish and shellfish extracted from the Bay each year exceeds $35
million, and that the industry generates total business activity of $150
million annually." The PEIS claims that possible. dumping of radioactive
waste water should have no effect on the marketability of seafood products
if the public is properly educated. I have attended meetings of this kindin Annapolis, Maryland, York, Lancaster and.Middletown, Pennsylvania.
Many of the people at these meetings read the PEIS, and some, like Nancy
Kelly of the Chesapeake Bay Foundation have very well reasoned out theaccuracy of the documentq I have yet to meet an opponent of nucl ear power
who has been convinced by that PEIS and the NRC briefings that dumping of
the waste water is safe. If the NRC cannot convince nuclear opponent~swith whom it can coimmunicate in public meetings of the safety of possible
water dumping, how can it convince nuclear opponents outside the affected
area, with whom it has never communicated, that dumping is safe. I cannot
predict how many people will quit eating Maryland seafood if the radioactive
waste water isdumped. If there is only a drop of 2 percent, I would thinka very conservative estimate, that will be $3 million a year. Further, It
may take years to win back these consumers' confidence, so the figures
should at least be doubled or tripled. In fact, I believe the economic
damage would be much greater, I hope you include these figures when you
calculate the economic cost-benefit relationship of various alternatives.
Finally, let me ask you one question. Will there be an opportunity forthe public to comment on the economic figures in the final EIS?

JOHN MONOHAN (Tr 100): My question is: what gives you the right to takerisks with our lives? You know, I take risks every day. You know, I
cross-the street. That is a risk. But I get angry if someone were to
stand in back of me and calculate that that risk was so small that hecould push me into the street. How do you get the right to take risk withthe seven lives -- rather the three lives of the workers who might getcancer due to the cleanup? How can you take risk like that?

A-159

_06vm

--

19 -10GWYNNETH HOWARD -(Tr 102): First of all, I know that Three Mile Island
is a big problem, particularly for those people who live around it inPennsylvania. Ihave had the feeling over the last couple of months thatthe people in Pennsylvania have had difficulty realizing that people in
Maryland are also concerned about this problem, and sort of discovered
Maryland down the river with some trepidation and started asking
questions. I have to make a couple of points. We live already in Harford
County in the vicinity of Peach B ottom, which was rated in the New YorkTimes as one of the worst plants on the East Coast, and it has accidents ona regular basis and there is no way you can deny that since it has beenin the Aegis, Secondly, we live in the vicinity of Three Mile Island, andthe difficulties and dangers of cleaning that up are already being suggested
as being more than the public knows already and will probably come out more thanthat. We have one reactor already on the our flats, and that is Peach Bottom,
which is enough of a curse, I suppose, for most of us to live with. In
addition, our bay is exposed to Calvert Cliffs Nuclear Power Plant, a plantthat already has stored on its premises waste well beyond the legal level -limit. Now, I realize that Three Mils Island creates a tremendous difficulty in cleaning it up, and it seems to me that if, as you said, we are ina safe shutdown situation, the only thing I could do is urge you to take yourtime and consider the human element as well as the economic and other elements that you are considering. I would also like to observe a couple ofthings, specifically about the Susquehanna Flats. You have spoken in yourstatistics of the probabilities and the generalizations, and I have a coupleof things to say about the flats because of my experience living on theflats. First of all,. in a summer like this you have water levels that aretremendously low, which means you are going to have high concentrations of waterand evaporation, which means you will have problems which they are already having with pesticides. That is, you have pockets of perhaps radiation that you
had not counted on in your general statistics. The second thing is I am
not sure how all this is being handled when it gets to the dam and is concentrated if we already have had a Million gallons of water at the dam that
had low levels of radioactivity. How is that going to be effected when theother half-million gallons come down the river as well? And I would like you*to consider the effect of this and the other background radiation, specifically on the Susquehanna. They are going to have to think of ways of disposingof this waste that are not going to involve our economy and our health in somekind of jeopardizing way more than we are already being jeopardized by justbreathing in and out.

environmental impact statement reveals that federal agencies are following
a course of action that will make Three Mile Island a long-term storage
dump for radioactive waste. Nothing could be more dangerous to the
Chesapeake Bay and the people of Maryland.
No Responsible agency would
locate a dump for radioactive waste on an island in a flood plain abovethe water supply for a major metropol itan- area and poised at the head of
Chesapeake Bay; yet, because of refusal to consider any other realistic
alternative, that will be the result of actions described in a draftenvironmental impact statement." That is from Governor Hughes. So, now
we have this envirornmental impact statement, and evidently people here
tonight the ad hoc committee, feel that all is not well with the environmental impact statement. There are serious problems with it. I hope that in
April or March when the final statement comes out, that I will be able tothank the NRC for listening to the problems, to concerns that the peopleof Maryland have so clearly delineated to you tonight and over the past year
during the many hearings and meetings that have been scheduled. You have.
heard it all before. Everything that was said tonight so eloquently, youhave heard before; and I would feel more confident if we were not saying
the same thing a year later, over a year now. We are saying the samething. We are hearing the same answers. It-makes me wonder what is goingto happen when the final impact 'statement comes out. I have a few questions
maybe I can get an answer on. The first one, Dr. Snyder, I guess you would
not recall because you were not involved in 'the March 20 hearing in Baltimore,
but at that time we heard an agreement from NRC representatives to meet with
us and look into funding for independent scientists to analyze this environmental impact statement when it came out, and prior to that to have input
into it. I would like to know if you would consider reopening these negotiations at this time. The last thing. Would you develop a process other thanthe current method that allows the public to respond to decisions such as
the decision to dump water into the Susquehanna if you should make that -- inthe manner suggested by Roberta Scopes of the League of Women Voters just a
few minutes ago? Do you recall what she said? She was saying she wanted
an ongoing input as decisions were made. The thing that bothered me in.
your answer to. Mr. Cawood's question as to what wouldý happen when the final
statement comes out, you said that you would review the EIS after it wascompleted and see if in your opinion you had dealt properly with the meatof the decision, and if you think you had dealt properly with it,you would
go ahead, something like that.
EMILY JONES (Tr 114): 1 would like to ask some questions about an aspectthat has not been touched on tonight. We are discussing the Three Mile
Island situation as though it were static, and in fact it is my understanding that according to the NRC report, leakage from the reactor's primarycooling system adds 550 liters per day to the spill and the continuing
rising water level now poses a hazard. Some instruments, electric cables
have already been shorted out by the water, and a couple of motors thatare necessary to keep the core from deteriorating any further are now at somehazard. My question is this. You proposed to continue this considerationof the phase of what will we do until the end of March; is that true?

JOHN KABLER (Tr 105): If I believed that everything was under control as
you say it is, I would feel a lot better about this; but I really do not.
My confidence is still shaky after all this time and all these hearings.
I want to read into the record q auote from Governor Hughes, who is notconfident either, in a letter that he sent to President Carter on October 3.
Just one paragraph from this long, strong letter. He says this. "The draft

A-160

-

11 -

241 West 97th Street
New York, New York 10025

SUSAN EWING (Tr 116): I have a comment and a question kind of all rolled
up into one.
In any of the cleanup processes that you are considering as
far as the water goes, be it evaporation or bituminization or whatever,are the primary isotopes of the most concern tritium, strontium andcesium if they should be introduced into the environment, either accidently
or in a controlled manner? Am I correct in assuming that: How are theseisotopes assimilated in the body? And also, can you define what is acumulative whole body dose as opposed to ingestion or inhalation? What isthe difference between a cumulative whole body dose and a dose that you
might ingest, which leads back to the beginning of the question: how isstrontium, for example, assimilated in the human body? In the environmental
impact statement, I do not recall it being mentioned that strontium, forexample, will concentrate in your bones.
I do not recall the fact that
cesium will concentrate in muscle tissue.
In fish maybe it was.
At anyrate, is it the same, then, as far as whole body dose goes with water? Whatwould be the difference, swimming in the water or drinking the water? Would
I get the same whole body dose if I took a swin in an area of water that was
contaminated with detectable levels of, say, cesium? Would that dose to me
be the same as if I drank two liters of that water?

November 19,

1980

Dr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
2055S
Dear Dr.

Snyder:Enclosed please find our comments on the draft programmatic
Environmental Impact Statement related to decontamination anddisposa'l of radioactive wastes resulting from March 28, 1979,
accident Three Mile Island Nuclear Station, Unit 2, submitted toyour office in accordance with the published invitation for suchcomments.
Yours truly,

A resolution by HARFORD COUNTY appears as comnent number 42 in this appendix.

Daniel M. Pisello, Ph.D.

Comments by SENATOR PAUL SARBANES appear as comment number 39 in this appendix.
Richard G.
DMP:lfEnclosure

A-161

Piccioni,

Ph.D.

The proposed
nuclear plant

Critical Comment with Supporting Materials
on Draft Programmatic Impact Statement(TMI)of the population

Related to Decontamination and Disposal ofRadioactive Wastes Resulting from March 28,
1979 Accident, .Three Mile Island Nuclear
Station, Unit 2 (NUREG 0683)

clean-up at the Three Mile Island Unit 2
ispotentially lethalof the United States.

Regulatory Commission,
the United

to a large percentage
The United

together with the utility

States Nuclear(Met

Edison)Protection Agency carefully under-

States Environmental

estimate the real damage to public health ina major agriculturalarea of the United States,. and consistently underestimate
Richard Piccioni, Ph.D.
Daniel Pisello, Ph.D.

probabilityof catastrophic accidents

and structural

damageThe Programmatic(PEIS)

givesnoinandresultingthefrom existing core

the reactor.

Environmental

indication at all

Impact Statement

NUREG-0683

1

harm that will be done

ofthe

to

the health of the public as a result of the proposed clean-up ofTMI.

The PEIS specifically underestimatesradionuclides

that will be released to the environment

various phases of the proposed clean-up.
created(by the'NRC)

A falsethat public health isconcentrations

the maximum dose per.year

set by federal
to. any single

totgl number of induced cancer fatalities

in

impression iscertain maximum

law and thereby limiting

individual.
is

In

fact,

determined

the

by

the total population dose which depends only on the total
This study conducted under the auspices ofAccord Research and Educational Associates,

theprotected by diluting

so as not to exceed

and regulating the releases
permissible

the quantity *of toxic

amount of.

Inc.

radioactivity released,

not on the rate at which it

The.dose.response.factor,
per person-rem,
200 or more.

used ini~e.

The possible

released.

too small by a factor of about

accidents considered

incorporate the real possibility

A-162

the

the PEIS isis

induced cancer fatalities

inthe PEIS do notof structural damage and the core

m

-3-

-2-

5
antimony-12 , nickel-63,

condition which, taken into account, make the possible accidents
both more numerous and more lethal than discussed by NUREG-0683.

the monitoring program described in the PEIS isthe environment is

when

1,

and iron 55.
available toto destroy the integrity of the Zircaloy fuelcladding of the fuel rods.

This was done in the metal-water

reaction that occured in the reactor vessel resulting in the

Finally,

the hydrogen bubble was present in the reactor vessel.

4

The first step in making these toxic materials

No attention was given to the special dangers associated with thelarge quantities of zirconium hydride formed in the core,americium-2

production of large amounts of hydrogen gas.

totally inadequate

According to NRC

for detecting the release of significant quantities of radioactive

estimates 40% of the cladding was destroyed in this reaction.

toxins during clean-up.

The combination of the produced hydrogen with unoxidized
zirconium formed zirconium hydride destroying an additional 20%

Table I gives the total inventory of the TMI-Unit 2 reactor
as of July 31, 1980,

as calculated from the computer program

ORIGEN for radionuclides with significant activity.

of the cladding.

For a fuller discussion of this point see "TheZirconium Connection" 4 which is

For reference

submitted as part of this comment.

purposes we include the adult whole body dose conversion factor

Because of the destruction of the cladding much of thefor ingestion and inhalation in rems per curie taken from thegaseous fission products have escaped from the core and the entire

USNRC Regulatory Guide 1.1092 and from Handbook of Laboratory

inventory of radionuclides in the spent fuel can be leached out by

Safety tables 3,

the primary coolant water, which has been leaking from the primary

and the potential population dose in person-rem5

to the whole body for each radionuclide present.

In this way wecoolant system since the beginning of~the accident.

approximately 300,000 gallons of water in the Auxilliary and Fuelcan see at a glance which radionuclides have the greatest potential
for harm.

Itshould be noted that the dose conversion factors

doses to these age groups.

For example,

1.5 x 10 1

to the whole body from inhalation.

84 billion person rems.

To this must be added the radioactivityof the AFHB and the reactor building,

Other isotopes having large
cobalt-60,

This adds

that will be scrubbed from walls and surfaces in the decontamination

1.26 xl 012 person-rems

potential population doses are the cesiums,

Table II

up to a total of 619,000 curies representing a potential dose of

2.5 times

person-rems to the whole body fromand plutonium-239 and 240,

and 96,000 gallons in the primary coolant system.

water as dissolved and suspended material and as sludge.

According to these figures the worst potential threats

are strontium-90,

700,000 gallons in the reactor building

gives the amounts of the principal radionuclides present in the

1.86 x 106

rems per curie for adults and 4.71 x 106 for infants, i.e.

ingestion,sump,

the whole body dose con-version factor for ingestion of strontium-90 isgreater.

Handling Building (AFHB),

resulting in larger potential

are higher for children and infants,

There areas well as the material

that will be leached out of the core during the decontamination

ruthenium-106,

A-163

-

-4-

and flush of the primary coolant system.

-5-

This may result in

If only 1% of this amount were eventually ingested,an additional 300,000 curies of cesium-137 becoming dissolved as wellas unpredicted amounts of other substances.
still

in

There is,the core about 770,000 curies of strontium-90.

tenth of this leached out during the flush of the core,for example,
If

this would

result in a total population dose of 2000 person-rems to the peopleof these municipalities or to people who consumed food products

one

It

produced with water from these supplies.

that wouldisimportant to pointout how sensitive this calculation is to the assumed amount of

add another 77,000 curies of strontium-90 representing an additional

strontium-90 that will be leached out of the core during primary11
person-rems.
potential population dose of 1.4xl0

coolant flush or any other phase of the clean-up for that matter.

Thus thetotal dissolved activity could easily reach nearly one million

A leaching rate of 20% instead of 10% for strontium-90 would raise11
or 250curies representing a total potential dose of 2.5x10

the population dose to 3120 person-rems.

billion person-rems.

included the effect of other radionuclides beside strontium andAll contaminated water is

to be treated with one or anothercesium.

of the proposed decontamination systems that involve filters,
and either inorganic (zeolite) or organic (resin)
media.

In calculating airborne releases occuring during waterion exchange

treatment,

According to NUREG-0683 these systems will have an overall

decontamination factor of about 10-5.

Also, we have not

NUREG-0683 uses. the figure.01% of the total activity

processed to find the amount that. becomes airborne.

Thus the final productis'This figure"based On experience with a more complex chemical operation

will be water containing approximately one curie of strontium-90

associated with fuel processing."

and 9 curies of cesium 134 and 137 (10 curies in 106 gallons

important to note that this value is quite arbitrary and is=(6..3.4.1,

p.

6-17)

It

is

.003 microcuries per milliliter) representing a total potential

applied indiscriminately to a wide variety of operations involved

dose of 2.5 million person-rems.

in the clean-up.

If this was discharged into

-However, on the basis of this value we canthe Susquehanna River when the flow rate was 5000 cubic feet per

expect a total of 100 curies to becomesairborne

second or 3.2 billion gallons per day,of the water.

and water was taken

for Lancaster at 8 million gallons per day,umbia at 2 million gallons per day,
250 million gallons per day,for the borough of Col-entire time,and for the city of Baltimore

9xiO-

then 260 million gallonsper day or

8

If

during the clean-up

the HEPA filters function perfectly for thethen NUREG-0683

for the filters.

recommends the penetration factor

Applying this factor one predicts

9 microcuries will be released to the air.

However,

ifone

8% of the river would be taken into municipal water supplies,

applies the approach of NRC Regulatory Guide 1.140 as discussed

and 8% of the released strontium and cesium would also be taken in.

in NUREG-0683,

A-164

Section 5.1.4,

then one predicts 1 curie of

__.j

9AL-6A-7--6-

strontium and cesium will be released to the air during the waterassociated with the presence inside the reactor vessel of substan-clean-up without any accidents.

tial quantities,

of 2.75 x 105 person-rems.
area in Dauphin,This represents a total dose

If we consider that 40% of the landof zirconium hydride,and unreacted

This material is present in the reactor vessel partly

zirconium.

Lancaster and York counties is cropland andperhaps 4 tons,

in the form of. fine needles.

Itiscapable of reacting withassume 100% deposition and an annual uptake of I% of the undecayedwater explosively releasing hydrogen with a pressure of 1010 atmos-

isotopes we calculate that a total population dose of 1.6 x ]04

pheres.

person-rems will eventually be delivered to the people eating

and in the finely divided state they may ignite spontaneously.

food from this area.

These problems were discussed in a USNRC memorandum5

According to NUREG-0683,

6.5.4.1,

solidification orJune 6,

Zirconium and zirconium hydride also burn very hot

1979,from Kris I.

Division of Operating Reactors

water treatment will also yield airborne radioactivity amounting

Section Leader,

to .01% of the total activity processed.

Chief,of the preceding paragraph are simply doubled.
processing the waterborne activity,F.

the chief consequence will

be a release of possibly 2 curies of activity,
cesium-137

Thus fromstrontium-90 andThis will be in addition to the dose

to citizens downstream from release of the processed water,
calculated to be 2000 person-rems,of the radionuclides

for Paul S.

Check,

DOR,with copies to C. Berlinger,

Weiss and R. Vollmer.

Thermemorandum duly

not including the incorporation

into the human food chain via fish.

The memorandum concludes with the recommendation to take theMuch larger releases with correspondingly more tragic consequences can result from accidents involving,for example,

warning seriously and take the following precautions:

fires(1) To monitor the presence of hydrogen in
the primary coolant in order to establish
if the decomposition of zirconium hydride
takes place.

which destroy air filters, and fires which may involve spentresin beds or spent fuel.

DOR,

In contact with water at lower pressureshydrogen gas can be released .... Zirconium
hydride in powdery form is pyrophoric andwhen exposed to air may ignite and produce
violent reaction. The information from othersources shows that the auto-ignition temperature of zirconium hydride is 2700 in air.
It is, however, very much dependent on thephysical form of the hydride.

in the area causing a maximum population dose of

32 thousand person-rems.

through Carl H. Berlinger,

notes the problems:and 134 as airborne particulate which will settle on

the farmland

S.

(DOR),

Reactor Safety Branch,

Reactor Safety Branch,

Coffman,dated

Parczewski of the Reactor Safety Branch,

immobilization of the filters and resin beds resulting fromThus the predictions

In this fatter respect we must add

our warning to the warning comment of Professor Earl Gulbransenof the University of Pittsburgh concerning the particular dangers

A-165

in air-9--8-Although NRC staff isin the PEIS.

no mention is made of it

Especially in 8.2.3.3,

we get3.2 x 103 doubling doses

causing 900 additional cancer deaths.
If we assume a better filter efficiency of 3 x 10-4 we pre-aware enough of this problem to discuss its

dangers in internal NRC memos,(3.2 x 104 person-rems),

above(2) When opening the reactor vessel for cleaning
assure that the debris at the bottom of the vessel are
not exposed to the oxidizing environment (e.g., dry air).

dict air releases from clean-up of the water will cause 27 addi-

anywhere

The projected releasetional cancers in the generai population.

where reference is made tousing underwater cutting tools on fuel assemblies and collectionof contaminated water to the Susquehanna as calculated aboveof debris from inside the vessel, some account should be given of

resulted in a population dose .of 2000"person-rems or 200 doubling

how one will implement the above precautions.

doses and 56 excess cancers.

memorandum is

The maximum dose to workers in the clean-up is

attached and submitted as part of this comment.

Next we take up the question
meters used in the PEIS.

30,000 person-rems in NUREG-0683.

of the dose-response para-or individual dose to cancer risk.

i.e.,This is equivalent to 3000

Using the 10--rem doubling dose,cancer fatal.28,

The numbers used in

PEIS are taken from the National Academy of Sciences,

given asdoubling doses or 840 additional cancer deaths among the workers.

These are the factors used to convert

population dose to predicted health effects,
ities,

A copy of thethe observed cancer rate ofthe deposition and annual uptake of 100% and 1% respectively

and the 40% cropland figure for this area,

Advisoryfor each millicurieCommittee on the Biological Effects of Ionizing Radiation (BEIR)of airborne strontium-90 released we predict 8.4 fatal cancers.,

report,and for each millicurie of airborne cesium-137 released we

November 1972,6 and consistently underestimateof ionizing radiation by a factor of 200 or more.

the effects

Brossfind .35 fatal cancers.

hasChildren, infants and the unborn are much more vulnerable

recently analyzed the question of dose response in light of

The doubling dose for the unborn for example isthe most recent epidemiological studies and arrives at a

to radiation.

figure of 5 rads for the doubling dose for leukemia and some-

one rem or less as determined by Stewart.8

what higher value for solid cancers.

number of cancer deaths calculated above can be multiplied byof 10 rems for the doubling dose.

We will use a figure

5 ifThis means that in a popu-Thus,

the predicted

one considers an affected population made up primarily of
infants and the unborn.

Thus,

one millicurie of re-lation.like the one around TMI where 625,000 cancer fatalities

children,are expected in the population of 2.2 million people (seeleased strontium-90 could generate in'the young and unborn 42

Sec.

cancers and the entire cleanup might'generate up to 4,5000 deaths.
This past summer during the two week TMI venting period, mon-

6.1.5.2 page 6-5),

dose of 1000 rad (rem)in 100 x .28

i.e.,

28% cancer rate,

a populationdelivers 100 doubling doses and results= 28 cancer fatalities.

Using

the

itoring was done by Accord Research and Educational-Associates

figure for the(AREA),

airborne releases associated with water treatment calculated

a private scientific environmental and public healthresearch organization.

A-166

Air particulate samples

[Ew 0 1-

=-.Em

-

=

a-

I

E

I

M

-10-

-11-

were collected and the krypton-85 activity in the plume from TMI JI
was measured.
precedent.

This short venting period allowed us to formulate a

As a result of these measurements we calculated 7

millicuries of strontium-90 released,istypically 1.0 x10- 3 cubic meters per second.

a disperson factor, X/Q = 10-6 seconds per cubic meter,favorable for detection.

9f

The total number of cancer fatalities
If

resulting from these releases is predicted to be 50-300 (due tostrontium-90).

rather

We obtain:and estimated 20 millicuries
A = 10of cesium-137 released.

We will choose

Ge(Li) system is

These results are discussed in detail in the paper

attached that we submit as part of this comment,

the minimum amount of cesium-137 detectable using a
25 picocuries

Appendix M) the(NUREG-0683,

minimum detectable release of cesium-137 from the plant isbecause the NRC's

estimates of releases in this "minor" venting were calculated to

25 millicuries.

be as inaccurate and of "no significance"

cesium-137 in a gross beta measurement is

as are the estimates in

Typically,

detection of strontium-90,

NUREG-0683.

the threshold for detection of

1 picocurie.

2 picocuries,

Radiochemical analyses

for strontium-90 provide greater sensitivity,

Table III summarizes the proposed monitoring activities offordown to approxi-

the corresponding mini-

mately 0.5 picocuries.

These limits,measurement of radioactive air particulates and milk contamination

mum detectable releases

and the numbers of fatal cancers

during the clean-up of TMI.

expected on the basis of calculations described above,state and federal agencies,

as well as Met Edison,

regarding the

Of the six agencies involved in envi-

ronmental monitoring,

only two even attempt to detect strontium-90,

a pure beta emitter.

Only the licensee, Met Edison,

pointed out above,in Table IV.
The maximum rates at which these dangerous quantities ofattempts tomeasure strontium-90 more frequently than four times a year.

are shown

radioactivity could be released yet remain undetected depend

As

this isotope represents the single greatest sourceon the values in Table IV,period.

of harm to human beings of any nuclide in the reactor.
A simple calculation based on the reported or likely detection

and on the length of the sampling

Minimum detectable release rates for each monitoring

agency are presented in Table V, along with the mean response

limits for the procedures listed in Table III shows how these methodstime,

are very poor indicators of isotope release into the environment.

time is the average time which could elapse before a release of

The amount,any magnitude would be detected.

to f,

A, of radioactivity released from the reactor is related

the amount collected on the filter, as follows:t
A = tr(X/Q) rfs
We will assume that tr, the duration of the release,ts, the duration of sampling,are equal.

equal to one half the sampling period.

It

The mean responseis evident that improved sensitivity to, low rates of

release is purchased at the cost of delaying the response to alarge release.
andThe air flow rate,

r,

A-167

In fact, practical sensitivities for long

-13-

-12-

independent

entity responsive only to the welfare of the public
rather than the prosperity of Net
Edison.

sampling periods would be less than those given in Table V
because of higher background counts due to fallout collection

In summary,(typically amounting to 2 picocuries of gross beta or .03 picocuries strontium-90 per day of sampling at 2 cubic feet per minute).
This factor further points out the inadequacy of long sampling periods
in protecting the public.

18 fixed sampling stations,(i.e.,

directly downwind)

and at theare very small.

This probability is negligible in the case of Met Ed's 8 and
the State's 3 sampling stations.
itdetectable

over time,

Even under weather conditions

shortening sampling periods;

tional cancers.

flow rate); maintaining mobile

etc.

However,itis evident from the extreme

is

Also,

the induced cancer fatalities per
too small by at least a factor

has been determined by the NRC that 40% of
the claddingof the fuel rods has been destroyed, potentiallymaking available all of the radionuclides in the spent fuelto leaching out
into the primary coolant water.
The primary coolant system

including determinations of gross-beta and strontium-90
The results in absolute (curie)

2as been leaking this primary coolant water since
the beginning

amounts for each nuclide should be made public without delay.
Itthe total number ofIttion that onsite measurements of air- and waterborne radioacti-

must be made on a daily basis.

In fact,of 200.

toxicity of the materials released during this cleanup opera-

vity,

lucky enough to die of other causes before

person-rem used in the PEIS isunits on the plume centerline at the distance of maximum groundlevel activity,

he isillnesses, and genetic mutations
depend only on the total amount of radioactivity
released which
determines the total population dose.
The rate at which these
releases are made is not a factor in the total
number of addi-

increasing the minimum

Some obvious measures could be taken to improve offsite

increasing sample size (i.e.,

ifadditional cancer fatalities,

releases by 10-fold.

monitoring of air particulates:

is much greater than

The NRC insists repeatedly that

protected by diluting and/or regulating releases

the next such planned release.

would not be unusual for X/Q tofall below 10-7 seconds per cubic meter,

either over time or

to not exceed certain maximum permissible
concentrations set bythem and 'enacted into federal law.
These laws apparently limit
the maximum dose per year to any single individual.
However,
an individual is only aided by. such manipulationof releases

the chances of an EPA sampler being

distance of maximum ground level activity,

favorable for detection,in any single phase of the clean-up,

public health isalso optimistic from the standpoint of detection; even within the plume centerline

posed clean-up of the damaged TMI Unit-2,

estimated by NUREG-0683 (PEIS).

The value of X/Q chosen here (10-6 seconds per cubic meter)isthe total quantity of lethal and toxic radionuclides that must be released to the air and waterin the pro-also essential that these measurements be performed by an

A-168

-14-

of the accident,

and to date,-15-

the water continues to leak.

The

acknowledges these possibilities in the existence of interoffice

total amount of principal radionuclides now present in thewater,

either dissolved, suspended or as sludge,

ated to be 619,000 curies,

can be calcul-

or 84 billion person-rems.

be made available during clean-up procedures,a possible 300,000 more curies.

More willroughly equivalent to the radiation from the fallout of a one
megaton nuclear bomb.

a total potential population dose of 2.S million person-rems.
The

available air and water contamination will all enter the food

Zirconium fires involving spent fuel would

release long-lived alpha-emitting plutonium, and americium,aswell as strontium, cesium and all the other radionuclides.

This

would cause immediate death to tens of thousands of people andchain as a factor for the next 5 to 10 generations of people

would contaminate the land for hundreds of thousands of years.

eating the crops from the surrounding Pennsylvania farmlands.

In addition to the proclaimed ignorance regarding a major

Enormous possible dangers are associated with the existence

hazard,originally formed in

ignition of the zirconium hydride cladding,carries out four key deceptions in assessing risk.

the core when the hydrogen bubble was present in the reactor

the NRCFirst, thevalue assumed for the fraction of radi6activity expected toThis existing core damage has created an unstable andbecome airborne

dangerous condition and must not be considered a predictableis speculative and not based on experience withthe operations proposed.

The interaction of clean-up

Second,the efficiency of air filtration

assumed exceeds the NRC's own maximum dependable value.

technologies with the core's unstable condition might be ofcatastrophic proportions.

Direct gamma

radiation from cesium-137 released from such a fire would be

106 gallons = .003 microcuries per milliliter) representing

factor in the clean-up operation.

For example,

of dispersed strontium-90 and other radionuclides.

of strontium-90 and 9 curies of cesium 137 and 134 (10 curies

vessel.

spent fuel, etc.)

beds could lead to millions of deaths from inhalation and ingestion

will be water containing approximately one curieof large quantities of zirconium hydride,

thus clear that they are informed of

calculations show that a fire involving 1% of the spent resin

The final pro-Air releases are also greater than proposed in this PEIS.

isare calculated to be of enormous proportions.

duct figured here using the NUREG-0683 decontamination factor

inIt

hazardous and flammable materials (resins,butalarming quantity of radionuclides to be finally released intoof about 10'-,

Operating Reactors.

Reactor Safety Branch, Division of

Releases from accidents due to zirconium fires and other

The treatment of contaminatedthe Susquehanna and taken Up as drinking water.

1979,

these real scientific hazards of the proposed clean-up.

calculated to bewater will reduce the contamination to an "acceptable"

memo dated June 6,

Third,

the radiation dose/effect relation employed by the NRC to esti-

The PEIS makes no reference to themate the effects of exposing large numbers of people to relatively

possibilities of this lethal situation, although the NRC

low rates of irradiation are based on effects observed at high

A-169

-16-

REFERENCES
irradiation rates.
orders of magnitude.

These values underestimate effects by two
Most significant,however,is1.

The Programatic Environmental Impact Statement NUREG - 0683,(PEIS), Environmental Impact Statement related to Decontamination
and Disposal of Radioactive Wastes Resulting from March 28, 1979,
Accident, Three Mile Island Nuclear Station, Unit2.
July, 1980.

2.

U.S. NRC Regulatory Guide 1.109, "Calculation of Annual Doses to
Man From Routine Releases of Reactor Effluents for the Purpose of
Evaluating Compliance with 10 CFR Part 50, Appendix I,"
Revision 1, October 1977.

3.

N.V.

the totallyfalse assumption that distributing release of a given curieamount of radioactivity over an extended period of time in any
way lessens its ultimate biological effect.

In fact, becauseof the irradiation-rate phenomenon just mentioned,
activity is

the radio-

Steere,ed.,

Handbook of Laboratory Safety,

Second Edition,

Chemical Rubber Co., .1971.

likely to deliver a greater effect when exposure is

prolonged.

5.

USNRC Memorandum, June 6, 1979, Kris I. Parczewski,
Safety Branch, Division of Operating Reactors.

6.

National Academy of Sciences, Advisory Committee on the
Biological Effects of Ionizing Radiation, "The Effects on
Populations of Exposure to Low Levels of Ionizing
Radiation," November 1972.

7.

Bross,I.D.J., Ball, M., Falen, S.:"A dosage response
curve for the one rad range: adult risks from diagnostic
radiation."
American Journal of Public Health 69, 130-136,

8.

Bithell, J.F., Stewart, A.M.: "Prenatal irradiation andchildhood malignancy: a review of British data from theOxford survey."
British Journal of Cancer 31, 271-287, 1975.

and.a major improvement in the intensity and scope of environmental monitoring; that the region around TMI be officiallydeclared unsafe for human habitation; and that agricultural
products from the area be declared unfit for human or livestock consumption.

A-170

1979.

Daniel Pisello,

We demand that no clean-up be made unless there is a substantial reduction in the probability of radioactive releases,"The Zirconium Connection",

4.

Reactor

1979.

01

0)
00

C)

CD
o

C'

s0

OC)'

I-.
in

10

0

C4
.e

4-o
C)

I-.
in

0 0C)
4)
)
C>

co

C)CD

C)

C,
'

4

4)

-4

0
C)
0

C)

C>
C'
-

00

C.
C,

0

a0

0•

U

4-)

C

C)
C)

0

0)
C)

0

co
0),

4-)
'-4

CY
U

0)I

CO

C>

I

o
C>

Pq

E_
LU

H
in
in
Li-C
H
4)

'8

'0

'0

4)

o)
0

0
H

'8
:3

E4
;I

0•

F-

VII
in .

01

0.

in

EH

I

TABLE I.

nuclideH-3

half-life(years)12.3

Radionuclide

inventory(curies)inventory of TMI-2

on July 31,

ingestion
dose
potential
conversion
population
factordose(rems/curie)(person-rems)

1980

inhalation
dose
potential
conversion
population
factordose(rems/curie)(person-rems)

x 105

3,800

1.26 x 102

4*8 x 105

1.26 x 102

4.8

1.1 x 107

4.93 x 102

1.43 x 107

Fe-55

2.7

29,0004.43 x 102

Co-60
Ni-63

5.3
100.

300,000

4.72 x 103

1.4 x 109

1.85 x 103

5.6

10,0004.36 x 103

4.4 x 107

1.81 x 103

1.81 x 107

Sr-90

28.1

790,000

1.86 x 106

1.5 x 107.62 x10S

6.0

x 1011

Sr-89.1490,0008.84 x 103

7.9 x 10

3

9.8

x10

1.4

x10

x 108

1,300,000

3.48 x 10

2

4.5 x 101 2
8
8

'1.09x 10
1.09x 10

3

x 108

7
9

Ru-106

1.

Sb-1252.7

42,0004.05 x 102

1.6 x 104

3.65 x 103

1.S

Cs-1342.1

220,000

1.21 x 10S

2.6 x 1010

9.10 x 104

2.0

x 1010880,000

7.14 x 104

6.3 x 1010

5.35 x 10

4.7

x 10101.6 x 103

1.21 x 106

4

x 10

1.24 x 10

5.

x106

1.39 x 10

1.4

x 108

2.
1.3

x10
x 1012.3

x10

Cs-13730.

U-235

7 x 108U-236

2.3x 107

Np-2372.1 x 10U-238
Pu-2394.5 x 10
24,390Pu-2406,537

Am-241

433

6
9

3.3

4.86 x 102

4.1

4.96 x 102

2.0 x 1031

5.57 x 104

S.57 x 104

18
7,900

4.5
6.4

2,200

6.39 x 10

220

x102
x 104
4

5.46 x 104

3

8.1 x105. x 108
1.4 x 108

1.2 x 107

1.1
1.6

4

8
6

x10
x 108

1.59 x 10
1.36 x 10

8
8

6

7

.03 x1012
12

TABLE IV.
TABLE III.

agencySummary of air particulate and milk monitoring activities
near TMI*

no.
stations

Met Edison
USEPA

8
18

air particulate
sampling periods (days)
method:Ge(Li) gross-beta Sr-89&906*
7***
2-3

7
-

90
-

hod

milk
samp. period
methodGe(Li) 5r-839&90*
7-Conn of PA

3

7

90

30

USDOE

7

-

-

-

USNRC

1

State ofMD-

Minimum detectable releases of strontium-90 and cesium-137 from
TMi under proposed monitoring program*

90-

isotopemetminimum
detectableamount (pCi)minimum
detectablerelease (mCi)*

Cs-137Ge(Li)

25""

25

8.8

Cs-137gross beta

2

2

0.7

Sr-90

gross beta

1

1

8.4

Sr-90

radiochem.

0.5

0.5

4.2

cancers
due toingestion***based on sampling rate of l.0x 10- 3 m3 sec- 1 (2 CFM) and atmosphericdispersion (X/Q) of 10- 6 secm- 3 .
**reference: NUREG-0683 Appendix M (USEPA "Long-term environmental• radiation surveillance plan for Three Mile Island" March 17, 1980).
***see text page 9.

-*reference NUREG-0683, Appendix M (USEPA "Long-term environmental
radiation surveillance plan for Three Mile Island" March 17, 1980).
**Sr-8990 measurement by radiological analysis..
***performed only when gross-beta result is positive.

A-172

mm--now -------NO-El-. .

. _NPNU____ff_

TABLE V. Minimum detectable release rates and mean response times under
proposed monitoring program

agencyisotopemethodmin. detectablerelease rate
(mCi/day)mean
response time*(days)Met Edison

Cs-137Ge(Li)

3.6

3-4

gross-beta

0.3

3-4

gross-beta

0.2

7**

radiochem.

0.011

45

Sr-90

Measurement of Strontium-90
Released in Venting of the TI
Unit 2 Containment Atmosphere:
June 28 - July 11, 1980

Joan Harvey, Ph.D.
Richard G. Piccione, Ph.D.
Daniel M. Pisello, Ph.D.

USEPA

Cs-137Ge(Li)

8-12

1-2

Commof PA

Cs-137Ge(Li)

3.6

3-4

Sr-90

radiochem.

0.011

45

*mean response time is equal to one half the sampling period statedin NUREG-0683, Appendix M (USEPA "Long-term environmental
radiation surveillance plan for Three Mile Island" March 17, 1980).
**allows for approximately 10-day yttrium ingrowth.

This study was conducted under the auspices
and Educational Associates, Inc.
•

A.R.E.A.,of Accord Research

1980

Permission to use this copyrighted material was granted by Daniel M. Pisello,
Joan Harvey, and Richard G. Piccione.

A-173

-2-

away as two miles from the plant and often observed ground level-Between June 28 and July 11, 1980,(Met Ed)
Islandconcentrations of krypton-85 substantially greater than the maxi-

Metropolitan Edison

mum permissible concentration (MPC)

vented the containment building of their Three Mile
(TMI)

Unit 2 nuclear reactor.

cubic meter.

Prior to the ventingof 300,000 picocuries per

In addition, AREA sampling of air particulates
indicating that the

Met Ed reportedI that the building atmosphere contained

yielded a positive result for strontium-90,

approximately 57,000 curies of krypton-85,

release of this hazardous isotope was at least one-million times

a few curies ofgreater than what the utility had estimated as possible.

tritium, and far smaller amounts of other isotopes present assuspended particulates,

Radiation levels were measured with a thin window Geiger-

e.g. radioactive cesium and strontium.

probe connected to a Victoreen "Thyac III"The utility claimed that the amount of suspended particulate

Mueller "pancake"radioactivity was very small and that the exhaust stack filtra-

portable rate meter.

tion system was good enough to keep emission of radioactive

into a digital accumulator-timer.

particulates below detectable limits.

changes in the count rate of 10 counts per minute

The NRC decided to waive

The audio output of the rate meter was -fed
This arrangement detects(cpm),

using

The background count rate in thethe "required" environmental impact statement for the venting.

a one minute counting period.

The NRC further compromised public health by temporarily

Three Mile Island area consistently averaged around 30 cpm.

suspending the federal

converted our excess counts above background to krypton concen-

regulations that limit the concentration

Weof airborne isotopes that may result offsite from plant releases.

tration using a calibration factor determined from laboratory

Finally,experiments with a similar detector performed at Pennsylvania

the releases were made without the NRC requiring

These experiments yielded 310 cpm above back-

immediate check on the amount of beta activity that was being

State University.

released in the form of suspended particulates,

ground per microcurie of krypton-85 per cubic meter.2

leaving them blind to strontium-90,

specificallytion, comparison of measurements made in the field by this Penn

one of the most abundantState group with measurements made by the AREA group at the sameand lethal isotopes in the reactor.
Accord Research and Education Associates (AREA)

In addi-time and location confirmed our use of this calibration factor.

set up24 hour monitoring in the field during this entire two week period,

Air particulate samples were collected on one-inch diameter

to measure radiation levels and collect air particulate samples inMillipore membrane filters (pore size 0.45 microns),

the vicinity of TMI.

rate of 10 liters per minute.

AREA detected the released krypton as far

at a flow

After aging for several weeks,

each filter was counted for gross beta activity using a low background thin plastic phosphor scintillation detector.

A-174

Subsequently,

-4-

-3-

all filters were combined and analyzed for gamma emissions usinga Ge(Li) detector.

Our ground level measurements of krypton-85 concentration

Finally the combined filters were subjected

provided an estimate of the rate and pattern of releases fromto radiochemical analysis for strontium-90 and strontium-89,

the reactor.

yielding the positive result discussed below.

calculated a release rate of 100-150 curies per hour for most of

Twenty-four hours daily throughout the TMI venting,two-manteams in the field tried to locate the point of maximum groundlevel activity.

This point is found directly downwind from theat which the spreading cloud or "plume"the daylight hours of June 30 - July 7.

This value iswith the utility's data for that period,

available through the

NRC.4

exhaust stack and somewhat further from the plant than the point

Using a simple atmospheric dispersion model3 we

However,consistent

for late night and early morning hours during thisperiod and for the daylight hours of July 8 we calculated releaseof effluent gas andrates 3 to 4 times higher.

These higher release rates were acknow-

aerosol first reaches the ground.

Low-lift helium balloons

ledged only for the daytime releases on July 8.

were released frequently both up-

and downwind of the stack indata has been made available by the utility or the NRC for night-

order to study the local wind patterns and locate the plume centerline.

Air particulate samples were collected in the plume at

the point of maximum ground level activity,
was recorded continuously.

of activity observed around midnight on June 30, July 3 and July 5.

While one two-man team tended the

The absence of such midnight peaks on other nights is probably
due to a high degree of atmospheric stability and low wind speed.

a second team continued to survey the surrounding

On those nights these conditions caused the plume to rise very

area with another radiation detector to verify that the pumphigh resulting in low ground-level activity.

had indeed been set up at the point of maximum ground level
activity and to detect,as quickly as possible,

any shift in

the location of this maximum.

on July 2 there were no AREA monitors in the field.

low activity in Figure

1 may be due to the occurrence of similar

atmospheric conditions,interruptions

For example,

Gaps

in the venting,or the factitwas impossible to reach this line when the wind

was blowing down the river.

in the graph indicate periods during which no data was recorded,e.g.

Other periods ofthat the monitoring teams were not in the centerline of the plume.

Figure 1 shows the measured ground level activity averaged
over one hour intervals for the entire monitoring period.

time venting.
The high rate of nighttime venting is evidenced by the peaks

and that activity

air sampling pump and recorded radiation levels during sample
collection,

No release-rate

Figure 1 also shows the time periods during which air particu-

Thelate samples were taken.,

NRC-specified maximum permissible concentration for krypton-85

The volume of air sampled and the amountof krypton-85 in each sample iswas exceeded for several hours around midnight June 30, July 3

shown in Table I for each filter.

A total of 6.3 microcuries of krypton-85 in a sampling volume ofand July 5 and for ten daylight hours on July 8.

A-175

-5-

51 cubic meters passed through the set of 12 filters.
disc

showed gross beta

activity above the-6-

No filter

detection limit

maximum ground level activity throughout the entire ventingof 1.2

received a krypton-85 skin dose of approximately 6 millirems.
picocuries.
area

is

The averagegross beta backgroundper cubic meter,

0.02 picocuries

inthe Harrisburg
5cesium-137.
asreported

Doses due to inhalation and direct exposure to other componentsof the plume are apparently negligible.

Thus backgroundgross beta activity deposited on each filter

However,the long termishealth effects of particulate radionuclides released
well below the detection

to thelimit.

surrounding farmlands are much more serious.
The gamma scan of the combined filters

showed no radionuclides

Using Met Ed's post-venting estimate of 43,000 curies ofabove the detection limits shown in

Table

II.

However,radio-

krypton-85 released and our measured ratio of strontium-90 tochemical analysis of the combined filters

for strontium-90 yielded

krypton-85 activity, we calculate a total of 7 millicuries of
0.95±0.36 picocuries or .018

picocuries per cubic meter of sampled

strontium-90 released.
air.

This value is

18 to

50 times larger

released isconcentrationfrom global fallout.6

A reasonable estimate of cesium-137

than the local backgroundapproximately 20 millicuries.

sistent with our strontium,
averagestrontium-90

to krypton-85

activity

ratio

in

Accordingto Met Ed's reported containment

inventory giveninto krypton-85

the plume,

Table

III,

atmosphere

2.1 x 10-10,

approximately

the claimed particulate
calculates

assuming no filtration

at all,760 times less than our result.

filtration

efficiency of 99.98%,

isbeta activity for individual

About 40% of the land in the TMI area is

AREA

pastureland for milk cows.

isof 2.0 x 10-6

inthe filtered

tent with the gamma analysis

in

air.

ingested by humans each year.

decay,and of thisAllowing for thethe result is a total of 1.1 millicuries ofresulting in a popu-

lation dose of 2000 person-rems to the whole body from the ingested

consis-strontium-90.7 Using a doubling dose of 10 rems for adults for

Table II.

all forms of cancer derived from the results of the Tri-StateOn the basis of our field observations we conclude that anindividual

We assumed therefore that 40% of thestrontium-90 eventually ingested by humans,

to krypton-85

This limit is

1% isradioactivewith the result of the strontium analysis and provides

an upper limit to the ratio of gross beta activity
activity

discs

the

cropland including

released isotopes are deposited on crops or pasture,amount,filter

We calculate here only the effect of strontium-90,

most important isotope.

Assuming

tium-90 as they had originally predicted possible.

consistentWefurther estimate about 1.5 millicuries of strontium-89 was alsothat Met Ed released 3.8 million times as much stron-

Measured grossand with the higher volatility of cesium.

the maximum ratio of strontium-90

released.
ingamma emission and gross beta

the effluent

measurementsof 1.6 xl0-7.

This estimate is con-This result indicates an

Survey 8 , we find 200 doubling doses delivered to the population.

located on the plume centerline and at the distance ofIn a population with a fatal cancer rate of 28%9,

A-176

this much

-8-7-

radiation will yield 56 additional cancer deaths.

in significant and variable amounts of background strontium-90

Children,from fallout.6

infants and the unborn are much more vulnerable to the effects
Studies by Stewart 1 0of radiation.

the sensitivity of their measurement of the crucial strontium-90

on the carcinogenic effectto krypton-85 activity ratio.

of x-rays indicate a doubling dose for the unborn of approximately
1 rem.

Thus,

quantity of strontium-90,

the additional risk of cancer or-other radiation-and measured by AREA,

induced effect is ten times greater in the young and unborn.
Therefore,

In summary,as many as 560 or more additional cancer deaths could

result from this release of strontium-90 if

As AREA wished to know

wedge called a plume,

The long term health effects of strontium-90 released as particulates onto the farmlands were calculated to yield 56 additional

at a distance of maximum ground level activity wherever possible.

fatal cases of cancer to adult humans eventually ingesting

the background strontium-90 from global fallout was

food from this area.

picocuries) of the reactor

the background strontium-90

did not limit the sensitivity of our measurement,

this area, because they will be children,

are more vulnerable

Thus, AREA calculates SO

effects will appear in the next five to ten generations.

Noreports of deposits of strontium-90 or other particulate

The United States Environmental Protection Agency (USEPA),

radionuclides have been made by Met Ed or the USEPA to date.

relied on chance to blow the narrow

This design also increased the volume of air

ratio to the reactor effluent strontium-90,

ingesting crops fromto 300 additional fatal cancers and other genetic healthratio in the reactor effluent to be 1.6 parts in 10 million.

plume their way.

Future generations

to the effects of radiation.

and we wereable to measure the strontium-90 activity to krypton-85 activity

using their fixed air samplers,with the highest readings seen downwindof the reactor and at a distance of maximum ground level activity.

we drew air samples from the plume centerline and

Therefore,

The air-borne toxic radionuclides patterned themselves in a pie shaped

and to measure specifically the amount of strontium-90 in those

effluent strontium-90.

(June 28 - July 11) of the contain-of Met Ed that were accepted by the NRC at the time.

Significant releases of strontium-89

only a small fraction (less than .05

AREA's findings showed toxic radionuclides

that are 4 million times greater than the published predictions

the ratio of strontium-90 to krypton-8S5 in the TMI releases,

In this way,

was not reported by the USEPA.

ment building of the damaged TMI Unit 2 reactor in quantities

90 was released to the environment from TMI during the June 28 -releases,released to this agricultural region

the two week venting period

AREA's results show that a significant amount of strontium-and cesium-137 must also be inferred.

The significant and remarkableincluding significant amounts of strontium-90 were released in

the contaminatedfood was consumed principally by infants and pregnant women.

July 11 venting period.

This background deposit substantially reduced

and also resulted

A-177

a

0

a

a

a

*e

0

a

a

0

0

*J

nII

-9

REFERENCES
1.

2.

Letter from W.E.
dated October 8,report.

Riethle, TMI Environmental Control Manager,
1980.
Data exerpted from Met Ed in-house-

Jester, W.A., "Evaluation of radiation monitor effectivenessfor detection of krypton-85," report from Breazeale Nuclear
Reactor, Pennsylvania State University, June 1980.

3.

Turner, D.B., "Workbook of atmospheric dispersion estimates,"
Office of Air Programs, Research Triangle Park, United States
Environmental Protection Agency, 1970.
AP-26.

4.

NRC purge status reports from Middletown Office,9 July, 1980.

5.

Report 19-20,

6.

7.

8.

9.

April,

3

-

]-

..

I

*

1 I

]_-.

i

<CL

*c
,

=
H•.

1980.

,

Alan Smith, United States Environmental Protection Agency,
Las Vegas, Nevada, personal communication, and Environmental
Measurements Laboratory, Environmental Quarterly, October 1,
1980, EML-381.
Bunch, D.F., "Dose to various body organs from inhalation oringestion of soluble radionuclides," in N.V. Steere, ed.,Handbook of Laboratory Safety, Second Edition, Chemical
Rubber Co., 1971, and U.S. NRC Regulatory Guide 1.109,"Calculation of Annual Doses to Man From Routine Releasesof Reactor Effluents for the Purpose of Evaluating Compliancewith 10 CFR Part 50, Appendix I," Revision 1, October 1977.
Bross, I.D.J., Ball, M., Falen, S.: "A dosage response
curve for the one rad range: adult risks from. diagnostic
radiation." American Journal of Public Health 69, 130-136,

]'

-_I.
C9

29 June -Office of Radiation Programs, Quarterly Report:
Environmental
RadiationEnvironmental
Data, United Radiation
States Environmental
Protection Agency,
Eastern
Laboratory, Montgomery,
Alabama,

-

C

1979.

c

0=

0
a

a

r.
o
o<

'

-

-=

I

The cancer mortality rate of 28 per cent is calculated fromthe 625,000 cancer deaths expected- in a population of 2.2
million people referred to in NUREG-0683, section 6.1.5.2.

10. Bithell, J.F., Stewart, A.M.: "Prenatal irradiation andchildhood malignancy: a review of British data from theOxford survey." British Journal of Cancer 31, 271-287, 1975.

-

zz

0

A-178

0

0

0

0

0a

000

0

-

,

~-.u
*A

rn-u

*

-

mA7
-W-

TABLE IITABLE I

Results from combined

filters*

Sample volumes and krypton-85 activity
Gamma-ray emission
Ge(Li) Spectroscopy-

for each air particulate sample

FilterNo.

VolumeFiltered(cubic meters)

Krypton-85
Filtered(nanocuries)

Total activity(picocuries)

beryllium-7

LT 30

potassium-40

LT 60

manganese-54

LT 2

2.1

97

cobalt-58

LT 2

0.9

16

cobalt-60

LT 3

3

4.3

nd*

zirconium-95

LT 3

4

2.7

180

ruthenium-103

LT 20

5

1.9

130

iodine-131

LT 6

6

3.2

830

cesium-134

LT 3

290

cesium-137

LT 3

nd

barium-140

LT 4

710

cerium-141

LT 4

1,700

cerium-144

LT 20

50

radium-226

LT 50

thorium-228

LT 5

7

8

14
1.6

9

4.2

10

12

11

5.0

12

16

2,900

TOTAL:

51.6,300Radiochemical*no data

analysis**strontium-89

LT 2

strontium-90

0.95 + 0.36

*Total filteredvolume of 51 cubic meters containing
6.3 microcuries Krypton-85.
LT = less than.
-'Measurements performed by Teledyne Isotope, Westwood,
New Jersey.

A-179

a 16

TABLE III
Reactor building air sample results (Met Ed)
NuclideHalf-Life

Concentration(Curies per cubic meter)

Hydrogen - 3

12.26y5±1 X 10-5

Carbon - 145730y

4±1 x 10 7Iron - 55

2.6yCobalt - 58

71.3d

<6 x 10-11.
4 1xl10-11

Cobalt - 66

5.26y

(1 x 10-11

Kryton - 85

10. 76y0.93-±.07

Strontium - 8952d1.lI±.5 x 1-1

Strontium - 90

28 . ly

Ruthenium - 103

39.6d

x 10"102.2±.2<2x-102 x 10 -9

Ruthenium

106

367d

< 2 x 107

Silver - l10m

253d

< 2.5 x 10 1 !

Iodine - 129

1.7 x 10 7 y

6±2x 10-11

Cesium - 134

2.05y

1.7±.i x 10-10

Cesium - 137

30.23y9.3±.3 x 10"10

Uranium - 235

7.1 xlOy<5 x 10"12

Uranium - 238

4.51 x 109y

<2 x 10"11 -Plutonium - 238

86y<2 x10-12

Plutonium - 239,240

24

-

,

4 00

The Zirconium Connectionby10

y & 6580y

Daniel N. Pisello, Ph.D.
241 W. 97th St.
New York, New York 10025
April 25, 1979
Revised May 14. 1979

Q1979

D. Pisello<2 x 10-12

All nuclide concentrations listed with a less than symbol
indicate that those nulcides are below the listed instrumentation
sensitivity for those nuclides.

Permission to use this copyrighted material was granted by Daniel H.
Joan Harvey, and Richard G. Piccione.

Note:

Sample taken April 1980 through containment penetration R-626.
Approximate inventories can be calculated by multiplying the con4
centration by the free volume of the containment building, 5 x10
cubic meters.

A-180

Pisello,-2The Zirconium Connection
by Daniel M. Pisello, Ph.D.

The same source indicates that 95% of the nuclear power plants in the world2
outside of Great Britain are water-cooled reactors.
Great Britain has

The vast majority of nuclear power reactors in the world are

currently no water-cooled reactors,
operating with a fatal design flaw.

The flaw isexists which can safely clad the uranium fuel.

since the British Government has thusthat no material
far resisted the world-wide marketing efforts of the American manufacturers
3of these power reactors.
The Three mile Island reactor is a pressurized

Yet cladding isnecessary to contain the radioactive products of fission in
the fuelwater reactor, one of several types having the fatal design flaw.
rods, and to maintain the integrity of the fuel.
must be a good conductor of heat and it

The lies

The cladding material
told by the NRC concerning the hazards of these reactors emerge as all

must be relatively transparent
the more hideous as the real dangers become evident.

to thermal neutrons.

In addition it

must resist corrosion under the
The dangers of zirconium are well illustrated by the events atextreme conditions obtaining in a reactor core.

The material currently
Three Mile Island.

used as cladding in all water-cooled reactors is an alloy of the metal
zirconium.

Mechanical difficulties, the details of which are

not of crucial importance here, led to a partial loss of coolant, andThis alloy called Zircaloy has the dangerous property ofa partial meltdown of the reactor core.

reacting explosively with water under a variety of conditions likely to

As an emergency measure, reservecooling water was sprayed onto the dangerously exposed and overheatedoccur in water-cooled reactors.

The danger we face isinevitable nuclear
core.

disaster.

Because of the zirconium cladding each of these reactors runs

Hydrogen explosions occurred in the containment and later ita high risk of violent chemical explosion and subsequent release of

unexpectedly inside the reactor vessel.
radioactivity on a catastrophic scale., There is,however,wasreported that a hugh bubble of flammable hydrogen gas had formed

no material

This bubble not only interferedwith efficient cooling of the damaged core but also presented thewhich can be used to replace the zirconium effectively.
frightening possibility of a hydrogen explosion inside the reactor
This problem has been deliberately concealed from the public by thevessel.
American nuclear industry and the United States Nuclear Regulatory
Commission (NRC).

The likelihood of such an explosion increased hourly as theoxygen concentration in the bubble approached a critical level.

Such

The recent accident at the Three Mile Island reactor
an explosion would precipitate a meltdown and result in large scalein Harrisburg Pennsylvania has brought to light both the design flaw andthe extent of the coverup.

and long term contamination of the atmosphere and the Susquehanna River
All water-cooled reactors, both heavy waterand light water, are affected by this flaw.

valley. (Spokesmen for the utility company and the NRC claimed ignorance
According to the World Listof Nuclear Power Plants published by Nuclear News,on the subject of the origin of the hydrogen bubble, referring to it

asFebruary 1979, all

but one of the 68 plants in the United States are light water reactors.

a "new twist" and "something that had not been foreseen when the reactor
4
was designed."
The next day the bubble shrank and disappeared.
The

I

A-181

-4-

-3-

the character of the cladding (i.e., the metal cladding isconverted toan-oxide), which can effect its behavior on
8
quenching.

American media carried the story of the disappearance but gave no
explanation indicating only that its disappearance had been more rapid
5

The water-zirconium reaction

than expected.

Zr + 2H2 0-

The claims of ignorance and the pretension of mystery on the partof the utility company, and federal experts In

regard to the appearance

and disappearance of the hydrogen gas are lies.

Explanations for theseisexothermic,

Na + H2 0

NaOH + ½H2
9

While sodium metal combines vigorously with water at room temperature,
the zirconium catches fire in steam at about 20000F, well below theprivately that the hydrogen was produced by the reaction of tons of50009F achieved in a meltdown.

zirconium cladding with steam formed in the reactor vessel during the10(Melting can occur in the core at much

lower temperatures since the zirconium cladding melts at 39000F.

But weeks after the event the only

Also,

eutectics and intermetallic compounds which melt at about 2550°F can form

public reference' to the role of zirconium in the production of the

between the zirconium and supporting materials.)(Recall that of all theWe cannot accept the statements of ignorance by the nuclear industry

major nuclear powers only the United Kingdom has no water-cooled reactors.)

and the NRC.

The April 12 issue of Nature magazine quoted from a letter to The-

cladding.

Guardian, by Sir Martin Ryle of the Cavendish Laboratory in Cambridge.

These men know full-well the hazards of zirconium fuelBut they also know that there is no safe alternative tozirconium in water-cooled reactors, and for this reason they have concealed

He stated in the letter that a highly dangerous hydrogen bubble should
7
The
have been predicted as a matter of "A-level textbook knowledge."
following excerpt is-familiar from high school chemistry which releases about 43 kcal per mol.

engineering and safety, and center around the use of zirconium alloy
6
Experts within the American nuclear establishmnent agreeý
cladding.

hydrogen bubble was in the British press.

releasing about 129 kcal per mol of metal compared tothe analogous water-sodium reaction

occurrences are commonly available in the literature on nuclear

early stages of the accident.

ZrO2 + 2H2

the truth concerning the catastrophic events at the Pennsylvania reactor.
In an effort to protect the nuclear industry as a whole, the NRC istaken from a standard text on reactor-safety and isputting the blame on individual operators,

part of a report dated February 1969:

regulations.

The chemical reaction of the cladding with steam, which issupplied by the water remaining in the bottom of tne primary
vessel after the blowdown or introduced by the operation of theECCS, has.three important effects. First, it furnishes
energy, which can increase the heating rate of the core.
Second, hydrogen, a reaction product is released to thecontainment structure. Third, the reaction also changes

faulty prodedures and insufficient

The power company (Metropolitan Edison) and the reactor

manufacturer (Babcock and Wilcox) are to be the scapegoats.

The entire

American nuclear power industry is committed to the light water reactor
concept.

The fact that an accident in these reactors can lead tozirconium-steam fires in the core, releasing enormous quantities of

A-182

-6-

-5flammable hydrogen and heat and causing extensive damage to the cladding

There appears to be no way to overcome the inherent material
problems associated with zirconium alloys and the current
design of the reactor.

and fuel has been known for a long time and is now proven by the Three
Mile Island disaster.

The suppression of this information has been

going on for a number of years prior to this accident, since it

Greater wall thickness for cladding and lower operating
temperatures of the fuel may help but the chemical andmetallurgical behavior of zirconium alloys cannot be overcome.
No backup or alternative design is available if the present
design and materials prove unreliable. 11

isclear that public awareness of the use of explosive materials in theconstruction of nuclear power plants presents an intolerable challenge

His warnings went unheeded by industry and government.

to their continued existence.

The controversy

was kept from the public.
At the time of this writing the only public protest by a qualified
This writer made calculations based on the quantity of hydrogenscientist against the use of zirconium in power reactors was made by
Earl A. Gulbransen, a materials scientist at the University of Pittsburg.
Soon after his retirement from Westinghouse, where he had worked as a
research scientist for 35 years,

Professor Gulbransen wrote a letter

which was published in Bulletin of the Atomic Scientists.

reported and concluded that about 43% of the approximately 20 tons ofzirconium cladding in the core of the Three Mile Island reactor had been
oxidized in the steam-zirconium reaction-12(The damage done to a groupof four zirconium clad fuel rods after exposure to steam in a laboratory
The following

are excerpts:
After 25 years of research and development work on thechemical and metallurgical properties of metals and alloys
used in nuclear power plants, I have come to the ,conclusionthat the current design and materials cannot give us asafe and well-engineered nuclear power plant,
The use of zirconium alloys as cladding material for the hot
uranium oxide fuel pellets is a very hazardous design concept
since zirconium is one of our most reactive metals chemically.
At the operating temperature of nuclear power reactors
zirconium cladding alloys react with oxygen in water to forman oxide layer which partially dissolves in the metal
embrittling and weakening the metal tubing. Part of thehydrogen formed in the zirconium metal reaction dissolves in
the metal and may precipitate as a hydride phase also
embrittling and weakening the metal tubing.
At temperatures above 1,1000 Celsius (19800 Fahrenheit) zirconium
reacts rapidly with steam with a large evolution of heat andthe formation of free hydrogen, with most metals to form
intermetallic compounds and with other metallic oxides to form
its own oxide. Once zirconium is heated to 1,1000 Celsius,
which could occur in loss of coolant accidents, it is difficult
to prevent further reaction, failure of the tubing and of thereactor.

experiment is shown in a photograph
An unreacted fuel rod is

on page 504 of Thompson and Beckerly.

shown for comparison.)

The enormous amount ofheat released by this reaction adds to the fission product decay hea
and increases the likelihood of meltdown.
Another matter which needs discussion is the disappearance of thehydrogen bubble.

The uptake of hydrogen by the coolant water,even under

the high pressure prevailing in the reactor vessel, can account for only asmall fraction of the bubble.

On the other hand, there is more thanenough unoxidized zirconium cladding left in the core to take up all
the hydrogen in the form of zirconium hydride ZrHI.4.

The dissociationpressure of the hydride is a fraction of a millimeter of mercury at
the reported temperatures,
dynamically favored.

13 so that the formation of hydride isthermo-Hydrogen is known to go into the zirconium through grainboundaries and edge defects of the oxide film.

14(This reference contains a photo-graph showing how formation of hydride leads to disintegration of Zircaloy cladding

A-183

-8•-7--the vessel.
material.)

If all the hydrogen in the bubble were taken up by the zirconium,

another 25% of the cladding would be chemically consumed.

to rekindle the exothermic steam-zirconium reaction releasing hydrogen

A total of

68% of the zirconium in the core has been converted to oxide or hydride.
The NRC describes the cladding as having been "devastated". 1 5Theslower rate of dissipation of hydrogen and heat.

The slow reaction

Both effects increase

the chance that new bubbles of dangerous hydrogen will form.

of zirconium and zirconium hydride with the coolant water continues to

It becomes painfully clear why there has been a systematic censorshiprelease hydrogen from the hydride and also to produce additional hydrogen.

of information available to the general public concerning the behavior of

constantly monitored and removed new bubbles

zirconium in nuclear reactors.

The process of removing theZirconium cladding is the Achilles heelof water-cooled nuclear reactors.

hydrogen is slow and dangerous involving the release of more radioactivity

Ironically, the application of emergency

cooling water to an overheated core can result in a violent chemical reaction

to the atmosphere unless costly liquid hydrogen or liquid, helium traps areof the water with the zirconium metal cladding, producing large amounts of

The complete

heat and explosive hydrogen gas, massive destruction of the cladding andremoval of hydrogen from the reactor may take up to two years.

core, weakening of the reactor vessel and piping from hydridation, hydrogen

Currently cooling water is being circulated through the damaged

explosions and large scale releases of radioactivity to the environment.

core by convective flow which operates with about 1% or less of the pumping
force of the normal operating system.16

Furthermore,convective cooling means lower flow-through of water and therefore a

In addition the danger of hydrogen explosion will not

employed to remove inert gases like krypton and xenon.

is fortunate that the core was only three months oldamounts of long-lived contaminants such as deadly pluionium.

altered and inhibited the flow of coolant through the core resulting inwill accumulate and possibly explode.

Itat the time of the accident since a mature core would yield even greater

The extensive damage and crumbling in the core has also

Unless this hydrogen is

It must also be borne in mind that the steel containment lining

primary coolant.

out of the core and multiplies greatly the amount of radioactivity released

be over as long as there is hydrogen in the reactor.

vessel,through the system for several weeks resulting in extensive leaking ofdrastically increases the rate at which radioactive contaminants are leechedlocal hot spots.

resulting in an explosion and the rupture of the cortainment

absorption of hydrogen from the saturated coolant which has been circulating

The resulting massive exposure of fuel to coolant water

to the environment.

rapidly,

and reactor vessel as well as all the piping have been weakened by theformation of oxide and hydride leads to severe crumbling of both cladding
and fuel pellets.

Such local heating could achieve the temperature necessary

No safe material exists which satisfies the requirements for coating nuclear

The switchover to convective

fuel in water-cooled reactors.

cooling from active pumping by one of the main coolant pumps means aThus the plan of the nuclear industry is

to obscure the knowledge- that these reactors have a major design flaw.

greater likelihood that hot spots will develop in blocked portions of

All water-cooled reactors present the imminent and inevitable danger ofthe damaged core or in the crumbled debris piling up on the bottom of

nuclear disaster and we must insist on the immediate shutdown of all such

A-184

-10-9Footnotes
reactors in the United States and elsewhere.

In addition we must stop

1. "World List of Nuclear Power Plants."
February, 1979, p. 59-73.

Nuclear News.

the sale of these reactors to foreign countries.
2.

Ibid.

Finally we must face the grim reality of the storage of spent fuelrods.

3. First Report from the Select Committee on Science and Technology.
"The Choice of a Reactor System," British Parliament, Session 1973-74(January 29, 1974).

Each of these big power reactors produces waste in the form ofspent fuel rods, thin zirconium tubes filled with radioactive substances4.
including deadly plutonium.

A typical pool may contain a ton or more of relatively volatile plutonium
Only a few feet of water separates the flammable zirconium from

air in which it

1979, p. A32.

5.
The Wall Street Journal, April 3, 1979, p. 2: and also:"Now we are kind of surprised at the rate at which it has moved out."
Joseph Hendrie, Chairman of the NRC, USNRC Discussion of the Three Mile
Island Incident, Chairman's Conference Room, 1717 H Street, N.W.
Washington, D.C. April 2, 1979.

under water in circulating pools designed to carry off the decay heat.

oxide.

The New York Times, April 1,

These rods are stored on the plant site

may ignite at around 14000F.

. 6. For example: Thompson and Beckerly, eds., The Technology
of
Nuclear Reactor Safety, Volume II (Cambridge: M.I.T. Press, 1973), esp.
Ch. 17.
"Chemical Reactions." Sections 3.2.1, "Metal-Water Reactionsof Zirconium Alloys," and 4.4 "Estimation of the Extent of Metal-Water
Reaction During Reactor Accidents."

A zirconium fire in aspent fuel rod storage pool is one of the worst conceivable disasters
because tons of plutonium would be smoked out into the atmosphere.

7. Joe Schwartz, "Harrisburg: Counting the Cost."
12, 1979, p. 589.

Every year the power reactors in the United States produce ten tons of

8. Thompson and Beckerly, p.

deadly plutonium packaged in a thin cladding of flammable zirconium.

9.
1962),

p.
10.

Nature, April

502.

Charles R. Russell, Reactor Safe Guards (New York: MacMillan,
107.
Thompson and Beckerly, p.

485.

11. Letter by Professor Gulbransen, Bulletin of the Atomic Scientists,
June 1975, p. 5.
12. These calculations are based on the following figures given by
the NRC in a memorandum for Roger Mattson from R.O. Meyer, dated April
13, 1979, "Core Damage Assessment for the TMI-2" p. 8.
Hydrogen consumed in explosions: 226 lb mol.
Hydrogen remaining in containment: 80 lb mol.
Hydrogen in the primary system bubble: 76 lb mol (corrected forradiolysis).
The total 382 requires the oxidation of 382 x 91.2 x 1/2 - 17,420 lb
zirconium.
The absorption of hydrogen in the bubble by zirconium to form thehydride ZrH1 .4 consumes 76 x 2 x 1/1.4 x 91.2 = 9,900 lb of zirconium.
13. Warren B. Blumenthal, The Chemical Behaviour of Zirconium(Princeton: Van Nostrand, 1958), p. 77.
14. Earl A. Gulbransen and Kenneth F. Andrew, "Reaction of0
Hydrogen with Preoxidized Zircaloy-2 at 3000 to 400 C," Journal of theElectrochemical Society, 104 (1957), 12, 709-712.

A-185

-1115.

Radio News Report WQXR-AM, New York, New York.

'-3j.0C

16.
In preparation of this portion, the author benefitted fromdiscussions vith Richard E. Webb, author of The Accident Hazards of
Nuclear Power Plants (Amherst: University of Massachusetts Press. 1976).
17.

'.A3

April. 15, 1979

I'irI.F1',WDUII TOR:Paul S. CI~ck, Chief. Reactor !aý'-y rranch, U,)RTHIRU:

Cirl H. B~irlirjer, Section Lr;.!ir, ý:ctur Shl'tty D,,^;nch, I.OR

FROMI:

K~ris I. raic--cds-i

SUBjECT:

FOR114.TICN OF ZIRCONIUM HYDRIDES IN THE 1XHiEE M~LE ISLAND-2
I NCIDE14T

Thompson and Beckerly, p. 455.

Rcactcr. Sa,'tty ^ýench.h

W3P

Introduction
The Secretary of the Derart.ent of Envirormental Rasources, Cornon'ealth ofPrennsylvania trars.•itted to us a letter from Pr.ofessor W. E. Wallace of theU,•iversity of Pittsburgh in which he draws attention to the fact that during
the ThI-2 accident large amount of generated hydro~en may have caused fornotion of zirconium hydrides which, if not handled p,'operly, can under certain
circumstrnces cause a violent reaction. Prof. Wallece quoted the work ofprofessor E. Gulbransen, also rrom the University of Pittsburgh. -'ho for thelast 25 years v.:as studying th•e kinetics of forration ind d•composition of
zirconium hydrides.
The purpose of this viL;TO is to -val.:aae, in light of the pr:sently evailable
information, the concerns brought by Prof. 'Wallace.
Available Infoa;;•ation
The information used in evaltating the problem of zirconium hydrides came fromthe following sources:

A-186

(1)

Telephone ccnversation with Prof. Gulbransen (C-6/04/79).

(2)

Conversations with several ie,rbors of the iNRC Staff (F. D. Coffran,M. L. Picklesimer, 0. A. Powers).

(3)"The Metallurgy of Zirconium," by B. Lustran Lnd F. Iterze, Jr., VIc GrawHill Book Cownpany, Inc., 19S5.

(4)"The Vetallurgy of Zirconium." by D. L. Dougli.ss,(5)"The Encyclopedia of the Chciaical Elm;i-ents," by C. A. ,Xa:mel, FReinhold
Book Corporation, 1968.

(6)"Dangerous Prooerties of Industrial M:atcrials," by N. I. Sax, Van fiostrand
Reinhold rn,pany, 1975.

IAEA, Vienna,

1971.

F.:.ul S. Check
Paul t.

Check

-2-.

3.- hek~:lIVC 1131

JLA0 6wj?3

EvalUation of the Problem
Prof. Gulbranson (Source 1) ha.d indicated that iJ.:n Zr ccees in cont.ct Otth
J
hydrogen at certain pressures tv-o types of zil'roaluIhyde:ide are fot---J:
Zr H1.4 and Zr 141.9. At ab:ut S00OC the equilibrii. hydro-wen pressures ror.these compounds are few hund,-eth of i.v Hg end few r:m Hi, respectively. Th.se
hydrides 'are for,'ed despite the existence of potective ZrD2 because, eccrdIng to Prof. Gulbransen, ZrO2 cannot stop co.mpletely pei~etration of hyd.4,Ves
Into metallic Zr. This is a controversial point since in th! opinion of otJier
people (Source 2) ZrO2 could completely pravent hwydrogn r,-em coming in .cntAct
The information from the literature (Sources 2 and 3) alsowith metallic Zr.
confirmed the view that ZrO2 w;ould very significantly limit hydrogen renetration.

TI.0 e.xstig infor,-ation on for.rAtin and 2'..:::vicur uf 1rcunium hIydie: :re-ceuse of th, o,;sibility of exist".:o,:C ofsc.,..hat cont.roversial, l*o;..,r, [..:vreproci.tic::s .,,e1.;,;,,gthis hazardo'us material in t;, r:.actor-vzssel ikhe
recow.rended:(1)

To monitor the presence of hydrogen in the primary coolant in order toestablish if the decomposition of zirconium hydride takes place.

(2)

When opening the reactor vessel for cleanring a.surz that the dbris at
the bottom of the vessel are not exposed to the oxidizing env';rC,:::erit(e.g. dry air).

Prof. Gulbranson pointed out that Zirconium hydride i.orm.ed on Zr surfsces r47
spall off forming a highly divided mass at the bottom of the reactor vessel.
This point was also challenged by other people (Source 2) who did not believethat Zr tiydrfde could ever assume a highly divided form.

Kris 1. Parcie,ski
Reactor Safety Branch
Division of Operating R-actors

According to Prof. Gulbransen the presence of zirconium hydride in the r.actor
vessel in THI-2 rould cause two problems:(I)

In contact with water at lc-fer pressures hydrogen gas can be rel.esed.
Although the rate of release woutd be slow the existence of this sou.rce
of lfydrogen should be taken into consideration.

(2)'Zirconium hydride in powdery form is pyrophoric and wThen exposed to air
may ignite and produce violent reaction. The information obtai.wd ifroother sources (Source 6) shows that the auto-ignition temperature of
Zirconium hydride is 270"C in air. It is, however, very much dependent
on the physical form of the hydride.

As a remedy Prof. Gulbrar.sen has suggested a m~ethod for decomposing zirconisia
hydrides by circulating hydrogen free water at'low pressure and preferably
containing some oxidizing agent (e.g. dissolvced air). The rate of decoa.ptsitfonwil) be slow because of a slow rate1 of reaction and it would take a long tine
to decf~npose all hydrides.
In order to.dt.4ennine tlhe Ixim:in amount of zirconium hydride which could
theoretically be formed during the accident it i;as assumred that 30' of Zr isthe core reacted with steam or water and that 30% of the hydrogen generated
in this reaction formed hydrogen hydride. With these assumptions aýout ?500 lb
of zirconium hydride would be formed in the rcactor vessel during the accident.
and ItIt should be realized however, that this is an upper theoretical liin.mt
is most unlikely that such large amount of zirconium hydride would ever be produced.

A-187

cc:

C. Serli; er
F. Coffi-,,•nS. Weiss
R. Volli.,er

FRANKLIN and MARSHALL COLLEGEFRANKLIN and MARSHALL COLLEGELANCASTER, PENNSYLVANIALANCASTER, PENNSYLVANIA 17604

DEPARTMENT of GEOLOGY

November 19, 1980

DEPARTMENT of GEOLOGYCOMMENTS ON NUREG-0683
DirectorThree Mile Island Program Office
U.S. Nuclear Regulatory Commission
Washington
DC 20555

DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENTRELATED TO DECONTAMINATION AND DISPOSAL OF RADIOACTIVE
WASTES RESULTING FROM MARCH
28, 1979, ACCIDENT THREE
MILE ISLAND NUCLEAR STATION, UNIT 2
Docket No. 50-320

1. Models presented for the behavior of radionuclides discharged in plant effluents
into the Susquehanna River are not supported by existing scientific data. Estimatesof radionuclide buildup in river sediments (6.3.5.4) are unrealistically low.
NUREG 06.83 (P.6-27) recognizes that isotopes of cesium have an appreciable
tendency to combine with clay particles suspended in river water. Based on an
estimate of 10 to 20 mg/l suspended material during normal flow and 40 mg/l duringstorms, NUREG 0638 concludes that the bulk of the cesium (75 to 100%) will remain
attached to suspended clay and only a small percentage will be deposited in river
sediments (Gross, et. al., 1978, is cited by the document).
These predictions are in error for the following reasons:.

Dear Sir:This letter plus enclosed statement constitute our comments on the NRC's plans
for the cleanup of the TMI-2 accident (NUREG 0683).
As geologists familiar withthe physical and chemical processes that influence the environment, we feelcompelled to voice concern.
The plan demonstrates a lack of understanding of
how physical, chemical and biological processes will affect the radionuclides
released to the environment.
Existing scientific data suggest that radionuclides
may be reconcentrated by some of these processes.
The plans for off-siteradiation monitoring are not adequate to determine the maximum doses to theindividual or to detect any reconcentrating of radionuclides in the environment.
NUREG 0683 does not adequately discuss the interim storage and final dispositionof nuclear waste generated by the cleanup.
Significant problems which alreadyexist with wastes generated to date are not addressed.
Discussions of alternative
methods for each step in the cleanup should include a description of the expected
waste products and should consider the management, stability, and disposal of
the waste products before choosing a preferred cleanup procedure..

(1)

Since NUREG 0683 mainly puts forth alternative cleanup schemes, without choosing
a definite cleanup procedure, we strongly urge that a more finalized anddefinite plan be prepared and presented for public comment.

(2)

Yours truly,

Arthur H. Barabas, Ph.D.
Assistant Professor of Geology
Coordinator of Environmental Studies

17604

Steven Sylvester,-M. Sc.
Specialist in Geology(3)

Gross et. al. (1978) found that under normal circumstances
between 1/2 and 2/3 of the Susquehanna River's suspended loadthat passes Harrisburg, PA is deposited before reaching
Conowingo, MD.
Schubel (1968, Fig. 1B) provides data indicating that thesuspended load at Conowingo, MDis less than 10 mg/l during
65% of the year.
(These data indicate that the bulk of the cesium, as wellas the other radionuclides that attach to clay particles, will
be deposited in the bottom sediments of the Susquehanna River.
Since clays settle out of river water only in calm or still
areas, most of the cesium-charged clays will be deposited inselectedsites, producing appreciable reconcentration ofradionuclides).
Predictions of the behavior of cesium-charged clays reaching
the upper Chesapeake Bay do not consider that the clays will
undergo flocculation when encountering salt water. Flocculation
results in rapid deposition of clays, suggesting that theremaining cesium-loaded clays'will be deposited and reconcentrated
in select areas of the Bay.

A-188

3.

2.

characteristics of the sediments to determine if the samples

2.
The NRC should be complimented for its efforts to assure that occupational

contain recently deposited clays.

radiation exposures and airborne and aqueous releases to the environment arewithin levels permitted by federal regulations.
In some areas, however, its
approach is rather short-sighted. We believe that in order to assure the publicof the safety of the cleanup activities at TMI and of the nuclear industry ingeneral, the NRC should undertake further scientific studies of offsite waste
dispersion. Although the environmentaiionitoring program (Chapter 11) is heavily
skewed toward detection of airborne releases, the airborne monitoring network
cannot adequately determine the ultimate fate of a known amount of radioactive
material released from the stack or from other sources at TMI. The NRC should beready to track and make instantaneous measurements of both controlled anduncontrolled airborne releases. This would necessitate having mobile monitors on
the ground on both sides of the river as well as aircraft with detection equipment
hangared at local airfields. At present, the radiation dosages are only time
averages at the fixed monitoring sites on the ground. At all other geographic
positions the dosages are extrapolated from the fixed sites. The total dosage
will almost certainly err on the low side since a plume of radiation is more
likely to pass between the fixed monitoring sites than over them. Likewise,radiation dose received by an individual positioned between monitoring sites
will be underestimated. Installation of a much larger number of stationary sensors
would improve estimates, but tracking releases is preferable since it minimizes
extrapolation and allows a more scientific understanding of the dispersion
processes.
3. NUREG 0683's Environmental Radiological Monitoring Plan for ground and surface
waters, sediment, and biota is inadequate for the following reasons:(1) Most monitoring efforts involve air sampling while most of theremaining clean-up activities involve work with liquid
effluent and solid wastes.
(2) The monitoring consists of six different monitoring plans
drawn up by six different agencies with differing goals andareas of concern. A single, coherent plan using the resourcesof the six monitoring groups in a coordinated manner should
be developed.
(3) Monitoring of the Susquehanna's bottom sediments andinvertebrates is not detailed or extensive enough to detect
the reconcentration of radionuclides in select areas. Analyses
of bottom samples should include descriptions of the physical

A-189

(4)

Monitoring of river water is not detailed or extensive
enough in light of expected variationsof the amount ofradionuclide-charged
time.

clays suspended in the river at any one

The amount of suspended material will vary widely due

to variations in river turbulence and velocity.
(5)

Contingency Surveillance Procedures (11.8) are inadequate tomonitor the dispersion of radiation resulting from any
uncontrolled release.

-

The maximum two hour response time fora mobile laboratory and 6 hours for airborne monitoring dolittle to monitor a short intense, airborne release.

Composite

sample analysis will delay the detection of uncontrolled
release of liquids into the Susquehanna River by as much asa week since samples are composited on a weekly basis.
Contaminated samples should not be composited with any samples
collected before or after uncontrolled releases.
4.

The use of organic resins to filter radioisotopes(e.g. EPICOR II)

isfrom contaminated water

highly questionable since the stability of the spent radio-

active resins, either in the untreated formed or immobilized in some medium suchas concrete,is poorly understood.

In addition, the radioactivities of EPICOR II
3

resins from TMI-2 (Cs-137 activities of approximately 40 Ci/ft ) are considerably
in excess of the limits proposed by the government for shallow land burial.
Inspection of a report by the staff of the Nuclear Waste Management Division of
Brookhaven National Laboratory (R. E. Barletta, et.al.,
Leachability,

Structural

Resins Solidified in Cement and Cement with Additives"),Public Documents files,

May 1980,"Status Report on

Integrity, and Radiation Stability of Organic Ion Exchange
isavailable in the NRC

particularly revealing about the lack of knowledge ofthe expected behavior of the TMI resin wastes and about the types of problems
which will probably be encountered in attempts to immobilize and store thesewastes.
Experience with organic resins containing much lower activities than those
produced by EPICOR II and preliminary experiments with small. quantities of resins
loaded with higher concentrations of radionuclides suggest that resins andresin-cement mixtures are structurally and chemically unstable.

Mechanical effects

include swelling of resins, and disintegration in water, cracking,weakening of concrete.

and general

Significant radiation damage which is anticipated will

5.
4.
a Submerged Demineralizer System is under construction at TMI, again before thepresent document has received comment and formal approval. We wonder whether
the alternatives to the systems, currently operational or under construction,
can be fairly evaluated given the ex post facto nature of the EIS. The EIS
does not choose between alternative filtrationsystems or clearly specify whichwastes will be treated with which system. We believe that this ambiguity shouldbe eliminated before the current document is approved. Otherwise, we fear that
acceptance of NUREG-0683 will constitute a blanket approval for all of theundoubtedly produce chemical decomposition with generation of chemically active
by-products including acids, oxidants, and gases (e.g. hydrogen, methane, andoxygen), as well as heat. Recently published news stories suggest decompositionof the resins has already converted them into a gel-like substance. The casks
currently containing the TMI resins are also subject to chemical attack. The
possibility of explosions due to buildup of gas pressure or ignition cannot be
ruled out. Resins have been known to ignite at relatively low temperatures.
In addition, small sample studies reveal that most of the cesium in resins isleached by water during mixing with cement.

filtration alternatives.

the Brookhaven staff to conclude that it was impossible atpresent to predict the extent to which leaching of the TMI wastes might takeplace or to assure the public that these wastes would be characterized by low
release rates and low total releases when buried. The Brookhaven staff recommended
that a more systematic investigation of the behavior of organic resins andresin/concrete mixtures be undertaken. They also recommended that "more stringent
waste management procedures be applied to the TMI-2 first stage EPICOR-II
resins" (p. 19). We concur with their conclusions and recommendations.

6. We believe that one could better understand the cleanup and waste disposal
alternatives if the discussion were tied closely to an inventory of the radioactive
materials at TMI-2. This inventory should consider the fuel in the TMI-2 reactor
before fission began, the radioactive materials (including unburned fuel,transuranics, and fission products in the fuel rods and cooling water, andirradiated water and equipment) and their probable location just before theaccident, and the best estimates and possible ranges (for "best" and "worst case"scenarios for each of the contaminated systems) for dispersion of radioactvematerial as a result of the accident, preliminary cleanup activities and/other

5. This information leads us to question the desirability of continued operation
and use of EPICOR-II during TMI cleanup until a more informed choice among
filtration systems can be made based on determination of the safest and mosteffective scheme for immobilizing and isolating the wastes from the environment.
If this is not done we run the risk of having the solid wastes from water treatment
in an undesirable, dangerous , and unstable form. In addition, NUREG-0683 does
not adequately address the effectiveness of the EPICOR-I1 system in treating thewaste water from the Auxiliary and Fuel Handling Buildings. Table 5.2-2 indicatesthat 96 filter liners will be used to process this water. NUREG-05g1 predictedthat 50 liners would be needed. This discrepancy should be addressed, given the
proposed use of EPICOR-I1 for continuing cleanup activities.

should also be
occurrences up the present. Such a mass-balance approach bOe
applied to each cleanup step, including calculations of/ lsposition of radioIas well asactive materials before cleanup and dispersion due to cleanup activities4 to thesolid, liquid, and gaseous waste-products of the cleanup and to-the storage anddisposal alternatives. Calculations should include estimates of changing nuclide
abundances due to radioactive decay and nuclear reactions beginning with theaccident and extending into the future until the wastes will no longer constitutea major source of radiation. For example, the worst and best case estimates forthe contamination level of the primary coolant water, both in its present state
and as a result of removing the fuel rods, could be compared with estimates of
the total concentrations of radioisotopes (and their activity) presently containedThis analysis led

in the fuel rods.
We anticipate. that serious problems are likely to be encountered in the future
because filtration systems for the treatment of contaminated waste water are

Adopting this approach would provide an organizational framework which would allow
the reader to assess the importance and potential hazard of each step in thecontext of the whole cleanup. The choice among alternative cleanup procedures
would be based on an assessment of the integrated effects of all cleanup activities,

being constructed before Environmental Impact Statements have been prepared andbefore management of the wastes which they produce is well understood. EPICOR-II
was built before an EIS studying the alternatives was prepared.

Nowwe learn that

A-190

I

N

0

2

ON,

N

6.
including those of the particular step under consideration. Choices based on the
myopic view of only the short-term exposure and accident scenarios for a particular-procedure, considered alone, would be avoided.

FRANKLIN and MARSHALL COLLEGELANCASTER. PENNSYLVANIA

17604

November 24,

DEP.RTMENT of GEOLOGY

The inventory approach would also permit assessment of accidents and controlled
and uncontrolled radiation releases during the cleanup and might permit a backcalculation to determine the total amount of airborne radiation released during
the accident. One would gain valuable knowledge and insights into the steps in
the accident, equipment performance, design criteria for reactors and safetysystems, as well as scientific data about dispersion processes and mechanisms.

DirectorThree Mile Island Program Office
U.S. Nuclear Regulatory Commission
DC 20555
Washington
Dear Sir:
The enclosed list of "References Cited" was inadvertently notincluded in comments concerning NUREG 0683 we submitted to yourIn the interest of
Middletown office, November 19, 1980.
completeness, we would appreciate your adding them to ourcomments.
Yours truly,

Arthur H. Barabas

S. Sylvester

A-191

1980

FRANKLIN and MARSHALL COLLEGELANCASTER, PENNSYLVANIA 17604

REFERENCES CITED
DEPARTMENT

Gross, M. G., et. al. Suspended Sediment Discharge of theSusquehanna River to Northern Chesapeake Bay, 1966-76,
Estuaries 1 (2): 106-110, 1978.

of GEOLOGY

November 18,

1980

QUESTIONS ON THE DRAFT PROGRAMMATIC ENVIRONMENTAL STATEMENT (P.E.I.S.)
Relating to decontamination and disposal of radioactive
wastes resulting from March 28, 1979 accident at Three
Mile Island Nuclear Station, Unit 2.

Schubel, J. R. , Suspended Sediment Discharge of the SusquehannaRiver at Havre de Grace, MD. during the Period 1966-67,
Chesapeake Science 9 (2) 131-135.

In compliance with the NEPA legislation allowing comment on P.E.I.S, theEnvironmental Problems Seminar (Geology 54) at Franklin and Marshall College wish
to respond.
We have chosen to organize our comments into three categories:
Decontamination and Cleanup Plan, Waste Management and Transport, Environmental
Effects and Monitoring.
We feel as though these categories best depict theactivity that is necessary in the decontamination of TMI-2.
In our opinion thisstatement is deficient in several areas:

a)
b)
c)
d)

There is a lack of choice between alternatives proposed for cleanup
operations.
There is a lack of knowledge about the status of the reactor core.
There is inadequate provision for waste disposal and storage.
There is a lack of chronological sequence in the sections of thestatement.

Initially, our group approached this document with a degree of optimism.
We wereunder the impression that we would be able to accept or reject particular sectionsof each chapter. However, as our criticisms accumulated, we discovered that
there was not a single chapter left untouched.. Consequently, we have decided
to reject each chapter.
Where criticisms are few, thechapter itself is vague.
,.We do not intend these comments as an assault on the NRC, but as constructive
criticisms or questions that can be posed as decontamination possibilities of
TMI-2 are studied. We ask that the NRC be
reful and judicious in selecting
the correct procedure.
Remember We are on-.human.

/•"

-

.

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."4-

•J.

,,77K

.

*
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A-192

"

"

.1
I .

6.6.2.2

Decontamination and Cleanup Plans
Because of uncertainty about the extent of the radiological damage
within the reactor building, the P.E.I.S. sections on decontaminationof. the reactor building and equipment are incomplete. More thought
and work will have to go into a plan which should be:(a) More definite in terms of which operations are the mosteffective.

6.6.2.3
and6.6.4(b) More definite in determining the sequential order ofoperations.

6.7(c) More definite in estimating the timing, duration andintegrated amounts of expected releases of radioactive material.
Criticism of specific sections include:(1) The P.E.I.S. only puts forth a "plausible" sequence of the

6.4.2.1

major decontamination steps for the reactor building. However, choices
among specific cleanup procedures for each step are not made.
(1) The section asserts that the sump water could be removed in

to date is not taken into account in the evaluation of future wastesof this type.
The N.R.C. states that compaction and incineration will be "used tothe extent practicable".
There is noeffort to define this statement.
This is of considerable concern because compaction and incinerationof 'tash can give off radioactive effluents directly to the environment.
Onewould have to determine whether these are alternative techniques
which would reduce the releases of radiation to the environment. A
total estimated amount of radiation releases from this source has notbeen determined by the N.R.C.

Table
6.6-15several ways. However, none of the alternatives described provide
a satisfactory method of cleanup. No data is given on which

One of the casks containing the first stage zeolite liner is made toendure a 30' drop. However, transporting and handling requires thecasks to be 60' above ground level. Since a 60' drop from a cranewould be part of a worst case scenario, casks capable of survivingsuch a drop should be used.

alternatives provide lowest worker exposure.
(2) The procedures and alternatives for remote decontamination, semiremote decontamination and hands-on decontamination described in this7.

section are well thought-out and complete. Nevertheless, the statement
offers several methods without choosing a preferred method as being
less expensive, easier or safer than another. For example, thestatement says that remote decontamination above the 347 ft. elevation
could be accomplished either by the overhead spray system or by a lowelevation stream injection with pulsed overhead water spray. No
6.6.3.2

2.
The N.R.C. does not discuss adequately the final disposition of thehigh-specific-activity zeolites after they have been packaged in theirdewatered state. In addition, the immobilization and dewatering of theorganic resins were still being evaluated. Information about thepresent condition of organic resins generated by the EPICOR-II system

7.2.3.5

The N. R.C. has issued a Draft Programmatic Envi ronmental Impact
Statement on Reactor System inspection and has requested comment, after
inspection has already begun. Section 1506.1 of the National Environmental
Policy Act states, "that until an.agency issues a record of a decision,no action concerning a proposal should be taken which would limit the
choice of alternatives".
Section 7.2.3.5 states that the system needed.for decontamination could
be used in some combination with the manual plant system to process
primary water and the associated waste. This 'may" result in less than
optimal facilities being used for some individual processes, in orderdecision is made as to which method will be used.
The N.R.C. states that because of the drum's surface radiation and thespecific activity of the sludge, the packaging of the waste will haveto be done "remotely or within a drum shield". Yet, the N.R.C. admits
that there has been no decision as to the design of this drum packaging

to better optimize the use of all facilities in the decontamination
process. This suggests selection of less than optimal clean-up

station. The N.R.C. off-rs no procedural conditions, burial constraints,
environmental or health implications relevant to the decision of the
packaging an~d packaging facilities.

Table
8.4-1

procedure.
The number of Spent Filter Cartridges which will be produced is notdetermined due to the uncertainty of constituents within the waste
fluid.

A-193

3.
8.4.3.3

8.2.1

8.2.2

Reactor coolant pumps and pump motors will be disassembled andtransported out of the reactor building to an on-site decontamination
area should.in-place decontamination techniques prove unsuccessful.

II.
9.1.1

Transport and disassembly procedures lack details (i.e. package type,route of transport, size of disassembled mechanism).
If decontamination

Waste Management and Transport(1) Certain phases of the cleanup, as well as construction of
on-site storage facilities has commenced prior to the preparation of
the P.E.I.S. Hopefully, the P.E.I.S. will not prove to be an ex
post facto rationalization.

Is not possible off-site disposal, as the N.R.C. reports, is the only
other alternative. Due to the large waste volumes (radioactivity(2) The nature of "remedial activities" mentioned in this section
are not defined or explained.

around 5 R/hr with parameters of 712,000 pounds and 12,200 ft 3 ) andinherent potential hazards in handling, procedures for packaging,handling, and transporting mustbe developed.
This section states that trapped fission gas may be released during
deleveling. The amount and final disposition of this gas remains
unaddressed.

(3) This section states that the current phase of operations has no
significant impact associated with it.
No definition or explanationof the "current phase of operations" is provided.
(1) The length of time radioactive wastes are to be stored on-site
and the location of ultimate disposal site is not discussed.

9.1.3.3(2) Can the on-site facilities accommodate all wastes produced by
the clean up?

The best case conditions is "based on estimates of the most probablecondition of the reactor core".
No details of the analysis which
identified this "most probable conditions" are given.

(3) The time period over which the interim storage facility's
integrity is assumed is not given. Over what period is the integrity

The worst casecondition reflects the impact of more severe damage conditions. Why
is a more severely damaged condition considered a less probable one?
Does a best case-worst case analysis provide an adequate model forreactor clean-up method?
8.2.3.4of this facility assumed? Was an expected lifetime considered.
(4) What is the present condition of the existing waste? What
provisions have been made to monitor its condition in the future?
(5) The potential hazards of on-site storage were not discussed in.depth.
(6) A more comprehensive geologic survey should be undertaken to
insure stability of the on-site storage facility.

One learns that "because of need for working with encumbrances (suchas protective clothing) and because of the complexity of the cleanup
operations, productivity factors are assumed to be 50% for best-caseconditions and 40% for worst-case conditions". The reason given forthe lower figure in the worst-case condition is due to the uncaused
complexity of the operations.
was reached are given.

8.1.1.3

8.1.2.1

9.1.3.1

No details of how either of these figures

The N.R.C. staff states that high temperatures and changing pressures
may have caused distortion in the reactor pressure vessel head (RPV)and various other components comprising the core structure. Until amore detailed analysis of the distortions in the RPV head is complete,

9.1.3.3

no coherent plan can be put forth for the clean-up of the reactor or
estimate the environmental impact of such a clean-up.
The N.R.C. staff states that once the core structure has been dismantled,
the huge pieces of radioactive metal will be temporarily stored behinda shield in the building. What effect would temporary storage have onother aspects of the clean-up?

A-19 4(1) Will additional shipping casks become available, and, if so, when?
(2) What'is planned if the casks cannot be acquired? Are otheralternatives now being considered?
(3) What are the minimum number of casks needed?
Commercial LLWburial sites may soon refuse wastes from TMI.
contingency plans exist?

What

9.2.1.1

Secti6n 9.2.1.1 makes no reference to the fate of the on-site lowlevel wastes in the event of a natural disaster (i.e., severe storm,
floods, etc).

9.5.1.1

Concerning the transportation of nuclear wastes, the study fails topresent methods to deal with an enroute vehicle accident and possible
subsequent radiation leakage.

5.

III.
2.1

2.2.3

6.
The P.E.I.S. does not state what the damages the surrounding ecologicalcommunity might incur. A worst case estimate is needed in Chapter
Three.
A study must also be made of the future consequences of a radiation

Environmental Effects & Monitoring
The NRC plans to store high-specific activity and transuranic wastes
for an unspecified time at TMI despite their acknowledgment that thesite does not meet U. S. Government standards for such storage.
This immediately creates an unacceptable situation, especially when
no indication is made of how long this "interim storage" will last.
This section discusses alternatives for disposition of radioactive
waste, but the descriptions lack detailed accounts of the advantages
and disadvantages of each. The safety of each alternative is notdiscussed. This information is of primary importance to facilitate
public understanding of the rationale for the actions taken. One

build-up in the plant-animal food chain. Only small amounts ofradiation may be found in the river but over the years concentration
may occur in plants and animals which are stages in the food chain.
11.1

been formulated. The P.E.I.S. fails to clarify how monitoring
responsibilities, sites and monitoring techniques Were determined.
In addition, the weekly, monthly and quarterly sampling indicated by
the vast majority of monitoring schedules is inadequate to assure
accurate tracking of episodic radioisotope releases. These samplingintervals tend to obscure the actual dose from each release to
specific areas. If large releases do occur, their magnitude and extent
will be hidden by the long term averaging.

alternative not mentioned in the PEIS deals with the disposal of
Epicore II treated, tritiated water. The public has indicated concern
over the possibility of disposal of the water into the SusquehannaRiver. It is apparently assumed that this water will end up in the
Direct oceanic disposal is not considered as an
Atlantic Ocean.
alternative. Pollution of the Susquehanna River could thus be
3.1.6.2

3.1.2

3.1.4.2

Chapter Three must include a case study of unexpected consequences.
(1) It is evident that a coherent plan insuring adequate and accurate
radiologic monitoring of the environment in and around TMI has not

avoided.
(1) The criteria used for defining the impact study area are notgiven. The study area includes the counties of Dauphin,Lancaster,and York, "although impacts may also occur outside of this area".
An impact statement should take into account all those areas which(2) The hydrology of the Susquehanna River and channel sediments isinadequately addressed. The adsorption of radioactive isotopes onto
clay-rich sediments and the subsequent distribution patterns of theseclays are hardly mentioned. These fine sediments, along with theiradsorbed radionuclides will accumulate behind downstream dams andmay be affected, but at the opening of this section, it is clearlystated that this is not the case. A list of the criteria used indefining the study area would be most informative.
(2) This portion of the P.E.I.S. is purely descriptive and provides
the public with no information about the short and long term effects
a clean up operation will have upon the land and its inhabitants.
Toinsure full examination of the possibility of water loss throughfractures and faults in the bedrock of TMI, core boring should beclosely spaced over the entire island. Furthermore, a monitoring
device must be set up to record - any contaminated waterleaking
into the Susquehanna River from the bedrock.

other sediment traps during times of low discharge and will subsequently
be remobilized in effectively higher concentrations during periods of increased
river discharge.

A projection of the cumulative expectations of increased radiationlevels in the Susquehanna River is absolutely necessary.

A-195

Comments on the Draft Programmatic.
Environmental Impact Statement(Three Mile Island)

MILLERSVILLE STATE COLLEGEMILLERSVILLE, PENNSYLVANIA 17551

November 14,

1980

C. Byron Kohr, Ph.D.
Department of Physics
Millersville State College

Dr. Bernard J. Snyder
Program Director, Three Mile
Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

The description of decontamination of the large quantities of water contained in the auxiliary and fuel handlingbuildings (AFHB) and in the reactor building (RB) is incomplete on several counts.

Dear Dr.

I.

Snyder:Attached are my comments on the draft Programmatic
Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from
the March 28, 1979 accident at Three Mile Island Nuclear
Station, Unit 2.

A.

My particular concerns are directed toward thesteps in the clean-up that appear to result in the largest radiation doses to the public:(i)

Release of processed water into the SusquehannaRiver.

(2)

Release of tritium to the atmosphere as aresult of the removal of the RPV head and.
internals.

(3)

Storage and disposal of the resins resulting
from the decontamination of radioactive
water.

The (AFHB) water is presently being treated by an ionexchange system (EPICOR II) resulting in highly radioactive resins, which are unstable and highly acidic.
The properties of these resins indicate that they areprobably not in a solid form, but in the form of aslurry.
As stated in the PEIS, "The relatively high specificactivity and nature of the fission product contaminants on some wastes will make them unique to TMI-2."(Section 2.2.1.3) Furthermore, it states, "Thestandards applied to these unique wastes will beconsidered on a case-by-case basis and, where
warranted, these wastes will be handled, packaged,
and disposed of in accordance with special requirements."(Section 2.2.2)
Comments: The PEIS should state clearly
the range of possible unique wastes anticipated, and the methods by which each such
waste would be handled, packaged, and disposed of. It is disturbing to find that
there is no consideration of potential characteristics prior to proceeding with theclean-up.
Such considerations and analysis
should be part of the PEIS.

The PEIS should address itself more fully to~alternatives to the areas presently proposed.
Sincerely,
B.
C. Byr n Kohr, Ph.D.
Nuclear Physics
Department of Physics
Millersville State College

The highly radioactive EPICOR II resins are presently
in steel-lined containers stored onsite in a concrete
matrix.
It is suggested in the PEIS that these con,ýtainers could be stored onsite for periods of up to
20 years or shipped to. special facilities for either
storage or treatment.
(Section 2.2.3.3)

1ms
1

A-196

M

1L -

Comment: Operation of SDS will produce
spent resins with radioactive loads
comparable in activity and type of isotopes (except transuranics are notexpected) to high-level military wastes.
DOE has not agreed to accept this waste
at military disposal sites and it will
be much too "hot" for disposal at lowlevel waste sites.
The problem of eventual disposition of these SDS wastes isClear, wellnot addressed in the PEIS.
developed plans for disposal offsite
should be made and approved before SDS
can be considered an acceptable treatment
alternative.

Comment: Due to the high acidity of theresins, the steel liners are expected todisintegrate at a very high rate (perhaps as much as a 2% loss of mass perweek).
At this rate the containers could
start to leak in less than one year. The
PEIS does not address this concern atall. Analysis of this problem and possible
solutions should be incorporated into the
PEIS.
Comment: Shipment to special facilities
depends upon several considerations.
What
are the special facilities contemplated
and where are they located?
Shipment
requires adherence to standards establishedby the NRC, one of which is solidificationof these wastes.
What method, or methods,
are proposed for this solidification? Whatis the present state of the resins? How
would the problem of disintegration of thecontainer be handled while in transit?
What route would be used for delivery to
the disposal site?

III.

These questions must be fully discussed andalternative methods of dealing with these
problems must be presented in the PEIS.
II.

As stated in section 6.3.1, 3.9 x 106 liters of highly
radioactive sump water are contained in the reactor
building.
Appendix K of the PEIS describes techniques
Using the Zeolite/Resinfor processing this water.
Process the following concentrations of radionuclides
in the liquid effluent (total volume of 3.9 x 106
liters) as given in Appendix K are listed in the column(2) of Table A. The total amounts of the principal
radionuclides in the processed water from the reactor
building are reported on Table 10.1-2, as corrected,
and are reproduced in column (3) of Table A.
Table A
Principal Radionuclides in Processed
Water from Reactor Building

The reactor building sump water is not yet being treated,
although the plant operators are constructing, without
NRC approval, an ion-exchange.system (SDS) for decontamination of this water.
Since this water is even more
highly radioactive than the (AFHB) water, the problems
encountered in its treatment and storage, and the ultimate
disposal of the wastes, should parallel those of the(AFHB) water, but be more extreme.

(1)

(2)
(From PEIS)
Concentrations(PCi/ml)

Comment: A complete analysis and reviewof the treatment of this water and thedisposal of the wastes should be contained in the PEIS, including consideration of those concerns expressed in Part
I of this comment.

H-3

9.5 x 10-1

3.7 x 109

Cs-137

5.56 x 10-5

2.2 x 105

Cs-1349.56 x 10-6

3.7 x 104

Sr-90

1.78 x 10-5

6.9 x 104

Sr-89

4.2 x 10-6

1.6 x 104

3
2

A-197

(3)
(From PEIS,
Corrected Data)
Total Activity
Processed Water (jiCi)

Comment: In all these calculations complete mixing of the discharge water withthe river water was assumed.
As statedin section 6.3.5.2, consumption of 21 kg/yr.
of fish in the plume would lead to doses
20 times higher, that is, 12.2 mrem to an
adult individual.

Comment: If this processed water is released
into the river, the doses as reported on
Table 6.3-12 are too low by a factor of 1200.
Incorporating the assumptions used in the
PEIS calculations, the corrected values are
Also listed
listed in column (3) of Table B.
in column (2) are the incorrect values
appearing in Table 6.3-12 of the PEIS.
IV.
Table B
Total Body Doses for Exposed Individual for Reactor
Building Sump Water (Zeolite/Resin Processing Method)

(1)

(2)

Pathway

Total Body
Doses (mrem)(From PEIS)(3)
Total Body
Doses (mrem)(Corrected Data)

Drinking Water

2.2 x 10-4

2.7 x 10-1

Fish Consumption

5.1 x 10-4

6.1 x 10-1

As indicated on Table 10.3-1, the largest offsite total
body dose to a maximum exposed individual is expected tooccur as a result of the removal of the reactor pressure
As described invessel head (RPVH) and internals.
section 8.1.5.2, the principal radionuclide contributing
to this dose is tritium, the total amount to be released
over a period of one year being estimated at 560 Ci.
Comment: Alternatives to release of thistritium to the atmosphere have not been
The PEIS should include theconsidered.
possibility of condensing the tritium (inthe form of HTO) from the vessel atmosphereand disposing of it in another manner, such
In as muchas solidification in concrete.
as the PEIS indicates that the offsite dosefrom this source, as well as that fromrelease of processed water to the river (ascorrected above), constitute, by several
orders of magnitude, the largest doses tothe public, greater attention should begiven to alternative methods.

Comment: Using the probabilities for healtheffects as given in the PEIS (Table 4.5-1),
the health effects as given in the PEIS
(Table 6.3-13) and Table 10.3-1) should be
The correct values for therecalculated.
health effects due to the Zeolite/Resin
Processing Method for the reactor building
sump water, including discharging of theprocessed water into the Susquehanna Riverare given on Table C.
Table C
Health Effects
Probability ofCancer Death overLifetime of
Exposed Individual

Probability of
Genetic Effect over
Next 5 Generationsof Exposed Individual

Drinking Water

3.8 x 10-8

7.0 x 10-8

Fish Consumption

8.5 x 10-8

1.6 x 10-7

Pathway

The discharge of the processed water into
the Susquehanna River represents a healthrisk to the public significantly greaterthan any other step in the clean up process,with the possible exception of removal of
the RPV head and should be avoided.

5

4

A-198

November 19,

5AVIE QU DAY 2

1980

~I<
To:

Student Government Association of Catonsville Comm.

CollegeItis our responsibility to keep our bay and wildlife

alive.

For this reason we cannot allow the representatives

DO .DO)This waste will eventually filter

the Chesapeake Bay and it
result will be.
isis

not yet known what the final(for the public)

Pennsylvania in the town hall at 7:30 p.m.

Unfortunately,

this incident has not been very well publicized.

TKIHIS 15 YOUR CNPANC'ý To BE HZAO- -SiGH pmoL'.
\V !2.

IS.LAU A

TH~Vk f1ISTAKEC-Am MOOPS
SDtJ
4:'

The media does not seem to think these public hearings are
It

RR[DIOACTIV& WFhTCR WAJFSTCEVCNT7ULLY FUL1CR INTO THE C4SAPEAVk•3 AY'?oto take placein Middletown,of interest to the public.

TO S•

into

Can we afford to take this risk? Tonight,

the last of 32 hearings(ý)T

DOMPUD INTO THZ S.SQUCHANVAA WHtCH
IWILL

from Three Mile Island to dump radioactive waste into theSusquehanna River.

p THE
H LLDLLDUS AVV

is up to us to prove that thepeople of Catonsville Community College are concerned.
Your vote of support will be greatly appreciatedSincerely,

Robyn M. Sachs (Sophomore at C.C.C.)

A-199

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C)
4367 Americana Drive
Annandale, Va. 22003
November 18,1980
Dr. Bernard J. Snyder
Program Director, Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

e~-i--

Dear Dr. Snyder,
Please find enclosed a copy of my comments no Docket No. 50-320,
the draft programmatic environmental impact statement related to decontaminationand disposal of radioactive wastes resulting from March 28,1979, accident Three
Mile Island Nuclaer Station, Unit 2. I hope that the commemts of myself and myfellow citizens are carefully read and considered in a most thoughtfulmanner.

~uI4

I would like to make the general point, that due to the lackof cost and cost/benifit analysis, that the next edition of this EIS must
be considered to be an additional draft, not a final EIS. This would allow
the public to participate in a meaningful way in the process, for without
the cost information, public participation in the process has been stimeed.
Also, that a draft EIS should be produced for each decision in the clean-up
process, again to allow public participation.
Thank you for your considerations.
Yours truly,

Ira May
Environmental GeochemistI

A-2r03I

Comments of Ira May
Environmental Geochemist,

2)1 found no mention of the disposal of liquids wastes except for the waterin the containment building. Are we to believe that that water is all the radioactive liquids on-site?
Annandale,

VA3)The proposed mass balances do not add up.

In general, I feltthat the hydrology of the Susquehanna Riverand of Three Mile Island, itself,
and the impact of the disposal of radioactive
liquids into those systems is incompletely addressed. Estimates of concentrationsin the river assume complete mixing during low flow periods by the drinking
water intakes of Lancaster, PA.
Yet, there is no discussion as to how a complete
mixing theory was arrived upon.
What about thermal effects, both in a stratified
river system and in the released water?
Does the meeting of a safe drinking
water standard at the intake point suggest no impact? I would suggest that an
EPA drinking water standard is not an impact free level rather it is a levelat which corrective action must be taken.
If the water of Lancaster, PA. contained
the drinking water standard for tritium,, it would be time to investigate theuse of that water not a safe point.
Would the location of the several dams
downstream aid or hinder the complete mixing assumed?These questions must be
answered before a complete assessment of the potetial impacts of release ofwater to the River can be arrived at.
Sediment deposition with the Susquehanna River and Chesapeake
Bay, and adsorbtion of radionucleides by clay minerals, is barely addressed in
the Draft EIS.
My studies of estuarine systems would suggest that mucb of thereleased radionuclides would adsorb to clay particles almost immediatly, andwould be removed from the water column to the sediment layers. The work of
Edjington and Robbins of the Argonne National Laboratory(i.e. Chapter 44,
Environmental Biogeochemistry, ed. by J.O. Nriagu, Patterns of Deposition of Naturaland Fallout Radionuclides in the Sedimetns of Lake Michigan 15 their relation
to Limnological Processes)states that the residence tdme of
Cs in aquatic
systems is less than 1 year with the result that 95% of that which enters thesystem is in the sediments.McHenry etal.(Accumulation of Fallout Cesium 137 inSoils and SEdiments in Selected Watersheds, Water Resources Research Vol.9,
No. 3, P. 676, 1973) state that Cesium 137 is concentrated up to 24 times inthe sediments than in the respective watershed.
This information would
suggest that Cs will be concentrated into the sediment layers to a great degree
and that the could potentially lead to areas of the Bay bottom that would
be heavily contaminated with radioactive elements.
I am disturbed by the lack of mention of the fact that oyster
and clams and allother shekl building aquatic organisms will use Strontium inplace of Calcium in their carbonate shell makeup.
As a matter of- fact, studies
by Dr. Holland of Harvard and myself during my studies at Johns Hopkins University
in Baltimore, suggest that the geochemistry of the strontiate-aragonite crystal
building process in shells favors strontium use. Therefore it would appear that
addition of Sr to the aquatic system would lead to concentrations of the elementin the shells as well as the tissues of these organisms, and would lead to impacts
greater than those postulated in the draft statement.
I feltthat those three geological and geochemical points were in adequatly addresssed in the statement and are of vital
importance to someone of
my technical background. The other major issues which disturbed me I have decided
to present only in summary form as they are not areas of my immediate expertise.
They are as follows:
1) I found that the document was poorly written, some sections did not appear
to even have been proof-read.Technical figures often did not add up and evenmore often did not agree with other figures elsewhere in the statement.

A-m44)the use of tritiated water as a cleaning fluid was proposed in one section of
the document, however, there is no mention of any occupational exposure fromsuch a program.
5)There is no listing of the radioactive elements at the site. An inventoryof the scope of the radioactive on site would be helpful for any clear
understanding of the problem.
6)There is no discussion of the disposal of high-level wastes. And now thatthe Hanford Washington site has been closed by the citizens of Washington state
to low level waste, where will those wastes now go?
7)There appeared to be no discussion of alternatives in the document fordifference courses of action. Also it would appear that the statement"it isSuch a statement
against regulations" is inappropiate in an impact statement.
by it self is not sufficient to limit a course of action:8) Why was the relative merits of ocean dumping not assessed? It would appear
that dilution with ocean water of liquid waste is an attractive alternative.
9)There, is.no mention in the document of what the license requirements are,although an impact is asessed often on-the basis that it is within thoserequirements.
i0) does the monitoring program match teh decontamination procedure or is
set up for general monitorring?

itii) There is no mention of the training of the number of workers who will be
required to complete the decontamination procedure. Although their occupationaldose may be low, will they be prepared to cope with the situation in the con-tainment building?
Thank you again for this oppurtunity to comnent.

Atomic Industrial Forum, Inc.
7101 Wisconsin Avenue
Washington, D.C, 20014
Telephone: (301) 654-9260
TWX 7108249602 ATOMIC FOR DC

November 20,

Nuclear Regulatory Commission

U.S.

Director,Three Mile Island Program Office

The Atomic Industrial Forum's Committee on Three Mile Island 2
Recovery has reviewed the Nuclear Regulatory Commission's draft
Programmatic Environmental Impact Statement (PEIS), NUREG-0683.
The Committee endorses the draft PEIS conclusion that clean-up
operations will have minimal adverse effect on the public healthand safety and the environment, and agrees that offsite radiation
exposure would be much less than the design objectives of Appendix I of 10 CFR 50 for an operating power plant.

oCriteria for liquid and gaseous releases are not statedConsideration should be given to permittingin the PEIS.
releases under the same criteria as required in the TMI-2
operating license.

oPotential conflicts between the NRC, other federal agencies,
and the Pennsylvania State and local governments, are not
Problems have occurred at Three Mile Island
discussed.
and are briefly addressed in the PEIS. Other problems arelikely to occur during the clean-up activities and should
be considered.

There is a real need in the view of the Committee for the clean-up
Possible leaks and indecisions can leadto proceed expeditiously.
Prompt action will minimize the risks
to further public fears.
and the possible psychological stress to those living in thevicinity of TMI.

The following general comments are submitted for your consideration:
o

o

1980

1980

U.S. Nuclear Regulatory Commission
Washington, D. C. 20555
ATTN:

November 20,

Should you wish to contact AIF Committee members to obtain further
information on the Committee's views for the clean-up of TMI-2,
the Committee Secretary, Frank Graham, would be pleased to assist
is enclosed.
A Committee membership list
you in the arrangements.

The PEIS provides a thorough and accurate analysis of therisks to the public health and safety and environment.
The analysis is supported by an overwhelming amount oftechnical information.

Sincerely,

The draft PEIS does not recognize, however, the risks topublic health and safety and to the environment associatedwith delays in the clean-up.' The risks associated withdelay should be considered and this urgency should also
be recognized in the approval process for the PEIS.

Vincent S. Boyer
ChairmanCommittee on TMI-2
Recoveryo

Alternatives for disposal of radioactive waste not suitWhile itable for shallow land burial are not addressed.
is recognized that the disposal of high level waste is anunresolved national issue and that such wastes should be
removed from TMI as soon as possible, consideration needs
to be given for the Department of Energy to provide :interim
storage at federal sites.

oWhile the PEIS points out some unacceptable clean-up alternatives (such as doing nothing), it does not indicate which
Of the clean-up alternatives are acceptable.
Indicating
acceptable alternatives can expedite clean-up activities
and provide some degree of planning certainty in the process.

-2-

A-2Q5

Rev. 10-80
ATOMIC INDUSTRfAL FORUMCOMMITTEE ON THREE MILE ISLAND TWO RECOVERYCOMMITTEE ON THREE MILE ISLAND TWO RECOVERY
Page 2Chairman:Vincent S. Boyer
Senior Vice President, Nuclear Power
Philadelphia Electric Company

Irwin Spickler
PartnerDames & Moore Company

Frank W. Graham
Special Studies Manager
Atomic Industrial Forum,

Fred N. Stern
Vice President
Engineering and Development
NSSS Projects and Licensing
Combustion Engineering, Inc.

Secretary:

A. Philip Bray
Vice President & General Manager
Nuclear Power Systems Division
General Electric Company
Robert Brooksbank
Section Head
Pilot
Plant Section
Chemical Technology Division
Oak Ridge National Laboratory
James A. Buckham
Executive Vice President
Allied General Nuclear Services
John P. Cagnetta
Assistant Vice President
Nuclear and Environmental Engineering
Northeast Utilities
Service Company
Deslonde R. deBoisblanc
Vice President
Advanced Technology
Ebasco Services, Inc.

Richard Jortberg
Director of Nuclear Safety
Commonwealth Edison Company

John J. Taylor
Vice President and General Manager
Nuclear Energy Systems
Westinghouse Electric Corp.

George H.. KimmonsManagerEngineering and Construction
Tennessee Valley Authority

Robert Uhrig
Vice President
Advanced Systems and Technology
Florida Power and Light Company

Herbert J. C. Kouts
Department Chairman
Brookhaven National Laboratory
Milton Levenson
Director
Nuclear PowerElectric Power Research Institute
Saul LevineVice President and General Manager
NUS Corporation
Warren Owen
Senior Vice President
Engineering and Construction
Duke Power Company

David J.
Fogarty
Senior Vice President

Southern California Edison Company
Robert J. Gary
Executive Vice President andGeneral Manager

Texas Utilities Generating Co.
D. Clark Gibbs
Vice President
Middle South Services,

Inc.

Inc.

Nunzio J. Palladino
Dean, College of Engineering
Pennsylvania State University
William B. Reed
President
Southern Company Services,
Marcus Rowden, Esq.
Fried, Frank, Harris,. Jacobson

Inc.

Shriver

A-206

Russell Youngdahl
Executive Vice President
Consumers Power Company

SI

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7Oov. 17, 1950
To.

N7ý2Commissioners

Re,

P.213
gives a very fractionated view..

The format of the PEISit

W94t44that such waste would be created".

was never anticipatee"since it

3Cti::LatO4 concentration of dissolved contaminants in

P6-13

iMCi/sL

Rarc.h 31, 19O

a lay-person,

developed for the "types of unique wastes" generated

No regulations

P2-13
at TUi 2As

Some of the puzzling informationt

to get one's act together.

difficultis3300
652,000
112,000

0.95
163
2]3

7ritiu!

137
13..

sump water,

qCi/gal.

03-12"Gas will be stored or vented to the atmosphere as deemed advisable."P0-ý;:-tl! bc released Iy the Ovaporatloi. of water froa the spent

fuel pool arn fuel transfer canal.
any gallonz?
How mdhowrelease to atnop

total

is

this contained during

Auxillas-_-P5-.3,'

P 6-

,

03-3

3.5, OC(Assuros

,f

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430 erumm after

3

Rteactor bldl.

lkfuelinG ern primary system decontaminationand vegatableor A=-C2

burnirng???

cnapter)

5700 drums direct trash compaction."'"ecause of the rapidly renewal nature of the. Susquehanna
powers and vast dispersive capacity of the atmosphere,fro:disperse the effluents of chemicals andth- clean-up off T!:- 2 is

not considered to represent

radioactive

material

Lrreversibleor irretrieva le com.itTm:rne.s of these resources."

nZ,l

bldg.

burning?

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hav-

bldg.

can be burned)

the use ofthese- resources to dilute arn- A-mw8

fuel hanilii.

cnpactinr. and trash incinr-ration (reactorR•iver and the regenrerative

Yill "tlds'.hat will be ther.

_osn IT./.

P10-2-

ft.

3

total body doses (by inalatior.
tm'a.''i-ra.-m."oonsuýptdn.
gives

1500

l10'O0O ft.

com'tislc'Tablh•UP6-,4cleanup?

ri ve,?

rebe ar:otihe-arn.o easy sAiutions.

2- Lc,¢ rve'
serious concerns for our homes and children.
nharles and Generieve Zmerick
illow St.
439
17034
g spire, Pa.

-Uj

THOMASK. GILHOOLCHIEFCOUNSELSALTERJEROMEMICHAEL
CHURCHILLELIASS. COHENJUDITHA. DORSEYFRANKFINCHiIIFRANKJ* L'ASKI
BEVERLY
J. LUCAS

OFP*ILADLPIILACENTER
UMITRS LAW
Comment to

LNUT ST., 6t

DAVID G. DAVISADMINISTRATIVEOFFICERFL,

PHIL. 1910 7

PE 5-7200

T. HOYLE
LAWRENCE

EDWIN U. WOLFCHAIRMANOF THE BOARD-

EXECUTIVE
DIRECTOR
1974-I976

DRAFT PROGRAMMATIC
ENVIRONMENTAL IMPACT STATEMENTDr.

Bernard J.

Snyder

RELATED TO DECONTAMINATION AND DISPOSAL

Program Director
Three Mile Island Program Office

OF RADIOACTIVE WASTES RESULTING FROM

Office of-Nuciear Reactor Regulation

MARCH 28,U.S.

NUCLEAR REGULATORY COMMISSION

Washington,
Dear Dr.

D.C.

ACCIDENT

THREE MILE ISLAND NUCLEAR STATION,

19 November 1980

20555

1979,

NUREG-0683

UNIT 2

Snyder,Prepared by the

Enclosed you will please find our comment to the

PUBLIC INTEREST LAW CENTER OF PHILADELPHIA

draft PEIS on the TMI-2 cleanup.

For theIf

you or any of the NRC staff

about this document,

have any questions
SUSQUEHANNA VALLEY ALLIANCE

please do not hesitate to calleither me or Judith A.

Dorsey,Esq.
Yours sincerely,

Bruce Molholt,

PhD.

Science Director

Judith A.

Enclosure

Dorsey,Ph.D.

Public Interest

Law Center

1315 Walnut St.
Philadelphia,(215)

AFFILIATEDWITH LAWYERSCOMMITTEE FOR CIVIL RIGHTS UNDER LAW

A-209

Esq.

Bruce Molholt,

735 -- Suite 1600

PA 191077200

COMMENT TO THE PEIS FOR TMI-2 CLEANUP
Table of Contents
Susquehanna Valley Alliance

I.

General Comments - Deficiencies of the PEIS

1

II.

Summary of Specific Comments

6III. Radwastes

7

IV.

Tritium Releases

9

A. Planned releases

10

B. Tritiated water genotoxicity

11

C. Tritiated thymidine genotoxicity

12

D. Suimmary of genotoxic effects

13

I.

13

B. Estimated actinide inventory

14

C. Actinide genotoxicity

14

D. Summary of genotoxic effects

26

V1. Other 'Radionuclide Releases
VII.

Summary of Adverse Human Health Effects

17

VIII.

20

C. Mutagenicity

21

D. Teratogenicity

21

Miscellaneous Coimments
A. Draft PEIS authors

22

B. Proprietary information

23

C. Missing pages

23

D. Sump water tritiim.

23

E. Storage and transportation of tritium

23

IX. References

24

X. Appendix

26

Deficiencies of the PEIS

The deficiencies of the draft PEIS for TMI-2 cleanup are
substantive, procedural and organizational.
The document is nota balanced impartial scientific analysis of the potential environmental impacts from the proposed steps.
Where scientists
disagree, it chooses those quantitative values most favorable
for the licensee.
The reader is never informed of other quantitative estimates or even that a range of disagreement exists.
Ranges in quantitative-risks from all radionuclides potentiallyreleased during TMI-2 cleanup are invaluable for the process of
The one-sided presentation of theunbiased decision-making.
draft PEIS has never been permissible when determining how manyfatalities will result from narrowing the curb of a highway;
it clearly is unacceptable when the risks involve health hazards
to the people of the Susquehanna Valley.*18

A. Radioecological transfer factors
B. Carctnogenicity-

The draft Programmatic Environmental Impact Statement(PEIS) related to decontamination and disposal of radioactive
wastes resulting from the March 28, 1979, accident at Three
Mile Island Nuclear Station, Unit 2 (NUREG-0683) is aseriously deficient document.
This draft PEIS is so deficient
as to render it useless in its present state for the purposes
for which it is mandated - informing decision makers and protecting the public.
The deficiencies of the draft PEIS include gross underestimation of the potential adverse impactof the release of radionuclides during many of the TMI-2
cleanup steps proposed upon the people of the SusquehannaValley region.

V. Actinide Releases
A. Lack of consideration in PEIS

General Comments*Airborne releases potentially affect 2 million people within a
50 mile radius.
Water discharges potentially affect the cities
of Baltimore, Lancaster and other municipalities which derive
their drinking water from the Susquehanna River.

A-210

-

-

-3-

-2The basic purpose of an impact statement is to permit
decision makers to know the impacts and risks associated withany action - in this case with the cleanup of TMI-2.
Th6 first
principle is comprehensiveness.
All of the impacts-must be included and discussed, however, in this draft PEIS some very important impacts are left unmentioned in their totality, suchas possible releases of plutonium-241, uranium-235, uranium-238
and other actinides known to exist in large quantitites within.the reactor core.

The
reactors, the accident and prior "cleanup" activities.
draft PEIS ignores this principle entirely, treating any proposed releases of tritium into the Susquehanna River as if theseprior releases had never occurred and ignoring evidence that repeated discharges increase the impact upon human health.
The third requirement of a PEIS is that it must identify andevaluate alternatives so that a decision maker can know what
This is particularly
choices are available to him or to her.
important in a highly technical area like the cleanup of TMI-2.
The organization of the draft PEIS does not make clear the consequences of the choices which are being considered, nor the
Furthermore, because the cost of eliminating any
alternatives.
particular hazard or impact may be either very great or relatively

Secondly, an impact statement must fairly and completely
include all inforiaation about potential risks.
This draft PEIS
has consistently ignored reports or evidences indicating greaterrisks, including reports which the NRC itself has commissioned.
For example, Appendix H "Engineering Considerations Related to
Immobilization of Radioactive Wastes,"cheap, it is important to know some range of magnitude of com40 CFR Section 1502.23 requires that an EISparative costs.
should include factors not related to environmental quality that"are likely to-be relevant and important to a decision."
Clearly

gives a detailed analysisof the alternatives for imnmobilization.
Yet nowhere in thatappendix is reference made to a report commissioned by the NRC
entitled "Status Report on Leachability,
and Radiation StabilityinStructural

the comparative costs of alternatives for each aspect of the cleanThe absence ofup fall within Section 1502.23's requirements.
such cost information from the draft PEIS* renders meaningfulevaluation difficult at this stage.

Integrity,of Organic Ion Exchange Resins Solidified

Cement and Cement with Additives."

This report,

compiled by

Brookhaven National Laboratory, Nuclear Waste Management Division, outlines some of the potential problems with solidification
by cement, yet it is never cited in the draft PEIS.

The most obvious example of alternative courses which mustbe evaluated is a cleanup where the end product is recommissioning
Although these
the reactor (the chosen policy) or decomnmissioning.
even
differences
are the end of the line differences; they produce
even
not
does
PEIS
draft
The
cleanup.
ofstageseven in the early
how
soon
and
taken
be
would
steps
different
of
what
list
a
includethis choice would be reflected in differing types of work, dif-This problem is particularly important in the area of estimating biological dangers inherent in potential releases ofradionuclides during the TMI-2 cleanup operation.
The NRC iswell aware of discrepancies covering several orders of magnitude in risk assessments from radionuclides, yet these rangesof values are not commented upon in this draft PEIS and decision
makers are never informed of the range of human health risk.

fering environmental impacts and differing health risks.

Another aspect of the fair evaluation principle is that it
must be based on real and actual conditions, not on a hypotheticalor imaginary world.
This means any health consequences must be
evaluated in relation to the discharges already absorbed by the

While the agency apparently believes that the raising of thisissue would be politically unwise, the fact that environmental impacts of the cleanup will be affected makes it impossible to avoid.

*It has been promised for inclusion in the final PEIS.

Susquehanna Valley population during the operation of the TMI

A-22.1-4any disagreement with the agency's
position that the reactor core must be removed from the containment
vessel at some point, it is not nearly so clear that other portionsof the cleanup of the containment building would have to be so thorough.
If in fact the facility is never to be recommissioned (andit is the opinion of some scientists that it is ludicrous to evenconsider recommissioning, in light of the internal damage to thefacility that has taken place as the result of the events between
March 28th and April 7th, 1979), then it makes little
sense tospend the scarce resources of the utility on making the facility"white-glove" clean.
It would also change the problem of disposalof resins, with the containment building becoming a possible interior site. Nor does it make sense to generate more resin orother wastes than is absolutely necessary, in light of the tremendous problems of ultimate disposal of those wastes.
The public has the right to detailed information regarding the alternative of decommissioning, even if'that
is not the alternative eventually chosen.
It is a reasonable alternative, if not a politically comfortable one, and legally must be considered.
While there islittleif

As another example, the agency has made no direct, clear-comparison of two major alternatives in the cleanup - between the
proposed quick processing of containment building water and storage of resulting radwastes on the island for an apparently indefinite period, or the alternative of keeping that water in thecontainment building, unprocessed, until it is clear that there
is somewhere other than the island to store the wastes. *Scatteredthroughout the document are bits and pieces of such a comparison.
It is stated that under no circumstances should TMI become a permanent waste storage site, and yet, in the absence of any othersteps, that is exactly what will occuri There is no attempt todirectly balance the vague threats of leakage of containment building water against storage of concentrated waste in storage facilities that are constructed to withstand "design basis" flood, andnot probable-maximum flood; against the fact that the steel containers holding highly radioactive EPICOR-1I resins may be almost-useless as a second barrier to leakage of radioactive material.

A-?L7- 5 (See comments of NRC staff reported in October 6, 1980, issue
of Inside NRC, stating that theresins could degrade to give offgases and corrode the containers.)
These considerations, alongwith the fact that there is significant decay of radioactive
material as the water sits in the containment building (and thus
less radioactivity to handle and dispose of, the longer it isretained), should be pulled together from the document and presented as a clear, reasonable alternative to rushing into further
cleanup.*
In many instances throughout the draft PEIS (because of astated policy in the document and in public meetings), the NRC
staff have stated no preference for a particular alternative.
Staff have indicated that'the PEIS is not meant to be a decisionmaking document, and therefore neither the draft nor the final
PEIS will contain preferences.- While the PEIS need not, in fact
should not, be a decision-making document, CEQ regulations do
require that preferences be clearly stated.
40 CFR 1502.14(e).
As submitted to the public for comment, the draft PEIS does notgive the public any sense of how the cleanup might proceed.
Rather,it consists of a confusing set of ifs, ands and buts, with no clear
direction except to complete the cleanup in the shortest time possible. While it is recognized that the cleanup at TMI will not bea simple task and there are many unanswered questions concerning
the-conditions inside the containment building and reactor vessel,
there appears to be no need to make the cleanup one big question
mark, as the NRC has managed to do.
It is important to note that the NRC ignored its own policyof not stating preferences in those instances where it preferred*Again, important technical information necessary for evaluatingthese alternatives has been omitted from the draft PEIS in violation of the law. The report continues to allude to the terrible
consequences. of not maintaining certain operating-equipment, without adding that a system is being developed for keeping the corein a permanent shutdown mode without the. use of any mechanical components. (see .NRC. Status Report of October:14.r 198-0, p... 3).
Thisreflects the same scare tactics used in the Environmental Assessment for venting krypton-85, which impartial reviewers found badly
overstating the need for immediate entry and the risks of mechanical breakdown.

-7-6We strongly suggest
not to consider a particular alternative.
that the staff include all reasonable alternatives, attempt toplace alternatives in the context of particular scenarios where
possible, and to explicity state staff evaluations of particular-

Susquehanna River prior to and during the accident in March 1979.
Additional releases of tritium may be planned following the cleanup of containment building sump and primary coolant waters.

alternatives.
Finally, the draft PEIS attempts to urge a "quick and dirty"
analysis and "get on with the job" approach in order to reducestress (and just by coincidence to reduce the opportunity for
It is now claimed, as it was during the krypton
critical review).
venting controversy, that the more quickly the cleanup occurs andis completed, the lower the stress levels in the surrounding comSince the cleanup will take several years in any
munity will be.
case, the difference between five years or seven years will makemuch less difference in the levels of stress than a well-planned procedure that takes into account the real fears and concerns of theStress is caused to a significant degree by a lack ofpublic.
Acceleration of the review and decision
trust and understanding.
making processes only increases this lack of trust and fear of3) In evaluating intentional releases of tritium into
air and-water, the draft PEIS ignores the concerns and fears
of the public while exaggerating the consequences of keeping
tritium on-site. Costs of alternative methods of tritium disposal off-site, such as storage for 60 years in steel tank cars,
are not discussed.
None of the release tables contain any information con4)
cerning actinides, this despite the existence of 150,000 curiesof plutonium-241 and unknown quantities of plutonium-239, uranium,
thdrium, polonium and other actinides in the TMI-2 core in which
The adverse human
90 percent of the fuel rods have been broken.
of the crumbled
cleanupduringhealth impact from these actinides
problemofThe entire
core must be accurately assessed.
core disassembly is paid only the barest of attention, a problem of-sufficient magnitude to require a PEIS of its own.

a cover-up.
5) Human health hazards resulting from environmental contamination by the other radionuclides released during the TMI-2
cleanup have been underestimated due to low radioecological transfer factors and conservative estimates of resultant genotoxicity.

II. Sumnmary of Specific Comments
The remainder of this comment to the draft PEIS addresses
Specific
specific failures and inadequacies of the document.
which
reply
our
of
III-VIIIsections
in
contained
comments are
summary:
incomprise the following points

III. Radwastes

radio1) No facility exists at present which will accept
cleanup.
active wastes generated by the various phases of the TMI-2
stoppedhas
PEIS
The Richland, Washington site, mentioned in theThis problem must be solved
taking TMI-2-generated radwastes.
before the cleanup operations generate additional radioactive
wastes which must be stored on Three Mile Island.

Although Nuclear Regulatory Commission regulations, theNational Environmental Policy Act and Council on Environmental
Quality guidelines all require preparation and filing of aprogrammatic Environmental Impact Statement prior to the initiationof any major actions which will significantly affect the qualityof the human environment, the cleanup of the accident at Three
Three forms of radioMile Island, Unit 2, has already begun.

of context.
2) Tritium releases are taken completely out
curies and560
ofreleasesairborne
potential
theto
In additionwater releases of 270 curies from the auxiliary building water,
into thethere previously have been excessive tritium releases

active wastes (radwastes) .have already been generated by thiscleanup operation:

A-2B

- 8 itself, where they now reside.

1) Gaseous; the 43,000 curies of krypton-85
which were released into the environment during two weeks
in June and July,safest site on Three Mile Island at present.
Until alternative
off-site radwaste storage is available, the reactor vessel,
complete with circulating boron-saturated water and steel andconcrete walls represents a safe interim storage site.

1980,2) Liquid; the 475,000 gallons of tritiumcontaminated water inbuildings, and,

-9This location is surely thethe auxiliary and fuel handlingNo further phases of decontamination and disposal of radioactive wastes from Unit 2 of the Three Mile Island nuclear reactor
should take place until the issue of radwaste disposal can be unambiguously resolved.
The programmatic Environmental Impact Statement must address this issue before safety for the environment
from any other aspects of the cleanup operation is addressed.

3) Solid; the contaminated resins generated
by the EPICOR-I filtration of radionuclides other thantritium from the auxiliary and fuel handling buildings'
water.
Additional gaseous,liquid and solid wastes exist and will befurther generated bythe cleanup operation, including sump andprimary coolant waters and any resins and zeolites generated bytheir cleanup, and, most importantly, 100 tons of the reactor
core which resides in a highly disorganized and potentially
irretrievable state. The radwastes generated by the core alone
during cleanup will comprise some of the most highly contaminatedmaterial both in terms of volume and specific radioactivity evergenerated in the history of the nuclear industry.

I•V.

Tritium Releases

Although the PEIS clearly states "The March 28, 1979,
accident and its associated environmental-impacts also are notwithin the scope of this PEIS," this approach is untenable fromthe standpoint of protection of human health, from which standpoint, presumably, the PEIS is being written.
Obviously the
PEIS can do nothing to abate the environmental insults incurred
around Three Mile Island from March 28th until April 7th, 1979.
However, failure to take these releases of radionuclides into
account as a premise for the present PEIS is a failure to recognize the Cumu7ative nature of radionuclide damages to the humanenvironment.

Generation of these volumes of radwastes presumes theexistence of safe radwaste disposal sites.
No such sites exist.
The Hanford Reservation at Richland, Washington, which heretofore
has accepted TMI-2-generated radwastes, has limited the number of
shipments it will accept and may in July, 1981, cease acceptanceof all TMI-2 radwastes.
An immediate problem are the primaryresinscontaining one-half million curies of radioactivity.
Storage of these resins on Three Mile Island has not been cer!tified by.the NRC.
The problem will only be exacerbated when

Genotoxic insults to the human gene pool such as carcinogenic and mutagenic changes in the DNA of human chromosomes are
not removed once they are trapped into replicating (viable) cells.
Hence, sequential genotoxic insults accumulate in the human genepool and a population's risk for cancer and birth defects increases each time it is exposed to further releases of genotoxic

the core, which contains over 35 million curies, is disassembled
and packaged up for radwaste disposal. At the moment, thesafest vestibule for these 35 million curies of radwastes; plus
unknown millions of curies of uraniumm-235,: uranium-22>, pluto-

radionuclides.
This is particularly true of the population residing around Three Mile Island who received the genotoxic insult
from 24 million curies released at the time of the accident,

nium-239 and-other actinides, imay wel-l be the reactor vessel

A-?14

M

Mb~

M_

ý

W7

- I0 43,000 curies from the venting of krypton-85 gas thirteen months
later and are imperiled by further releases of radionuclides during
subsequent phases of the cleanup operation over the next five to- 11 reason is that genotoxic agents attack DNA in direct proportion
to the total number of molecules. If 2,000 carcinogenic and mutagenic events were to be initiated by 200 curies of tritium in thewater supply, it would not matter if these 200 curies were present
during onesingle day or over 500 days, the same 2,000 total irreversible changes in DNA of human cells would take place.
It
has been conclusively proven that there is no lower threshold below
which human carcinogens fail to act (2).
If anything, small, persistent doses of a carcinogen are more damaging than one large dose.
This has been shown by Baserga et al (3) for tritium in experimental induction of cancer in mice using tritiated thymidine.
Moretumors were induced by a 10 microcurie per gram dose given in six
injections spread over eight days than as a single injection.

seven-years.
Specifically with regard to tritium, the population residing
near Three Mile Island had received considerable exposure prior to
the accident on March 28, 1979.
Assuming that Unit 2 released tritium at a rate similar to Unit 1, area residents were receiving atleast annual releases
of 1,434 curies of tritium into their
air and 378 curies of tritium into the Susquehanna River (1).
The latter may be an underestimate since the technician at TMI-2
in charge of tritium-monitoring reported after the accident that
his supervisor often rejected tritium sampling data from the Susquehanna River for three or four days because they were too high.
Only values which fell within the NRC regulations were reported.
On top of this normal tritium release into air and water, an unknown quantity was released into the environment between March
28th and April 7th, 1979.
There were at least 200 curies oftritium in the 265,000 gallons of contaminated water released
into the Susquehanna River on March 30th and 31st, 1979.
When
it is realized that the City of Lancaster water intake 17 miles
downstream from TMI receives 8 million gallons of Susquehanna River
water daily and that the Baltimore water intake, 49 miles downstream, may receive as much as 250 million gallons per day, it obtains that significant populations have received tritium contamination prior to any further planned releases as a result of thecleanup process.

B. Tritiated water genotoxicity
Dobson (4) recently measured the biological effects from
His
protracted exposure to low tritium concentrations in water.
biological endpoint was irreversible loss of female germ cells inboth mice and monkeys.
His conclusion4 "Effects from tritium wereobserved at surprisingly low concentrations where tritium wasfound more damaging than previously thought."
Since Dobson conducted similar experiments with cobalt-60, a gamma-emitter, he
could compare the biological effects of the beta particles emitted
from tritium and the gamma rays from cobalt-60.
At low exposures,comparable to tritium concentrations in the auxiliary and fuelbuilding contaminated water after EPICOR-II processing, the relative biological effectiveness was found to approach three, or
three times the potency of the cobalt-60 gamma rays.
Dobson also
warned of possible special hazards to the fetus of both tritiatedwater and cobalt-60.

A. Planned releases
Clearly NRC regulations and EPA guidelines regarding contamination of drinking water by tritium are designed to protect
the health of the public, since this radioactive isotope of hydrogen is genctoxic.
The. total genotoxic effect of several hundred

Tritiated water (THO) equilibrates with normal water (H2 0),remarkably quickly upon ingestion, beginning within 2 minutes andcomplete by 45 minutes (5).
The biological half-life of THO in
the human body is 11.5 days (5), which, considering the 12.26 year
physical half-life, is enough time for disintegration of 0.2 percent

curies of tritium will be the same whether it is put into theSusquehanna River on one day or over the course of more than one
year, as proposed in one alternative of the PEIS, however.
The

A-?_5

- 12 -

-13skin, lung and liver; ref. 9).
Tritiated thymidine similarly
causes increased cancer frequencies in mice whose mothers weretreated with the radioactive compound while they were in utero,of the ingested tritium atoms in the human body.
Beta particles
released from the tritium atom carry an average energy of 6,'000
electron volts (18 key maximum) and travel an average of 1.5 microns in tissue (8 p maximum).
Although tritium-released beta particles have weak--penetrating power and may be stopped by a piece of wood, thick clothingor layer of skin outside the body, this short track length becomesa deficit for tritium inside the body.
The THO tritium atom freely
exchanges with hydrogen atoms in the hydrogen bond of the DNA double
helix, for example.
Disintegrations here or anywhere within the
nucleus of a human cell releases a beta particle which expends 90
percent of its energy within the nucleus, creating in the process
about 200 ion pairs.
The energy of a beta particle released fromtritium decay within the nucleus of a human cell is so great thatchromosomal breaks are i'nitiated at a frequency of about one perbeta decay (6).
Only 1000 atoms of tritium in a cellular nucleus
are sufficient to provide it with a radiation adsorbed dose of
one millirad per hour (6).
It is estimated that for every visible
chromosomal break engendered by tritium decay, there are approximately 20 unrepaired genetic alterations in DNA.
C. Tritiated thymidine genotoxicity
Specific adverse biological effects of many radionuclides
are enhanced several orders of magnitude if inorganic precursors
are biologically converted to their organic form.
For example,
vitamin B12 containing the cobalt-60 nucleus is 5,700 times as
detrimental radiologically as is an equivalent number of inorganic
cobalt-60 atoms when ingested by the human organism (7).
Similarly,
atom for atom, tritiated thymidine is 1000 times more lethal thantritiated water as tested in human cell cultures (8).
Tritiated
thymidine may be created by all cells, whether microbial or mammalian, when exposed to tritiated water.
Tritiated thymidine is highly carcinogenic in mice.
Asingle dose of I microcurie per. gram induces tumors in half ofthe treated mice (lymphomas and carcinomas of salivary gland,a specific type of teratogenic effect (3) . In addition, tritiated thymidine causes birth defects in offspring of treatedmales (10).
In these experiments it was estimated that the number of DNA mutations was over four times the number of tritium
disintegrations, a fact again attributed to the high release oftritium's beta energy within the nucleus (10).
In summary, tritiated thymidine is 1000 times as genotoxic
as tritiated water and has been shown to induce carcinogenesis,
teratogenesis and mutagenesis in treated mice.
D. Summary of genotoxic effects
If the NRC is to maximally protect the health of persons
residing in and around the area of TMI, then for each radionuclide
which has been released or will be released as a result of thecleanup operation, the NRC must err on the side of caution.
The
draft PEIS does not do this, erring on the contrary far in favorof the licensee.
Specifically with regard to tritium, since tritiated water itself, and even mcreso tritiated thymidine have beenfound to be carcinogenic, teratogenic and mutagenic, it would makesense to keep this radionuclide, to the extent possible, out of
the environment in which it will come into human contact.
Thismeans abstinence from dumping tritiated water into the SusquehannaRiver and abstinence from dumping tritium itself into the air.
Alternatively', retention of tritiated'water in tanks for 60 years
at TMI-2 would reduce its radioactivity by about 95 percent,sparing the population living around the island this much genotoxic insultf especially those who drink Susquehanna River water.
V. Actinide Releases
A. Lack of consideration in PEIS
Although by far they constitute the major health threat
both in terms of radwaste disposal and potential contamination

A-716

-

14 -

of the public during the cleanup operation, actinide or transuranic elements are scarcely mentioned in the PEIS.
In only
one place, Table 10.4-3. TMI-2 Core Inventory, is an actinic
element mentioned, and there only one, plutonium-241, of which
150,000 curies were shown to be present as of June 30, 1980.

events occur within the same cell

(12)..

S-1.5,In rare cases one ofthese genetic events is inherited from a parent (13), but in general both genetic changes are engendered by contact with anenvironmental carcinogen.
Since the human is composed of 20
trillion cells, it is rare that one cell suffers two independent
genetic changes in the same genes of homologous chromosomes, formost carcinogens act during a discreet period of time and thenare eliminated from the body.
Actinide particles, however, remain entrapped within the same group of cells for a lifetime,emitting alpha particles all the while. The probability of agiven cell being hit in homologous cancer genes now increases
dramatically, up to a probability of 1.00 (unity) in the caseof I microgram of plutonium-239 (11),B. Estimated actinide inventory
The TMI-2 core when new consisted of 100 tons of uraniumoxide, which was 97.04 percent uranium-238 and 2.96 percent
uranium-235.
Although the TMI-2 reactor was only functional
for three months before the accident on March 28, 1979, sufficient neutron bombardment of uranium-238 atoms occurred to
produce considerable plutonium-239.
This radioisotope of
plutonium is not only dangerous to health if breathed or consumed, but also in that only eight pounds are sufficient tocreate the nucleus of a nuclear bomb, which is the major reason
that spent- uranium fuels are no longer reprocessed in thisActinides spontaneously disintegrate by alpha decay,
These
alpha particles create tens of thousands of ion pairs for every
micron they traverse in human tissue.
The relative biologicaleffectiveness of the alpha particle from americium-241 (5,5 Mev)
was recently found to be 278 for 100 millirad or less (14).
This
is roughly 278 times as genotoxic as an equivalent number ofgamma rays.

country.
In addition to uranium-238, uranium-235 and plutonium-239,
there should be trace amounts of thorium-230, radium-226, radon222 and polonium-210 in the crumbled core and primary coolant
water.

In addition to several convincing studies of actinideinduced experimental carcinogenesis in test animals, there havebeen numerous epidemiologic studies in humans which demonstrate
higher cancer incidence as a function of low level actinide exposure.
Among the first
epidemiologic studies were those of
uranium miners in Bohemia before the first of the century (15).
Nuclear workers at the Hanford Reservation (16), Portsmouth
Naval Shipyard (17) and Lawrence Livermore Laboratory (18) haveall been shown to have a higher cancer incidence than closely
matched control populations.
Utah school children who lived
downwind from the Yucca Flats nuclear test site developed two
to t1hree times the expected leukemia rate in the following decade

C. Actinide genotoxicity
No substances are known which are more carcinogenic thanA mere microgram of plutonium-239 in the lungs
the actinides.
of a human is a 100 percent carcinogenic dose (11).
What isworse, detection of these alpha-particle emitting compounds is
impossible by whole body scanning, the alpha particles being
unable to pass more than a fraction of a micron through humantissues.

(19).
Three times as many of the cast and crew of The Conqueror
developed cancer as anticipated after spending only a few months
in the same area one.year after il nuclear tests. (20.)... Similar
increases in cancer and birth defects have been seen among soldiers

The reason for acute genotoxicity of actinides can be
Initiaunderstood in the light of modern carcinogenic theory.
tion of carcinogenesis requires that two independent genetic

A-?r.

- 16 --

who witnessed nuclear weapons testing and their families (21).
The actinides and other radionuclides released accidentally atmunitions manufacturing sites or purposefully at nuclear weapons
test sites are of approximately the same spectrum as now contained in the core of the TMI-2 reactor.

-

employed to cut through the tangled network of uranium oxide,zirconium cladding and steel? Will hacksaws be employed? How
many of the potentially required procedures can be mitigated byremote control? If not, what will be the exposure to workers?
How much danger is there of drops, spills and inadvertant crumbling contaminating the environment as large, irregular chunks ofthe core are lifted out of the containment vessel? This section

D. Summary of genotoxic effectsof the PEIS must be written as to address all potential scenarios
encountered in the decontamination of the core, and may requirea separate PEIS in itself.
This decontamination procedure may
unavoidably cause exposures in excess of those standards which
the draft PEIS assumes otherwise will be met.

In addition to the dangers of tritium, whose deliberate
release into the air and Susquehanna River is Proposed , we have focussed on the actinides as the most dangerous
genotoxic radionuclides to be encountered and potentially dispersed into the environment during the TMI-2 cleanup operation.
Unlike most of the radionuclides contaminating the TMI-2 site,
most of the actinides have half-lives in the millions of years,
meaning that they may contaminate the environment for thousandsof generations if released or improperly stored.
This fact

VI.

Other Radionuclide Releases

This comment has emphasized health problems arising fromcoupled with their high carcinogenic potential makes it imperative that a sanctioned high level radioactive disposal site
is available before any part of the containment building cleanup, sump water, primary coolant water and especially the corepotential contamination of the human environment with tritium
and actinides originating from the TMI-2 cleanup operation.
Of the approximately 170 other radionuclides created during
the three months of TMI-2 operation, many, due to their prevalence, genotoxicity or both are also dangerous to humanhealth. Almost 1 million curies of radioactive strontium andhalf a million curies of radioactive cesium remain in the core.
There is sufficient iodine-129 remaining to stillcause neoEven
natal hypothyroidism if released into the environment.
the remaining carbon-14 is more dangerous than realized considering its long half-life and that the EPA estimated that
releases from reprocessing plants in the year 2000 could be
responsible for 12,000 cases of.cancer and birth defects (22).

itself; begins.
The draft PEIS is not reassuring when it comes to describing alternative methodologies for decontamination of that mostcritical source of actinides, the reactor core.
Section 8.2
treats this operation almost as if it were the normal defuelingprocess, moving fuel rod assemblies out through the fuel canalfollowed by "scavenging and vacuuming."
This benign approach
ignores the present condition of the core in which 90 percent'of the fuel rods are broken and in which more than 50 percentof the fuel pellets may have melted and formed an uranium oxide
lattice intermixed with fragmented cladding extending all theway to the bottom of the containment vessel.' Described alternative methodologies are inadequate*for sectioning and removalý ofthis massive bulk, perhaps being a continuous solid weighing upward of 50 tons.
Perhaps none of the fuel rod assemblies canbe withdrawn without sectioning this lattice.

17

Each of the 187 radionuclides created in a nuclear powerreactor has its own series of transfer factors from air or
Each of these radionuclides, if trLnswater releases to man.
ferred to man, has its own 'inherent genotoxic potential asmeasured by its relative biological effectiveness.

Will torches be

A-218

dM

-

VII.

18

-

- 19 -

Summary of Adverse Human Health Effects

Regarding the potential exposure to persons living within

A. Radioecological transfer factors

three miles of a normally operating nuclear power plant, or deriving all of his or her vegetation from within three miles ofa normally operating nuclear power plant, the Heidelberg groupconcluded that a conservative estimate of exposure might be 720
miliirem per annum as contrasted to the absolute minimal fraction

In deciding what the ultimate biological damage to persons
residing near TMI from the Unit 2 cleanup might be, the firstina series of calculations depends upon the radioecological transfer factors involved.
In its draft PEIS., the NRC has utilized
the same transfer factors for transfer of radionuclides from air
and water to soil, soil to plants, plants to animals and plants
and animals to man as they and the AEC before them used for the
past two *decades, this despite sound criticism of these transfer
factor values by the Institute for Energy and the Environment in
Heidelberg, West Germany.
If the NRC as a regulatory body is toact on behalf of public health, then it must take the criticismsof this Heidelberg group seriously, and adjust its calculations
accordingly in order to incorporate the wide range of transfer
factors for each radionuclide dependent upon the type of soil,
plant and animals involved, humidity, type of fertilization employed, biological activity of the soil, chemical form of theradionuclide and biological form of the radionuclide.

of a millirem as calculated by the NRC.

When there exists a wide
range of transfer factors possible considering all the variables
mentioned above, it is prudent to err on the side of caution withrespect for human health.
These same uncertainties in transfer
factor variables exist for the transfer of radionuclides emitted
from TMI-2 during the cleanup operation into the human environment, and a more conservative estimate on the side of human healthshould be central to the final Environmental Impact Statement.
Without considering contamination of the human environment by actinides, the draft PEIS concludes that a maximum of
2.5 millirem exposure will be suffered by any member of the
public offsite.
This maximal figure is already at odds withestimates of the PEIS of exposure from standing three feet awayfrom a truck loaded with TMI-2 radwastes for six minutes, which
would expose an individual to 2.6 millirem (or 26 millirem if
exposure were for an hour).
Worse, the 2.5 millirem exposure

In its recent article entitled "Radiation Exposure to
the Public from Radioactive Emissions of Nuclear Power Stations,"*
the Heidelberg group has shown that transfer factor calculationsof the NRC/AEC may be off by orders of magnitude.
Citing thevariation in biological dosage obtained from vitamin B-12 (co-60)
as compared to inorganic cobalt-60, the Heidelberg group finds
a 5,700-fold difference.
Similarly they point out that transfer
factors for water-borne plutonium-239 are based on the IV oxidation state of the radionuclide, whereas the predominant form inchlorinated drinking water, especially after heating is the VI
oxidation state.
The difference in intestinal absorption is1000-fold, in favor of plutonium-239 (VI).
In this comment wehave pointed out that tritium as tritiated thymidine has 1000
times the biological effectiveness of tritium as tritiated water.
*In

maximum is based on the same minimal transfer factor estimatescriticized by the Heidelberg group as being at least three ordersof magnitude lower than possible maximal transfer factors, thatis, it is no maximum exposure limit at all.
Considering all thevariable soil, plant, chemical and biological conditions possible,
a more likely maximum exposure level to a member of the public
offsite is 2,500 millirem (2.5 rem).
Added to this 2.5 rem maximal exposure to the public estimate must be the risk of exposure to actinides released during
the cleanup of containment building sump and primary coolant waters
and the TMI-2 reactor core itself.
Since the draft PEIS does notprovide data on any of these actinidesi other than plutonium-241,
it is impossible'to accurately estimate maximal exposure levels
to the public from accidental actinide releases into air or water.

that this paper (ref. 7) is unpublished and vital for thecomments presented here,

itisThe badly disintegrated state of the core makes actinide contamination

appended in its entirety.

A-Mf

I

-

of sump and primary coolant waters
Similarly, the fused lattice-state
removal difficult, which may raisenation of the humah environment by
from the core itself.

20 -

-

21 -

The carcinogenic potential of accidental actinide release

veritable certAinties,of the core makes it physicalthe risk of accidental contamiactinide particles released

during the TMI-2 cleanup procedures is difficult to assess due
There are two knowns, however, thatto the number of unknowns.
the core originally contained 100 tons of uranium-238 oxide pellets and as of June 30, 1980, was estimated to contain 150,000
curies of plutonium-241.
Much of the uranium-238 and other actinides must now reside in the sump and primary coolant waters.
Taking the weight of plutonium-239 which is 100 percent carcinogenic, 1 microgram, as a measuring stick, it is calculated that
contamination of the environment by dust containing only
0.000000001 percent of the core could still
initiate 500 cancers.

We shall consider the adverse human health effects fromactinides and other radionuclides separately in the three sections
below in which we describe potential genotoxic effects resulting
from the TMI-2 cleanup.
B. Carcinogenicity

C. Mutagenicity
There is considerable disagreement in the scientific community as to what carcinogenic factor should be assigned radiationlevels under 50 rads.
Extrapolation from high level exposure
values is difficult in that cell killing is imposed upon cell

Utilizing conservative estimates of radionuclide-induced
mutagenicity for non-actinide releases, 500 person-rems as one
birth defect in five generations, it is calculated that the pro-carcinogenicity,

bability of the maximally exposed individual to bear progeny withleading to an underestimate of carcinogenic

dangers in low level exposure.
Similarly it has been found thatfragmented low level doses are more carcinogenic than one cumulative low level dose.
Despite these differences within the scientific community, the NRC has chosen to use one interpretation, thatof the 1972 BEIR report, to assign carcinogenic potential to millirems of exposure.
More conservative estimates, by an order ofmagnitude, exist and would again allow the NRC to err on the sideof caution concerning potential adverse health effects resulting
from the TMI-2 cleanup (23, 24).
These more conservative estimatesof carcinogenic potential translate 1000 person-rems as one cancer.

birth defects is 0.7 percent. Hence, for every 150 persons so
exposed, there would be one birth defect, or, if 30,000 persons
living around TMI were exposed to one-tenth the potential maximal non-actinide radionuclide release, there would be 20 birthdefects.
The mutagenic potential of actinides has not been as wellstudied as their carcinogenic potential, however, if delivered
to-germinal tissues, it is clear that actinides will have considerable mutagenic effect (25, 26).

As calculated above, the maximal offsite exposure from nonactinides may be 2,500 millirem (2.5 rem).
Using the conservative
carcinogenic factor above, the probability of this individual developing cancer over his or her lifetime 0.35 percent, that is, forevery 300 persons so exposed, there would be one cancer.
On theother hand, if 30,000 persons living around TM! were exposed to
one-tenth the potential maximal non-actinide radionuclide release,
there would be ten cancers.

D. Teratogenicity
The developing fetus is exquisitely more sensitive to radionuclide-induced detrimental effects than the adult. Potentiallythis was seen during the nine month period following the TMI accident when neonatal hypothyroid incidence in Lancaster County jumped
to ten-fold the anticipated frequency and infant mortalities doubled
within 10 miles of: the TMI-2 reactor.

A-MJ

-

Some radionuclides,
genic than others.

such as iodine-129,

However,22 -- 23 -are more terato-

any radionuclide which is

Where possible the persons who are responsible for aparticular analysis, including analyses in backgroundwill
Normally the list
papers, shall be identified.
not exceed two pages.

ingestedor inhaled by the pregnant mother, has the potential for crossing
the placenta and entering the fetus, where it can exert teratogenic effects.
In general the developing fetus is

The NRC in its draft PEIS has made no attempt to comply with thisThe final document should be
provision of the CEQ regulations.
in compliance.

10 to 100 times moresensitive to the genotoxicity of ionizing radiation than theadult. Translating this as one teratogenic event per 100 fetusrems, we would assign a probability of 3.5 percent teratogenicity
if a pregnant mother happened to be the individual exposed toIf 3,000
the maximal 2.5 rem exposure from the TMI-2 cleanup.
such pregnant mothers were exposed to one-tenth the potential
maximal non-actinide radionuclide release, there would be ten
infant mortalities or birth defects.

B. Proprietary information

The teratogenic potential of actinides has not been as
well studied as their carcinogenic potential, however, if delivered to a pregnant mother and traversing the placental connection,
it is clear that actinides have considerable teratogenic effect(25, 26).

dize the health and safety of the public.
C. Missing pages

It must be re-emphasized that the major failing of thedraft PEIS with regard to all radionuclides potentially emitted
into the human environment during the TMI-2 cleanup operations
is not to provide the public with sufficient data regarding therange of possible health effects, especially genotoxic effects.
VIII. Miscellaneous

We request that there be no further use of proprietary methods
Itin the cleanup procedures, as suggested in Appendix P, page 2.
is difficult to perceive of the need for proprietary information
when. a method which potential impacts on the human environment is
The fact that EPICOR-I1 is proprietary has hampered the
involved.
progress of critical studies to determine the integrity of the resin
Unless the NRC is willing to take a stronger position.
containers.
on its right to obtain information quickly on such proprietary processes, the use of such processes -during the cleanup could jeopar-

Pages 1-25, bottom, to 1-26, top, A portion of the paragraph was left out. This portion of the draft PEIS makes no sense
as it now stands.
D. Sump water tritium

Conrsnents

Table 10.1-2, page 10-3.
The figures for tritium concentration in the sump water of the containment building are low by
more than three orders of magnitude.

A. Draft PEIS Authors
40 CRF 1502.17 requires that(T)he environmental impact statement shall list
the names, together with their qualifications (expertise,
experience, professional disciplines), of the persons.who
were primarily responsible. for preparing the environmental
impact statement or significant background papers, including
basic components of the statement (1502.6 and 1502.3),

A-M1

E. Storace and transportation of tritium
We request a citation to the DOT regulations that would beviolated my shipment of the tritiated water to some other site for- 24 -

disposal (such as the ocean).

(See draft PEIS,

page 5-13).

-

25 -

We

request an explanation of the fact that the NRC is willing to permit
indefinite storage of radioactive resins on the island, but not11) Gofman, J.W. (1976) The cancer hazard from inhaled plutonium.
Committee for Nuclear Responsibility, San Francisco.

solidified tritiated water.
(See draft PEIS, page 5-13.)
We request an explanation for the position that dumping tritiatedwater in the river is completely safe, but transporting it is not.
(See draft PEIS,-pa'ge 5-13.)
Dilution of the tritium will not
suffice as an explanation - totalharm to the environment and tothe human population will not decrease with dilution.
The harm
is simply spread so that it cannot be as easily detected.

12)Knudson, A.G., Jr. (1977) Genetics and etiology of human cancer, In, Harris, H. and K. Hirschhorn (eds), Advances in Human
Genetl-cs, Vol. 8, pp. 1-66.

13)

Knudson, A.G., Jr. and B. Molholt (eds) (1980) Genetic Predisposition to Cancer in Man.
National Technical Information
Service, SpringField, VA (NCI/ICRDB/OK-80/05).

14)

DuFrain, R.J., L.G. Littlefield, E.E. Joiner and E.L. Frome(1979) Human cytogenetic dosimetry: A dose-response relationship for alpha particle radiation from 2 41 Am.
Health Physics
37, 219-289.

IX.

15)

Lundin, F. (1969) Mortality of uranium miners in relation toradiation exposure, hard-rock mining and cigarette-smoking.
Health Physics 16, 571-578.

References

1) Phillips, J.W. and J. Gruhlke (1977) Summary of radioactivity released in effluents from nuclear power plants from 1973 thru 1976.
Tables 8 and 16 were consulted for TMI-I in 1976.
U.S.E.P.A.,
Office of Radiation Programs, Washington, D.C. 20460.

16) Mancuso, T., A. Stewart and G. Kneale (1977) Radiation exposures
Healthof Hanford workers dying from cancer and other causes.
Physics 33, 369-385.

2) Cairns, T. (1979)(Fall issue)17) Najarian, T. and T. Cotton (1978) Mortality from leukemia andLancet 1, 1018-1020.
cancer in shipyard nuclear workers.

The ED 0 1 study.

J.

Env.

Path. Toxicol.

33) Baserga, R., H. Lisco and W. Kisieleski (1962) Further observations on induction of tumors in mice with radioactive thymidine.
Proc. Soc. Exp. Biol. Med. 110, 687-690.
4) Dobson, R.L. (1979) Proceedings of the International Symposiumof Biological Implications of Radionuclides Released from Nuclear
Industries.
N.T.I.S., Springfield, VA.
UCRL-81756.
5)

Pinson, E.A. and W.H. Langham (1957) Physiology and toxicologyof tritium in man.
J. Appl. Physiol. 10, 108-126.

6) Plaut, W. (1959) Cytogenic damage to chromosomes as a result oftritium labelling in radioautography.
Lab. Invest. 8, 286-291.
7) Franke, B., E. Kruger, B. Steinhilber-Schwab, H. van de Sand and
D. Teufel (1980) Radiation exposure to the public from radioactive
emissions of nuclear power stations.
Unpublished manuscript (seeAppendix).
8) Painter, R.B., R.M. Drew and W.L. Hughes (1958) Inhibition of
HeLa growth by intranuclear tritium.
Science 127, 1244-1245.

18) Dickson, D. (1980) Melanoma increase in radiation labs Nature 287, 475.
Livermore data may be significant.
19) Weiss,
Utah.

E.S. (1965) Leukemia mortality studies in southwestern(unpublished).
R.C.

(1980)

Personal communication.

20)

Pendleton,

21)

Committee on Interstate and Foreign Commerce, Subcommittee onOversight and Investigations (1980) The Forgotten Guinea Pigs.
U.S. Government Printing Office, Wash-fgton, D.C.

22) U.S. Environmental Protection Agency (1975) Draft Environmental
Statement "Environmental radiation protection requirements fornormal operation of activities in the uranium fuel cycle.
U.S.E.P.A., Washington, D.C.
23)

Gofman, J.W. and A.R. Tamplin (1979) Poisoned power: The caseagainst nuclear power plants before and after Three Mile Island.
Rodale Press, Emmaus, PA.
(1980)

Personal communication.

24)

Franke,B.

9) Lisco, H., R. Baserga and W.E. Kisieleski (1961) Induction oftumours in mice with tritiated thymidine.
Nature 192, 571-572.

25)

Edsall,nides.

J.T. (1976) Toxicity of plutonium and some other actiBull. Atomic Scientists 1976, 827-838.

10) Bateman, A.J. and A.C. Chandley- (1962) Mutations induced in themouse with tritiated thymidine.
Nature 193, 705-706.

26)

Sanders, C.L., R.H. Busch, J.E. Ballou et al (eds) (1973)
Radionuclide Carcinogenesis, Atomic Energy Commission SympoTCONF-7 0505).
s'um Ser. No. 7.

X.

ý

0006" 1 N

M

0

-

26 -

2 -

Appendixlides(Cobalt 60,

Strontium 90,

Plutonium 239 etc.)
plants,Iodine 131,

from fodder into animal products,

EMISSIONS OF NUCLEAR POWER STATIONS

ina Scientifically questionable way andsome cases inthat the factors are often locatedthe range of realistic
diation dose is

Critical Analysis of the Official Regulatory Guides

reasonE.Kruger,

Institut

fur Energie-

values.

neglected
und UmweltforschungHeidelberg e.V.*+ Garching/Minchen

at the lower

Thus,
is

A furtherthat the chemical

the foodchains is

Cobalt 60 bound in(e.g.,

end ofthe potential ra-

substantially underestimated.

for current underestimates

form of the radionuclides in

B.Steinhilber-Schwab,

Hvan de Sand, D.Teufel
IFEU -

and from thegastro-intestinal tract into the blood are determined

RADIATION EXPOSURE TO THE PUBLIC FROM RADIOACTIVE

B,Franke,

Caesium 137,

for the transfer from soil intooften

vitamin B 12).

For

conservative estimates of radiation doses,

as recuired

under the radiation protection regulationsof the F.R.G.

mainly for radiation exposurestion of radionuclides indue to longterr. accumula-the environment,

poctential ex-

posures must be taken into account which could be morethan two orders of magn'itude higher than previous estimates.
Abstract

There istherefore no guaranteethat even if

the emission unit of 1 Ci aerosols/yearwith the dose would be within limits.
isCurrent regulations for radiation protection in-

the population dose,iscoupledA further problem

which should also be taken into

volve determining dose limits for the exposure of theconsideration because of its

individual

tive global health risk from emissions of radioactivity.

stations.

to radioactive emissions of nuclear power
Supposing that a known quantity of radioac-

tivityemitted,isexact knowledge of the parameters

1.)

for the abiotic dispersion and the transfer into foodchains including the behaviour of radioactivity in thehuman body is

tries

Introduction

limit the exposure of the individual

to radio-

activity emitted from Nuclear Power Stations.

regulatory guides of

the USA and the Federal Republic of Germany

for the cumula-

The radiation protection standards of many coun-very important.

Comparison of the official

importancevalues,(F.R.G.)

These

which are mainly derived fzom recommendations

for calculating annual human doses with the results
reported in the international literatureshowsof the ICRP,'worst case"for example, limit the exposure for thein the F.R.G. to 30 mrem/year for thethat the recommended factors for essential radionuc-

whole body,while for different organs special values

existmailing address: IFEU,

Im Sand 5, 6900 Heidelberg, West Germany

A-223(SSVO,

1976).

ý

I

-

-3-

Usually,

compliance of the dose ILmits with thedischarge limits of nuclear facilities
radioecologicalreviews,

is

TABLE 1

proved by

4 -Selection of radionuclides
into the air ( ti2emitted by nuclear facilitiesj

8 dwhich try to describe the com-plex behaviour of radionuclides in

the abiotic andbiotic environment mathematically,

A prediction is

nuclidet1/ 2

nuclide

t1/2

P

32

14.3 dSr 89

50.5 dP

33

25.3 d

Sr 90

28.5

a

Cr S1

27.7 dY58.5

d

.Mn 54312.2 dZr 95

64.0 d

Fe 55

2.7 a

Nb 95

35.2 dFe 59

44.6 d

Ru

103

Co 58

70.8 d

Ru

106

368

d

Co 60

5.3 a

Te

127m

109

d

attempted of the maximum possible radiation dose withina period of several decades.

The often stated value of

1 mrem/year radiation dose to the public from radioactive emissions from nuclear power stationsisthe re-sult of calculations and not of measurements.

Even inroutine releases nuclear power reactors emit hundredsofradionuclides of which Table 1 gives a selection.

There we find noble gases,

products ofvated corrosion products,

and othefs.

whichfission,Radionuclides

are discharged into the environment,

great number of transport processes,

acti-

91

undergo a

Ni 63

100

a

Te 129m

where they are

39.4 d33.6 d

Nb 92

10 8

a

Cs 1342.1

amore or less diluted or enriched and can lead by many.

Sn 117m14

d

Cs 13613ddifferent ways to radiation exposure of the indivudualW

18575.1 dCs 13730.1 a(figure 1). One of the most important exposure pathways

U

237

6.8 a

Ba 14012.8 d141

32.5 disby ingestion of contaminated foodstuffs

sols,

which accumulateconsiderinthe soil.

through aero-

Points we have toinclude the atmospheric dispersion,

the beha-

viour of radionuclides and thesystems soil to plant,

plant to animal,

to man.

and foodstuff

been made to calculate potential doses,
tical

(Ng,

1968,

Fletcher,

The main problem liesnot
model but rather inusing mathema-

to illustrate

USNRC 1976,

so much infound innature.

284.8 dCe 144
Nd 147
11doTHER FISSION

131m
133•

d
12
5.3 a

____133

SSK 1977).

1of theThis paper

I

•129
131

1.57.16'a8

IODINE-ISOTOPESL.
-AEOSLparameters.

A-224

PRODUCTS
Pu 239__5;3NOBLE GASES

the problems by examples invol-ving the main radioecological

PRODUCTS

Xe
Xe

the calculation

the enormous variability

different factors which is
attempts

1971,

Ce

0•8 aaKr,85 Kr 8510.8
8.9 d
Xe 129m

Attempts havemodels and standard table values for transfer

factors

ACTIVATED CORROSIONd

24 000a

Pu 2406 600 aAm 241458 a

Cm 242164 d

Cm 24417.8 aAEROSOLS

M M M

M_

0

0

lýý

no

- 5-

2.)

6 -

Radionuclides from Soil into Plant

Transfer of

The transfer factor soil to plant (pCi/kg plant
fresh weight: pCi/kg soil, dry)dioactivity

describing how much ra-

taken up by plants depends on an enormous

number of parameters,for example:- elements- plant species- part of the plant
form of radionuclide- chemical- type of soil
- fertilization- humidity of soil
- temperature-

concentration of stableelements- perhaps

FIGURE 1 :Exposure pathways by effluents of radioactivity

inconcentration of radionuclides- biologicalIisotopes and similar

Soil

in

The reason,

soil

activity of the soil
why for example the transfer factorof nuclear facilities

for caesium varies by four orders of magnitude can be( from:found in

Soldat,1976

these influences(figure 2).

topes Cs 134 and Cs 137 contribute

The Caesium iso-to the radiationindose from ingestion of contaminated foodstuffIn

the transfer factorifor Caesium(pCi/kg plant,

pCi/kg soil,of soil(indry)

percent).

The water content of plant isall,and measurements

142 values of different
for grass-plants by dif-ferent authors have been taken into. account.
parison,

A-225

dry:

are correlated with the clay content

assumed to be 80 %. In
experiments

thefigure 2 values forvacinity of nuclear facilities.

the officially

recommended

For com-transfer factors

0

0

4-4

0

0

44

4.4

4r4

,n
r:

14

44

C"-.-

q4-

ý4
04

0;

0

U,

444

M 4j

0

44o

o

44 o

o

0

04

0

0

0

0o

c!

c!

0

I

I

!

co

44
4.4C

.-I

c!

0

441

04

I

4444

4

,40

4o

o

0
>

U

r4
444

4.

4

ý44

'0

ao

•

0

0

V)

,f)

ý4
o
0
'o
4 0 )4

a)

>

'0
44

4.

o

4.

04

M4

"4

0

'0

4
(.4
W4

u"

0

4.4

0144
$0 -

recommended

values by
U.S.A.

theauthorities'of
1

>

. 04

10%!:1U

10

and(corrected

+

•

for

dry weight)

+
+

+
0

the F;R.i.

4.
+
+

÷

+

1

+

+
+4.

+

I

4.

+
44

+

14.

'a
4

*++ ++

+

+

++

*

+
1"

+

U,
4-4

T

,

I

4.
+4.

+4,
-

0.01

BMI,

1979

+

0.1

44

I

I

i

....

+

4
+4.
+

+

+

,1976

USHRC

+

+-

+

I 14:4-Ior

!

SSK,

1977b

t
0.001.0

0.00

.0

5.00

10.00

15.00

20.00

25.00 30.00

clay content

FIGURE

2:

Transfer factor

plant/soil

against clay content

in

35.00

( pCi/kq dry plant

soil

f%)

40.51

45.00 5010" 55.00 60.00(%)(from:: pCl/kq dry soil) for cesiumFranke,Ratkavan de Sand,

1978)

1

0

-

. M M.

0-

.

.

I

- . . . .

M

.1

M.

0

0

0

9

for Caesium from American and German (F.R.G.) are indicated (plotted). Although the factor can vary by morethan 4 orders of magnitude in most Orevious radioecological reviews, in the recommendations only 1 transfer
factor for all
recommended.

itplant species and soil types has been
is clear*, that with such an instrument

an accurate radioecologicalassessment is

n0

not possible.

Analysis of the recommended transfer -factors soil toplant showed that for most radionuclides the recommended values lie in the lower part of the range of realistic

values.

Intable

2 the variation intransfer factors

afor Caesium and Strontium,of references,derived from a great number
for different plant species is comparedwith the values recommended

in

a

•

= o
fi~

the official handbooks.

00

As may be seen,

the recommended values may in special
cases underestimate the transfer of radionuclides
1Ofold,10Ofold,

or even

1OOOfold.

How have the values in0.

the official handbooks been

derived? An analysis

ofTeufel et al. ,-1979,

for Caesium is shown

the history

of

these

valuesby______________

in figure 3.
The references indicated for the recommended values
and

the

references

cited

in

those

referenceso00

had been-ianalysed. The astonishing result was that the values
recommended by the German Radiation Protection Commis-

1971,

in

which,

ttransfer factor of 0.019,

10fold the value inisgiven.

five references and- the values in'-offor example,

for leaf vegetables/soil the
SSK 1977

4.

pci/kg soil, dry) has been derived from a publi--I
Baker, 1976 Baker dd his values froa handbook by Fletcher,0-sion are derived from a very poor study of references
and that the cited values did not agree with the recommended values. The value of 0.002 (pCi/kg plant
fresh:

0000

I

i

Fletcher cites

thcse references

are

A-297

__

=

I

-

11 -

12 -

-

1 to 2 orders of magnitude higher than the recommended

centrations of stable elements invalues(Franke,by SSK,1977.

The value recommended by the USNRC,

Hbpfner,meat and fodder

Other American han'dbooks,

1978b).

1976 has been derived by a formal division of stablefor examole the collection of data of Baker,

ele-ment concentrations

and Fletcher,handbook)

and soilinplants(reference:

1968.

This method istificgrounds.

(reference:

englishrussian handbook)

in

Ng,

1971,

in

Nevertheless,commissions,previous radioecologicalreviewers,

use these

false values,

values used would be conservative,

as 0.004,

meaning that realItshould be clear,fixing on theoreticalthat infactor for soil for radionuclides inof planned nuclear facilities

isthe transfer

the surrounding

1. If,

1.

results infor Sr 5 : 1, for I 7 : 1, forfor example,

a radiation dose by beef

consumotion of Cs 137 contaminatedshould be measured toto be I mrem/year,

beef isa radiation dose of,4.)

Behaviour of radionuclides

inhuman body(meat)The 3rd important radioecological area

Another problem
incalculated

for example,

25 tremr/year will result.

Transfer of radionuclides from fodder into animal
foodstuffs

for Cs 25 :e.g.

Du 350 :give a proper base for radiological assessments.

3.)

given

experimental observations.

a linear underestimation of ootential radiation dose.
The ratio of conservative to offical values for beef

future instead of

regulatory values,

lying below all

On the contrary,sorts of meat isUsing such an inaccurate transfer factor,

values would only be less than the ones used.

for theinto beef must be taken as 0.075

the recommended value for all

to state that there-authorities,
value

A realistic

literature.

0.02 and a conservative value of 0.1.

and members of radiation protection

1976,

factors based on

the West-Germancommended by the USNRC,
with values

transfer

Table 3 compares the values

experimental results.

more than questionable on scien-transfer of Caesium
administrations

indicateisthe transfer of radionuclides

meat. The transfer isindicated by a factor which

is

the

system foodstuff to man. .The behaviour of radionuclides inhuman body depends among other influences on

gives the daily amount of the radioactivity ingestedby the animal that isfound inpCi/kg meat : pCi/day intake).

1 kg of meat

An analysis of the re-commended values led to the result,or conservative

assessment.

-

the amount of stable isotopes in- the age of thethat for importantradionuclides these values are not suitable
listicthe chemical form of radionuclides(dimension:

the foodstuff

individual- state of healthfor a rea-

- genetical constitution

Our research showed,- composition and amount of foodstuff

that these recommended values also had been derived bya questionable method dividing non-corresponding con-

A-228

I EW
i

or

"1

-

-

01
i

/

.

14

-

((D
0

Because of the various influences the same amountof radioactivity can lead to very different radiation
exposures for individual humans.

Instead of reflecting

this variation the recommended dose conversion factors
0

CD

(D
O:
0

influences

stated above are considered.

,(actually calculated for a "reference man"
implying that all

be "conservative",tion doses are considered.

LL

Instead,

is

it

fac-

often asserted that the recommended dose conversion
tors,

L

Noreof the othervary only between adults and children.

C-the behaviour of zinc,-potential radianot right.

This iswould

As example

and cobalt show.

plutonium,Ra-

dioactive zinc can be emitted by nuclear power reactors
as an activated corrosion product and thus contaminatedconsumed,

As these foodstuffs arefoodstuffs.

foodstuff will be resorbed in~*1.

of humans.
o

on

•

0o .

F.R.G.,

0. io. o

in

it

is

very

zinc inimportant to ask how much of the radioactive

gastro-intestinal

tract

previous recommendations of the US andusing values

from ICRP II,

1959,

it

is assumed

that 10 % of the ingested radioactive zinc will be;(Steinhil-resorbed in

the GI-tract.

A literature review

ber-Schwab,

Teufel,shows that the mean resorption

1978)

rate for zinc actuallylies

at about 50 % with extreme

values higher than 90 % (figure 4).

~

i0

00

~

0
(0

The differences are even more obvious in(0I<

the caseof the radiotoxic element plutonium.

0

mendations the assumed resorption rate for plutonium

0

means,

from the GI-tract into blood iSInprevious recom-

(0

0.001

to 0.003%. Thatthat only from 1 of million parts up to 3 of0

100 000 parts of the ingested plutonium by foodstuffnwill be resorbed.

00

Our literature

analyses showed,

that

the resorption rate of plutonium depends very much on

C'

0

its

(0

chemicalform inthe environment.

The officially

recommended resorption rates are only valid for poorly

-

EL -

A--n

16 -

-

Z

Z

ý5

C

C

C

C

C

-

C

C

soluble plutonium,

however,

for example,

as Pu-nitrate

or Pu-citrate or as Pu VI,

plutonium isresorbed at arate,

3 to 4 orders of magnitude higher than PuO 2(figure 5).

The potential hazard lies inmechanisms that will complex

05

nuclear facilities
is0

known for other heavy metals,

e.g.,emitted by

Similar behaviour
lead.

Anothers the changing oxidation state of plutonium
under varying chemical conditions. Larson and Oldham
7(1978)

ttA

found that plutonium which inIV can be changedCS0water.

aa

Pu VI isWAnoxidation state

into Pu VI by chlorinated drinking

resorbed inbetter than Pu IV.
.

human GI-tractin

preparation of food,rate for plutonium is771

dose to man.

tea or coffee.

for instance,
The resorption

related linearly to the radiation

Therefore,it

can happen,

tion dose from plutonium in'C-4

lOOfold

Highest amounts of Pu VI were formed

when drinking water had been heaten up,

0CS

the environment.

ploblem0S

inthe biologicalPuO 2 which isthat the radia-

drinking water or fromplutonium taken up by plants can be up to IOOfoldhigherthan calculated by official

A third example isradioactive

emitted by nuclear power stations
corrosion product,
naturally inrecommendations.
cobalt which is
as an activatedsimilar to zinc.

soil and inplants in

Cobalt is

found

inorganic

form.

When taken up in

this form by man,transfer rates indifferent organs as well as the

biological halflife in
small

(ICRP

1959).

resorption andthe organism is

Cobalt is,however,

relatively
an essential

constituent of a biologically very important compound:vitamin B 12.
of cobalt is
formrs:Inthis caseas vitamin B 12 isganism and cannot be

-

SL

-

A-230

the physiological behaviour

completely different

from theinorganic

essential for the human or-synthesized by the human body,

I

I

- at

'2
I

•

I

-o

Pu IV n::ratc(young rats)

S
Ce
0

18 -

-

Pu IV nitrate

resorbed from food to a very high degree.

it is

min B 12 has a very long biological halflife

Pu VI citrate*0

750 days)in00

halflife

of inorganic cobalt,

Pu IV citrateliver,

be 9.5 days.

0
Pu V!

Pu IV citrate

0

-

0
C

Pu with DPTA

the form of vitamin B 12

Although inof the cobalt isaassumed by ICRP II

to

is

up to

5 700 times higher than the radiation dose frorn inorganic cobalt.

00which compares to the biologicalThe effective radiation dose from radio-

active cobalt in

*0
0

Vita-

(uo
to

many foodchains a proportion

built into vitamin B 12

5 % and inmilk 23 %),sidered inprevious

land et a!.,1979).

(e.g.

in

beef

this problem has not been conradioecologicalassessments(Bru-

Pu citraten

The degree of underestimation of the radiationdose from Co 58 andwith DTPA and Pu citrate

'9
Ce

n

Pu in

[

plantE

7 =t

0
Pu III nitrate teýýJjtable 4,ingiven.

In

previous estimates the radiation dose

cobalt60 contaminated milk is

Pu IV nitrate

which the variation of potential values isfromunderestimated by a

Because of the great uncertainties involved inID
0.

Pu IV nitrate,

making calculation models for radiation doses, it seems
to be important to verify the model calculation by

PH=1

direct measurements.

Hoffman et al. (1978) investigatedthe variation of the input-parameters for calculating

5
Pu VI nitrate(athe thyroid dose by I 131

ID
0

0Pu

(grass-cow-milk-child-path_way),

IV citrate0*0*

Although this pathway islb

95% Pu IV,

Cengated ones,•5% Pu vt

0*tion of I

lb

0

-

C
C-

C

C

I
all forms of Pu

0

A-231

one of the best investi-

the calculated dose

131

in

air

(in

range of 1800 to 50 000,

96% Pu !V, 4% Pu V'~0

for the exposure pathways

factor of 280 to 2300.

0
~0
ID
Ce

ID

Co 60

involving beef and milk consumption can be seen frommrem/afor a given concentra. PC!/cm ) varies ina factor of 28.

the

-

19 -

-

TABLE

4:

coMPARISON OF RADIATION DOSES TO LIVER BY 58Co AND

60

variation of inputAssuming the statisticalvalues to be logarithmic, the use of parameters, recommended by USNRC will lead in 30'%of the cases to anunderestimation of potential radiation doses by I 131.

Co

AFTER CONSUMPTION OF CONTAMINATED ANIMAL FOODSTUFFS WITH ANDWITHOUT CONSIDERATION OF THE TRANSFER INTO VITAMIN B12(RELATIVE UNITS,(from:

Parallel measurements by USNRC of I 131 emissions
from nuclear power stations and I 131 concentrations inmilk led to the result, that in 28 situations at 5 reactor sites milk concentrations have been underestimated
8 times. Four of the 20 overestimates were greater than
2 orders of magnitude(Hoffman.et al. 1978). A considerable source of uncertainty can be referred to meteorological models.

ROUNDED)

Bruland,exposure pathway

Franke and Teufel,
inorg. Co
[11

1979)

58

Co considering vit. B1260

Co considering vit. B12

consumption ofbeef

1

5.4 - 77

22 - 480

1

67 - 370

280 - 2300

20 -consumption of
milk

5.)

Radiation dose to individuals

Since the various parameters for radiation dose
calculation for critical individuals are so uncertain,a conservative assessment of the potential radiationdose seems to be necessary. Compared to previous estimates, a radiation dose lying several orders of magnitude higher than previous estimates seems to be possible.
A radioecological assessment for the Wyhl nuclear power
plant from the"Tutorium Umweltschutz an der Universitdt
Heidelberg" (department for environmental protection at
the University of Heidelberg) led to the results inTable 5, assuming for the area of maximum concentration
annual discharge limits for airborn effluents of- 80 000 Ci noble gases
I Ci aerosols (halflife greater 8 days)
0.3 Ci iodine 131.
The calculated whole body dose of

720 mrem.is e.g. 24

times the whole body dose limi.t in F.R.G.

A-M2)

M

ýI

. .

I

.-

MrW

N

. N

. M

M

A

MW

-ý

"- 21 - 22 TABLE

Radiation doses to individuals at area of maximum

5

concentrationby emissions of radioactivity by theIt

Wyhl nuclear power plant into the atmosphere(from:

Tutorium,can be concluded,

1978

for radiation dose isuncertainties in
exposure pathway

radiation doses inmrem/a to:bone

thyroidwhole bodythe assessments,

ments of transfer-factors

have to be und3ertaken.
used in

31

31

31

parameters,

ground contamination

15

is

15

for conservative estimates.

leaf vegetables

11

323

6.5

root vegetables

40

1 700

beef consumption
milk consumption

350

900

380

160

840

210

wine

110

940

96

sum

720

4 700

740

limit

(F.R.G.)30, meat/fodder,6.)

1978;,

previous estimates,

SAIU,

are not suitable

the research

1978; Handge et al.,

1978.

The oroblem of collective doses
For theassessment of health risk from emissions
the collective

by nuclear facilities,

90

milk/

The radioecological

Similar results have been obtained inby KrUger,

0.4

180

site-specific measure-plant/soil

fodder etc.

limitsTo minimize the

not guaranteed.

noble gases

dosethat by conservative assess-ments compliance of discharoe limits with theas (when not more)dose seems to beimportant as the dose to individuals.

The rise of emission height of a facility

(e.g.

200 m

instead of 100 m) will lead to a dilution of radioactivity
TABLE 6 :Ratio of global( man-rem ),collective dose

integrated over 500 years and 00
dose caused by firstthe same,to collective

the vicinity cf the plant and so to lower
nevertheless.

man-rem)with time,

1978)

will beFigure 6 shows how much therelative importance of various nuclides

exposure after emission

calculated from values of Hesel et al.,invalues but the collective dose (infor the collective dose

will change

from a single

emssion of various radionuclides from a reprocessing
plant.
nuclideorgan

ratio global collective dose/dose
exposureat first

f500 years
H3

whole body

0.05 :

1

Considering only theradiation exposure after emission,
0.05:

globally,1

C 14

whole body

23 :

190
1

Kr 85

skin

18 :

1

18

:

1

0.013:

1

100

:

1

thyroidthe relative importance of C 14 and I 129

changes considerably.

I

: 1

129
.

Integrating the collective dose over a longtime period,

the collective dose ineven ifman-rem caused by thisemission can be underestimated considerably,
derestimating
whole.

thus un-the health risk for the population as aConsidering,for example,

only the firsttion exposure from Kr 85 emission,

A-233

first

integrated

radia-

the radiation doseII- 23 24 --to the skin will thus be underestimatedportance

by a factorof orimarily im-of 18. The collective dose which isfor the potential health risk(cases of cancer

a.s.o.) merits serious attention and should be reviewed
worldwide in7.)

the interest of future cenerations.

Conclusions
The following conclusions can be drawn:

1.)

Recommendation

and use of radioecologicalfor calculating

the behaviour of radionuclides

the environment should be limited.
tors,

for example,

ininFixing of fac-

regulatory guides can leadto the neglect of the complexity existinc:t isfactorsinnature.

incorrect to represent the complexity andvariation of nature by choosing
are found inradioecologicalsuch factors as

regulatory guides.

An analysis of these guides shows on the contrary,
FIGURE 6

Collective doses by one-year emission of H 3,
Kr 85 and I 129 inworld populationthat the assessment

C 14,

dependence of integration time
110 10I) (from: HESEL et al.,of many of the most importantradioecological parametersof .agnitude1978)

calculated

wb=whcle bodyis

too optimistic.

up to several orders
Thus,

radiation doses

from these regulatory guides will be

underestimated considerably.
2.)

Major attention should be given to site-soecificmeasurements of parameters for the transfer ofradionuclides
ments,

3.)

e.g.

in

the different ecological compart-transfer

Similar researchisfactors plant/soil
necessary inetc.

the field of phy-siological behaviour of most radionuclides,

par-

m-

-

-

Bachner,

The longterm behaviour of radionuclides, e.g.
Pu 239, which can be more easily taken up by
plants owing to complexing in soil, should also

5.)

Baker,und Mtller,

W.,

und

durch Inhalation oder ingdsticn

von Aktiniden",

GRS-i,

et al.,

August 1979

"Food - an Interactive

Interns

Ccde to Cal-

1 Radiation Dosis from Contamnina-

ted Food Product,

but also the collective radiation"Strahlenexposition

Strahlenrisikoclate

To evaluate the potential health risk for theworld population by radioactive emissions from
nuclear facilities,
not only the individual ra-

BNWL-SA-5523,

February,9T6

Ballou,J.E. und Thompson, R.C., "Metabolism of Zinc 65
in the Rat", Health Physics 6 (1961),
6-18

Ballou,J.E.

et al.,

Influence cf"The

DTPA on the'Bio-logical Availability of Transuranics",

dose should be reviewed.

Baxter,D.W.

und Sullivan,

M.S.,

sorption and 'etention

Important parts of this work could be realized by financial
support of the ministry of economics and technclogy of thestate of Hessen, F.R.G. Further aknowledgemezts are given to

Physics 22
Bowen,

H.J.M.,

named."

Dymond,Series B,
Bruland,

W.,(1972),

144

Franke,"Gastro-Intestinal Abof Pu-Chelates",

Health785-786

J.A.,(1955),

B.,

Health1445-450(1978),

Physics 34"Aknowledaement

many people who are not personally

D.

D.E.

investigated.

diation dose,

26 -References:

Attention should also be given to nuclides notconsidered previously, e.g., Tc 99, Fe 55 etc.

be

W

0

25 -

ticularly for risk groups in population (the oldand insane, the embryo etc.).
4.)

M

Proc.Royal Soc.

London,355-368

Teufel,D.,"Transfer of organicallybound radionuclides through food chainsmodel-wexample
Internationalof Radionuclides
stries,Released from the Nuclear Indu-

IAZA-SM-237/17,

Bundesregierunq,

Bericht

Burch,

R.E.

1977",

et al.,

Mancanese,
Chem.

A-25

21

Vienna,an den"UmweltradioaktivittJahre

to man:with radiocobalt and vitamin BlI",
Symposium of Biological Implications
26.-30.1.1979

Deutschen Bundestag iiber

und Strahlenbelastung

Drucksache 8/3119,

im

20.8.1979"Newer Aspects of the Roles of Zinc,

and Copper in Human Nutriticn",(4),(1975),

501-520

Cln.

I

27 -

-

Bryant,Durbin,F.J.

et al.,

AuStralian Journal of Science,(10)397-409(1962)P.W.,"Plutonium innium Chemistry,

Fletcher,

J.F.,

Mammals.

Influence of Pluto-

Route of Administration

12.

Distribu-

schutz,Hesel,

W.L.,

Hermes Digital Computer Code
f-rom

pfad',

USAEC-

Norderney,report, 1971
B., Hbpfner, U.,

Steinhilber-Schwab,H.,

Teufel,

R.,
D.,

NEZ",

des Niedersachsischen Ministersf',r Soziales,delberg,B.;

U. (verantw.),Honstead,

Energie-und UmweltforschungRatka,

R.

v.de Sand,

H.

in(verantw.),tieICRP -zur Modell!Ur

Heidelberg e.V.,

Pflanzen",

okologie Biblis,

KrUger,"Zur Ab-im Auftrag des hess.
IFEU -

Institutund Umweltforschung Heidelberg

e.V.,

Fredriksson,

L.,

Erilsson,A.,

137 insition4n the plowlayer of Cil,

fir
Larsen,Oktober 1978

Sr 90 and Ci

Shor,

E.M.,
in

Radio-

D.N.,"The Uptake and Retention of

1975

.

"Gutachten Uber die Strahlenbelastung

E.H.,

Tail A,

fur Energie-

in

der

der Umgebung des Kernkraftwerkes

R.B.,

Nr.

6,

Universitht Bremen
R.D.,

Oldham,"Plutonium in(Hrsg.),

1978

Drinking-Water:

Effects of Chlorination on iti Maximum Permissible
1008-1009
Concentration", Science 201 (1978),swedish crops and milk at a total.depo-

FDA 4 rapport C 4354-28,

Rupp,

Grundremmingen durch Kontaminierung von Nahrungsmitteln", Informationen zu Energie und Umwelt,"Expected content of Sr 90

and Csper km 2",

Ministers

C.A.,

Little,

C.F.,

D.E.,

International Commission on Radiological Protection,- Publication 2, Pergamon Press, Oxford 1959

Bev6lkerung

Beitrag zur Modellstudie Radio-

Wirtschaft und Technik.

Brady,J.F.,- Publication 23,

Okt.1978schatzung des Transfers von Raionukliden aus dem
Baden inBaes,

P 32 and Zn 65 from the Consumption of Columbia(1967, 455-463
River Fish", Health Physics 13,"Zur Abschatzung desrische Nahrungsmittel (Fleisch)", Beitrag-studie Radiobkologie Biblis, IFEU - Institut

B.,

Hei-

31.3.1979

Hbpfner,D.L.,

Dunning Jr.,

C.W.,

ecological Models", Vortrag 12. Jahrestagung Fachverband fUr Strahlenschutz, Norderney, 1978

im Auftrag

Transfers von Radionukliden aus dem Futter

1979"An Evaluation of uncertainties

R.W.,

des geplanten Nuklearen

Entsorgungszentrums bei Gorleben

Jahrestag Fachverband Strahlenschutz,

Schaeffer,

F.O.,

Miller,

Unter-"Regionalwirtschaftlicheund.Okologische Auswirkungen12.

= Fletcher

Hoffmann,"Zur Verwendung von Fall-

fur radiodkologische Messungen",suchungen zu dem Gutachten

HermesB.,

fUr Strahlen-

Bonka, H., Grdndler, D., Schmidtlein, P.,"Strahlenexposition durch radioaktive Emissionen aus
kerntechnischen Anlagen Uber den Abluft und Abwasser-

Effects

Ratka,

Fachverband

1978

D.,

HEDL-TME-71-168,v.de Sand,

Franke,29

Jahrestagung

Norderney,

the Nuclear Power Industry,out-MessungenFranke,radioaktiver Stoffe aus kerntbchnischen

Anlagen",Health Physics

for Estimating Regional RadiologicalFranke,Ableitungand Physic-

495-510

Dotson,"Ermittlung potentieller StrahlenNahrungsketten durchG.,

Meurin,P.,

expositionen uber terrestrischetion and Long-Term Metabolism",(1975),

24
Handge,logical Status of the Animal on Initial
(4)

28 -

-

Lombeck,

1, Cs 127i.

et al.,"Resorption of Zinc inEnteropathica",

Stockholm 1968

A-236

The Lancet(1975)

Acrodermatitis
855

W_

-

29 Teufel,D.,

Steinhilber-Schwab,

v.de Sand,
Neel,

J.W.

et al.,"Soil-plant interrelationships

A.A.,

E.M.

University

Tamura,et al.,

Cs 137,"Environmental mobility of(1970),

10"Plant uptake of Sr 90,

Gcrlegen

35-45

I 91,

Ru

et al.,

23(3)(1975),(1965),

Zum Tin-

Untersuchunc

Blattgemise,Kar-zu dem Gutachten

fur Soziales,

Heidelberg,

15.2.1979

Zinc 65"Radiodkologisches

Gutachten zum Kernkraftwerk

wvhl",

1. Aufl.

Heidelberg,

Mai 1978,

2.

Aufl.

United Nations Scientific Commitee on the Effects
Radiation,tion","Zinc 65 Metabolism During Low andUniversitat

Journal of Nutrition

Report,Bremen,und Umwelt,

Strahlenschutzkommission
USNRC,

fir die Be-

Juliof Atomic

New York 1977

"Radiodkologische Ab%ýassaerqutachten
Teil A,

Nr.

4,

information zu Energie

Bremen,Juli

Regulatory Guide 1.109,"Calculation

1978

of Annual Doses

stimmung der Strahlenexposition durch Emission

to Man from Routine Releases of Reactor Effluence

radioaktiver

for the Purpose of Evaluation Compliance with

Stoffe mit der Abluft,

der Strahlenschutzkommission

Empfehlung

50," Appendix I,

1977b- Allgemeine Berechnungsgrundlagen fir die Bestimmung der Strahlenexposition durch radioaktive
Einleitungen in

Oberfl~chengewisser,

der Strahlenschutzkommission,
Strahlenschutzverordnung,

Steinhilber-Schwab,
schatzungB.,

Teufel,

1

9 77

D.

(verantw.),ins Blut",berg e.V.,

Oktober

et al.,

10 Cfr1977"Further Studies

on the Gastro-Intesti-

nal-Resorption of Plutonium",

Radiation Research j,339-347.

a
Soldat,J.K.,-Radiation doses from Iodine-129 in

Health Physics

the environment"

30(1976),61-70"Zur Ab-

Beitrag

aus

BMI

dem

Allgemeine Berechnungsgrund-leitungen mit der Abluft oderim Auftrag desund Umweltforschung,(Bundesminister des innern),lagen fur die Strahlenexposition bei

zur Mo-Ministers fUr Wirtschaft und.Technik, .IFEU
ftr Energie-

M.H.

(1956),

13.10.1976

dellstudie Radiodkologie Biblis,

Institut

Empfehlung

der Resorption von Radionukliden

Gastro-Intestinal-Traht
hess.

Janur

Weeks,

1978"Sources and Effects of Ionizing.Radia-

zum Atomkraftwerk Esensham,':169-177- Allgemeine Berechnungsgrundlagenbei

im Auftrag des Niedersachsischen

Tutorium Umweltschutz an der Universitit Heidelberg,

255 A

man",

NEZ",

Ministers

106,

Soil Science 8_3"Absorption and Retention ofHigh Calcium- Intake in

SSVO,

Zwischenbericht:

Parameter auf den Transfer vom

T.,

Radiation Botany

Patience with Taste and Smell Dysfunction",Res.

und Klee",R.,"Regionalwirtschaftliche und OkclogIsche Auswirkun-

369-37686

tcffeln

Ratka,

gen des geplanten nuklearen Entsorgungszentrwun

and Ce 144 from Soils",H.

Ce 144,

Los Angeles,U.,

UCLA-247(1957),

W. et al.,Ru 106,of California,

Cs 137,

Clin.

SSK,

Pflanzen,

Hbpfner,"Transfer von Radionukli-

Ctsium und Strontium vom Boden inin

Spencer,den vom Boden in

B.,
B.,

I. The uptake of Sr 90,

cesium 137",

Ru.mple,Franke,fluS verschiedener

March 9, 1953,

Romney,withH.,

respect to the uptake of fission products.
and 7 91",

Rogowski,

30 -

in

radioaktiven

Gemeinsames Ministerialblatt30,Nr.21,-

Heidel-Ab-

Oberflchengewzsser,
15.8.1979

Ng,Y.Z.,Burton,C.A.,Thompson,S.E.,Tandv,R.K.,Kretner,M.K.,
Pratt,M.W., "Prediction of the maximum dosage to man

1978

from the fallout of nuclear devices
estimating the maximum

released to the biosphere",

A-237

1V.Hanrdbook

forinternal dose from ra•,ionucl.ides
UC.R-5061,.Part

1Z9,.8

Sf41.

£'

1~

T~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON. D,C 20460(5) the estimated costs of the clean up actions; and(6)
the psychological impacts of each alternative.

NOV 2 0 1980

EPA believes that the FPEIS should be organized in such afashion that all information pertaining to an alternative becontained in one section.
The FPEIS should be written inplain language so that the public can readily understand it.

OFFICE OF
THE ADMINISTRATOR

Dr. Bernard J. Snyder, Progam Director
Three Mile Island Program Office
U. S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear.Dr.

EPA recommends that the NRC issue a supplement to the DPEIS
which satisfies the concerns which we have regarding theinadequacies in the DPEIS.
EPA also recommends that NRC
issue supplements to the FPEIS as additional data andinformation become available during the clean up operations.

Snyder:In accordance with Section 309 of the Clean Air Act, as
amended, the U.S. Environmental Protection Agency (EPA) has
reviewed the Draft Programmatic Environmental Impact Statement(DPEIS) Related to Decontamination and Disposal of Radioactive
Wastes Resulting from the March 28, 1979 Accident at Three
Mile Island Nuclear Station, Unit 2 (NUREG 0683).

Should you or your staff have any questions about our comments,
please call: Mr. Jeremiah Manley (NEPA Matters, 755-0770) of
my staff; Mr. Terrance McLaughlin (Technical Matters, 5577604) of EPA's Office of Radiation Programs; or Mr. Matthew
Bills, Senior EPA Coordinator for TMI, (Monitoring Matters,
426-4452) of EPA's Office of Research and Development.

EPA has been involved in monitoring the impacts of this
accident on the environment since March 30, 1979, so we arein a unique position to recognize the unusual nature of thisWe commend the Nuclear Regulatory Commission's
action.
determination to protect public health and the environment.
during the decontamination of Three Mile Island, Unit 2(TMI-2) and the permanent disposal of the resulting radioactive
wastes.

Sincerely yourWilliam N. Nedeman, Jr.
Director
Office of Environmental Review

EPA's detailed comments are attached; our major concerns are
We hope they assist the Nuclear Regulatory
described below.
Commission (NRC) in the selection of alternatives in authorizing and licensing utility actions during clean up and disposal.
The final programmatic EIS (or a supplement to the DPEIS)
should provide more information on:

Attachment(1) the amount, nature, and disposition of radioactive
wastes from the TMI-2 decontamination;
the health effects associated with various levels(2)of exposure (public and occupational);(3)

the effects of possible transportation accidents;(4) the cumulative effects on the public of all
exposures suffered as 5 a result of the accident (this would
include the krypton-8 venting);..
.

A-238

- 2 -U. S.

ENVIRONMENTAL PROTECTION AGENCY (EPA)

6.
The FPEIS should eliminate the inconsistencies in waste
and tritiated water inventories as well as clarify theoccupational exposures should tritiated water be used in
Ventilation failure accidents could leaddecontamination.
to significant exposures.

DETAILED COMMENTS
ON THEENVIRONMENTAL IMPACT STATEMENT (DPEIS)RELATED TO
DECONTAMINATION AND DISPOSAL OF RADIOACTIVE WASTESDRAFT PROGRAMMATIC

7.
The DPEIS includes the alternative of releasing liquids
Two alternatives for liquid
into the Susquehanna River.
disposal are permanent storage on site or evaporation.
These liquids represent what is left after the 480,000
gallons of radioactive water has passed through a treatment
phase which is likely to be an ion-exchange (EPICOR II).
The resulting water would then be mixed with uncontaminatedwater so that it satisfies EPA's interim drinking water
standards (40 CFR 41) at the plant discharge.

RESULTING FROM THE
MARCH 28, 1979, ACCIDENT AT
THREE MILE ISLAND NUCLEAR STATION, UNIT 2(DOCKET NO. 59-320, NUREG - 0683)
1.

The FPEIS, or the supplement to the DPEIS,

shouldclearly identify the type and amount of radioactive wastes
This should include the high specificas an inventory.

activity wastes, damaged fuel elements, decontaminationlfquids, and those of processed water anticipated during
It should also include those amounts that arecleanup.
estimated to have been inadvertently vented during theaccident and intentionally vented during the bulk krypton-85
and weekly/monthly ventings.

The plan to meet the drinking water standards calls for
mixing the radioactive liquid and dilution water at the
It would takerespective rates of 0.8 gpm and 36,000 gpm.
To
416 days to discharge all this water to the river.
demonstrate that this procedure would work consider the datatabulated below:

2.
The FPEIS or Supplement should detail the options
available now and the best available estimates of options
available in the future (i.e., the reasonable expectation oftime to be considered for clean up operations) for theultimate disposal of the radioactive wastes from thedecontamination.

Isotope3.
The FPEIS should clarify the statements made on thesubject of transportation of radioactive liquids and should
rigorously explore and evaluate all reasonable alternatives.

Input
Concentration(pCi/)

9

Cs-137
Cs-134

The FPEIS should address the technical feasibility of4.
the off-site deep well injection as well as that of ocean
disposal. We recognize that legislative, administrative,
and other obstacles may currently prevent the use of some
But we urge the NRC to address all technicallyalternatives.
This
possible alternatives and their costs in the FPEIS.
would then allow the recommendation of changes in legislation
and/or regulation to allow the selection of a technicallysuperior alternative for waste disposal.

Sr-90
Sr-89

8.4x109
1. 4x10 8

1.4x10 7
3. 2x10OutputConcentration*(pCi/l)Concentration
when mixed
with Dilution
Water(pCi/l)Concentrationthat Givesa dose of
4 mrem/yr
to a
CriticalOrgan(pCi/l)58.4xi0 5
1.4x10 4
1.4x10 3
3. 2x10

18
3.3
0.33
0.07

200
80
8
80

As can be seen from this analysis the concentration using
the evaporation/resin process is at least an order ofHowever, amagnitude below the drinking water standards.
The mixing ratio of 0.8/36,000
number of questions arise.
The FPEIS should indicate how this is
is a very large one.
to be achieved, whether it is possible to get reasonably
complete and uniform mixing with this big a difference, andis range of the potential variations in concentration.

5.
The FPEIS, regardless of preferred alternative for
disposal of low specific activity processed water, should
provide an assessment similar to that done for the krypton85 venting.
It would be beneficial in showing not only theworst case impacts but also the best controlled conditions
for minimizing radiological exposure, psychological stress,
and other impacts.

I*Effluent from processing decontamination liquids by theevaporation/resin process.

A-259

I

4 -

-3The fate and transport characteristics of the liquid waste
will depend on the properties of the radioactivity contained.
The isotopes listed above are the main contaminants;
however, others are present and comprise a wide variety ofchemical elements.
The different chemical elements would
behave in different ways.
For example, if the radioactivity
was in ionic or particulate form, what would determine where
it would go? If the radioactivity were part of the particulate
fraction, it might sink to the river bottom and become partof the sediments.
This would not be a permanent sink andcould, for example, be stirred up in a dredging operation.
Has the possible problem of a buildup of radioactive sediments
been investigated?

(f)

As soon as the samplers are built and analysis
arranged (approximately Dec. 1980) tritium in air
samples will be taken at the same stations as
the Kr samples.

(g)

EPA also collects and analyzes water samples asfollows: (EPA does gamma spectroscopy, DER analyzes
for tritium, gross alpha and gross beta; weekly
composites are analyzed for Strontium 89 and 90 at
the Eastern Environmental Radiation Facility, EPA,
Montgomery, Ala.)(1) TMI Outfall (All plant discharge, both units) daily,

In some cases, chemicals are more toxic to aquatic life thanto humans.
Is the radioactivity in this case more toxic tohumans or aquatic life? Fish and other aquatic life are
known to bioconcentrate metals and other toxic substances.
What are the biocentration rates for these radioisotopes
being ingested by aquatic life indigenous to the SusquehannaRiver? What is the resulting human exposure from eatingsuch fish?
8.

The FPEIS should correct the statements made in the

Section 11.3
(a)Effective 12/31/80,
to 5 miles.

(b)

Analyses are done at EPA's TMI Field Station,
Middletown.
The Harrisburg setup was phased
out in June 1980.-(c)

Sample and analysis frequency is now once per
week for the charcoal filters and 3 times per week
for the particulate prefilters.
Both will bechanged to once per week as soon as telemeteredgamma monitors are installed.

(d)

The TLD dosimeter layout was changed thefirstweek in October, 1980 to that given in
Appendix D to EPA's Long Term Monitoring Plan,
revision 2, to be provided to NRC shortly.

(e)

Weekly continuous compressed gas samples aretaken for Kr-84 analysis at Bainbridge, Goldsboro,
Middletown, Hill Island, and the TMI Observation
Center.
The Hill Island Station was pulled
October 3, 1980 because of pending shut down of
The Kr sampler
the marina where the boat is kept.
at Bainbridge will be moved to Yorkhaven Jan 1,
1980 when the Bainbridge station is shut down.

Lancaster Water Works intake - daily,(3)

City Island weekly, and(4)

Sediment pond, TMI (run off water) behind
Unit 2 cooling tower.

(upstream river water)-

There is a continuous gamma monitor on the 001 TMI
outfall with a high-level alarm that automaticallyalerts EPA and DER to the presence of gamma
activity in the water in excess of 1,000 pCi/l
137Cs (1/20 of permissible level).

DPEIS concerning EPA's activities in the following sections:I.

(2)

EPA will have 13 stations out(h)

EPA Press releases are now on a weekly basis
on Friday;II

Section 11.5.3

Community Monitoring Program.
Most of the EPA recorders
have been pulled back to the test site due to equipment
shortages in the off-site monitoring program.
Units remain
at Newberry, Fairview and West Donegal.
Reports are nolonger issued on a daily basis.
III

Appendix M

This Appendix has been substantially revised and will
be made available to the NRC.shortly.
9.
The FPEIS should explain why, in spite of the fact thatthe decontamination is going to be done using processedwater qontaining tritium at concentrations up to 0.98
uCi/cms, no mention is made of tritium as an occupational
hazard.
Perhaps this is factored into the doses given, but
the specifics should be given more clearly.
Tritium is bothan inhalation and immersion hazard, but the occupationaldose discussions appear to be limited to the external dose.
Tritium is also omitted from several tables in Section 6
where it should appear (cf Tables 6.4-5, 6.4-6, 6.5-1
through 6).

A-240

-

6 -

10.. The PPEIS should correct the following items withregard to Kr-85:(a)Page 2-13, Sect 2.2.1.4.
Not all of the Kr-85 has
been removed.
There is still
potential for the
release of more during water treatment and during
the defueling operations.

(b)Sect 6.1. Kr-85 may still
be coming from theprimary coolant and the fuel rods.
If so, thisshould be stated and factored into cumulative
impacts and inventories.

(c)Sect 6.1.4 Should note the initial problems
with the particulate alarm system, the cause
thereof, and the resolution.
The presence of
the EPA Onsite Coordinator in the control room
during purging should be noted.

(d)Table 6.1-2 and sect 6.1.6. Should include a
comparison of the measured doses - EPA, Met Ed
etc. - to the estimates presented.
It may bereassuring to the public to show how conservative
the estimates being made actually are.

(e)Sect 8.1.4.1 What about Kr-85 release?

(f)Sect 8.1.5.2, 3rd pp. line 6. If Kr-85 releases
can vary by a factor of 500 from the estimated
100 Ci, we have a real problem.
It is intended
that the actual doses resulting from a given
release will be wi-t-in a factor of 500 of theprediction.
The entire question of the isotope balance for
Xr-85 is unclear.
It would be very helpful tostate how much was present in the rods before
the accident, how much was released in the accident
and during the purging, and how much is left.
Taking the number of fuel assemblies (177) andthe 320 Ci of Kr-85 per 8.2.4.2 one could estimate
about 56,000 Ci of Kr-85 in the reactor.
This
may represent the activity that was present withall rods intact.
This should be clarified.

(g)Table 10.1-4.
The 8.5 x 108 uCi. entry underShould not it be 4.3 x 1016;
85 may be in error.

11. The FPEIS should clarify the discussion of accident
scenarios.
The scenario on page 6-27 appears to indicatethat the total exposure resulting from the accidenta.l releaseof 500,000 gallons of water from storage over a two-hour
period would be less than that from a planned release.
Do
you mean to imply that the alternative of rapid discharge tothe river is preferable?

12.
The FPEIS should clarify the statements in the DPEIS
that there are 51,000 Ci of Krypton-85 in the core.
There
is no mention of it being in the primary coolant.
13.
The FPEIS should include a discussion of the technicalfeasibility of ocean dumping of low-level radioactive wastes.
The current Ocean Dumping Regulations can be found in theFederal Register of Jan 11, 1977 with the criteria for
disposal in Section 227.11.
We believe this is necessary
to fulfill the mandate of NEPA for assessing all feasible
alternatives, even though we recognize that, as a matter ofpolicy, no permit has been issued by EPA to ocean dump
radioactive waste at any level, and that there has been no
ocean dumping of radioactive wastes since 1967.
Neitherthe Marine Protection, Research, and Sanctuaries Act (MPRSA)
nor the' London Dumping Convention (LDC) preclude the dumpingof low-level radioactive wastes; they prohibit the ocean
dumping of high-level radioactive wastes.
The designationof disposal sites requires an application to EPA with theapplicant responsible for time consuming, expensive studies,and for monitoring to assure selection of an environmentallysound alternative.

332 Valley Read,
ittersPennsylvania 17319
November 18,

1980

Commissioner Ahearse
NRC, Washington D.C. 20555

JOHN J. KEARNEY,
Senior Vice President

EDISON ELECTRIC

Dear Sir,
All points of view kave not been preasnted in the body of the Pzrwgrmatie
Environmental Impact Statement, nor have all of the environental consequences
to all of the surrounding areas been adequately addressed. We feel a persenalaffront in that consideration of the impact on Cumberland County, with a popukbties of more than one hundred thousand, was not_. ineluded. The effects of theclean-up oz the Now Cuaberland Army Depot. and on the Mechanieaburg Naval Supply,Depot were met addressed. Such exelusiena jeopardise, the entire statement.
The- safety ef the routes chosen for transporting radioactive wasta from
Unit 2 could not have been carefully eonsidered. 1-80, for example, Is in aeedof repair and is presently being repaired, section by section; a hazard an Itself.
The poor conditien ef thia ne*route alone sassed nuereus aceidenta is the. past.
Those who prepared this statement could have senneissioed a study to determine
the nunbers and severity of esideonts on this route* If much a study was done,
reoul'ts were not reported in the statement.
We have a concera, to say the least, about evacuation. In the eerrider
between the Suequehanna River and Route 15 to the west, there: ar•e only tweother routes running north-south: two-lane Route III and limited- aeeess
Route 1-83, and 111 is the route giving access to 1-83. Many of the secendary
reads in this area are narrow with steeply-dropped shoulders, or none at all.
We have been isolated for days after anew storms and have had to wait for
special eqaipfent to be brought in to have snow cleared. Accidents or weather
genditioun have resulted in miles of traffic .ens effectively closing 1-83.
Another deeply diet-arbing aspect of evacuation is the fact that there are net
enough sekool buseeee to transport children and others out of this area. Whowill go first and who will have to stay behind and who sakes that decision?
Difficulty in reading the statement Is a universal complaint. The small
print and the scattering of the many subjects throughout the entire body ofthe statement makes trying to follow a particular subject more complieatedthan it need be. Trying to enlarge on quotations from other sources has been
expensive and aggravating. Being vastly overcharged for one small booklet seems
to be ,last one other way to discourage the public from finding the informationneeded to eomnent constructively.
While it may be business as usual to the NRC, we are anguished by state..
sents such as these"Almost all the risk(NRC genetic effect risk)would be. borne by future.
descendants of workers at the plant.""NRC intends to allow the disposal of TMI-2 wastes at existing disposalsites provided it can be demonstrated that these wastes have similar characteristics to wastes routinely generated and disposed of at these disposal site..""Regulations allow maximum individual occupational doses of 3 rem perquarter to the whole body, head and trunk and active blood-forming organs, lensof eyes, or gonads; 18-3/4 rem per quarter to the hands and forearms or feet
and ankles; and 7-1/2 rem per quarter to the skin of the whole body.""The use of these resources(Susquehanna River and the atmosphere)to diluteand disperse the effluents of chemicals and radioactive materials from the cleanup of TMI-2 is not considered to represent irreversible or irretrievable con-

I NSTITUTE The assocation of ebecrc companies
111119th Street. N.W.
Washington, D.C. 20036
Tel:(202) 828-7400

20,

November

1980

Nuclear Regulatory Commission
Washington,

D.C.

Attention:

DirectorThree Mile Island Program Office

Subject:

20555

Draft Programmatic Environmental Impact Statement(PEIS)

relatedtodecontaminationand disposal

Gentlemen:
The Edison Electric Institute (EEI) is the national
association of the investor-owned electric utility industry
whose members

investor-owned

serve

99 percent

of allcustomersof thesegment of the industry and 77.5 percent

of all users of electricity in the United States.
of EEls members operate nuclear power reactors,

A numberhaveplants under construction and are considering possible
future additional nuclear power plants.
We have reviewed the subject DRAFT PEIS and agree with
the Staff's general conclusion that it has "... evaluatedthe environmental impacts of alternative methods ... " andthat "... existing methods are adequate, or can be suitably
modified, to perform all of the necessary operations ... "to decontaminate, defuel and dispose of the wastes from
TMI-2.
While we are not offering detailed comments on thereport, we want to point out that the public health andsafety is better served by expeditiously cleaning up TMI-2
rather than delaying the work.
Therefore, the NRC is urged
to proceed rapidly with the completion of the PEIS andwith its safety review and approval of the necessary program
elements.
The clean up of the facility is essential andits early completion a standpoint of overall safety for the
public.
Very truly yours,,

mitments of these resources."
If this environmental impact statement was supposed to address constructively our fears and concerns regarding the clean-up of Unit-2, it has failed,todo so.

mhn

64/

of

radioactive wastes resulting from March 28, 1979
accident Three Mile Island Nuclear Station, Unit 2.
NUREG-0683 (45 FR 54493)

JJK: skmr

K

rney

REt

Docket No.
RE,
50-3202855 Croyden Road
Harrisburg, Pa., 17104
November 19, 1980

Docket No.

2.

Page

50-320It

may be possible to develop such a plan in

conjunction

with the newly created Advisory Panel For The Decontamiation

John Ahearne, Chairman
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

of TMI,

Unit 2.

The media cannot and should not be depended'upon
Dear Commissioners,

mailings to individuals must be continued (including allcomments are directed at the Draft PEIS

These

to the decontamination

relating

Three Mile Island Nuclear Station,

openness on the part of Met-Ed (GPU)most frightening I

FederalThe Draft PEIS isadversary,and their

purpose inregulatory role?

Itbusiness,government,

medical professionals

public meetings.periodicly

ten years so there isand NRC

officials

She isvery afraid there

I

Her

is

a

just learned today that
tonight for the final

you plan to be in

Middletown

public meeting.

Unfortunately

I have other commitments
It isannoying tomany of us that there was no notice of your visit

over the nextprior

to the day of the meeting.

I propose a
Sincerel2you)'s,

quarterly reporting and input mechanism with government
and utility

September because she was

and will not be able to attend.

opportunity for input to Met-Ed

to affect decision making.

incalledcalling was to request information or direction

Commissioner Ahearne,-and other 'groups must have on going access to information
presented at

a local doctors office

and adequately researched and responded to.

of the final PEIS do__ment.
Citizens,

to follow-up on

relationship to TMI but would not reveal her identity.
Fears and rumors will continue if they are not openly

ls crucial-that coliciee

and procedures for Public input andreporting purposes
for the duration of the clean-up be established as part

A nurse in

to on going studies.

so involved and lengthy thaton the technical aspects.

of the decontamination
wastes at TMI-Unit 2.

she had seen diagnosed the normal yearly number of"enlarged" thyroids (she used other medical terms).

be ablecitizens are intimidated or unable to comment

most

government

essential tovery concerned about the dramatic increase, in thyroid
two months
She said that within the lastproblems.

We (the area citizens) have very

to continue the vigilant,

must be assiged

is

DER)

animal and human health effects

Three Mile Island Alert incontinued capability to adequately and safely follow
proper procedures.

staff

reports of plant,This huge clean-up operation isWill the NRC and EPA staff

and Pa.

process and disposal of radioactive

the TMI area.

Met-Ed (including GPU)

DOE,

EPA,

(NRC,

and allreassure area residents for the life

and asked questions of Commissioner

I AM -SCARED I
in

Unit 2.

November 10, 1980.

Victor Gilinsky,

faithagencies

the Harrisburg area, heard presentat-

ions by the NRC staff

little1979,

three months I have attended several

Over the last
public meetings in

A network of

those who responded to the Draft PEIS).

and disposal ofradioactive wastes resulting from the March 28,
accident attherefore,

the note worthy information,

to disseminate allir; attendance.

cc:

A-243

Commissioner VicGus Speth, Aller
John Heinz, A. S

r.g. Bernard Snyder,g.iJ 1/4.21

,vý
AAýý,
AMERICAN SOCIETY OF UTILITY INVESTORSThe Earth Alliance
c/o Mrs. Johanna Ezell
LibraryMont Alto Campus, PSUMont Alto, PA
17237

PRESIDENT
Dr. James R. Spang

P.O. BOX 605, CAMP HILL, PA 17011

U. S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Washington, D. C.
20555

November 18,

Dear Sirs:
We know the "Draft Environmental Impact Statement" proposed by the NRC
intended to be the blueprint for cleanup of TMI Unit 2 to be insufficientin protecting our health and the health of the environment.

The Commissioners
Nuclear Regulatory Commission
Box 311

MET ED and the government have chosen their courses of action concerning
the incident and cleanup at TMI since the very beginning with consideration
towards saving money, not with consideration towards health and safety.

Middletown, PA

This "Draft Environmental Impact Statement" has glaring omissions, deficiencies
and errors.
As the ones who will suffer the effects of this whole incident,
we demand that this DEIS not be used.
We demand that a responsible and wellresearched statement be used instead.

Gentlemen:

Signed by students of Mont Alto Campus,
Pennsylvania State University.

First, a word about the Society. The Society has a membership of morethan 3,300 GPU shareholders.
It was organized to provide a voice for theinterests of the shareholders in all economic and related matters including
protection from the unfair attacks of local and national activists and theirorganizations.

~J
,,A

7K
..

tc

We are pleased to report that in our judgment the draft is an intelligible, comprehensive and exhaustive model of responsible and objective commentary on a highly technical subject. Many alternatives are explored withineach of the major parts of the report and feasible actions clearly identified.

i

A-

17057

Staff of the American Society of Utility Investors has completely reviewed the draft Programmatic Environmental Impact Statement related to thedecontamination and disposal or radioactive wastes resulting from the March
28, 1979 accident at Three Mile Island Nuclear Station, Unit #2, Docket #50-320.

The use of the proposed DEIS would threaten our lives and this Earth welove.
You are being held responsible for our future.

L

1980

4-

We assume that any of the alternatives identified-as feasible would beequally acceptable to the NRC and is the prerogative of the Company to implement.
If this interpretation is not correct and that by some curious, circuitous reasoning another interpretation can be held, we would like to know
about it.
In our estimation, any other conclusion would be silly, because -by definition-- it would, ipso facto, not be feasible.

VaQ

In closing, we expect and recommend that the staff report be acceptedand fully supported by the NRC.

Since ely y~urs,

41

R SparngT
Jaes"INVESTMENT IS THE FOUNDATION OF GROWTH"744!LMARYLAND
Mr. Bernard Snyder
November 19, 1980
Page Two

DEPARTMENT OF STATE PLANNING
301 W. PRESTON STREETBALTIMORE. MARYLAND 21201
HARRY HUGHES

November

19,1980

CONSTANCE LIEDER

GOVERNORSECRETARY

Baltimore Regional Planning Council provided comments directly td theapplicant by transmittal letter
dated October 17, 1980.

Mr. Bernard Snyder
United States Nuclear Regulatory Commission
1717 H Street
Washington, D. C.
20555
SUBJECT:ENVIRONMENTAL NRC IMPACT STATEMENT(EIS)Applicant:Commission

Project:

U.

S.

Nuclearegulatory

REVIEW

Draft EIS - Decontamination of Three Mile Island
Nuclear Station - Unit 2 NRC Docket #50-320

State Clearinghouse Control Number:

Dept. of Health and Mental Hygiene. Office of Environmental Programs wasprovided an ample opportunity to review and comment on the project within
thisreview period but has not responded as of thisdate.
If any substantive
comments are received subsequent to this letter,the comments will beappropriately forwarded.

81-8-158

State Clearinghouse Contact: James McConnaughhay
Dear Mr.

Department of Natural Resources noted that they are the lead agency in theState regarding nuclear matters and are performing an in-depth analysisof the Statement.
The Department hopes to have theirreview completed by
the November 20 cut off date and will forward theircomments directly tothe applicant to conserve time.
The Department will also send an information
copy of such comments to the State Clearinghouse.

(383-2467)

Snyder:We appreciate this opportunity to review the draft EIS and anticipate
that the review comments will be properly considered and addressed in
the final
document.
Thank you for your attention to the A-95 review process.

The State Clearinghouse has reviewed the above project.
In accordance withthe procedures established by the Office of Management and Budget Circular
A-95, the State Clearinghouse received comments from the following:

Sincerely,

Dept. of Public Safety & Correctional Services. Dept. of Health & Mental
Hygiene. Office of Planning. Dept. of Economic and Community Development,
including their Historical Trust section. Dept. of Transportation, andour staff,
noted that the Statement appears to adequately cover those areasof interest
to theiragencies.
Cecil County provided detailed
concerns:

comments(attached)

Director,

regarding the following

State Clea inghouse

JWM:BG:mmk
cC:

1.

Three Mile Island Nuclear Station should be cleaned up as soon
as possible.

2.

The "local release" of processed nuclear waste water into the Susquehanna River is an inappropriate action and an unnecessary risk
considering
the alternative of storing the water in the two 500,000 gallon tanksthat have already been installed.

3.

Detailed safety precautions and backup systems should be outlined tomaintain the boron concentration in the water circulating the core,thus ensuring that the reactor will be safely maintained.

4.

High level radioactive waste should not be stored on TMI
than necessary.

any longer

TELEPHONE: 301-383OFFICE OF STATE CLEARINGHOUSE

A-247

G. Kamka/E.
C. Pyers/H.

Pigo/S. O'Hara 80-364/M. Pugh/S. Long w-a/L.
Silbermann/M. Eisenberg/N. Thompson

Frederickr '%\~~CECIL COUNTY, MARYLAND

OFFICE OF PLANNING AND ECONOMIC DEVELOPME4
ROOM
210. COURT,OUSEBuLbDWG
ELKTONMD21921V

Fp7t

Cc

77

1. Additional Effects
A.

Additional effects of "local release" of the processed radioactive waste
water into the Susquehanna River should be assessed. As the proposed
alternative reads now "after on-site dilution and mixing in the river,
the water would satisfy EPA's interim drinking water standards of thenearest potable water source".
This allows for a higher concentrationof radionuclides in the Susquehanna River between Three Mile Island andthe nearest intake for drinking water. The radioecological consequences
have been assessed after the effluent has completely mixed with the river.
What are the radioecological effects at the point of discharge? There
has not been enough study on the effects of low level radiation to set
a definite standard. What may be a safe drinking water standard today
may not be considered safe tommorrow.
To complicate matters further,safe levels of radioactivdty are relative. We are affected by the amountsof radiation we have been exposed to in a lifetime.
For example, a person
who has already been exposed to high level radiation, or someone who lives
on the Florida Coast which has a high level of radiation, could safely
be exposed to a much lower level of radiation than someone living in alow level radiation area. The EPA has deferred from setting standards
in RCRA, Subtitle C for just such reasons.
"Local release'"of the processed water will hurt the fishing industry.
Fish will be above the maximum
radiation level.
The bad publicity will effect the marketability of all
seafood.
The form of the radionuclide is not discussed in the EIS. Are
the radionuclides in salt form which could lead to a high level of bioaccumbulation from low level sources or are they in more insoluable forms.
The chemical form of each type of radioactive material, and the effect ofeach should be included with the concentration level.'

B.

Additional effects of storing high level radio active waste if even fora short duration, should be considered.
Thre" Mile Island is subject
to floods and its proximity to the river makes the possibility of spills
or leakage a particular concern.

TELJEPHON(301) 39011200. EXT.144

September 19, 1980

TO:

Maryland Department of State Planning -FROM:

Michael R. Pugh, Director

Re:

Draft EIS - Decontamination of Three Mile Island Nuclear Station

N

After reviewing the draft environmental impact statement for the clean-upof three mile island, we have developed the list of the following concerns:
1. Three Mile Island Nuclear Station should be cleaned up as soon as
possible.
2.

The "local release" of processed nuclear waste waterinto theSusquehanna River is an inappropriate action and an unnecessary
risk considering the alternative of storing the water in the two
500,000 gallon tanks that have already been installed.

3.

Detailed safety precautions and backup systems should be outlined
to maintain the boron concentration in the water circulating thecore, thus ensuring that the reactor will be safely maintained.

4.

High level radioactive waste should not be stored on TMI any longer
than necessary.

3.

Better or more appropriate measures
A.

We have enclosed further comments as requested.
4.

A-241

There isn't enough data on effects lw level radiation to set
standards in order to evaluate possible effects.

definitive

Additional control measures to reduce adverse environmental effect.
A.

If "local release" of processed radioactive waste water is chosen as analternative, a maximum discharge level should be set, in addition to the
maximum radiclogic level at the nearest drinking water intake.

B.

Periodic inspection of the clean-up process should be made to ensurethat the procedures setforth are met'. In addition, safety precautions
and backup systems should be implemented throughout clean-up procedure.

7AfIA: THREE MILE ISLAND ALERT, INC.
P315
Iffr St. Harrisbur. Puass 17102

2 - Nuclear Regulatory Commission

Noveber19,198(717) 233-7897

November 19,

our concerns (and even our apprehensions) concerning the DPEIS
in general and specific sections thereof in particular.
toWe have been privileged to receive copies o. letters sentIs.
the NRC regarding the DPEIS from the following persons:Pa.;
Kay Pickering and Ms. Mary Osborn, both of Harrisburg,
John F. Brougher, Carlisle, Pa.; Edwin and Mary Ann Charles,
Mechanicsburg, Pa.; and Geirge A. Herman, R.D., York, Pa.
Any differences between their viewpoints and those of Three
Mile Island Alert as regards the DPEIS would be in amounts
too small to measure.
in fourThree Mile Island Alert's concerns with the DPEIS are andPlanning,
Emergency
Costs,
Alternatives,
areas:
major
are
Toansportation and Disposition of Wastes. Our main points
follows:
as

1980

Nuclear Regultory Commission
Office of Nuclear Eeactor Negulation
Attn. Bernard J. Snyder, Prcgrairi Director
Three RIle Isltnd Program Ofdice20555
Washington, D.C.
In re: NUREG-0683, Docket No. 50-320
Draft Prograrmatic Environmentpl
Ipact Statement
Gentlemen:

Alternatives

We take this opportunity to present the co•mnents of Three
Riile Island Alert on the subject of the referenced DPEIS,
in writing.

to us
We find no mention of any consideration of what appears
to be a viable, and the most preferable, alternative - namely,
cleanup of Unit 2 to the degree necessary to insure no futureradioactive releases therefrom (removal oL contaminated waterand of the core and no more, if that would suffice) to befollowed by the permanent decommissioning and entombment of
the reactor.

For weeks, members of this organization have been attending
a number of the various public rieetings held by the NiC to
e:.plain the DPLIS and tu obtain public input and comments
concerning it. Their auestions, and corments, concerning
the Statement are rr.Etters of public record and are contained in the transcripts of those several meetings. We commend
their questions and comments to your attention and study.
While they represent individuals' thoughts and opinions,ThIA in general both synpathizes with and agrees with theirstatements.

Costs
It is our understanding that costs of the several suggested
alternatives will be included in the final PEIS. While we areinterested in learning why this was not included in the Draft
we are more concerned that, in this regard as in others, there
will be no provision for meaningful public comment on therevised PEIS.

In addition, we would respectfully suggest that you pay
meeting ofspecial attention to the record of the :irst
the Advisory Panel _or the Decontamination of Three Rile
Island, Unit.2, held in harrisburg, Pa. on November 12, 1980.
host particularly we urge a careful reading o the questions
and comments presented at that meeting by Dr. Thcmcs G. Cochran,physicist of the National Resources Deiense Council znd himself
a member of the Advisory Panel.

The ultimate solution to the pressing problems of who is to
pay for the cleanup and what those costs ultimately will totalremains as elusive as does the solution to the over-riding
problem of what is to be done with the high-level radioactive
wastes from TMI and the operating reactors in the United States.

We are aware that various agencies, including but by no means
limited to, the Environ-mental Protection Agency and the Commonwealth of Pennsylvania, will also be reviewing and commenting
on the DPEIS. While we cannot anticipate their specific concerns we are hopeful that they, together with those of othersof whom we do have specific knowledge, will serve to emphasize

To discuss alternatives without due regard to costs end how
more.
those costs will be met is an exercise in theory and little
Emergency Planning
Throughout, the DPEIS appears to have a fixation cn the ideathat decontamination will proceed without significant hazard,
.

A-247

I

November 19,

3 - Nuclear Regulatory Commission

1980

and the possibility of a major accident in the course of thecleanup appears to be treated as so remote a possibility thatitrivals the once predicted impossibility of the accident
that ultimately occurred at TXI Unit 2 on Narch 28, 1979.
The environmental impact of a major accident during the extended time now predicted for the cleanup is not only notadmitted, it appears to have been completely blanked fromthe minds of the cleanup planners.
If emergency preparedness plans are required be.ore licensingof new reactors, how much more should they be required in thecase -of a severely-damaged reactor, end should not the desirability of a practical emergency plan; including evacuation,
be addressed in the PEIS?
Transportation and Disoosition of Wastes
The very obvious error in the DPEIS o. indicating that a crowded
and dangerous highway route would be used or shipments ofwastes from T1'I between 1.iddletown and Interstate 80 (an error
now admitted by the NRC) is, we fear, symptomatic of the superficiality, haste and incompleteness which has already marred
any claims for acceptability for the DPEIS.
Where the high-level wastes will find a resting place, particularly now that Vashington State citizens have voted not to
accept such wastes after July 1981 is a pressing problem.
Again we are presented with the recurring argument that theoretically there are solutions to the problem of ultimate 7
position o. such wastes. Gentlemen, please give us the relief
of dealing with the practical world o. what is, and do' notcompel us to deal interminably with the ethereal world of thetheorists. If we believed them, then we would know that the
bumble bee cannot fly, because theoretically it is aerodynaFmically impossible for them to do so. Fortunately, for the
bumble bee and for us, the bumble bee is not bound by what istheoretically possible, or impossible.
Sincerely,
Eary Hartnett
Chairman, TIVIA
Steering Committee
cc: The Eon. John Heinz
Congressman Allen E. Ertel
Congressman Dill GoodlingCouncil on Environmental Quality

R.D.#l, Box 299,
17512
Columbia, Pa.
November 19, 1980
Dr. Bernard J. Snyder
Program Director, TMI Program Office
Office of Nuclear Reactor Regulation
U.S.

Nuclear Regulatory Commission

Washington,

D.C.

20555

Dear Sir:
In the Federal Register of November 27, 1979, the Nuclear
Regulatory Commission announced its decision to prepare a programmatic environmental impact statement on the Decontaminationand Wisposal of Radioactive Wastes resulting from the March 28,
1979 Accident at Three Mile Island, Unit 2.
It seems to me that the substance of the impact statement,
as issued on August 15, 1980, is a cruel parody of what isrequired from the NRG to ensure that public health and safetyconcern during the long and unprecedented
will be of firstcleanup procedures that should result in removal and burial ofradioactive residues from a flood-prone island in the middle of
the Susquehanna River.
The paramount need unaddressed by this EIS, which is labeledAsa disposal statement, is to address the problem of disposal.
long as the government, whatever agency, or group of agencies,
or legislative body that may need to be, does not find, or create,
permanent,safe storage facilities which will accept TMI wastes,
people who live in the Three Mile Island area will not be able torest easy
I know that the subject of segmentation regarding the cleanup
has often been discussed before, sometimes far-too lightly, in myThis EIS doesnot contribute significantly to alleviating
judgment.
fears of the population,

inasmuch as the accident,

itself,withIts doses to the public, and longterm onsite storage are not Ins;
cluded as factors which must be considered for cumulative radiationdose, added on to the projected doses from the various cleanup
procedures.
Iam deeply concerned that the National EnvironmentalPolicy
Act does not provide a clear mandate that NRC must choose the best
environmental alternative for this cleanup, that economic andtechnical benefits may be permitted to override environmental needs.
Cost analyses of cleanup alternatives are not discussed in the EIS.
I am fearful because this does not provide information to the publicwhich will assure us that go-ahead decisions are being given to
the licensee that are clearly best for the health and safety of people,
not primarily for the health and viability of Metropolitan Edison
Company.
• .. fact that INSIDE NRC has pointed out the fact that thecontainers in which the resin filters from EPICOR II are stored,
are now deteriorating, makes us who live In the area question
whether NRC knows what to require of the licensee in the way ofcontainers to contain, that can be moved from Three Mile Island
if a storage site can be secured.

I

.-

a

-00

-

M

- I

2

The
Chesapeake Bay Foundationa maximum probable flood would inundate the
The fact thatwhich is being used to store containers
concrete storage facility
analysis ofwhich could soon be leaking, necessitates a detailed
I haveconcrete.
the effects of radiation bombardment and heat on
137 in the resins,heard serious speculation about whether cesium
concrete.
through
if released from the canisters, could percolate
are needed, or are
The E1S contains no indication that studies"Citizen Representation - Ensironmental Education - Land Preservation"

being done.

162 PRINCE GEORGE STREET - "THE CHURCH"

anxietyIn the psychological stress sectiont to describe
danger has passed fromafter an actual stressing event, as If all
as being phobic..
the unprecedented, untested cleanup procedures,denies thewhat is,because It focusses on what-if, rather than
It is rational to be anxious in aof area citizens.
rationality
This EIS attempts to denigratesituation that is fraught with danger.
E. Jones, secretaryconcern about the &6•nitionOf what Clifford
Resources, hasof Pennsylvania's Department of Environmental
in the world."
described as the "most unsafe radioactivb site
reachedIt seems to me that a pinnacle of unconcern has been
done in Harrisburg,when the NRC holds hearings, as Is presently being
where cleanupof another nuclear reactor at this siteon the restart
I would suppose
procedures must go on for most of the next decade.
is granted, there wjll be far better management and.
that If restart
the accident, BUT
NRC oversiSht than was the case as the time ofoperatingto consider allowing "normal" releases from a "normally"

reactor,in addition to the expectable,

projected ones,

and theultimate diaregart
possible unexpected ones from the cleanup is showing
health.
for public opinion, and mental health, not to mention physical

These considerations,as well as a wide range of other public

for NRC to issuecomments which have been sent to your office, call
can bedraft
another DRAFT of the EIS for comment, before a final
issued to govern the cleanup.
SincerelBeverly M.66ss* ANNAPOLIS, MARYLAND 21401

301 268-8816 (Annapolis) 269-0481 (Balto.)

Officers
C. TROWBRIDGE STRONG
Presidemt
GODFREY A. ROCKEFELLER
Vice-President
ROBERT M. HEWES, 3rdSecretary
JAMES E. TEMPLETON
Treasurer
Zx Officio Trustees
GOVERNOR JOHN N. DALTON
GOVERNOR HARRY R. HUGHESTRACY A. GILL -Student
E. T. BUCHANAN - Lynnha-en Chapter
J. PARKER CROSS. JR. -Norfolk Chapter
HAYDEN ROSS-CLUNIS - York Chapter
RUSSELL C. SCOTT - Richond Chapter
7ntteea
BERTHA S. ADKINSGEORGE E. BAHENJR.
JOHN M. BLOXONtELISABETH REED CARTERJOHN C. CLARKSONVICTOR L. CRAWFORD
L EUGENE CRONIN
T. MARSHALL DUER, JR.
CLAYTON EWINGCHARLES S. GARLAND,JR.
ALBERT F. GOETZE, JR.
M. GRANT GROSSEVELYN M. HALLEY
D. HEYWARD HAMILTON, JR.
WILLIAM J. HARGIS, JR.
BRUCE F. HARVEY
T. HUGHLETT HENRY,JR.
C. A. PORTER HOPKINSERNEST W.jENNES
E. POLK KELLAM, JR.
LUCIUS J. KELLAM
CHARLES V. B. LaMOTTEJEROME LaPIDES
M. LEE MARSTONCHARLES McC. MATHIASJOSEPH H. McLALN
PHILIP MERRILLJAMES W. MULLEN, II
WILLIAM B. MULLINS
L CLEMENT NLXONSTURE G. OLSSON
M. LEE PAYNE
TRUMAN T. SEAMANSARTHUR W. SHERWOODLEONIE L. SIMMONSWILBUR E. SIMMONS, JR.
ROBERT L' STEVENSDOUGLAS WARNER,JR.
WILLIAM W. WARNERARTHUR L. S. WAXTER
Director
DAVID B. McGRATH

A-249

261-2350 (Wash., D.C.)

November 20,

1980

Mr. Bernard Snyder
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear Mr.

Snyder:

The following comments are intended tosupplement the comments which we submitted at
the public hearing on September 30, 1980 regarding
the draft PEIS on Three Mile Island.
We believe that there are serious deficiencies
in the draft PEIS which will necessitate extensive
Such deficiencies
revision of the document.
include the absence of cost estimates for thevarious alternatives, inadequate evaluation of the
impact of the release of the processed water to theSusquehanna River on the Bay commercial andrecreational fishing industry and an expandeddiscussion of the long-term radioactive waste
disposal options, as well as numerous factual errors.
Agencies of the Federal government must
prepare and circulate a revised draft environmental
impact statement, if the original draft statement"is so inadequate as to preclude meaningfulor prepare aanalysis "(40 CFR S1501.9(a)),
supplement to the orginial draft statement, whichmust also be circulated for public comment, if
there is significant new information (40 CFR
See also, 1-291 Why? Ass'n
S1502.9(c) (1) (ii)).
1975); Lathamv.Burns, 517 F.2d. 1077 (stT7Cir.
v.Brinegar, 506 F. 2d. 677 (9th/cir. 1974); andCedar - Riverside Environmental Defense Fund v.
This
Hills, 422 F. Supp. 294 (D. Minn. 1976).
Federal agencies (40requirement is binding on all
CFR S1500.3).. "Federal agency" in this context
is defined in 40 CFR S1508.12 to include "all~t?/.,4 ,,p,,sJ.; 7 vv~.i4...
6 0

Page Two
Letter to
Mr.. Bernard Snyder
agencies of the Federal government" excluding only tpe
Congress, the Judiciary, the President and the President's
Executive office staff.
Since no specific exception ismade for independent regulatory commissions, there can be
no question, but that the Commission should either prepare arevised draft preliminary environmental impact statement or a
supplement to that statement and circulate the new material for
public comment.
We therefore request that such a document be preparedand circulated for public comment prior to publication of the
final PEIS.
We hope that you will seriously consider our request.
Sincerely,,Na5celK~ly
Senior Staff Biologist

H pe M'.Babcock
Senior Staff Attorney~2~.~6~-i~%o4

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November 20,

1980

Bernard J. Snyder
Director of the
TNI - Program Office
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

,.

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,iX,

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1536 Sixteenth Street NW, Washington, D.C. 20036 (202)483-0045.-,

Dear Dr. Snyder:/,j.z

We are writing to comment on NUREG - 0683, the Draft Programmatic Environmental
Impact Statement related to decontamination and disposal of radioactive wastes resuiting from March 28, 1979, accident Three Mile Island.Nuclear Station, Unit 2.
According
We are requesting that a Revised Draft HEIS be prepared at this time.
to NEPA Regulation 1502.9 (a), a revised draft EIS must be prepared "if a draft
statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and circulate a revised draft of the appropriate portion".
It is our contention that the Draft PEIS for TMI-2 is so inadequately preparedand presented as to be meaningless in vital areas of cleanup such as waste disposal,
where in-depth information is needed for decisions to be made.
Attached are coimnents
to that effect made by our organization to Matthew Bills at the U.S. Environmental
Protection Ahency on November 14, 1980. We wish to submit these comments to you,which will describe some of the areas which we have identified as inadequately developed for decision making and which document the need to prepare a Revised Draft PEIS.
Also attached are additional comments, which support the request that a Revised
Draft PEIS be done, by Pennsylvannia's state-wide group called the Environmental
Coalition On Nuclear Power.
We will remain in contact with the Nuclear Regulatory Commission concerning ourrequest that a Revised Draft PEIS be done and that these issues be addressed properly.

Rýýtf llY.LJ9

Coral Ryan
For the NIRS Staff

cc:
NOTE:

I

U.S. Nuclear Regulatory Commissioners
Comments mentioned in the above letter as being attached are included inthis appendix as comment number 64.

A-253

I

*

NS-TMA-2341
Dr. Bernard J.

Westinghouse
Electric Corporation

Water Reactor
Divisionsx355
PinlsburghPesyiv"-2-

NS-TMA-2341
November 19, 1980

15230

In comparing TMI-2 with other experience, Section 1.5.6 of the draft PEIS
notes that "At all the previous accidents, the workers began recovery
operations immediately and got the job done quickly and effectively".
Westinghouse observes that the most difficult and frustrating part of theTMI-2 cleanup appears to be obtaining authorization to proceed.
We hopethis situation will be corrected by prompt approval of the PEIS.

November 19, 1980

Dr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Dear Dr.

SnyderWe are somewhat concerned about the consistent tendency throughout thedraft PEIS to equate millirem or microrem public exposure to probabilityof cancer fatality or eventual genetic effect. Nowhere are the assumptions
and probable conservatisms of the linear, non-threshold dose response model
discussed.
As noted in the. 1980 BEIR-III report, "It is by no means clear
whether dose rates of gamma or X radiation of about.lO0 mrads/yr are in
any way detrimental to exposed people; any somatic effects would be masked
by environmental or other factors" (BEIR-III, p. 187).
We agree with thejudgement of the draft PEIS, "On the basis of comparison of the doses
calculated here to those of natural background radiation, it is suggested
that the health effects are non-existent, especially in consideration of
the fact that natural background radiation in the United States varies
from one location to. another within a range of about 70 to 310 mrem peryear" (PEIS, Sections 4.5.2, 8.1.5.2, etc.).
We also agree that it isappropriate in the PEIS to quantify the probability of cancer or genetic
effect using'an appropriate model.
The result, however,.should be presented
as a calculated or theoretical result based on assumptions believed to beconservative,.rather than as an actual probability. Also, an appendix,.
based on the new BEIR-III report, should be added to explain the linear,
non-threshold model.
We do not quarrel with the dose-response coefficients
While coefficients based
usedin the draft PEIS, as noted in Table 4.5-1.
on the' new BEIR-III report reconmmendations would be somewhat lower, theserecommendations came after the draft PEIS was generated and are not yet
in common usage in environmental impact statements . Thus, we suggest thata discussion and comparison in an appendix would be appropriate.

Snyder:We are pleased to provide the following comments on NUREG-0683, Draft
Programmatic Environmental Impact Statement on the Three Mile Islandcleanup activities.
The draft PEIS appears to bewell written and technically accurate.
Thorough analyses have been made, and an overwhelming amount of technicalinformation is presented to provide the basis for the conclusions.
Based on our review, we believe the information contained fully supports
the draft PEIS conclusion that recovery operations will have minimal
adverse effect on the public health and safety and agree that maximum
offsite radiation exposure would be "much less than the design objectivesof Appendix I of 10 CFR 50 for operating nuclear power plants".
(PEIS,
page S-10, Section S.4.)
We also support the draft PEIS conclusion that
potential or postulated accidents are unlikely and do not have the potential
to spriously threaten public health (except for psychological stress).
The draft PEIS correctly notes that the cleanup "should proceed in a timely
manner . . . to complete those activities which can cause psychologicalstress for residents in the area. The sooner the cleanup is completed,the sooner the sources of concern will cease to exist".
(PEIS, page S-3.)
In addition, we point out that public fears are unnecessarily reinforcedby the appearance of indecision. Thus, expeditious cleanup activities
can'provide public reassurance as soon as they begin.

Section 9 of the draft PEIS presents a detailed assessment.of the impacts
of. transporting wastes to the Hanford disposal site, 2300 miles distantfrom the TMI site. This section should emphasize that this represents thebounding, or worst-case, assessment of transportation impact and does not
imply that disposal at the Hanford site is the only acceptable alternative.
As noted in the draft PEIS, "Onsite storage for an interim period prior to
shipment is a viable and necessary option" (Section 9.2.1.l).
Regardlessof the duration of such interim storage, Westinghouse believes interim
storage would be an improvement over existing conditions at TMI, both as
to waste form and location. Thus, we urge that cleanup, not be delayed
pending selection of the ultimate disposal site.

As a corporate citizen of Pennsylvania, Westinghouse urges that public
fears of TMI decontamination be minimized by prompt completion and approvalof the PEIS.
Section 1.5 discusses some of the vast decontamination experience available
from other sites, and properly notes that "The removal of unwanted radioactive contamination from materials and equipment is a familiar and routine
operation in the nuclear field for reducing radiation levels".

Further, we believe additional efforts should be made to disseminate theinformation contained in the PEIS to the public.

A-294

Z
Dr. Bernard J. Snyder

-

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NS-ThA-2341
November 19, 1980

A descriptive document should be prepared for public distribution summarizing the PEIS in non-technical language, that clearly shows that the propose
cleanup operation of ThI-2 will have negligible impact on the population
with respect to health effects resulting from radiation exposures. The
document should include, as a minimum, information on the following items
covered in the PEIS:a.

No new technical advances are needed to successfully carryout the cleanup. Decontamination, radwaste handling andeffluent control are "state-of-the-art" technologies.

b.

There is a real need to get the job done as soon as
possible to minimize the risks of uncontrolled leaks
which would cause further public fears. Prompt action
will minimize psychological stress.

c.

Effluents (primarily liquids) that would be released areinnocuous -- specific radioactivities should be comparedto those in other common liquids, drinking water, etc.,
so the public can have a basis of comparison. Tritium
activity should be placed in perspective.

d.

The transportation impacts, volumes of low-level waste
generated, and their significance, should be discussed.

e.

The role of environmental radiological monitoring
programs to assure that unacceptable radioactivity
is not being released, merits emphasis. The role ofmonitoring program (pg. 11-2), whereby
the cloca commnin ties can confirm that radiation levels
are indeed negligible, should be stressed.

_O'i 17,
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A means of getting this document broad coverage to the people located in
the vicinity of the plant should be determined; i.e., through means suchas newspaper inserts, regular press, electronic media.
Very truly yours,

T. M. Anderson, Manager
Nuclear Safety Department

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Public Interest Resource Center
1037 Macjay Street•

Harrisburg, Pa. 17103

717/233-4241
20 November 1980-

Dr. Bernard J. Snyder
Program Director, Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

424~Le42 aDear Dr. Snyder:Pursuant to notice appearing in the Foreward to NUREG-0683, I am
submitting to you the enclosed comments on the Draft PEIS on TMI-2
cleanuý and disposal of radioactive wastes.
Your'attention to the issues raised in these comments in the
preparation of a Revised Draft PEIS and Draft Supplements to the
Final PEIS will be appreciated.

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I will gladly elaborate further on any of these matters withyour staff if this will prove helpful.

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I also expect that the Staff will take into account the comments
which will be made by the Special Review Committee being established'by the Environmental Protection Agency. This groupof experts has beencreated to provide comments from an independent source.

42t,

Sincerely,......

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Steven C. Shoily
Project Director
TMI Public Interest
Resource Center.

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-2COMMENTS ON DRAFT NUREG-0683

2.

The Final PEIS is greatly in need of much tighter editing thanthe Draft PEIS was given.
There are some run-on sentences in the
Draft that would give a junior high school English teacher a coronary.

3.

The page numbering system used in the PEIS makes it very hard
to use as a reference.
I believe that it would make much-more
sense to number the pages sequentially in numerical order (e.g.,
1, 2, 3, 4, etc., rather than 1-1, 1-2, 2-1, 2-2, 2-3, etc.).
Witha good table of contents, the sequential numbering system would
make specific portions of the PEIS much simpler to locate, and.thereby increase the utility of the document.

4.

The reference citations appearing at the end of many sections
I suggest that the Staffof the Draft PEIS are totally inadequate.
envision an interested member of the public ernestly trying to locate
any of the following (from page 1-17, Section 1.5):

submitted by:
STEVEN C. SHOLLY
Project Director
TMI Public Interest
Resource Center
Harrisburg, PA
19 November 1980

INTRODUCTION
These comments cover three general subject areas:changes which should be made in the Final PEIS;(1) Editorial(2) Technical,

scientific,"Nuclear Incident at SL-1 Reactor," ID0r19302.

and policy comments on the Draft PEIS which should be addressed in the
Final PEIS; and (3)Skarpelos and R.B. Lobsinger, "Decontamination of H Loop
Following a Fuel Element Failure," HW-42081, March 23, 1956.

J.M.

Lojek and W.T. Lindsay, "Attempted Decontamination of the
Chalk River CR-VI Loop," WAPD, COA-AO-50, February 1959.

Comments on the Draft PEIS regarding NEPA matters.

Obviously, these reference citations to not provide the reader
with sufficient information to locate these papers.
A full bibliographic
citation (including name and address of publisher) is necessary.

EDITORIAL CHANGES
1.

J.M.

The Draft PEIS is far too technical for the general public.
I realize that the NRC has legal obligations to the NEPA process
which require, as a practical matter, a highly technical and very
lengthy document.
I do believe that, especially in this matter,that the NRC has an additional and equal obligation to the public
to produce a readable and complete discussion of the cleanup andalternatives.

Further, specific page references are missing entirely. Some of
the referenced documents are hundreds of pages long; searching such
documents for a specific fact or quotation without page citations(or even chapter citations) is impossible.
In order for anyone toevaluate the PEIS, page citations to referenced documents is anabsolute necessity. Such page citations must have been available
to the Staff-when the PEIS Was prepared; therefore, there is no
logical reason for not providing them to the general. public.

The Commission has been criticized in the past by the Council
on Environmental Quality on the nature of its EIS's (SEE "Environmental
Quality--1979", the Tenth Annual Report of the CEQ tot~e President,
pages 577-581).
In the case of the Draft PEIS, this criticism
seems to have fallen on deaf ears.
I can see two alternatives which would comport with the spiritof the new regulations adopted by CEQ on 30 July 1979.
First, the
NRC could publish the Final PEIS in two forms, one a less technicaldiscussion which is much more readable than.the Draft PEIS (SEE
as an example Volume I of the Rogovin Report), and the other the
typically voluminous, highly technical discussion which is commonly
The second
associated with NRC Environmental Impact Statements.
alternative would be to produce a very tightly focused Final PEIS
which meets the requirements of.NEPA, but without.the voluminous
explanations with which the NRC seems to be the most comfortable.
The more detailed explanations would then be included as appendicesto which the reader could turn for more details.

5.

The Draft PEIS is nearly devoid of visuals (photos, drawings,
diagrams, etc.).
Increased use of such visual aids would greatly
enhance the public's understanding of the Final PEIS.
Especiallyneeded are drawings/photographs of the interior of the auxiliary,
fuel handling, and reactor buildings at TMI-2.

6.

The units of expression used throughout the Draft PEIS areinconsistently applied.
In addition, while it is common to findboth the concentration and volume of contaminated fluids, very
seldom is the total activity calculated.
It would be a service
to the readers to include some basic appendices on units ofexpression and to expand the glossary to include such terms as
shutdown margin.

I
U

A-299
U
U

-3-

-4TECHNICAL,SCIENTIFIC,AND POLICY COMMENTS
9.

7.

The Draft PEIS is flawed in major areas of concern due toa number of factors (incomplete information, incomplete discussion,
artificially restricted scope, and artificially restricted assumptions
about the feasibility and acceptability of alternatives).
Revisionof the Draft for Final form will result in very substantial changes.
Some material will be included in the document for the first timein the Final PEIS if the Staff follows its present intentions (e.g.,cost factors and the real transportation route to be used for waste
shipments); this is clearly not acceptable procedure under NEPA.

It is clear, for instance, that full cleanup with equipment
removal with minimal or no decontamination could be accomplishedwithout precluding restoration or decommissioning.
Decommissioning
could follow directly (e.g., mothballing the facility); restoration
could be accomplished simply by decontamination of the equipment.

It is necessary, therefore, that one of the following
alternative pathways to a Final PEIS be followed.
First (and themore desirable of the two), is to publish a Revised Draft PEIS
for a thirty-day comment period. Second is to proceed with the
Final to the extent that substantial revisions are not necessary.
Where this is not the case, issue a Draft Supplement for publiccomment, then publish the Supplement in Final form.
Either ofthese alternatives will provide the public with due process rights
of comment on materials that are presented for the first time, whileat the same time meeting the NRC's substantial obligations to the
NEPA review process.

The argument has been advanced by the NRC Staff during public
meetings on the PEIS that the same level of decontamination would
be necessary regardless of the future disposition of the facility.
Nothing, other than the opinion of a limited number of NRC Staff
personnel, has been advanced as providing a technical or scientificbasis for this position. Why is it not conceivable, for instance,
to decontaminate the containment sump water, construct shielding
around the upper portion of the reactor, defuel the reactor, andmothball the facility until radiation levels decrease (when further
decontamination could be accomplished with a much lesser exposure
to cleanup workers)?

If it is necessary to proceed with a particular action before
this process is completed (I would estimate that it would becomplete by May 1981), an Environmental Assessment of that particularaction could be performed.
However, I do not foresee that thiswill be necessary (nor do I foresee that the Licensee would havesufficient funds to proceed until this time in any event).

8.

The Draft PEIS is thoroughly slanted toward cleanup alternatives
which would permit restoration of the plant to operating status.
For
instance, it is stated on page 2-1 that the "only" alternatives which
would not affect a decision between rebuilding and decommissioning
are those in the group labelled "full cleanup, salvage and decontaminate
usable equipment."
This is misleading and serves only the corporate
interests of General Public Utilities and the image of the nuclear
industry. Never in an Environmental Impact Statement from any agency
have I seen alternatives rejected so out-of-hand and summarily.

The "Tenative Outline for TMI-2 Programmatic EIS" dated
10 January 1980 and provided to the public during the "scoping"sessions, clearly indicates at section 2.2 that there was anintent to discuss the decommissioning/restoration issue, at least
to a limited extent.
Between 10 January 1980 and the issuanceof the Draft PEIS, however, there appears to have been a change
in intent and this issue was never fully developed.
The issueof decommissioning/restoration is absolutely central to theentire cleanup.
For the Staff to attempt to avoid its discussion
is a clear violation of the spirit of NEPA.

The information presented in the Draft PEIS in Chapter 4
regarding the potential for recriticality does not fully address
the problem.
There are numerous studies related to the problem
which are not even referenced in this section.
This is an extremely serious issue which merits a more detailed
discussion in the Final PEIS.
For instance, the Draft acknowledges
that introduction of 1000 ppm borated water in the core (assuming
the original configuration) could result in recriticality due tolack of control rod material.
The fact that the geometry of thecore was altered during the accident in a manner which will not
be understood until the core can be examined visually makes thisprediction very tenuous.

The Staff's intent in attempting to avoid this issue isunclear--however, the obligations placed upon the NRC by NEPA
are clear. The issue of decommissioning/restoration must be addressedTo doin either a supplement (draft) or a Revised Draft PEIS.
otherwise is to artificially restrict the scope of the PEIS, toeliminate from consideration a fundamental question regarding thecleanup, and to violate NEPA in the truest sense of the spirit
and letter of that law.

No mechanisms are postulated for the introduction of "underborated water" into the reactor, despite the seriousness of arecriticality accident.
There two readily available mechanisms
by which underboration could occur--sabotage and operator error.
Neither is addressed in the Draft.
Neither are the potential
consequences on the environment and on the continued cooling of
the TMI-2 core from a recriticality accident addressed.

10.

A_2r7

A related concern to this issue, which also gets into thefinancial condition of Met-Ed/GPU, is the expenditure of funds
by thecompany related to restoration activities while it isuncertain that there will be sufficient funding avail'able to
The NRC should take a firm standeven complete the cleanup.
that until the contaminated water is removed from the reactor

ONE

-5-

-6'potential impacts on the environment, and the schedule for the completionof cleanup.

building sump and until the reactor core is removed (the. two main
sources of potential releases of radioactivity to the environment)
the Licensee should be prohibited from spending funds on activities
This will
related to restoration of TMI-2 to operating status.
ensure that Licensee's unstable and limited funding base will
be used toward its primary responsibility, which at this point
in time is the decontamination of TMI-2 and the disposal of theradioactive wastes resulting from the accident and the cleanup.
Absent such a stance by NRC, there is no guarantee whatsoeverthat the Licensee will not spend significant amounts of money
It is clear from public
on activities related to restoration.
statements and from its own publication "TMI Today" that the
TMI-2
to an operating status;
Licensee fully intends to restore
this should not be permitted in any form (including planning,
engineering studies, expenditures for hardware, etc.) until the,Inlevel of risk represented by Unit 2 is greatly reduced.
my opinion, this will only occur after the containment sump
water has been processed, the core has been removed, and all
high-specific-activity waste has been removed from the island.
11.

12.

14.

The last sentence on page 2-8 states that it is possiblethat loose fuel debris could be present in large enoughamounts in the Reactor Coolant System to present a criticality
problem.
This situation should be fully explored in the PEIS,
including a description of how much fuel would be required
to present a criticality problem, what the radiation doses
to workers might be, and how the criticality problem could
be mitigated once initiated. A simple one sentence descriptionof this problem is insufficient for an EIS.

Restoration as a nuclear unit.
Decommissioning alternatives.
Conversion to another power source (e.g.,

15.

fossil-fuel).

Blanket statements on this problem which are found in Chapter 1of the Draft PEIS are totally inadequate.
13.

a.

Average and maximum whole-body gamma doses for the workers
and the public living within 20 miles of the plant (orout to whatever distance radiation doses due to the accident
are indistinguishable from background doses).

b.

Beta radiation doses (whole body, skin,
the same persons.

c.

Alpha radiation doses for the same persons.

d.

Separation of total doses into component parts (i.e.,
whole body, inhalation, internal deposition, deposition
on ground, immersion, etc.).

and inhalation)

for

These doses and expected additional doses (as well as population
doses in person-rems) should be compared both to existing standards,
doses to the public from other similar reactors which are operating,and doses from the operating history of TMI-I.
These discussions
will permit the reader of the Final PEIS to place radiation doses
from the cleanup into perspective.

The PEIS should include discussions for each cleanup alternativeof what potential impact the alternative could have on future
There are at least three general possible
options for the facility.
futures for the facility:
a.
b.
c.

In order that the cumulative impact of routine and accident-related
releases of radioactivity can be placed in perspective, the PEIS should
contain a section (perhaps an appendix) which describes the doses
which have already occurred, both to the public and to the workers.
This discussion should address the time period from the accident up
until the period following the venting of the Krypton-85 from thereactor building. The following doses should be described as fully
as possible (with ranges of uncertainty indicated for each):

The Draft PEIS fails utterly to deal with the eventuality ofwhat could occur if the Licensee goes bankrupt during the cleanup,
a possibility which certainly cannot be ruled out (in data submitted
to the NRC at a meeting on 14 August 1980, Licensee notes an
expected revenue shortfall to cover cleanup of over $500 million
in excess of insurance coverage).
This issue must be dealt withfully in a supplement or Revised Draft PEIS.
It cannot simply
be skipped because of Staff preference or the promise that it
will be addressed in another report. The PEIS is the EIS forthe cleanup, and as such should address all relevant issues,
includi,ng the potential for bankruptcy of the Licensee and the

A-261

The applicability of prior decontamination experiences at othernuclear facilities is very questionnable.
These facilities were not
located in populated areas, nor were they as large as TMI-2.
The
Draft PEIS contains many contradictory statements on this matter,so many so that a firm conclusion cannot, in my opinion, be drawn.
The following statements conflict with the conclusion drawn in
the Draft PEIS that "the basic technologies for decontamination are
well established and that available techniques can be modified tosuit the conditions at TMI-2":a.

"experience is limited with high-level decontaminationof building interior surfaces and equipment where thecontamination has spread over large areas such as theentire interior surfaces of a reactor building." (page 1-12)b.

"Applicable experience in removing damaged fuel andcore components is limited, and development of techniques
specific to TMI-2 will be required."(page 1-11)c.

"Chemical decontamination experience to remove fuel failure
debris, including fuel fragments. is very .limited. Only
one reactor, the Plutonium Recycle Test Reactor (PRTR),
at. Hanford, Washington, has undergone such a decontamination."(page 1-14)

-8-

-7d.

"There has been little experience with removing fueldebris from large reactors. . ."(page 1-14)e.

"Experience at other nuclear-facilities in removing
damaged fuel and core components has been rather limited,
and much of the existing experience is not directly
applicable to TMI-2." (page 1-16)f.

"Other plants have had fuel removed after severe damage;generally these incidents have involved only a single
or a few fuel assemblies. For the most part these fuelassemblies have been constructed of stainless steel-clad
The ThI-2 fuel is quite different
uranium metal fuel.
in that the fuel is uranium dioxide pellets withzircaloy cladding, which is more susceptible to oxidationand embrittlement." (page 1-17)

g.

h.

"If significant fuel cladding has occurred, insoluble Zr0 2
could be distributed throughout the reactor coolant system.
Hydrofluoric acid, one of the few ZrO2 solvents, is too
corrosive to be used as a general decontaminant; therefore,
the ZrO2 will h ave to be removed by mechanical means."(page 1-17)

It is stated on page 1-20 that the NRC Staff intends to address
disposal criteria for "nonroutine wastes" on a case-by-case basis.
This is not acceptable.
Certainly general classifications of such
wastes can be postulated and defined by contamination levels andby the specific isotopes which are most likely to be present.
These
wastes are some of the most significant in potential environmehtal
impacts; to "pledge" to deal with them on a case-by-case basis
is totally unacceptable.
A thorough attempt to evaluate theenvironmental impact of the nonroutine wastes (and their storage
and disposal) must be made.
To the extent that this evaluation
fails to cover specific waste forms proposed by the Licensee,
supplements or environmental assessments should be issued indraft form.

18.

The Staff is aware that the 11 February 1980 revised Technical
Specifications are the subject of a pending litigation.
It appears
that disagreements between the Staff, the Licensee, and the Intervenors
is possible in the near future.
The Final PEIS should reflect any
changes to the Technical Specifications.
It would be advisable toinclude the revised Tech Specs as an appendix to the Final PEIS.

19.

The Final PEIS should thoroughly address the status of thesolidification of the EPICOR-II resins as required by Commission
Order dated 12 March 1980 (Amendment 10 to License No. DPR-73).
The discussion in the Draft fails to adequately address thisimportant matter.

20.

Section 1.6.3.2 addresses proposed criteria for radiologicaleffluents from decontamination activities.
The net effect of this
discussion is to permit the Licensee, with Staff concurrence, toestablish precedent-setting radiological effluent criteria which
could be applied to future cleanup activities at this and othernuclear plants. The NRC should exercise its regulatory functionand establish cleanup criteria, and then require the Licensee tomeet these criteria.
The criteria should be the subject ofa rulemaking proceeding to commence as soon as possible.

21.

Referring again to Section 1.6.3.2, I feel that it istotally inappropriate to use 10 CFR Part 50 Appendix I criteria
in conjunction with cleanup.
These criteria are intended foruse with operating nuclear reactors, ones from which (presumably)
the public receives at least some benefit.
In the case of
TMI-2, the Licensee's customers received the equivalent of 95
full-power days of electricity.
Many of the residents in the
20-mile radius of the plant and most of the residents downstream
from the plant received nearly zero benefit from the operationof TMI-2 since they are not customers of the Licensee (the only
possible benefit would be power that was sold to their utility
as replacement power from the Licensee).
There is no positive
benefit to be gained from radioactive releases from TMI-2
during cleanup, only the reduction in possible negative impacts.
It is therefore inappropriate to use radiation release objectives
designed for operating reactors in the case of TMI-2 cleanup.

"Commercial nuclear power plants are not designed withspecial considerations for large-scale decontamination
operations." (page 1-17)

This issue requires much fuller explanation in the Final PEIS.
More details should be given, and the applicability of each experienceshould be addressed.
16.

17.

'-

In Section 1.6.1.2 (page 1-19), the Draft PEIS states that"to ensure reasonable radiation stability of the organic resinover ten half-lives, resins having specific activities greater
3
than 1OCi/ft will undergo specific evaluations to ensure thatradionuclide migration and other impacts within the waste container
are minimized over the hazardous lifetime of the wastes." When
will these evaluations be done (after the contaminated resins are
created?)? Who will do them? How will they be done? How can
the physical, chemical, and radiological environmental conditions
which will be present through 10 half-lives (Cs-137 or Sr-90)
be simulated? What criteria will be used to perform the evaluations?
What is the current condition of the EPICOR-II resins? Information
available to me from outside sources indicates that the resins
should be breaking down into caustic products which could destroy
the resin liners. Further, this source postulates that the resinsthemselves are breaking down into a gelatinous mass in which thecontaminants can migrate. This entire issue mist be fully exploredin a Revised Draft PEIS or a Draft Supplement.

A-262

m

-10-

-9-

Accordingly, the Revised Draft PEIS or a Draft Supplement should
contain a thorough discussion of this situation, including all its
ramifications.
The discussion should include as a major focus thepotential impacts of long-term storage of radioactive materials at
the site. The attitude that "we'll cross that bridge if and when
we come to it" is not sufficient, in an Environmental -Impact. Statement.
Long-term storage is a possibility which cannot be precluded simply
because a portion of the current NRC Staff feels that such an-action will not be permitted.
The cleanup will last far beyond
the 5-7 years so glibly predicted in the Draft PEIS; a completion
date in the period of 1988-1995 is more likely.
Long-term storage
on-site of high level wastes should be evaluated for its environmental
impact, not because it is a desirable alternative (which it certainly
is not), but because given the current political, environmental,
regulatory, and institutional climate, such storage cannot be
precluded from becoming necessary.
The impact should be evaluatednow, not after it becomes a matter of fact.

Radiation releases from TMI-2 alone beginning with the accident
have already far exceeded values given in the FES for both TMI-1 and -2.
The following examples are given for your consideration:

22.

a.

Noble gas releases from the two units were not to exceed
a combined total of about 4,000 curies per year.
Estimatesof the total noble gas releases during the Krypton-85 venting
alone totalled at least 42,000 curies, or the equivalentof 10 years of operation (the venting took less than
2 weeks).
Releases during the accident (as reported in
NUREG-0600) were approximately 13 million curies (mainly
isotopes of Xenon).
The latter figure is equivalent
to over 3,000 years of operation.

b.

Iodine releases were to have been a fraction of one curie
per year.
Iodine releases during the accident are reported
to have been around 14-15 curies.
This is at least equivalent
to 14-15 years of operation, and almost certainly much more.

25.

Section 1.6.3.3 postulates the decontamination of TMI-2 tolevels equivalent to those which are permitted for "unrestricteduse."This will be necessary only if the plant is to be restored
to operation.
This is a continuing example of the bias of the
PEIS toward restoration.
The decontamination need only proceed
to a level compatible with protection of the public health andsafety, i.e., to the level necessary to permit decommissioning.
If a decision is made to restore the plant, then and only thenshould additional decontamination be authorized.
The worker
exposure will be reduced by this policy, as will the quantities
of contaminated water which will require processing.
This bias
reflected in Section 1.6.3.3 pervades the entire PEIS and shouldbe eliminated in the Final PEIS.

23.

Pages 2-1 and 2-2 discuss possible interim storage ofhigh specific-activity and transuranic wastes at the island.
There is no technical justification for this position containedin the Draft PEIS.
Such justification must be included in a
Draft Supplement or Revised Draft PEIS and must be fully explained,
along with possible alternatives (including storage in containment
at Units I and 2, storage at a location offsite, and storageat another facility away from a river location).

24.

Section 2.1 of the Draft PEIS discusses in a cursory fashion
the possible storage of radioactive materials on-site beyond
the normal 30-year operating license period.
Additional discussion
on this matter is excluded from the Draft, according to the text,
because the Staff considers that the PEIS should be restricted
to alternatives that provide for complete removal of all radioactive
materials from the site. While this is a laudable goal, keep inmind that this is the real world, and that there do not appear to
be serious prospects for construction of a high-level waste repository
in the next several decades due to political, regulatory, andinstitutional constraints.

m

Page 2-5 contains the statement that there are tanks andequipment in the Unit 2 Auxiliary Building which are needed for"maintaining the reactor in safe shutdown."
This statement should
be expanded upon to include a discussion of whether this equipment
is safety-grade, and if not, what degree of reliance should beplaced upon it in terms of preventing adverse environmental impacts
related to safe shutdown loss.
Further, the discussion should
include possible impacts on that equipment (safety-grade or not)from cleanup activities which have already eccurred or those that
may occur from various cleanup activities.
It is possible, forinstance, that important pieces of equipment or systems may not
be environmentally qualified for the environment which will
be present during various cleanup activities.

A-2197

26.

Section 2.1.2.2 discusses, very briefly, the so-called"corridor concept" of selective decontamination.
After adiscussion of four sentences, this alternative is summarily
dismissed. The brief discussion present in the Draft PEIS does
not reflect any but the smallest consideration which may havebeen given to this alternative.
The corridor concept of selective
decontamination must be thoroughly explored, including costs,
possible doses to workers involved in setting up the corridor,
and environmental impacts as compared to other alternatives.
It would appear that the corridor concept, if carefully plannedand executed, could greatly reduce worker dose during cleanup.

27.

Section 2.1.2.2 discusses destructive decontamination andscrapping of equipment rather than thoroughly decontaminating
it.
These two issues are again swept aside with the strokeof the pen, another obvious bias in the Draft PEIS in favor ofpreserving the restoration option.
The consideration should
be what method results in the lowest doses to the public andthe workers, the least environmental impact, and the smallest
amount of radioactive wastes.
Both methods mentioned above
are inadequately discussed, and must be further elaborated
in a Revised Draft or Draft Supplement.

-12--1128.

29.

Page 2-7 contains a statement that "lack of knowledge ef:.thereactor vessel integrity" increases uncertainty about core fixation
alternatives.
Lack of knowledge about reactor vessel integrity
also increases possible environmental impacts from recriticality
accidents, sudden pressure-temperature changes (getting possibly
into nul-ductility problems), and other situations where loss of
integrity of the reactor vessel could create unanalyzed problems.
This entire issue must be fully explored in a Revised Draft or
Draft Supplement.
Page 2-10 contains a statement that "It may not be possible
to decontaminate some of the equipment contaminated during theaccident and return it to service" (emphasis added).
Thisagain indicates a very Eea-vy-bias toward cleanup alternatives
favoring restoration of TMI-2 as an operating reactor. The
Staff should forthrightly deal with this issue.

30.

Section 2.2.2 again raises the policy of "case-by-case"consideration by the Staff, outside of the NEPA review process,of the environmental impacts associated with specific waste
forms.
This is unacceptable.
The potential environmental
impacts from these wastes must be fully described in a Revised
Draft EIS or a Draft Supplement.

31.

There are several places in the Draft PEIS (for instance,
Section 2.2.3.1) which discuss possible Incineration of certain
types of radioactive wastes.
Incineration has supposedly been
mentioned by Met-Ed officials as one possible means of disposingof the EPICOR-II resins (I find this rather difficult to believe).
Nowhere in the Draft PEIS, however, are the environmental impacts
from such incineration addressed.
Are the radionuclides containedin the wastes released when incineration occurs? What types offiltration are available? What is the efficiency of the filter
systems? This issue suggests quite a lengthy line of issues,
yet none are discussed in the PEIS, or even mentioned for thatmatter. This issue must be fully explored in a Revised Draft
PEIS or a Draft Supplement.

32.

33.

Section 3.1.4.1 contains the assumption that complete mixingof TMI effluents with the full flow of the Susquehanna River isassumed below the York Haven Dam.
The bases for this assumption
should be fully explained in the Revised Draft PEIS or a Draft
Supplement.

34.

The Final PEIS should address the impact of water treatment
on radionuclide concentrations present in river water.
No
information on this matter is found in the Draft PEIS.

35.

The Draft PEIS fails to adequately address the impacts ofrelease of treated but still radioactively-contaminated water
into the Susquehanna River.
Psychological impacts on downstream
water users has been conveniently ignored.
Further,there is
no realistic consideration of possible impacts on the marketabilityof Chesapeake Bay seafood. JI believe that if any contamination
is detected in the seafood taken from the Bay, regardless of
NRC claims as to Its source, seafood eaters will take this asrepresenting contamination from TMI, and,- therefore, the seafoodindustry on the Bay will suffer irreparable harm.
This isa very real impact which must be assessed with a fullscale
market survey of both consumers and seafood industry sources.
The survey must be carefully conducted and constructed so.as.
not to prejudice the responses in any manner.
Similarly, the option of evaporation of such water throughthe plant's forced-draft cooling towers is inadequately assessed;
Again, psychological impacts are ignored completely.
No assessment
is made over potential reconcentration of radionuclides released
to-he environment.
These issues must be fully developed in a Revised Draft PEISof a Draft Supplement.

The discussion in Chapter 3 of the site geology and hydrology
is insufficient when consideration is taken of the quantity ofradionuclides available in solution at the damaged reactor. According
to the State Geological Survey, there are no site-specific studiesof the transfer characteristics of either the bedrock or soils
found on the islands; therefore, any estimates of how fast leaking
radioactive materials might reach the water table or the riverare pure speculation.
Site-specific studies should be conducted
and reported in the Revised Draft PEIS or Draft Supplement.
Thequestion should also be addressed in terms of the continuing
high levels of radioactive water (containing tritium) found inmonitoring wells on the island.

A-264

36.

The statement in the Draft PEIS that the Susquehanna River is"not an attractive source of public water supply" (page 3-12) ispure nonsense.
If this is so, why do the cities and towns of
Lancaster, Baltimore, Columbia, Havre de Grace, Wrightsville,
Conowingo, Chester, Safe Harbor, and Holtwood use it as asource of drinking water? How about some consistency and honesty?

37.

In Section 3.1.6.2, it is noted that impacts may occur outside
the so-called "study area."
If this is so, these impacts should
be investigated and quantified.
NEPA reviews are not permitted
to be limited in scope at the discretion of the'NRC Staff. NEPA
requires that environmental impacts be evaluated, not just those
impacts and portions of impacts that the Staff "feels" likeevaluating.

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38.

The section on psychological stress (Section 3.1.7), is purefantasy.
It was totally undermined by comments made by Dr. SiegfriedStreufert (Human Design Group and Hershey Medical Center) during
a public meeting in Middletown held during the Comment Period
on- this document.
This section is nearly fascist in its orientation,
placing anyone who does not accept the agency's version of theaccident and its. aftermath in the category of "phobic", implyingThisthat such persons are somehow mentally ill or incapacitated.
is fascism in its purest sense.
It is high time that the NRC
begin to deal realistically with this issue.
Why is it, for instance, that in the first attempt by NRC toaddress the problem of psychological stress t"at the NRC contracts
with an organization whose lead staff member is also a professor
at the Uniformed Services University of Health Sciences, whichis associated with the Department of Defense?

44.

What is the source of the Plutonium cited in Table 5.3-1?
could indicate fuel melting.

45.

The discussion of waterborne releases in the Draft PEIS fails
to deal in any way with bioaccumulation or any other means of •reaccumulation of radionuclides following release from the plant.
Simply looking at the concentration at release is not in itself
sufficient to ensure minimal environmental impact.
Possiblemeans of reconcentration following release must also be examined.

46.

In examining the radionuclide inventories listed in Section
6.4.1.1, if 99.99% containment of these radionuclides is assumed
throughout cleanup, the following releases will occur:

NRC has an obligation under NEPA to fully and frankly assess
psycholigical stress related to cleanup, and, given the utter
failure to do so in the Draft PEIS, is.now legally bound to do
so in a Revised Draft PEIS or a Draft Suppleim;ent.
39.

The Section 4.1 discussion on why the Krypton-85 was vented
from the reactor building should explain why, after four monthsof waiting since the venting was completed, the fan coolers have
not had any maintenance performed on them.

40.

The Final PEIS should address how much longer so-called"mini-ventings" will be needed to continue to remove Kr-85
from the containment.

41.

As a whole, in discussing possible accident scenarios, thePEIS fails to consider the possibility of sabotage.
The Final
PEIS should include this consideration in all accident assessments.

42.

43.

Erm

E

a.

42 Ci of Cesium-137b.

7 Ci of Cesium-134

c.

.67 Ci of Strontium-90

d.

.16 Ci of Strontium-89

This

This raises the question of how high a percentage ofcontainment can be expected throughout cleanup.
It would seemto be relevant to review the experiences of fuel reprocessing
plants and other cleanup incidents in this regard.
47.

The meteorological assumptions used in computing offsite
radiation doses in the Draft PEIS (including dispersion anddiffusion characteristics) should be fully justified in the
Final PEIS,. perhaps in an appendix.

48.

Section 9.2.1.1 discusses possible radiation doses at thesite boundary from a proposed onsite radiation storage area.
The listed dose of 0.5 mr/hr works.out to 4.4 Rads/year at
the site boundary.
What is the impact on site workers (person
rems .for the duration of occupation of the island? Further,.
what is the dose to the public? Even if attenuated by afactor of 100, this is significantly above regulatory criteria
for the entire nuclear fuel cycle.
If attenuated bya factor of 1000, it is still over two times higher than the
total dose projected by the Staff for the entire cleanup.

Comparison of radiation doses from cleanup with doses occurringfrom natural background radiation is misleading.
First of all,natural background doses are unavoidable.
Secondly, they are causedby different types of sources than the releases from the cleanup.
The exposure pathways will be different in many cases, as will
the specific type of radiation which is causing the exposure(i.e., gamma, beta or alpha).
The practice of comparison ofcleanup-related doses to natural background should be eliminatedfrom the Final PEIS.

NEPA COMMENTS

The assumption made in many instances throughout the Draft
PEIS that all filter failures will be detected within 15 minutes
is not justified by any material contained in the Draft. This
assumption must be specifically justified in the Final PEIS.

49.

A-2G5

I believe that it is clear that the Draft PEIS as issuedin August is so deficient as to not represent a sufficient basis
for a Final PEIS without providing for public comment on therevisions to the Draft, which will be substantial.
Therefore,
I conclude that a Revised Draft PEIS or a series of Draft Supplements
should be issued prior to the Final PEIS.

.

-15November 19, 1980
50.

The Staff should acknowledge that the further one qets down
the road for cleanup, the more likely it is that the Staff's
projections will be in error, thus necessitating Draft Supplements
on a variety of issues at some point during cleanup.

51.

The practice of the Staff analyzing "best-case and worst-case"situations, rather than actual situations (even where known inthe case of the Submerged Demineralizer System) is not permissibleor acceptable procedure uncer NEPA.
The public is entitled toknow the environmental impact of specific proposals.

52.

555 Main Streit
Bethlehem, PA 18018

Re: Docket No. 50320
NUREG E-0683
Bernard J. Snyder
Program Director
Three Mile Island Program Office
Nuclear Regulatory Commission
Washington D.C. 20555

As I have made clear in letters to the Staff during the last
several months, I believe that the law clearly calls for public
hearings on the PEIS.
The public meetings which have been held,
while helpful, do not take the place of such hearings, since
witnesses are not sworn, no cross-examination is possible, and<no discovery can be had of the Staff or the Licensee on mattersraised by the cleanup.
I believe that it is a clear violation of NEPA not to hold such hearings on the PEIS.
The NRC should
expeditiously publish notice of availability for a public
hearing on the PEIS and proceed with the adjudication of the.matters raised as contentions so as not to delay cleanup while
the proceeding is in progress.

Dear Mr.

Snyder,

The Draft Programmatic Envoronmental Impact Statement Related To The
Decontamination and Disposal of Radioactive Wastes Resulting From March 28,
1979 Accident Three Mile Nuclear Station, Unit 2 is much to overwhelming
and confusing for the average citizen who will be affected in the thousandsby what is done with the accident's disastrous aftermath. Even lawyers anddedicated environmentalists have difficulty making sense of what is being
proposed and how these proposals will really affect us.
There must be abetter, more comprehendable way to present material of such significant
impact.
Living 6 little
distance from Middletown (approx. 80 miles), theresponses of citizens in that area ore not immediately available to me.
However, your assumptions that the Krypton-85 releases have increased
feelings of safety and decreased psychological stress seem a little
hasty and very shaky. Even at this distance the actual affect appears
mare to be a crushing of the human spirit -- increased feelings ofhelplessness and loss of control, a withdrawal to mare mundane concerns,
and respression of anxieties that appear to have no resolution.
The attitude of your entire document contributes to this destructionof the will to fight back, as has most official response to the accident.
You continue to downplay how much people have suffered already and deny
the extent of the problems facing the community in the future.
You claim
to have safe solutions when everyone 'knows there is a tremendous amount of
bluff in the proposals you're trying to sell. You quietly describe yourconsistent uncertainty about so many of problems needing solutions,rather than delineating them clearly and seeking the wide range of supportand input necessary to even begin to address these problems. Alarm by
the community is appropriate, since only through that vigilant concern
will these problems .be faced and dealt with properly, if that is evenpossible.
If you continue contributing to complacency, the next
disaster at TMI may be assured.

A-26

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To gain support your agency needs to admit the errors of past policies
and separate itself from the present alliance with the Metropolitan Ediso
Company.
Until Met-Ed's ambitions for profit at all expense are removed
hope exists
from planning for dealing with the accident aftermath, little
for a truly coamunity and worker safety orientation in that planning.
For your report to contain credibility you should immediately joinarguments by citizen groups that TM! Unit I can never be reopend safely atwhat has now become a waste storage facility. All available resources from
Unit I are certainly necessary to make the best possible attempt at dealing
with the waste at Unit 2. Any possible uses for Unit 1 in this recovery
plan seem to have been totally ignored by your report.

-IELL
7
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The cummulative doses faced by citizens due to the accidents multiple
radioactives releases contaminating the public's environment to date (theinitial stages, the Krypton-85 releases, the water dumpings, and otherpuffs and spills here and there) should always be listed clearly
littleand concurrently with the predictions you make for future radioactive
releases, so that total impacts are readily determined.

I

,Y--x

A criticism noted early in your report seems to hove been subsequently
You fail to-address in any clear fashion what happens if and whenignored.
Met-Ed is no longer functioning as a utility. Their crippled status and lackof insight so for make them a very dangerous trustee of such an ominous
situation.
Perhaps, again, you should state this clearly and call for theremoval of Met-Ed as a controlling Interest in safety decisions and directions
Then you should present proposals forfor the salvaging operation at TMI.
addressing the problems in that situation. (This should not absolve Met-Edof financial responsibility, just as individual criminals are not absolvedof responsibility for their deeds when hospital and health care professionals haje taken over the mending of the human suffering the criminal
caused.)The citizen advisory committee established to address the TMI clean-up
is certainly a beginning step, but lacks so much of the strength necessay
They should have power and funds to seek independent
for it to be meaningful.
research, to demand the truth from officials and Met-Ed, and to function
The "cle~nin a credible way informing and speaking for the community.
up" at TMI is such a long-term process that it will need strong input fromThat should be sought as
many segments of the community for many years.
often as possible. In fact there would seem to be no point at which afinal plan could be laid out that would be so perfect as to preclude thenecessity of further citizen questioning and advice.

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Nancy.Tate

A-267

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Finally, a most serious flaw is the reality that you can really'makeno environmental impact statement because you do not know what to do with
Even yoar "low-level" waste plans have been halted byany of the waste.
the voters of Washington state. Again, this alarming situation has tb beThis should be the issue of extreme concern to officials rather
faced.
than the financial Lail-out of Met-Ed that has Congress, the PUC and others
Why aren't you representing the public in seeking
enamored at the present.
solutions to this enormous problem? And before responding that you are doingso, please note that any such response carries no credibility as long as
you continue to prombote and condone the continued production of these
undisposalbe, deadly wastes.

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Union of
CONCERNEDSCIENTISTS
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November

20,

1980

,
Three Mile Island
Program Office
Officeof Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

' •

Attention:

Mr. Bernard J. Snyder
Program Director

Dear Sir:e,,•,,.
,.,•],.

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,;,_ .A...4.-•--JQm

I should like, on behalf of the Union of Concerned Scientists,
to submit some brief comments on the NRC's Draft Programmatic
Environmental Impact Statement (NUREG-0683) concerning thecleanup of Three Mile Island Unit #2 nuclear plant.

" c

We concur with the NRC staff'sview that there are no acceptable
alternatives to fulldecontamination of the reactor and associated facilities
and complete removal of the fuel.
Further, weconcur with the NRC's position that waste should not be shipped
off-sitein liquid form.

.-_. ,The suitabilityof solid waste forms for final disposal has notbeen sufficiently considered in this EIS.
Associated with thisdeficiency is a lack of consideration of options for interim
storage of waste, as a solid, in a manner which does not preclude
eventual processing into a new solid form.
The safety of on-site storage and handling of both liquid andsolid waste forms has not been sufficiently demonstrated in thisEIS.
For example:(1)

Section 10.5, "Potential Releases due to Flooding,"
does not give sufficient assurance of the integrityof the Interim Storage Facility, especially in view
reliance on compacted earth fill.
of that facility's(2)

Section 10.4.4, "Leakage of Reactor Building Sump
Water", does not give sufficient assurance regarding
retention of radionuclides in the ground.
Further,
as for other accidents postulated in this EIS, no
person-rem dose is estimated.

If an adequate range of options regarding interim solid waste
forms and storage and treatment facilities
is to be examined in
the final EIS, then included should be a thorough examination of
the potential for off-sitestorage and processing.

A-063

1384 Massachusetls Avenue • Cambridge, Massachuselts 02238

Telephone (617) 547-5552

1725 1 Street. N.W , - Suite 601 , Washinc'cn. DC: 20006

Telephone (202) 296-5600

7m

or

November 19,

U.S. Nuclear Regulatory Commission
November 20, 1980 - Page 2

1980

DirectorThree Mile Island Program Office
Nuclear Regulatory Commission
20555
Washington, D.C.

The limited scope of the above comments does not preclude further
interest by UCS in the TMI-2 cleanup issue.
Sincerely,

Comment on Draft Programmatic Environmental
Impact Statement Relating to Decontamination
and Disposal of Radioactive Wastes atUnit 2 of the Three Mile Island Nuclear
Power Station, NUREG-0683

Carla B. Sohnston
Deputy Executive Director

CBJ: abc
cc:

Dr. Gordon Thompson

I respectfully suggest that the Nuclear Regulatory Commissionagree to prepare and issue a revised draft Programmatic
Environmental Impact Statement (PEIS)on the decontaminationand disposal of radioactive wastes at Unit 2 of the Three Mile
Island Nuclear Power Station -- rather than a final document
at this time -- in order to include consideration of a numberof options and issues which have been raised at some of the
30 or more public meetings held to date on this matter, and toinclude consideration of the following suggestion on decontamination and disposal of radioactive wastes, using the Unit 2
containment building as the primary structure for safe longterm storage of nuclear waste from the accident.
I suggest that a revised draft PEIS include serious considerationof the feasibility, and of the reduced radiation doses that would
result from long-term use of the Unit 2 containment building
to store the core and other radioactive waste from the damaged
plant.
This is a reasonable option to consider because of the fact that
there currently are no disposal sites to accept the Unit 2 wastes
and core, and there is. no reasonable expectation that such sites
will be available during the foreseeable future.
The advantage of storing the core material and other wastes inside
the containment building is that this structure, with its 4-footthick walls and other safeguards, offers far more protection to
the public, and less worker exposure, than would the use of the
far-more fragile structures that might be constructed on Three
Mile Island for "temporary" storage of the core and other wastes*for the many, many years that will pass before possible sites forpermanent storage are secured.
-more

-

A-269

I

Comment on NUREG-0683
Frank D. Davis
November 19, 1980 -- Page 2

HOUSE OF DELEGATESANNAPOLIS, MARYLND 21401

Under present conditions, it would be a fiction to contend thatis not now and will not continue to be a long-term
the TMI-2 site
Therefore, it would be prudent to use thewaste depository.
existing containment building as a structure to house thesewastes more safely and with less risk to the public than would
be true if the core fuel and other wastes were removed tostructures that would not provide nearly as much safety.

OFFICE:HARFORD COUNTY

20 OFFICE STREETSIXTH LEGISLATIVEDISTRICTBEL AIR. MARYLAND 21014
PHONE,COMMITTEES:ENVIRONMENTALMATTERS
JOINT COMMITTEEON ENERGYCHAIRMAN.ADMINISTRATIVE. EXECUTIVEANDLEGISLATIVEREVIEW

83-7010HOME:
747 ROLAND AVENUE
BEL AIR. MARYLAND 21014

November 18,

Dr. Bernard J. Snyder, Director
Three Mile Island Cleanup
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555

Very truly yours,

Frank D. Davis
200 Gettysburg
Mechanicsburg,

CATHERINE I. RILEY

Dear Dr.
Pike
PA 17055

Snyder:I had indicated to you at both the Annapolis and Havre deGrace hearings on the Three Mile Island Cleanup that the Harford
County Delegation would submit its
comments on the Draft Programmatic Environmental Impact Statement in writing.
The following
remarks constitute our formal opinion.
We believe the draft PEIS is deficient in many ways.
Whilemuch discussion is directed toward the eventual dumping of decontaminated water into the Susquehanna.River,other alternatives
are not explored to the degree necessary.
The environmental impactof dumping in the River, as well as the potential impact of air
evaporation are not addressed as thoroughly as we had expected.
We are concerned that dumping will release not only tritium but
strontium-80 and 90 and cesium-134 and 137 into the River.
The PEIS does not adequately delineate the constant need formonitoring of the contained water so as to assure the maintenanceof minimum levels of contamination.
Should the water be released
in anyway to the environment, and even if long-term storage on
site
is undertaken, careful, regular on siteand downstream monitoring should be standard practice.
We believe that the PEIS should contain some cost benefit
analysis, which it does not.
Also, we feel that the NRC must makea definitive statement~to the Department of Energy, Congress andthe President-as to the absolute necessity to provide for a longterm, permanent storage facility
for the high level waste presently
at the site.
There is no question in our minds that waste must be
removed from the island as quickly as practical and safe.

A-270

1980

Dr. Bernard J. Snyder
November 18, 1980
Iage Two
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF PUBLIC WELFARE

HELEN B. O'BANNONWe believe that both dumping of the water into the Rive'r andairevaporation will have substantial environmental impact.
The
PEIS does not allay our fears in any significant way.
We are concerned about any impact on our citizenry and our Bay.
As the water
source for Havre de Grace, Harford County and Baltimore City and asource of livelihood and recreation for so many people, we can notafford to jeopardize the Susquehanna and the Chesapeake Bay.
Thus,
we, the Harford County Delegation to the Maryland General Assemblymust oppose any dumping of Three Mile Island water.
We also must
express equally serious concern about any proposed release to theBoth approaches will release radioevaporation.
atmosphere via.air
nuclides into the environment at levels which have, as yet, undetermined long-range effects.

November 19,

SECRETARY1980

TELEPHONE NUMBER
171717787-2600/3600

Bernard J. Snyder, Program Director
Three Mile.Island Program Office
Office of Nuclear Reactor Regulation
Nuclear Regulatory Commission
20555
Washington, D.C.
Dear Mr.

Snyder:

You have requested comments on the Nuclear Regulatory Commission's environmental impact statement on the proposed clean-up of Three
My comments will deal with the issue of psychologicalMile Island.
stress and are based on consultation with appropriate officials in the
Office of Mental Health, which is under my jurisdiction in the Department of Public Welfare.

We appreciate your response to our hearing request.
We feelour citizens made theirpoint well, and we hope you fully comprehend.
the intensityof our concern.
Thank you very much.
Sincerely,
Hafod

ounty

,ams
Jr.,

GeorgeWilliam H.

WiamAmoss,.Cox,Jr

Psychological research, notably the study conducted by Dr.
Evelyn Bromet of the Western Psychiatric Institute, University of Pittsburgh, indicates that for some in the immediate area, mental stress did
result and continues to result from the TMN accident.
While anxiety
cannot be eliminated, the way in which the TMI clean-up is handled canminimize it.
One point is of key importance:
the need for the availability to the public of accurate and timely information which they cantrust and use to help them cope with stress-producing situations.

eegto

The symptoms of stress are cumulative and can mount over time.
While the clean-up itself,
no matter what process is used, may prove to
be stressful for some, it is certainly, true that continued inaction andthe containment of radioactive wastes in a facility
that was not designed
for longterm storage can add, on a daily basis, to anxiety levels in thegeneral population.
The best way to end stress is to eliminate the cause.
Thus, the expeditious, safe and complete clean-up of existing contamination at TMI can be expected to reduce stress within the population.

Delegate

Delegate

I call your attention to the attached report by researchers
from Hahnemann Medical College in Philadelphia.
Of particular note is
the finding that during the TMI accident, "people had a considerable
lack of faith in the information they received, and in the quality of
the reporting of that information.
Approval ratings seldom reached 50%."(Page 7)The creation of effective networks to disseminate accurate
information during the clean-up process is crucial if stress is to beminimized.
As the NRC, Metropolitan Edison and the appropriate stateagencies'plan for the clean-up, effective public communication should
be a major priority.

elegate

CIR: B

A-271

I

-2Submitted to:Pennsylvania Departmentof Public Welfare
Office of Mental Health

It appears essential, therefore, that the NRC must be prepared
to respond quickly and completely, in an understandable fashion, to demands for information about the clean-up process, and must also be prepared to respond to any malfunctions or unexpected developments which
could be stressful to area residents.
For unless they have information,
which they trust, that stress will increase.
This can be accomplishedthrough regular and well-planned briefings to the news media.
Specialcare should also be given to making sure that appropriate community
leaders and opinion makers are briefed and kept intimately aware of developments in the clean-up process as it progresses.
These individuals,
through their existing community networks, can serve as trusted sourcesof information and guidance for the population at large.
May I say thatthe way in which the krypton venting was handled indicates that you already are aware of the need for effective communication with the public.

October 27,

REVIEW OF STUDIES ON THE
PSYCHOLOGICAL AND BEHAVIORALIMPACT OF THE THREE MILEISLAND NUCLEAR ACCIDENT

I hope these comments are of help to you in your deliberations.
Sincerely,

Helen B. O'Bannon

BY:
Jonathan A. Morell,
George Spivack,

Evaluation and Applied Social

Ph.D.
Ph.D.

Research Program

Department of Mental Health Sciences
Hahnemann Medical College
112 North Broad Street
Philadelphia, PA 19102
(215)

A-272

LO8-0860,

ext. 266

1980

-2-

Measuring instruments were hastily constructed.
point of view.
Existing measures were at times used because of their availability rather than their suitability.
Sampling plans were notas carefully drawn as might have been possible under other cirStudies were not carefully grounded in theory or
cumstances.
None of this is surprising sincein a well developed rationale.
A unique and important event was
speed was of the essence.
Better that it be studied with less thanhappening very quickly.
optimal means than not studied at all.

INTRODUCTION
Immediately following
the
TMI nuclear
accident,
severalsocialresearchers
undertook studies
todeterminethe psychologicaleffectsoftheaccident,
and toascertain
why people
behaved as they did.
Much, but not allof thiswork, wascarriedoutby researchers
inthevicinityof
TMI.
Some ofthework found its
way into
thePresident's
Commission Reporton TMI,
some of it
did not.
All oftheresearch
was hastily
designed
in
order
to
capture theunique eventsas they unfolded.
Most ofthework was done on a very low budget.
This reportisa review of each of those-studies
inlightof the others,
done
with
an eye toward determining
generaltrendsand common findings.
The purpose of undertaking
thework was tobe abletomake recommendations for
improved planningin
TMI-like situat-ions, and to
identify
importantareas
forfutureresearch.

Fourth, the findings of the various studies are reasonable
and make sense when put in the context of other research which
has been done on the-reactions of people to disasters.
TMI may
have been a unique event, but the reactions of people weretypical.
This finding is of considerable help in aiding
planners; and in determining the nature of future research whichshould be carried out.
Fifth, the research was surpris-ingly rich.
There may nothave been many studies to rely on but the work that was doneyielded a large number of insights into the needs for planningand for the types of future study that would aid planners.

While preparing
thisreview, several
distinct
impressions
emerged.
First,
thestudiesreported
here form an importantbody ofinformation.
The accident
unfolded quickly
and theresponseof theutility,the
Publicand Government was in
a.
rapid
state
of flux.
There was a constantand everchanging
streamof informationexchange, action,
emotion and decisionmaking.
The picture
was often
confused.
At the time of thisconfusion
severalstudies
were conducted which "caught" and recorded emotional and psychologicalreactionsofthepublic.
Individial
memory fordetailfades,
and as time goes by thedetailedrecordobtainedby thatresearch
will
become increasingly
important.

In making recommendations about future needs we wereguided by a strong sense that the original accident at TMI cannever happen again.
There may be future nuclear accidents, but
the social psychological and political climate will never be
the same because TMI has affected all of us, and continues toaffect us.
The event is not over - announcements, reports about,and decisions at TMI are still
news, and the pot continues toboil. •Thus, we have attempted to make recommendations thatwould make sense in terms of the new social reality that wouldin our judgment surround a similar accident.

Second,because of theuniqueness ofthe
TMI event, thereislittleliterature
which is directly
relevant
to understanding
thephenomenon.
TMI was not a disaster,inthe classic
sense oftheterm.
There was no specificcatastrophic
eventwith a concrete
manifestationand impact to which people had torespond immediately
and ina selfevident
way.
Further,thenegative
effects
of
the
event
were unknown to the
TMI area
population
at
the
time
of
its
occurrence.
When floods'come,or when planes
crash,
orwhen earthquakes
strike,the problems are
immediate,evident,
and have clearly
perceived
and agreed upon negative
consequences.
Not so inthecase of TMI, where the likelihoodofa catastrophy
was unknown, and where the negative
effectsof theaccident
were inconstant
debate.
Inaddition,
information
conveyed tothe public
about theaccident
and decision-making
on the partof officials,
were embedded ina web of social,political
andeconomic interests.
That fact,
combined with
ambiguity concerningthemagnitude of the problem makes forsurprisingly
littleprevious
information
which can be usefulfor
understanding
the
TMI affair.

We are also aware of the possibilities of related types ofaccidents.
At present many nuclear power plants are in operation, and more will likely be activated in the future.
Inaddition to the plants themselvesi one must consider accidents
which may occur in the removal, transportation and storage of
waste from these plants.
TMI has most certainly changed thesocial-political context for any accident involving nuclear
power.
This report will be divided into four sections.
First, wewill summarize the researcý which has been done and important
findings in those studies.
The summary will deal with needs
for information, psychological stress, and evacuation behavior.
Second, we will present general conclusions which can be drawn
from the data.
Third, will be recommendations concerning theMore research was done than is summarized in this report.
Weincluded only those studies that had an appropriate combinationof methodological strength and relevance to the problems at hand,and for which sufficient data were available.

Third, thereisa surprising
uniformityofconclusions
andclarityoftrendswhich emerge from thevariousstudies.
This
uniformity
and clarity
is
all
the
more telling
because eachindividual study is

not particularly strong from a methodological

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-3-

SUMMARY OF RESEARCH FINDINGS
need to collect more information and conduct further research
about TMI-like accidents, both in terms of social research
activities and in terms of information collection throughexisting bureaucratic channels.
In writing this section we
attempted to focus on information which will-allow planners
to deal better with TMI-like accidents and the psychologicalaftermath of those accidents.
Finally, we will make recommendations for planning-action.
This section will deal withactions that can be taken immediately, and for which further
information gathering is not a prerequisite.

Table:

Summary of Research on the Psychologicaland Behavioral Impact of TMI

Study-Descriptive
2
Title ,

Shorthand
Designation

Time of
Study

Population

Reactions of Adolescentsto the Three Mile Island
Nuclear Power Plant
Emergency (Part of President's Commission)

PC

May

Adolescents in the
TMI area (junior an,senior high school
students)

Psycho-Social Effects of
TMI on Nuclear Power Plant
Workers (Part of President's
Commission Report)

PC

AugustNuclear Workers at
TMI and Peachbottom
PlantsThe Credibility ofGovernment Officials
in the Aftermath of TMI

G

JuneJuly

Gene-ral Populationof TMI area; Mother!
of Young Children,
TMI and Wilkes-Barrt
area

Demographic and Attitudinal Characteristics
of TMI Evacuees

Eliz.

April

Adults; Middletown,
Marietta andElizabethtown

Voluntary Withdrawal from
TMI area of Middletown
Residents

FM

April

Residents ofMiddletown

In the following summary, quotation marks will be used to indicate
adjectives and phrases which are taken directly from the original research.
We hope these quotes will give a sense of the reality of eachresearch situation.
This section is a summary of those findings which
we consider to be most telling in light of our review of all the initial
work that was done.
Full details can be obtained by consulting theoriginal sources.
A catalogue of these sources cdn be found in
Appendix A.
Needs for Information
Radio and television played an extremely important role in disseminating information about the TMI accident.
Sixty percent of thepeople named radio as the prime medium for information.
Forty-fifty
percent named television (FM).
Opinion was divided as to the way in which the information media
handled the reporting of the TMI accident.
While 49% "approved" of
how the media reported the event, 46% "disapproved" (Eliz.).
2

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This information is taken from a brief report we prepared earlier.
That report is included in its entirety as Appendix A of the present
document.

I
-6-5-

Similarly, opinion was divided on felt need for information.
In one study, only 50% of the respondents claimed to have "enoughinformation on emergency procedures" (Eliz.)
In a second study,
53% requested more information on nuclear safety, while 35ý wanted
more information concerning evacuation, and 35% wanted information
concerning happenings at the TMI site.

"broke usual
habits' (stayed
in home, kept
children fromschool, etc.)

18%

PC

saw accident

76%

ELIZ.

as "very serious"

The following chart summarizes how various sectors of the
population saw the credibility of public information during the
TMI accident:
TABLE 2:

In addition to these general findings, several interesting
facts~emerged which related to the amount of stress people felt.
Physical proximity to the TMI plant was importfnt.
Adults living
within a five mile radius of the plant were more "upset" thanthose living farther away (PC).
Also, adults within a fivemile radius perceived the health threat as greater (PC).
A
similar finding emerged for teenagers.
The closer they lived
to the plant, the more "upset" they were (PC).
These findings
were replicated in another study which found that those living
closer to the TMI plant tended to judge the accident as more
"serious."% Claiming Information Source was Credible Source"government
officials"

general population

11% (FM)
21% (G)

mothers of young
children50%

TMI workers

30% (PC)utility
co.
6% (FM)

Denton,unspecified
source45% (FM)

57% (FM)
48% (ELIZ)'

Dr.

(G)
"Time after the accident" was also an important factor.
"Severe demoralization" dropped from 26% to 15% within a twomonth period after the accident (PC).
Similarly,*the perceived
health threat dropped in that time period, as did teenagers
ratings of stress (PC).

73% (PC)

While the data from the above chart may be open to varied interpretations, it is our impression that perceived credibility of information sources during the. initial days and weeks of the TMI accident
was quite low.
The only exception is the perceived credibility of
the utility company in the eyes of utility employees, which very
likely reflected the unique, common interest relationship existing
between employees and employer.

Family status was also important.
Mothers of pre-school
children were more "upset" than the general population, as were
teenagers who had pre-school siblings (PC).
In addition, suchteenagers experienced more somatic symptoms than peers without
pre-school siblings (PC).
People who were married experienced
more "upset" than non marrieds (PC).

Stress

The age of respondents made a difference.
Older adults
perceived less of a "health threat" than younger adults (PC,Eliz.).
In this regard, it is worthwhile to note that neitherof these studies tapped large numbersof the very elderly.

A general summary of the important findings about stress
reactions in the adult population surrounding TMI is presented
in the followingtable:
TABLE 3:

Summary of TMI Stress Reactions
Stressreaction% claiming tohave reaction

source ofinformation"felt threat toself or family"

50%(42% saw noconsequence)FM"panic orconcentration
problems"

38%

FM"severe demoralization"

26%

Finally, sex played a role.
Among adults, females weremore "upset" than males, and also perceived more of a'healththreat" in the TMI accident (PC).
This finding also characterized teenagers.
Females experienced more somatic symptoms than
did males.
Evacuation Behavior
Three separate estimates of the extent of evacuation wereobtained:
62% (PC), 53% (Eliz.), and 57% (FM).
Family related factors played a large part in determining
who evacuated.
Seventy-two percent of mothers with pre-school
children left (PC).
Another study found an-evacuation rate of
48% among families with at least one child, 41% for married
couples, and 28% for singles.

PC

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-7-

-8-

In
The age of respondents was also a factor in evacuation.
For younger
the 50+ year old group, the evacuation rate was 29%.
age groups it varied between 42 and 40% (Eliz.).
of evacuation, speaks strongly for the validity and the importance
Finally, the sex difference found in stressof the findings.
is also an indicator of the validity of the research results.
There is considerable literature which indicates that womenscore higher than men on measures of stress 4 psycho-somatic
Had that pattern
symptoms, anxiety, depression and the like.
not been found here, data would have been suspect.

A final issue of considerable interest is where evacuees
Eighty-one percent went to family, while another 9% went
went.
to homes of friends (FM).
General Conclusions
1.

People had a considerable lack of faith in the information
they received, and in the quality of the reporting of that
Approval ratings seldom reached 50%.
information.

2.

There was a significant amount of stress and ppychological
Althoughdiscomfort among the people living near TMI.
the figures do not appear terribly high, they must be_considered in light of the sample of people who wereA large number of people left the area,
questioned.
and it is reasonable to believe that those who left
Thus the research reported
experienced the most stress.
here is likely to be biased in the direction of sampling
those who experienced relatively small amounts of stress
Seen in that light, findings
or psychological discomfort.
such as 26% feeling "severe demoralization" take on a newmeaning.

3.

Most people found places to go without having to resort
to the efforts of the authorities or to special evacuation
Ninety percent simply visited friends or family.
plans.

4.

if any panic.
There was little
People acted rationally.
These results emerged from the striking parallels between
Mothers of youngthe "stress" and the "evacuation" data.
children and people with family ties left in large numThey also felt morebers than the general population.
The same pattern.
stress than the general population.
held for physical proximity to TMI, and for other factors
which logically would increase people's psychological
None of the
discomfort or their wish to leave the area.
research turns up mention of, wide spread panic or clearlyInterestingly, these findings
irrational behavior.
replicate a more general finding in disaster research.
Contrary to popular belief, disasters seldom result inpanic reactions among the population experiencing thedisaster.

NEEDS FOR FURTHER INFORMATION AND RESEARCH
Although filling in the information gaps higlighted in thissection will necessitate the special skilld-of people trained insocial research, some important information can be collectea
Where such possibilities
with existing bureaucratic resources.
exist, we will point them out in the subsequent section.
Credibility of Information Sources:
Who are the more or less credible information sources in
TMI-like situations? More important, what are the propertiesof credible sources and how can their credibility be improved?
overall confidence in any information * '.
The data show little
source, as well as considerable diversity in credibility among
Unfortunately the data do notvarious information sources.
indicate why the overall ratings are so low, why some sourcesscored higher than others, or what might be done to improve
the situation.
To what degree is credibility a function of informant role,
informant personality, and of institutional response? There isThegood evidence to believe that each of these plays a part.
contribution of institutional response to the problem has been

4

The parallels found between evacuation and stress patterns iseven more remarkable given the rough measurements used for stress
The factthat such patterns showed
and psychological discomfort.
up at all with such measures, and that they reflected -the patterns

In: G.W. Albee andGuttentag, M. The Prevention of Sexism.
J.M. Joffe, Eda. Primary Prevention of Psychopathology
The University Press of New England,Vol. 1. Hanover N.H.
1977.
The Psychology of Sex
Maccoby, E. M. and Jacklin, .C.N.
Differences, Chap. 5 Stanford.CA, Stanford U. Press,
1974.

3

Fritz, Charles E.
International Encyclopedia of the Social Sciences
National Researh gCouncil, 2101 Constitution Avenue, N.W.
20418, >k•S.
Washington D.C.

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-10-9It may be that since
indicate the source of that dissatisfaction.
sources of information were not perceived as credible,.publicdissatisfaction with the information was generalized to the media
On the other hand, it may be
which reported that information.
that factors unique to the media themselves contributed to theuse
There is little
low credibility of the information sources.
in reporting credible information if people are dissatisfied with
Were there problems with the amount of
the method of reporting.
information given? The timing of the reports? The reporters?
The editing of the news broadcasts? These and many other factors
might be involved, and research should be conducted determining
what the issues might be, and how they could be managed.

suggested by others.
Reichlin 5 has argued that considerable confusion during the TMI accident resulted from poor coordination
among the involved government agencies.
The report further
argues that such problemsare a.unction of organizational structure rather than 6f the individual personalities involved.
This 6conclusion is also found in the general literature on disasters.
The importance of organizational structure is givenadded credence if one notes the difficulties encountered by State agencies
during a recent TMI accident practice drill.

Evacuation

In terms of factors related to role and personality, there
is considerable evidence in the social psychological literaturethat these play a large part in how people perceive the credibility of information which they get from other people.7

We know that evacuees left, and that the decision to leave
was related to sex, age, age of children, perceptions of'seriousWe also
ness of the-situation, and proximity to the TMI plant.
Butknow that almost all evacuees went to family or friends.
step, it seefs
As a first
we do not know how they traveled.
reasonable to determine the modes of transportation that would
Such a study would
be used if another TMI-like accident occurred.
give a sense of any strains on the transportation system that
could be expected.

Although we know that institutional and personal factors
will undoubtedly affect the credibility of information in another
TMI-like accident, we do not know how they might operate, or themost effective way of dealing with those factors in order to increase the credibility., of information.
If any future crisis is
to be managed effectively, information on this topic must be
discovered or generated.

What would people's evacuation behavior be if another TMItime people went to friends
The first
like accident occurred?
and relatives, and they apparently moved reasonable efficiently.
But would more people leave more or less quickly if the problem
recurred? Would people evacuate more quickly, irrespective ofwhat they may be told by those in "authority?" Given the publicity and the expanded knowledge people have about the facts
surrounding TMI, such conjectures are not without substance.
It is important to find answers, as changed patterns of evaucation might very well put more severe strain on transportation
time, or greater strain on formal
systems than occurred the first
evacuation structures if they left late.

Finally, one must consider the potential of exisiance indigenous community structures as information-giving channels during
periods such as the one that immediately followed the TMI accident.
Police and fire departments, school systems, churches,
township offices, welfare agencies - these and many other structures might provide efficient means of conveying information
viewed as credible by particular sectors of the population,
depending upon the nature of the community.
But how might thesestructures best be used or interrelated? At present, suchquestions remain unanswered.

A related issue concerns the average distance ,that evacuees
In the event of another nuclear accitraveled or would travel.
dent, how far away would neople have to be before they felt safe?
A new nuclear accident may see many more people leaving theirhomes sooner. Also, people from a greater geographical area maygo, including the family and friends of those-who live close toIf such were the case, the range of evacuation
the accident site.
resources would change significantly and be a potential source ofGovernment
increased stress for those close to the accident site.
officials would be faced with a much more serious set of evacuation
logistics than they had to deal with during the TMI accident.

Media Reporting
The research done on TMI indicates considerable dissatisfaction with how the media handled the situation, but it does not
5

Reichlin, Seth. Government Response to the TMI Accident - The
Organizational Constraints.
Paper presented to the American
Sociological Association, 1979.

6

Fritz, Charles E.
search Council,
20418, 1961.

7

Wrightsman, Larry, S.
Social Psychology in the Seventies(Chap. 10), Monterey, CA, Brooks/Cole Inc., 1972.

Disaster and Community Therapy, National Re2101 Constitution Avenue, NW, Washington, DC

It is also important to consider the question of who cannot
evacuate on their'own, what type of help they may need, wheresuch people should be sent, and where they can be located if an
These people would include
evacuation should become necessary.
shut-ins, the elderly living alone, and residents of a large

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-11Social Change
variety of institutions (prisons, hospitals, nursing homes, residential treatment facilities, and the like).
Some type of geocoded directoryshould be developed and continually updated so thatin the event of an evacuation, particular segments of the population are not left out.

Have people's interest in living near TMI changed? If they
are unwilling to relocate, are they more willing to encourage
their children to relocate? Will outside people be less likely
to move into the area? Will any of this affect property values,
a sense of "home," or any of a large number of other facto-rs that
could change people's quality of life and psychological well-being?
Evidence collected soon after the TMI accident indicates that
although many people considered leaving the area, few have done
so and that although some suspicious changes have taken placein the real estate market, no serious economic problems haveefisued. 1 0 It is unknown, however, how public pentiment willchange concerning nuclear power or other man-made hazzards suchas chemical waste disposal areas, liquid natural gas installations
and the like. It is not unreasonable to assume that such proximity mightaffect people's perceptions of the quality of theirlives, of where they might wish to live.

Stress and Stress Reduction
Previous disaster research indicates that initial stresslevels quickly return to normal, and that even under relatively
prolonged disaster periods, there is little
overt increased
stress felt by the population. 8 This pattern certainly seems
to be evident in the TMI situation.
On the other hand, previous
disaster research has not focused on the effects of prolonged
low levels of stress, or of changes in people's stress thresholds as a function of a stress.
Further, there is evidence that
prolonged low levels of stress can have deleterious effects.
Thus, it is important to ascertain whether such-stress effects
exist in the population, and to determine what their effects

Another issue involves the effect of TMI on the general
economic health of the TMI area.
Little systematic research has
been done on this topic other than anextremely preliminary
investigation by Flynn and Chalmers. 1 1
At the time of the study
no factors were detected which might have long term negative
economic consequences.(In fact there is even the possibility
that the money needed to clean up the TMI facility might havea salutory effect on the economy.)
Still this data is extremely
tenuous, and the likelihood of longer term problems should not
be ignored.

may be.

A related concern is that different sectors of the population
probably experienced varying amounts of continued low levels ofstress. As an example, the stress levels of teenagers with preschool siblings did not return to normal as quickly as othergroups.
A recent follow-up study conducted nine months after
the TMI accident suggestthat this is also true of the mothers
9of young children.

It is also important. to determine whether TMI altered people's
priorities for social or political action.
Given the furor overnuclear power, this question might-have considerable impact on
the social and psychological functioning of the community, on the
stress that people feel, and on the general quality of life forpeople who live near TMI.
It might also have profound effects
on the decision making climate in which government must function,on the types of people who get involved in government, on thelobbying pressures which will exist, and on the will of thepeople.
Some evidence suggests that such a change'is alreadytaking place.
We know that there has been an increase in the
TMI area in the number and level of/activity of anti-nuclear

The general lesson is that the initial levels of stress inthe population did not remain at extremely high levels, but that
there may be continued low levels of stress which are manifest.
Further, those remaining stress levels might well differ indifferent- sectors of the population.
The existence of theseeffects should be discovered and measured.
A related set of issues deals with reducing any low levelsof long term stress which may exist.
What might acheive thatgoal? Knowledge about nuclear power? Job flexibility? Knowingthat one has people to go to in the event of another accident?
In general, it is likely that stress is a function of uncertainty.
Thus, it is important to determine what people are uncertain about
as a starting point to dealing with the problem.

10

Finally, the role of social support systems in the reductionof stress should be studied.
It is likely that such systems areimportant in helping people to deal with stress, and any plans
made should attempt to capitalize on already existing social
support systems.
8

Fritz,

Flynn, C. B. and Chalmers, J.A.
The Social and Economic Effectsof The Accident at Three Mile Island Seattle, Mountain West
Research Inc, 1979.
(See especially sections 4.3 - 5.3.
These authors mention a pending long range study of realestate values in the TMI area, but give no further information other than Pennsylvania State University as the siteof the research.)l1Flynn and Chalmers,

op. cit.

9Bromet, Evelyn.
Preliminary Report on the Mental Health ofThree Mile Island Residents.
Pittsburgh, PA, University ofPittsburgh School of Medicine, Department of Psychiatry,
1980.

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OP.

CIT.

-13-

-14-

pressure groups.12 We also know that the general level of political involvement in the population is relatively high,,•and that
it is related to georaphical proximity to TMI.3

RECOMMENDATIONS FOR PLANNING ACTION,It is clear from the previous section that much important
information is lacking, and that maximally effective planningcannot take place without more being known.
But it is also
true that specific steps can be taken by planners with theinformation that is now available, and that those steps would
considerably enhance Government's ability to deal with TMIlike situations and to manage such crises when they occur.

Finally, has TMI stimulated the emergence of new groups
Has it changed association patterns(both formal and informal)?
for friendship patterns in the community? Has it brought abouta new set of community leaders? Previous studies of disasters
indicate that such changes do take place, but the "staying power"
Since deciof those changes has not been carefully researched.
sions relating to TMI have and continue to cause public controversy,
and probably will for some time to come, TMI related social changes
Also, they may result in nek relationships
may be permanent.
All of these changes
between the Public, Government and Utilities.
may have considerable impact (positive and negative) on stresseffects, on people's ability to cope, and the way in which people
organize their lives.
12

Flynn and Chalmers,

13

Houts, Peter S.,Miller, Robert W., TokuhataGeorge K. and Kum,
Shik H. Health Related Behavioral Impact of the Three Mile
Island Nuclear Incident, Part 1 Pennsylvania Dept. of Public
Health, 1980.

OP.

The recommendations in this section emanate from specificfacts which were uncovered by those who researthed the TMI
accident.
In brief, those facts are:1- The telephone can be an extremely important tool.for
the collection and dissemination of information during crisis
situations.
Many of the studies reported here relied on thetelephone as their main data gathering tool.
The experience of
these researchers was that people will answer their telephones,
and that they will volunteer considerable information concerning
their needs, feelings, and beliefs.
In addition, it is significant that during the entire TMI accident, the telephone system
continued to operate.

CIT.

2- During the TMI accident people acted reasonably on thebasis.of.what they believed was true and how they felt about it.
Most were suspicious of instructions and information theyreceivpd,. and many were willing to evacuate.
Thus govenment
leaders were faced with a situation that made it very difficult
to "artifically" manipulate people's staying or leaving theirhomes.
3- Left to their own devices, the organizations in chargeof managing TMI-like crises are ill-prepared to do so, both interms of disaster planning and inter-organizational coordination.
4- Concerns about family members played a major role indetermining people's attitudes and behavior concerning evacuation.
5- Considerable segments of the population are able toevacuate on their own, and have places to which they can evacuate
themselves to.
On the other hand it is clear that many people do
not have the ability to evacuate at will, nor do they have an
obvious place to go.
We believe that these facts.dictate that the following actions
can be taken:
1- A system should be developed which will quickly allow
government officials to use a "random telephone survey system"in order to:
A - monitor citizen needs and activities during acrisis,B - evaluate where plans concerning evacuation arebeing carried out effectively,

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• -16-15-

7 - Specific plans for the evacuation of small children
This should involveand their mothers should be established.
education of such parents as to the necessity of theirevacuating, this in turn suggesting the need to have a preestablished destination and means of getting there.

C - assess public beliefs about the adequacy andcredibility of information they are receiving.
If appropriate random representative sampling is used,
several surveys could be taken each day without fear ofbothering any household more than once.
The actual numbers ofcalls needed in any given survey would be relatively small, andthe precise number could easily be determined with the adviceof an expert in survey research.
Finally, the length of eachsurvey could be quite short.
Each call should take no morethan 10 - 15 minutes, if questions are carefully chosen.
2 - Plans should be made to coordinate the disseminationof public information about the crisis.
Given turmoil in suchsituations, the pervasiveness of the media, and the numbex ofpeople and agencies that can become involved, it is not reasonable to channel all information through a single source.
Still,
particular highly credible officials should be designated, andall efforts should be made to channel the dissemination throughas few of those sources as possible.
The public should beknowledgeable about information dissemination plans before thecrisis.
3 - Information should be compiled as to which members ofwhat community organizations would be willing to serve as information conduits, and how any system involving them might be
activated in a crisis.
As an example, how might information
about a nuclear accident be transmitted to local police forces,and how might the police be used effectively to answer people's
questions about the latest events?
4- A review mechanism should be established to make surea.) that people are given the best information available, andthat b.) they are told precisely how reliable that informationis.
The assumption must be made that in the short run people
will act rationally if told the truth, and that such a policy
will in the long run establish the credibility of information
sources.
5 - Plans for evacuation should consider how to bringfamilies together.
This must involve coordination with schools
and with work places.
If this is not done, considerable telephone
use and travel time may be wasted by people who want to unite
themselves with their family members.
6 - A complete and updated list
should be kept of all
institutions that house people who cannot or should not evacuateon their own, including those in prisons, hospitals, residential
treatment facilities, geriatric homes, and the like.
The listshould be maintained by whoever has overall authority forevacuation plans, along with specific plans as -to where suchindividuals are to be moved and how.

A-?SflTable of Contents

Sumnmary of Completed Studies .......................

1

Major Implications of Completed Research ............

4

Bibliographical5

Information on Completed Studies ....

Additional Studies ..................................

6'-1

Summary of Research Completed on thePsychological Affects of the Three Mile
Island Nuclear Accident. *Prepared by:Jonathan A. Morell, Ph.D.
Hahnemann Medical College and Hospital
112 North Broad Street
Philadelphia, PA 19102

For:
Department of Public Welfare
The Office of Mental Health
Division of Planning and Evaluation

Many of the studies listed in this summary contain much data which has not been analyzed,
All research reported here has, however, analyzed dataor has not been analyzed'fully.
to the point where some conclusions can be drawn.

-2Population, Time of
Study and Principal Author
4.

Residents of TMI
Area, Primarily
Within 15 MilesTime:
Author:5.

Discriotive
Title
Telephone Surveyof Resident in the
TMI Area

July 23-August 6
Flynn

General Populationof TMI Area,
Mothers of YoungChildren, TNT Area,
Mothers of YoungChildren,

Structured
Interview,
Carefully Drawn
Random Sample
n = 1500

The Credibility ofGovernment
Officials in the
Aftermath of TMI

Structured
Questionnaire,

Demographic andAttitudinal
Characteristics
of TMI
Evacuees.

Phone Survey,
Random Sample

Wilkes-Barre

Time:
Author:Methodology.

n's for eachsample:494,
428, 368

Summary of FindingsConsiderable amount of stress andupset imnediately after the accident
and continuing during time of study(Summer, 1979).
Local Information
sources (media and officials) weremost trusted.
Approximately half of
respondants were not satisfied withinformation.
Satisfac.ion increased
with increasing distance from TmII.
Very considerable distrust of
government officials and utility
company statements concerning safety,
the true magnitude of the problem, et.

June-JulyGoldsteen

S. Adult Populationsof Middletown,
Marietta andElizabethtown

n = 290

Younger people more likely to evacuat,
Proximity~to TMI also a factor,
people living closer more likely.
to leave.

Time:

First
Week of
April

Evacuees felt more negative thannon-evacuees about TMI, nuclear
power, etc.

Author:Kraybill

Little faith in information given
about accident.
In general, appro.alrates run about 50%.

C.'1

c

SUMMARY OF COMPLETED STUDIES
Population, Time of
tudv and Principal Author

Discriptive
Title

Adolescents in the
TMT area (junior andsenior high school
students)

Reactions ofAdolescents to theThree Mile Island
Nuclear Power
Plant Emergency(Report Prepared
for President's
Commission)

Time:
Author:May
Bartlett

Residents of Carlisle, Social andChildren and Adults
Psychological
Effectsof TMI
Time: April-September',thor:Bechtel-_learWorkers *i TMI and
Pcachbottom
Time:
Author:AuqustDohrenwend

Psycho-social
Affects of TMI on
Nuclear Power
Plant Workers

Methodology

Summary of Findingsn = 632

Affective domains measured.
Ordering
as follows (high to low):
concerned,
worried, disturbed, anxious.
Psychosomatic symptoms also measured.
Reported overall symptoms:
headache23%, loss of appetite 18%, increased
eating 13%,others at less than 10%.

Open-ended,
AnthropologicalInterviews

Only cursory data analysis isavailable.
Evidence suggests a lotof stress among population.

Structured
Questionnaire

n = 500
Structured
Questionnaire

In general, workers had more trust in
plant officials than did the general
population.
Their trust in otherpublic ofticials matched that'of thegeneral population.
TMI workers weremore demoralized than Peachbottom
workers, Perhaps as a result of public
attitudes.
Unlike general population,
demoralization did not return to normi*This study is part of the technical staff report on behavioral effects to the President's Commission.
The findings of some of the other studies on this list
were Also reported in the President's
Commission Report.

-4-

Implications of Completed Research

1.

Present research indicates that the TMI accident, led to a considerable amount of stress among
It is important to monitor the longer termeffects of that stress as they
the population.
relate to mental health; the way people behave, and their attitudes towards political and social
The data also indicate that stress and its effects was not uniform across all sectors
issues.
Thus, differential stress effects on various groups (young, old, mothers,of the population.
power plant iw'orkers, etc.) must be taken into account.

2.

The data indicate a good deal of mistrust of information that was given out during the TMI
Ih addition, local information sources seemed to be more trusted than other sources.
accident..
It would be extremely useful if the dynamics of "trust in information" among the population
could be studiec.
These studies should be done for the purpose of determining how information
aboutT.IZI could be transmitted to people in an efficient, accprate and believable manner.

3.

Evacuation behavior is nct consistent across all social or geographical sectors of theIt would be useful to know more about this phenomenon so that appropriate andpopulation.
Non-evacuation or premature evacuation
timely evacuation can be carried out when necessary.
can cause serious problems.
Studies should be conducted which would lead to minimizing such
behavior.

-3-

Population, Time of
L an Princi1pl Author
7.

Adults (Taxpayer
List) in ;ewberryTownshipTime:
Author:

Discripive
Title

Newberry TownshipStudy':
Need For
Health Monitoring
Study

April
Newberry

Methodology
Telephone Survey,
Closed-end
Questionnaire andElicitation of
Spontaneous
Responses

Summary of Findings
Strong interest in health monitoring
project, assurances of safety
notwithstanding.
Belief in President
Commission Report:
Yes

Mo

Complete'

13%

49%

Truthful

25%

42%

Factual30%

30%'Township

Board ofSupervisors

8.

Adults in
Middletown
Time:

Author:ElFirst 3Weeks of
April
Smith

Voluntary
Withdrawal FromTMI Area Among
Residents ofMiddletown

Structured Phone
Interview, 123
Respondents
Systematic Sample

Evacuation seems 'related to faith ininformation givers.
Those who
evacuated had least amount-of faithin.those who gave information about
the accident.

-6-Additional Studies
in addition to the studies listed above, other studies were done which for methodologicalreasons are highly suspected.
Descriptive titlesof these studies are listed here in orderto give a sense of the types of issues that people saw fit to study.
1.
2.

Utilization of Mental Health Service's during the Four Months After TMI.
The Impact of TMI on Demand for the Early Childhood Intervention Program at
Holy Spirit Hospital.

3.

Emergency Room Utilization during the TMI.Aftermath.

4.

The Effects of TMI on the Attitudes,
Young Children.

Behavior and Adaptive-

Coping in

Bibliographical Information on
Completed Studies

Bartlett,

G.S.

Reaction of Adolescentsto the Three Mile Island Nuclear Plant Emergency(Report prepared for the President's
Commission on the Accident at Three Mile
Island)Hershey Medical Center, Department of Pediatrics and Behavioral Science,
1979 (Commission Report available through the U.S. Government Printing. Office).
Bechtel, D.R., Kassovic, J., Kassovic, M. and Malmsheimer, L.
The Reaction
Reactor Accident -'A General Population Study, Unpublished flanuscript,
of Religion, Dickenson College, Carlisle,
PA, 1979.

to theDepartment

Dohrenwend, B.P. et al.
Report of the Task Group on Behavioral Effects to the President's
Commission on the Accident at Three Mile Island_ .1979 (Commission Report available
through the U.S. Government Printing Office).
Flynn, C.B.
Three Mile Island Telephone Survey:
Preliminary Report on Procedures andFindings.
Mountain West Research Inc.,
Seattle,1979 (NRC Contract #04-78-192).
Goldsteen, R.,
Officials

Schorr, J.K., and Martin, J.
The Credibilityof Government and Utility
in the Aftermath of Three Mile Island. , Paper read at the Annual Meetingof the Pennsylvania

Sociological Society, University of PA,

November 2 - 3,

1979.

Kraybill,

D.B.,
Buckley, D., and Zmuda, R.
Demographic and Attitudinal
Characteristics
TMI Evacuees.
Paper read at the Annual Mleeting of the Pennsylvania SociologicalSociety, University of PA, November 2 - 3, 1979.

Newberry Township Board of Supervisors
Newberry Township Study on Need
Monitoring.
Address of Board:
RD 2, Box 4, York Haven, PA
17370.
Smith,M.H.

The Three Mile

Island Evacuation:

Voluntary Withdrawal

Power Plant Threat.
Unpublished Manuscript,
Anthropology, Long Island University, 1979.

for Healthfrom a Nuclear

Department of Sociology andofI
Citizen Comments
NUREG 0683
Page 2
Citizen Comments
NUREG 0683
November 19, 1980

That waste is not going. anywhere - not to Nevada or Washington
or South Carolina.
It is not going to disappear, not for hundreds andthousands of years. You can concentrate it, dilute it, vent it, disperse it,
dump it, repackage it, compact it, store it, fill
it with cement, or move it.from building to island to state. But it is not going away.
The PEIS talks
only about the above manipulations.
We want it contained and maintained.

The Draft Programmatic Environmental Impact Statement is aplan to clean up TMI.
That sounds good, and at public meetings
everyone has agreed.
We are making a mistake.
I don't believe thatis what we want.

Some of your suggestions are practically obscene.
Take evaporationfrom ponds to create a radioactive fog in a stagnant air basin inhabited bypeople.
That
isasolution?
100,000
When you were challenged in hearings about solutions of this type,youusually replied by stating that this was not your first choice among thealternatives you presented. Why then are they presented at all? Whatis the PEIS supposed to be doing - brainstorming all sorts of wild ideas, orpresenting viable alternatives which could be implemented by the licensee?
In addition, are you honestly suggesting he pick "none of the above." I'm confused.

I am reminded of the statements made by the Governor's Commission
on TMI.
"Clean it up," they said. And then they went on to elaborate,"by venting the Krypton, the sooner the better."
The Krypton is cleaned up all right.
It's
not around to botheranybody in the containment building any more. That's because we've
got it in our air and maybe in our bodies. And you make more ever' week.

If you are truly brainstorming, then let's include everything.
Let's include polluting the Chesapeake Bay and its food chain for thousands ofyears, perhaps even destroying the eco-system of the whole East coast. If
you are really going to present Worst Cases, let's include Recriticality and
They did it with stored
wiping the Commonwealth of Pennsylvania off the map.
waste in Siberia - it could happen here.

Cleaning that place up and containing the radioactivity can be
two entirely different things. We should not be mislead into proposing
and supporting the superficial goal of Cleanup. What we are reallytalking about is HOWBEST TO CONTAIN THE LETHAL BYPRODUCTS OF A CLASS 9ACCIDENT.

The PEIS proposes to be a serious scientific document, but it has
a few lapses (like putting TMI in Lebanon county on the map).
More importantly,
you cannot say on one page that you may release anywhere from 30,000 to 300,000
curies of radiation and on the next page say it will produce exactly 1.6 millirema.
Does a variable that diverse produce an absolute figure?

You admit - and we know - that you don't know what is in thatplant. We know that everything you say in those 500 small-print
pages is based on a guess - an educated guess, yes - but because thishas never happened before, a guess really no better than mine.
That is why I resent your devoting page after page to outlining
the environmental impacts down to the last millirem x 1014.
Couching
your guesses and your gambles in scientific jargon does not make me
any safer or protect me any better from genetic damage, degenerative
disease or cancer.

Even if I accept your figure, you've left out a lot of exposures.
Just how many waste truck drivers with how many loads, driving cross-country,
will get how much exposure? Protesting that they do it at their own riskbegs the question.
How many members of the public may stand three feet fromthose trucks at how many stoplights and for how long? How close will thosepolice escorts ride? How many accidents will happen in how many crucial
places? Can you be sure those casks will drop less than 30 feet? That they
won't be defective? Who will clean up those accidents and how long will ittake them? How about those wooden boxes of noncrushables- don't they break open
in accidents? And how much radioactivity is contained by a wooden box anyhow?
Have you counted the people exposed as they load and unload and guard those
shipments - and for how many hundreds of years? And lastly, how many generationsof people living near Hanford and Beatty and Batnwell did you include in that
offsite exposure?

I give you credit for trying, but let's be honest:-- You don't know what is in there-- You don't know how to get it out of where it is-- You haven't invented anything safe to put it in when you do-- You have no safe way of getting it to where you might put it-- And you haven't a place to put it when you get it there.
That waste isn't going anywhere,so let's start talking about thesafest way to protect and maintain it where it is.
Pf, course thisis a lousy place to leave these wastes.
Believe me, I am the first person
to want it out of here and as far away as possible.
But where? How?
You declared the Susquehanna River Basin a Sacrifice Area the moment you
allowed the first pencil to be put to the first plan.
We know the monster is cooling down now.
It has structural protection
we can't buy (the containment); it has mechanical protection (decay heat
system); it has chemical protection (borated water).
Why don't you discuss
how to maintain that Containment building and that reactor vessel rather
than considering putting it in barrels in makeshift bunkers on a floodprone lower island? Why suggest a No Action option without maintenance?

A-285

How can you confidently state that offsite exposure won't add asignificant amount of radioactivity to our bodies? What is significant? You
have no base line to know how much we got before the accident.
You never publicly
discuss what exposure we got from those two operating plants (except to say that
we got much less Krypton last summer than we'd normally get from an operating plant).

ICItizen Comments
NUREG 0683
Page 3You confirm that every day Peach Bottom discharges radioactivity
into the Susquehanna "which meets safe drinking water standards.'
Every weekly operating report cites liquid effluents released from
Unit I "within limits specified by the technical specifications."
How much safe radioactive water is too much for the people downstream
to drink?
Where are the studies you have done since the accident on
our physical health? Where can I read them? I don't want to hearstatistics on what I should have gotten or how much I would have gotten
if I divided my dose up with everyone who lives 50 miles from here.
I
didn't.
At the very least give us objective evidence that the people wholive within sight of those "damn chimneys" did not get more than theyshould have had already.
Confirm this not by statistics, but by closeand continuing monitoring of their health.
Then let's talk about thesignificance of additional exposures.
I shudder at every mention in the PEIS that says you will
limit exposure to As Low As Reasonably Achievable.
I know what thatmeans-it means we'll try to keep it down but if we can't do what wewant without overexposing you-tough.
I don't like reading that the dose I will get from a particularbperatiog is o.k. because if it were divided up over a whole year it
would be within safe limits. Because in the next sentenae you say
it won't be divided up over a year. It will come out in one blast
which may be 500 times greater than that safe level.
That's statistics,
not my life and my health. That's an Alice in Wonderland environmental
impact statement.

November 21,
Dr. Bernard J. Snyder
Program Director, TMIA Program Office
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Cosrmission
20555
Washington, D.C.

Dear Dr. Snyder:
We have just become aware that the Nuclear Regulatory Commission's draft
programmatic environmental impact statement, NUREG-0683, contains no discussion of potential worker exposure for the entire clean up at Three Mile Island.
We view this as a very serious omission which reflects an inadequate consideration of radiation dangers to those workers who are now employed at Three
Mile Island, as well as to the many more who will be employed at Unit Two during
the long and potentially hazardous clean up process.
We regret that we have missed the announced period for public comment on
the draft EIS, which passed on November 20. We need, however, to point out thisvery serious omission.
We look forward to seeing a revised draft that will address our concerns,
upon which we can comment.

Don't misunderstand.
I don't want that reactor to go critical.
When you say you must fix a fan and put in a new monitor, I say do it.
If you have to drain out some of the water in the sump to keep theelectrical system from conking out, go ahead. We're willing to discuss
taking those risks. But can we be positive you are not crying wolf?
You told us you had to vent the Krypton to fix those things. That wasJune and it's
now almost December and nothing has been fixed.
How about a real environmental impact statement that deals withthe safest healthiest way to decommission this monster, not just clean
it up? I am insulted by a PEIS which pretends to say how my government
will best protect my health and safety - while offering MetEd a cafeteriaof options detailing how it can best dump radioactivity into the air I
breathe, the water I drink and the ground I grow my vegetables in.

1980

Andrew L. Stern
President

ALS: red
UEU-Local #1

Beverley Davis
200 Gettysburg Pike
Mechanicsburg, Pa. 17055

pennsylvania social services union*

1037 maclay street * harrisburg * pa 17103

andrew 1.stern, president * jane perkins, secretary-treasurer
717.234.4113

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Washington, D.C. 20555, I tELIThe.
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Pennsylvania
1980

Re:

Draft Environment Impact-Statement
Three Mile Island, Harrisburg

Dear People:. Tx

As a victim of the accident at Three Mile Island, my only comment for the
Draft Environmental Impact Statement is not one of "expert opinion." I speak
on behalf of the many in the 100 mile radius of Three Mile Island who attempt
to garden or farm in an organic* fashion. Surely there is no area on this green
earth exempt from man's (and in this case, it is truly "man's" doing) pollution in the soil, air and waters.
Yet in Pennsylvania, we have the only environmental
constitutional amendment in the nation that states:

bemaOse if
g+to~es oWA-+h-oc-e-i rnoK.U)+-aNKC, -Jmuld bot hihxhy e&-rbarrau"d. Who
kmuors, rr-oVbA_ yolk 5"~S Lx•ffl\ 5Lrpri•- rne-1"The people have-a right to clear air, pure water, and to the preservationof the natural scenic, historic and aesthetic values of the environment.
Pennsylvania's public natural resources are the common property of all
the people, including generations yet to come.
As trustees of theseresources, the Commonwealth shall conserve and maintain them for the
benefit of all the people."

4-2J Spn,-o• b-Teet-

Need more be said? The impact on the local environment is and will continue
to be atrocious.
To deny that the levels of radiation will not affect thehealth of our children, livestock and pets is plain stupid. Certainly a person
doesn't have to have a degree to realize that everything in this world is connected.
Everything causes a reaction. Radiation, gases of questionable safety, chemicals all has a huge negative influence on living organisms.

ýAiddleftwvn ,PA.

I beseech you to move gingerly with the clean-up of a messy situation.
beg you to consider the safest way to avoid any unnecessary exposure to theenvironment.

I

May God guide your way.
Sincerely,
V•

J

Debbie Fetterman
cc:

Mr. Gus Speth, Executive Director of Council on Environmental Quality
Congressman Allen E. Ertel
Congressman Bill GoodlingThree Mile Island Alert*As defined by Webster's New Collegiate Dictionary (3a-2) - Organic: relating to,
produced with, or based on the use of fertilizer of plant or animal origin without
employment of chemically formulated fertilizers or pesticides.

A-"AICity of Zancaakz~s£PAnnsylv~arzia

120 'I'ý'ýdusE

November 19,

U. S. Nuclear Regulatory Commission
November 19, 1980
Page 225k-t,

gP.LD. Box 1559

77603

that natural evaporation from a 'pond would befeasible (evaporation of approximately I million
gallons per year from a 53,000 SF pond, 265' longby 20' wide by 7' deep).
However, even if one
accepts the statements and conclusions concerning
equivalent evaporation and rainfall accumulation, it
must be recognized that they apply to the volume ofwater rather than the amount of tritium. Depending
upon the time of year evaporation begins, weather
conditions and similar factors, the tritium levels
should be reduced to 35-50% of the original amountin a 12 month period.
If radioactive decay is also
considered, a storage period of 2-3 years would reduce the tritium level to below 10% of the originalamount.

1980

U. S. Nuclear Regulatory Commission
Washington, D.C.
20555
ATTN:
RE:

Director, Three Mile Island
Program OfficeComments on the Draft Programmatic Environmental
Impact Statement Related to Decontamination and
Disposal of Radioactive Wastes Resulting fromMarch 28, 1979 Accident
Three Mile Island Nuclear Station, Unit 2
Docket No. 50-320(b)

No increased risks are specified for this alternative,
and no details are given as to possible methods ofhandling and transportation.
These details should be

Dear Mr. Snyder:
We believe the EIS is deficient in the following four areas:

provided,

We believe that the EIS
1. Cumulative radioactive discharges.
should include a detailed discussion of the cumulative radioactive discharges to be expected in the Susquehanna River in
Particular attention should be given to
the next decades.
the cumulative radioactive discharges to be expected from
Only
nuclear power plants operating and soon to be operating.
against this background can the effect of any future discharge
from TMI Unit 2 be evaluated fairly. Our concern involves
both the total Curies present in the water, plant life andanimal life and the radioactivity levels, past, present andfuture.
2.

(c)and subject to comment.

Solidify with chemical agents and retain on site insolid form as a concrete slab.
Again, no increased risks are specified, and nodetails are given about handling.
Any problems known
to the NRC staff should be specified in detail, andsubject to comment.

3.

In paragraph 5.2.2.2 of the EIS, eight
Disposal alternatives.
process water disposal alternatives are mentioned, but several
We believe the followingof these are discarded summarily.
alternatives should be elaborated upon:(a)

Solidify with chemical agents and ship to licensed
burial ground.

Release to the air via natural evaporation from a pond.
We disagree with the statements concerning the viability
Our own experiof evaporation as a disposal technique.
ence with evaporation of water reservoir sludge indicates

A-292

Psychological stress.
We believe the EIS seriously underestimates, the psychological stress which will be experienced
by water users downstream of TMI if processed radioactive
water is released to the river. We believe that 20% to 40%of the people in Lancaster will experience significant longterm psychological stress if accident-generated water isreleased to the river. Because of City concern and customer
reduction, pumpage from the Susquehanna facilities*was reduced
from 12 MGDto 8 MGDafter the TMI accident. We feel that therelease of accident-generated water would result in a longterm decrease in customer use of our water.
A recent Universityof Pittsburgh study indicates that long-term psychologicalstress has been underestimated by previous studies of theaccident and its aftermath.
(See the attached article concerning the study).
We strongly urge that local release to
the river of processed water be rejected as an alternative.

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1980

The psychological stress which would be experienced by alarge proportion of local residents would be unacceptable.
Dear

4.

Costs of alternatives. We assume that at some point the
Estimates
costs of various alternatives will be considered.
of the costs of the alternatives should be specified indetail, and should be subject to public comment.

SiTS,"Uraitýnvirjrmnnntaio0Dailyý

t!a rI'r.,sa-e O[sccv:> nctelectr.cal

and renewableof nuclear power.

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Arthur E. MorrisMayorinaaequacies:,isniormation b.' bothand theindustry andSincerely,islanJ,*inoree Lile

toe public

The above matters should be addressed directly, clearly, and indetail and the Commission's draft comments on such matters should be
subject to public comment.

:,pact Statement".

oetail theZxpCrts•

We support the rejection of the "no action" alternative.
The indefinite use of the TMI site as an uncontrolled waste storage or
disposal facility is totally unacceptable.

regards to theconcern 'nm:isn to express mysave us from tue

Sellproblems

will be iore rapid whenoi._cials

recognize

and acnowleuge

the truth about renewables and the nuclear ::yths.

NOTE:

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is copyrighted.

verys.,.;ly,

no regard

to cost,environment
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-2-

Comments Received at November 10, 1980, Meeting with Pennsylvania Citizens
Harrisburg, Pennsylvania

linear extrapolation is too conservative.
This is according to Arthur
Upton, who was recent Director of the National Cancer Institute.
Inthe past we have heard false promises from the old AEC concerning any
fallout in Nevada and Uath.
We've also seen past, quote, "safe," endquote, levels of pollutants in every new industry, and these have become
obsolete with time.
Do you honestly understand our concern? And I'll openthat up to anyone who would like to comment, and specifically on the solidification of the treated water, but anything else you would like to commenton also. Does anyone here have any data on release of tritium in themonths we are talking about into human beings and follow-un data thereon?
I am talking about, is there any known data in the literature concerninq
imbibiding water with concentrations of tritium such as we will see if thiswater is released into the water? Is there anything on the books, anythingscientific? That's all I have concerning that, and I would like to get on
to another subject, if I may. This is concerning solidifying or stabilizing and solidifying the radioactive cesium in the Epicore-2 resins, which is
a completely different thing than solidifying tritium. And I would like toread to you for the record some of the conclusions from a Brookhaven
National Laboratory report which I have received.
I understand that thisreport is not being quoted with great openness by the MGPC. It is entitled"Status Report on Leachability, Structural Integrity and Radiation
Stabilityof Organic Ionic Exchange Resins Solidified in Cement and Cement with Additives," dated May 1980, by R. E. Barletta et al.
And this is more or lessa summary from their report: "The first stage Epicore-2 resins from
TMI-2 will have cesium 137 activities, approximately 40 curies per cubic
foot, that are about 1,000 times greater than the concentration guides
for shallow land burial sites.
The total inventory is equivalent to about
20 years production by a pressurized water reactor such as TMI-2."
Someof their conclusions include -- and there were others, but I chose thosethat I thought might be more pertinent:
One -- and this is from the
Brookhaven National Laboratory, I might add -- they weren't able to findany study which answered the questions they felt pertinent to shallow
land burial for this high specific activity and quantity of the firststage TMI-2 resins.
Two, they were not able to find leaching data on
samples larger than about one liter. The two types of TMI-2 containers
are about 1400 liters and 4800 liters. The literature on vermiculite andziolite additions to cement-resin waste mixtures is, quote, "nromisingbut sparse."
Four, the fundamental processes causing radiation
damage in resins are not understood.
TMI-? resins would undergo significant decomposition specific to resin type.
A moderate level of gas
generation as a result of radiolysis will occur.
Substantial liberationof radioactive cesium from resins will occur immediately after mixture
with cement.
Number five, they believe this type of resin waste shouldbe treated by thoroughly understood more stringent waste management
procedures.
I would like to combine that, if I might, with one
paragraph from a source entitled "Inside NRC," October 6th, 1q80: "In
March 1980 GPU President Herman DeCamp warned that it might prove difficult or impossible to solidify the Epicore-2 resins left from decontamination

First, I'd like to just read for the record an
DR. ALLEN PETERSON (Tr 9):
article that appeared in "The Intelligentsia Journal," Lancaster paper,
Friday, October 31st, 1980, entitled "Long-Term Depression Prevalent in
Mothers Living Near TMI Plant." And I just want to read a couple ofparagraphs from this article for the record: "Many mothers of young children living near the scene of the nuclear accident at Three Mile Island
suffered long-term depression, according to a study which contradicts
previous findings that mental stress resulting from the accident was
short-lived." "I think" -- this is a quote now from the physician who
did the study: "'I think our study shows that they were wrong,' Dr.
Evylin Bromit of the University of Pittsburg said at a press conference
Thursday."And I quote again: "'There were long-term effects.'" Once"'25 percent of the mothers at Three Mile Island showedagain, I quote:clinical levels of depression or anxiety during the year following theaccident,' Dr. Bromit said, adding that '12 percent of those with proResearch will continue over the next threeblems sought professional help.'
years to note the duration of the mental problems.
"The study wascommissioned by the National Institute of Mental Health, at a cost of about$375,000. "Pennsylvania's Welfare Department called the study ' the mostauthoritative and detailed' of any so far completed on the health' effectr
At theof the nation's worst commercial nuclear power plant accident."
Lancaster meeting, which I could not attend, there was a recommendationfrom someone there that there be a public meeting such as this held at a
local place after Met Ed has suggested what to do with the water from
TilIand after the Commissioners have decided what to do also. And I
Mr. Collins, I thinkwould like to also add my.plea for such a meeting.
that at that meeting in Lancaster a question was posed that you were notable to answer at the time, and hopefully you can now. And the question
is:- Does the present Clean Water Act prohibit discharge of radioactive
waste into navigable rivers? I would like to make a plea that theYour reason for not wishing totreated water not be released into the river.
solidify the waste water, as given in Section 513, and I quote: "This
option would require the reactor site to be qualified as a low-level waste
I would like to point out that TMI is already a high activity
disposal site."
Certainly, solidification will take up somewaste disposal site by default.
But I think the major problem to Met Ed, of course,
space on the Island.
I would rather that the water not be released, as thewould be the cost.
The fact
health consequences of radioactive wastes are not fully known.
that within a month of the release of the EIS you had already increased thea third
of
one
and
by
a
factorrisk of cancer deaths and genetic defects
Your assumption of calculatingadds to the uncertainty of the situation.
a linear dose-effect curve at low and lower doses -- at lower and lowerSomedoses -- is an issue that scientists have now completely agreed upon.
Others feel that the bulk of radiobiologicalreasonable.
feel that it's
evidence indicates that for low linear energy transfer radiation, the

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get into this, you know, I think it is ridiculous to sit here end tell thepeople that Met Ed is going to be given a choice as far as the
choice is concerned, as far as the costs are concerned. Hell, we areinterested in getting rid of the stuff and disposing of it in the safest
method. And however you're going to do it, you know, let's 00 it insuch a manner that they are not going to be able to take a part of it
and flush it into the riser or send it into the atmopshere.

of difficult" -- I'm sorry -- of 500,000 gallons of, quote, "intermediately
contaminated waste," unquote. Last month's "Inside NRC" says: "Researchers
in the waste solidification field are urgently warning that radioactive
decay of isotopes stored in 49 of the 69 canisters on the site may be causing the resins to degrade from a granular form into a jelly or molasseslike matter that could emit gases and, due to high acidity, may corrode
the carbon steel containers rapidly. Uncertainties about the qualityof the epoxy coating of the metal-lined containers adds to the concernthat these resins will soon be a critical radioactive waste problem atTM!, one for which the research community lacks solutions other thanthe possibility of on-site incineration. "Each canister is believed
to contain 1,000 to 1300 curies; in all , some 50,000 curies, mostly cesium137." Would anyone like to comment on what I have just said conerning
the solidification of cesium". My next question, do you have a centralized registry of the migrant nuclear workers' radiation exposures?
In other words, as they traveled from state to state, as one plant closes
down to be cleaned up, I'm just wondering how this is followed so thatthese people are not overly exposed, or at least it can be recognizedin time so that they can be told at the new facility that they cannot
work, because they have already reached maximum exposure. Since thecitizens of the state of Washington have voted to allow non-medical
nuclear wastes to be placed in their state, what is your alternative totransferring low-level wastes there, taking for granted that the courts
will not overturn the democratic wish of the people of the state ofWashington? I just have two short questions, if I may. Is it possible
to run a nuclear power plant on the site of high activity waste storage
outside of spent fuel pools, with the existing regulations within the
NRC at the present time? And my last question. I am just wondering
where the Epicore-2 resins are presently being stored today at TM!.

PAULA KENNEY (Tr 31): I have one short question to ask you, and that is:
You have asked us to give you our comments, and I would just like to know,
are our comments going to have as much weight as they did concerning theventing of the krypton?
JANE LEE (Tr 33): I want to address something to you, first Mr. Glilinsky.
I sent a letter to all of the Nuclear Regulatory Commissioners regarding
an incident on 83 where two nuclear chemical trucks were traveling and sprayeda gentleman and his 12-year-old son's car, when the gentleman tried to pursue
the truck to call to the attention of the driver that his car had been sprayed with some debris, he had to get his car up to 80 miles an hour and was
unable to catch that truck. He didn't even get the license number. I received a reply from the public relations, a man by the name of Inqram,
informing me that my letter would be forwarded to the NRC office at TM! andthat there were no provisions within the Nuclear Regulatory Commission
to take care of shipments. I have real problems with that. I also haveproblems with the idea that we write to the Commissioners, some of whomI
believe are genuinely concerned about what is going on down here, also theviolations prior to the accident. I think there are a few. Unfortunately,
they are outvoted on the NRC. My reservation is,we write to you, but you
never see-our letters. !t's the same way with the President of theUnited States or anybody else. What becomes of our country when we get tothe point where we know that our lives are in danger, that the children'
lives are in danger, there is no one responding, there's no one watching
the store? Then what? How long can we endure as a democracy, as anation with a Constitution of the people, by the people and for the people
that guarantees us life, liberty, and the pursuit of happiness, when it
is all eradicated, when we continuously watch the bureaucrats with theirblinders on, suffering from tunnel vision, who continuously respond in acold-blooded manner and wipe everything away with a wave of the hand as
if, who are we, we are expendable?. All though these hearings, all we haveheard, all that has permeated through the discussions -- and I haveattended many, many of them -- is ensvironmiental impact. What is an environmental impact? Is it to establish how you are going to try to fix Unit 2,
to clean it Up? I always was under the impression that an environmental
impact was to discover what is in the envirornmental, so that we can establish
what is already there, to make a comparison to the damage.. We don't evenknow what happened or what was in the environment prior to the accident.
There is a very superficial report, just so everything is in order, let'sgo by the book, fellows; let's make sure we've got it in file. It doesn't
make any difference whether we actually did it or not. Just make sureit's on file. Now, I've talked and I've talked and I've talked, before
the accident even happened, about what is going on in the environment.
And I have yet -- and I am still waiting for the first person to comedown other than Mr. LaRoche from the NRC. I am waiting for the first

DAN PEFLY (Tr 24): My question would be relative to the conversation
here with reference to the disposal sites. I would like to know theeconomic feasibility of the Metropolitan Edison Company to seek, at thecosts probably necessary, sites in the western part of the country todispose of this irradiated material. There's talk now that they'regoing bankrupt. I mean, they have to raise their rates, double theirrates now, as far as service to their customers is concerned. Whatassurance do we have that they are going to be given a choice to get into
this? If we the taxpayers have to foot the bill to dispose of thematerial , then you fellows who have the technical knowledge should be
the ones to make the choice and not the deflunct and sorry, but inas a hazardous
credible company at this particular point. I look at 1141
waste disposal site. You know, your spent fuel cells are here. Your
unspent fuel cells are stored in crypt that was constructed for that
purpose; are a potential hazard to the community if something would
happen to that crypt. So they're no different from the chemicals thatwere wasted in Love Canal. They're no different than the chemicals
that were probably disposed of in Devil 's Swamp in Louisiana or in Charles
City, Iowa, or in Henderson County, Tennessee, perhaps as reported in New
Jersey, Elizabeth, New Jersey, as current, you know, as April the 20th,
1980, and in various other sections of the country. And really, when weA-2A)50

-6 - 5now if we don't go to the water? I mean, that's the big problem. That's
what I'm saying. We have not solved this problem. We keep loadingthese things, and when they get the *okay even more will be~started or
built. But we haven't solved problem number one, which is when -- andgentlemen, this is the first, I keep telling you, nuclear -- it is notyour last; it's your first accident. - When do we solve the problem ofwhat we do with this terribly hot material, this radioactive material,
when you should have had that solved before you put the first plant in
operation. That's why we're coming to you for the answer. Why isn't it
done, why wasn't it done? I can see up to the accident. But why are we,
18 months after the accident, still scratching our heads saying there is
no solution? There really is no cafe depository. But we haven't evencome up with a feasible plan that we can offer to these people for hope.
And you want to pollute their water. I can't even imagine, after what
we have taken in the air here and what has gone on here and what we havethat your solution is, if we didn't get you the firstbeen through here.,time, guys, we're going to get your water.

governmient official on the state or the federal level to come down on
the west side of the river and try to ascertain what is going on withthe animals. Now, we have animals going down there, who have gone down,
who suffer from muscle deficiency, who were born blind. We have awoman on the east side who had dogs who were born without eyeballs, multiple
hairline fractures, waterlogged bones. We have animals with constricted
uteruses, constricted birth channels, animals who are retaining theirplacentas and refuse to release then. We have animals who have been born
dead, aborted, kittens in four different fetal stages. And I could go on
and on. And I am telling you gentlemen here right now that I had people
in my home who were born and raised on farms, who are appalled at thestory that I'm telling then. Why Is it that the report that was put out,that I only received today -- I haven't even had a chance to read it.
People are calling me up and saying, open the book, look Jane, look what
they're saying. Well, they can damn well say anything they want. The
fact of the matter is you people do not know anything about low-level
radiation. You haven't taken your blinders off to find out. You refuse
to come into the enviroanment and find out. And even when we tell you,
you go back to Washington and you distort everything that we say.

AL MADDOCK (Tr 53): You have a plant in upstate New York that's beenfor six months. It's in trouble. You have a plant under conshut -down
struction in Texas that you fined the utility for poor quality control,
poor workmanship, in other words. You turned around now, because of thereferendum in Washington, and make Three Mile Island a bigger dump. And-.
m telling you, it's a mess. But you've been listening to us for quite
some length of time here now. Now, I would like to listen to you. What
are your plans for 1981? What are your safeguards, what are your risks,
where are you going? We know where we're at. You're in trouble. But
where are you going? What are you going to do for us? Don't go beyond
the year 1981. . Let's just take the year 1981 and tell me what you're going to be doing in 1981. You've been here long enough now, like therest of the people have been telling you, to have some kind of a plan
shaped up here. What are you going to do in 1981?

ANN SESSA (Tr 42): How many nuclear plants around the country we havegoing right now, fired up and going. And how many more by the end of
next year? And how long has the longest one been in existence, the one
we just phased out down there because it did its job? Now, the otherplants, now well over 100 going to be by the end of next year are nuclear
plants. And still , we have no repository for nuclear wastes. Still, it
took an accident. Still , it took 18 months. And *we are sitting here
tonight saying, what are we going to do with this hot baby, where are wegoing to get rid of it. And we come down with a great answer, that we'regoing to dump some water in the Susquehanna, into the drinking water ofthe people of this area, of Maryland, and the way downstream into thatdelicate area called the Chesapeake Bay, which is the spawning groundfor all of our seafood, where temperature can make the difference in whatlives and survives. I'm asking you: Why can w," have faith in that, when
I could have come up with that plan, with no education, with no nuclear
background, back in 1957 coming out of high school? I could have said,
if you have water in the way throw. it in the river. Now, we were goingto take this repository, this material, up in Washington, until they.
decided they didn't want it. Now our next feasible alternative plan
is to take our hot water, clean it up so that we say we should believe
you now that it's clean enough. We have never, as fareas I know, done thisbefore. Over in Russia, as I understand, they tried to bury some material
in a hurry. .And you want us to stand still for this. And that is what
we are saying, gentlemen. It's not that we are saying y-u're lying.
What we're saying is you don't know any more than we know. And this isa dangerous, dangerous thing you're proposing to get the thing over with.
We all want it over with. But what we are doing is creating crazy, insane schenes to clean it up in a hurry. My God, we have to live with it.
We have to live what that thing down there. We are scared. But I don't
want to pollute the air and the water and everything else that goes tomy progeny when I leave, because I wanted the fast way out. And that. is
what I am saying to you men. Can't you say why? Why was it going tobe Washington until the referendum was ounsed? Where do we deposit It

CARROLL S. EUELL (Tr 64): Are the rods in the reactor up or down? Arethey in the reactor or are they pulled up out of the reactor? Do you
have condensers to cool the surrounding liquid around the reactor? Do
you have any condensers on that reactor to cool that surrounding liquid
down?
JAN EMERY (Tr 69): We have been talking about evaporation, Unfortunately,
everything that -- we can evaporate things, but it isn't going to only bewater vapor that comes up from the evaporation, is that correct, no matter
what method you use? And then there is the compatible, combustible trash~on page 535. It says 99,000 cubic feet they expect in the auxiliary andfuel-handling building. Page 663, 45 to 150,000 cubic feet in the reactor building. And page 843, 35 to 100,000 feet in the refueling and thePrimary system decontamination., And the EIS says, we assume that 75 percent of the compactible trash can be burned. Actually, what it says
is, we assume 25 percent of it cannot be burned. . Page 674, Table 6.618,

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is offsite total body doses for trash compaction and trash incineration.
Now, since this is in the chapter that deals with the reactor building,I assume this is in the reactor building.
It gives a dose for inhalationand vegetable consumption.
Do you want the page again? 674.
Now, thedoses do not seem large because, if you read it, it says millirems per drum.
One of my questions is, is this per drum before or after burning, because
there's 5700 drums belore burning and 430 drums after burning? Is thisdose per drum before or after burning? What are they talking about?
Here's another very small point.
On page 1027, which is just about thelast page of the document itself, paragraph 10.7.3, because -- now, thisis right out, quoted directly from your EIS: "Because of the rapidly
renewable nature of the Susquehanna River and the regenerative powers
and vast dispersive capacity of the atmopshere, the use of these resources
to dilute and disperse the effluents of chemicals and radioactive materials
from the cleanup of TMI-2 is not considered to be represent irreversible or
irretrievable commitments of these resources."
But what about the resourcesýf the people?

believe that. If EPA, NRC, DER want to believe or help people believethat any other process is going to happen, you will actually have toshow us step by step how decisions are made, get input from citizens
in a hearing process, and show that those things that Met Ed has goneahead and done sometimes are irreversible and not wholly based on financial decisions. Well, it is important that we have the information andI think that you have builtthat it be dispersed to citizens' groups.
up a list. You are increasing your list. I think it is important not to
let down.
As much information as possible should get out.
It is imporYou havetant to have advisory meetings that are open to the public.
to do it in a multitude of ways.
I mean general meetings.
There haven't
been any hearings or hearings planned on the PEIS, as I understand it.
I mean general meetings and hearings.

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MRS. RANDALL (Tr 87): On the waste issue, I've been around with Mr.
Collins on this before, and I beg his time one more time.
I've beenaround with Mr. Snyder.
High-level resins, stage-one resins in canistersof questionable integrity, which the Brookhaven report says may be leaking,which the other report says the epoxy may not be working, that 30 to 90
days after it'isin there the cesium comes unbound and is floating around,I guess in some kind of a gelatinous mass.
It sits in an area where there
might be a big flood.
If the flood -- which the data they're using iseight years old.
If the flood is bigger, which it's
got to be because
there are more bodies and more driveways in this area, it will give it acontinuous water path and the crud will go down the river.
If the crudgoes down the river you'll lose the bay.
It's obviously not any good.
When I asked Mr. Collins and I asked Mr. Snyder in Lancaster and Havre deGrace and at other meetings, where are these high-level wastes going, they said,
why don't you write to Mr. Charles Duncan, Secretary of the Department ofEnergy.
The Nuclear Regulatory Commission, in this house with no outhouseat the time of this accident owes to this neighborhood, owes to the UnitedStates of America, a solution of the wastes issue now.
I don't want to be
told that, as a housewife living in Lancas~er, it is my responsibility towrite to Charles Duncan at DOE and to ask him if he would please open a military dump, or if he would please designate a deep geological repostory. How
many years later? 1957.
Would you please, Mr. Gilinsky, sketch for us,
where are the wastes going, who are we supposed to be writing to while wewould rather be reading children's stories at home, what is the time frame?
Will you assure the people in this room that the radioactive.wastes on aflood-prone island in the middle of the river will be gone, and will you
put a time on it? And if you can't do ft,'will you tell us where we aresupposed to be going with our anger and our worry and our concern?

MARYOSBORNE (Tr 73): Are all the environmental impact statements basically the same? Do they cover the same studies or whatever you people haveto do? Is there anything different about one EIS than the other? Whatabout the cumulative effects, though? You know, nobody has ever told me
what was released the first two or three days.
But I heard on TV, okay, somaybe I can get this finally answered -- there was a number mentioned, 13
million curies, and I think it was xenon.
Okay.
The first two days,
that stuff was highly potent, okay. So what about that? Was that stuff
taken into consideration? Was that a true number? Well, is it possible
to get more radiation six miles out than three miles? Is there any
possible way that it could have been in between your monitors? Because
I saw -- and I picked over a dozen mutated flowers. And I've lived inthis area, that particular area, over tenyears and that has never
happened.
And every year we have picked those same flowers.
So to me
I just feel that, you know, that's what happened.
And you're saying,
you know, it was so well dispersed.
But why would that happen?
KAYPICKERING (Tr 83): What process or processes do citizens or citizens'groups have for input into the cleanup process as decisions are made by
Met Ed and then approved by NRC, step by step? How will we know all thethings that are laid out, how Met Ed makes decisions, and then what goesintc NRC approval or disapproval? The hearings are something that we'vebeen asking and asking and asking for, and we have not had an answer.
I
am anticipating hopefully that there will be hearings and that there will
be hearings soon, and that there will be hearings at each point.
It isreally crucial.
I know at this point you don't have more people here,
because most people believe decisions have been made and that facilities
are being built down there to implement those decisions that Met Ed wants
to see happen on down the road in the cleanup.
People actually fully

DUNHOSTLER (Tr 99):
One thing that you should realize is that it'svery
difficult for the people to take that large volume and really digest it.
Ithink you can see some of the frustration tonight. And I've shown the document to many people and said, I'd like you to take a look at this, take achunk of it and see what you can do with it.
And I even had trouble going

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10 -

- 9I think a meeting
you were asking one of the other ladies was important.
about every six weeks, like DER was holding, would be great, where you
You might only get 50 or 60 people,' buthave Met Ed and you have NRC.
people are -- it's
something that Robert J. Lipton calls the denial
The people are denying that this kind of thing is happening,
syndrome.
And that's.
and they say, oh, well, they're going to reopen it anyway.
a big problem that we all have here.
Another thing -- well, let's see.
I'llskip that.
Okay. Then on chapter 3, page 24, this Mr. Dupont, who
evidently is a psychologist -- there's a quote in here on page 324:
"Dupont, however, says that worry of what-if reflects a general nuclear
phobia, amplified by national TV news coverage."
Well, I think a "what-if"
is what's going to happen with this highly radioactive waste.
It lookslike it's a what-if situation to me, and I think we ought to know aboutit.
And the final thing is the last sentence on chapter 3, page 24:"The degree to which the community believes it has some control over TMI
decisions will have a significant impact on the public's perception of
future events at TMI."
And first of all, I don't see how anybody canhave control, when they try to read this big green thing.
And the second
thing is there just aren't any public meetings like this, where questions
can be asked of the utility and of the NRC by the people are really care.
That's what's important, the people who really care. And there are a lotof people who care, but they say: Look, I'd rather stay home and read mydaughter stories at home, I'd rather rake the leaves, because I know thegovernment's just going to run right over you anyway.
But I don't thinkthat one -- I don't want that thing reopened and I want it cleaned up.
And that's a very prevalent attitude in this area.
But I don't think
Dr. Struford has done very many clinical studies, which.a group in Middletown
is prepared to do, to prove that we've got a problem here.

.through parts of it.' And it's very, very difficult, single-spaced.
People with visual problems won't even try to tackle it.
And I thinkit'srather disjointed.
I have a couple questions and then.I'd like to
say a few things.
First of all, Mr. Collins, I guess you can decide to
decommission or restart TMI-2.
So let's say you decide to decommission
it.
I guess the preferred immediate way would be to mothball it? If
you would decide to mothball it, which would probably be the easiest, I
suppose, of all of the other decommissioning possibilities, would you
reduce worker exposure to a degree than if you would try to recommisslon
it? And then the second thing is, like on the cost estimates -- you
know, remember during the venting, this thinq about selective absorption.
Met Ed said in their'thing it was like 20million, and then finally the
figures were coming out, courtesy of Congressman Ertl, and I guess it
was 8 to 10 million. I don't know if my figures are right, but anyway
it was reduced.
And what I am getting. is, when you come out with thesecost estimates in the final, you know, you've got a lot of cynicism
here, a lot of frustration, and I can't say that I would believe any of
those cost estimates unless somebody independently could verify thatthey were accurate, because probably those estimates are coming from theutility, is that right? But I'd Just like to say a.few things here on
the PEIS, on page 10 -- chapter 10, page 24.
For example, here it says:"Thestart of the purging" -- they're talking about the krypton gas -"was well-publicized, so that persons concerned about long-term healtheffects could leave the area." Well, that's not true. Some people did
not have enough money to leave the area. Some people didn't know where
to go.
A lot of people were prisoners in their homes for several days.
Also, you say here that: "Radiation mapping and damage assessment inside
the reactor building, the next phase of the decontamination, should haveno psychological effect on the people." I disagree, because every time
Met Ed goes in there they keep saying things like: Hey, we could get
No. 2 on line. There's a good chance that it isn't damaged that
bad.- And I'll
tell you, that is really damaging psychologically to thepeople of this area.
That brtngs me to another thing.
I'm just saying,
like you state in here, going in here doing radiation mapping and assessment won't have any psychological effect. Well, I'm sorry, it does when
Met Ed comes out with these glowing statements about there isn't as muchproblem in there as was originally though. Well, now the other thing:"Including Epicore-2 processing of contaminated water has been In progressfor many months, with little
apparent concern to the population." Theprogram is that the last public meeting was held in March at the
Liberty Firehall -- I'm sorry, it occurred one day after the Liberty
Firehall meeting in Elizabethtown.
It was a DER meeting.
From March
until September there were no public meetings.
Yes, you went to
Kiwanis Clubs and all that kind of thing.
But the point is that a meeting where Jane Lee 6an come to and Judy Johnswood and people like that,and can ask questions, that the press can jump on and dig for more information, and get the kind of things we need to know, those kind of
meetings were not held.
And that's why there wasn't much concern about
Epicore.
We had no forum to go to. And I think, Mr. Gilinsky, what

Comments made by ANNE VALSING of the LEAGUE OF WOMENVOTERS appear as comment
number 56 in this appendix.

A-29

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Comments Received at November 19, 1980, Meeting with Pennsylvania Citizes
Middletown, Pennsylvania

like to know what is the answer.
What are you going to do with that highlevel radioactive waste? You say we don't k;iow, maybe by '85 we will
figure that out.
AL MANICK (Tr 9): There are basic flaws in the environmental and impact
study that would invalidate the entire document.
We urge the NRC toprepare a new draft that will be acceptable to this committee and thecitizens not only of Maryland but all the citizens who are involved orwill be involved in nuclear energy. On your slides you somewhat boast of
the only 2.2 increase in cancers. Whether theybe an increase in this diseaseof cancer deaths I do not know.
But this I know for certain: that we must
and will decrease that 2.2 figure to zero for future generations.
We want
the plant shut down for nuclear energy. May I say this issue is further compounded by the waste water problem.
The best that the NRC can hope for isthat while experimenting with the waste water it may be possible to come up
with some solution that may work.
So I hope you can meet this problem.
However at the present time you, the NRC, are doing a lot of groping.
At
the present time you do not know what you are doing.
However you knew very
littleof the problems in dealing with this accident.

BARBARA HIVELY (Tr 21): On October 20, 1980, Middletown area- residents
gathered here to address the subject of the draft Environmental Impact
Statement with representatives of the NRC and the Environmental Protection
Agency.
That meeting was arranged by P.A.N.E. and provided area residents
with the opportunity to express their concerns about the cleanup of TMI.
Many also attended a similar meeting held by the NRC on November 10 in theSome others traveled to Lancaster on
Forum Building in Harrisburg.
October 1st, 1980 to attend the NRC meeting hosted by the Susquehanna Valley
Alliance.
Still others attended the NRC meeting in mid-September at the
Swatara tuwnship building hosted by Three Mile Island alert. PA.N.E.
sincerely hopes that the NRC heard the people's comments, criticisms andsuggestions at those meetings and that the NRC staff will use them in preIn September 1979 P.A.N.E. petitioned the NRC toparing the final PEIS.
be admitted as an intervenor intthe TMI Unit No. 1 restart hearings which
are currently under way.
P.A.N.E.'s only contention was to provide testimony on the psychological stress which has been caused by the March 1979
accident and will continue until Unit No. 2 is safely cleaned up and TMI
is permanently closed as a nuclear facility. During the 13 months since
September 1979 the NRC Commissioners have neither accepted nor denied thepsychological stress contention.
We find this inaction to be for abhorrent.
Concerns about the psychological stress were considered in both the environmental assessment on the decontamination of the containment atmopshere of TMI
Unit No. 2 and in the draft EIS on TMI Unit No. 2 cleanup.
In fact it has
become the most talked about "non-issue" in all the discussions about Three
Mile Island.
The presence of psychological stress in this area cannot bedenied.
Area residents must have a strong voice heard by the NRC and heededin shaping the future actions of TMI.
These actions will embrace our lives
for the next seven years and beyond.
The NRC shows a callous disregard forthe people of this area by holding tonight's meeting which was firstpublicized this past Sunday as only three days ago In a newspaper in
Lebanon, Pennsylvania, 25 miles from here.
It was not in our local newspaper.
During the past week there have been two NRC-related meetings heldin Harrisburg.
Why was there no announcement made then at that time about
tonight's meeting? -BEN SLOAN (Tr 12): I would like to address Section 7.2 of the PEIS.
In there
you consider various alternatives to processing of the primary water system.
I believe you consider various alternatives including EPICOR II filter/
zeolite/resin.
However it seems you did not include various modifications
which could be made to the EPICOR I1 system which would include some type ofprefilter/zeolite/resin system in EPICOR II for processing of primary watie.
It would seem at this time that if the NRC did permit EPICOR II processingof the primary water that it could be done in a short period of time, essmtially probably somewhere in the period of nine months to a year before any
decision is probably made on the SOS.
Could somebody comment on that?
JOHN SMITH (Tr 14): Dr. Snyder last time talked about the waste problem.
He said there was a possible court challenge to challenge the referendum
in the State cf Washington and that Hanford would not become available.
I think at this point in time one gets the distinct impression between arock and a hard place regarding disposition of waste.
We have the military
who doesn't want the waste mixed in with its military waste.
So I am wondering at this point in time, Dr. Snyder, (inaudible).
What I would like toknow at this point in time is where are the wastes going to go on disposition.
They can't go to the military.
They can't go to Hanford.
They
can't go to Barnwell.
Where are they going to go?

ANN SESSA (Tr 26): i want to know under what the NRC operates? I-sit a law?
Was it established by Congress? And if so, why wasn't there, why isn't
there a provision put in there that any utility that generates an accident,
say of a 3 dimension automatically loses control of that facility until
after the cleanup and the NRC and the Government people step in.
What
we have now and what is throughout the area here is the utility proposing
things well in advance of what you gentlemen say you will do.
For instancein Lower Swatara Township meeting Mr. Arnold stood there and said we willvent and the bottom line he gave us was: it doesn't matter whether you
like it or not. When we get the NRC's approval, then we will vent and we

FRANK THOMPSON (Tr 18): Just a bit of a followup question to his.
Cleanupis projected now to. take until when, 1985 or '87? When you go to work on
the core you will have a large quantity of high level radioactive material.
It is becoming clear to me and I believe to most of us that nuclear dumps
are going to be a problem in the future and citizens such as ourselves aregoing to raise our voices and say "not here." You answered part of hisquestion about low level radioactive material dumping.
I don't believe
you have any answer for high level radioactive material.
We in Middletowo
are afraid that TMI will be very convenient and it will be stored on theisland in the middle of the Susquehanna and we don't want this,I would

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We don't want any water leaked into our river, not one iota, because a lotof these things, the tritium wouldn't be released into the water.
It doesn't
When thatdie for a long time an! it will go into some living organism.
We are just breedorganism reproduces it will reproduce with a malfunction.
ing death.
And you gentlement are breeding apathy by not listening to us
Please listen to us and pleaseand apathy is going to kill the country.
take what we say.
You give us this great big Environmental Impact Statement
I went to give meetings.
Every meeting I
to go through and listen to.
went to and somebody asked a good question.
You took no responsibility,
somebody was just supposed to look at all the different options.
You say
we don't have the answer, we can just check it out.

horsed around for months but they vented because it was the cheapest,
easiest way to do it.
Now you are asking the utility to govern themselves,to escalate their costs for the common good and when it hits the pocketbook
they are not going to do it.
So I am asking you if you truly are a government agency, when they generate a 3 accident, which isn't supposed -o happen
we all know, why don't they lose control? Because God knows they didn't havecontrol in that whole accident down there. And why doesn't someone step inand say here is where the buck stops? Because what we have in meeting after
meeting is Dr. Snyder saying we don't want to see that water dumped in theSusquehanna but if Met Ed proposes it we are going to have to take itinto consideration.
And geneltmen,that sets my head on end, because I
came to you and said, "Do you have a rubber stamp?" Do you remember that,
Mr. Collins? And you very blithely said, "I don't have a rubber stamp."
What I meant and what I mean tonight is when the money speaks is that who
you listen to or are our kids and our safety and our family important? And
if they are, why in heaven's name would we allow these utilities to govern
their own cleanup in this tragic accident? I am really concerned about
this.
It struck me last week when we were talking about it, when they had
the newly elected Citizen's Counsel talking about it and it always came
down to that: well, we have to take into consideration.
The other thing
I wanted to ask you Commissioners is does that not go back to Met Ed until
the fifthcommissioner is appointed? In this regard wouldn't the case go
back to Met Ed with what they can and cannot do without your fifth commissioner?
Do you see what I am saying? We are going to wait until January. We are goingto waste months.
We are going to appoint a commissioner who is going to acquaint himself with all the facts.
We are going to waste some more months.
I
have the feeling we are going to do what you wanted in the beginning.
It wishit was changed.
I have seen it happen one time before.

VOICE (Tr 47): You said that this EIS will not address the dispositionof Unit ;. I didn't even read the environmnental statement so I don't know
anything about the cleanup.
So it would seem to me that you would have totake both those questions Into account when you do an Environmental Impact
Statement. And I don't know if Met Ed sits in on the meetings when we are
discussing the environmental impact, but couldn't they say well, if you doit that way and clean it up that way that means we cannot refurbish theplant? Does that have a bearing on the Environmental Impact Statement?
Are you saying that this Environmental Impact Statement only goes so far?
Is that what you are saying, that it only covers, that it doesn't matter
what you are doing right now in the cleanup of that plant to either decommission it or refurbish it? In the Environmental Impact Statement on thereleasing in the atmopshere there was a table and I think it was 131
million to decontaminate and decommission plus another couple of hundred
million to remove the whole containment building and it was about half amillion to refurbish. Why is it $1 billion now? It was a billion in
0662, Volume 2. Now has that jumped up to a billion from a half a billion
which was the high estimate to refurbish the plant after it was cleaned up?
Why is it a billion now? A billion in this table was to build a new planton the old site. Now I would like to know how you came up with $1 billion?

MICHAEL CORRIGAN (Tr 42): I heard Mr. Ahearne say that his role, the NRC's
role for the Environmental Impact Statement was to look at all the options
and people's comments were very important.
In the Environmental Impact
Statement if you were looking for all the options, why don't you address theissue of decontaminating by decommissioning the plant.
That is a viableoption and that would be very cheap. Why not? Secondly you said thepeople's comments are very important.
If the people's comments •re very important why then, there was overwhelming response for no venting of krypton,
something like 800 to 500.
Yet they did vent. We asked for a citizen's
advisory panel.
You gave us some kind of shit that wasn't even near it.
You
don't listen to us and we don't believe you.
Very recently we heard about
Russia having an accident.
I found out that over ten years ago the atomic
agency, now the NRC, did a study on this.
You kept it from the public.
I
am just wondering how much you are keeping from us. What is going on at
TMI? What is really going on? What was vented and what will be released?

PATRICIA LAWBETTER (Tr 54): October 20 we met and I brought up some incide-its in Canada in Section 1. 1 asked if some followup could be done fromthose incidents.
One was the Chalk River.
They were 1952 and.1958.
In
these cases we had rems such as 5 rems exposure to workers.
We had radioactive water spillage~and we gave those incidences as examples of mechanical,
technical cleanup.
If they are included in an EIS then it would be my hopethat there has been followup after these to indicate there was no impact
on the environment in these cases.
The one I refer to especially was thewater was allowed to seep into the soil.
It said it removed it.
It
it
to
where
is
my
question.
How, has there been followup? I would
removedlike some information on this.
The point is here we have excellent examples
Here we are into the '80s.
The time period has elapsed. Who
to look back.
but the people in Canada today in these areas could give us some advice as
to what is going to happen here to our ground water and our environment,right? I have one other question.
It keeps coming up again and again

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6IE

ra001M-5--6throughout here.
We have exposures of rens to be expected.
We have seen
it down on the island again week In, week out with workers.
Supposedly
they are inconsequential doses. Now where in the history of your agency tave
studies been done with human beings to show that these are safe allowable
doses? How were these doses arrived at for us to be following todaý in 1980?

CARLA MEYER (Tr 67): I think this whole business about lIke you have as
well as I understand it I think the people are saying look, we don't
want like a TMI to waste and store.
But then you come up and say well,what about South Carolina, our fondest last hope.
I think that is likeputting people of this country against each other. There is no safe
storage for that material.
So what are the people from Nevada supposed
to do, suffer the same pains as people in this area? It's like pittingregi(on against region.
I think there is a lot of lessons to be brought
out here.. I think actually what NRC is sitting on top of is a meltdown
much more severe and long term than the meltdown of the reactor.
I think
it is a meltdown of people's whole trust in this goverrnment and people's
whole trust.

SUSAN BARLEY (Tr 58): What I am really concerned about: there was one sention
here of something like an estimated 300,000 worker hours for total cleamp.
This was the projection when the cleanup would have been completed in '84.
Now they are saying '87.
I want to know how does this change the projected
number of working hours? How will this affect the maximum-minimum which
will the maximum and minimum doses be? Where will the workers come from?
This original figure is 14,000 workers years which worked out to about athousand workers for four years.
It Is not going to take us four yearsNow it is going to take us seven.
How many more people? Where are theseworkers going to come from? And who is going to go on high radiation first?
I don't think it is going there because they are not as expendable as IO
paid spongers.
What about records? Will there be records kept on all
workers? And send them down the road with the cash and don't even pay thenby check? Medical records for how long? These TMI-2 technical specification hearings going on right now how modify the technical are going toeffect the cleanup and implementation of this blueprint? And one thingthat Snyder said very early on is that very littlehigh level risk has been
generated thus far except in the core.
I want to know about the spent resin
filters from the high level wastes that were formerly a solid form and are
now turning into Jelly because No. 1, the acid base and No. 2, the inteide
radiation.
I don't think 5,000 curies is a small amount, especially whenit contains only 49 or so containers.
This wasn't considered in the PEIS.
Because it already exists does not mean it is something going to come up.
We have to deal with that. What is going to happen there? Clean water tobe used for cleanup.
So basically my concern that we still have to live
here, is what about the workers? Met Ed wants to throw out all the records
on the workers after five years and that is one of the things that came op.
How is that going to affect the cleanup and recordkeeping? What about
temporary workers, does it keep records on sponges? There is one morething that was mentioned about decommissioning versus restart. I am anelectrician in industry so when you go into a place I know how to put ina system.
You do it carefully. And it matters whether or not the pipes
are cut straight or how the wire is clipped.
On the other hand when you
are tearing something out you don't have to take as much care with it.
The same goes with cleanup.
If you are trying to preserve the integrityof the plant or system you have to be really careful how you clean up,
which is going to take longer. On the other hand if you are going in todecommission it is very simplistic to turn it off and tear It down.
That
is going to affect worker doses too.
You got out of addressing it bysaying that decommissioning it not granted.
It is not according to therL.le that you are playing with. But that doesn't mean you ignore thealternative of it.
You didn't even talk about it.
dust because you
don't have to doesn't mean you shouldn't.

DON HOSTER (Tr 71): My first question is the accident occurred on March 2B,
1979 and it took the NRC eight months to decide to do this document a lotof organizations, they blame organizations which are nuclear critics forholding up the cleanup.
And I think I should say it took eight months for the
NRC Commissioners to decide on this document formally.
I would like foryou to explain to 'ne why it took the NRC Commissioner to vote on a document
like this.
Then I have some comments, since you clarified that.
For example
on Chapter 10, page 24 you talk about the psychological effects of the PEIS.
In here I find many interesting problems and I would like to get it on therecord rather than writing a letter.
For example in here it says that -I will quote from the document -- stress would be less severe for a personwith gas.
I find that a difficult statement because a person that has smne
krypton is still going to be around for ten years or whatever it Is, eventhough it is going to disperse somewhere.
Nevertheless it will be in theatmopshere and a lot of gases that are released.
Also the statement thatssys, "The start of purging was well publicized so that persons concerned
about long-term health effects could leave the area." Unfortunately somepeople didn't have enough money to leave the area.
Some people didn't
have anywhere else to go.
So that is not a very true statement either.
Then it says, "Radiation mapping and damage assessment inside the reactor
building -- the next phase of the decontamination- process -- should haveno psychological effects." I disagree with that because quite frankly
every time you go in there the suspended licensee comes out and says it looks
good, there is a good chance we are going to get this thing cleaned up andstarted.
I think that is a psychological problem also. Also it says in
here, "including EPICOR II processing of contaminated water, has been inprogress for many months with little
apparent concern for the population.'
I would like to point out to you that from the middle of March in 1980 until about the midele of September there were no regular public meetings.
There were meetings with (inaudible).
There were no meeting with DER held
successfully I thought for people to come and ask the utility and NRC questions. The press had an opportunity and this helped people understand alittlemore what was happening.
I say the reason why there was no apparent
concern with the general public (inaudible) didn't have much access.
We
could have walked down to the NRC office.
I know that.
But there arepeople who are afraid to talk to the NRC and are afraid to get up and talkA-301

-7 -8 that in mind. I will move
tonight a lot of people. You have to keepn
right along. The last section here under coimnents, Chapter 3, page 24,
there is a (inaudible) psychiatrist. He is cited in the references. He
is talking here about Chapter 3, page 24: DuPont, however, suggests, thatworry of what-if reflects a general nuclear phobia amplified by national
T.V. news coverage., The problem I have is that I think the problem nuclear
waste disposal permanently and safely isn't a what-if. I think it is avery real problem here. I really have trouble with that statement. Thenin the last sentence it says, "The degree to which the conmmunity believes
it has some control. over TM! decisions will have a significant image on
the public's perception of future events at TM!." -Like I said it was alarge document like the PEIS with no regular monthly public meetings anybody can come to. I don't think the people have a good control over theentire situation. I would also like to remind you that in January of 1980
Peter Houts of Hershey Medical Center released a study showing that 20,000
to 40,000 people living within ten miles of ThI -showed stress on the physicalsystem, plus the program study recently came out which you are probably
aware of. So those are my basic comments on the psychological part of PEIS.
My final question to you is Ilam wondering if you can tell me who theDecision Science Consortium of Falls Church, Virginia, the consultants for
DOE, who are they and what are they doing here in TMl area and what impact
will they have on the cleanup or whatever?

which filters out to the Bay and the drinking water of Baltimore andinto people's lives? You can't promise that it-wouldn't affect the.
fish and the wildlife. Was there ever any precedent set when you built
Three Mile Island? All I can say is we are against the dumping of thatradioactive water into the Susquehanna, no matter what. I would say that
if the people as individuals get their vote across then it would bevoted out.
MR. GREEN. (Tr 83): Do you not recognize the people who live here
sh-ould have the right to make the decision? Do you or do you notrecognize that right?
LANA HUNTER (Tr 83): This book here, I would like to show people who haven't
had one or seen one. The print is so tiny that you can't read this formore than an hour without really having a lot of difficulty, even with goodvision. An*other thing, the language used in it is not the kind of languagethat a person with a limited education, say a high school graduate canunderstand easily. Surely with something to back it up they can understandit and these are the people that this book is for. These are the people
that this book is about. Most of them even if they felt brave enough todive into it, they have they would have a lot of difficulty. It seems
highly ineffective to me to-put this thing out and then this is what yourcomments are based on and this is what everything you say is based on. Andif people bring it up, even when they do bring it up at these meetings you
say oh, we can't talk about that now because we don't knew, we will getback to you. It -'snonsense. I appreciate the fact that you are doing
it for us. But I think that it should be more directed for the people tounderstand. That is just my opinion and my comment. There is one thing alsothat I was curious about. After this is out will this be the last publication of your people? I mean how much of a lapse of time will pass between
when this goes out and something else that you would print as far as for
the American public?

JACK SUSKIND (Tr 78): I think that to follow up on the comment, the lack ofcommunication between the citizens and the governmient employees I thinkstems more from other sources than lack of a microphone. I think that is
a sense of where we are coming from. We are concerned with our lives andthe lives of our families. You are concerned with the bureaucratic problem, the scientific technological problem, with an economic problem. We
are vitally concerned with our lives and our family's lives and our family's
futures and hour homes. I think that is for me anyway a big gulf that I
ha ve. I am a lay person. I think I am fairly intelligent like any
ordinary individual . And for me to read through that EIS statement andto make some intelligent comments about it is not really a layman's job,
not really my job. I should be able to entrust you with my life. I
should be able to hope that you will clean up that plant quickly andsafely. And I think that is what I have been hearing you say tonight. I canonly hope that you will take our feelings into account and proceed in themost safe and expeditious manner.

VOICE (Tr 87): I want to know if there is a deadline for the emergency planand the radiation protection plan. I also want to know can too much boron
or borax solution cause any problems? Will potassium iodide also be included in that? Will we have to have a supply locally of that? Wouldthe boron ever indicate a problem if you had too much 'of that? My lastcomment is I don't like the idea of putting the water into the river but
I also don't like the idea of evaporation. A couple of economic questions.
Largely due to regulatory constraints there has b--en
a rapid escalationin the cleanup budget for TMI-2. What is your regulatory right or position on a grant or a loan for general public utilities? And if generalpublic utilities go bankrupt before the completion of the cleanup does
the NRC have an action formulated to take over the site or tonianage the site and what is that plan of action? If I could address one

ROBIN SITES (Tr 79): As an observer tonight and seeing everything more orless -objectivelybetween you and the people of Middletown, I can seethat a lot-happened that you didn't anticipate of course when you built
Three Mile Island. Of course you didn't anticipate that there would be an
accident in the first place. But I would like to know if there was evera precedent set that if there was an accident, of course you take that
into consideration, was there ever a precedent that said we would be allowed
to dump our nuclear waste, the radiated water waste into the Susquehanna

A-302

-9-

other question, if it is proper, about the accident itself: during theaccident the NRC came out very strongly with the hypothesis that the hydrogen
At the same time I
bubble in the core created an extremely large concern.
believe various other nuclear experts as such declared that there was nothydrogenbubble.
Now I
possibilityofcatastrophe
due
to
that
a strong
believe it has been resolved by the Kemeny Commission concluding that there
was notan extremely large probability of additional accident scenarios
I would like to know if the NRC has resolved
because of a hydrogen bubble.
the hydrogen bubble incident and if the NRC has done anything to correct •such things as the hydrogen bubble scares from leaking out to the press orto the general population without confirming them.

1960 Quarry Road
Lebanon, Pennsylvania
17042
Phone: 717-865-2594
November 18, 1980
Dr. Bernard J. Snyder, Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

PAULA COLKEY (Tr 93): I know I said this before but please understand weare not anti-cleanup. We definetly want this plant cleaned up. But understand we want it done safely, not to skip through the red tape and everything.
We want it step by step safely, but we want it cleaned up. Concerning
the psychological effect that this accident had and is having, continuingFirst of all I just briefly want to tellon the majority of the people.
you in the '60s when I was a senior in high school I used to look at the people
against the Viet Nam War and I thought what are these idiots doing marching
Don't they know theirin the street and carrying on like a bunch of fools.
Governifent is going to take care of tham? What good is this? Little did I
know that in the March of 1979 and ongoing that I would be the same nut
walking down in Washington with a sign saying for God's sake, please help us.

Dear Dr.

Snyder:I am writing to- express my comments on the "Draft
Programmatic Environmental Imact Statement(related to decontamination and disoosal of radioactive wastes resulting from Iarch 28. 1979
accident Three IMile Island Nuclear Station. Unit 2,-NUdEG-0683)".
At thistime, I wish to thank you for mailing me this draft for myreview and comment.
First,
I would like to express my comments concerning the structure and general presentation of the report as follows:
1. One of the basic purposes of the PEIS is to inform and involvein the decision making
the public as well as government officials
has utterly failed toprocess of the Commission. The PEIS staff
effectively draft a statement which would allow the public torationally and comprehensively participate on the subject of
decontamination and disposal of radioactive wastes concerned at
The staff
has cateThree Mile Island or any nuclear facility.
report a lack of ability
togorlcally demonstrated through thisproperly convey and inform the public as to a clear understanding of the subject. It is not that the public lacks the intellihas failed togence or desire to comprehend, but that the staff
organizeand present that material in an educatable manner.

A-303

2.

correct prospectThe material presented must be placed into its
ive of its
significance to other releases to the environment
with respect to industrial, other energy producers releases,
non- industrial, and background.

3.

Since the accident, the role the NRC has assumed- in involving andinforming the public in the decision making process has not servedinthe residents in gainning greater confidence, credibility
the nuclear industry. But, rather, has consistently served thoseof the negative minority at the expense of time, of the majority
the utility,
and the nuclear industry,

Page 2-

Comments to PEIS-continued

Page 3-Ccmments to PEIS-continued
3.

The facade of neutrality has long since been lost
through yourlack of leadership and has become in essence a politicallytaxfunded organization, which I feel should be totallyabolishedby Congress. If you are to establish a positive rationale,then you soundly educate the public and allow those membersof the majority to be represented on the same basis as thoseof the negative attitude.

3. To promote public confidence,the staff should illustrate whatthese filters are, their purpose, placement in the buildings
involved, failure under normal operations, failure and resultant
releases involved during the operation of decontamination involved in the Auxiliary and Fuel Handling Buildings. Then thereader can realistically place this possibility In Its true
prosepotive and relationship to the cleanup effort.

4. The organization of the report Is often confused and constantlyinterrupted with "refer back to" or "see appendix" for further
reference. The arrangement and discussion of subject material
In the present order is not constructively set up for logicalunderstanding. At least
four or five chapters should be arranged
as to order in the total
presentation.

4.

Next, I would liketo express my views concerning material in
the report as follows:
1. In the firstchapter, the staff stated that commercial nuclear
power plants are not designed with special consideration forlarge soale decontamination operations. This statement represents
the total
inabilityof the NiC to provide leadership in plantsafety and design. Quite frankly, I believe the commercial
industry would have been far better to regulate itself
as tothan to be engulfed
staff
design,safety, and training of its
inability
to lead andIn bureaucratic strangulation and totalindustry.
set standards and educate those concerned with this
These efforts, or lack of, have only served to undermine publicof the nuclear indconfidence, severely attack the credibility
ustry and the utility
in question.
2.

3.

To give credence, by disclosure, of such ideas as pouring cement
into the containment building to solidify the water in containment, only serves to enhance your lack of expertise and seriously
impairs your ability to lead and regulate. I feel the publicshould be grateful that the staff could not find a way to insert
a slurry into the building and give us a permanent problem.
With the additional time the staff required to prepare this draft,it seems to me that the staff desparately grabbed at all ideas,
the more the better, to enhance the facade that YOUt NRC IS ON
THE JOB AND CAN OUTDO THE INDUSTRY. The licensee has demonstrated
its expertise through its presentations, carefully studied andresearched' This presentation of a quantity of altennatives
against the licensee's presentation only serves to confuse thepublic and demonstrate your success in using paper not intelligence.

5. We simply do not have an eternity to clean up the plant and todelay this effort for the presentation of your studies, and reports
places the citizen in a situation of severe financial burden
and a attitude of endless frstration. In over eighteen months
you have only succeeded in raising the costs, increasing thedamage, and increasing the risks of safety and health to thegeneral public.

The major environmental impact of the cleanup at TPI is the occupational doses received by the workers involved. This is notpresented in a clear and concise manner to the public in relation
to the workers and the best alternatives for them. To demostrate
your fairness and neutrality, you should have a representation
views to be presented andwork force to allow theirfrom thisadvise considered. Yet you have consistently ignored the workers,
and the public, and taken under advisment those views fromareas''are the most vocal, and threatening , and technicallylacking in expertise on the matter.

or insigniIf the alternatives presented will result in little
ficant impact environmentally to the public; then you should
demonstrate this in the context of other releases or pollutantsin the environment. To say that this is not within your area.of demonstration; then.this report should have been compiledin concjunction with the proper agencies concerned with thetotal environment and perhaps taken the total responsibility
from your agency.

7.

I have far greater confidence in proposals presented by thelicenseg,such as the SDS system, especially since their provenperformance in designing the venting of Krypton-85 gas and its
successful completion.

mentioning of theto comment on the repetitive
I would likeand its
possible release of radioactive
failureof the HEPA filters
effluents to the environment. As of the writing of the PEIS.
much of the Auxiliary and Fuel Handling Builings have been deconthe actuality of
taminated, yet, the report does not illustratereleases during thisof these filters
and their
the failure.operation.

6.

A-3rY4

Page 4-8.

Comments

toLise K. Hanger
2 Madison Place
2
Annapolis Maryland
21401

PEIS-continued
Office of Nuclear Reactor Regulation
U.S Nuclear Regulatory Commission
Washington, D.C. 20555

toof neutrality which you have tried to relate
The attitude
the public concerning decontamination at TKI is totallydiscredited through the selection of individuals to sit
and haveon the T1hI ADVISOaY PAINEL. If you wish to be fair
representation for the minority, then you must have themajority represented. By ignoring, refusing to appoint members
or individuals of groups repxenting the majority, you cannot
The official
and equal represnntation.
consider this a fairfurther corrodes publiccredence of the negative attitudeconfidence in your efforts.

Novemberadvance for your consideration

in

this

matter.

Yours truly,

Mrs.

PAB/pab
cc: yr.
Mr.
Mr.
Mr.

Patricia A.

1980

Sirs:
I am writing to express my interest and concern about how the Three
Mile Island clean-up proceeds. How it proceeds is within my interest
as a taxpayer and a resident of the Chesapeake Bay area. I (along withother taxpayers) am paying for it and I will have to live with theconsequences of the choices made by the Nuclear Regulatory Commission.
As a taxpayer, I should have access to cost estimates of the clean
up methods proposed in order to submit a
judgement about thebest clean-up proposals in the P.E.I S. yet the P.E.I.S. does notinclude cost figures. Why not?Certainly cost is a factor.Nor does the
P.E.I.S. make any proposal about what the N.R.C. will do if
Metropolitan Edison defaults.The most upsetting aspect of the P.E.I.S.
to me though, is the proposal to dump radioactive water into theSusquehanna River. The N.R.C. has not adequately demonstrated to me
that tridium will have little
or no effect on the marine lifein theBay. And it can not since whatever long term effects tridium may haveon living organisms can not be foreseen but must be observed over along period of time. Trace amounts of strontium 90 and cessium 137
would also be released with that water but no amount of those substances is safe.Those radioactive substances would mutate marine life
species and ultimately be absorbed into our bodies to irradiate us
and mutate our genes for the rest of our lives.
I find and proposal to release radioactive water into the SusquehannaRiver preposterous and cospletely unacceptable. Once the water isreleased , it would be irretrievable forever and the negative effects
would last
for an equally long time. Many people depend upon theBayfor their livelihood.The Bay and the creatures who live in it are
unique and beautiful. The quality of these lives
should not be
jeopardized.

I hope my comments will constructively aide you and your staff
report. My purpose is simply to help
in preparation of the final
relationship with the public, andyou effect a better and fairer
creating a positive atmosphere concerning the decontamination
effort at TnI and the nuclear industry. As a resident of Pennsylsituation must be placed into
vania, I strongly feel that thisprospective, so that an expediously safe and cleana realistic
effort can proceed and the unit returned to operation. If I canbe of any further assistance, please do not hesitate to contact me.
Thanking you in

19,

Books

Ed Felminski
Matthew Bills
Allen Ertel
John F. AhearneYours Truly,

Lise K. Haager

A-305

ENVIRONMENTAL COALITION ON NUCLEAR POWER
Co-Oiretof: Mr. George Boonrrr-R.D. *1, Peach Bottor,

Patricia A. Smith

Pa. 17563 717-548-2836
Dr. Judith Johlrurd-433 Orlando Avue, State College. Pa, 16801 814-237-3900----------'alNovember 14, 1980
RD 1, Fore Fairway Dr.- Valley Green Golf Course

Etters, PA 17319
Secretary of the Commission
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555

171ýd

9,r,~c§Dear Madame or Sirý

le

1--

I enclose a summary of comments on NUREG-0683, the Draft
Z
6>•---Y..- '-

Programmatic Environmental Impact Statement on the Decontamination
and Disposal of Radioactive Wastes Resulting from the March 28, 1979,r.

Accident at the the Three Mile Island Nuclear Station, Unit 2.

comments are of a general nature, covering the major over-'l-•These

all deficiencies which members of our public-interest organization
throughout Pennsylvania and adjoining states have expressed to us.
Detailed critiques and comments are being submitted separately bymembers and by member, groups of the Environmental Coalition on Nuclear
Power. Additional criticisms have been voiced by ECNP's members andmember groups at the'numeraus public comment meetings held by NRC
Staff personnel at locations throughout the lower Susquehanna Valley
during the past two months.

. '
-2

•

e'

It is our position that the Nuclear Regulatory Commission has
failed to comply with the Council on Envtronmental Quality's regulations
concerning public hearings under the National Environmental Policy Act
1969. Although many "public meetings" have taken place, the agency
has failed to provide for full and proper hearings to fulfill the spirit
and purpose of NEPA.

'of

4..-/` •7/i•_,~~2-C. &We find the Draft PEIS on TMI-2 decontamination and radioactive
waste disposal incomplete, erroneous, and inadequate to permit theCommission to make a finding that the cleanup of TMI-2 may proceed
under the program options considered in NUREG-0683W We recommend thatthe Draft PEIS be withdrawn, rewritten, and reissued for further draft
review by Federal agencies and the public, with adequate time for receiving and commenting on the document. We recommend that NEPA hearings
be provided prior to issuance of the Final PEIS.

L--• ,The precedents set by the NRC in the aftermath of the TMI-2 accident
will affect the operations of the entire nuclear power industry for theremainder of its duration. The "business-as-usual" mind-set of the NRC
Staff in this seriously flawed docunent must not be tolerated by therCommissioners of the NRC who are ultimately responsible for carrying out
theof the andAtomicEnergy Act of 1954, as amended, to protect
the mandate
public healthsafety.

I*See CEQ's NEPA Regulations
Part 1502.9(b) and 1503.4(b)SneeyJudith H. J~hnsrud, PhD
Cb-Di rector

NOTE:

A-306

Comments mentioned in the above letter as being attached are included in thisappendix with comment number 64.

=13ftw I

ýýFl

104 Davey Laboratory
The Penn. State University
University ParkPa.,

Environmental Impact of theThree Mile Island, Unit 2
Decontamination Program
by

16802

'.illiam A.Lochstet,Pb.D.

19 November 1980
Director,
U.S.

T-e Pennsylvania State University*

Three !'ile Island Proracm OfficeNovember 1980

Nuclear Regulatory Commission

h asbington,

).C.,

20555

Enclosed are my com-ents

on

NUi2EG-0683,

the Drtft Progremmatic

Inmract Statenmnt on the clennur of

Please note thrt

T-i

decontaminate and disrose of the radioactive wastes resulting fromthe lparch 28, 1979 accident at Three File Island, Unit 2 in its
Draft staterent, NUREG-0683 (PEIS) (aef. 1). There are several- 2.

the o-inions and calcu'ntions presented are riot

those of The Penns-

Leakare of the reactor buildinr
asnurnoses only.

contents leak out inan accident

section 6.3.4.2

in

to nroba~le normal
st'-tement

will reflect the suggestions

sumn water is(

one or two days.
It

leaks.

omitted or Overlooked.

have beenof the -roeram whichasnects

vania State Univ'rsity,

free thinkrs.
which is well known as e collection of-l.5 used h-re for iclentificrtion
The Universityaafiliation

I hone th-at tl-e final

toof the program

evaluate

Environmental

necessarily

has attemnted to

The Nuclear Regulatory Commission (NRC)t~e exnected environmental ima'ncts

Gentlemen:

1),
1ef.

consideredvhichsection 6.1.2

that "the building could begin to leak unexnectedly".

enclosed herein.

reactor buildin,

Sincere]y,designedisthe entire

No consideration isstated in

is

in

given
(Ref. 1)The

with a steel inner meimbrane which isfittedto limit leakage to0.2', by weight in

2L hours,

at

55 nsiag air -ressure. The buildine has -n internal free volumeof 2,00D,0.0r cubic feet. Thus, the building is not obviously,*m. A. Lochetet

water ti."ht.
Sec.

is

1.2,

Ref.

of about

the building to a brheirt of 8 feetet the bottom

standing in

•ter

1).

This nroduces a "ressure¼ atmoshphre,

being maintained atdriving differential

or

3.75

-sig.

T1e rea-tor building is

neg tive nressure, so that-a net
a slihtof 3.45 nsig will be used here ( Ref. 2

notes a rressure of -0.3

rsig).

This is6.3% of the designo The oninions and calcula tions contained herein are notnecessarily those of The Pennsylvania State University,
encouragement of independent
which is well known- for its
Affiliation

A-307

for identification

nurposes only.

thought.

1

PEIS,

Nov.

.80

P2IS,

2

total

If

it

area.

of 104,546 s-uare feet of membrandcontact with about 16,of th!e area.

As a firstwater is

Thus,

in

assumption,

or 4,000 cubic feet.

1i% of 4,000 cubic feet,leak rate isThus,

airborne is 10-4.".

This is given -ith no further justification.
There seems to be more certainty in the statement in the PEIS
than in AN"L-75-78. Furtha-rmore;this firure of 10-4, or 0.01%

1.1 * 106
A leak rate of 10 cubic feet of wtter per day ta isis suggested in the PEIS ( Fig. 3-1, aef. 1) thatml ner day. It
may berin to be processed in Jan 1981. This issumn ',ater
1 3/4 year afteryý/

about l9Oefi/mL ( Sect.

Inthe accident.

of 7.2 x 10- ml, would escape.

a totalRef.

6.3.1,

apnears in many othrr nlares such as: sections 5.2.4.1,

this time,.t a concentration of

5.4.4.1,
8.4.4.1,

amounts to a1) thisrelease •f 137,000 curies, contained in about
activity
total
190,000 gallons. It is un'ikEly tl-at such a large release hasreactor building,spmeleakagec~nnot be tstallynot considered

in

-EIS

the

The NRC has considered a number ofaccidents
wouldthings

be

in

its

analysis of theuseful if
thatvery well could

cleanunan oversimplificationindustrial

program.

itIt

happen.

The siteisvery nearof any size.

the crash of an airalane

about a possible flood.

There: is

Section 10.5.3

Hurricand Agnes flood (300.5

ft

some

I

oresumeinconsistancy

surgests thot

1'8L)

was below theto not discuss particle size. Therefore,
is suepested that these sections on HEPA filters be re-writtenwith explicit discussion of narticle sizes.
There is also little
discussion of the failures of HEPA
filters except for burning.
In particular, no oroblems are xxgx
suggested due to personell error.
This is in contrast to thefinding of Ploeller (R•ef. 4) that the major share of filter
failures " anrear to be due to errors by those resoonsible k

but no consideration ias given to ti;ethis oversite will be remedied.

1972

exnectedsome imagination were used to anticinate

to an active airport,
effects of adismissed.

1).

(Ref.

No mention

is given to the size of the narticles. The efficiency
of HEPAfilters depends to a very large degree on the size of theparticle in tie air. A'.L-75-78 suggests a minimum efficiency
for particles of rlutoniur
near 0.4 micron diameter.
It ishere a discharge to the environment which wasthere isThus,

5.3.4.1,

6.3.4.1 twice),
6.5.4.1, 6.6.4.1,
7.2.6.1,
7.3.4.1,(Rief. 1).
These discussions frequently (in the PEIS)

go on to discuss the rrotection givon by HEEA filters.

but lacking an exterior sumn surrounding thegone undetected,

the dike was under water.

of plutonium, not fission nroduct releases. Further, the statementin Ref. 3 is " The fraction of r-lant materiel estimated to becomeor 40 cubic feetper day.

±3k

In fact,

It is stated in section 5.3.4.1 that exnerience in theorocessing of nuclear fuels in chemical processes that 0.01% oft~e total material nroressed may become airborný Ref. 1). The
reference for this isA1L-75-78 (%ef. 3), which is a study

water on the floar suddenly
by the accident may have altered thethe leak rate is
assumption,
ith thisstatus of the membrane.
The origional leak rate is t:oken as".
6.3;, of 16;, or about 1
0.2ýi of 2,00,000 cubic feet,3

It is su-F~ested in
section 1.6.1.2 that organic resins
are stable at exposures less that 109 rads( iRef. 1). It would
be useful if the NRC could reference some studies td orove thisroint.
This is narticularly interesting in contrast to thecomments made in Anpendix H , at section H.3.3 about theeffects of 109 rads on bitumen.

in thethe flow rate for water will be takrn the same as for air
nre-accident condition. If the leak ooenin:s are unchanged insize, this should overestimate the leakage. The spilling of hot

the expected

80of the st~jtion dike at 304 ft VOL.

As assumed that leaks are distributed randomly,
The water is inthen they will occur in nronortion to area.
contact with 16,540 snuare feet of I membrane area. There is a x

pressure,

Nov.

the

for the operation and maintenance of air-cleaning enuipme nt.,,
is honed that this will be discussed in the final PEIS.

too

It

A-308

PEIS,

Nov.

•

4

PEIS,

The discussion in section 5.1.4.1 of the H;PA filters (Ref. 1)
with a given penetrationof 3 x 10-4 eachfor a total rating of 9 x 10-8.
It is then pointed out that
NRC Regulatory Guide

1.140 allows only a factor of 10-2.
In
the NRC should honor its ownn Regulatory Guide andtabulate tve numbers base-7 on 10-2.
Similar discussions
arnear in sections: 5.3.4.1,
6.3.4.1,
6.4.4.1,
6.5.4.1,
Xkk

be also mi.dified to

5

These nonulation doses must be carried out beyond 50 miles ( toinfinity) and for at least 100 yearS. The case of Kr-85 is usefulas will be show.n next.

10.4.1, (VHf. 1). In addition there are several nlaces wherea factor of 10-6 is noted as in sectionsk : 5.!.5.2,
5.4.5.3,
6.6.5.?,
6.6.5.3,
7.3.5.2,
7.3.5.3,
8.4.5.2,
and 8.4.5.3
The discussion in section 7.2.4.1 does not give a factor.
These discussions should
effects mentioned above.

89

In general it is unclear how the doses renorted in the
PEIS .,ere totaled. 2 Total dose commitmants should be given
for the nest 50 years or so.
Also, total ponulation doses
in person-rem) should be calculated for all cases, rather t'an
just nresenting the dose to the maximum exposed individual.

nresents two ,stares

this caseNov.

The -r-P5 inventory of the reactor building was estimatedat 57,000 curies.

If

this were uniformly diluted inthe atmosphere,

the concentration would bex discuss the size

1.4 x 10-20 Ci/cm3 . Given the conversion

4

ýfactor of 1.5 x 10 (rem/yr)/1()C/cm>)

from the EPA ( P. C-12,
the doae rate is
2.1 x 10-10 rem Per year ner nerson.
I here assume a linear, non-threshold dose response relationship!
as mer the 1972 HEIR renort(,.ef. 6). For a world pooulation

It is imnlicitly assumed in trese discussions thst the amountof materi•l released is nronortional to the amounts processed.
It is c~rtainlY true t'at
if no matlria! is m rrocessed, none
is relen-ed, but there are other factors tht
relate releases
to inventories. It is unclear how similar the practices and careof a DGE military facility comrare ,ith a commercial onerationof a unicue kind.
it a is also true that for many years
one of the smal'est nuclear rower reactors had the largest
releases ( Hu3boldt Gay).
There are many other variables kthat have been ignorej bh tle Ii.-C here.

Ref.

5),

of

4 billion,

the starting dose rate is
0.84 Person-rem per year.
Summed over all time this produces a total dose com' itment of
13 oerson-rem. This should he i-cluded with the other effects
in the final PEIS.
There is a discussion of bhckrround in section 5.1.5.2.
It occurs as the ton oaragraph on rage 5-8 ( Ref. 1).
Thisparagraph arpears many times thruout the PEIS, verbatum.
It comnares the radiation dose to badkrround. This may be interesting,but most readers know' the level of backrround, and at mbst need
to be reminded only once.
The PEIS is required rz by NEPA
to evaluate the imnact mf the project at hand. The exist-nce of
background cannot justify any exnosure , regardless of how smalll.

It is not indicated that workere will be using breathingarnaratus at '1) ti-es. Thus , the-• vill be breathing inradioactive dust. This should be taken into account as adose commitment in cvaluatine
occutational doses for bothnormal o-rations and accidents.
It is also true that- eorle in the general muhlic will

Deaths of peonle due to othsr causes does not justify adding to
the death rate by releasi.nd
dancerous materials, or direct murder.

absorb matrrinlýs
( Cs-1'7, -;r-90) by breathirg , Etc.
These should be evaluated as a lifetime dose comittment.

In narticular

The moni=oring of employees should be extended to include

in themiddle of this paragrarh it states thatthe health effects are non-existant", but later it evokes thelinear, non-threshold *kXry model." This is a contradiction.

urine sam-les as a measure of body burden of CZ-137 and Sr-90.
These should be taben 'weekly a-d Red/.hite Llo-d coutts should be
performed monthl y.

The linear theory clearly statcs that no effects are "non-existant".
A regulatory ax'ency should be more cautious.

A-309

-71S,

6

Nov.80A similar situation occurs in the

10I.1 ( Ref. 1) which

?EiS,

lVov.

7

S0

References

forth paragraph of section

discusses the threshold level for

1-lhePEIS discusses the nsycholonical stress imoacts to someextent. This sho:ld bew cDnsidered in light of some thinking
resort to torturethat the NEC, or otýer arencies mray have tofor rlutonium control (, Page 163, Ref. 7)1.
in interrogations
It is a small otes from heirr concerned wit'
terrorist ants
against plutoriur to such acts ar inst a. shirment of snent
fuel or othrr hich- level w=aste.

"Draft proFgrammatic Environmental IMract Statement related
to -!econntoination and diomosal of radioactive w~astes
resulting from Parch 28, 19"9,accwdent fTree V.ile Island
Nuclear
Nuclear Station, Unit 2." IUIti-O683, Draft, US.
July 1960).,erulatory Commission(

2

Proý-ram Office '. ly Stctus lienrort,
1;;C rI
October 2'6- :Novwmmhr 1 1, c.

3till the water
The thIrd r.rarranh -n mare 3-2 imnlics t!'t
in the summ care thru the 702:/. T'uch of it lea-ked out of the
Afr t:-e block valve
primary loop well after tle accident,
w!s closed.

"cJ Steindler, " Mharacterization'<e
P .Z. Jeefrldt,
of Particuol-te -Nut-niu; Hele sed in Fuel Cycle Onarationý".,~borao, L-75-78, P 71., Pay 1976
National J.'rooe

4

D....

5

f
Analxys'sa"Bnvironmento,:];'ucl]!ar Fuel Genrocessing"
Crviroom. ental Protection .

deleterious

non-threshold modcl must be t'ebosis f(rregulatory moli.cy.

The discussion in section 1.2 ( 2sf. 1)
Reactor

The linear,effects on aouatic snecies or humans.

sun,-rrts t!-ot thepressurE was reduced to LOP 7.3i on 7 I.,ril, andlatter mart
the 7resaae d c-' 'v In fct

was not increased.
of .'nril i-as

Page 1-22 (Pr.
Somethin.

et.

10 50-Pca 2S1lG. Plea.se c'-ech iit-

Vss. (1,ef 8).

0

is missing.

The discussicn on secti-on 9..5.2.1 ( >.2f.

st tes that])source of water, but tie submersion makes theItshould be noted thath.ig

:nolysis easier.

temn er-sares d, stroy

as is XM used for cement inrobilizaition of waste.

the cement V

The ECfects on no,t'1.a cranium Fue Cycle" Dart IlI
h 7-52C-/"-73-X:3-D, U.6.
aens., (ac!ober iS73)

actions of Extosure tIo(BInR),
sffects ofo.ow levels ofeport of t~e PN'diror" Com-ittee
i-ti
ne "s/PRI-,nizino-

7

C. Gordon, T. . -Gcssell,P'. Prichard, (.' n,!ýr-on, " Review
7otential
and lntegration of Existino lit,•r-.ture Concecnin,"at7rials
Social Imoacts of Tr:Insnortation of .tadioactivein Urban Areas", PURDG/CN-0742,
S. .aD78-707, (July 198C)

8

Letter fromsolidified TWI i-aýstes ý'ouO be sirilo-r t.o simulated wa:ste inThis statement is not at all ohvious, and right a-nearglass.
to be rediculus. It is sug-ested that some exo-lanation might
be useful to justify this rosition.
In the sam- discussion considc.ration shoulA be given to an
accident involving a fire and subseruent immersion in cater.
This 4s a more likely.
Post fire deoartments use water on fires.

-fcell er, "Problems in Nuclear .. ir--Cleanir:m Systems"
P. 469 ( July- P-ugust 1975)
Nuclear Safety, 16 (4):loniinr Radiation"on the Piolocic:'•!
(;,ov. 1972.

] ) %_o'snot follow from ti-e urevious roýge.

ý.ee'%rC, P.ttached as"ir7ndix,

fol'K

inj.

-

Ila
UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555

August 13,

Mr. William A. Lochstet
119 E. Aaron Drive
State College, Pennsylvania

0I
16801

S

In the Matter ofMetropolitan Edison Company, et al.
(Three Mile Island Nuclear Statio67,UThnit 2)Docket No. 50-320 OLA
Dear Mr.

3

1980

No
'0
No
F

Lochstet:

I have just obtained a graph of the post-accident pressure history for
the TMI-2 reactor coolant system mentioned at our July 11, 1980 meeting.
A copy of that graph is enclosed for your information.
Sincerely,

00-4

Steven C. Goldberg
Counsel for NRC Staff
Enclosure:
As stated
cc w/enclosure:
George F. Trowbridge, Esq.
Mr. Steven C. Sholly
Dr. Judith H. Johnsrud

_7'

-J.

QD

'-

A-311

.

.

.

..

.

~

-2-

3.

The susquahanna River is used in several ways and is critically important.
.There are several towns below m that draw their drinking water from it.
Its purity has to be maintained as high as possible for that reason.
Also, several small industries that are involved with food processing
The marketability ofalso draw water from the Susquahanna River.
their products depend on the status of the cleanliness of the river.
The Susquahanna River empties into the Chesapeake Bay whqre one of
the most productive areas for seafood and fish is located.
It is clear that we do not want the dumping of any radioactive
water into the aasquahanna river regardless of whether it has been
There is no filtering process that can remove tritium
filtered or not.
The PEIS gives no information on the effects offrom the water.
tritium on animals and plants that live in the river nor on the
Even small dose
population who would be drinking the water from it.
releases into the river would be recycled in the food chain in theriver and possibly accumulate to significant levels.

4.

The study is deficient in that there is very little information on
the ecological impact of radiation releases that might occur during
Some values were given for human consumption ofclean up operations.
water and fish from the river, but there is a paucity of informationon the ecological effects of radiation releases. What amounts could
be recycled within the food chain? What substances are likely to bereleased that would have, or not have, significant effects on the
wildlife?
We might point to a study published in the December 1979
where plutonium that was released twenty years ago
issue of Ecolo
being recycled in theat the Savanna River S.C. station is still
plants and animals and within the firat 5 cm. of topsoil both near
Dispositions of radionuclides
and at some distance from the plant.
during clean up operations should be discussed in this statement.

MILLERSVILLE STATE COLLEGEMILLERSVILLE, PENNSYLVANIA 17551(717) 872-5411

November 18, 1980
Dr. Bernard J. Snyder
Program Director, WI Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear Dr. Snyder,
Attached are our comments on the Draft Programmatic Environmnetal
Impact Statement related to the decontamination and disposal of radioactive
wastes resulting from the accident at Three Mile Island, March 28, 1979.
Some of the comments are general and some are specific. We are all fromWe
different disciplines, however most of our concerns are:the same.
have found the PEIS deficient in some respects, misleading in other respects,
You are to be complimented on requesting imput fromand inconsistent.
the outside (public) regarding a complex and involved topic..
General Comments:
Although amply detailed, this document is not a "statement." It lists
1.
only alternatives in some cases andgives the 'best' and the 'worst'
alternatives in other cases. If this is to be a statement, it should
develop a suggested program of compatable processes to bring about thesafe and expedient clean up of TMI 2. As a regulating body, NRC should
give priorities for Metropolison Edison to operate by in carrying out theclean up operations.
2.

Bvecific Comments:
1.

Throughout the statement references to different measurements of radiation
It is our opinion thatare made (e.g. RE24, RAIlS, person-rems, etc.).
every effort should be made to use one measurement of radiation.
Comparing for example the number of curies released or obtained withthe population exposure in person-rems is practically impossible forStandardize the units.
the reader.

2.

Once a plan of clean up procedures has been chosen, it is our opinion
Hearings
that there should be public hearings on the choices made.
on the EIS are called for in the guidlines of the Council on Environmental
Quality. There is no-: indication that these hearings were held orplans indicating they will be held in the PEIS. We urge you to havepublic hearings on alternatives given and dhosen in the statement.

It is our understanding that all the alternatives were considered
We suggest that not all alternatives were
for this impact statement.
in fact considered.
a.

All the alternatives given are alternatives that preclude reopeningof WI 2. No alternatives mere considered (or at least reported)that would in any way jeprodize the reopening of the reactor.
We understand that decontamination
Entombment is one example.
procedures 'will have to proceed regardless whether TMI 2 resumes
operation or not. Procedures already in existence for the decommissioning of a nuclear reactor may very well apply here. Why
were these procedures not listed as alternatives?

b.

As stated in the opening comments, cost analysis was not a factor
in consideration of any one alternative. This ii difficult tocomprehend since one method of disposal of radioactive wastes
It is a costly
was not mentioned, namely ceramics and waste.
process and we believe it was eliminated for this reason.
From our knowledge of research at Penn State University andother institutions, ceramics as a means of waste disposal isone of the best ways.

A-312

-4-

-3-

3.

a.

b.

c.

4.

to exposures of radiation do not take into account the synergistic
effects. For example, will smokers have a greater chance of cancer
deaths than non-smokers if both are exposed to additional radiation(above background)? Some analyses of radiation coupled with otherconditions that bring about itress that may result in cancer deaths
should be addressed in the PEIS.

Some of the radioactive water has already been processed by Epicor II.
The resins from this system are being stored on the island in continers
in a special pool.
There are several questions which the PEIS failed
to consider regarding these resins.
How "hot" are they? At meetings with the NRC and with Mat. Edison
it was stated that the resins were being considered for deposition
in a military depository because they mere either too radioactive for
the Washington State depository and/or because they were in a slurryand not solidified. We would hope that NRC would work with DOE
in finding a depository for these resins.

Submitted by:

How long will these resins be stored on the island? The commonly used
word is "temporary storage".
This is not precise enough.
Perhapsmore importantly, what is the maximum period they can be storedsafely on the island?
The resins are fairly acidic.
In what type of containers arethey being stored in? Some estimates from Penn State University
researchers indicate that the resins are losing as much as 4%
weight per 2 weeks.
This loss is due to the interaction of theresins and the canisters.
If this is true, then it will be avery short time before the resins will eat through the canisters.
This potential problem is not discussed in the EIS and it should be.

Conrad Miziumski, PhD
Physicistd.

What alternatives for resin waste disposal are there if
depository can be found?

e.

In the sections discussing the Health Effects of the clean up operations
constant comparisons are made using the number of cancer deaths peramount of people.
Figures on the occurrence of non-fatal cancers are
not given. This is a great oversight. It appears that the study istrying to present the smallest effect of radiation by reporting
the number of cancer deaths rather than the number of cancers that
may result. If Health Effects are to be considered in the PEIS theyshould include more than cancer deaths (and genetic effects).

no suitablef.

In a few sections of the PEIS a 'threshold dose' of radiation is
mentioned. If the concept of the linear model of dose response isused, as was stated, then there would not be a threshold dose.
This
is very contradictory in the PEIS.

g.

Radiation doses reported in the PEIS are often given as whole bodycounts.
There is clear evidence from a number of sources thatradioactive nuclides are accumulated in certain parts of the body(e.g. kidney, thyroid, etc.).
It is logical to assume that theseorgans would have'higher doses than could be apparent by giving
doses as whole body counts.
Efforts should be made in the PEIS
to itemize the radiation levels per organ.

David R. Dobbins, PhD
Biolo ist

Thomas Greco,
ChemistIn the summary it is stated that an average exposure to radioactive
releases during clean up operations would be 1.2 mrem.
This would
amount to 1.7 cancer deaths per 10 million population. It is also
pointed out that the normal cancer death rate in the U.S. is 1 in 5,
from all causes.
This is an unfair comparison because the 1 in 5
figure includes synergistic effects. Calculations of cancer deaths

A-31

PhD

William Yurkiew cz, PhD
Biologist*7~

9

le 4 en
lae

4-

55

5

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A-314

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Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.

.

.-

"
._.

__ck"_•_•></Z.d>,ct.,,o

..

.

.

,_.<~2c4• ~November 20,

,

1980

Dear Sirs:~-,~ -/.5 jd"k~2'
i 7,D.,/<-...,qt'/I",?42,.•

We, the members of Priority, the environmental action group at MillersvilleState College, appreciate the opportunity to comment on the draft programmatic
environmental impact statement related to decontamination and disposal of radioactive wastes resulting from the March 28, 1979, accident at Three Mile Island
Nuclear Station, Unit 2.
Despite numerous pages of charts, graphs, tables and text, the draft says
little about possible effects on the environment.
The words "No significant
effect on the environment is expected" are repeated over and over with little
or no supporting evidence.

>7

There are several issues we wish to address specifically.
The first isa matter of obvious error. Health effects are estimated using figures from
These figures are well below the figures given in the text:
Table 10.2.1.
"It should be noted that based on a task-by-task examination of the reactor
building decontamination effort, an occupational dose of 30,000 person-rem has
been estimated." A range of estimated dosage from 2,700-12,000 person-rem isused in the table to calculate additional cancer deaths and additional genetic
effects among offspring of the work force; this is at most a third of the dose
reported in the text.
The second is a matter of ecological effects.
The conclusions in the draft
state (12-1), "After suitable dilution, the processed water could be released to
the Susquehanna River without adverse environmental impact." This statementsummarizes the points made in sections 10.7.3 and 3.1.5 and seems to be based on
the philosophy that has haunted America since the problems of pollution began,"The solution to pollution is dilution." Whether or not one believes in thatphilosophy is not the point, however.
In Section 10.7.3, it is stated that"the use of these resources (water and air)to dilute and disperse the effluentsof chemicals and radioactive materials from the cleanup of TMI-2 is not considered
to represent irreversible or irretrievable commitments of these resources."Thatthis statement isfalse isapparent to allof us as students of biology; anychange of an eco-system must have an effect and is indeed irreversible.
The
dilution of the wastes is "assumed" in the draft, but no supporting data is provided.
More importantly, however, the biota of the river are not mentioned here at all.

...... /,:/i

In Section 3.1.5, where the ecology of the area is considered, there is no
support for the statement that no environmental effects will result from thecleanup of TMI-2.
The section reads like a local tourist guide, and a poor one
at that; it is hardly an in-depth and specific account of the ecosystems to beaffected by the cleanup. Apparently no experimental research has been done
specifically for the impact statement; it is further apparent that little researchof the literature has been done. There are no references cited on the effects oftritium and other wastes on aquatic organisms.
Unless some research investigating
the effects on the plants and animals in the TM1 area and downriver is done, any
attempt to do a "cost-benefit" analysis is meaningless.

17
A-315

NUREG 0683

Nov.

20,

1980.

-2The discussion of the storage of fuel and high activity wastes on theisland also concludes with the statement, "No significant environmental effects
Yet the impact statement also says (12-2), "Long-term...
are expected."
The statement
storage of high-level waste is not appropriate at the TMI site;"that it is "safe" to store wastes on the island is based on calculations using
Hurricane Agnes as the worst possible flood and four days as the longest-possible
istime that storage cannisters might be subjected to flood conditions. ,Itobvious that the occurrence of a worse flood is very possible; increased building
and paving over of ground continues to make flooding worse every year.

ANTI-NUCLEAR GROUP REPRESENTING YORKlb
245 WEST PHILADELPHIA STREET.

What is it that makes "temporary" (how long is temporary?) storage safe andThis is an important"long-term" (how long is long-term?) storage inappropriate?
question, especially since the recent decision closing the Hanford plant to more
nuclear waste makes the date for finding an offsite storage area further in the
In addition, the draft does not explain that the liquid
future and indefinite.
In
resins from Epicor-Il cannot be transported until-they are solidified.
Section 10.1, it is noted that after decontamination of the water by Epicor-Il
the suspended and dissolved radionuclides removed would be transported to an
For a complete picture of the TMI-2 cleanup, it is necessary
repository.""offsiteto inform the public about the problems with finding such a repository and transporting wastes

PA, 17404.

717/,843-7705

DR. BERNARD J. SNYDERPROCRA:M: DIRECTOR, TREE N:ILE ISIA:,YD PROGRA!: OFFICE
OFFICE OF NUCLEAR REACTOR REGULATICO
U.S. N:UCLEAR REGULATORY C0121ISSION".-ASMHI1GTON, D.C. 20555
C0221'TS C,, TME DRAFT FROCRAMNýATIC I-N:VIRO-72?`--TAL II'APCT STATrr7RELATED T- DZCCi:TA.kTIC;. AND DISPOSAL 07 RADIOACTIVE "A5T-3
28, 1979, ACCIDEN.T AT THREE NILE ISLAND NUCLEARRESULTI:OC FRO!:-WARCH
CUREG 0683)(N.
UI-IT TSTATIO•,TOs

to it.

OUTLINEThe Draft Programmatic Environmental Imapact-Statement (PEIS)
issued in July 1980 as :Cureg 0683 is an insufficient document inboth scope and content and therefore the NRC should issue a Revised
While
Draft PEIS for public comment before issuing a Final PEIS.

Psychological stress is addressed a number of times throughout the draft.
it is stated that some low-level stress will probably
In the conclusion (12-2),
continue in some people for as long as the cleanup is in progress and that
It seems to"Consequently, completing the cleanup expeditiously is desirable."us that the desirable factor in preventing or alleviating stress is not tocomplete the cleanup quickly but to complete it most safely.
Despite claims that the draft was written in "layman's terms," we found theGenerally, the problem
rhetoric to be nearly incomprehensible in some sections.
was not one of too highly technical language; rather, it was simply a matter of
The organization of the draft is such that related subjects arepoor writing.
In some cases, theThere is much repetition.
separated from one another.
confusion seems almost deliberate, such as tables of figures in microcuries
When there is some obvious
accompanied by text discussion framed in millirems.
attempt to relate, information for the non-scientist, as in Table 10.3.2, it isso oversimplified as

YORK,

the clean-up requires timely consideration, safety -and adequate
opportunity for public. corment on the full scope of the clean-up
are more important than simple timeliness.
The Draft PEI3 is incomplete and in violation of NEPA in thatit does not set forth or discuss the financial costs of the clean-up
and 'in that it does not discuss alternatives that would involve otheragencies of the Federal Government which might play a part in- theto be ridiculous.

Because economic costs were not available at-the time of the preparation of
The cost-benefit analysis printed in thethe draft, they were not included.
draft simply states that the cost.of not cleaning up TMI-2 outweighs the cost
The validity of this analysis is undermined by the lack ofto the environment.
supporting evidence throughout the draft statement.

clean-up.
The Draft PEIS is insufficient in scope in that it does not
but should also include discussion of the impact that the restartof Unit One has upon clean-up, particularly in the disposal of
additional spent fuel created by the operation of Unit One, the"abnormal occurances,"
impact of possible accidents, incidents,"unscheduled outages," or run-of-the-mill unusual events might haveupon the clean-up or the licensee's ability to effect a safe clean-up.
It should also adress the psychological impact of the restartof Unit One during the clean-up and the possible stress related to

The effects to the environment of the accident at ThI-2 and the cleanup
However, we feel that the draft
procedures will not truly be known for years.
leaves some essential questions unanswered and some important conclusions
unsupported by scientific data.
Sincerely,

Carolyn J. Kroehler, President
Priority, environmental action clubMillersville State College
17551
Millersville, PA

A-316

-3the decision on the disposition of.Unit .wo,and stress caused by

the combination of the restart of Unit One, Unit Two and the
Surely this assessment should be in thisclean-up processes.
Programmatic EIS and not be allowed to slip between the cracks

the INRC fails

to comply with its

requirement thatconsequences are of the lack of adequate funding or of having tocease in the middle of the process for lack of funding.
The timeline set forth for the Final PIS is unnecessarilyadvanced and does not allow enough time for the Three 1Nile Island
Advisary Panel to research and-assess the situation, and it does
not, perhaps intentionally, allow time for public input on the many
By adhering to this timeline
gaps in the statement as issued.
and not issuing a Revised Draft PEIS the NRC will further erode
public confidence in the !RC and cause further stress and frustration
including the state and local representato the area population,
tives on the Advisary Panel whose time and efforts will be wasted
if they are not given the time and resources to do the job thatthey have been asked by the 1-RC to do.
The Draft PEI3 is more notable for the missing information
than for the actual comment; discussion of what is in the Draft
PEIS follow"s discussion of specific lacks.

that mandates public

Therefore,

stage.

that fully sets forth all

the cost details.-

human safety,
Costs, w-;ithdetermine the the alternatives elected.
But costs
are the most controversial aspects of the statement.
are only peripheralyy referred to because the N;RC knows *that the
public will demand to have a full hearins as to how much eachThus,alternative will cost and from where the money cill come.

A-317

on the PEIS,

At one of the NRC presentations(intativean !RC represen-

response to a question) stated that the PEIS does notdiscuss alternatives
discussion is

involving other arencies because such athe question::ore particularly,

not permissible.

involved the possible use of missle silos as storage
The representative

wastes.
feasible,such a theory is

court cases interpreting7 NIFA so as
sider and discuss alternatives
one issuint the Statement.
Revised Draft FIS
wvolveany othermandatory w'here,as ina Statement

involving arencies other

Therefore,

instance,

would

to con-than thethe NRC should issue aSuch a discussion is

this

Army,

inconsistent withto requirethat discusses and alternatives
agency.

(thesuch an alternative.

theRC could not consider

Besides being bureaucratic,

for contaminatedindicated that the.idea was considered

but because an agency other than the NRC

be involved,that would

particularlya solution might be feasible

and possible.
There isThe Draft P1IS barely discusses the respective costs of the
Ruman safety is held forth as the mostvariuos alternatives.
important consideration in the evaluation of the alternatives,
yet, in reality, the costs will be the primary factors that ,aill

input at the draft statement

the !%RC should issue a Revised Draft PEIS

not only adequate

but also sfety and public
DISCUSS I0N

and substance of NEPA and the :,*RC

This defeats the spirit

regulations

FEIs.

its

to adequately discussstatement will more fully set forthcosts by saying that the final
costs.

and regulatory

requirement

The NRC cannot elude its

separating the issues involved,
The Draft PEIZ is also incomplete in that it does not set forthor select criteria for the selection of the mode of clean-up anddoes not identify the YRO'staff"s choice amoung the modes ofFurther, it is incomplete in that it not only
clean-up discussed.
does not address financial costs it does not address w,,hat thehistoricalcost analysis be performed ina detailed

time for a Revised Draft FEIS
require it.

confidence

On page S-3.Section 3.2,"....tinely

the Staff states,of the damaged fuel to safe storage

removalthe paramount .objective ofisthe clean-up.""Timely removal" should not bepriority.

the first

removal and safe storage must be the priority.
decontaminate and defuel the reactor poses a

public health and safety.
that the staff

presents

N::oreover,-reat danrer to thein the PEIS,

does not justify

deserves priorty over long-term safety.

its

Safe

Any rush to
the information

conclusion that sceed

-4is-notadequately addressedinthe T1I-i restart

must not be allowed to be ignored in

Dispite repeated public requests that safer disposal of
KR-85 be used the 1RC allowed venting because, it claimed, speed

radwastewas essential in order for the licensee to do vita• maintainance.
The FRC decided to allow venting ostensibly because of timelinessbut in reality we think this was because the licensee did notwant the expense of safer disposal.
In the four months sinceventing the licensee has done little
or no naintainance aid haseven delayed or temporarily suspended clean-up operations because
So much for the importanceof financial conflicts with the Pa PUC.
of a speedy removal of K}R-85; we find that the licensee's finances
determine the safety of the clean-up, and once again publicconfidence in the ,RC is further eroded.
TheStaff states, rightly, that Three 7:il e Island is nota suitable site for long-term storage of radwaste.
The PEIS focuseson the dangers of leakage and recriticality if the waste remains
within the containment building for a long time.
But the PEIS does not demonstrate that removal from containmnt
will reduce the chances of leakaces into the environment.
Lnreality, the Staff wants to keep the restart option open and thus
dismisses all alternatives which would preclude restart.

TV.I-2The PEIS confesses (at 2-i) that "there is currently no waste
repository open for the disposal of high-specific-activity andtransuranic wastes, it will be necessary to place these 'astes in
temporary storage until a permanent waste repository can be found.
Onsite storage is considered for this temporary measure."
Furtherthe restoration and restartdisposal from "normal" operation of TgI-2

be addressedinin the PEIS,

1986,

given thatthe licensee";ile Island,inRiver which feeds the largest inland

the middle

commercialof GFU.

of the Susquehanna

fishery in

The PEIS does

for spent and damaged fuel and other radwaste?
and itnot-address this,'herepository

world will the r:RC allow to become a 30-year "temporary'should.

Such "interim onsite storare"isconsistent with the practiceof storing high-level waste within the containment buildincs.
This forces the question:
The supposition

w.hat sort

controlled storawe within theinof onsite storage

safest?

not founded

containment building is'hy then should there be any rush to move

the PEIS.

The PEIS

off the island?

and no forseeable place to move it

provides no reasonable

the fuelno safer place to store

from the containment building when there isit,isthat the bunkers proposed will be safer thanfor the rapid decontanination

justificationand the removal of the fuel fsom containment.

lonp-term

Safe,"interim" storage within the containment must be considered.
The

only conceivableof "timely wem'oval'

justificationof the TM•I-2 reactor.

disnosition of T:I-2
(p.

...

is

not within the scopeis

The Staff isthestates thatperpetrating a fraud on the public when itof this"ultimate

FEIS"

S-i).
On page 2-6,

refuses to consider thethe Staff explicitly

alternatives

federal policy on high-level waste disposal, such a length of time
for onsite storage of hith-level wastes seems probable.
The PEIS must therefore address the additional waste which
T:.:I-I would generate if it is allowed to restart.
7'ot
only mustthe higrh-level spent fuel ''astes be considered, by also the inter-made of the nuclear steam supply system...

A-318

should also"plans" to reopen

according to recent financial statements

How much of Three

dovrm on page 2-2, "lon.-term storare" is defined as "beyond thenormal operating lifetime of a pow:erplant, which is approximatelyThus, the P2IS considers storage of high-level w'astes
30 years."
onsite for up to 30 years.
Given the current lack of a coherent

mediate and lo:-level wastes which the "ovember elections in the
Ltate of .lashington may not now allow at -isinford.
This consideratior

Hearings and
The question of

the PEIS.

of "destructive decontamination" becauseit"implies

assumes on page 1-1,

"A

decisiona decision not to rebuild."

restore or decommisssion

to either

the facility

probably w.ould nota detailed inspection and engineering assessr.:ent

occur until
requiresItthat the core he removed."that only technical

To make this, This isa blatant assumption

and design or financial considerationsof the restattof a reactor

the possibility

destroyed"an area the size of the state of Pennsylvania."
fraud concerninE

consideration

willthat almost

determineThisisinspection

the scope of the PZIS and the lack ofof the effects of the possibilityof restarting

either

Ew-

-- O-

even more reprehensible in the Staff's
At page 3-24, the Staff

Unit Cne or Unit Two isof "psychological stress."consideration
states-0----

that "Theplans for T-1-2,

responsible for those activities."
created by the potential

It

disposition of Unit T'woof the many.:ho want T7I out of theirand most local poll she.: that ,5?-60, of the people

forever,area do not want even TI.2I-l

to ever go on line again,

refuses to acknow.%led-e that it

Staff

possibilityof eitherof stress in

this

not

the violations of h:EPA by omissions,analyses of alternatives
itisunreasonableitisissued by the beginning of the year.

impossible for the newly-formed

job by the Staff's

January deadline.

lives
In

and advice of theirchoosing,

inthe T1[Itechnical support

addition to sufficientaddress the issues set forthand those omitted

but theTHI Advisary'Je also

recommend that the T:RC Commissioners empow.:er and enable
Advisary Panel by providinr funds for outsidethehere and inlistedto expect that a complete

in

time

this

to

Draft PF5I.

the rFRC's allow-inr theisthat isreactor to restartarea,

Likewise,
Panel to do its

The Staff'sof either reactor.

restartinclination to put off any decision on themultiplies the stressignores the stresscompletely

issued,and satisfactory PEIS could beof thoseand a distrust

the PEIS asother cowmentaries,

continuing tension seems related to two issues:

future decontaminationinand the insufficientjust the clean-up

the central

cause

or the distruSL

of

Respectfull,

submitted,

the I.RC and the licensee.
In

the case of the ',R-85 venting,the iRO's haste

venting instead of a safer 7,iode of clean-up
public,of the •,[2C by theand increase distrustand frustration,and yet on paCe S-11

inallo'inm

served to increase stre-s
generalstates " The long-tern nature

itof theclean-up pro.ram presents the potential for chronic psycholoricalstresspeople;for sore

expediciouslyisever. zoes so

The Staff

co-nipletimg

the clean-un

Their conclusion. is

i.I;ply wrong.

consequently,

desirable_"

far asto claim

stress(page S-11)that

has been relieved,"now that the venting of the reactor buildina

has been completedin

a controlled manner."

cation does the Staff have for cuch a bald,
The licensee
clean-up activities
approved,justifi-statement?

has elected for financial reasons to sloew., theto a cra.l'-

operation scheduled for 1931 isis.;hat possible
erroneousthe only major decontaminaticn
the operation of SDS--

if

that

*...'hich we go on record opposingfor reasons better

covered by the Susquehanna Valley Alliance and other commentators.
Under the circumstances,and the licensee's slo%'.-don-,of the Draft FEIS, there is

PEIS that is

as nressinr a need as to insure

opportunity for public
directions

conment

and for full,from the T IAdvisary Panel.

occured after

no need to issue the Final

the issuancecompletenessinformed

In

fact,

and fulland consideredriven the gaps

A-319

, ail Bradford, .on behalf of
the Anti-,uclear group
Representin; York.
This Comment was prepared by
Stephen Drooks,
Penny Sanstead, Esq.
and Gail Bradford.

3164 Main Street

Buffalo, New York 14214

3184 Main Street(716) 832-9100

November 24, 1980
Dr. Sernard Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dear Dr. Snyder:
The Sierra Club Radioactive Waste Campaign wishes to submit the enclosed
comments on the draft PEIS for TMI-2 cleanup. These comments are submitted
four days late and we apologize for the delay. As a citizen group whose primary focus is not TMI but other nuclear waste matters, we have not been able
to put full-time effort into our review. We trust that these comments can befactored into the final EIS without too much difficulty.
Je would appreciate it greatly if you could send us the final EIS on
T•I-2 cleanup.
cc:

Sincerely yours,

B. Hess

Buffalo, New York 14214(716) 832-9100

COMMENTS OF THE SIERRA CLUB RADIOACTIVE WASTE CAMPAIGN
on theDRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENTRELATED TO DECONTAMINATION AND DISPOSAL
OF THREE MILE ISLAND-2 WASTESNUREG-0683

PIRC
NIRS
r. Marvin ienikofco-director

The Three Mile Island-2 situation, if not so desperate for citizens in
the vicinity of and downstream of the TIII-2 reactor and for Met Ed and its ratepayers, uould be comical.
Reactors are built on an island, in a river - an absolutely unthinkable location for a permanent radioactive waste repository, yetthere is no acceptable location for the TMI-2 wastes.
No permanent waste repository exists and space is severely limited in low level waste burial grounds.
;!here will the radioactive rubbish be taken? The Harrisburg community understandably wants each gram of radioactive contamination removed, yet no community wishes to accept the material and many do not even want this toxic material
to pass through its borders. Met Ed is busily in the process of decontaminating the T1`I-2 reactor, chat is, it is in the process of moving
radioactive
material from one-place to another, attempting to collect and reconcentrate theradiation in one location. According to the PEIS, this decontamination to al.:iost"surgically clean" standards, is taking place in order to stabilize the
TMI-2 reactor.
This decontamination is taking place at great cost to the occupational personnel at TMI-2 and to the ratepayers of Met Ed, who must bailout the utility and the banks for their, and not the ratepayers', mistake.
Itis clear to any disinterested observer that Met Ed is on the path to rebuilding
and restarting TMI-2.
There is no other reason for making TMI-2 "surgicallyclean" .t this time.
The Harrisburg conmunity is opposed to the restart ofeither TMI reactor, yet the utility and the NRC are intent on imposing theirdecision on an unwilling populace, the absolute antithesis of democracy in action.
The TMI-2 situation is replete with irresolvable contradictions.
The Sierra Club Radioactive Waste Campaign, an educational and organizing effort by the Sierra Club on the issue of radioactive wastes, has examined
in detail the PEIS, NUREG-0683.
Gur viewpoint is that of an environmental organization located outside the immediate Harrisburg area who is concerned about
the health and safety of Harrisburg area residents, occupational personnel, andthose residents living along transportation routes and near low level waste
dumps.
Because of our experience at the West Valley low level waste dump and atother radioactive waste sites, we have been able to compare the NRC claims on
decontamination factors for HEPA filters, submerged demineralizer systems, etc.
We do discuss these matters under Specific Comments below.
However, what isneeded here is a discussion of overall policy and direction and not a fixation
on minutia or a debate on whether the PEIS is "off" by a factor of two on cesium
releases to the environment.
, great weakness of the PEIS is that it is lostin detail and lacking in creativity.
The major question must be addressed: how
Is the cleanup to proceed and towards what end?

rae

F.

sierra club
radioactive waste:club

i wasteT. • "-,I"nA-320

Sierra Club Comments
Page two

Sierra Club Comments
Page three.

PROPOSED NRC DIRECTION TOWARDS DECONTAMINATION
AND DISPOSAL OF TMI-2 WASTESWEST VALLEY IS UNFIT AS A BURIAL SITE

In gross outline, the NRC plan is to decontaminate all sections of theTMI-2 reactor and concentrate, by zeolites and resins, all radioactive contamination, except tritium. After most of this work has taken place, the reactor
pressure vessel (RPV) will be opened and the uranium fuel will be removed.
All
All radioactive materials, in up to 1700 shipments, will be taken to an unknown
waste dump 2300 miles away.
Radioactive materials which have not been adsorbedby the ion exchange resins will probably be released to the Susquehanna River.
We assume that an EIS will be produced to show that the harm is trivial compared
to background radiation.
Then, after up to 12,000 person-rems of radiation dose,
have been absorbed by occupational personnel, a decision will be made by Met Ed
and the NRC Staff, with criteria presently unknown, whether to reconstruct thereactor internals and restart TMI-2.
That decision will be an economic one andhave little to do with the public health and safety.
The above approach by the
NRC is based on years of past decontamination practice, and, from our perspective, is intended to lead inexorably to the startup of TMI-2.
We suggest insteadan alternative approach which will lead to lesser occupational exposures andlesser environmental releases, but will not lead to the startup of TMI-2.

Because many persons, including the NRC Staff, are unfamiliar with theoperating history of the West Valley dump site, we want to briefly sketch thesalient points. As will be clear, West Valley is not an option to be considerThe poor operating history of the West Valley site is
ed for the TMI wastes.
primarily due to the poor location, but was compounded by the operator, Nuclear
Fuel Services.
The West Valley burial ground was opened for commercial radioactive
As an Agreement State, it was licensed by the State of New
wastes in 1965.
The burial
York.
Clearly inadequate studies were performed at that time.
ground consists of long trenches 500' to 700', dug 20 to 30 feet deep in preThe area has a heavy rainfall and the soil is waterdominantly clay soil.
saturated and relatively impermeable except for sand lenses wi-thin which water
One set of trenches, the northern trenches, were filled
moves more rapidly.
by l970; another set, the southern trenches, were filled between 1970 and 1975,
The trenches are covered withwhen the burial ground was finally closed down.
a clay cap -4' in the northern trenches and 8' in the newer southern trenches.
In 1975, radioactive water broke through the top clay covering of the trenches
The reason for burial ground failure could
and began to enter the waterways.
If one digs
have been diagnosed by a third grader who has played at the beach.
a hole in water-saturated earth and fills it with floss (filters, resins, papers and animal carcasses), the hole fills with water. This water entered the
The capped northtrenches through the clay top, but also through sand lenses.
ern trenches filled with water, broke through the cap and radioactive water beit was thought that the
can to flow out, like water overflowing a bathtub.
newer southern trenches, capped with 8' of clay and contouring to aid water
The optimism concerning the southern trenrun-off, %!ould not fill with water.
ches was expressed by DOE,".xperience with the southern trenches indicated that it is possible
to operate and maintain the burial area so that there is no significant release of radioactivity.""...experience with the southern trenches would indicate that filtration through the caps should now cease and erosion should be prevented."(TID-28905-2, "iestern New York Nuclear Service Center Study", November,3
3
1978, p. -5 , DOE)
At the same time DOE was writing those sentences, Nuclear Fuel Services was
pumping out the southern trenches to prevent a recurrence of the cap breakthroughof the northern trenzhes, i.e., DOE was telling a direct lie. This radioactive
trench water was pumped to a water treatment plant, similar in some respects to
EPICOR-Il.
Cesium and strontium were removed and placed back in the burial
ground; tritium was released quantitatively to the Cattaraugus Creek watershed.
Between the years 1975-1977, two million gallons of radioactive water were released to the environment, including 6,700 Ci of tritium. The figures are not
yet available for the period 1978-1980, though we do know that 700,000 to 900,000
gallons of radioactive trench water were pumped from the southern trenches in1980.
Unless the radioactive material in the burial ground at West Valley is
exhumed and placed in above ground bunkers, a position the Sierra Club Radioactive Waste Campaign advocates, this problem, leading to the continual radiooctive release of radioactive materials, will recur for hundreds of years.

SUGGESTED DIRECTION
The NRC plan should be directed instead towards the goal of zero releaseof radioactivity, and a minimization of occupational exposures, consistent withthe goal of stabilizing the reactor so that re-criticality cannot occur. We
suspect that this requires opening the RPV to remove the fuel which is now distributed within the RPV in an unknown array, though we are not convinced by the
NRC Staff arguments that this is necessary.
Ue think that the only decontamination work that should take place should be directed towards this end. We differ
with the Staff that the containment building should be "surgically clean" before
the RPV is opened.
Continual decontamination work and recontamination of previously cleaned areas will only lead to higher occupational exposures and is not
Our recommendation is the following: a lead-lined conconsistent with ALARA.
trol room inside the containment building, within which operators could manipulate remote equipment, should be designed and constructed.
Such a shielded
work room is required in any case to remove TMI-2 reactor internals at a laterstage, ýnd is needed for decommissioning reactors that operate 30 years without
accident.
If it is necessary to remove the sump water, it should be placed inshielded tanks.
After securing the reactor, the U fuel could be placed in casks.
The end result would be a contaminated containment building, with all radioactive liquids remaining on-site.
This situation would remain so until a permanent
waste repository is available to accept the contaminated materials.
At thatlater time, the radioactive cesium and strontium could be separated from thetritium, which would have decayed to low levels compared to the Cs and Sr, orthe entire quantity could possibly be shipped as a liquid and be made into a
It makes no sense to us to make thecement at the Federal waste repository.
containment building "surgically clean" and to prepare the radioactive materials
for transport at this time when there is no burial location that would accept
the radioactive garbage.
It is absolutely necessary that the company be forced to set aside aliquid decommissioning fund for the later decontamination, transportation andfinal disposal costs.
These liquid funds must be an independent public agency.
This proposed direction, discussed under Specific Comments (E) below, would
lead, we believe, to almost zero environmental releases, lesser occupationaldoses, and be less expensive in present day dollars. We therefore propose that
the NRC give it serious consideration.

The problem of the West Valley burial ground is of concern to a large
population since Cattaraugus Creek enters Lake Erie near the water intake forFurther down Lake Erie this radioactivity enterssouthern Erie County towns.
the Buffalo water intakes.
These water intakes service 1½ million people.
Because of the annual rainfall and inadequate geology of the West Valley site,
it is a poor location for a low level waste burial ground. Further, the con-

A-321

Sierra Club Comments
page four.ierra Club Comments
Page fivesciousness of persons in Western New York concerning toxic and radioactive wastes
is very high. It would be an understatement to say that additional radioactive
materials would not be acceptable.

B.
The total radioactivity released from the U fuel to the sump water andother locations within the T1I facility seems rather high, higher than we had
previously thought.
Over 50% of the Cs-137 produced in the fission process
is now dispersed within TMI-2.
The nuclear industry and the NRC Staff haveoften stated that no more than 1% of the Cs contained in spent fuel assemblies
could be released in a spent fuel transportation accident.
For high.burnup,
short-cooled fuel assemblies, in an accident involving a loss of coolant, it
appears to us, based on the TMI experience, that much more than 1% could be
released.

ARE THERE OTHER LOWLEVEL BURIAL SITES?
To recount the low level waste situation in the United States, the lowlevel waste dump at Maxey Flats, Kentucky has had simil'ar waste migration problems. The dump at Sheffield, Illinois, is filled and the State of Illinois has
opposed its expansion. Of the three remaining sites, Carnwell, SC, is still
accepting radioactive wastes, but is reducing acceptance to ½ of previous levels. ýecause of a recent referendum, the Hanford , Washington site will be
The remaining site at
off-limits to all but medical wastes after July, 1981.
Beatty, Nevada is open, but the Governor of the state is attempting to close
Pu-conit after operating irregularities, and waste transportation mishaps.
taminated wastes are barred at all, but the Hanford site, and that wil'l be offlimits after July, 1981. While it is generally recognized that TMI, in the
middle of a river, is not the proper place to dispose of radioactive materials,""here is not a safe or publicly acceptable site to take this radioactive garaage.

To document this assertion, we have the following amounts of Cs-137
in various sections of the TMI facility:;,uxiliary Building Tanks (Table 5.2-1)
Auxiliary Building Sumps (Table 5.3-2)
Containment Bldg. Sump Water (p.6-13)
Primary Coolant System (Table 7.2-2)

Cs-137 (CilT.87
r x - 10F

9,000
4.32 x l10
1.39 x 104
4.84 x 105

Assuming a burnup of 3165 MWd/MT, 90 MT of U fuel, and using the computer code
ORIGEN, a total production of 9.06 x l05 Ci of Cs-137 is expected.
Thus, 53%of the produced Cs-137 has been released to various sections of the TMI-2 faciiity. This may indicate that more than 50% of the U-fuel was exposed to airfor extended periods of time.

Since the Federal government cannot resolve this issue, it has asked thestates to do so. Federal legislation is being readied to allow states to enter
into compacts. One state may have a facility for toxic chemical disposal andanother state may have an ideal location for radioactive waste disposal,(wedoubt it). A swapping of poisons would occur. It is our intuition that state
governors will have less success locating a low level waste dump than the Federal
government. It is not a function of the level of government, but the technicalfact that there is no secure radioactive waste burial ground in areas of highrainfall, and there is a continuous infinite stream of radioactive materials
to be disposed of.

There also seems to be an anomaly in the data in the PEIS in the ratiosof Sr-)O to Cs-137.
The ratio Sr-90/Cs-137 is 0.68 and 0.016 in the primarycoolant, system and sump water, respectively.
One would expect this ratio tobe the same in both systems.
The NRC Staff should explain the reason for thedifference.
C.
The population and occupational radiation exposures in the PEIS due tothe transportation of radioactive materials appear low.
Our estimate, using
WASH-1238, is 435 person-rems.
The NRC estima~tes 26 to 66 person-rems (p.S-l0).
Assu~ing a dose of 10 mrem/h at 6 feet, a population density of 130 people per(km)- (which is representative of populated areas), with no person closer than
30 meters, a travel distance of. 320 km per day and 1700 shipments of 2300 miles,
u!e find a radiation exposure to the population and .occupational personnel of.155 and 280 person-rems, respectively, or a total of 435 person-rems.
'e differ with the NRC as to the significance of these radiation expo-

Since there is no acceptable location for Pu-contaminated radioactive
materials, it is our position that TMI should be secured so that no off-site
releases occur, &nd re-criticality is not a possibility; This should occur
with minimal occupational exposures. We disagree with the NRC head-in-the-sand,business-as-usual approach of securing Cs-Sr for low level waste disposal, releasing tritium, and scrubbing the reactor till it is "surgically clean". The
NRC plan is a thinly disguised attempt to start up TMI-2 again.
SPECIFIC COMMENTS

sures and others, within the PEIS.
The data from Hanford workers, as re-analyzed
by Gofman (Health Physics 37, p.617 (1979)) suggests 3,774 additional cancers
per million person-rems.
TUther analyses which the NRC employs suggest many
less cancers.)
Thus, the Hanford data indicates 1.6 additional' cancers fromthe transportation of TMI radioactive materials.
Genetic effects may be threetimes this number.

A.
The PEIS is not complete because no economic costs have been included.
According to the agreement between the City of Lancaster, the utilities andthe NRC (p.1-23), no discharges can take place until the PEIS is complete. Apparently, these economic costs will be put in the final EIS (p.1-1).
If thisis so, Che public must still be given an opportunity to comment upon this section before the EIS can be considered "final". The economic costs must include
costs of transportation and disposal.
There is a real possibility that Met Ed
may go bankrupt before cleanup is complete, the remaining assets (less TMI-l
and -2)being purchased by another utility. The EIS must address this possibility and the consequences.
Citizenslin public hearings have asked the NRC
to address this point concerning Met Ed bankruptcy and the NRC has stated that
this comment has "been considered in planning this statement where appropriate
to its scope".
However, questions of Met Ed insolvency have, in fact, not-yet
been considered.

D.
The major number of additional cancers and health effects will arise
from occupational exposures and these will be greatly increased with early decontamination.
The NRC estimates a range between 2,700 and 12,000 person-rems.
If the occupational exposures reach 12,000, the-number of additional cancers
among workers may reach 45 (with genetic effects three times as much).
Assuming 200 workers (an arbitrary number) involved in radiation work at TMI, one

A-322

1.I

Sierra Club Comments
Page six

Sierra Club Comnents
Page seven

would expect 50 cancers since the cancer rate is 20% of deaths.
Thus, occu-.
pational personnel may have a doubling of the cancer rate due to cleanup opera.
tions. This occupation is, by far, the most hazardous industrial adventure in
These exposures could be greatly reduced if the goals of
the Unifted States.
the cleanup operation were changed and the methods were improved.

active liquids could be reduced by evaporation later, and the evaporator botIf it is desired, the tritium, contained intoms could then be solidified.
The NRC Staff objection to the evaporatthe evaporate, could be solidified.
ion process, that iodine would also be vaporized with the water, is correct.
However, the zeolites and resins are also not effective in trapping iodine
either. The evaporation method a hieves decontamination factors for non-vol-E.
We are in agreement with the NRC Staff that the "paramount objectiveof the cleanup of TMI-2" should be the "timely removal of damaged fuel to safe
storage", in order to prevent criticality. However, we believe the scope of
It is notthe actual effort indicates that Met Ed desires to restart TMI-2.
required to make TMI-2 "surgically clean" in order to secure the damaged U fuel.
couldcontainmentbuilding
objective",theIf restart were not the "paramountremai•-in its present contaminated state, except for the possible securing of
the sump water.
Cleaning the TMI-2 facility to "surgically clean" standards
will only increase the occupational exposures and environmental releases ascompared to other options which could be employed.
We suggest instead a shielded control room. designed to be quickly
assembled within the containment building, be set up above the RPV.
All operutions,'such as removal of the RPV head, used fuel and other operations, shouldbe accomplished remotely by manipulators from this inner control room.
Such ashielded room, albeit less substantial than the one proposed here, would haveto be constructed in any case under the NRC plan to remove the U fiel pellets
and reactor internals (we do not propose removing the reactor internals, if
this can be avoided).
Further, such a shielded room could also be used atnumerous reactor decommissionings or accident situations. From the containment control room, the U fuel pellets could be prepared for removal by theoverhead crane through the fuel channel and loaded into casks.
If the reactor
internals need to be removed in order to remove the remaining fuel pellets (ifthere is sufficient remaining to cause criticality), they could be dissected
and placed in shielded containers, assuming cutting torches are developed to
cut through the thickness of commercial reactor steel.
We see no point in separating Cs, Sr and other radionuclides from tritium
at this time since the radioactiv material cannot be moved anywhere at present.
Radioactivity, un the order of 10ý Ci of Cs- 137 must be buried in a permanent
waste repository and none will be located until the year 2,000 at the earliest.
On the other hand, TMI-2 should not be considered anything more than a nearterm holding tank for this radioactive contamination.
We believe that the NRC should examine the option of a 60 year holding
period in much greater detail.
After a long waiting period, the radioactivity
would decay to less than a fifth of present levels (assuming 60 years) and theresultant occupational exposures would be a fraction of the preferred option.
F.
Even if the NRC decides to make the containment building "surgicallyclean" and to remove U fuel and damaged components of the reactor at this time,
the liquid radioactive contamination could still be held in specially designed
tanks within the containment building.
There does not appear to be a need to
immediately remove the liquid contamination from tanks within the containmentbuilding and to separate Cs and.Sr from other radionuclides at this time, uniess the NRC and Met Ed wish to restart the TMI-2 reactor.
In a 30 to 40 year
pericd of time, tritium levels will be reduced to less than 10 Ci while Cs
levels ,•ostill be on tne orter of Z Ci.
*t a;•pars to Lis t'r.t.ne ra.no-

atiles, on the order of 105 to 10.

G.
The planning schedule andmethods for removal of the fuel and lower reactor internals is not sufficiently detailed in the PEIS.
The NRC Staff refers
to fuel removal by "special equipment".
What does this mean? The Staff mustspecify what it is referring to.
If the equipment is not available, the STaff
must specify the R & D requirements and the probability of success.
To cutup reactor internals, a plasma arc has been used to cut through 1½ inches ofstainless steel underwater at the Elk River Reactor, but it will probably benecessary to cut through 2 3/4 inches of stainless steel at TMI-2, more if
the metal has agglomerated.
The carbon steel pressure vessel at the Elk River
Reactor was 3½ inches thick; a large power reactor would have a pressure vessel 9 inches thick.
H.
The postulated accidents considered in the PEIS inexplicably do notinclude the possibility of reactor startup. Since the purpose of all the decontamination and disposal is to avoid re-criticality, we regard this as afatal flaw in the PEIS.
The Staff does note, on p.S-3, that it is possible
for re-criticality to occur, "even though improbable".
Yet the Staff does notaddress the possibility of this occurring during cleanup operations at TMI-2,
especially the possibility of this occurring while the RPV is opened.
It seems
to us that this is the worst credible accident and therefore it must be addressed under CEQ guidelines.
The Staff argues both ways on this point.
Onthe one hand it states that neutron absorbing material, especially boron in
the coolant, has been effective in preventing criticality. On the other hand,
it states (p.2-7) that neutron-absorbing material may not reach all parts ofthe fuel because of blockage within the reactor.
This argument is advancedby the Staff in opposing a suggestion to fix the reactor with neutron absorbing material that dries to a solid.
It seems to us that if boronated watercan reach the fuel, so can other liquid neutron absorbing material.
If noliquid reaches the fuel, no criticality can occur in any case.
The sections
on recriticality and the probable success of different types of neutron absorbing material have not been done carefully and should be considered in greater
depth by the Staff.
I.
From our experience with nuclear companies who disappear when the clean
up bill must be paid, ue believe that the Staff must, with each option considered in the PEIS, indicate how that option will be financed.
The option proposed here, removal of damaged fuel, minimal decontamination and holding tanks
for radioactive liquid materials, is the least expensive option, in present
day dollars.."ost deferred action options are less expensive in present day
dollars.
However, we only support this option if a decommissioning fund is
set aside by Met Ed and the liquid funds are administered by the NRC or theState of Pennslvania. It this is not done, Net Ed will likely disappear whentLeimust be paid. The NRC Staff will probably argue that the NRC only
regulates the public health and safety aspects of nuclear power and the State
Public Utility Comnmission sets the rates.
We regard the two as inextricably
linked in this case.

.~,4eIo,~Avly,-.\,a ,

frQien6s & fAiLY Of: trmi
P. 0. BOX 82, HIGHSPIRE, PENNSYLVANIA

November

20,

I

ple,-l V1 Ck.

17034

1980

CL

(

1

e'oc

e-4

0

~ ~C

0'v(, ? ý. j.

"

epA

Dr. Bernard J. Snyder
Program Director
TNI Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Dear Dr.

'1-7ZI
t

T e

s -

i

k Y"

c)OSkI4I
6

Snyder:

The Programmatic Environmental Impact Statement presents comprehensive
choices of cleanup for Unit 2.
We of Friends & Family of TMI would like toaddress one of the activities
of cleanup (the treatment of radioactive liquids),
recognizing that this is the essential firststep in the entire cleanup process.
We are confident that efficient technology exists to decontaminate the radioactive
water, and we urge that this be approved and implemented as soon as possible.

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Specifically, we feel the Submerged Demineralizer System now underconstruction by Metropolitan Edison Company is a safe, efficient means ofprocessing contaminated water.
Friends & Family believes this system iscrucial to the cleanup process, and we urge the NRC to approve its
use.
Processed water should be either returned to the. Susquehanna River orused for further decontamination efforts.
Of the alternatives for dispositionof the 6rocessed water, these seem to be best.
Solidifying the water or
evaporating it seem to serve no one's best interest.

Oaýýe-Go-ý

A-c,+0,re- ,The large amount of contaminated water generated by the accident in
Unit 2 can be efficiently and safely handled by the systems Metropolitan Edison
Company now has, instead of searching for other ways to get the job done, andthus prolonging the risks and stress.
Friends & Family supports the methods
stated above as described in the Programmatic Environmental Impact Statement.

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Sincerely,

Lori Dubiel
President

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11/19/80-1V1h of)cd*

Comments on
ENVIRONMENTAL IMPACT STATEMENT BY NRC
byGeorge K. Tokuhata, Dr.P.H., Ph.D.*
Director, Division of Epidemiological Research
Pennsylvania Department of Health*Also, Professor of Epidemiology (Adjunct), University.of Pittsburgh Graduate
School of Public Health; Associate Professor of Community and Family Medicine(Adjunct), Temple University College of Medicine.

DEPARTMENT OF HEALTHHARRISBURG

November 20,

1980

Comnents made on the draft Environmental
the U. S. fNuclear Regulatory Commission,
Mr. Bernard J. Snyder, Program Director
Three Mile Island Program Office
Office of Nuclear Reactor Regulation
Nuclear Regulatory Comnission
20555
Washington, DC

Impact Statement prepared bydated July 1980 are primarily con-fined to those areas related to offsite radiation doses and health effects,
including psychologicalstress and behavior in the local population.

The NRC staff's conclusions regarding potential health effects are based

Dear Mr. Snyder:on the existing literature on the biological

You have requested a review and con•nnt regarding the Nuclear
Regulatory Cannission's Environmental Inpact statement.

(health) effects of radiation andsome of the studies conducted since the TMI accident,

Attached are the oemments of George Tokuhata, Dr.P.H., Ph.D.,
director of the Pennsylvania Health Department's Division of Epidemiological Research.

lated to the psycho-behavior of local residents.

I trust Dr. Tokuhata's camments will be of assistance to you
and your staff in your important discussions.

psychological effects.

particularly those re-Our comments are divided into two major components:

It is

Sincerely,

Somatic effects andThese comments are made under three premises:

First,

difficult to separate the effects of the TMI accident itself from those of

the residual cleanup activities; this is particularly true in terms of the psychological effects.

H. Arnold Muller, M.D.

Second, We consider radiation doses comnuted and cited in thedraft document "as given" since this is

Attachment

professional expertise.

A.

not our-area of responsibility nor of

Third, only human exposure isconsidered.

Somatic Effects:
The NRC standard indicates that the cumulative whole body dose to any

individual offsite exposed to gaseous and liquid release from the cleanup operations-should not exceed 1.2 mrem.

POST OFFICE BOX 90.

HARRISBURG.

PA. 17120-

717-787-6536

A-325

The probability that this dose would cause a

-2-

-3-

cancer death over the lifetime of the individual who received the dose is about

to the biological

1.7 in 10 million.

recent report BEIR III from the National Academy of Science clearly reflects

This potential excess cancer death is too small for theavailable epidemiologic method to detect with any certainty.

The probability

this reality.

(health) effects of low levelionizing radiation.

The most

Although the maximum estimated total body radiation offsite

of genetic effects from that dose to offspring of the exposed individual isduring the 10-day period of the TMI accident is said to be no more than 100 mrem

about 3.1 in 10 million.

per person, combination of this dose with already existing (accumulated)

These risks are extremely small compared to the normal

incidence of hereditary disease in offspring in the U.S. at the rate of one intion in certain individuals from various other sources (e.g.,17.

tional,The maximum total body dose that is estimated to occur to an individual

medical,radia-

occupa-and industrial) could possibly subject these individuals to a differ-

ent risk category.

offsite during the cleanup operation is about 1 mrem, and the probability thatB.

this dose causes a cancer death over the lifetime of the individual receiving
the dose is about one in 10 million.

Psychological

Effects:

The NRC staff's conclusions regarding psychological effects are based

The 50-mile cummulative population(approximately 2 million people) dose that could be expected would be about

on several studies of.human behavior and psychological stress attributed to the

6 person-rem (6,000 person-mrem),

accident at TMI-2 and on the general literature concerned with response to

and the average dose received by an indivi-

dual in this population would be 2.7 x 10-3 mrem.

various disasters.

The background radiation in

Undoubtedly,

this area is reported (by NRC) to be about 116 mrem per year (including 36%

anxiety was high among some members of the local population

cosmic radiation, 39% terrestrial radiation; and 24% internal radiation-mostly

at the prospect of any emissions from the plant, especially of krypton gas

K-40 deposited in the body).

released to the atmosphere from the reactor building.

Comparison of this extremely small offsite doses

The NRC staff considers

releases of the gas should be

calculated here to those of natural background radiation suggests that thethat the stress on persons who feared accidental

somatic health effects are essentially non-existent.

relieved considerably after the purging has been essentially concluded.

This we agree without

Weagree with this view.

reservation.

On the other hand,-disposal of "accident water," even though it

Although we.do not anticipate any significant somatic effects of low

wouldlevel radiation within the TMI population, we do continue epidemiological sur-be essentially decontaminated of all radionuclides except tritium,

veillance as a matter of routine practice of the State Health Department.

concern of downstream communities who oppose its release to the Susquehanna River.

Suchremains asurveillance program includes cancer and congenital anomalies, as well as otherWe agree that this concern could result in stress for some individuals

radiation-related conditions.

because of their perception that drinking the water would be harmful.
to say,One important comment that deserves mention here is that there is stillthe "accident water" will continue to be a source of anxiety until its

proper disposal is accomplished.

disagreement among certain radiation biologists and epidemiologists with regard

A-326

Needless

-5-4importance.

diseases or conditions in the affected local population should be evaluated

The presence of damaged nuclear fuel on site will probably prolong theanxieties of some individuals in the local population.

in such context.

Also, transport ofradioactive wastes, as it occurs, will probably result in anxiety for a small

2.

number of people alongthe route.
The NRC staff's analyses of plausible accidents associated with the decon-isimportant that proper documentation of the impact, posistress isthe most important area of epidemiologicalHowever, it is understandable

indicated.

investigation is

Probablythat ofpregnancy outcome (immediate impact) and child growth and developmentthat any accidentthat occurs, however small, probably will increase anxiety and(long-term impact).

stress, as well as amplify public distrust of those who are responsible for the

A special Study of Pregnancy Outcome (prematurity,

immaturity, congenital

TMI-2 cleanup.

anomalies,

fetal and neonatal death,etc.)

within the 10-mile radius is currently underway and another special

The NRC staff concludes that "low levels of stress will continue during
the cleanup process and that releases to the environment,

Study of Child Growth and Development (physical growth such as height,

planned or unplanned,

will be perceived by some people as a threat, which will thereby increase stress.
For the great majority of people in the TMI community and downstream, no long-weight,head circumference, and intellectual-social-emotional

ment) isscheduled to conmence

develop-in January 1981 for a period of five

years.

Nevertheless, the long-term nature3.

of the cleanup process does present the potential for chronic psychologicalstress for some of the population.
Weittive or negative, of the psychological

tamination activities indicate that the.offsite doses for most of them would beterm psychological effects are anticipated.

In the absence of documented comparable experience prior to the TMI
accident,

small and would have negligible health effects.

Possible increase in the incidence of certain selected

are generally in agreement with this view.

However, some additional

Two recent studies of psycho-behavioral

impacts in the local populationsuggest that (a)the psychological effects are much longer than pre-viously assumed,(b)

the extent of stress and its manifest behavior

is a function of the distance from the damaged nuclear plant (beyondcomments are in order in this respect.

15 miles. the level of stress significantly decreases),

1. In considering possible health effects of decontamination and cleanupand (c)womenwith small children are most vulnerable in terms of anxiety and stressactivities of the TMI plant, such effects cannot, in reality, becaused by the nuclear accident.

separated from those of the initial unit 2 accident where releases of4.

larger radiation doses and greater psychological stress were monitored.

Two new studies are also scheduled to commence shortly within the

Furthermore, from an epidemiological standpoint, the combined orState Health Department;

cumiulative effects of these two phases over time would be of greaterand its potential

A-327

(a)

psychological stress due to TMI accident

impact on cardiac mortality; and (b)psychosocial

-6-

5.

-7-

impact of TMI accident upon family structure (particulaHy divorceof cancer (various forms) and thyroid diseases in the area at theand separation).

time of the accident.

The Pennsylvania Department of Health has established a TMI Popula-

9.

tion Registry based on the 1979 special census within the 5-mile radius.

same area.

way,

i.e.,

by the accident.

within the 5-mile radius and for all pregnant women (at the time of the
These individualized dose esti-mates are being derived from several well documented source materials
compiled by other agencies,

Federal and State,

and will be used for-various epidemiologic surveillance activities of the affected populatio6.

7.

The Pennsylvania Department of Health is also planning an automatedhealth-environmental monitoring system around all nuclear power plants
in the State in order to provide baseline epidemiologic data for
future studies.

8.

An in-depth analysis of the 1979 TMI census data now underway will provide valuable information relative to the incidence of spontaneousabortions following the nuclear accident,

no convincing evidence has been found that the

The incidence of congenital

hypothyroidism also

appears to be within the normal range of expectation.

another study currently under-

Individual Radiation Dose Assessment for those registeredaccident) within the 10-mile radius.

To date,infant mortality rate in the 10-mile radius of TMI has been affected

ity in and out of the 5-mile radius.

Related to the TMI Population Registry is

We are continuously monitor-

ity along with the incidence of congenital hypothyroidism in the

The same census has

also provided necessary basis for a special study of population mobil-

6.

infant mortality-

ing and evaluating the level and specific causes of infant mortal-

puter tape, will be followed for an indefinite period of years to study
possible health impact of the nuclear accident.

One of the most often used indicators of potential health effects of
the TMI accident isApproximately 36,000 individuals included in this cohort, now on com-

This will provide important baseline data.

as well as the prevalence,,-328

BILL GOODLING
19TH DISIHICT. PENNSYLVANIA

COMmIT'ION

MEUCATION
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TMI Program Office

I would like to take this opportunity to give myposition on the Draft Programmatic Environmental Impact
Statement.
I think it is of the utmost importance to hold public
hearings which should be very well publicized in the Three
There hasMile Island area on the environmental impact.
of public servants as well as ofbeen a growing distrust
the operators of the nuclear power plant, mainly because of
In order topoor and inadequate channels of communication.
restore confidence in the people, it is imperative to havetheir input on any decisions which may be made in regard totheir health and safety.
Ino.0rOO

October 3, 1980

United States
Nuclear Regulatory Commission
20555
Washington, D. C.
Director,

appreciate your consideration of my comments.
Sincerely,

BILL GOODLING
Member of Congress
BG:re/rpMarylandIA •B
Ila NonII H
1701M
C.I,..o. PDOTr.vI

Watbingter, I.C. 20515

AFFAIRSI~m"•

1980, Meeting-with Maryland Citizens

17B3

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R-~ Mxxr

AFFArRSE
ON

Attn:

Comments Received at November 17,

S-Im

Baltimore,j)ouge of Atpre•entatibeiFOG-r0-•)

NO
11F_

I7NIS

The
BRUCE GILMORE (Tr 37): I am a Special Assistant to Senator Sarbanes.
Senator had a previous engagement in Southern Maryland tonight and he asked
of
part
as
submittedbealso
requestshewhich
me to read this statement
I appreciate the opportunity to submit this statement at thisthe record.
public meeting on the draft environmental impact statement concerning the
Earlierpost-incident clean-up of the Three Mile Island nuclear reactor.
this fall I wrote to the Chairman of the Nuclear Regulatory Commission
underscoring the importance of public comment on this issue and urging that
It is important that this meeting provide
this public meeting be held.
Maryland citizens with a further opportunity for a public hearing of theThis hearing is, of course,
critical issues raised by the TMI clean-up.
part of the public comment process associated with the draft EIS, a public
It is my undercomment period which was extended to November 20th, 1980.
Whilestanding that the NRC plans to complete the final EIS by early 1981.
the public comment period on the draft EIS will end shortly, it is mystrong view that the NRC should actively continue to seek public participaThe serious nature of thetion in the clean-up decision-making process.
TMI accident and of the consequences of any clean-up activity will require
the opportunity for further public comment before a final decision is madeMaryland citizens, given
on any of the various proposed clean-up options.
their proximity to TMI and the possible consequences for our environment,
Turning to the draft EIS itself, I remain conare entitled to no less.
cerned about the adequacy of the environmental assessment of the various
Releasedisposal options for the contaminated water now being held at TMI.
of this water into the Susquehanna River and thus into the Chesapeake
Bay is clearly an alternative fraught with serious negative environmental
Chesapeake Bay is one of our nation's preeminent estuaries
consequences.
The Susquehanna
upon which Marylanders depend in a number of important ways.
River provides the greatest amount of fresh water for this huge estuary systems as well as drinking water for a substantial number of Marylanders.
Under no circumstances can the integrity of the river as a source of drinkConsequently,
ing water or the bay and its seafood products be compromised.
I take strong issue with the draft EIS statement at pages 10-23 downplaying
Ongoing
the effect of the release of the processed water on the bay.
research on the Chesapeake Bay's ecosystem has revealed that both fin fishand shell fish and even aquatic grasses are under a great deal of stress.
Populations of many species have decreased and evidence is accumulating
Under thesethat adverse changes in water quality may be responsible.
circumstances increased levels of radiation, even small, may have a severe
Furthermore, I believe the views set out in the impact statement
impact.
that the marketability of the fisheries products will not be adversely affected if, and I underscore if, the effects are properly understood byconsumers amounts to a tacit admission that such adverse effects will infact occur. The NRC must undertake a more complete analysis of the otheroptions for dealing with the contaminated water, including more detailed
The purpose of theinformation on each option and the full cost thereof.

-3

-2-

-

EPA funded Independent Scientific Research Team, something that EPA has
just put together that we are looking forward to working with, and also, thatyou complete the revised environmental impact statement quickly.
I. know
you have indicated to me that you thing we are trying to slow the process down.
That is not true now.
It was at the beginning.
It was like trying to catcha speeding bullet, this clean-up, going somewhere.
We wanted to catch it
before it got away.
Now I thing we have caught and we want to see where itgoes.
We want to change its direction. That is what we are trying to do.
We are not trying to slow things down.
What we would like would be full
public hearings on the revised draft. We would like the revised draft not-to be a best case/worst case analysis as the present environmental impact
statement.is,'.bu't. instead to be a blueprint, as we suggested on March 2Oth,a blueprint to follow that would suggest compatible processes that would work
together to ensure a safe cleanup.
We feel that the credibility of the Nuclear
Regulatory Commission is shot with the public anyway, with the people ofMaryland, and that you can't put it back together without us,.without working
with us.
The accident focused a powerful spotlight on the clean-up arena,
My quesa beam of light on the arena.
We can now see what needs to be done.
tion to you is, will you do it? Will you write a revised EIS as quickly as
possible and have public hearings, cost estimates, adequate considerationof waste disposal methods, develop alternatives to dumping In the SusquehannaRiver, an option that is clearly not acceptable to the people here, to thepeople in Harve De Grace and to the people of Maryland, to Senator Sarbanes.
It is not acceptable to anyone, to the Maryland Waterman's Association, theChesapeake Bay Foundation, and the list-goes-on and on.and on, as.you know.
Will you write a new environmental impact statement?

environmental impact statement process is to set out the details of therange of choices available.
The draft EIS will not achieve that purpose
unless all the options listed are subject to greater analysis.
Detailedcomments on the draft EIS have been made by many citizens in groups aswell as public officials and representatives from Maryland agencies withresponsibility in the environmental area.
The expertise and criticalanalysis offered by these Commentators were critical to the decisions to
be made about the clean-up action.
In his respect, given the unprecedented
and highly complex nature of the clean-up, it is imperative for the Nuclear
Regulatory Commission-to continue to consult with the public concerning
the clean-up.
I again urge the Commission to assure Maryland -citizens andpublic officials that they will be consulted prior to and be given a chance
to comment upon any action the Commission proposes to authorize during
the lengthy clean-up process.
JOHN CABLER (Tr 43): As you know from former testimony in Annapolis andHarve De Grace, the Ad Hoc Committee and the Clean Water Action Project
believe that basic flaws in the document invalidate the document completely.
We would therefore urge you to put together a revised environmental impact
statement that will correct the flaws by including cost estimates, because,
as you know, there are no cost estimates in the programmatic environmental
impact statement which makes it impossible for citizens to perform a costbenefit analysis to find out if maybe you are doing maybe the cheapest andnot the safest clean-up.
Also, we are worried that there are no assurancesthat the high-level waste on the island will bedisposed of or any of- thewaste on the island;
Governor Hughes agrees with me.
This is a letter from
Governor Hughes to President.
"The draft environmental impact statement
reveals that federal agencies are following a course of action that will
make Three Mile Island a long-term storage dump for radioactive waste.
Nothing could be more dangerous to Chesapeake Bay and the people ofMaryland.
No responsible agency would locate a dump for radioactive waste
on an island in a flood plane above the water supply of a major metropolitan
area poised at the head of the Chesapeake Bay.
Yet,. because of refusal toconsider any other realistic alternative that will be the result of actions
described in the draft environmental impact statement."
I agree with
Governor Hughes that that is not the right answer.
Also, as faras thestatement in the draft about the marketability of the seafood, it seems
from what your fisheries expert said there will be an effect on themarketability of the seafood if a release occurs.
Our feeling is that if
you are consider releasing water into the Susquehanna River and expect thatstatement-to fly that it won't affect.the marketability of the seafood,
you will at least have to do a market research analysis independently, hire
an independent team that can do those surveys and come up with a morecredible answer.
We would also hope that you would respond to the new

BILL HOLSTON (Tr 50): I am an engineer in the Nuclear Engineering Section
at Baltimore Gas and Electric working on the Calvert Cliffs Nuclear Power
Plant.
I would like to. point out at this point my viewd do not necessarily
represent those of Baltimore Gas and Electric's.
I am here as a citizen.
I would like to read a statement I have read in the Nucleonics Week, andthen ask a question from that. Metropolitan Edison, the Nuclear Regulatory
Commission and the Department of Energy are acutely-aware of the political
relations ramifications of dealing with TMI waste and therefore are hesitant
to strike a clear waste management plan even though the waste that must be
handled is no greater, and I repeat no greater in radioactivity or volume
than that generated by some government and commercial nuclear operations avariety of sources say. Most of the waste in question at TMI consists ofcesium and strontium isotopes and is divided into two categories, low-levelmaterial consisting of resins from the Epicore 2 systems, treated water
which spilled into the TMI auxiliary building~and high-level material in
the water resting in the containment sump.
Speaking of low-level waste, a
DOE source said ordinary low-level waste can be disposed of by shallow
burial.
This, however, has been deemed not ordinary. The comment was areference to NRC's order. that low-level waste as TMI be solidified.
I
realize that you said that cost is not a question, but I question thefact that why.are. taxpayers' and ratepayers' valuable resources being.wasted on spending on systems that really aren't needed? Why. is a concrete solidification system needed at TMI when this waste is no different
than at other plants and it is not done there?

A-33 0

-5-4KAREN GUSTIN (Tr 63): We have a few friends here that would like to
They would likesay something to you from the Union of Concerned Crabs.
Our friends, crabs, rock fish, sea nettles, clams,
to tell you something.
oysters, turtles and others have asked us to come here to tell you we
don't want radioactive water dumped in our hope, the Cheapeake Bay. We
We have for a very long time
live there, we eat there and we sleep there.
It is the human beings' responsibility to
and we hope for a long future.
protect the planet and the creatures dependent upon it who have no voice
We ask you
in your conference rooms and no stock in your corporations.
the representatives of the Nuclear Regulatory Commission to take our message
Don't dump the water.
to-your leaders in Bethesda.

LEWIS FOSTER (Tr 54): For five years up until last November I worked asa nuclear environmental research technician for a nuclear environmental
contractor.
In April 1979 I was transferred to the Three Mile Island plant
to work on a unit team doing studies on the environmental air and water
quality.
We were doing monitoring.
In my previous statement at the Harve
De Grace meeting on. October 29th I mentioned the tendency of the nuclear
industry to emphasize data which fits the needs of the industry and to overlook relevant information which is less than desirable to the industry. We
believe that several aspects of the biological and psychological impact of
the TMI situation have been overlooked in the present PEIS draft. The
current position of the industry and the NRC is based on conclus~ions arrived
at after considering what they believe to be meaningful and accurate data.
All too often it was my experience that similar conclusions are based ondata that is frequently in a scientific sense erroneous and irrelevant as
far as the human and biological aspects are concerned.
One such situation
was the improper use of air monitoring equipment in auxiliary buildingof the damaged reactor at Three Mile Island.
Radioactive iodine was themost prevalent contaminant in the air of the auxiliary building after theaccident.
The company that I work for designed and marketed the charcoal
cartridges used to determine the iodine levels at Three Mile Island.
Ipersonally did the quality analysis testing in the lab myself almost a year
before the accident occurred.
Known quantities of air would be pumped
through the charcoal cartridge at a constant flow rate. The cartridges
would then be measured by equipment sensitive to radioiodine and to determine
the amount and particular type of the isotopes.
Samples were taken from fivedifferent installations by health physics personnel on a daily basis from early
April until June 22nd and every three days thereafter.
These samples wereanalyzed in my lab as well as by the NRC and were used to determine thelevels of air-borne radiolodine in the Unit 2 auxiliary and fuel handlingbuildings. The results were subsequently posted at the health physics
control point and were used to determine the necessity of breathing apparatus
by the Three Mile Island personnel.
My research program necessitated frequent entry into the restricted areas of Unit 2.
During my activities in
the auxiliary building and the fuel handling building I would frequently, findcigarette buts that hadn't been there on the previous visit. Presumably
the workers involved in the clean-up would assume that the levels of iodine
were safe and would remove their respirators to have a smoke.
Also, when thelevels of iodine were low enough workers would be issued respirators which
would not filter iodine but only particulate material. .1 am simply sayingthat my request to the NRC is that they seriously consider the possibilityof another draft statement.
I think it is very important that we look into
these matters.
Some of the biological factors haven't been completely
addressed.
Several of the factors that my colleague John Cable mentioned
have not been correctly addressed.

TANYA PALMITY (Tr 64): I have a rather simple question.
ing what the activity was in the low-level tanks?

I was just wonder-

BONNIE FRADKEN (Tr 66): I work with the -Communist Workers Party. I am not
I aman expert, but I know when the wool is being pulled over my eyes.
getting really tired of hearing about how the NRC is really concerned
about the public health and well-being, and. I think a lot of people in here have
Cleaning up the Three Milebeen thinking this, and I am going to say it.
Island Nuclear plant doesn't mean they are cleaning it up for the interest
It means cleaning it up to start it up. That is what it is allof us.
about and I think a lot of people here know that. Also, the NRC isn't a
I am
neutral body concerned about the interests of the American people.
just saying that I am tired of having this run down on me every time you
I think all of us know that Three Mile Island showed where you stand.
speak.
The NRC is just covering for the fact, you know, that the monopoly corporations that are profiting from the nuclear industry are going to be allowed to
The questions that people have asked haven't been ancontinue to profit.
Notswered sufficiently because you don't intend to answer those questions.
only do the monopoly corporations want the profit, but the government is
For World War III you need a large nuclear
preparing for World War III.
stockpile. The Communist Workers Party under the leadership of Jerry Tongue
There are going tosays that in the 1980's we can be certain of two things.
be two things that could happen. One is world war, and that means World War
I believe that theIII, or the other solution is socialist revolution.
American .people are not going to profit by world war any more than they aregoing to profit by the nuclear industry and the system that backs it up to
the hilt. When workers control this country they are going to be putting an
That is what we are fighting for and thatend to this nuclear nightmare.
is why I am taking a stand against the nuclear disasters that are being
All of these nuclear accidents, the burdens areforced down our backs.
put on the working people in this country while the monopolies who arebehind them and the government who is behind them are profiting at ourI am really tired of it and I am really tired of you guys, soexpense.
called experts, being paid with our tax money to try to pull the wool over
our eyes.

A-33_

7

-6going to, no matter how slowly we would let the stuff go at Three Mile
Island, build up the material on the Susquehanna flats, which of courseis the upper bay breeding ground.
This is where the rock fish spawn.
This is where the young fry survive the dangers of the larger fish eatingthem or something because it is very shallow and there is grassland there
If we dump radioactive material in an
and they are protected from this.
area where the first cells of the first eggs are hatching is this not athreat to us? Are we in turn dumping most of the radiation in the wombof the Chesapeake Bay?
The water that is there at low tide many times,
it will expose the shoreland. Twenty-five thousand acres is covered by,this area in the upper bay.
It is very shallow.
You can be miles andmiles from shore and be standing in ankle-deep water.
It is a very
special area, one that is very rare as far as a giant estuary like this.
I know of no other shallow lands other than some perhaps marshlands overon the Eastern Shore that would be similar to this.

PAUL YOUNG(Tr 69): I have here a synopsis of the NRC report we are
discussing here this evening.
One item in the report has not received
any discussion during the course of these hearings.
I will read thisparagraph to you because my questions will be on this material.
Thissummary was written by Lee Tory for a British publication called "NewScientist" and appears on page 766 of the September llth, 1980, issue.
"Removal of the sump water, expected to be the most difficult task of theclean-up operation, must be accomplished before full-scale decontaminationand defueling of the reactor can begin.
According to the NRC report,
leakage from the reactor's primary cooling system adds 550 liters per day
to this spill, that is in the sump, and the continuing rising water level
now poses a hazard.
Some instruments and electric cables have alreadybeen shorted out by the water.
Late last month the water level was amere 2.5 centimeters below electric motors on two valves that must remain
in operation in order to maintain the safe Cooling of the reactor.
Unless the water leakage is ended or it is transferred to a different location, warns the NRC impact statement, the present safe status of the plant
may deteriorate." What is the current volume in the sump right now?
Are there any present contingency plans for an emergency should this water
have to be discharged?

STEWARD STAYMEN (Tr 80): I am trying to get a perspective of the dose rates
from a potential release of the water from theplant into the river.
I wasvery glad to see one of your charts contained a table showing comparing the
EPA drinking water standards to the levels of contamination from TMI.
I
would suggest that you include that in the final EIS.
I would also suggestthat you include a comparison of what the potential controlled release ofwater from the clean-up to the river compared to what the release from TMI,
if it was operating normally, what the license from the NRC permitted.
Ithink that that would help give readers some of the perspective that you
have been trying to provide tonight.
I would also like to make two othercomments.
I would suggest that further down the road when you are getting
to removal of the high level radioactive material, if we still do not haveat that time civilian high-level waste storage facilities that because of
the special circumstances of TMI that you not wait until some ar foundbut that you use military facilities. Thirdly, a very minor point, I
just have a question, in the trucking of the low-level wastes out toWashington State, will that be done by commercial private contractors or
will that be done by the government?

THOMAS GLOSS (Tr 73): I use the bay a lot, the upper bay.
I fish theupper bay almost exclusively. The bay is hanging on by threads now, especially the rock fish industry which benefits everybody up and down the
East Coast.
The grass beds, the small microscopic life that the fry
feed upon have enough problems with pollutants in the upper bay, letalone dumping this from up in the Susquehanna River up in Pennsylvania
and bringing it down here. We have had enough problems with not getting
an adequate flow coming over the Susquehanna Dam in previous years.
There have been thousands of fish killed and yet you want to dump waterlike that in there.
I find it unbelievable.
GREG DUNN(Tr 73): Early on in you presentation this evening you mentioned several times that youhave not as yet specifically recommended
releasing the water into the river.
You also, in that presentation mentioned that the tritium ladened water that you are planning to recycle it
and use it in part of the scrubbing process within the plant itself. What
I am asking is if you choose not to release the water what other specificrecommendations are you considering at this point and will that recycling
pocess impact on those decisions and, if so, how?

JOE CLYDE (Tr 82): I am very inspired by the amount of technicalresearch that people have put into this question.
I mean I see a lotof people using their hard earned years of training for what I hope we
However, I take exception
all here tonight regard as social purposes.
with the conclusions and the role that the Nuclear Regulatory Commissionis playing here.
I think it is essentially a cover-up of a massive
catastrophe in terms of the way our technology is being misued.
Interms of public comment and public input I think there are basically millions
of people who should be here tonight or somehow involved in direct input into
this.
Now, we all know that when we tried to call people to get them to comeout we are dealing with the weather, we are dealing with the short noticethat John Cabler talked about and we are dealing with people's so-called
apathy which I don't think is apathy.
People no more feel apathetic about
who runs this country than they did about what happens with nuclear power,
I think it is a question of getting information and it is a question of feelr
ing that you can actually do something about it.
So I would like to encourage

BILL MALLISH (Tr 77): I am still a little
concerned that we haven't
addressed one issue in the dumping as much as I would like even though
the biologist has talked to us about this.
The Susquehanna flats itself
where the river literally'ends or becomes part of the Chesapeake Bay,
we seem to have a flow rate problem here.
I guess that is why we formed.
a giant delta there.
We have hundreds of acres of very, very shallow
water which means to me that the river is dumping the sediments that it
carries right there and has been doing it for hundreds of years. Are we

A-332

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M__

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ýý

301

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-Bam commenting on pages 30 and 31 , I am not reassured by the fact that
there will be only 3 to 10 cancers in workers from this clean-up process
and between 7 and 20 genetic defects in children of the clean-up workers
which are the estimates that you make.
And I am certainly not reassured
by your putting this in the context of one in five Americans getting
cancer and one in seventeen people in the country passing on a genetic
defect.
To me that is the height of cynicism, particularly when it Is
largely recognized that the majority of those cancers are caused by industrial factors.
I would like to make one last comment.
Again, I would
agree with everyone who said that there should be public hearings on thisclean-up process every step of the way. And in the future 12 days, which
was the notice given for this hearing and the one in Harve De Grace Is
just not adequate.

people here tonight, anyone who belongs to a trade union, to be sure andgo back to your unions and try to get them very much much involved inthis struggle and all of my brothers and sisters in the environmental
movement.
Please realize there is a powerful movement of over 20 million
people just on the brink of becoming anti-nuclear en masse and we can't
lose a minute in getting the resources of the labor movement.
So let's
pull together as fast as we can because we don't have a day to waste.
We
don't know when the next catastrope will be the last one.
CAYLE SCHNEIDER (Tr 84): The one question I would like to direct to youis that the Susquehanna River supplies domestic water to Columbia Borough,the City of Lancaster, Safe Harbor Village, Holtwood Village, City of
Chester, City of Baltimore, Conowingo Village, Brainbridge Naval Training
Station, include Port Deposit, Perry Point Veterans Hospital and Harve De
Grace.
Section 3.19 of Draft PEIS states that the Susquehann's use as acommunity water supply is very limited.
Please explain.

MORTON REFF (Tr 91):
I have two areas of concern and two basic questions.
No. I, I was impressed with the data, the statistical data on the effectof a processed discharge, discharge of processed water in the Chesapeake.
I was really very impressed with all of the specific effects on thevarious fish, the various chemicals.
I didn't hear at all any doubt on
the part of the speaker in terms of question, is there that much surety
that a fish, any fish in the Chesapeake, doesn't act as a filter and won't
maintain various levels of any of the chemicals that you have described?
Is there any doubt at all is my question.
Do you have any data on residual
effects of the chemicals; in other words, long-term effects of the chemicals
on the fish? Why can't you combine a couple of alternatives.
I noticedthat in computing the&s-lidification alternative you indicated that it would
end up as 10,000 cubic yards.
If you evaporate it first you would reduce
your volume by 1/30th, according to your own figures.
That would end up
with less than 400 yards, 400 cubic yards and then solidify it and thendump it in the middle of the ocean.
I don't see why you are hung up only
on one alternative.
It is either discharged process, vapor, forced injection or holding it at TMI.
And holding it at TMI for 60 years Is
ridiculous.
In other words, why can't you combine the alternatives? Why
are you hung up on only one?

BRUCE PRIOR (Tr 85): I was just curious if this is only one out of several
alternatives and if you were holding similar meetings in other parts ofthe country where they where considering dumping this material? Well, I submit that you should be having similar meetings in other areas where you
would be considering dumping.
ROBERT JACOBSON (Tr 88): I just want to make two comments on points madein the blue covered booklet, Answers to Frequently Asked Questions About
Clean-Up Activities and so forth.
On page 25 of the booklet you discusstransport by truck of the nuclear wastes from Three Mile Island andyou state that all the states along the way from Pennsylvania to Washington
are notified prior to these shipments and that some states provide police
escorts.
Since this was published in September you neglected to mention thatlast spring the Federal Department of Transportation came out with proposed
regulations that would change all of that. Basically it would deregulate
truck transportation of any radioactive materials so that they could virtually go over any highway, any toll facility and through any state without
notifying any emergency response agencies and go through any locality at
any time of day.
I see this as nothing but dishonest that this wasn't included.
While taken at face value what you stated here is true now, but I
believe this month the Deparment of Transportation is going to decide on
those changes.
They were proposed last spring and they were published in
the spring.
Final comments were in by June 30th and they are to be decided
on this month.
If these regulations are changed then obviously you have tosignificantly change your predictions on the number of accidents which you
assume would be between two and seven accidents which is significant
enough.
I am certain that with those restrictions being lifted they will
be significantly higher. My second comment.
It seems to me that. the blue
booklet has two purposes.
One is to inform the public on what the various
options are. The second is to reassure the public. Personally, and I

MICHAEL TAYLOR (Tr 94): My comment tonight is I believe it is time for thepeople of Maryland to take a stand on the issue of nuclear waste.
How you
can say that dumping of nuclear wastes into the Susquehanna River causes
no threat to the people of Maryland is beyond me.
I do not want my family
and children to die or to become ill from the NRC's incompetence* The river
feeds into the bay.
If it is so unsafe why not leave it at Three Mile
Island, or better yet shut down the reactor permanently.
I would rather
move from the state than witness the results of the stupid actions the
NRC is considering.
I thank you men for letting me speak tonight, andyou have got to find another way to get rid of this stuff.
Don't put it
in Maryland.

A-333

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11 -

10 of that.
There are other things to consider like the dose, which is a
Like the tritium, it gets incorporated
concentration at a distance.
into your DNA. So you can have a very small amount of tritium and It
In fact, many scientists believe that tritium
can cause great damage.
Also, there is a great controvery
is the most dangerous isotope there is.
In the National
among scientists over the safe level of radioactivity.
there is a wide range ofradiation
Academy of Science report on low-level
what they consider to be safe doses. -As far as cancer is concerned, it
just takes one single vent for one alteration for cancer to occur. So
But, as I said,
there is really no safe level of radiation for anyone.
there is a great controversy among scientists over what a safe level is,I haven't read the whole report
and this is not presented in the report.
so I don't know if it is or it isn't. But there is this big controversy
and it should be pointed out in the report that no all scientists feelthat there is one safe level of radiation.

VIRGINIA COBLER (Tr 95): I would like to know why does Metropolitan
Edison continue to spend significant amounts of money and time in constructing a submerged demineralizer system when the EIS is still indraft
form? There is no reassurance that this system will be approved as best
to protect the environment and health and safety of the public. Will
this expenditure prejudice the NRC's decision as to which alternative forclean-up of the highly radioactive water will be best?
TONY WALLACE (Tr 97): Given that tritium' cannot be removed by any
feasible methods, and given that the radiological effluent released by
the TMI site will have an insigificant, even undetectable effect on theenvironment, therefore in order to minimize the clear and present dangerof psychological stress to the general population, I propose that acontrol group of fewer than 15,000 nuclear power advocates can serveas the environmental processors.
These would be strictly volunteers.
They could divide the 750,000 gallons of contaminated water into an
equal share of, say, 55 gallon drums.
Surely you could find 15,000
dedicated advocates of nuclear energy, maybe the shareholds, who would
drink this. My question is if the water is going to be safe, if
the effluents Are suppdsed to be minuscule, why don't people simply takegallon jugs home? Why are we worried about trucks breaking down on the
highway? That would just spill off the highway into the ecosystem justlike dumping it into the river. You would think the trucks could be
open-bodied pick-ups driving along and spill it out.
They could-drivein all directions.
They could rive to New York City, California, they could
just spill the water out over 3,000 miles in any direction.
The fact thatthe water is just going to be processed and received directly into theriver suggests to me that it is the cheapest way. And when you say
feasible, removing tritium, is that economic or is that an engineeringtask?

MICHAEL BRYAN (Tr 105): I am a resident of California and I would like toaddress one point that Mr. Snyder made before about a forced evaporation
not being very relative to the people in this area or not being of concern
to the people in this area but just to the people in the immediate area of
It is a concern of mine and I think any decision thatThree Mile Island
you make is a concern of every person in this country that cares about
this environment and about themselves and about future generations.
I
want to make that clear.
STAN CHARODS (Tr 105): I wasn't satisfied with your answer to the question
That is a problem because
raised earlier about radiation into the flats.
of the spawning grounds,and if that is a problem isn't that significant
enough not to consider that as an alternative?
(Tr 107): Now, after listening for two or three hours of
JOHN MONAHAN
statistics from the NRC and after having listened to them at other meetings,
I am left with the fact that as many statistics as you give us, we have to
We have to trust you. My question is, why should wetake you at your word.
trust you? Why should we trust the clean-up of Three Mile Island? You are
In a
the same people that licensed Three Mile Island in the first place.
clean-up that will take five to eight years, how can we trust people that
only give the public 90 days to comment and who ultimately have the ability
to accept or dismiss these comments arbitrarily?

DIANE POLINSKY (Tr 99): I want to know on a ratio how many comments haveyou gotten in support of dumping the tritium water? One final comment.
I have never heard of anybody at any of these meetings, and I have been
coming for over a year, stand up and say that they thing that the tritium
water belongs 'in the Susquehanna.
So if you care about the democratic
process at all, we shouldn't even be here still talking about this because it should be settled.
BOB ADAMS (Tr 101): Basically my comments have to do with the nature ofradioactivity. The way that the radioactivity has been presented it has
been in terms of concentrations and that is really misleading to thepeople of the nature of radioactivity.
It is not so much the concentrations of the radioisotopes, there are many other considerations, suchas the half life which I don't know if everybody knows.
What a halflife is, but it is considered to be a time for half the amount of the substance to no longer be there which we call decay. So if like you havea hundred atoms of a substance, the half life is when you have 50 atoms

I would like to suggest that instead of dumping
PETE SPASKEY (Tr 110):in the Susquehanna which is sort of like sweeping it under the rug or it
has the connotation of, you know, getting rid of it and hiding it, thatmaybe the water should be left in the containment building as a monument
to a nuclear disaster, the same way that after World War II there was a
The secondbuilding in Berlin that was left as a monument to World War II.

A-334

Pennsylvania
State
Clearinghouse- 12 -

proposal .would be that if the water couldn't be kept at Three Mile Island
for some reason because they might have some reason they don't want it
there, there is a body of water in Washington, D.C., there is a Reflecting
Pool where there are no fish, no life in it, and I would imagine it could
monument.
Ithold a hundred thousand gallons, and then put up a little
would probably be safe to all kinds of life except certain political kinds
life.
politicalof
VOICE (Tr 112): One way, it seems to me, to put things in proper perspective in Maryland would be to have a referendum vote on this question of dumping
the water in the Susquehanna.
MS MATTHEWS (Tr 113): I am concerned about the difference between exposure
to radiation and the exposure one's tissues have to something that is taken
I would like to know what you know about the effect of tritium
into the body.
on tissues, when it is taken into the tissues and becomes part of the body.

P.O. BOX 1323 - HARRISBURG, PA. 17120 -(717) 787-8046

783-3133

CommonweilthafPennsylvan ia

GOVERNOR'S OFFICE
OFFICE OF THE BUDGET

December 2,

JIM TITEN (Tr 116): It says here on page S-7 for local release to the riverthat the water would satisfy the EPA's internal drinking water standards at
I would like to know how far away is
the nearest potable water supply.
that from the water supply, from the source, and what would be the amountof curies per cc in the water released at the source? Do you have any numbers for the EPA internal standards for the potable water supply as comparedto the values at the discharge point?

1980

Dr. Bernard J. Snyder
Program Director
Three Mile Island Program Office
U.S. Nuclear Regulatory Conmission
Washington, DC 20555
Dear Dr.

BRENT VANZUST (Tr 118): You talked about a person standing three feet awayfrom the truck for three minutes gathering about three millirems, and I
was just curious about this poor sucker that is driving the truck for eight
hours that is three feet away.

Snyder:Enclosed are comments on NUREG 0683,"Draft Programmatic

Environmeatal Impact Statement relating to decontamination anddisposal of radioactive wastes resulting from the March 28, 1979
fromaccident at Three Mile Island Nuclear Station Unit !I",
Dr. Walter Plosila, Director of the Governor's office of Policy

andPlanning.

Please incorporate these comments in the final

PEIS to be issued in

March 1981.
Sincerely,

Anne Ketchum
Supervisor

F

-7

L

I

A-75

OA-S01

1"•47

COMMON•WLAJLTH OF PENNSVLVANIA

November 19,

SUBACT,

Environmental Impact Statement
Three Mile Island Nuclear Station,
PSC 58008024

1980

Unit 2TO:

Pennsylvania State Clearinghouse

FROMS

Walter Plosila, Director
Governor's Office of Policy and Planning

In Section 10.6.1.1. of the above referenced document
under the section entitled Housing, reference is made to a
decline in the number of homes sold and new construction
starts,and decreased property values within five miles of
the Three Mile Island station in the time frame which
followed the TMI emergency period.
A report issued by
thisoffice is footnoted as the source for the finding.
This finding was based on preliminary data which wasavailable at the time the report was issued.
Subsequent
analysis of more current data indicates over the longer
term, through March, 1980, that the TMI-2 accident had no
significant impact on property values, new construction
startsand number of homes sold.
this

The final
environmental
more current'finding.

impact statement should incorporate

A-336

APPENDIX B. COMMISSION'S STATEMENT OF POLICY AND NOTICE OF INTENTTO PREPARE A PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT

Federal Register / Vol. 44, No. 229 / Tuesday, November 27, 1979 / Notices

The development of a programmatic
impact statement will not preclude
prompt Commission action when.
needed. The Commission does
recognize, however, that as with its
Epicor-LI approval action, any action
taken in the absence of an overall
impact statement will lead to argumentsthat there has been an inadequate
environmental analysis, even where theCommission's action itself is supported
by an environmental assessment. As in
settling upon the scope of the
programmatic impact statement, CEQ
can lend assistance here. For example
should the Commission before
completing its programmatic statement
decide that it is in the best interest of
the public health and safety to
decontaminate the high level waste
water now in the containment building.
or to purge that building of its
radioactive gases, the Commission willconsider CEQ's advice as to theCommission's NEPA responsibilities.
Moreover, as stated in the Commission's
May 25 statement, any action of thiskind will not be taken until.it has
undergone an environmental review,and furthermore with opportunity for
public comment provided.
However, consistent with our May 25
Statement, we recognize that there may
be emergency situations, not now
foreseen, which should they occur
would require rapid action. To theextent practicable the Commission willconsult with CEQ in these situations as
well.
With the help of the public's
comments on our proposals we intend toassure, pursuant to NEPA and theAtomic Energy Act, that the clean-up of
TMI-2 is done consistently with the
public health and safety, and withawareness of the choices ahead. We are
directing our staff to include in the
programmatic environmental impact
statement on the decontamination anddisposal of TMI-2 wastes an overall
description of the planned activities anda schedule for their completion alongwith a discussion of alternatives
considered and the rationale for choices
made. We are also directing our staff tokeep us advised of their progress inthese matters.
Dated at Washington, D.C. this 21st day of
November 1979.

Statement of Policy and Notice ofIntent To Prepare a Programmatic
Environmental Impact Statement
AGENCY: U.S. Nuclear Regulatory

Commission.
ACTION: Statement of Policy.
SUMMARY: The Nuclear Regulatory
Commission has decided to prepare aprogrammatic environmental impact
statement on the decontamination anddisposal of radioactive wastes resulting
from the March 28, 1979 accident atThree Mile Island Unit 2. For some time
the Commission's staff has been moving
in this direction. In the Commission's
judgment an overall study of thedecontamination and disposal process
will assist the Commission in carryingout its regulatory responsibilities underthe Atomic Energy Act to protect the
public health and safety as
decontamination progresses. It will also
be in keeping with the purposes of the
National Environmental Policy Act toengage the public in the Commission's
decision-making process, and to focus
on environmental issues andalternatives before commitments tospecific clean-up choices are made.
Additionally, in light of theextraordinary nature of this action andthe expressed interest of the President's
Council on Environmental Quality in the
TMI-2 clean-up, the Commission intends
to co-ordinate its action with CEQ. In
particular, before determining the scopeof the programmatic environmental
impact statement the Commission willconsult with CEQ.
The Commission recognizes that there
are still areas of uncertainty regarding
the clean-up operation. For example, theprecise condition of the reactor core is
not known at this time and cannot beknown until the containment has beenentered and the reactor vessel has been
opened. For this reason, it is unrealistic
to expect that the programmatic impact
statement will serve as a blueprint,
detailing each and every step to betaken over the coming months and years
with their likely impacts. That theplanned programmatic statement
inevitably will have gaps and will not be
a complete guide for all future actions
does not invalidate its usefulness as aplanning tool. As more information
becomes available it will beincorporated into the decision-making
process, and where appropriate
supplements to the programmatic
environmental impact statement will be
issued. As the decontamination of TMI2 progresses the Commission will makeany new information available to the
public and to the extentnecessary will
also prepare separate environmental
statements or assessments for individual
portions of the overall r!ean-up effort.

For the Commission.
Samuel 1. Chilk.
Secretary o fhe Commission.

IFRDoc. 79-36476 File 11-254- 0:45 aol
BILLING COOE 7590-04-)

B-1

APPENDIX C. "FINAL ENVIRONMENTAL ASSESSMENT FOR DECONTAMINATION OF THE
THREE MILE ISLAND UNIT 2 REACTOR BUILDING ATMOSPHERE,
FINAL NRC STAFF REPORT," VOLUME 1, U.S. NUCLEARREGULATORY COMMISSION, NUREG-0662, MAY 1980

C-I

NUREG-0662
Vol. I

Final Environmental Assessment for
Decontamination of theThree Mile Island Unit 2
Reactor Building Atmosphere
Available from

Final NRC Staff Report

GPO Sales Program
Division of Technical Information and Document Control
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
andNational Technical Information Service
Springfield, Virginia 22161
TMI Support Staff
Office of Nuclear Reactor Regulation
Prepared for
U.S. Nuclear Regulatory
Commission

C-2

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End--

NUREG-0662
Vol. ITABLEOF CONTENTS

Final Environmental Assessment for
Decontamination of theThree Mile Island Unit 2
Reactor Building Atmosphere

Pace
Preface ......

...................

1.

Sutmeary and Recommendation .........

2.

Proposed Action . . . . ...

. . .

S . . . . . . . .

2-1

3.

Introduction . . . . . . . . . . . . . .

. . . . . . . . .

3-1

4.

Reactor Building and Airborne Activity.

. . . . . . . . .

4-1

4.1
4.2

Final NRC Staff Report
5.
6.

Manuscript Completed: May 1980
Date Published: May 1980

..

4-1

Gas Sampling and Analysis .....
Source Term Derivation .....

Need for Decontamination ...........

. . . . . . . . .

5-1

Decontamination Alternatives ......

. . . . . . . . .

6-1

6.1
6.2

No Action .................
Reactor Building Purge System.
6.2.2
6.2.3
6.2.4

TMI Support Staff
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20666.

. .

Slow Purge..........
Fast Purge..........
Elevated Release Points

6.3
6.4
6.5
6.6
6.7
6.8
6.9
7.

C-3

6-8

6-8
6-9

.......................
.
............

Staff Evaluation of Union of Concerned Scientist Elevated Release Proposals

6-9

Hot Plume Release Through a 250-Foot Stack ...........................
The Tethered Balloon/Tube Release at 2000 Feet ..............

6-9
6-10

Selective Absorption Process System . . ..
. . .
Charcoal Adsorption Process System ...................
Gas Compression System
Cryogenic Processing System......................
Combination Process and Purge Systems . . . . . .
Onsite Long-Term Storage of Kr-A85. . . . . . . .
Transportation and Offsite bisposal . . . . . . .

Health Effects .........

.....................

Physical
Psychological..............

7.1
7.2

6-1
6:1
6-6

. . . . . . . . . . . . . .

EHtending Stack Aeight to 400 Feet .........
Constructing a 1050-Fact Stack............
.
6.2.5

. a..

. . . . . . ..

Stress..

. . . . . . . . ..

6-12.......

6-17..............
. . . . . . . . . . . . . . . .
. . . . . .
. . . . . .. .
.
.
. . . . . .
. . . . . . . . . . . .

.........
..

7-S
7-8

....
. . ..

6-33

7-S........

Environmental Monitoring Program ..

6-22
6-24
6-30
6-31

8.

Radiological

9.

Response to Conaents . ......

.

. . . . .

. ..

DD.

Public Information Activities ..

Si.

References . . . . . . . . . . . . . .

12 .

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

............

..

.

8-1
9-1
10-S

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. . . . . . . . . . . . . . .

11-1
12-1

PREFACE

This Final Environmental
March 1980.

Assessment revises the draft Environmental Assessment

issued for public comment in

Revisions to the draft Assessment have been made in response to comments received and to additional

1.0

Summary and Recommendation

reviews and analyses conducted by the NRC staff.
The NRC staff has prepared this summary of the Final Environmental Assessment
The Nuclear Regulatory Comaission has not yet made a decision on the disposition of the krypton-85 gas inreactor building atmosphere at TMI Unit 2.

thefor those who prefer to follow

the main themes of the assessment without referring to the technical descriptions,

The views and recomnendations expressed here are those of thedata that provide the foundation upon which the staff's recommendation is

calculations,and otherbased.

Commission staff.
The krypton-85 (Kr-85)
This report was prepared by the staff of the Three Mile Island Program Office,Regulation, with the assistance of additional

Office of Nuclear Reactor

released into the reactor building during the accident on March 28,

1979, must be

removed from the building so that workers can begin the tasks necessary to clean the building, maintain instru-

staff members from within NRC.

ments and equipment,

and eventually remove the damaged fuelwhether or not the plant ever again produces electricity.
dispersed throughOr. Bernard J. Snyder, Program Director
Three Mile Island Program Office
U.S. Nuclear Regulatory Commission
Washington, DC 20555

work inthe reactor building atmosphere,

from the reactor

core.

Those tasks must be performed

Radiation from the krypton gas,

although thinly

nevertheless poses a threat to workers who would have tothe building for prolonged periods.

This Final Environmental Assessment (NUREG-0662) presents a discussion of the information considered by the
NRC staff in arriving at its recommendation that the preferred method for removing the krypton-85 from thereactor building is by a kind of flushing process by which the gases would be pushed out of the building andfresh air pulled in.
The Metropolitan Edison Company (the licensee) on November 13,

1979,

asked the NRC staff for permission topurge or remove the reactor building atmosphere containing the krypton-85 to the outside (Ref.
1900,

1).

In March

the NRC staff published the draft version of this Environmental Assessment (NUREG-0662) and two subsequent

Addenda for public comment (Ref.

2).

Assessment.

Of these, approximately

approximately

500 opposed

the krypton or commentsit,

The staff has received approximately 800 comments on the draft Environmental
195 responses generally supported the purging of the reactor building,and the remaining responses were either recommended alternatives for removingthat took no position on the staff's recommendation.

Substantive comments received by

the NRC staff will be printed in Volume 2 of this Assessment.
From this process

have emerged some NRC staff conclusions

on four basic aspects of dealing with the reactor

building atmosphere:--- The potential physical health impact on the public of using any of the proposed strategies
rid of the krypton-U5 is

for getting

negligible.

--- The potential psychological impact islikely to grow the longer ittakes to reach a decision, getstarted, and complete the process.
--- The purging method is the quickest and the safest for the workers on Three Mile Island to accomplish.
--- Overall,no significant environmental

impact would result from use of any of the alternatives discussed

in this Assessment.
The Problem

As will be developedin the following discussion, decontamination of the reactor building atmosphere at thistime is a necessary activity irrespective of whether subsequent cleanup operations are authorized or of thenature of such operations.

There presently exists a need for relatively prolonged access to the reactor

building for purposes of maintenance of equipment essential for continuation of the safe shutdown mode and fordata gathering activities so that the nature and extent of future cleanup measures can be determined.

C-4

In

1-3

1-2

addition,it

The Proposed Solution

is believed that the prompt initiation of decontamination will be beneficial from the standpointof alleviating some of the psychologicalstress now being experienced by the nearby public.
In performing its Environmentil Assessment of Metropolitan Edison's proposal

Furthermore,

atmosphere,

authorization of any of the alternative methods for decontaminating the reactor building atmosphere.

being an action independent of any subsequent cleanup activities,

does not foreclose,

nor predetermine,

to purge the reactor building

the NRC staff has not only evaluated that plan but also has evaluated several alternatives.

including the following:theconsideration or selectioh of any alternative to such subsequent measure.

Taking the foregoing into consideration,

the staff believes that it

is in

1.

No action.

2.

Purging (Slow or Fast, Lower or Higher Release Points).

3.

Selective Absorption Process.

4.

Charcoal Adsorption,

5.

Gas Compression and storage.

6.

Cryogenic Processing (Liquifying the Gas and Storing for Later Disposal).

7.

A Combination of Purging and the Other Alternatives.

the best interest of the publichealth and safety to authorize this activity at this time, prior to issuance of the Programmatic Environmental
Impact Statement, now in preparation.

The March 28, 1979 accident
reactor.

in Three Mile Island Unit 2 heavily damaged the uranium fuelin the core of the

Many radioactive substances that normally remain trapped in the fuel rods were released when thefuel .rods were themselves broken.
system,Some of the radioactivity,

along with a large amount of water.

in the form of gases,

Some of the gases escaped to the environment and some of thewater reached other parts of the plant before being captured.

A great deal of water and a substantial amountof ralioactive gases remained confined in the reactor building.

As long as the damaged fuel inboron,

the reactor core is cooled and remains relatively undisturbed

and surrounded bythere is essentially no chance that the fuel chain reaction, which was abruptly stopped by the accident,

could start again.

But as time passes,

the NRC staff believes

essential equipment wearing out or malfunctionlng.
reaction once more,

itIf

for safe storage is1.

that there will be an increasing chance ofNo Action

the core were accidentally to begin to undergo a chain

could cause releases of more radioactivity within the reactor building.

removal of the damaged fuelShortly after the accident,

cleanup process undone.

But because these gases decayed to nonradioactive forms rapidly,

account for only about one millionth of the radioactivity
that air comes from the relatively

in the building air.

longer-lived krypton.

radiation given off by krypton-85
primary concern for worker health.

However,itispublic,accounts for as much as
Even with the krypton-85

removal of the krypton is necessary.

be radiation from the damaged reactor core,

Under these conditions, workers may belose considerations woulditto the extent that it

would interfere withindefinite delay might cause failure of equipmenta safe condition.

Third,

the building could begin to leak

could generate the same anxiety and stress that similar minor leakage incidents at the plant havegenerated in the past.

Since

75% of the total in some areas of the building),

would be physically more difficult, if
the building because of the heavy protective

Although the leakage is not considered a significant threat to the health and safety of theunexpectedly.

not this "beta" radiation that is ofSecond,in the building,essential to keeping the damaged reactor core in

Most of the

The primary concern is with the more penetrating gamma radiation.

the building.

maintainance of already over-used equipment

Traces of a radioactive form of hydrogen,krypton-85 contributes significantly to the gamma dose within the reactor building (itremoved, there would still

also limit-the 'lstaytime" of workers inin the reactor building is a kind that can be blocked by heavy layers ofclothing (which could also severely hamper workers).

First, it

for workers to do any significant cleanup work inlimited to only 15-30 minutes in the building before air sopplies must be replaced.

they now

Nearly all of the radoactivity

called tritium, are in the building, atmosphere at levels 18,800 times lower than the krypton.

It would also carry other risks.

clothing and air-supply equipment they would be required to wear.

the radioactive gases xenon and iodine accounted for most of the radioactivity inthe reactor building atmosphere.

the reactor building indefinitely would leave one important phase of theLeaving the contaminated air in

Therefore,

the paramount objective of the cleanup of TMI-2.

not impractical,

now inIncluding a Refrigerated Adsorber System.

leaked out of the reactor

2.

Purgingfrom radioactive material deposited on
But, theThe TMI-2 reactor building has two separate systems that can be used to move air from the inside of the building

radiation dose rate for workers would be cut from about 2.3 rem per hour to 1.6 rem per hour at the 300-footto the outside by way of filtering and monitoring equipment leading to a ventilation stack that reaches 160 feetlevel in the building, and from about 1.3 to 0.3 at the 347-foot level if the krypton-oh were removed from thein the air.

building.

to reduce hydrogen concentrations insurface, and from the more than seven feet of contaminated water in the basement of the building.

The smaller of the two systems was designed as a backup system to the hydrogen recombiner system

gas explosions.
At the present time, the reactor building is sufficiently air-tight so that steady cooling of the air in

1,000 cubic feet of air per minute.

thethe building foilowing a loss-of-coolant accident so as to prevent possible

This hydrogen control subsystem,

when modified, would employ a fan with the capacity to move up toThis fan would be started slowly and run at low rates until the krypton-8O

building has kept its pressure at slightly below outside air pressure.

Whatever small air leakage there hasconcentrations in the building had been lowered by dilution with fresh air so that larger volumes

been has come in from the outside,

the cooling system fans,sent outside without raising the concentrations of radioactivity around the site.

rather than to the onjtside.

run continuously for only a few hours,of time.

However,

designed toand ducts was used by itself,have been running for more than a year, and they may fail over a period

If they do, a rise in pressure inside the reactor building would lead to small puffs of uncontrolledleakage of the building atmosphere to the outside.

would take about 30 days of actual purging,spread over about a 60-day period,

The larger of the reactor building purge systems is the building's venti-

lation system. If this larger system were used along wth the hydrogen control subsystem,

This would not pose a health hazard to the public but

would be of major concern and could contribute to anxiety among residents in the area.

itto complete the purging operation.
the required amount of air in

Controlled and monitored

could beIf this system of fansabout five days of actual purging,

during good weather,both systems could remove

over a 14-day period.

Boththe hydrogen control subsystem and the reactor building purge systems are equipped with control valves and theirremoval of the building atmosphere before the cooling fans fail would avert that possibility.

C-5

1-4

1-h

own trains of filters so that fine particulate radioactive material would be removed from the air before it
discharged to the outside through the ventilation stack. Just before reaching the stack, the air from thereactor building would be mixed with air from other plant buildings to provide some dilution before it
discharged from the stack.

As the air bearing the' krypton-R5 isfrom the outside would enter the building through an open valve.

iscomponents,

and no competitive bidding.
This estimate does not consider the need for a suitable building at
the TMI site and is based on other questionable assumptions.

ispulled out of the reactor building, fresh air
In the best judgment of NRC construction experts, the shortest possible time to design, procure, construct andtest a suitable selective absorbtion system is 16 months. This time period is considered-by the staff to be.

an undesirable delay in getting the cleanup of the reactor building initiated.
It is relevant to note that
the Oak Ridge National Laboratory, the organizaton most knowledgable about the selective absorption system,has recommended against using that system and favors controlled purging to dispose c-f the krypton gas. -The staff also examined the possibility of extending the 160-foot high stack to 400 feet with piping supported
by scaffolding or guy wires.

The staff believes that under the best of weather conditions elevating the stackcould reduce the maximum pbssible exposures closest to the site to as little
occur for the 160-foot stack.

as 1/8th the dose predicted to

The staff has estimated that designing, construction,and leak testing theadded stack section would delay cleanup of TMI-2 by about four to five months.

4.

The staff next considered construction of a new 1000-foot stack to provide additional altitude for releasing
the reactor building air. The staff estimated that it would take at least 11 months to design, build, andCharcoal

test such a stack to adequate safety criteria.

contact with it.

Charcoal Adsorption

adsorption is a process by which the contaminated air from the reactor building would be piped into
The krypton would adhere to the surface of the charcoal after coming inlarge tanks containing charcoal.

They also felt that while the higher stack would reduce thepublic's radiation exposure,4the.projected exposure was already so low as to pose no radiological healthhazards and that the minimum of an 11-month delay to build a stack of 1000 feet could not be justified.

The charcoal

from this process would then be isolated and stored.

Finally,

The NRC staff evaluated both normal temperature and refrigerated charcoal adsorber systems. Both systems
require large quantities of charcoal; the first 34,000 tons and the second 12,000 tons.
During normal operation,(Ref.

no releases of radioactivity would be expected.

Since noble gases do not react chemically with charcoal,just stick to its surface,would be required during storage.

the staff evaluated two proposals submitted by the Union of Concerned Scientists to Governor Thornburgh
3).
The first proposal was that the reactor building air be heated to give it more buoyancy upon its

release from the stack for more effective rise and dispersal.

long-term surveillancecharcoal would have to be stored (and watched over)

the UCS has underestimated the time it

operation,and that instead of the seven to nine months predicted by the UCS, it

would take to put such an incinerator-heating

system into
The staff's major concern was the environmental

would take a minimum of 9months.

(The UCS estimated -construction time only, excluding design, engineering, procurement, and testing of
the incinerator scheme.)
The staff said the expected dose reduction of a-factor of about 30 to an individual

by construction of the charcoal -system.

and the delay do not justify the impact-of delaying the cleanup operation.

overall cleanup effort.

The second proposal was that a 2000-foot tube of reinforced fabric,
as a stack for discharge of the reactor building air.
said there was some uncertainty as to how long it
work.

The staff thought itheld aloft by a tethered balloon,

Because the method is unique and untried,

would take to implement,

would take 7 to 10 months to design,,build,

staff felt that the psychologicalto four years the containment atmosphere cleanup.

5.

be usedand the long delay caused

and testing of a charcoal system would delay by from two
The staff considers this to be an intolerable delay in the.

Gas Compression

Gas compression is a process by which the air containing the krypton gas in the reactor building would be
drawn off into pressurized storage containers.
These pressurized containers would then be stored in sealed

could

However, thesections of piping.

impact of a balloon clearly visible over the site may offset any advantage

For example,

at a pressure of 300 pounds per square inch,

pipe, 36 inches in diameter would be required.

which might be gained by a reduction of the dose to any individual.

3.

impact of long-term onsite storage,-Construction

the staff

but the staff thought it

and test such a system.

for up to 100 years to allow the radioactivity to decay toinsignificant levels.

The NRC staff believes that although heating of the discharge would reduce the public's radiation exposure
somewhat,but

The krypton-bearing

Selective Absorption

about one million cubic feet ofThis corresponds to about 28 miles of piping..

of this process are that it

The advantages
would expose the general population to less radioactivity than purging the krypton

and gas compression and isa known technology.

to put the system into operation,- The disadvantages are that two to four years would be required
the krypton gas would have -to be maintained under pressure in storage in

The selective absorption process would withdraw all the air in the reactor building, separate from it essentially
all the krypton, and return the decontaminated air to the reactor building. The contaminated air would passthrough a column in which liquid Freon would absorb the krypton while allowing the other gases to pass throughmany pressurized containers for approximately 100-years, and the krypton could leak at some time during storage.
The staff has-concluded that this alternative is impractical.

unchanged.

6.

Once separated,

the krypton could be stored for approximately 100 years under either high pressure

Cryogenic Processing

in a few gas cylinders, or under low pressure in a larger number of cylinders.
Cryogenic processing is the condensation of krypton-85 from the incoming air by bringing it
The Union Carbide Company of Oak Ridge,

Tennessee,with liquid nitrogen (-3 2 OF).

has been developing a selective absorption process since

The liquified krypton-8O

is collected,

into direct contact

restored to a gas form, and stored toin operation since 1978, can remove 99.98 of the krypton passed
Union Carbide officials are optimistic that a larger version of this pilot plant (scaled up atleast 10 times) can work at Three Mile Island.
Estimated times for completing this larger version vary.
Oak
Ridge personnel estimate that a system could be put in service at TMI in 10 months. To construct the systemallow decay.

in

The NRC has looked at several cryogenic systems available from commercial nuclear power plants. None of thesesystems has been operated successfully. Although these new systems could be purchased, a new building would

1967.

Their latest small-scale pilot plant,

An alternative to storing would be to transport the containers of the separated krypton (whether

from the cryogenic or selective absorption systems)

through it.

to a burial ground or to a remote area and release thekrypton gas to the environment.

this period would require a crash program that would use standard industrial design cri'teria, off-the-shelf

C-6

06"
"

1-6
1-7
be required to house the system und contain any possible leakage.
the piping of the existing hydrogen control system.

The cryogenic system would be connnected to

Public Health and Environmental Effects

The air from the reactor building would be passed throughthe filters and charcoal adsorber of the hydrogen control system and then piped to the cryogenic processing
system in

Physical Effects

At least20 months are estimated to be required to obtain a fully operational

the adjacent building.

cryogenic system at the ThO site.

This estimate is based on NRC staff assessments and consultations with

The NRC staff has determined that there are negligible physical public health risks associated with the use of

construction engineers at Oak Ridge National Laboratory.

in
During the approximately 2-i-month period r6quired to process the reactor builidng atmosphere,

about 60 curiesof krypton-85 would be released to the environment with the purified effluent from the system.

Also,

Protection Agency,

somethe U.S Department of Health,have reached the same conclusion.

leakage from the system is anticipated, but the staff believes this can be minimized by judicious monitoring
and a rapid system shutdown if trouble develops.

of the alternatives (excepting the "no action" alternative).
For, the venting alternative in particular,
independent analyses, the National Council on Radiation Protection and Measurements, the U.S. Environmental

radiosensitivity of humans,

based on limited experience with these systems,

However,

operation and maintenance are litely to result in a relatively high occupational
proposed to store the radioactive krypton on the site while it

decays.

dose.

Designs have been

Alternatively, burial or release of the contaminated krypton at a remote site could be accomplished.
the NRC staff believes

option).

that release in a remote area probably would not be acceptable to local officials

purging would have no adverse impact on plants or animals.

Almost all of this small risk would be borne by workers exposed at the plant (purge = 0.0002,

cryogenic = 0.034).
about 0.0001.

The total fatal cancer risk among all people within 50 miles of TMI from purging would beThis corresponds to an average risk of 0.000000000045

within 50 miles of the plant,
Combined Processes

systems, such as charcoal adsorption,
krypton,gas compression,and purging the rest to the environment.

cryogenic,

to thepublic within 50 miles and plant workers has also been estimated.
This genetic risk has been estimated torange from a minimum of 0.0005 effects (purge option) to a maximum of 0.066 effects (cryogenic option).

or selective absorption for most of the

One of the krypton recovery systems would trap about 95% of

the krypton (54,000 curies) and the other 5% (3,000 curies) could be released to the environment.

Again, almost all the risk would be borne by workers (and their descendants) at the plant (purge, 0.0003
effects; cryogenic, 0.066 effects. The maximum genetic risk to any offsite member of the public from thevarious options would be 5 chances in 100 million (0.OOOOOOO05), compared to the current expectation of all

The size ofthe processing system or the size of the storage facility for the final material holding the krypton would be
only about 25% to 33% of what would be needed if there were no purging used at all.

Of all the combinations

kinds of normally occuring genetic effects of one million to five million in 100 million (0.01 to 0.05).

considered by the staff, those using smaller size cryogenic processing or selective absorption could be built
the fastest but even so would take at least one year to be operational.
to complete the processing and final purging.

The `staff still

Additional time would then be requiredconsiders this an unacceptabledelay inFinally,thethe 5h-mile population of 2.2 million people.

leave the radioactive krypton to be stored onsite,

in some form,

other causes,

all the proposed

for about a century.

an above-ground storage facility at the site, actions could be taken to terminate the leak bytransferring the contents of the leaking container to a new one.
the selection of materials for such storage containers,

Psychological

The staff believes that more study is needed

Other risk comparisons are provided in Tables 7.2 and 7.3.

StressThe various alternatives

to decay away.

for decontamination of the TMI-2 reactor building atmosphere are expected by the NRC

staff to have different psychologicalTransportation and Offsite Disposal

impacts.

The NRC staff, with the assistance of consulting psychologists

Alternatively, the krypton gas would be appropriately packaged and transported to a waste burialthat the impact of handling,around TMI.

and in their fabrication, because of the possibility

that containers may corrode over the projected 100 years it will take the krypton radioactivity

burial or taken to a remote location,such as a desert,

additional skin cancer deaths among

This compared with about 4,000 deaths from skin cancer (fromprimarily sunlight), which would normally be expected in the 50-mile population (assuming 75

years life expectancy)

If a leak

As a result of purging,is estimated to result in a risk of

A population skin dose of 63 person-rem (purge option)

would be estimated to cause considerably less than one (about 0.000006)

With the exception of direct controlled purging of the reactor building to the outside,into the maximum exposed individual,

death of about one chance in a billion (0.000000001).

Onsite Long-Term Storage of Krypton-85

were detected in

the hRC staff has estimated risks associated with development of skin cancer.

a skin dose of 01 nrem (see Table 1.1)

overall decontamination of the reactor building atmosphere.

processes

to each of 2,200,000 individuals living

i.e., about 5 chances in 100 billion.

The total risk of some type of genetic abnormality, resulting from the decontamination alternatives,using one of the krypton extraction and recovery

The staff evaluated combinations of various alternatives,

and the Union of Concerned Scientists

number of fatal cancers, resulting from purging and the other alternatives, has been
The total potential cancer deaths for both the 50-mile population surrounding TMI-2
and plant workers is estimated to range from a minimum of 0.0003 (purge option) to a maximum of 0.034 (cryogenic

and residents.
7.

and Welfare,should be noted that, based on the relatively greater

made by the HRC staff.

years and represents a continuing risk to workers at the site, as well as a potential source of anxiety to the

However,

Education,

An estimate of the total

This will require surveillance for 100

public.

Additionally it

and released to the environment.

from the Human Design Group,

to what already has been found by some studies of the psychologicalfacility forPrevious research suggests that an event like the accident at TMI-2 produces

The HRC staff estimatescontinuing.

packaging, transportation and burial or remote release of the Kr-85 would be 0-24

after the accident,with time,

C-7

two types of stress:

short and

Short-term effects or those directly related to the occurrence of the incident are reported to beintense but short-lived.

person-rem (total body).

has compared thesestress effects of the TMI accident.

Some researchers have reported that while stress-related

they bad dissipated by mid-summer of 1979.

indicators were high shortly

Their findings suggest that stress changes

and that long-term mental health implications may be less than previously thought.

1-9

1-8
of Pennsylvania,

Based on consultations with psychologists, the staff has concluded that the purging alternative, which can be
implemented promptly, has less potential for creating long-term psychological stress than those alternatives
which take lopger to complete. Furthermore, since a prompt decision on, and completion of, purging will be
the first major step toward eventual cleanup of the reactor building and decontamination of the site, it isanticipated that a majority of the public will perceive this action as leading to elimination of future risks
from TMI-2. The NRCstaff, based on advice received from its consulting psychologists, believes that thispublic perception will reduce the stress and anxiety of the public.

PA 17126,

Government Publications Section,

and York College of Pennsylvania,

Education Building,Country Club Road,

Commonwealth and Walnut Street,

York Pennsylvania

17405.

Harrisburg,

All substantive

comments received will be published in Volume 2 of this final assessment.
Public Information Activities-

In an effort to better inform the public in the area aroundThree Mile Island about the contents of the draft
Environmental Assessment (PUREG-D662, and Addenda 2 and 2), ARC has conducted a series of 38 informational
meetings and activities.

Radiological Environmental Monitoring Program

The staff also issued an easy-to-understand report that answers frequently asked

questions about removing the krypton from the reactor building.

Copies of the report,"Answers to Questions

about Removing Krypton from the Three Mile Island Unit 2 Reactor Building" (NUREG-0673),

The radiological environmental monitoring around the TMIsite and nearby communities during decontamination of
the reactor building atmosphere would be performed by (1) the U.S. Environmental Protection Agency, (2) the

charge by writing to the Division of Technical Information and Document Control,
Commission,Commonwealth of Pennsylvania, (3) the U.S. Department of Energy, (4) the Nuclear Regulatory Commission, and(5) Metropolitan Edison Company(the licensee),Washington,

D.C.

U.S.

are available free of

Nuclear Regulatory

20555.

Most of the meetings held were planned by the NRC, although some were organized by other interested groups,
which NRC officials were invited participants.

The EPAis the lead agency for the Federal government in monitoring the area surrounding Three Mile Island.
EPA operates a network of eighteen air monitoring stations ranging from one-half to seven miles from TMI. EPA
will also use a number of mobile radiation monitoring vehicles positioned in the predicted downwind trajectoryduring purging. EPAwill issue daily reports of their measurements to the public during the purging of krypton.

Members of the U.S. Environmental

atProtection Agency and thePennsylvania Department of Environmental Resources (DER) were usually invited participants at these meetings.
EPA officials outlined their agency'sprogram and responsibilities for environmental monitoring in the vicinityof the TMI site, while State DER personnel
related to the clean-up of TMI Unit 2.

explained the community monitoring program and other state functions

At these meetings,

with other groups of people who had an interest in

In addition to their own direct monitoring, the Department of Energy and Commonwealth of Pennsylvania aresponsoring a Community Radiation Monitoring Program that involve people from 12 communities in an approximate
5-mile circle around TMI.

Assessment or clean-up operations at Unit 2.

About 50 individuals have completed training classes conducted by the Nuclear Engineering Department of Pennsylvania State University. The classes involved classroom instructions, laboratory training, and actual radiation
monitoring in the field. The teams will use EPAgamma-rate recording devices, which are currently in placearound TMI, and which will be supplemented by gamma/beta sensitive devices being furnished by DOEthrough EG&G
Idaho, Inc.
The training sessions were designed to provide a working knowledge of radiation, its effects, and detection
techniques, and included hands-on experience with monitoring equipment in the field. Citizens will be expected
to demonstrate minimal competence in radiation monitoring before actual monitoring efforts begin. Following
the completion of training, team representatives in each of 12 selected areas have been gathering and reporting
data from the gamna and gamma/beta-sensitive instruments on a routine basis.
Response to Comments
The draft "Environmental Assessment for Decontamination of the Three Mile Island Unit 2DReactor Building
Atmosphere" (IUREG-0662) and two subsequent addenda were issued for public comments late in March 1980. The
public comment period ended May 16. Approximately 800 responses have been received, each of which fell into
one of three categories: (1) those supporting the purging alternative recommended by the NRCstaff (approximately 195 responses), (2) those opposed to the purging alternative (approximately b0Aresponses), and (3)those who recommend decontamination alternatives other than those discussed in the Environmental Assessment or
who otherwise commented on the assessment (approximately 105 responses). Section 9 of this report provides
the NRCstaff's response to these comments.
Copies of correspondence received are available for inspection and copying for a fee at the NRCPublic Document
Roomat 1717 A Street, NW, Washington, D.C. 10555, and at the NRCLocal Public Document Rooms, State Library

C-8

NRC officials expressed their willingness to meet

receiving additional information on the Environmental

Table 1.1
Reactor-Bullding Atmosphere
Environmental impacts of Alternatives for Removing the Krypton-85 from theused Individual
Total Offslte Dose to Maoimum tBxp

0

formalProcessing

Accidents

occupational Exposures

Beta skin dose 11 mrem
Total body gamma dose
0.2 mrem

Beta skin dose - 25 mrem
Total body gaimma dose - 0.3 mrem

1.2 person-rem

Reactor Building
Slow Purge

Reactor Building
Fast Purge

Same as above

Same as above

Same as above

Elevated (400 ft.)
Purge

Approximately 1/B (0.13)
of Slow Purge above

Same as above

Same as above

Elevated (3000 ft.)
Purge

Approximately 1/230 (0.004)
of Slow Purge above
I
Approximately 1/30 (0.003)
of Slow Purge above

Same as above

Same as above

Same as above

Same as above

Approximately 1/300 (0.003)
of Slow Purge above

Same as above

Same as above

Selective Absorption
Process System

Less than Cryogenic
Processing System

Absorpti
Process
Beta skin ose---rem
Total body gamma dose - 0.1 mrem
Gas Storage
-asý
oneve
- 1700 mrem
Total body gamma dose - 20 mrem

115-220 person-rem

Charcoal Adsorption
Systems

Less than Cryogenic
Processing System

S
stem
Betakin dose -1mreml47 person-rem

Method,Hot Plume (250 ft.)
Purge
Balloon/Tube (2000
Purge

ft.)

-

Total body gama dose - 0.5 orem
Refrigerated Charcoal System
Beta ski. dose - 124 mrem
Total body gamma dose - 1.5 mremaoTable 1.1 (Continued)
Total Offsite Dose to Maximum Exposed Individual*
MethodNormal Processing

Accidents

Gas Compression
SystemLess than Cryogenic
Processing System

Beta skin dose - 410 mrem
Total body gamma dose - 5 mrem

41

Cryogenic Processing
SystemBeta skin dose 0.01 mrem
Total Body Gamna dose less than 0.0002 mrem

Beta skin dose - 1700 mrem
Total body gamma dose - 20 mrem

157-255 person- -rem

Approximately 1/95 (0.01)
of Slow Purge above

Beta skin dose - 1700 mrem
Total body ganmmadose - 20 mrem

115-255 person--rem

Combination Process!
Purge
No Action

Beta skin dose - 0,01 mrem
Total body gamoa dose less than 0.0002 mrem

Occupational Exposuresperson-rem(The potential offslte and occupationaldose from the extremely large inventoryof radioactive material within thereactor building cannot be reliably
estimated for long periods ofcontainment, but is potentiallyhigh and could exceed otheralternatives considered.)eThe collective SO-mile offsite population doses resulting from the purging
alternatives are estimatedbe 0.76 and 63 person-rem for total-bbdy and skin doses respectively.
Although elevating the release topoint would reduce these population dose estimates, the reduction would probably be no greater than 10%.

2-1

2.0

3-1

Proposed Action

The action proposed is

to purge from the reactor building at Three Mile Island,

released fromnthe damaged fuel as a result of the accident on March 28,

1979.

Unit 2,the krypton-B5

This NRC staff Final

Environmental Assessment responds to a proposal submitted by Metropolitan Edison Company (thelicensee)

3.0

Introduction

for purging the reactor building atmosphere through the building's existing hydrogen control subsystem
(Ref.

1).

This Assessment does not address decontamination of reactor building equipment,

and surfaces, and treatment and disposition of water in the reactor building sump or insystem.

interior walls

As a result of the March 28, 1979 accident at the TMI Unit 2 facility,

the reactor coolant

significant quantities of radioactive

fission products and particulates were released into the enclosed reactor building atmosphere because of sub-

These issues will be addressed in a Programmatic Environmental Impact Statement to be issued by the

stantial fuel

NRC staff later in 1980.

failure in the reactor core.

At the present time, the dominant radionuclide remaining in thereactor building atmosphere is krypton-S5 (Kr-85),

which has a 10.7-year half-life.

of the reactor building atmosphere since the accident,
1.0 pCi/cc, yielding a total

inventory of approximately 57,000 curies.

and. analysis are discussed in detailAt the present time the reactor is
the reactor vessel.

Based on periodic sampling

the concentration of the Kr-85 in the building is about
Reactor building atmosphere samplingin Section 4.0.

safely shut down, and is being maintained that way. with the damaged fuel in

Reactor building air-cooling equipment is maintaining the building at a slightly negative

pressure (approximately-0.7 psig) with respect to the outside atmosphere.

This pressure differential ensuresessentially no leakage of the reactor building atmosphere to the environment.

However,

before the facility

can be considered to pose no threat to public health and safety,

the damaged fuel must be removed from thereactor vessel and building, placed inand safely stored.

containers if necessary,

the reactor building are currently such that occupancy isreactor. building istion-program,severely restricted.

The radiation levels in

Less restricted access to therequired to facilitate the gathering of data needed for planning the building decontamina-

and for the subsequent work required to accomplish decontamination and other cleanup operations.

Less restricted occupancy will require that the building atmosphere be decontaminated to protect workers fromexposure to the beta and gamma radiation associated with the Kr-85 in

On November 13, 1979,

the reactor building atmosphere.

the licensee submitted a request to the NRC staff for authorization to decontaminate thereactor building atmosphere by controlled purging (feed and bleed) through the reactor building hydrogen
controlsubsystem (Ref.

1).

In a letter to the licensee on December 18, 1979,

the staff withheld approval of

the request to purge the building and stated that the NRG would prepare an Environmental Assessment on thesubject in early 1980 (Ref.

4).

The staff reviewed the licensee's submittal,

various alternatives to reactor building purging.
information in

As a result of that review,the form of 33 questions on December 18, 1979 (Ref.

request on January 4,

1980 (Ref.

6).

5).

including the discussion of
the staff requested additional

The licensee responded to the staff's

Pursuant to the requirements set forth in the Commission policy statementof November 21,

1979 (Ref.

7) and the February 11,

Regulation (Ref.

8); the NRC staff prepared a draft Environmental Assessment (NUREG-0662) in1980 Order by the Director of the Office of Nuclear Reactor
March 1980 (Ref.

2).

That assessment included the staff's evaluation of licensee modifications to the reactor building hydrogen
control sqbsystem, as well as a discussion of the need to decontaminate the reactor building atmosphere andalternatives to controlled purging to the environment.
to end April 17,
May 16, 1980.

The original comment period for NUREG-0662 was scheduled

1980, but was extended by the Commission,at the request of the Governor of Pennsylvania,

This Final Environmental Assessment (NUREG-0662) is based on information and public comments

received since publication of the draft Assessment and includes an update of the NRC staff's evaluation ofreactor building decontamination alternatives,and an evaluation of potential physicalhealth effects associated with reactor building purging.

1

C-I

and psychological

to

4-1

4-2

which,

if

utilized, would further reduce the already small airborne concentration of these isotopes.

The

removal efficiency (99.97% or better) of these filters would reduce any release of particulate radiation tonegligible quantities.

Airborne tritiumconcentrations in the reactor building are measured to be approximately 8.4 x 10-5 pCi/cc.
4.0

Reactor Building Airborne Activity

This value is consistent with the calculated estimates of airborne tritium concentration which-is based onreactor building relative humidity and on tritium measured in the reactor building sump water.
This

4.1

Gas Sampling and Analysis

concentration is 10 times lower than the maximum permissible airborne concentrationin Table I of Appendix B to 10 CFR 20 (Ref. 9).

Three types of reactor building air samples are periodically collected to determine the nature of airborne
contaminants inthe building.

radioiodine activity.

Samples are taken for noble gases (including Kr-85),

particulate matter,

Air samples are taken from two points in the reactor building.

andThe samples aretransmitted through two lines running from the dome to the reactor-building air-sample gaseous monitor.
Redundant inlet and discharge valves are provided for the system to prevent a single-active failure of any
valve from impairing the function of the system.

Samples are analyzed with a gas chromatograph to determinehydrogen content and isotopic composition is determined with a gamma spectrum analyzer.

The Kr-85 gas activity

in the reactor building atmosphere is determined by gamma spectroscopy techniques.

Isotopic identification ismade on the basis of the discrete energy levels at which gamma rays are absorbed ina germanium-lithium (GeLi)

detector.

Particulate activity isthrough a filter.
gamma spectroscopy.

determined in the reactor building atmosphere by pumping building air

Particulate activity isremoved from the air by filters, which are then analyzed using

To determine the concentrations of the different types of iodine in the atmosphere,

sample of the reactor building air is pumped through a series of filters.

aSeparation of the different formsof iodine is accomplished based on the relative affinity of each iodine species for a specific filter medium.
Each filter is then analyzed using gamma spectroscopy.
In addition to the routine sampling for noble gases,
and gross beta analyses.

particulates,

and iodine,

The results of the sampling program are presented insamples are obtained for tritium,
the following section, "Source

Term Derivation."

4.2

Source Term Derivation

Sample results to date indicate that the dominant isotope within the reactor building atmosphere isKr-85.

Radioactive decay has reduced other radioactive isotopes of xenon and krypton to negligible quantities.
Reactor building gas sample data from May to December 1979 indicate the source term for Kr-85 is 0.78 pci/cc,
with a standard deviation of ±0.23 pCi/cc.

Since late 1979,

reactor building gas-sampling techniques were

improved to eliminate small sample line leaks and to allow for direct counting of the samples.
improved sampling techniques,
deviation of ± 0.03 pCi/cc.

This smaller standard deviation indicatesnoble gases (e.g.,

Xe-133m,levels of 1 x

Xe-131m,

With these

the source term for Kr-85 is measured to be 1.04 pCi/cc, with a smaller standard
Xe-133, Xe-135)

improved sampling accuracy.

O -6.pCi/cc.

Radioactive decay has reduced iodine levels in the reactor building to below MDA levels of 1 x 10Particulate levels, primarily those of cesium-137,

are less than I x 10-p9

have been specifically analyzed for strontium-89/90.

Those analyses,

show that airborne strontium-89/90 levels are small,that is,concentration

Other

have decayed to below minimum detectable activity (MDA)0

Ci/cc.

pCi/cc.

Reactor building air samples

plus the results of gross beta analyses,

in the order of 1 x 10-10 pCi/cc.

The airborne

levels of all the above isotopes are measured to be below the maximum permissible concentration(MPC) levels listed in Table I of Appendix B to 10 CFR 20 (Ref. 9).
Additionally, it should be noted that allof the decontamination alternatives (listed in Section 6) include systems (e.g., HEPA, and charcoal filters)

C-1I

limit for tritium listed

5-2

5-1

5.0

Need for Decontamination of the Reactor Building Atmosphere

5.1

Summary

While activities leading to core defueling are being undertaken,
monitoring.

itwill be necessary to continue direct core

To allow the remaining core monitoring instrumentation to deterioriate would pose additional risks tothe public and to workers because of the potential for core recriticality
radioactive fission products at Three Mile Island.

to result in the generation of more

Should this existing instrumentation failit will be necessary

to decontaminate the reactor building atmosphere to achieve the access necessary to repair or replace them.
The reactor building atmosphere needs to be decontaminated ina timely manner primarily to permit the lessrestricted access to the reactor building necessary to gather information,
toward total decontamination of the Unit 2 facility.

to maintain equipment,

and to proceed

At present,

At present, the Kr-A5 dispersed inside the reactor building

Following decontamination of the reactor building atmosphere,

gathering.

radiation mapping,

preliminary decontamination,

radiation levels in the reactor building at the 305-body dose rates of approximately 2.3 rem/hour and 1.3 rem/hour,atmosphere limits operations which could be conducted inside the building to preliminary contamination dataprior to decontamination of the atmosphere,

larger scale activities, such as detailed

sary gear,and shielding placement, will be possible since loweredradiation

Ifradiation detectors,

total

a reactor building entry is madeheavy protective clothing and equipment will be required.

including self-contained respiratory equipment,

sonnel dosimeters,

exposure levels will reduce the need for personnel protective gear.

and 347-foot elevations would result in
respectively.

The neces-

communications equipment,per-and protective clothing would weigh approximately 85 pounds and would hamper the movement

necessary for workers to perform decontamination or maintenance-related

tasks inside the building.

Heavy pro-tective clothing would be expected to shield workers from essentially all of the direct beta radiation from the
The eventual removal of fuel from the reactor vessel (or defueling) is

an important milestone in the overall

small, but finite, potential for inadvertent core recriticality, wiich could occur, for example,
boron dilution of the reactor coolant.
material in

the reactor building.

krypton cloud (150 rem/hour to unshielded skin), although some diffusion of the krypton through the suit would

Defueling will eliminate thecleanup effort which cannot proceed until atmospheric decontamination is completed,probably occur.

from accidental

beta-emittingThis clothing,

however, would not protect workers from gamma radiation or from high-energy

radionuclides which are believed to contaminate surfaces inside the building.

In addition, defueling will eliminate the major source of radioactive

Decontamination of Kr-85 in the atmosphere would also provide the lessDecontamination of the reactor building atmosphere would reduce the total body dose rate by 30% on the 305-footrestricted access to the reactor building needed to repair or replace core nuclear instrumentation, to maintainthe reactor building air cooling system,

elevation and by 75% on the 347-foot elevation (the operating floor) to 1.6 rem/hour and 0.3 rem/hour,

and to support processing of the reactor building sump water.

tively.

respec-The dose-rate values shown below provide an example of expected dose rates accruing to an individualin

self-contained breathing apparatus and protective clothing.
Although difficult to quantify, present conditions inside the reactor building pose risks to the physicalpsychologicalhealth of residents in the Harrisburg-Middletown area.

stress, will continue to be a concern throughout the cleanup process.

In the NRC staff's opinion,

these risks require a safe and expeditious completion of all cleanup activities at the site.
the reactor building atmosphere is

the next required step in achieving this goal.

andincluding psychological

Public health risks,elimination of

Dose Rate (Rem/Hour)

Decontamination ofRadiation

5.2

Discussion

Elevation 305 Feet

The TMI-2 reactor is presently being maintained safely shut down, with damaged fuel inextent of fuel damage and the present core configuration are unknown.
to be maintained subcriticalIt

the reactor vessel.

is important that the reactor continue

and that the damaged fuel inside the reactor be removed from the reactor vessel andplaced in a safe configuration to eliminate any potential

After Decontamination

Gamma (total body)

2.3

1.6

Beta (skin)

0.8

0.8

Elevation 347 Feet

Before Decontamination

After Decontamination

Gamma (total body)

1.3

0.3.

Beta (skin)

1.2

1.2

for core recriticality.

As the minimum negative impact, core recriticality would resultin the production of additional radioactive

Radiation

Core recriticality could also lead to further degradation of thematerial which would require decontamination.

Before DecontaminationThe

reactor coolant system and the possibility of uncontrolled release of radioactivity to the environment.
The licensee is presently relying on boron injected into the reactor coolant system to maintain the core subNormally, this function is accomplished by inserting control rods into the core.

critical.

During the accident,

however,itpresent,

most instrumentation provided for monitoring reactor neutron flux, and therefore providing feedback on

is believed that some of the control rod material melted and may have drained'out of the core.

boron effectiveness,isinoperable.

direct measurement of neutron flux in

Only one nuclear instrument channel

is operating.

the reactor core would not be possible.

If

this instrument fails,

It would then be necessary to infer

the status of the core by periodic sampling and analysis of boron concentration in

the reactor coolant.

the staff considers the potential for core recriticality to be of low probability,it

before defueling is anticipated.
removing the fuelcore inAt

It should be noted that-Kr-85 beta skin dose (approximately 150 rem/hour) is not a factor in this example due tothe presence of protective clothing before decontamination and elimination of Kr-85 beta radiation after decon-

Althoughwill be a number of years

tamination.

In the interests of public and worker health and safety, the staff believes thatin a timely fashion will eliminate the potential risk, no matter how small, associated with theits present condition.

Since decontamination of the reactor building atmospherestep in the path leading to core defueling,

it

then,

is necessary to reduce worker risk from

tective clothing (including risks involving tearing the protective suit and worker injuries due to falling).

is the necessary next

should be undertaken in a safe and expeditious manner.

Decontamination of the reactor building atmosphere,

gamma total-body exposures from Kr-85 and to eliminate and the risk and inefficiency of working in burdensome pro-

Purging thereactor building can achieve both of those goals.

C-12

r|am

6-1

5-3

The reactor building atmosphere,
mately7which isat 100% relative humidity,

is currently being maintained at approxi-

This cooling action is maintaining the reactor building

5QF by the reactor building air-cooling system.

at a slight negative pressure (approximately -0.7 psig) with respect to the outside atmosphere.

This pressure

Other factors that affectdifferential prevents leakage of the reactor building atmosphere to the environment.

the pressure differential between the reactor building atmosphere and the outside atmosphere include:(1) pressure

differentials caused by wind currents over and around the building, (2)(3)

in external

air temperatures,changesand (4) the solar heat load on the building:in barometric pressure,

Four fans have been operating nearly continuously since the March 28,

humidity environment.
expected to failIt issequentially over a period of time.

The NRC staff has considered the possibiilty that no action be taken to decontaminate the TMI-2 reactor building

a 100% relative humidity

1979 accident in

atmosphere.

a high-Their sequential failure would result inthat for worst-case conditions (i.e.,

all fans fail),First, taking no action would subject the public to potential health and safety risks which exceed those of any

reactor building during its most recent leak-rate test (conducted
day at 56 psig.

atmosphere.

The

pressure,continuation of activities

the staff calcu-

the one-day dose could vary from approximately 0.02 milllrems to 0.00002 millirens.

that the annual average X/Q isapproximately 6.7 x 10-6

would involve small amounts of Kr-R5,

In view of the fact

the environment,leakage from the makeup and purification system resulting in a gaseous discharge of 0.3 Ci

psychological1980),

leading to eventual defueling.

This access,in turn, depends on the decontamination

An indepth discussion of both publichealth and occupational risks resulting from the employment of other deconta-

mination alternatives

the following subsections.

is presented in

Public health risks for all alternatives have

6.2

leaks of gaseous effluents to

6.2.1

Reactor Building Purge Systems
Introduction

the staff believes that future uncontrolled leaks could generate significant

stress in the community.

fully monitored,

In the staff's view,

A number of purge methods could be used to decontaminate

a controlled purge, which is publicly announced,

and conducted during favorable meteorologicalconditions,the reactor building atmosphere.

The staff has

evaluated four purge methods which could be implemented utilizing existing plant systems and structures and two

is preferable to uncontrolled leakage.

other purge methods which would require either new or modified plant systems and structures.
include:The reactor building cooling system will also perform a vital function following decontamination of the reactor
building atmosphere.

'Thethe staff does not consider such leakage likely to threaten the health andHowever, based on past public response to relatively smallof Kr-85 on February 11,

Thesebeen determined to be negligible.

sec/m3 and uncontrolled leakage from the reactor building

safety of the public.
(e.g.,

in Section 5.0.

of the reactor building atmosphere.

The

corresponding beta skin dose to the person receiving maximum exposure from this leakage would be dependent on
local meteorology (i.e., the dispersion factor or X/Q) which typically varies from 1 x 10-4 to I X 1 0m7 sec/m3
Thus,

for decontaminating the reactor building

NRC staff believes that minimizing these risks depends on access oa workers to the reactor building to permit

in early January 1978) was 0.095% by weight perleakage of Kr-85 from the reactor building would not exceed five curies per day.

considered within this Environmental Assessment,

The potential risks associated with taking no action are discussed in detailrisks include possible core recriticality and corresponding production of additional radioactive materials.

The measured leakage rate of theBased on the relationship between observed leak rate and differential

lates that uncontrolled

other alternative,

The NRC staff has calculated

this pressure could rise to as high as four psig.

reactor building has a design leakage rate of 0.Z% by weight per day at 60 psig.

This

as totally inappropriate for several reasons.

a decrease of heatremoval capability from the reactor building atmosphere and could ultimately cause the atmospheric pressure in thereactor building to increase and become positive relative to the outside atmosphere.

This alternative would necessitate retaining the radioactive gas within the reactor building.

option has been rejected, however,

The operating fans can ,oeasonably be

not known if the standby fan is operable.

Decontamination Alternatives
No Action

The ouilding air- cooling fans (fouroperating, one standby) were qualified for three to four hours of continuous operation inenvironment.

6.0
6.1

changesThose methods

a slow purge using the existing hydrogen control subsystem with releases from the unmodified

160-foot plant vent stack; (2) a fast purge using the existing hydrogen control subsystem and reactor buildingThis system will be needed to maintain a reasonable working environment inside the building

and allow expeditious building decontamination and defueling activities.

(1)

purge system with releases from the 160-foot plant vent stack; (3)Decontamination of the reactor building

an elevated purge using the existing hydrogen

atmosphere would allow for cooling system maintenance and avoid recovery effort nelays that might accompany cool-

control subsystem and reactor building purge system with releases from the plant vent stack elevated to 400

ing systemfailures.

feet; and (4)an elevated purge using the existing reactor building purge system with releases from a new

1000-foot stack.
Although a discussion of systems and alternatives for processing the reactor building sump water is not appropriate for this document (the forthcoming Programmatic Environmental

In addition,

Impact Statement is the appropriate document),

access to the reactor building will be necessary to effectively support processing this water.

the staff has evaluated two methods of purging proposed by the Union of Concerned Scientists in areport submitted to the Governor of Pennsylvania (Ref.

Should NRC approve3).

The two methods proposed are release of a heateda system for processing the sump water, the licensee will require less restricted access to the reactor building

plume from a 250-foot refractory lined stack and an elevated release at 1000 to 2000 feet through a relatively

to support processing with area washdowns.

light-weight tube held aloft by a tethered balloon.

Area washdowns will assist inmaterial that would otherwise adhere to the walls and surfaces indecline.

The primary reason for these washdowns

sources of radiation from the walls.

the removal of the crud and filterable

the basement of the building as water levels
6.2.2

is to protect workers from direct or airborne (from drying out)

Sloe Purge

Area washdowns will not be possible unless the reactor building atmosphere
The hydrogen control subsystem was originally installed for use as a backup system to the hydrogen recombiners.

is decontaminated.

The system is being modified to allow variable flow rates up to a maximum of 1000 cfm.

Actual purge rates

Lastly,the NRC staff believes expeditious decontaminaton of the reactor building atmosphere is necessary toduring a purge would be dependent on meteorologicalreducelong-term psychologicalThe hydrogen control subsystem would withdraw the reactor building atmosphere through a filter system,

stress in

the TMI area by shortening the time necessary to complete the entire

the effluent radioactivity

cleanup project.

environment.

C-13

conditions and reactor building concentrations of Kr-85.
monitorlevels, and discharge the effluent through the 160-foot plant vent stack to the

6-3

6-2

These releases would be made based on existing meteorological conditions such that release rates of radioactive

specification provides for relatively short periods of operational

materials would be controlled to ensure that the requirements of 10 CFR Part 20, the design objectives of 10 CFR

rates (and hence dose rates) can be averaged inPart 50, Appendix I (Ref.

6.2.2.1

and the applicable requirements of 40 CFR Part 190.10 (Ref.

11)

12)

The dose rate during a purge period is

System Description and Operation

subsystem of the reactor building ventilation system.

the Unit 2 vent stack,exhaust fan,isolation valves,

and a radiation monitoring system.

filtration system,

consists of a prefilter, a HEPA filter, an activated charcoal

therefore,systems and released throughrelease rates,

The filtration systemfilter, and a downstream HEPA filter.

During periods of less favorable meteorology,

release rites can be selectively reduced to maintain desired dose rate levels.

Detailed licensee

procedures for maintaining acceptable purge dose rates during varying meteological conditions by adjustingan

The major components of this system include:

can be adjusted to limit the resulting dose rate.

rate (Ci/sec)

Radioactive gases purged from the reactor building would

which is 160 feet above grade level.

dependent on the product of three variables; the Kr-85 release rate,0
Only the Kr-85 dose conversion(X/Q) and the Kr-85 dose conversion factor.
meteorological dispersion factor
mren-mfactor is a fixed value, m.
While meteorology (X/Q, sec/m3) cannot be controlled during a purge, release

Tbe proposed purge of the Unit 2 reactor building atmosphere to the environment would use the hydrogen control

be diluted with the exhaust air from the auxiliary and fuel building ventilation

Cumulative

cannot be exceeded.

Appendix I dose, however,are not exceeded.

flexibility because relatively high releasea quarter with relatively low release rates.

have been reviewed and approved by the NRC staff.

In addition,members of the NRC onsite staff

will monitor the licensee's actions during the entire purge.

Replacement

air to the reactor building would be supplied through the reactor building pressurization valve.
At the onset of the slow purge scenario, purge rates would be expected to be in the range of 50 to 75 cfm.
The slow rate purge alternative recommended by the NRC staff would be carried out within several limiting
conditions.

Most importantly, purging would be controlled to limit the cumulative maximum individual offsite

dose resulting from the purge to less than the annual dose design objectives (5 mrem totalof Appendix I to 10 CFR Part 50 (Ref.

in the reactor building decreases,

approximately 1000 cfm.

The purge rate during any period would be dependent on the aforementioned

Doses would be tracked during actual purging by using real-time

11).

meteorological

data to calculate hourly dose rates in affected sectors surrounding the plant.

around TMI isdivided into 16 directional sectors; wind directional

The incremental dose .(mrem) for each purge period is obtained(The region

sunming the individualit

the purge process.

based on these calculated dose- rates in

For example,

ifor beta skin (15 mrem) dose objective inreached the annual Appendix I total

through the reactor building pressurization valve.
subsystem exhaust fan.
when the fan stops.
building pressure

release rate limit and a quarterly average release rate limit.

Although these specifications haveradiation monitors in

Flow rate, temperature,is the remaining noble

operations.

10-u sec/mn)

maximum permissible concentration (MPC) for Kr-85 in unrestricted areas (3 x
20, Appendix B, Table 2, Column 1 (Ref.

9).

10

Table 6.2-1 provides a list

specification limit of 7200 pCi/sec,value (4.2 x 10-s sec/M3),

would also be applicable to a slow purge.

is based on not exceeding,in one quarter,

activity is

11).

I dose design objective.

of the major components used in

the hydrogen control subsystem.

The subsystem

detected in the effluent:

Figure 6.201 provides a flow diagram of the:hydrogen controlsubsystem.

based on a more restrictive X/Q

Modifications

to the hydrogen control

subsystem would include (1) replacing the hydrogen control subsystem exhaust fan with a fan capable of producing

This quarterly averaged release rate limit

four times the annual Appendix

area radiation monitors have local

exhaust fan is interlocked to stop automatically and valves close-autbmatically to isolate the system if highnimiting to operation because thecumulative Appendix I dose restriction also limits the conduct of the purge alternative (Ref.

Generalroom.

listed in 10 CFRThis specification provides for short-term operational flexibility..

Any extended release at this relatively high rate would quickly become

A quarterly averaged release rate technicaland remote readouts in the Unit 2 control

for the TMI site and the-7 pCi/cc) as

and radiation level are measured at the hydrogen control subsystem

General area radiation levels around the filter housing on the 320-foot level of theauxiliary building would be monitored by a local radiation monitor.

requires that the instantaneous rate not exceed 45,000 pCi/sec.

derived from the annual average X/Q' (6.7 x

and radiation level of hydrogen control subsystem flow would be monitored during purging

System flow rate, temperature,

fan discharge point.

This instantaneous limit isGeneral area

the auxiliary building would detect the radioactivity to signal for isolation of thereactor building by stopping the purge.

Release rate

the reactor building.

One Kr-85 release rate technical specificationinterlocked with the exhaust fan to shutfor backflow of contaminated reactor building air

As applied to the slow purge

specifications.

rate alternative, the technical specifications effectively apply only to Kr-85 since it
gas inthere is the potential

is not maintained slightly negative with respect to the auxiliary building.

These specifications consist of analone determines conformance or non-conformance with the technicalThis ensures that air would flow into the reactor building

The reactor building pressurization valve is

Nevertheless,13).

dose limitations as their bases, they have been implemented as noble gas release rate'limits.

pCi/cc in the reactor

through the reactor building pressurization valve to the 328-foot level of the auxiliary building if the reactor

In addition to Appendix I constraints, the slow purge procedure would be limited by the existing Three Mileinstantaneous5

anda small negative pressure relative to the auxiliary building would be maintained with the hydrogen control

increase in dose to the North sector.

Island effluent release technical specifications for noble gases.(Ref.

The staff estimates that over a 60-day period

would require approximately 30 days of actual purging to reach the MPt level of 1 x 10-

During purge operations with the hydrogen control subsystem, makeup air would be supplied to the reactor building

body (5 mrem)

the North sector, purging would be discontinued when existing windconditions could result in any incremental

incremental doses from each purge period.

andobtained byexcess of thethe calculated cumulative dose to a hypothetical person,

based on actual Kr-85 release rates and real-time meteorology,

from the product of the dose rate (mrem/sec)

The total dose due to the entire purge of 57,000 Ci of Kr-85 isbuilding.

would be updated hourly throughout

each affected sector,

No hypothetical person in any sector would be permitted to receive a dose inAppendix-I dose design objective.

of the period.

time duration (sec)changes during purging will result indiffering dose rates for individual sectors.)

Cumulative dose,

limiting

conditions.

15 mrem skin)

body,

As

the purge rate would be increased to a maximum of

the Kr-85 concentrationa maximum flow of 1000 cfm,

Again this

(3)

(2)

recoemissioning the auxiliary building and fuel-handling building filter trains,calibrating and reactivating the stack monitor,(4)

securing the supplementary filter train by turning off

the supplementary fans and closing the isolation door from the stack inlet plenum to the filters, and (5)ping the plant vent stack.

'See the Glossary for a definition of X/Q.

C-14

uncap-

I

I

I

I

6-5

6-4

6.2.2.2

Table 6.2-1

SystemOperator

Fan AH-E-34

Electrical

Pressure Sensing Line
Isolation
Valves A-VS &AM-V6

Electrical

RB Pressurization
Valve AH-V7

Air operated

Exposure

The design criteria for the existing hydrogen control subsystem isHydrogen Control Subsystem

Effects of Lossof Operator

Occupational

consistent with the "asachievable" guidance of 10 CFR Part 20 and Regulatory Guide 8.8 (Ref.
would be exercised rewotely from the Unit 2 contrul ruom.

Auto-Action

Interlocks

Reduced flo
thru system

Stop fanHigh activity
on HPR-229*

Fail a, is

None

None

be in

the auxiliary building during system operation.

14).

low as reasonably

Control during a purging interval

However, an auxiliary operator would be required toThis operator would have communication ties with thecontrol room and be stationed in a low-radiation area.
Changing the two HEPA filters

The dose to operators during processing will be approximately 0.8 person-rem.
will also contribute to occupational exposure.

These filters have a surface dose rate of approximately 0.17

R/hr and filter changeout will require approximately one-half hour per filter.
will be changed only once at the end of the purge operation,
fore,
Closes onloss ofpower

When fan AH-E-34
stops, valve
shuts

6.2.2.3

None

Slow Forge - Using the Hydrogen Control

RB Hydrogen
Control
Valve AI-V25

Electrical
motor-operated local
control

Fail as is

RB Hydrogen
Control Discharge
Valve AM_-V36

Air operated

Fail closed

Opens when fan NonestartsReactor Bldg.
Hydrogen Conrtrol Isolation Valve.AM-V52

Air operated

AH-V-3A, 8
RB Isolation
ValvesAir operated

is expected that the filters

the total exposure for processing and filter changeout would be approximately

Valve failclosedNone

Itresulting in approximately 0.4 person-rem.

Environmental Impact
Subsystem With Release from the Unmodified 160-foot Plant Vent Stack.

Based on the release of 57,000 ci, and the annual average dispersion factor of 6.7 x 10-6

Fall closed

None

There-

1.2 person-rem.

dose is estimated to be 11 mrem and the gamma total body dose is estimated to be 0.2 mrem.

3

sec/m , the beta skin
These numbers represent

the maximum dose that could occur to an individual present at the site boundary for 70% of the release period.

In the staff's evaluation,None

an annual average X/Q is used to calculate offsite concentration and dose.

annual average X/Q is used because predictions of actual meteorologicalimpossible.

However,The

conditions for a particular time are

the probabilities are high for having hourly atmospheric diffusion conditions during any

season that would provide a considerably less conservative X/Q than the annual average X/Q used by the staff inFail closed
on highradiation,

Fail closed
loss of power

their evaluation.

None

The dose received by the population residing in the SO-mile radius around the reactor due to the release of the
57,000 Ci of Kr-85 was evaluated.
(Ref.

15).

The methods used for this calculation are described in

A standard grid was employed which segmented the population into 160 elements.

16 sectors (N clockwise through NNW)each centered on the appropriate direction.
segments at standard distances of 2000 ft (.37 mi),logical1, 2, 3,4, 5,

10, 20,Regulatory Guide 1.109
This grid contains

Each sector is divided into

30, 40, and 50 miles.

dispersion parameters which were used were the same as those that were used for the Final

the Final Environmental Statement for Three Mile Island Nuclear Station,
1976 (Ref.

Unit 2, (NUREG-0112),

The meteoroSupplement toissued Oecember

16).

The meteorologicaldispersion parameters represent annual average conditions and were developed on the basis ofhistorical data collected at the site.

The 1980 population was taken from NUREG-0558 (Population Dose and

Health Impact of the Accident at the Three Mile Island Nuclear Station) (Ref.

The SO-mile population dose calculated by this method is

17).

0.76 person-rem total body due to the gamma componentof krypton decay and 63 person-rem skin due to the beta component of the krypton decay.

6.2.2.4

Accident Analysis

The components for the purge system are located in the Unit 2 auxiliary building.
system would allow Kr-85 to be released to the auxiliary building.
rMonitor mounted inexhausted through the auxiliary building ventilation systemnto the plant stack.

the exhaust duct downstream of the exhaust fan.

release pathway as that for the normal purge system.

C-15

A major rupture in the purge

Any Kr-8S released to this building would beThis path would be the same

6-6
6-7

The worst-case accident would be an inadvertent initiation of the purge system at maximum flow of 1000 cfm witha Kr-8S concentration
were
isin the reactor building atmosphere of 1 uti/cc.

extremely conservative

and was used only for calculational

Figure 6.2-2 provides a flow diagram of the reactor building purge system.

In our analysis we assumed that 30 minutes

required-tor the operator to detect the leak and isolate the system.
purposes.

include two air supply fans and filter units,

The 30 minutes used in this analysis

fans and filter units,

During actual operation a high radiationof a prefilter,

alarm monitor would automatically stop the hydrogen control subsystem purge fan and valve closure would automatically isolate the reactor building.
In a 30-minute period,

For conservatism,

Using Regulatory Guide 1.109 (Ref.

15),

the meteorologicaland two isolation valves in each purge air exhaust duct.

(Ref.

9).

ditions,

the staff calculates that the total body gamma dose tobody dose represents only a small fraction of the 10 CFR Part 100 limit *(Ref. 18) of 25 rem.

The total

where X/Qi

6.7 x 10-6 sec/M3.

ments of 10 CFR Part 20 (Ref.

(Skin dose limits

for Krypton-85 (Kr-85)

These Technical Specification

favorable meteorological conditions,

When favorable meteorological

5.. FastPurge

19),

The reactor building purge system is an existing system originally

However,by controlling the purge rates to take advantage of more

the design objectives of 00 CFR Part 50, Appendix(Ref.

A scenario for this purge is described inThis variation in

5000 cfm.

the purging alternative would

conditions favorable for atmospheric dispersion.

In addition,

specifications.

The

with the weighted annual average requirements of 10 CFR Part 20 (Ref.
Part 50, Appendix I (Ref.

conditions exist, the hydrogen control subsystem would be operated at its maximum

the fast purge would be conducted to conservatively
specification

When the reactor building Kr-85 concentrationis reduced to 0.22 uti/cc,

It would

the hydrogen control

The reactor building purge system would operate at S000 cfm for approximately

would be. approaimately 120 hours.

Thus,flow rate of

70 hours to 'reduce thethe total actual purge time using both systems

The calendar time frame necessary to complete the fast purge scenarioisdependentupon achieving favorable meteorology and is especially sensitive to the seasonal variations that canoccur (see discussion in Section 6.2.3.3).

19), the design objectives of 10 CFR
12).

in the reactor building is reduced to 0.22 uCi/cc.

building concentration of Kr-8O to MPC (1 x 10-s uCi/cc).

the purge

fast purge would be conducted in accordance11), and the applicable requirements of 40 CFR Part 190:10 (Ref.

11) and thesubsystem would be secured and the the reactor building purge system started with an approximate

in accordance with the existing instantaneous and quarterly average release rate limitsof the existing radiological effluent technicaltechnical

0.22 uCi/cc.

for decontaminating the Unit 2 reactor building atmosphere.

Subsection 6.2.3.1

I (Ref.

12).

require approximately hO hours to reduce the current reactor building Kr-85 concentration of 1.0 uCi/cc to

installed for purging the reactor building

Use of the reactor building purge system in conjunction with the hydrogen control subsystemrepresents a variation in the purging alternatives

releases through the 160 foot plant vent stackhigher purge rates can be achieved while still not exceeding the require-flow rate of 1000 cfm until the Kr-85 concentration

could not be conducted

two air exhaust

filter units consist

limits are based on conservative annual average meteorological con-applicable requirements of 40 CFR Part 190.10

are not included in 10 CFR Part 100.)

function only under meteorologicalThe exhausta HEPA filter bank and a second HEPA filter bank.

Specification limit (45,000 pCi/sec)

dispersion

100 times higher than the annual

an individual at the site boundary would be 0.3 mrem and that the beta skin dose would be 25 mrem.

atmosphere.

The major components of this systemeach purge air supply duct,

The slow purge method evaluated in Section 6.2.2 was based upon not exceeding the existing Appendix 6 Technicala total of 850 curies would be released.

parameter (X/Q) used for this accident scenario was 6.8 X 10-4 sec/ma which isaverage value.

two isolation valves in

Additionally,

limit the maximum beta skin dose rate to 3 mrem/hr,

6.2.3.2

sincelimits which normally accomplish this would have to be waived, as discussed above.

The reactor building purge system is capable of purging the building at flow rates of 5,000-50,000 cfm.

Occupational

Exposure

The occupational exposure anticipated from the fast purge scenario is approximately the same as for the slow
.purge scenario as discussed in Section 6.2.2.2.

Actualpurge rates authorized during any time interval would be dependent on meteorological conditions and reactor
building concentrations.

Like the hydrogen control subsystem,

atmosphere through a filter system and discharge it

The advantage of using the reactor building purge system inthat, given the required favorable meteorology,itEnvironmental Impact

The fast purge environmental impact would be approximately the same as for the slow purge as discussed inconjunction with the hydrogen control subsystem is

Section 6.2.2.3.

could decontaminate the reactor building atmosphere in fivedays of actual purging over a total elapsed time as short as approximately 14 days.
time frame associated with heightened psychological6.2.3,3

this system would remove the reactor building

through the 160-foot plant vent. stack to the environment.

Accordingly, the calendar

For the fast purge during the spring season (March-May)

stress during the conduct.of the purge would be minimized.

there

is a fair likelihood of being able

toexpeditiously release and maintain sufficiently low doses to the public in accordance with the criteria
6.2.3.1

discussed in Section 6.2.3.1.

System Description and Operation

The fast purge alternative would use the hydrogen control subsystem described inwith the reactor building purge system.

During operation xf the system,

systems andreleased via the Unit 2 plant vent stack,operatedfrom the Unit 2 control

room.

However,This purge system isbecause of modifications to the system 'to allow for flow control,

auxiliary operator would be stationed in the auxiliary building to control the purge flow rate.

months (June-October),Thus,

we estimate,based on historical

March-May)for the fast purge during the summer

conditions, that this alternative would require approximately two calendar months togiven the June thru October meteorological conditions,both the fast purge and slow purge are essentially equivalent.

radioactive gases purged from the reactor

160 feet above grade level.

data which show a small probability ofcomplete.

These units can be operated

building would be diluted with exhaust air from the auxiliary and fuel handling building ventilation
which isHowever,and fallfavorable meteorological

The reactor building purge system consists of two air-moving units,each of which has a flow rate that can be varied from 5,000 to 25,000 cfm.
separately or simultaneously.

Section 6.2.1 in conjunction

We estimate that favorable meteorology during these months may permit the fast

purge option to be accomplished within a 2-calendar week period.

is nearly over,the calendar time frame necessary for'As the period of favorable meteorology (i.e.,the staff considers the fast purge to be a less desirable alternative for thefollowing reasons:an(1)

The auxiliary

The advantage of the fast purge,

namely a lessening of potential psychologicalstressfor area residents,

would be lost during the summer months when total elapsed time required for both fast and slow purge alter-

operator would have communication ties with the control room and would be stationed in a low-radiation area.

natives are essentially the same.

C-16

am

w n
-

t

6-9
6-8
6.2.4.3(2)

Constructing a i00A-Foot Stack

Reactor building purging should not be delayed past the sumner and fall months to allow for better wintermeteorological conditions for those reasonselaborated in Section

5.0.

The staff has evaluated the dose reduction benefit resultin

Accident Analysis

6.2.3.4

The accident analysis described in

fIrom the construction of a 5050-foot stack.

A 5000-foot stack would assure that releases are unhindered from the effects of all vasite
structures.
technology for Constructing a stack this height is well established.

The

Section 6.2.2.4 would apply to this alternative.
A stack 1000 feet high would require,at a minimum, a 60-foot diameter base.
Construction of a foundation thissize would require not less than three months and construction of the remainderof the stack would require
aporoximately six months. , Additional design, engineering, construction, and testingtime required to connect
the stack with the existing purge system and ensure proper operation would add two to
three months to the installation schedule.
Therefore, the staff estimates that a minimum of 11 months would be required to construct
andmake functional a new 1000-foot stack.

Elevated Release Points

6.2.4
6.2.4.1

Introduction

Stacks are normally designed to assure that effluent exit velocities will give maximum rise to releases andeliminate the wake-cavity effects of adjacent structures.

Factors affecting meteorologicaldispersion of stack

effluents include the height and position of nearby structures and the layout of local terrain.
plant vent stack is 160 feet above grade,with an exit diameter of 9 feet.

reduction offered by increasing stack height,

The existing

In order to evaluate the dose

6.2.4.3.1

Occupational

Exposure

the staff has evaluated the alternatives of raising the existing

stack to 400 feet or construction of a new SlOb-foot stack.

Occupational exposures described in Section 6.2.2.2 would apply to this alternative.

6.2.4.2

6.2.4.3.2

6.2.4.2.1

Extending Stack Height to 400 Feet

Environmental Impact

Description

A temporary sheet metal extension with the same diameter as the existing stack,be used to support the extension with the aid of guy wires.

A stack release at 1000 feet would physically place radioactive effluents above the effects of thecooling tower
wake cavity and nearby terrain and would result in reducing offsite doses to the maximally exposed
individual bya factor of approximately 230 below the doses estimated for the fast or slow purge.

could be used to elevate the

The extension would be surrounded with scaffolding,existing plant stack to 400 feet above grade.

which would

The existing stack could also be elevatea to

400 feet by the addition of 10-foot sections of the carbon-steel pipes.

These sections would have the same

6.2.4.3.3

Accident Analysis

diameter as the existing stack.
The accident analysis described
Assuming that procurement of the necessary materials for extending the stack can be readily accomplished,staff estimates that the engineering design, procurement, construction,
would require a minimum of four to five months.
existing and new structures (e.g.,theand leak testing of either variation

6.2.5

This estimate does not consider the potential interferences ofprocessed water storage tanks) which may result in

6.2.5.1

in Section 6.2.2.4 would apply to this alternative.

Staff Evaluation of Union of Concerned Scientist Elevated Release Proposals
Introduction

further schedule delays.
In response to a request by the Governor of Pennsylvania,

6.2.4.2.2

the Union of Concerned Scientists (USf) evaluated theof the disposition of the reactor building atmosphere including the purging
alternative recommended by the NRC staff in its draft Environmental Assessment (NUREG-d662).
In their report to
the Governor (Ref. 3), the UCS reported that based on "current evidence of effectsof whole body radiation onhuman populations, ... no health effects would be anticipated as a result of the 'groundrelease' venting."
However, the UCS did not recommend purging, as proposed by the staff, because of thepotential psychologicalOccupational Exposure

health and safety consequences

Occupational exposures described in Section 6.2.2.2 would apply to this alternative.

6.2.4.2.3

Environmental Impact

stress UCS believes purging might induce.

As a result, the UCS proposed two alternative means of purging thereactor building which they believe will minimize potential psychological stress.
The first method proposes
purging by heating the effluent with an incinerator prior to releasing it through a 250-footrefractory lined
stack.
The second method proposes an elevateo release at 1000-2000 feet through a relatively light-weighttube
held aloft by a tethered ballon.

An increase in stack height to 400 ft would eliminate the effect of the reactor building wake cavity however,the stack-would remain within the wake cavity of the site cooling towers.
In addition, the plant location in ariver valley surrounded by higher elevation terrain diminish the effects of an elevated release point of
400 feet.
7.1)

An increase in the plant stack height (up to 400 ft) would reduce the already negligible (see Section

dose to the maximum exposed individual

by a factor of approximately eight below the doses estimated for the

fast or slow purge.

5.2.5.2
6.2.5.2.1

6.2.4.2.4

Hot Plume Release Through a 250-Foot Stack
Description

Accident Analysis

The accident

analysis described in

The staff has evaluated the Union of Concerned Scientists (USC) proposal to construct an incinerator(and stack)to heat the effluent purged from the reactor building.
Under ideal conditions, an incinerator of this typeshould be located as close as possible to the auxiliary building to minimize the engineeringand construction

Section 6.2.2.4 wouid apply to this alternative.

C-17

6-11
6-10
This potential site is
UCS "rough estimates" place the construc-

effort necessary to interface with the reactor building purge system.
tion time for an incinerator facility at from seven to nine months.
requirements for design, engineering, procurement of material,

This time estimate does not include timeand pre-operational testing.

a considerable distance from the auxiliary building and the reactor building purge system
The large distance would magnify the engineering and construction effort

with which it would have to interface.

involved, and would ultimately impact the schedule for system availability.

The staff estimates

A detailed design and layout of theinterconnecting piping between the auxiliary building and the launch site would have to be performed.

for these required efforts would add at least two months to the overall construction effort, resulting in aminimum schedule of nine months for system availability.

The piping would have to be buried (at least in some locations)solid radwaste shipments,

Occupational Exposure

6.2.5.2.2

in Section 6.2.2.2 would apply to this alternative.

Environmental

in order not to restrict normal traffic (e.g.,

about the site.

The piping would require leak testing

The need for booster pumps would have to be

The staff has also consulted with the Department of Energy's

in a detailed engineering evaluation.

(DOE) Ames Laboratory concerning the feasibility of the UCS balloon proposal.

Impacttube behavior.

In their judgment,

the first

500

in determining what effect wind shear and air turbulence will have on fabric

to 1000 feet of elevation crucial
6.2.5.2.3

etc.)following welding to ensure that no gas bypass pathways exist.
determined

Occupational exposures described

concrete truck deliveries,

Testing is recommended.

The staff concurs with this observation.

Thus,

a test of the integrityof the reinforced fabric tube (b-foot diameter) under different wind shear and air turbulence conditions would
Staff evaluations show that dose reductions can be, achieved ifheat isthe effluents to raise above the wake cavity of the cooling towers.

added in sufficient quantities to allow

The staff has determined that theschedule required to accomplish these actions and demonstrate system operability is longer than the timetablereducing offsite doses to the maximally exposed individual by a factor of appro-

foot stack would result in

The staff envisions these tasks as a major design effort.

be required.

The release of a heated plume from a 250-

estimated to the UCS for system availability.

ximately 30 below the doses estimated for the fast or low purge.
The UCS stated that a timetable for a tethered balloon system was "somewhat difficult to estimate" but projected
6.2.5.2.4

Accident Analysis

a schedule of four to seven months.

This schedule isMile Island for system implementation and successful
The impact of an accident

involving this alternative would result in a total-body dose which is approximately

five times greater than the slow purge accident dose discussed in

Section 6.2.2.4.

represent a small fraction of 10 CFR Part 100 accident-dose limits (Ref.

based on the availability of a suitable location on Threecompletion of feasibility tests.

Based on the remotelocation of suitable land area from the auxiliary building, the staff believes that the UCS has underestimated

These doses would still

the engineering and construction effort required to maje this technique workable.

18).

The staff estimates that thiseffort would require from 7 to 10 months to make the tethered balloon system operable.

The staff does notbelieve that postponing decontamination of the reactor building atmosphere for this period of time is acceptable
The Tethered Balloon/Tube Release at 2000 Feet

6.2.5.3
6.2.5.3.1-for the reasons.discussed

inSection 5.0.

Description
6.2.5.3.2

Occupational Exposure

The staff, has evaluated the UCS proposal to purge the reactor building atmosphere through a reinforced fabrictube held aloft at 2000 feet above Three Mile Island by a tethered balloon (Alsosee Section 9.2.5).

As stated

Providedadequate controls are established to isolate or bury the required interconnecting piping,by the UCS, this technique is unique and untried and would require further study to determine its feasibility.

In general,

this alternative.

6.2.5.3.3

the staff finds the LES proposal,

while not without problems,

technically workable and probably

Environmental

Impact•An elevated release at 2000 feet would physically place radioactive effluents above the effects of the coolingcapable of*being implemented within a year from the time the decision is made to use it.

tower wake cavity and nearby terrain and would result in reducing offsite doses to the maximum exposed
individual by a factor of approximately

The major problem with the UCS proposal is that, at present, there is no existing area on Three Mile Island
which is suitable for launching the tethered balloon and its attached 2000-foot fabric tube.

However,theimpact of this highly visible alternative on nearby residents.

The UCS has stated

The staff has examined Three Mile Island for potential sites of sufficient size to implement

6.2.5.3.4

Accident Analysis

the UCS

proposal.

The island is

300 below the doses estimated for the fast or slowpurge.

staff would haveto assess the psychologicalthat their proposal would require unobstructed ground and air space approximately 2000 feet long by 200 feetwide.

the occupa-in Section 6.2.2.2 would apply to this alternative.

the UCS stated that they did not know if suitable space was available on Three Mile Island to

In addition,
implementtional exposuresdescribed

The accident analysis described in Section 6.2.5.2.4 would apply to this alternative.
approximately 11,000 feel inlength by 1,700 feet in width.

is occupied by Three Mile Island Nuclear Station Units 1 and 2.
open area, a fairly large wooded area,

The northern one-third of the island

6.2.6

Summary

The southern part of the island contains someand a shallow basin area that is prone to flooding.

most open space is south of theUnit 2 cooling towers and includes an existing parking lot.
the open space to he approximately 200 feet or more wide and 1500 feet long.

The area with the

The staff has evalsuated six alternative methods for purging the contaminated reactor building atmosphere to the-

The staff estimatesenvironment.

Some trees in the wooded area ofThose methods include (1)a slow purge using the existing hydrogen control subsystem with releases

from the unmodified 160-foot plant vent stack,the island would have to be removed to enlarge the area.

(2)

a fast purge using the existing hydrogen control subsystem

and reactor building purge system with releases from the 160-footplant vent stack, (3)an elevated purge using

the existing hydrogen control subsystem and reactor building purge system with releases from the plant vent
stack elevated to 400 feet; (4)C-18

an elevated purge using .the reactor building purge system with releases

6-12

from a new 0000-foot. stack,(5)

a not plume release using the reactor building purge system and a new incinerator

and 250-foot stack (a UCS proposal),and (6) an elevated purge using the reactor building purge system and areinforced fabric tube held aloft at 2000 feet by a tethered balloon (a UCS proposal).

am0m

All six purge alternatives are similar in some respects.

All the proposed alternatives would result in upproximately the same occupational exposure and the consequences of a postulated accidental release are also roughly
equivalent.
All the alternatives are capable of being implemented in accordance with the requirements of 10 CFRPart 20 (Ref.

19),

the dose design objectives of 10 CFR Part 50, Appendix

ments of 40 CFR 190.10 (Ref.
alternatives

However,I, (Ref 15), and the applicable renvireNo health effects would be anticipated from implementing any of the six purge

12).

(see Section 7.1).

'hthere are significant differences

essentially be

implemented immediately

among these alternatives.

The slow purge and fast purge could(except for meteorological constraints for the fast purge).

m

The remaining

four alternatives would require modifications to plant systems and structures resulting in estimated schedules
for system availability ranging from a minimum of four to five months (stack modified to 400 feet) to as long as
11 months (a new 1000-foot stack).
Another potential difference associated with the various purge alternatives
isthe potential psychological impact that each might have.
In fact, the UCS proposed their variations of thepurge alternative not because of concern over health effects (none are anticipated), but as a means of reducing

2

potential psychological9

stress.

the UCS proposals would succeed
could even augment stress,

Because of inherent and uncertain delays,
in alleviating psychologicaldepending on public perception.

stress.

a'

the NRC staff does not believe thatOn the contrary,

the tethered balloor.

A tethered balloon would be easily visible to the

nearby residents and would be an attraction of sorts that may create as much stress as it
alleviate.

isintended toC

The NRC staff supports the slow purge alternative
atmosphere,

as the best means of decontaminating

thereby expediting the continued cleanup of the plant in a safe manner.

best means of alleviating

psychologicalstess

the reactor building

In the staff's opinion,

:5
the

r

in the vicinity around the plant is to complete the overall

recovery effort safely and quickly.
6.3
6.3.1

Selectine Absorption Snstem
Introduction0o_.
The selective absorption system evaluated by the NRC staff would operate by withdrawing gases from the reactor
building, separating essentially all the krypton from the gases,Q•

and returning the gases to the reactor building.

Krypton is separated from other gases in a combination absorption stripping column which operates at greaterthan atmospheric pressure and uses a liquid fluorocarbon as a solvent.
The separated and concentrated krypton
may then be stored onsite or transported offsite for disposal.
Alternatively, krypton gas in containers could
be transported to and released at some remote site.
6.3.2

System Description and Operation

A fluorocarbon absorption process

for removing noble gas fission products .(krypton and xenon),other radioactive contaminants from gaseous waste,
Ridge National Laboratory (ORNL).
develop the processsystem,carbon-14,

andhas been under development since 1967 by Union Carbide at Oak

Following their initial work to obtain solvent chemistry information and to

ORNILpersonnel constructed a small pilot plant.

This pilot plant utilizes a single
absorption column process with a maximum gas flow rate of 15.0 scfm and has been in operation since 1978.
Actual removal efficiencies greater than 99.9% for krypton have been obtained.
However, these efficiencies wereobtained for influent concentrationt of noble gases substantially higher than those existing in the reactor
building.

Based on the results of the developmental and pilot plant test programs,

U-x

ORNL personnel are optimisticthat their absorption process could be used at Three Mile Island (TMI).

C-19

6-15

The existing pilot plant, however, is not believed, by either the NRC staff or ORNL personnel, to be a practicalsystem for decontaminating the TMI reactor building atmosphere.
This small-scale laboratory system was notdesigned to be portable and is

not readily adaptable for use at TMI.

Approximately 50% of the hardware,

includingrefrigeration and reversing heat exchanger systems, which would be needed at TMI; are not presently incorporated
in the ORNL model.

•

however, the existing pilot plant is

nate the atmosphere to the maxmimum permissible Kr-85 concentration

-.40

• "•

Most importantly,

unacceptable for use in decontaminating

the atmosphere in the reactor building because of this system's very small flow capacity. At 15 scfm it would
require nearly three years of continuous processing (i.e., no downtime for repairs and maintenance) to decontami-

o
o0

(1 x

3

I0-5 pCi/cns ) for workers as required

byhO CFR 20 (Ref.19).

j

A larger selective absorption system, with the capability to process approximately 150-200 scfm,

Z>Z

passing throughfromof thethan 99%of krypton
remove.....
to effectively
would
be expectedevaluatedby the NRC
staff.
Althougha selective
absorption
systemthispr.......str.....
size has never Afterbeen constructed,
it

has also been

Krypton would be removed from the column inthe column, the gas stream would flow back to the reactor building.
a separate flow stream and transferred to pressurized containers for long-term (100 years) storage.
The krypton

MdC)

removal may be accomplished by either a bleed-and-feed process or by continuous operation.
process 150-200 scfm,

if operated continuously for about twormonths,

reactor building atmosphere to less than 0.1% of its current
23,000,000 ft

3

of gas (11.5 reactor-building

A system designed towould reduce the amount of Kr-85 in theinventory.

We estimatethat processing about

volumes) would be required to reduce the krypton level in thereactor-building gases to the maximum permissible concentration of Kr-85.

This would require approximately

three months of continuous processing.
The absorption system isbased on the property of a fluorocarbon,

to selectively absorb noble gases.

porting equipment, as shown in Figure 6.3-1.
midified,m

Minto

namely dichlorodifluoromethane,Contaminated gases are withdrawn from the reactor building,filtered, compressed to approximately

125 psig,

and cooled to near -30lF.

525 psig.

M r-

The reboiler at the bottom of the column would operate at l04aF and

The solvent from which the Kr-OS has been removed would be cooled to - 3 0 oF before it

back to the top of the column.
the top of the column.
-n M

The decontaminated gas would then leave

Decontaminated gases may contain 5 to 10% Freon 12, and would,

through a turboexpander and a molecular'sieve.bed>thenwould be pumped

Irate quantities of water and iodine may be removed from this solvent stream bya molecular sieve and/or silver-impregnated zeolite prior to recycling.

S00•(a filter) to recover solvent.

be recycled into the reactor building until the Kr-85 concentration

therefore,be passed

The decontaminated gas would

reached allowable limits.

The concentrated krypton waste gas would be compressed and placed in high pressure cylinders
0

dehu-

The gas would then be fed

the absorption section of the combination column and contacted countercurrently with the downflowing liquidfreon solvent.
The solvent containing the dissolved Kr-85 would subsequently flow into the intermediate andfinal stripper sections of the column.

0or Freon 12,

The process has been integrated into a single combination column with sup-for storage.

The

cumulative waste gas collected from processing the contents of the reactor building could be stored at 2000 psig
3
in a few standard gas cylinders. The internal volume of one standard gas cylinder is 1.54 feet . The krypton

3

Z -n

activity in a cylinder will necessitate radiation shielding (approximately one inch of lead) and some cooling..
Alternatively, the krypton gas could be stored at lower pressure (and with lower risk of leakage) in a larger
number of these cylinders.

G) Mof<C

krypton in

...4

,,.,4

Srn

•

xz

Onsite storage is discussed in Section 6.8 and transportation and, burial or releasea remote location are discussed in Section 6.9.

Members of the NRC staff with extensive nuclear construction experience estimate that it

would require at leastb16
months* to make a scaled up selective absorption system, capable of processing 150-200 scfm,

iZ

into operation'ONipersonnel have estimated that a minimum of 13 months would be required on a "best effort" schedule for making
a 1bO-scfm system operational at TMI. This estimate includes no contingencies and several simplifying assumptions(Ref. 23).
A more optimistic schedule o0 6 months has also been estimated by a Congressional staff aide (See
Section 9.0).

C-20

-

¶S

M-II,1iMF-MJ

6-16

6-17

This estimate is based on such considerations as personnel mobilization and organization (including

at TMI.

engineers and construction workers),

system design, component procurement,

system fabrication,

effort" estimate,

22)

for the system would be the minimum required

some necessary equipment may be available "off the shelf" assumes,
other equipment will take approximately 3-4 months.
will be necessary to determine where it

sary prior to operation,

and whether it

for quality assurance,isfunctional,

to the confinement

Ifthat container ruptured,a release of the krypton

in a total-body gamma dose at the site boundary of 20 mrem and a beta skin dose of 1700 mrem,that procurement of

can components be connected

Numerous

the staff has asummed that all

structure and subsequent releases to the environment over a two-hour period would result

X/Q of 6.8 x 10-4 sec/m3 .

This calculated total

10 CFR Part 000 (Ref.

There are no skin dose limits in 00 CFR Part 100.

15).

what maintenance will be neces-is compatible with the system design (i.e.,

could be stored onsite in pressurized containers.

For a bounding calculation,

57,000 Curies of krypton are stored in one container.

seismic

It should be noted that even where equipment is available

is located, whether it

krypton gas,container configurations can be designed.

This estimate, although recognizing thatbased on experience,Gas Storage

The process product, concentrated

for radwaste systems built at nuclear

These criteria establish the minimum acceptable requirements

design, component quality classification, and preoperational testing..

it

As a "bestthis schedule assumes that competitive bidding for equipment would not be used and that thedesign criteria (Ref.
power facilities.

(2)

site coordination(including construction of a building to house the system), and system testing prior to operation.

assuming abody dose is a small fraction of the limits set forth inSummary

based on capacity and available connections).
The selectiye absorption process has been studied and has had extensive development on a small scale.
6.3.3

Occupational Exposure

scale operation has not been proven, but all

rily to remove krypton from the TMI reactor building atmosphere.
The occupationalradiation exposure at the Oak Ridge pilot plant has been negligible.

It is anticipatedsystem operation and maintenance is the volume of krypton contained within the process at any one time.

be completely

field.

For major maintenance activities,

removed from the absorber system to further reduce exposure.

decision were made to store the krypton onsite,
however,itwould be unrealistic

krypton can

If

As discussed inThis would result in

Section 6.9,

from a decision to transfer the gas for offnite disposal (i.e.,

operation phases of such a project.

an additional estimatedthe occupational exposure resulting

Environmental

although some leakage is expected.

processing should be very low.

boses to the public would be neglibible since only minimal

the system itself is

expected.

The estimated occupational exposure resulting from extended onsite storage is

90-170 person-rem.

(See Section 6.8.)

leakage of Kr-85 fromSee Section 6.9 for a discussion of transportation and offsite disposal.

6.4

Charcoal

6.4.1

Introduction

Adsorption Systems

a few cubic centimeters would be released each time gas cylinders are changed.

Subsequent long-term
however due to possible

corrosion of the storage containers with time the potential

for accidental

adsorber system.

Thissystem is similar to those used in boiling water reactor (9WR) off-gas treatment systems which are routinelyIn

storage of the pressurized containers on site will not affect the environment directly;

used to retain noble gases for decay prior to their release to the environment.
ambient temperature and refrigerated charcoal adsorber systems.

The staff evaluated both theBoth systems would require extremely

large

volumes of charcoal; the ambient system would require 34,000 tons and the refrigerated system 12,000 tons.

release would remain while the Kr-8O

charcoal systems when operating normally would have no releases associated with them; however,stored on site (see Section 6.8).

6.3.5

testing, or

the occupational exposure due to

The tollowing discussion presents the NRC staff evaluation of a nonregenerative charcoal

Krypton is removed from the reactor building and stored inpressurized containers with only minimal release to the environment,isBased on prior operating experience,

depending on theconstruction,

ImpactSelective absorption has zero release as a goal.

addition,procurement,

Worst case accident scenarios do not result in threats to public health and safety.

handling and packaging of theogas for transport)

would result in an occupational exposure of 8-24 person-rhmi.

6.3.4

but a longer time may be needed,

number and complexity of problems that could arise during the design,

to assume that the storage system would not require some maintenance and surveil-

exposure of 90-170 person-rems.

The NRC staff's "best effort" estimated time required to construct a scaled-up(1h0-200 scfm) absorption system at TMI is at least 16 months,anot portable

The pilot plant, because of its

would require more than three years to process the building atmosphere to the maximum

permissible concentration of Kr-85.

the storage system would be designed for remote operation;

lance during the approximately 100 years while the Kr-85 decays.
occupational

small flow capacity,

ShieldingWe estimate that an occupational

exposure of about 25-50 person-rem would result from operation of this system including filter renovai.

The existing pilot plant at ORNL isand does not incorporate all of the components which would be needed at TMI.

The feature that sets personnel exposure during

the exposure would increase slightly with a larger system.
would be provided for components having a high-radiation

that

Large-

signs indicate that the absorption system would perform satisfacto-

operational

occurrences minor releases can be expected.

Bothduring anticipatedSince noble gases do not react chemically with charcoal,

long-term surveillance-would be required.

Accident Analysis

For the purpose of analyzing potential accidents,

A regenerative charcoal

the absorption process system and pressurized storage containers

adsorber system was proposed inthis proposal is not feasible and it

will be reviewed separately.

isa public comment.

not recommended.

The NRC staff has determined that

A discussion of this proposal is contained in

Section 9.5.16.
(1)

Absorption

Process

6.4.2

The maximum curie content in the absorber system (12-inch column)

Curies. >Process components will be housed in a confinement structure.

Ambient Charcoal

Automatically activated isolation

detected.

of krypton (200 Curies)
period,System.

The transfer of radioactive airborne activity fromthe reactor building to the ambient

charcoal system would follow the same flow-path describedvalves would be used to separate the absorber from the reactor building and the gas storage system whenevera malfunction is

System Description and Operation

at any one time would not exceed 200
for the purge system.

from the reactor building atmosphere will contain moisture.

Assuming an accident which results in a release of the entire process inventory

to humidity in excess of 3%, the charcoal

to the confinement structureand subsequently to the environment over a 2-hour

If

The radioactive airborne activity

the charcoal in the adsorber system is exposed

would lose its capacity to adsorb krypton.

The major fraction of the

moisture would be removed as the airborne activity passed through the cooler condenser.

the resulting total-body gamma dose at the site boundary would be 0.1 mrem and a beta skin dose of

6 mrem assuming a X/Q of 6.8 x 10-4 sec/ma.

C-21

Additional

moisture6-17

DECONTA
VENT GA.

Gas Storage(2)

The process product,

concentrated krypton gas,container configurations can be designed.

could be stored onsite in pressurized containers.

For a bounding calculation,

57,000 Curies of krypton are stored in one container.

Numerous

the staff has asummed that all

If that container ruptured, a release of the krypton

to the confinement structure and subsequent releases to the environment over a two-hour period would resultin a total-body gamma dose at the site boundary of 20 mrem and a beta skin dose of 1700 mrem,
X/Q of 6.8 x 10-4 sec/m3 .
10 CFR Part

000 (Ref.

assuming aThis calculated total body dose is a small fraction of the limits set forth in05). There are no skin dose limits

in 10 CFR Part 100.

Summary

The selective absorption process has been studied and has had extensive
scale operation has not been proven,development on a small scale.

rily to remove krypton from the TMI reactor building atmosphere.

The existing pilot plant at ORNL is not portableand does not incorporate all of the components which would be needed at TMI.
small flow capacity,of Kr-85.

The NRC staff's "best effort" estimated time required to construct a scaled-upscfm) absorption system at TMI is at least 16 months,

but a longer time may be needed,

number and complexity of problems that could arise during the design,operation phases of such a project.
processing

should be very low.

the system itself is expected.
90-170 person-rem.

The pilot plant, because of its

would require more than three years to process the building atmosphere to the maximum

permissible concentration(150-200

Large-

but all signs indicate that the absorption system would perform satisfacto-

procurement,

Based on prior operating experience,

construction,

depending on thetesting, or

the occupational exposure due toloses to the public would be neglibible since only minimal leakage of Kr-8h fromThe estimated occupational exposure resulting from extended onsite storage is(See Section 6.8.)

See Section 6.9 for a discussion of transportation and offsite disposal.

Worst case accident scenarios do not result in

6.4

Charcoal Adsorption Systems

6.4.1

Introduction

k

VOLATICOMPO-

threats to public health and safety.

The following discussion presents the NRC staff evaluation of a nonregenerative charcoal adsorber system.

This

C

system is similar to those used in boiling water reactor (BWR)'off-gas treatment systems which are routinely
used to retain noble gases for decay prior to their release to the environment.
ambient temperature and refrigerated charcoal

adsorber systems.

Both systems would require extremely large

volumes of charcoal; the ambient system would require 34,000 tons and the refrigerated system 12,000 tons.
charcoalsystems when operating normally would have no releases associated with them; however,operational

occurrences minor releases can be expected.

LEGENDThe staff evaluated both the
Both-FLOWC(TC-TEMPERLC -LEVEL

during anticipatedSince noble gases do not react chemically with charcoal,FC•long-term surveillance would be required.

L

A regenerative charcoal adsorber system was proposed in a public comment.
The NRC staff has determined that
this proposal is not feasible and it is not recommended.
A discussion of this proposal is contained in

Pc
ccC-PRESSUF-COMPOSIR- REFRIGI

Section9.5.16.
6.4.2

System Description and Operation

Ambient Charcoal

System.

-The transfer of radioactive airborne activity from the reactor building to the ambient

charcoal system would follow the same flow-path described for the purge system.

The radioactive airborne activity

from the reactor building atmosphere will contain moisture.

the adsorber system is

If the charcoal in

to humidity in excess of 3%, the charcoal would lose its capacity to adsorb krypton.

exposedFigure 6.3-1

The major fraction of the

moisture would be removed as the airborne activity passed through the cooler condenser.

Additional moisture

C-22

C

- DIFFERE
CONTR

,PC

•

Schematic of the Combination Column

lI

IJ

WASTE GAS SLOWER AND
GAS DRYER COMPARTMENTS
THREE PLACESPLANCONVENTIONALBUILDING,,,.,CONSTRUCTIONinNOTES:
1. TANKS AND PIPING ARE ASMESECTION III,DIVISION 1.
CLASS 3.
2. BUILDING.TANK SUPPORTS,
AND SYSTEM COMPONENTS ARE
SEISMIC CLASS 1.

_OK

.

150'
VIEWA-A

Figure 6.4-2

Conceptual Layout - Charcoal Storage Arrangement
L)

LOCAL ISOLATION VALVES.
INLETAND OUTLET. FOR
USE DURING CHARCOAL FILLINGCHARCOAL STORAGETANKS.
450 TOTAL. RM SERIES* 34,000 TONS CHARCOALTANKS ARE 12' 0.D.
30' HIGH
s0,1 I0t POUND TANK* METALWEIGHT

2nd
TANK

.NK

-

-

-

IN

'5
FROM CONTAINMENTHEPA AND CHARCOAL FILTERSGAS DRYERS- - -----------------TOBUILDINGREACTOR
VENT ROOF

Figure 6.4-1

Flow Diagram for Purge Using Charcoal Adsorption System

; 6-23

Refrigerated Adsorber Systew.

This system would require 150 tanks of charcoal.

The radioactivity

offsite disposal.

in eachvolume,succeeding tank. would decrease as the activity inthe reactor building decreased.

activity would contain approximately 4300 Curies.

If the same accident assumptions are used for this evaluation

as were used above,

the resulting doses would be increased by a factor of 3.

The tank with the highest

Therefore,

This alternative is discussed in Section 6.9.

low-pressure storage system.

For example,

At the other end of the spectrum is a large-

if a container the size of the existing reactor building wereconstructed, the gas could be stored at 170 psig.

a beta skin dose of 124
The Generalmrem and a total body dose gamma of 1.5 mrem could be expected.

Public Utilities Corporation (GPU) contracted with MPR Associates

means for storing the compressed gas (Oel.

21).

would be stored at 340 psig in 36-inch outside-diameter

Summary

volume would be required,to investigate

the most practical

MPR recommended a low-pressure storage system in which the gas
standard-wall pipes.

One million cubic feet of storage

which would be equivalent to 150,000 linear feet, or 20 miles of pipe.

The proposed

It is possible to remove the Kr-O5 from the reactor building with either room-temperature or refrigerated charcoal

pipe storage complex is divided into two major sections (high activity and low activity) to minimize shielding

adsorber systems. The primary advantages of the room-temperature charcoal

requirements.

operation and the capacity to accommodate

adsorber system are simplicity of

extremely radioactive gas mixtures.

for a room-temperature charcoal adsorber system is the large volume of charcoal it
charcoal

adsorber system would reduce the volume of charcoal

volume, an increase in equipment complexity would result.
building atmosphere is Kr-85,

requires.

Since the primary form of radioactivity

adsorber to retain the Kr-O5.

for those reasons discussed

in 2-4 years.

activity piping,in the reactor-

high.

the charcoal
The NRCthe filters,

dryers,and gas compressors,

The building to house the high-would be 260 feet long,

90 feet wide, and 30 feet

Six inches of concrete shielding around the high-activity piping would be required.

The lo-actiuity

pipe section would contain 80% of the total piping and 10% of the Kr-O5.

The building for housing the low-

activity piping would be 220 feet long,

It would require no shielding.

160 feet wide, and 60 feet high.

This lead time is unacceptable
6.5.3

in Section 5.0.

Occupational Exposure

No significant amount of radiation exposure should be incurred by plant personnel during operation of the gas

Gas Compression System

6.5.1

Low-activity pipe units would be placed to the outside of thestorage area to act as a shield for the highest activity units in the center.

Loaded charcoal beds would then have tosystem could be made operational

The high-activity piping section would include 20% of the piping and would contain 90% of the

The high-activity section would be segregated into five units to limit Kr-85 releases in the event ofleakage and to optimize inherent shielding.

A refrigerated

to gain a reduction in charcoal

storage approximately 100 years to permit radioactive decay of Kr-85 to insignificant levels.

staff has estimated that a charcoal

6.5

However,a noble gas fission product that does not ordinarily react chemically,

adsorber would function as a physicalremain inrequired.

Kr-85.

However,, the major disadvantage

compression system.

Introduction

gas processing.

All system components are relatively simple and should require minimal maintenanceShould maintenance be required,

The gas compression system involves drawing off the reactor building atmosphere into suitable pressurized storage

exposure during repairs.

containers so that the entire inventory of Or-85, remains in pressurized storage for approximately 100 years tooperation and maintenance.

permit radioactive decay to insignificant levels.

This system would reduce the Kr,85 concentration

reactor building by feed-and-bleed operation to the maximum permissible concentration

duringmost components could be isolated and purged to decrease radiation

The staff estimates an occupational exposure of approximately six person-rims duringin theof I x 10-5 pCi/cc.

Periodic maintenance of the long-term storage system isToa potential source of occupational exposure.

Although a

accomplish this, approximately 23 million cubic feet (11.5 reactor-building volumes) would have to be processed

system can be designedby the system.

would not be necessary during the approximtely 100 years of storage required.

The staff estimates that surveil-

lance and maintenance during long-term storage would result in

exposure of approximately 42

operation,itwould be unrealistic to assume that some maintenancean occupational

person-rems.

The staff has received a number of letters from the public suggesting alternatives to the onsite purging of the
Kr-85 gas.

for maintenance-freeIncluded were suggestions for compression and storage of Kr-85 and offsite shipment with subsequent

release at a remote site.

Transportation and offsite disposal of Kr-O5 are discussed

in Section 6.9.

6.5.4

Addi-

Environmental

Impacttionally, comments on gas compression alternatives are addressed in Section 9.0.
Krypton-O5 can be removed from the reactor building and stored in pressurized containers with minimal release to
6.3.2

the environment.

System Description and Operation

The gaseous contents of the reactor building would be transferred to pressurized gas containers
storage.

The containers can be designed in various pressure/volume

The resulting doses to the public due to the anticipated minor releases would be insignificant.

Although subsequent long-term storage in pressurized containers onsite will not affect the environment directly,

for long-term

the potential

combinations to accommodate the reactor-

for accidental

releases will remain for over 100 years as the stored.Kr-85 decays7

building gases.
6.5.5
To reduce activity in the reactor building to maximum permissible concentrations,building volumes (23 million cubic feet) would be transferred to storage.
gas dryers,a charcoal adsorber,and valves.

Figure 6.5-1 provides a flow diagram of the system.

a HEPA filter, three gas compressors,compressed gas from the storage system.

and associated piping

analyzed since it

The compressed gas would remain stored on the

The raGiologicalconsequences of a failure in

The practical upper

therefore,

represent the most severe occurrences with respect to their potential

boundary.

Analyses were performed on accidental

An alternative to extended onsite storage would be to package the gas for

C-24

release of

the feed train were not'was assumed that the feed process would be isolated well before the accidental

approached a magnitude which would equal a release following a storage-system failure.

The minimum volume for

At this pressure, 80,000 standard gas bottles (1.54 cubic feet)the storage system would result if the gas were stored at the highest possible pressure.
would be needed to store the gas.

The gas compression process was analyzed for its radiological consequences following an accidental

The compressed gas train would include

storage containers,site for approximately 100 years to allow the Kr-85 to decay to insignificant levels.
pressure limit for gas storage is 2500 psig.

Accident Analysis

a total of 11.5 reactor

T

releasehe accidents analyzed

exposure potential

releases from several storage configurations.

at the site

6-24

segregated into four units, postulated unit failure with a subsequent
in a site boundary total-bodyAssuming the compressed gas storage system is0release of 14,250 Curies to the environment in a two-hour period would result

gamma dose of 5.0 mrem and a beta skin dose of 410 mrem assuming a conservative
total body gamma dose is a small fraction of the limit set forth in

X/Q of 6.8 x 10i4 sec/ma.

1ICFR Part bO0 (Ref.

Th>15); 1OCFR Part 100

ZZOX

does not include a limit for beta skin exposure.

1

ry
umga
The gas compression system offers several advantages.
system which could be operated
impact.

The gas compression system is essentiallya "zeroM.

release"to decontaminate the reactor-building atmosphere with insignificant environmental

The occupational exposure resulting from operation and long-term surneillanc.
of the system is estimated

0-

)l

-

5

u •

'm0
0
0

Cryogenic Processing Shstem

potential means of decontaminating the contaminated

i

0

L

Introduction

processing system.

;
05

reasonsdiscussedin SectionhO..

6.6,1

5

mhýz

The major disadvantages of the gas compression system is the entensive time required toto be 41 person-rems.
The NRC staff considers this time period unacceptable for thebuild and install the system (25 to 35 months).

6.6

z

-

m

oH

reactOr-building atmosphere is through the use of a cryogenic

The operating principle of the cryogenic processing system is the condensation of Kr-85 fromthe incoming air by direct contact with liquid nitrogen (boiling point,-195.RBC).

-

The liquefied Kr-85 would beallowed to concentrate and would then be vaporized and transferred to an ons;te storage facility for subsequent

membersof the2has bees recoommended
by various
or cryogenic
processes
disposition.Use of the liquefaction
public.

-____The NRC staff has evaluated the availability of an existing cryogenic processing system (CPS) at a comeercial
boiling water nuclear power plant to decontaminate the reactor-building atmosphere.

0

The cryogenic system has
0never been placed into operation and is being offered for sale by its current owner because of anticipated high

0

theis
to
would be required
new building
the erection
licensee,use bypurchaseforavailable
thehousesystemAlthoughthatofthea unit
wouldrequire.
of thecontinued
maintenancecosts
and theanddegreeoperatingsystem because of toe need to confine anticipated leakage from the CPS.

The building would be approximately 110qfeet longby 72 feetwide and uouldvaryin heigotfrom 20 feetto lb feet.
6.6.2

<I

System Description and Operation

If installed,

the cryogenic system would connect with the reactor building through the existing hydrogen-controlfnhecontaminated air from the reactor building would be transported to the cryogenic processing systemin the adjacent building after passing through the HEPA filters and charcoal adsorber of the hydrogen control
system.

S,7system.
fhe cryogenic processing system consists of three processing trains.
prefilter,

catalytic reconhiner,

afterrooler,

are supported by a hydrogen storage system,i

The major components of each train are theand cryogenic treatment subsystem.

The three processing trainsa liquid-nitrogen storage system, and a noble-gas storage system.

IA

flow diagram of the cryogenic processing system is shown in Figure 6.6-1.
The cryogenic processing system canprocess air from tne reactor building at a flow rate of approximately 225 scfm.
After passing through the HEPA
filters and charcual

adsorbers of the.hydrogen control system for removal of trace quantities of airborne radio-

active particulates,

the air from the reactor building uould be heated isnthe CPS preheater prior to injectionLA0

into the CPS catalytic recombiner for oxygen removal and corresponding volume reduction of the recombiner effluent.
T

IC

0

0
F T

he effluent gas from toe recombiner would then be cooled in a downstream afterconler and directed to the cryogenic

C-25

I

C-2E

treatment subsystem (CIS).
trace recombiner,

The major components of the CTS consist of two feed compressors,

an aftercooler,a condenser heat exchanger,
heater.

6-27

a separator,

three prepurifiers,a phase separator, a decay column,

a gas preheater,

judicious monitoring and rapid system isolation upon indication of an upset condition.
In any event, the staff
estimates that the environmental impact during normal operation of the CPS would be insignificant (i.e., lessaa cooldown heat exchanger; a removal column,

than 0.0b millrems beta skin dose and 0.0002 millirems total-body gamma dose, assuming a X/Q of 5 x 10-(A flow diagram of the cryogenic treatment subsystems isshown in Figure 6.6-2.)

6.6.5

The effluent gas from the CPS aftercooler would enter the suction side of the CTS feed compressors.

The feedgas ina downstream separator.

remaining moisture.

The gas would then enter the prepurifier for removal of carbon dioxide and any

to the environment over a two-hour period.

to collect ina poolbeta skin dose of 1700 milliremss,

xenon, and argon) would be removed by condensation from counterflowing
At periodic

at thebottom of the removal column.

intervals,

This failure assumes

Based on annual average meteorologicalconditions, the calculated

total-body gamma radiation exposure to a person at the site boundary would be 20 millirems, with a corresponding

The chilled gas would enter the removal column where the methane and noble gases

Kr-85 and stable krypton,liquid nitrogen

Moisture would be removed from the cooled

respectively.

system.

the rupture of all gas storage vessels and a corresponding breach.of the secondary storage containment structure.
Under these circumstances, the entire Kr-85 inventory of approximately 57,000 curies is assumed to be released

The purified gas would then enter the cooldown heat exchanger to reduce the gas temperature

to approximately -29GF.
(essentiallyand gas cooling,

sec/m3).

Accident Analysis

The CPS was analyzed for the hypothetical worst-case failure of the Kr-85 storage

compressors would transport the gas through the preheater, trace recombiner and aftercooler for gas heating,removal of trace quantities of oxygen,5a hydrocarbon conversion unit, and an ambient

assuming a X/Q of 6.8 x 10 -4 sec/m3.

small fraction of the limits set forth in 1OCFR Part 100 (Ref.

the condensed

15).

This calculated total-body dose isa

There are no skin dose limits in 10 CFRPart 100.

methane and noble gas pool would be vaporized and removed from the column via the CPS product compressor andcompressed into storage vessels for onsite storage at ambient temperatures.
The licensee estimates that it

onsite storage.

From consultations with construction engineers at Oak Ridge National
the staff estimates that it

See Section 6.8 for a discussion of

6.6.6

Air Products and Chemicals.

Inc.,and MITRE Corp. Systems

would take from 20 to 30 months to put the system into operation.
Laboratories and in the nuclear

industry,

The CPS discussed in the preceding section was chosen as a typical cryogenic system that is currently available.-would take a minimum of 20 months to get any CPS operational.

This system is designed by Linde Division of the Union Carbide Corporation.
which operates by essentially the same principle,

6.6.3

Occupational Exposure

also uses the basic two-step process,

Another currently available CPS,

is designed by Air Products and Chemicals,

which consists of hydrogen and oxygen recombination,

Inc.

This systemand then removal andconcentration of the radioactive gas by cryogenic distillation.
Of all the alternative systems considered for the decontamination of the reactor building atmosphere,
the most complex in that it
require a greater degree(85 psig)

the CPS is

consists of more and varied- components than the other systems and is expected toof maintenance during operation.

in addition,

so leaks must be considered as an anticipated operational occurrence.

occurred downstream of the CTS removal column,

Yet another CPS was described by the MITRE Corporation.

the system operates at positive pressureIfleakage from the systemthat leakage would contain highly concentrated Kr-85 (that is,least three orders of magnitude higher than in preceding portions of the system).

techniques,

Therefore,

also employ severalatthe exposure to

proposed project schedule totals 11 months,

alternatives.

The licensee estimates the exposure to workers due to processing,maintenance,and sampling) associated with the long-term storage of Kr-85.

does not agree with the licensee's

The staff's lower estimate

licensee has estimated.

The staff,

137

and two months for the startup,

debugging,system optimization, and removal of thethe schedule does not consider the need for a new building to house the system.
Section 6.6.2,

Thefabrication modifica-

The NRC staff,

believes this schedule to be an unrealistically short estimate.

The cryogenic system evaluated here is essentially the same as the other currently available CPS.

nhelicensee agrees that extra steps could be taken during design,

engineering,

tion.

and

the addition of a hydrogen supply to the recombiner in the Linde system to further avoid oxygen accumulaThe MITRE system, which includes an air-separation technique and a recycle to the reactor building, would

require additional fabrication,

they state that such changes would significantly extend

to 30-month period estimated for implementation of the CPS.

and more importantly,

may require proof-testing before finalization of a systemdesign.

The NRC staff believes that if ALARAconcepts

the initial engineering and design efforts for the facility,

the schedule would not be signifi-

The primary advantage of each CPS proposed is that the offsite environmental
system or from worst case accident scenarios are insignificant.
not without its disadvantages,

Environmental

A difference

noted iscantly extended.
6.6.4

which would allow nine months for procurement,

Sommarois based on the emphasis that would be placed on maintaining

construction stages to reduce worker exposure; however,the 20-However,based on the discussion in

inplant exposure ALARA and on the assumption that workers would spend less time in high-dose-rate areas than theare implemented in

and installation,

Kr-Oh.

and a process combination of

estimates of the frequency and dose rates that could be encounteredduring surveillance activities nor with licensee estimates that exposure to workers would be in the range ofto 255 person-rems.

tions,

feed,

and molecular sieve filter bed to remove the Kr-85.

90%) of this estimated exposure would occur because of surveillance activities (inservice

inspection of components,
however,and required

would be approximately 570 person-rems.

surveillance activities during long-term onsite storage of the Kr-8b,
Most (approximately

maintenance,

while using the same cryogenic

The proposal states that the system would

other unique features including a normal krypton makeup

air separation plant, krypton distillation column,

workers operating and maintaining the CPS is anticipated to be greater than that of any of the other treatment

This system proposal,

would include a closed recycle to the reactor building.

Impactinhowever.

First, design, construction, housing,

significant delays in the TMI cleanup effort.

a "zero-release" system.

During theto get any CPS operational.

estimated 2-1/2 months that would be required to process the reactor-building atmospshere, approximately 60
In addition to this, ancuries of Kr-85 would be discharged in the-purified gas effluent from the system.

we estimate that it

Second, based on prior experience,

likely to produce a relatively high occupational exposure.

would take a minimum of 20 months

operation and maintenance of each CPS would be

Finally,quantities of Kr-85 generated by each alternative would requireunspecified amount of Kr-85 would be discharged to the environment due to anticipated leakage from the system.
The staff believes that the CPS can be designed to minimize the environmental impact of uncontrolled leakage by

and testing the CPS would result

From NRC staff consultations with construction engineers at

Oak Ridge National Laboratory and in the nuclear industry,
The CPS, designed for a removal efficiency of 99.9% is not, therefore,

impacts either from operation of theSelection of any CPS as the best alternative isthe onsite storage of concentrated

long-term periodic surveillance and would" accordingly represent a continuing risk to workers on the site, as well as to the public.

C-?6

-

PURIFIEDGASTO REACTORBUILDINGROOF VENT
103SCFMINOTE:PREPURIFIERREGENERATIONCYCLESTEPS ARE:
STEP 1: REMOVEH20 AND CO FROMGAS
2

H2 RECYCLETO CATALYTIC
RECOMBINER

STEP 2: REMOVERESIDUALKR AND XE FROMPREPURIFIERCOLD BOXSTEP 3: REMOVEH20 a-d CO FROMPREPURIFIER2FROMCATALYTIC .
RECOMNINER(2 SCFMI

AIR
Figure 6.6-2

Flow Diagram of Cryogenic Treatment Subsystem(One of Three)(-3

Figure 6.6.1

Flow Diagram of Cryogenic Processing System

6-30

6.7

6-31

Combination Process and Purge Systems
These estimates for anticipated lead times for scaled-down cyrogenic processing and solvent absorption systems
or no redundancy (for increased reliability) in system comare based on the simplest designs and assume little

lntroduction

6.7.1

The staff has evaluated the feasibility of combining a krypton-recovery system (charcoal
compression, cryogenic processing,adsorption,

This combination method would be performed in two steps.

purge system).

First, a krypton-recovery system (theprimary system) would process and contain approximately 95% of the krypton

Then the remaining krypton (approximately

proposal

6.7.3

system requirements.

If

a 95% Kr-Oh removal efficiency

This advantage" results from smaller scale processing

this volume within approximately two months (comparable to slow purge time)This,require a flow capacity of 75-100 scfm.
flow or storage capacity (ifgas compression isfor such a method.

Occupational

Exposureand 6.6.3.

is desired with the primary system, approximately six

milliTon cubic feet of contaminated air will have to be processed before purging could proceed.
process

In order to
6.7.4

the primary system would

Environmental Impact

primary system used in combination with purging would require
The environmental

chosen as the primary system) approximately 25-33% of thedose impact associated with this alternative (assuming 5% of the reactor-building atmosphericpurged) would be approximately 1/95 (0.01) of the impact associated with the slow purge

inventory of Kr-8O is

capacity requirement for full-scale krypton-recovery systems described within this assessment.

alternative discussed in Section 6.2.
The staff has estimated a schedulethat could be operational

for making a combination alternative

operational.

20 months and 16 months,

6.7.5

in the least time are the cryogenic processing system (CPS) and the selective.absorp-.

respectively.

The charcoal-adsorption system and gas-compression

Section 7.1.)

Accident Analysis

The accident analyses described in Sections 6.3.5 and 6.6.5 would apply to tis alternative.

systems would require

Even scaled-down,

charcoal adsorption (e.g.,respectively.

3000 tons of.refrigerated charcoal) or gas compression

7 miles of 35-inch 00 pipe storage) systems represent relatively impractical

The resulting

total-body and beta skin dose to the maximum exposed individual are estimated to be 20 and 1700 mrem,a minimum lead time of 24 months for full-scale system availability and would represent a major construction(e.g.,

This would present negligible public health risk (SeeThe two primary systems

The staff estimates that the minimum times for a full-scale CPS or SAS to be operational aretion system (SAS).

effort.

for building and

The occupational exposures that could result from implementation of this alternative range from 115-255 person-rem(depending on the selection of either the SAS or CPS as the primary system) and are discussed in Sections 6.3.3

relative to the alternatives discussed inis the shortened time period,

which would be required to implement it.

Sections 6.3-6.6,

22)3,000 curies) would be purged to theenvironment through either the hydrogen control or reactor-building purge system (the secondary system).
The chief advantage of this alternative

regulatory requirements (Ref.

Thus the schedules for a combination method do not reflect allowances
for regulatory requirements which may be recommended as the result of a detailed staff review of a licensee

system quality and seismic classification.

(hydrogen control or reactor-building

from the reactor building.

These estimates also assume minimum standards inponents.

gas

or selective absorption) with one of the building-purge alternatives

alternatives compared to the

CPS and SAS.

Summarn

6.7.2

The staff's evaluation shows that the' "combined"

System Description

alternative method can reduce the lead time for system avail-the minimum time frame to make this method operational is one year
Section 5.0, represents an unacceptable delay in the decontamination of theability by as much as 25%. 'Nevertheless,In the NRC staff's estimation, a-scaled-down CPS would consist of one 75-scfm processing train (asthree trains in the full-scale system).

and,opposed toremain essentially as designed for the full-scale system (see Section 6.4.2).

The staff estimates,

as compared to full scale,by as much as 4 months.

Thus it

6.6

At least another month would be requiredconditions (see Section 6.2),

for purging,

All alternatives proposed for removing the Kr-85 gas, other than by reactor-building purge or disposal offsite(see Section 6.9), require provisions for a long-term storagefacility on site (for approximately 100 years toassuming summer/fall meteorologicalallow for radioactive decay).

to reduce the reactor building concentration of Kr-85 to below maximum permissible

concentrations ofKr-85 (that is,

The existing technology for storing Kr-85 is limited.

The full-scale SAS described in Section 6.3 would require the capability of processing several hundred standard

to 100 scfm.
cold trap,

Thus,

air, whereas,

the scaled-down

the scaled-down system could consist of a single train and feed components (dryer,

full-scale system.
as four months.

a common disposal method at the commercial low-level waste facilities, the NRC
staff is opposed to burial of any radioactive waste at Three Mile Island because of the potential for subsequentThus onsite gas storage in an-engineered facility remains as the only practicalrelease to the environment.
Although shallow land burial isbuilding requirements would be smaller than needed for the

The staff estimates that the lead time for the small-scale SAS might be reduced by as muchThus itwould stilltake a minimum of 12 months to get a small-scale SAS operational,

storagecompressor,

The requirements for the noble gas

by several months of system operation and at least one month for subsequent reactor-building

Table 6.8-1 provides an assessment of different

techniques.

SAS would be required to process from 75

and molecular sieve) and a lower flow capacity absorption column.

storage system would remain unchanged but the overall

See Section 6.9 for a detailed discussion of the trans-

portation and offsite disposal of radioactive gases.

less than 1 x 10-s PCi/cc).

cubic feet per minute of reactor-building

Onsite Long-Term Storage of Krypton-85

would still take approximately 16 months tomake a small-scale CPS operational and an additional two months to process the first six million cubic feet ofcontaminated air.

atmosphere.

based on theconstruction of a small building for a CPS with one processing train, that the lead time for the CPS might be
reduced,for the reasons outlined inreactor-building

The remainder of the CPS, including the noble gas storage system, would

For example, container corrosion is aeven though-this type of storage has not been perfected.
Also,
major problem that can be caused by collected gas impurities such as oxygen or nitrogen oxide, and water.
The long-term corrosion effects ofrubidium, the decay product of Kr-8S, may combine with oxygen to form Rb20.
alternative,

followed

purging.

Rb2 O in pressurized storage containers of Kr-85 are not known.

Thus further study and staff evaluation would benecessary if a Kr-O5 disposal method were chosen that required long-term storage.

C-28

6-33

6.9

, .1 , 1.

Transportation and Offsite Disposal

6.9.1

o

Discussion

So
The implementation of the Cryogenic Processing System alternative,

Z

Selective Absorption Process System alter-

native, or Gas Compression System alternative (using high pressure standard gas cylinders)contained inventories (57,000 Ci)

the hal-f-life ofj 10 2years for Kr-8h,
insignifJiant levels.

woud result inof Kr-85 which would be stored onsite to permit radioactiveitwould take approximately

d00years

decay.

Based onfor the krypton to decay to

An alternative approach to extended storaqý of the gas at Tel would be to transfer thegas to DOI and NRC approved containers for transportation and offsite disposal.
The staff has considered several alternatives of disposing of the Kr-8h at an offsite location.
include transport to a commercial

C.

<a

•.

CD

•

(e.g.,a desert)

6.7.2

Environmental

low level waste burial

shipments of waste from TMI Unit 2,

grounds currently

inFederally approved containers.

(up

to 1.5 atoospheres

restrictions<C CD<
cDlf CDD
D
CD
CDCCD

"'C

,

-CC

<C ,

located in

Barnwell,South

The Richland,

Washington site islicensed to accept pressurized containers

absolute) of gases containing not more than log curies per container.
and located at least 1O feet from neigboring containers.

The containers

Given the site

for burial of radoactive gases at Richland, the inventory of Kr-85 from TMI would require approx-

The site in Beatty,(absolute)in operation,

the State of South Carolina has imposed a ban on

leaving only the two Western sites as potential receipients of gas-filled

imately an acre and a half of burial.DC.-

However,

Each site has different criteria for acceptance and burial of radioactive gases

containers of Kr-R5 from TMI.

must also be buried individually...
C

fhe alternatives

and transport to a remote location

ImpactCarolina; Reatty, Nevada; and Richland, Washington.

.CD
T••

burial)for release to the environment.

There are three commercial low-level waste burialo,ground (forNevada isspace.

licensed to accept gas containers that are pressurized up to one atmosphereand limited to 1RRR curies or less.

Gas containers containing from 100 to 1000 curies must be

surrounded by at least 6 inches of concrete on all sides.

It should be noted that transportation of radioactive gases for disposal

in commercial shallow

land burial sites

has not been a common practice in the U.S.

Given the burial

site

limitations for container pressure and carie content, and the required use of DOT and NRC

approved shipping containers,
potentially high.

at Beatty and Richland,

The environmentalIc

the number of required containers for transporting 57,000 Ci of Kr-8S isUnder ideal conditions,a minimum of 57 and 570 containers would be required for acceptancerespectively.

impact resulting from the burial of 57,000 Ci of Kr-Rh would essentially be the population

exposure incurred by the workers who would be required to package the gas at TMI, handle
f

"1

-. 11

1

2

0

the gas shipping

containers, transport the gas to a low level waste burial site and handle the gas containers at the burial site.

.oThe packaging and transportation of the Kr-Rh gas would oe conducted in accordance with appropriate DOT and NRC
regulations.

The estimated exposure resulting from these operations would range from 8 to 24 person-reos.

corresponding population exposure to members of the general publiccontact of the waste containers

to the general publicaduring

The

is negligible by comparison because of limited

transportation.

In addition, the staff assumed

that the population dose due to subsequent release (from corrosion of the containers in the ground) of the total
inventory of Kr-O5 gas is also negligible.

The assumption is based on the minimal environmental dose impact ofa release of 57,000 curies of Kr-85 (see Section 6.2) and low population density in the vicinity of the burial
site.
11-

C-29

7-1
6-34
7.

Health Effects

7.1

Physicallocation for controlled release to the environThe alternative to offsite burial is transportation to a remotereleaseThis alternative presupposes that a suitable facility would be constructed to effect a controlledment.
dose to the public
at the remote site. This alternative also assumes that there will be a negligible population
Because the same basic operations (i.e., packaging, handlingfollowing release for the reasons elaborated above.
limitations (i.e., DOT and NRC
at TMI, transportation to a remote location, and handling at the remote site) andfor the burial alternative,
packaging and transportation regulations) on this alternative apply to the operations
burial or release of the radioactive
the expected population dose is the same, namely, 8 to 24 person-rem. Although
would not be acceptable tokrypton of a remote site could be accomplished, the NRC staff believes this probably

7.1.1

local officials and residents.

could be anticipated as a result of the 'ground release'

Summary and Conclusions

The fRC staff has determined that there would be negligible physical public health risks associated with theuse of any alternative evaluated in this assessment,
proposed purging alternative in particular,
Environmental Protection Agency,

U.S.

the U.S.

Department of Health,independent scientists reporting to the Governor of Pennsylvania.

Education,

The Union of Concerned Scientists reported

venting" (Ref.

their report to the Governor,

including theand Welfare and two groups ofthat, based on "current evidence of effects of whole body radiation on human populations, .

Protection and Measurements (NCRP) in
6.9.2

For the staff's

except the "no action" alternative.

this determination has been supported by others,

3).

no health effects

The National Council on Radiation

noted that "exposures

likely to be received

In the NRC(Ref. 23).
us a result of venting are no valid bases for concern with respect to health effects"
staff's judgment, there is, then, no physical public health basis for eliminating the purge alternative.

Summars

and offsite disposal
The environmental dose impacts resulting from the operations associated with transportationofwould be in addition to the exposures incurred during the decontamination (i.e., during process operation)
the surveillance required during
the reactor building atmosphere but would not include the exposure incurred for

Additionally it

extended storage.

7.1.2

should be noted that, based on the relatively greater radiosensitivity of humans,

there would

be no adverse impact on plants or animals following purging.

of the packaged Kr-85
Although the environmental dose impact resulting from transportation and offsite disposal
This course
reasons.
is negligible, the NRC staff does not recommend this course of action for the following
which would result
would presuppose the selection of a reactor building atmosphere decontamination alternative
Purging, as a method of decontamination, could be accomplishedin a delay of the entire TMI cleanup effort.

Discussion

The NRC dose model for Kr-R5 and other noble gases released at the time of the accident
day state-of-the-art dosimetric models.

The NRC Kr-85 dose model is in

exposure other than from immersion in a cloud of the gas.
estimates provided by other groups.

quickly with negligible public health consequences (see Section 7.0).

is based on present

Noble gases have no significant food pathway involvement or modes ofgood agreement with

The National Council on Radiation Protection and Measurements provides aconsensus of the risks of Kr-85 exposurein Krynton-85 in the Atmosphere--Accumulation

and Control Technology (hereafter RCRPReport 44) (Ref.

24).

BiologicalSignificance,

Much of the basic information about Kr-8b

inthis section is derived from NCRP Report 44.
Krypton-85

is a radioactive isotope produced by the fission of several heavy isotopes,

uranium-238,

and plutonium-239.

such as uranium-235,

Most of the Kr-Rb in the TMI-2 reactor building resulted from the fission of

uranium-235 prior to the accident.

Krypton is one element in the series of noble gases that include,inof increasing atomic mass,

helium,neon,

tasteless,and do not undergo chemical

reactions with other molecules in living tissue.

radiologicalargon,

krypton, xenon,

and radon.

half-life and emits beta particles by two different decays.

These gases are colorless,order

Krypton-85 has a 10.7-year

Beta emission is

not followed byemission of a. gamma ray for 99.6% of this decay process.
People are continuously exposed to Kr-85 which is normally contained in the world's atmosphere.
krypton has been released into the atmosphere during nuclear weapons tests.
continues to be released to the atmosphere from nuclear fuelresult of these releases,

In addition,

In the past

krypton has andreprocessing plants throughout the world.

As abackground levels of krypton throughout the earth's atmosphere are readily detectablewith suitable instruments.

In the TMI area,

the R.S.

for example,

normal background concentrations to be about 30 pCi/me.

Environmental Protection Agency has measured

This concentration results inannual Kr-85 backgroundskin and total-body doses of about 0.00004 and 0.0000005 mrem respectively to all members of the public.
compares to an average annual total-body background dose (from/inthe U.S.

Medicaland dental exposures normally accountsources other than medical)

Thisof about 100 mrem

for another 100 mrem per year to individuals inthis country.

Krypton-85 has low blood solubility and high lipid (fat)concentrations proportional
tration.

C-30

to those insolubility, but diffuses

the surrounding air,rapidly in tissue to reacha condition referred to as an equilibrium concen-

NCRP estimates that the equilibrium concentration of Kr-85 in body tissues (pCi/g)

relative to the

. JJ1'-

7-2

surrounding air (pCi/cms)

is as follows:(1) separable fatty tissue, such as Ureasts,

around some body organs-41% of the concentration
soft tissues (such as organs,muscles,brain,

in air, (2)etc.),-8.3% of the concentrationfrom beta particles and gamma rays (plus their resulting radiations,and inside a person, the skin istissue.

However,cancer.

Furthermore,in air.

in air, (3)Considering the dosesuch as bremstrahlung*)

the organ that receives the highest numerical dose,

as noted in NCRP Report 44,

thighs, waistlines andskeleton-13% of the concentration

both from aroundfollowed by lung and bone

the skin is one of the least susceptible tissues to radiogenic

while any cancer is potentially fatal, most skin cancers lend themselves to successfultreatment.
The 1979 draft report of the Committee on the Biological Effects of Ionizing Radiation (National Academy of
Science) provides a tentative estimate of risk of radiogenic skin cancer (Ref.
that the risk of inducing a fatal radiogenic skin cancer iscancers resulting from total-body irradiation (per unit of dose).
the total-body dose is criticalboth sexes.

25).

That model would indicate

less than IX of the risk of death from otherAs a result,the NRC staff concludes that
cc
Lu
e-)
Z

for determination of cancer mortality risk for estimating genetic risk forThis will be discussed

in more detail later inthis section.

z

The NRC health effects model was developed in 1975 for the Reactor Safety Study by a 13-member advisory group,r0(three of whose members were also members of the 1972 National Academy of Sciences Committee on the Biological
Effects of Ionizing Radiation (BEIR)
and six life scientists.

The NRC health effects model

26b.

fhe advisory group included six physicians,

is shown in Figure 7.1 infrom the 1972 NAS/BEIR Report (Ref.
during which no cancers occur.
specific type of cancer.**(Ref.

one veterinarian,Two members were from the University of Pittsburgh School of Public Health.

27),

assumes that,graphic form.

This model,

following a radiation dose,

The latent period is variable,

and isU.1
0which uses observed estimates
there is a latent period

assumed to be dependent only on the

2L0

Following the latent period there will a period in which cancers will be observed

ZL)(plateau).
Using the total-body dose estimates for the alternatives
estimate of 135 deaths per million person-rem,Zshown in Table 1.1 and the NRC cancer mortality risk

the potential cancer deaths were calculated.

cancer mortality to both the 5h-mile population surrounding TMI-2 and to plant workers isfrom a minimum of 0.0003 (purge option) to a maximum of 0.034 (cryogenic
would be borne by workers exposed at the plant (purge = 0.0002,

option).***

cryogenic = 0.034).

The total potential

estimated to range

Almost all of that risk
The cancer mortality risk

SINGLE DOSE OF RADIATION

among the general population within 50 miles resulting from the purge option would be about 0.0001.

The maximum potential

lifetime-individual

maximum estimated dose of 0.2 mrem.

risk of cancer mortality would accrue to a fetus that received the

Figure 7.1 Basic Model for Latent Cancer Fatalities

Using 300 deaths per million person-rems from Table 7.1, the excess

cancer-mortality risk for this scenario would be six chances
normal lifetime expectancy of one chance inin 180,008,088 (0.00000006)

five (0.2) from all types of cancers.

compared to a current

Risks for all other age

groups would be even lower than this extremely small value.

Using the total body dose estimates for the optionsof 260 cases per million person-rem the potential

shown in Table 1.1, and the NRC genetic effect risk estimate

genetic effects per generation were calculated.

The total*A type of X-ray.
"wAnimal studies

RISK COEFFICIENT

indicate that the latent period generally increases with decreasing dose.

*n*EPA, in an April 11, 1980 letter to NRC, (Ref. 28) independently estimated 0.00022 and 0.057,
These values represent close agreement with NRC estimates.

respectively.

C-31

TIME

_7%mts U S-i-U

7-5

7-4

potential for genetic effects in plant workers and the 50-mile population surrounding TMI-2 is estimated torange from a minimum of 0.0005 (purge option) to a maximum of 0.066 (cryogenic

option).

would be borne by future descendants of workers at the plant (purge = 0.0003,

cryogenic = 0.066).

genetic risk to future descendants of any offsite member of the public would be five chances in(0.00000005)

Table 7.1

Almost all the risk
The maximum

Summary of Age Specific Cancer Mortality Risk Estimators andAssociated Life-Shortening

100,000,000

Potential Cancer Mortality

compared to the current expectation of a normally occurring genetic effect at a rate between one

and five chances in

Age Group

100 (.01 to .05).

per

Average Life-Shortening

00

u06Person-Rem

per Person-Rem
Totals

Hours
87
37

7.2

25

1.5

Total Days

Recent cancer statistics indicate that more than 14 persons per 10,000 persons will contract skin cancer eachyear (calculated from Ref.

29).

Thus,

these cancers occur on the face, neck,the typicalarms,risk of occurrence per lifetime is about

110.

Most of

In-Utero

150 Leukemias
150 All others

300

0-0.99 years

50 Leukemias
43 All others

03

1-10 years

SD Leukemias
55 All others

105

24
12

1.5

11-20 years

25 Leukemias
171 All others

196

10
40

2.0

20-70 years

23 Leukemias
108 All others

131

5
10

0.63

All ages

28 Leukemias
107 All others

135

10
18

1.2

and hands due to exposure to the ultraviolet (UV) rays from thesun.
Since most skin cancers are not fatal,

most are unreported in cancer registries.

300,000 new cases of skin cancer occurred in the U.S.
of those cases reported,m~lanomas,

0

there were 5,900 deaths.

Estimates indicate more than

(population of 220 million) in

Of those that died,

4,300 (out1979 (Ref.

However,of 13,600 cases) were fromand 1,600 (out of more than 300,000) were from other types of skin cancer.

rates were about 30% for melanomas and less than 0.5% for non-melanomas.

29).

The overall

Therefore,

the mortality

lifetime mortality riskof all types of skin cancer is currently less than 2 chances per 1,000 persons (that is,about 1.5% of thetotal risk of cancer mortality).
The 1979 draft BEIR report indicates on the order of one case of skin cancer will develop per year per million
person-rem of low LET radiation (such as emitted by Kr-8O)
definite increase

(Ref.

25).

Although no studies have indicated ain melanomas as a result of radiation exposure,it

was assumed for this assessment that the

lifetime risk of mortality (not incidence)
spontaneous skin cancers.

0

For a population composed only of that age group.

A summary of other common competing risks of mortality comparable to the maximum total-body dose (purge option)from radiogenic skin cancers is the same as for naturally occurring

That assumption implies that the lifetime mortality risk is

11is shown inon the order of one

Table 7.2.

death per million person-rem (skin).
Based on this assumption,

the lifetime cancer mortality risk from a total body dose isgreater than a comparable skin dose.**Table 7.2.
Summary of Lif etime Risksof Mortality Numerically Equivalent to 0.2 mremat least 135 times

The beta dose to the exposed skin from Kr-85 is about 80 times greaterthan the total body gamma dose for unprotected members of the public.

This implies that the cancer mortality

0Type of Activity

Equivalent Mortality Risk

Causes of Deaths

Cigarette Smoking

Inhaling of few puffs

lung cancer andcardiovasculardiseases

Drinking

A few sips of wine

cirrhosis of theliver

Automobile driving

three miles

accidental death

Commercial flying

14 milesaccidental death

Canoeing

20 seconds

drowning

Being a man aged 60

one minuteall causes ofdeath at age 60*Sir Edward Pochin,"The'Acceptance of Risk," (Ref.

risk from Kr-85 skin doses to the public would be on the order of 60% of the cancer mortality risk from theKr-85 total body dose.
Therefore a skin dose of hi mrem to an individual(purge option) would be predicted to cause less than one(about 0.000006) additional skin cancer mortality among the 50-mile population of 2.2 million people.
compares with 4,000 expected deaths from skin cancerfrom other causes (primarily

total expected cancer deaths in the area regardless of whether the Or-85 isUsing the estimates of average life-shortening in Table 7.I,

sunlight),

released or not.

and the dose estimates in Table 1.1, it

to estimate the average loss-of-life expectancy associated with latent cancer mortality.
shortening would result from irradiation of a fetus in the mother's womb.
dose of 0.2 mrem would resultThisand over 400,000

is possible

The maximum life-

Using 7.2 days per rem, the maximum

in a statistically average risk of 2.1 minutes.

Risks to all other age groups

30).

would be even less.
The staff has compared the dose conversion factorsthat for Kr-O5.

cancer deaths/O15 person-rem (total
0 cancer deaths/Dot person-rem (skin)for the noble gases released during the TMI-2 accident withwould require the release of approximately

500 million Curies of

Kr-8O under the same exposure conditions that existed during the accident to result in population doses comparable

uMelanomas are a rare but dangerous skin cancer.
00135

It can be shown that itto those received from the 10 million curies of xenon and krypton radioisotopes

body).accident.

135

Stated another way,

actually released during thethe release of 57,000 Curies of Kr-8O under accident exposure conditions would

have resulted in only about 0.01% of the population dose which was estimated to nave resulted from the accident.

C-32

1

0

ME

M.

E

&-f

I

7-6

7-7

It should be noted that even the relatively large amounts of noble gases (including Kr-85) released during theaccident were determined to present little
Report (Ref.

32),

and NRC staff (Ref.

risk to the public by the Kemeney Commission (Ref.

Based on the canter statistics just discussed,31), Rogovinduring their lifetimes (Ref.

17).

24).

to ultraviolet rays from the sun.
18% that of white persons,Comparison with Other RadiologicalRisks

about bl out of every 100 persons will develop a skin cancer

is assumed that most of the current risk isIt

was assumed the difference is largely due to greater protection of the germinalitlayer of skin from UV by melanin pigments

A summary of other comon competing .risks of mortality comparable to the maximum total-body dose (purge option)

due to exposure of the skin

Since the current risk of skin melanomas among black persons is only about
in the epidermis o? black people.

that the difference is due only to UV irradiation,
Is shown in

7a

If

it

is'conservatively assumed

then about 80% of all skin cancers in the U.S.

would be due

about 9 cases per hundred persons).

to exposure to the sun (i.e.,

Table 7.3.
Comparing these figures with the 1979 draft BEIR estimate of about one case per year per million person-rem(Ref.
Table 7.3.

Summary of Latent Radiogenic Cancer Risks Comparable to 0.2 mrem

is

25)

indicates that background radiation accounts

further evidence that the skin isrelatively

Tope of Exposure

Equivalent Radiological Risk

Source of bose

Some people (for example,

Commercial Subsonicjet travel

29 minute flight at 30,000

cosmic rays
(Ref. 33)

the direct rays of the sun (primarily head, neck,

Commercial supersonicjet travel

18 minute flight at 60,000 ft.

cosmic rays
(Ref. 33)

person spends about 3 hours per day (including weekends,

Living in Denver, Colorado(as opposed to Middletown)

one day

Moving to a location about
20' higher in elevation
than Middletown(same type of home)

one year

Sleeping withanother personft.

farmers, commercial

for less than 1tOof the expected skin cancers.*

insensitive tofisherman) spend as much as a third of their lives exposed toarms,

and hands).

Others (e.g.,miners,

It was assumed hereetc.) may spend less than one-tenth of each adult work day in the sun.

average risk of UV induced skin cancer isThisnionizng radiation.

childhood and retirement years) inoffice workers,
that the average
the sun.

The

therefore:cosmic ray andterrestrial radiation (Ref. 34)

0.09 skic cancers
days/yr)(75 yr-s/person)'or 1.1 x 10-5 skin cancers/hour of sun.
(3 hrs/day)(36k

cosmic rays
(Ref. 34)

Using the 1979 draft BEIR estimate of 10-6 cases of radiogenic skin cancer per year per person-rem yields on

about eight months
at eight hours/day

naturally occurring K-40
gamma rays (Ref. 35)

Using the maximum individual skin dose estimated by NRC (11 mrem),

Living at the siteboundary of a coalfired plant

about two weeks

naLural radioactivity
emitted by coal
combustion (Ref. 36)

risk of skin cancer equal

Living in a tight,
energy-efficient houseabout one night

estimated equivalence of 0.045 hours of exposure to sunlight and one millirem of skin dose (Ref.

be equivalent to spending 30 minutes in the sun.

25).**

the added average risk of skin cancer would

The average individualin the population would have an added

to about a half-second of exposure to the sun's rays.

increased levelsof Rn-222u
3

Assumes (a) one extra 0.001 pCi of Rn-222 per m of room air (actual measurements have shown up to
0.03 pCi of Rn-222/Mn)* and 50% equilibrium for radon progeny, (b) 2 x 4-4 lung-cancer deaths per
working-level month (WLM), and (b) being at home 100 hours per week (or approximately 15 hours per
day).
Therefore,(2 x 20-4 lung cancer deaths) . (0.005 WLP 5h0percent equil)(
WO10.00] pCi/n((12 months)
yr)-(100 hrs/wk)*m
40 r-/h30 deaths
million people

Exopected:

O.11 k 2.2 x 1o0 = 24 million cases of skin cancer.

3 chances in 100,000(

l75

lifetime
compare with (0.0002=

3 chancesi.e.,rim) x (1.35*Halloweu,@u

108 persons)

year-

k

(,50 years at risk) (I x 106eskn/ceancers/yr2

person-re

k 100% o8-107_ 0.4% of total expected

I x 10-6 skin cancers/yr per person-rem2
1.1 y.

( 1000(2.2

8 X 104 skin cancers or,about 1,000 times greater risk for an energy efficient house(24_hrs)r)x 10-4 cancer deaths/(rem)in 100,000,000(365 days)

From 0.1 rem/yr of background radiation:

0.0 ron-am

ear
or:

0-- skin cancer7s/hour of suil(50 years at risk) = 45 hours
person-rem

8.80 hrs (a good night's sleep)) k (day)et al., invited paper,-CCorrection for differences

1979 Meeting of the American Nuclear Society,

San Francisco,CA.

in exposure periods at home compared with uranium miners.

C-33

I

7-8

7.2

Psychological

7.2.1

Conclusion

7-9

StressDepartment of Health, and Flynn's preliminary report (Ref. 39) on the TMI telephone survey of residents around
TMI for the NRC. Each of these studies attempts to answer in part the question, "What are the mental healthconsequences of the accident?"

The staff concludes

that the psychologicalfrom any of the other decontamination

alternatives.

decontamination alternatives and will, therefore,
alternatives.

removing Kr-8S

was an increase of psychological

Purging the reactor building is the quickest of the1979.

result in stress of shorter duration ýelative to the otherreleases.

38) and others (Refs.

after the accident.

In addition,

TMI-2,

from the reactor building may be perceived as a crucial first step in progress toward overall

37-39),and perceived as further evidence of NRC insensitivity to their apprehensions.
that, given the absence of radiological risk from the purging option,inand a distrust of those responsible for these activites.

seen to be acute.

Nonetheless,mentalthe staff believes

some of which are

future decontamination plans for

These two interrelated issues represent a new

The Kemeny CoMMission suggests that stress was inducedin those currently

in charge of TMI operations.

These stresses are

the Commission4 proposes that any increase in the incidence of long-termor physical health problems caused by the accident will be insignificant.
however,

several researchers (Refs.

The effects of stresses in40, 41)

foresee no long-term

stress-related health problems.

of the reactor building atmosphere will substantially alleviate psychological stress due to a concern overunplanned radiological releases from the facility and doubts about the ability and decisivenessIn addition,

the post-accident period are uncertain;

the long run, prompt decontaminationstress,nevertheless,however, find several indicators of stress that remain high even

The continuing stress seems related to two issues:and exacerbated by a lack of confidence
that the purging recommendation may be unpopular to a segment of the local population

These reports,

agree that there
stress initially following the accident that had diminished by mid-summer,

source of stress that continues beyond the accident.

decontamination of TMI-2 and elimination of the potential for future disruption from that unit.

The staff acknowledges

or mental well-being.

They felt that this drop indicated that stress linked with the accident was acute or event specific.

Houts..(Ref.

Such alternatives would use considerably more complex equipment and processes and would thereby

prolong the uncertainties and associated stress over the possibility of accidental

Each examined different indicators of psychologicalreports by individuals on their physicalstress resulting from atmospheric purging will be less severe thanof the NRC totake affirmative measures.

As a result of the above review, the staff suggests that current distrust of authority in a percentage of the
population will be an important factor in the community's evaluation of any decontamination plan (Refs. 37-39).

7.2.2

Such distrust can heighten a person's or a community's perception of potential danger and their feelings ofDiscussion

lack of control,
A number of studies reported psychologicalat the time of the accident (Refs.

distress as widespread in the population around Three Mile31, 37-39). Moreover,some level of psychologicalsource of the stress

distress continues to be

associated with various issues surrounding the current and future status of the facility (Refs.

38,

39).

31).

Recognizing

possible different levels and characteristics of psychologicalnation alternatives.

In reaching conclusions on the relative psychologicalsources,

after effect) of disasters.

Of particular relevance were studies,

37-41),

including studies of psychologicalthat specifically addressed conditions incomments.

The Human Design Group,

stressors.

stress and psychologicalsequedea

by experts on psychological stressfor creating long-term psychologicalPsychologicalstress is

31,

loss.

behavioral and physiological

These patterns include increased physical and psychologicalarousal,caused by a specific event,effects from the same event.
for long periods.

The

or

a person affected maylevel of stress is generally associated with a person's perreption of

While most persons have the capacity to recover quite well from acute stressa small percentage of a population may experience lasting physical and/or emotional
Such chronic stress, however,is usuallyrelated to events which cause stress

While chronic consequenses of short-term events that cause stress are still an open question,

the long and short-term

symptoms are similar:

The conclusions on the psychologicalbuilding are,harm,

and a search for alternatives toStress may be induced by a wide

suffer psychological as well as physical strain and their consequences.
the severity of loss or harm.

a response pattern

If a perceived threat is not controlled or reduced,

cope with or reduce danger or loss.
variety of situations or events.

phenomena,of an event or situation that threatens some kind of danger,

emotional

tension, cognitive impairment,

stress associated with atmosphericand somatic complaints.

decontamination of the TMI-2 reactor

in part, based on three valuable studies that have received wide distribution.

Dohrenwend's technicalreport (Ref.

37) for the Kemeny Commission,

Houts'

study (Ref.

38)

but should diminish thereafter.

seem pertinent to TMI-2 decontamination:

the duration of reactor building atmosphere decontamination(2)

They arefor the Pennsylvania

C-34

(1)

the immediate fears purging arouses; and (3)decontamination activities.

that the purging alternative has less potential

Acute stress for many

residents could be elevated by the purging,
operations;

The Human Design Group's principal members

stress than those alternatives which take longer to implement.

a complex set of mental,

resulting from a person's appraisal

Perceived feelings

the issue of duration of stres and related
Some stress will exist in the TMI area as long as decontamination is delayed and agencies are seen

by some to lack credibility and are perceived as insensitive to the area's welfare.

(of(Refs.

are affiliated with the Department of Medical Psychology, Uniformed Service University of the Health Services.
Based on consultations with psychologists the staff concludes

is present and by how people perceive their ability to cope with it.

In addition to stress related to distrust of authority, there is

impacts among the alternatives,

the Three Mile Island area and an evaluation of public

assisted the staff's evaluation.

These feelings may cause some TMI residents

this fact, the staff has explored thestress associated with each of the decontami-

the staff considered several

38, 39).

The level and duration of stress is determined in part by how long theof lack of control found in the TMI community are enhanced by previous conflicting and inconsistent stances
made by the major organizations involved during and after the accident (Ref. 31).

In

particular, anxiety is high among some members of the population at the prospect of krypton-85 releases to theenvironment from the Unit 2 reactor building (Ref.

as was found in several studies (Refs.

to resist any agency-sponsored action.

IslandThus,

three sources of stress

distrust of authorities responsible forLt I0

M-L

="-U

8-1

8-2

Mobile Monitoring - survey meter and ion-chamber

A minimum of three mobile radiation monitoring personnel equipped with survey instruments and one low rangepressurized ion-chamber will be positioned in the predicted downwind trajectory during purging.

Monitoring

personnel will be drawn from other Federal agencies as well as from the EPA in order to provide 24 hour
8.0Radiological Environmental

Monitoring Program

coverage.

In addition to making radiation measurements

throughout the day, personnel

will be prepared tocollect compressed eir samples based on those measurements.
8.1

introduction
B.

The radiologicalenvironmental monitoring around the TMI site and nearby communities

reactor building atmosphere would be performed by (1)Commonwealth of Pennsylvania,(3)

the U.S.

Metropolitan Edison Company (the licensee).

the U.S.

(2)

Environmental Protection Agency (EPA),

Department of Energy,(4)

the Nuclear Regulatory Commission,

The

Four compressed air sampling units will be positioned at fixed locations for the collection of weekly samples.

and (5)

Each program is summarized in the following subparagraphs; a more

complete description is given in the EPA report,"Long-Term Environmental

Krypton-85 Sampling

during decontamination of the

Radiation Surveillance Plan for Three

The units will be placed at Middletown,

the Observation Center,

representative coverage with emphasis in

the predominant wind directions.

Bainbridge and Goldsboro into two weeks prior to purging to provide background data for the TMI area.

Mile Island," March 17, 1980.

SamplesU. S. Environmental Protection Agency (EPA) Radiological Monitoring Program

EPA has been designated by the Executive Office of the President as the lead Federal Agency for conducting a comprehensive long-term environmental radiation surveillance program as a follow up to the accident at TMI-2.
to purge the reactor building atmosphere be approved.

network of 18 continuous air-monitoring stations at radial-distancesin Table 8.1.

a gamma rate recorder,

These stations constitute EPA's baseline,

A listof sampling locations

long-term monitoring program.

samplesC.

Tritium Monitoring

EPA operates aranging from 0.5 mile to 7 miles from TMI.

and three TLDs.

Additional

All samples will be analyzed

at the EPA laboratory facilities in Harrisburg.

One molecular sieve sampler will be operated at the Observation Center for collection of atmospheric moisture

Seven miles was established as the point well beyond that which EPA expects to detect any emissions from TMI-2.
an air sampler,

data.

EPA

has recently incorporated a separate section in their surveillance plan detailing the monitoring program to be
implemented should the NRC staff proposal

when necessary, based upon survey meter and ion-chamber

In addition

A minimum of one sample will

be collected each day (at the predicted offsite location of maximum plume concentration).
will be collected,

Each station includes

routinely collected in

Nevada will provide an indication of worldwide ambient Kr-85 levels for comparative purposes.
three compressed air sampling units will be deployed with the mobile monitors.

8:2

order to provide

Sampling will be conducted for one

for tritium analysis.

Analyses will be performed at the EPA laboratory facility in Harrisburg.

is shown

The air sampler units sample

A.

Routine Air Monitoring Network

at approximately 2 cfm and the samples are collected from each station and analyzed typically three times per week.
All samples are analyzed by gamma spectroscopy at EPA's Harrisburg Laboratory using a Ge(Li)limit of detection

detector with a lower

In order to verify that no radionuclides other than Kr-85 are released to the environment during purging,for cesium-137 or iodine-131 of approximately 25 pCi (0.15 pCi/m3 for a 48-hour sample).

samples from the established network of eighteen operating stations will continue to be collected.
in the downwind sector will be collected every day,Each monitoring station isequipped with a gamma rate recorder for measuring and recording external

exposure.

tions.

Recorder charts are read on the same schedule used for air sample collection and the charts are removed weekly forreview and storage at EPA's laboratory

in Las Vegas,

Samplesrather than the three times per week under normal condi-

In addition at least one sample from "control" stations in each quadrant not in the downwind trajec-

tory will be collected and analyzed on a daily basis.

Nevada.
EPA reports all results of their monitoring measurements from their baseline program three times each week to the

Thermoluminescent dosimeters have been placed at each monitoring station and at 0.25 mile intervals along roads

public and news media.

immediately parallel to the Susquehanna River near TMI out to a distance of about 2.5 miles from the reactor.

starting approximately two weeks before

TLDs have also been placed on the islands locatedHenry,

Kohr and Beech Islands).

In addition to the above,Vegas

b.5.miles to 1.5 miles west-of the reactor site (Shelley,

If Krypton purging is

8.3

a weekly compressed gas sample is taken at the Observation Center and sent to EPA Las

I
CommonwelhL

olfPennsylvanla RalogiOg'cal monitoringr rogram

The Department of Environmental Resources of the Commonwealth of Pennsylvania operates three continuous air samp-

for a determination of krypton and xenon.

ling stations; one at the Evangelicalin Goldsboro near the boat dock.

purging of krypton

the following manner if

cartridge.

is approved.
collection of compressed air samples

The charcoal

The particulate air samples

C-35

are composited quarterly and analyzed forsamples are gamma scanned for reactor-related radionuclides.

have the capability to sample or analyze for Kr-85.

collection of samples from routine air monitoring stations will be implemented.

one at the TMI Observation Building, and one

The filters and cartridges are changed weekly; the particulate air samples are gamma scanned and beta

Sr-89 and Sr-gA.
for Kr-85 analysis and intensified

Press Building in Harrisburg,

Each air sampling station consists of a particulate filter followed by a charcoal

counted for reactor-related radionuclides.

A monitoring program consisting of survey meter and ion chamber measurements,

completed.

Hill,

These dosimeters are read quarterly.

The EPA's base long-term program discussed above will continue and will be augmented inapproved, EPA will make daily reports to the public and news media

intiation of purging, and continuing until purging is

They do not, however,

8-4

8-3

8.4

U.S.

8.4.1

o

Department of EnergyoCommunity Monitoring Program

Argon-41 and Klrypton-85 monitoring
Supervised area monitoring with actual procedures andequipment

The Department of Energy and Commonwealth of Pennslyvania are sponsoring a Community Radiation Monitoring Program.
This program has as its purpose to:(a)trained local community people, and (b)provide independent verification of radiation levels in the TMI area by

At the completion of the instruction phase,to increase public understanding of radiation and its effects.

training of approximately one week.

Thea final examination was given.

This was followed by field monitoring

approach to achieve this purpose has involved the selection of individuals by local officials from the following
The training sessions provided basic information on radiation,

12 communities within approximately five miles around TMI.

its effects,

detection techniques,

aspects of the course before actual monitoring efforts begin.

East Manchester Top.

both the theoretical and practicalLondonberry Top.

completion of training in the third week of April,and included

Citizens were expected to demonstrate competence inhands-on experience with monitoring equipment in the field.

team representatives

inFollowing theeach of the 12 selected areas began

on a routine basis.

Detailed procedures wereYork Haven

data acquisition from the gamma and gamma/beta sensitive instruments

Lower Swatara Twp.

developed to consolidate the information being obtained into a central point of contact inConoy Twp.

Pennslyvania for dissemination to the press,

Goldsboro

Maintenance and calibration procedures were also developed and are in place prior to the initiation of routine

Fairvien Top.

field monitoring.

Royaltonthis program are reported daily to the public.

the Commonwealth of

local officials, and other interested parties on a routine basis.

The Community Monitoring Program was initiated on May 21 and the results of measurements from

West Donegal Twp.
8.4.2

Middletown

DOE 7 Atmospheric Release Advisory Capacity

Newberry Twp.
The Department of Energy will make available during the purging operations its Atmospheric Release Advisory

Elizabethtown

Capacity (ARAC).
Approximately 50 individuals participated in

Department of the Pennsylvania State University.
classroom instructions,radiation monitoring in the field.

independent predictions of the dispersion patterns for the krypton

data and National Weather Service reports.

The teams utilized EPA

programs.

The predicted dispersion patterns will be provided to the Environmental Protection Agency to serve as a

gamma rate recording devices which are currently in place around TMI and will be supplemented by gamma/beta sensi-

basis for their positioning of ground level monitoring teams.

tive devices which are being furnished by DOE through EG&E Idaho, Inc.

utility and the NRC, as an additional

This training was structured to cover the

8•.5These predictions will also be provided to themeans of assuring that the purging operation isfollowing areas:,

S.

These predictions will use atmo-

spheric dispersion models which have been verified during many years of field experience and tests in Government

Approximately 15 training sessions were conducted involving

laboratory training, and actualThis ARACsystem will provide

release based on local meteorologicaltraining classes conducted by members of the Nuclear Engineering

being adequately controlled.

n......
U.S.

NuclearKeguiatory ýominsssion

Kaolomolocail eonmsorsnorroram

Classroom instruction
The Nuclear Regulatory Commission (NRC) would operate one air sampling station located in the middle of theooIntroduction to radioactivity

reactor complex.

Interaction of radiation with mattertwo sets of TLDs at 59 locations as shown in Table 8.2.

Methods of radiation detection

flexibility exists to read one set at more frequent intervals should conditions warrant.

8.6

Licensee's Radiological Environmental Monitoring

Program

Health physics procedures
Radiation interaction

with biological systems

The licensee normally utilizes 72 radiological environmental monitoring locationsoAdministrative procedures for Conmunnity Radiation Monitoring

two thermoluminescent dosimeters (TLDs)

Program
TMI-2 accident and cleanup

TLDs will be placed in""

Meteorologicaldose over the entire purge period.

at each location.

to monitor plant releases with

In addition to these required TLDs, four additional

each of these locations during controlled purge; two for periodic readouts (frequency

depends upon purge duration and the influence of plume) and the remaining two for assessment of the integrated

conditions

In anticipation of certain sectors coming under the influence of the plume fora greater duration of purge period, additional TLDs will be placed in
2.

The NRC would place

Both sets would be read on a monthly basis; however,Radiation counting variables
Radiation protection unitso

The air samples would be changed weekly and analyzed by gamma spectrometry.

selected areas.

Laboratory instruction
In addition to the TLn'monitoring,oM.N.(Geiger

Mueller) counting experiments

grab air samples will be obtained by an individual(s) dispatched via two-way

communications to the projected plume touchdown area during the controlled purge.

Radiation counting statistics

The air sampler will be placed

and operated such that a grab.sample will be obtained over a 15-20 minute period while immersed in the plume.
Hourly update of plume direction and touch-down area,

Monitoring equipment familiarization

utilizing real time monitoring and an assessment program,

will be obtained and disseminated to field sampling teams.

C-36

rlr

n-1-

i1a -or

6"1
I A

8.6

8-5

Table 8.2
Table 8.1
DESCRIPTION OF NEC TILDLOCATIONS

Three Mile Island
EPA Long-Term Surveillance Stations
Air Samplers,

STATION

AZ

3

325

Gamma Rate Recorders,

DISTANCE (Miles)
3.5

El -

TLOS

NEI - On telephone pole by George Beyer Market,
25'

ASSOCIATED TOWN
Meade Heights,

Hwy. 441 on Laurel Road 1st telephone pole on right outside vendor TLD
0.45 ml90'
boa.
Geyero Church Road off 441.
08 mi

NE2 - On telephone pole at intersection of Hillsdale and next road on left
feom Geyers Church Road (closed road to gold church) by yellowlsh red
1.9 mi19'
house.

PA - Harrisburg

International Airport
NI
4

360

3.0

*Middletown,

5

040

2.6

Royaltown,

PA - Elwoods'- On chain ltnk fence

for p.enr esbotatcon,
358'

NE3 - On telephone pole on Rt.

3.0

230 directly across from Shady Lane Motel.
3.05 sO
15.

PA - Londonderry Townshipjusttaloono,NEI - On volephvne pole oo Rt. 743 josl north of Texaco
6.3 ml55
north of Turnpike onderpuss.

Building

100

Middletoun St corner.
2.6 mlSunoco Station

RNewville, PA - Brooks Farm (Earl

Ninsley283,

directly

across the

N2- On telephone pole on Middletown Road N of Rt.
street from childrens care center.

N3- On oigo pole on Middletown Road at intersection to It 322 E.
7.0 ml0.
Signpole says 322 West.

N4- So telephone pole on Hoe Road,2Sd pole on left.
Road.

N5

- On telephone pole on Rt.

Residence)

11

130

2.9

Falmouth,

PA - Charles Brooks Residence

13

150

3.0

Falmouth,

PA - Dick Libhard Residence

14

145

5.3

*Bainbridge, PA - Bainbridge Fire Company

16

180

7.0

*Manchester, PA - Manchester Fire Dept.

NW5 - Enviroonental Stcalon (Met Ed) at West Fairview,
Falrview Fire Depaurtent, adjacent to tracks.
305'

NW4 - On telephooe pole on Meadowbrook just off Bridge Stceet.
8.6 ml300'
side fros Bridge Streeo.

17

180

3.0

*York Raven, PA - York Haven Fire Station

20

205

2.5

Woodside,

21

250

4.0

*Newberrytown,

Goldsboro,

31

270

1.5

*Goldsboro, PA - Dusty Miller Residence

34

305

2.7

Plainfield,

PA - Polites Residence

35

068

3.5

Royaltown,

PA - George Hershberger Residence

36

095

0.5

TRI Observation Center

37

025

0.7

North Gate,

TMI

38

175

5.8

South Gate,

TeI

15 m1
one block on N.

turoplke
1st pole over75.4
mi

WA - Oo "No Parking Any Time" sign within I'
264'
Goldshoro.

verposo,of water at old boat ramp at
1.25 sO

W2 - On conlutent onleor inside chain link fence to Monitoring Station,
By etnema.
Goldsboro 00 Rv. 262.
1.3 ml252°
Sal - On telephone pole approxisately 25' from tracks in turn around full of
Across from 2 .mull trallers (green and blue) inflattened beer cann.
2.1 ml2009
clearing (N end).
W3 - On colephone pole on Pine. Road at intersecthon of 974 Red Mill Road.
2.9 ml.
264'
near N eberry.
W5 - O telephone pole at intersection of 01.
259'
Lelsbsurg.

382 and Rh. 177 NW corner
7.3 ml.

W4 - On telephone pole oo Rt0 392 (Pathshill Road)
266'
S. nide. Beyond ohorpbend.
*Sampling stations located in indicated town.

rear to Annex Building

NWI - On telephone pole direntl7 in front of church vt intersection of RN. 262-n hood).
O and Rt. 392 W (Valley eRadend To
2.6 ml305'

PA - Muealar Resident

2.9

Rd.)

NW2 - On telephone pole on Marsh Road by Clovert under RN tracks off Old York
3.9 nO
300'
hood.

PA - Exxon Kwick Service

Station265

39 at Intersection of Rt. 22 (Allencoe
13 ml
0o

NW3 - SO telephone pole on Old York Road.
295
woet aide.

PA - Zane Resner Residence

23of Union Deposic
Juov N. of Indere. ctio
9.0 ml0.

Just beyond Ridge Road on
5.9 miOther sampling stations are located near indicated towns.

I
C-37

8.7

Table 8.2

8.8(Continued)
Table 8,2

SW2 - On telephone pole at intersection of 382 E and 295.
Diagonally acrossfrom Texaco station, York Haven Road and Reeders Hill Rd. PleasantGrove.
2031
2.5 m1
S-1- On telephone pole at Intersectlon of Rt. 181 and 382.
Across street
from York Haven Office.
In front of Catholic church, York Haven.
1686
3.15 m1301'

1.3 ml

NW - Hill Island

316j

1.2 ml

NW -

3267'

5 ml

332'

0.5 mlighaplre

NNW - dohr Island

S-2 - On telephone pole at intersection of Meeting House Road and N. George
Street (Rt. 181 S), Manchester.
175'
5.1 ml
S-3 - On telephone pole on Rt. 238 at intersection to Rr. 181 S.
and cement block building, Emigsville.
180'
9.1 nO

NRC - TLD SCHOOLLOCATIONS

By old brickSW3 - On telephone pole at intersection of Lewisberry Road and Butter Road.
By small frame house near Anderson town.
210'
8.1 .mNla

NORTHUMBERLANDSCHOOL
2.4 ml N

Nlb

MANSBERGERSCHOOL
2.7 m NNW

Nlc

FEASER SCHOOL
3 ml NBid

CAPITOL CAMPUS, PENN STATE 0.
3.5 ml NW

Nle

GRANDVIEWSCHOOL
3.5 ml NNW

Ni

MIDDLETOWNHIGH SCHOOL
4 ml NNW

SW4 - On telephone pole at intersection of Butter Road and Bull Road
215'
10.1 J.
S-4 - York substationi,

sampling enclosure.
180'

12 n

SE5 - On telephone pole at intersection of 441 N and Vinogary Ferry Road
across entrance to Cargill Truck entrance.
SE4 - On pole at intersection of 441 N and 241 N.
141'(Continued)

WNW- Town of Plainfield

Pole next to fruit stand.
4.6 ml

NE-3a

SE3 - On chain link fence on right side by Collins Substation sign at
Intersection of 441 and Falmouth Road.
160'
2.25 mlTOWNSHIP SCHOOL
3.6 ml NE

W-3a

NEWBERRYSCHOOL
4.4 1 W

SE2 - On telephone pole at intersection of 441 N and Turnpike Road.
162'
1.85 ml

S-la

YORKHAVEN-NEWBURGSCHOOL
3.3 mi S

SEI - On telephone pole across from Red Hill Farm fruit stand 441 N, I milefrom 3 Mile Island.
150'
1 mi
E2

- On telephone pole at Hillsdale Road and Turnpike Road.
110*
2.7 mi

E3- On telephone pole at Turnpike Road and Boosmer Road.
I18'
3.7 mlE4- On telephone pole at intersection of W Hight Street and Mosorie Road,
Ellzabethtown.
go.
7.0 mlE5- Meadow Lane,N- Bre 441

SE1 a

Inc house on south side of street.
0.4
86'
03'

1.8 mi

NE - Under TMI high tension lines

44'

i.1 ml

ENE - Rte.

230

64*

3.8 ml- Rte.

411

130'

0.5 m1203'

0.7 mlSW - Newberry Township227'

1.8 mi

NNW- Shelly Island289*

0.3 n1

SE

4

SSW - Beech Island

.

C-38

BAINBRIDGE SCHOOL
5.0 ml SE

mm

U - ~±....

I

ra

-

a

i

a-

m'mL

m

n

9-2

9-1

workers are also members of the public and thethat do not release the KR-8p to the environment, the occupationalin person-rem (both occupational and general
health impact (if any) best relates to the total population doseto provide estimates of the total
In this regard, they stated that it would be appropriate for the NRC
public).
The NRC staff has included these recommended dose estimates in
population dose (both offsite and occupational).
9.0

Response to Cormients

9.1

Introduction

this Final Environmental Assessment.
9.2.4

Building Atmosphere"
The draft "Environmental Assessment for Decontamination of the Three Mile Island Unit 2 Reactor
The public commeent period for these three(NUREG-0662) and two subsequent addenda were issued for public comment.
At the close of the comment period approximately ASP responses had been received.
documents ended May 16, 1980.
Comments on the Environmental Assessment were received from various Federal, State, and local agencies and offiAll substantive comments received appear
cials; from nongovernmental organizations, and from private individuals.
(1) those supporting
The comments received fell into one of three categories:
in Volume 2 of this Assessment.
the purging alternative recommended by the NRC staff (approximately

those opposed to the

195 responses), (2)purging alternative (approximately 500 responses), and (3) those who recommended decontamination alternative:
other than those discussed in the Environmental Assessment or who otherwise commented on the assessment (approxi-

building atmosphere.

Several of the responses included specific editorialcomments,

comments have been resolved by revision of appropriate sections of this final

9.2

Where appropriate,

review had identified
from the Assistant Secretary for Environment, stated that theirclarification would enable a more complete assessment
several areas where they felt that additional information or
The following comments on
the reactor building.
of the potential effects of the removal of krypton gas fromthese

NUREG-0662 were offered for consideration:

Environmental Assessment.

action, should include estimates of the
The accident analysis for each alternative, including the proposed
This would permit a more complete evaluation of theprobability of occurrence of the worst case scenarios.
impacts.
safetyandhealthpotential for adverse

Comments Supporting the Recommended Purging Alternative

the various alternatives should be provided
A more precise estimate of the time necessary to implement
Estimates should beprocess.
because of the importance of this factor in the overall decision-making
program for each alternative.
based on realisticprojections of an accelerated construction/testing

The NRC staff received approximately 195 responses supporting the purging alternative recommended in the Environmental Assessment.
9.2.1

CEQ stated that in

President's Council on Environmental Quality (CEg).

be quantified to the extent possible
The potential hazards associated with the storage of Kr-85 should._
in order to better reflect the seriousness of problems associated with the storage.

their view the NRC staff's proposal

Advancedaction would be helpful.
A more detailed description of the monitoring program for the proposed
the incremental dose at the site
monitoring to'calibrate and verify analytical methods for predicting
determine off-site concentrations
accurately
andpromptlytoabilityThe
discussed.
beshouldboundary
also should be discussed in more detail.

to separate the decontamination of the reactor building atmosphere from the preparation of the Programmatic Environmental Impact Statement does not violate 40 CFR § 1506.1 (1979) (Limitations on actions during NEPA process) of
the Council's regulations

9.2.2

implementing the National

The U.S. Environmental

Environmental Policy Act.

Protection Agency (EPA).

ble, when meteorological conditions most favor dispersion.
very low environmental

A.A) does not represent an accurate
The description of DOE's radiological monitoring program (Section
is enclosed for your information.
summary of our current efforts. An updated version of this section
The
venting should be presented.
The nature and extent of the controversy surrounding the proposedof the public anO scientific combasis for the technical questions being raised by various segmeots
assessment
meaningfulmoreaprovidemunity along with a critical evaluation of their concerns wouldof the significance of the impacts of the proposal.

EPA stated that the most acceptable method for decontami-

nating the TMI-2 reactor building atmosphere is a controlled purge to the environment

in as short a time as possi-

EPA based its recommendatior:and public health impact that would result from the controlledof this method on therelease of the Kr-85 andstated that this method would eliminate the large occupational radiation exposure which could occur from use of
EPA also stated that their assessments of the offsite doses for thethe other decontamination alternatives.

of the worst case scenarios for the
The recommendation to include estimates of the probability of occurrence
Since the health effects resulting from worst casevarious postulated accidents was considered by the NRC staff.
probabilities of occurrence are irrelevant.
accident scenarios for any of the alternatives are negligible, theAs for the proposed actions to below.
Although these probabilities have not been quantified, they are considered
require that appropriate emergency and contingency
taken in the event of a postulated accident, the NRC staff willof the facility Technical Specifications prior toprocedures be prepared and approved pursuant to the requirements
alternative.
decontamination
the implementation of any

general agreement with those calculated by the NRC staff and that the estimated healthrisk of releasing the Kr-85 was 0.0001 excess deaths to the 1,750,000 population within 80 kilometers (50 miles)
purging alternative were inof Three Mile Island.
9.2.3

U.S.

Department of Health,

The AEW Bureau of Radiological
two addenda,

it

impact.

Education and Welfare (HEl)Health commented that after reviewing the draft Environmental Assessment and its

is their conclusion that the purging of the KR-P5 in

under controlled release is

had performed an
The Assistant Secretary for Nuclear Energy stated that his staff
DOE submitted two responses.
purge was indeed the preferred method forindependent review of the matter and had concluded that a controlled
accrues from many other power plants,
decontamination since it would result in less public radiation exposure thanand in the event ofThis response urged the Commission to act promptly on the matter,both nuclear and fossil.
off-site conditions during the purging process
NRC approval, offered the resources of DOE to assist in monitoring
Their support for the(See Section 8.0).
to help guarantee that conditions remain within acceptable limits.
on April 25, 19A0 during a Commission briefing on
purging alternative was reiterated by a DPE representative
Krypton in TMI-2 Containment.
Selective Absorption Process as an Alternative in Pealing with
The second DOE response,

The third category also included all other commoents on the five alternatives evaluated in
Assessment, as well as suggestions for additional methods for decontaminating the TMI-2 reactor-

mately 105 responses).
the Environmental

The U.S. Department of Energy (POE).

alternatives,
The estimated times to implement the various decontamination
construction/testing programs, have been reviewed.

the TMI-2 reactor building to the atmospherethe prudent and proper course of action which provides minimal,

if not zero,

They further noted that although members of the public in the vicinity of Tf1,1may call

healthfor alternatives

C-39

including the use of accelerated

9-4

9-3

There is, I have found a broad-based consensus among these sources that the venting proposal now
before you would have, in the words of the Concerned Scientists, 'no direct radiation-induced health'the exposures likely to be
Similarly, the CRP concludes:
effects on the residents of this area."received as a result of venting are not a valid basis for concern with respect to health effects."

The potential hazards associated with long-term storage of Kr-85 and the NRC staff's reason for recommending
against long-tern storage of Kr-85 are discussed in Section 6.8.
The description of the monitoring program to be used if the purging alternative is approved,
updated to reflect the current monitoring program.
monitoring program,has been revised and

There is a consensus on the accuracy of the radiation dose rate calculationt made by your staff. inconjunction with the utility, and there is a consensus that those dose rates are "insigniitcant."
A
I should point out that the Union of Concerned Scientists feels that the psychological stress alreany
experienced by many residents of this area since March 28, 1979 should seriously be considered in any
decision you make with regard to the cleanup operation on Three Mile Island, and I agree with that.
As you know, I previously instructed attorneys for the Commonwealth to introduce stress as a legitimate
factor for you to consider in other decisions growing out of this incident.

Section 8.0 contains a detailed discussion of the planned "including an updated version of the DOE sponsored portion.

In its preparation of this final Environmental Assessment,

the NRC staff has again evaluated,

as recommended,thenature and extent of the controversy surrounding its recommendation to decontaminate the TMI-2 reactor building
atmosphere by purging to the environment as presented in draft NUREG-0662.
and responses to this proposal is contained

An evaluation of the public comments

in Section 9.0 of this final Environmental Assessment while Section 7.2

contains a discussion of the psychological aspects of the proposal.
9.2.5

UCS also recommends that you consider two alternative venting plans described in its report, and that
I am sure.you will give
you reconsider two non-venting plans previously rejected by your staff.
I do urge that any new assessments be completed as promptly
due consideration to those recommendations.
the sooner any stressisresolved,
I am advised and believe that the sooner this matteras possible.
related to it will be dissipated.

Advisory Committee on Reactor Safeguards.

In a joint meeting between the KRC Commissioners and the Advisory Committee on Reactor Safeguards (ACRS) On April
11,

1980,

several members of the ACRS recommended that the reactor building atmosphere should be decontaminatedsoon by controlled purging to the environment.

I recognize that part of the delay already experienced has been due to my effort to be assured of the
I now have that assurance, and I feel that a safe cleanup plan should be implesafety of venting.
mented as quickly as possible.

Their reasons for this recommendation were that a controlled purge

would permit less restricted access to the reactor building for equipment and instrument maintenance and repair
which may be required in

9.2.6

the near future,

I am advised and I believe, however, that the question of stress, as related to the venting plan, is
directly linked to the question of its safety, and that the consensus finding that the plan poses noradiation threat to public health should, in itself, substeotially reduce any stress that might haveaccompanied it.

and that the health effects of a controlled purge would be very small.

Should you proceed with the venting proposal advanced by your staff, be assured that I amprepared tosupport that decision. To minimize stress, I am prepared to commit all of the resources at my disposal
to assure the residents of the area, as I am now persuaded, that this plan is, indeed, a safe one ....

Governor of Pennsylvania.

The Governor's comments were contained ina letter submitted to Chairman Ahearne after the Governor received an

independent assessment of the proposed decontamination effort from the Union of Concerned Scientists (uCS).

In his letter, the Governor noted that the UCS had recommended consideration of two alternative purging plans as
Inwell as consideration of the Cryogenic Processing System and the Selective Absorption Process System (Ref. 3).

The

Governor had requested this independent assessment and had been granted an extension of the public comment period
to permit the completion of this independent assessment.

In his letter to Chairman Ahearne,

preparing this final Environmental Assessment,

the NRC staff nas.evaluated the two alternhtive purging planssuggested by the UCS and has also reconsidered use of the Cryogenic Processing System and the-Selective Absorption

the Governor stated:

Process System.
This is to notify you of my views, on behalf of the Commonwealth of Pennsylvania, regarding the proposal
now before you to remove radioactive krypton 85 from the Three Mle Island Unit 2 containment building
by the process of venting it into the atmosphere.

The first

I have sought and received assessments from the broadest range of knowledgeable sources available

a discussion of which is given in Section 6.2.5.

regarding potential health effects of that proposal.

of UCS' proposed plans would use a tethered balloon to support a 200T-foot-high reinforced fabric stack,This technique is unique and untried, as stated by UCS.

These sources have included:
In general,

your director of nuclear reactor*Members of your own staff, and especially Mr. Harold Denton,

the staff finds the UCS proposal technically workable and probably capable of being implemented within
However, the staff has examined Three Mile Island for
was made,

regulation.

a year fromthe time the decision to use it*ahe Union of Concerned Scientists (OCS), the nation's foremost critic, I believe, of existing

unobstructed ground and air space to launch a tethered ballon.

nuclear power safety levels.

ballon launch is not readily available on theisland without substantial modification to the site.

*The National Council on Radiation Protection and Measurements (NCRP), an organization of distinguished scientists and physicians which has been instrumental in setting radiation health.standards in this country for nearly 20 years.

The second proposal of UCS was that the reactor building atmosphere be heated in an incinerator and discharged
through a 250-foot-high stack. The staff evaluated this proposal in Section 6.2.5. Reconsideration of the*Representatives of the electric utility and nuclear industries.

Cryogenic*The U.S.

Department of Health. Education,

Processing and Selective Absorption Process Systems are contained in Sections 6.6 and 6.7, respectively.
the staff continues to believe that the Kr-85 should be purged to the environment

Hasing evaluated these proposals,and Welfare.

through the hydrogen control system.

*The Governor's Commission on Three Mile Island.
*The Pennsylvania Departments of Health and Public welfare,the area of mental health in our state.

Adequate unobstructed land recommended for thethe latter of which has jurisdiction in*The Pennsylvania Department of Environmental Resources (DER),
Protection.

Finally,

the staff and the Commonwealth of Pennsylvania would have to ascertain the psychological impact on theThis difficult task was recognized

nearby residents regarding the Kr-85 purging techniques proposed by the UCS.
including its Bureau of Radiation

by UCS as a valid concern in

The assessments of these various groups and institutions are being forwarded to you under separate
cover, and I respectfully request that you enter them into your official record on this matter.

its report to the Governor.

As enclosures to a subsequent letter, the Governor of Pennsylvania provided copies of the various reports andassessments he had referred to in his previous letters and stated that the joint press release which he had developed with the UCS contained a clarification regarding the first recommendation on page 57 of the UCS report.
subject UCS recommendation stated:

C-40

The

9-5

9-6

9.2.8

UCS recommends against any procedure that would result in citizens in the area around TMI being
deliberately exposed to radiation from the plant at levels comparable to those expected from theMet Ed/NRC venting proposal.
Dr. Henry W. Kendall,

UCS chairman,

said the organization ultimately decidedof the existing Met Ed/NRC venting plan,

Coemisuioners of Cumberland County,

The Commissioners of Cumberland County,

to recommend against implementation

alternative.

Pennsylvania.

Pennsylvania,

Their resolution stated that it

issubmitted a resolution supporting the recommended purging
interest to provide for the health and welfare ofin the public

the people of Cumberland County by cleaning up TMI as soon as possible and that "tle Government"

but he emphasized that this was primarily because of the stress problem.

should exert thenecessary leadership to accomplish this action.
The enclosed report of The Governor's Commission on Three Mile Island stated:
9.2.9
In light of our review of the alternative risks, this Commission urges the NRC to make a prompt
decision concerning the proposed venting of the Unit 2 containment buIding atnosphere.
Avoidanceof this decision by the NRC is unacceptable.
This Commission would not oppose an NRC decision torennvsyivnuiia

Ohe Middletown Borough Council passed a resolution in

vnet the kryptongas,providedthatdone levelspojnectedin the environmental
impactassessmen~tThis resolution stated:-cceAtfaole.
nis. position is based on a careful review oi the nest evimence auaimole at thos•T--e__
emnss ilein original)

support of purging the krypton-85 gas into the atmosphere.

"this council supports the venting (of.krypton-e5 gas in the atmosphere)

as recommended

by the NRC staff and calls for implementation as quickly as possible.'

An enclosed memorandumto the Governor from the Pennsylvania Department of Environmental Resources stated thatthey had concluded that controlled purging using the hydrogen control system, as recommended by the NRCstaff, wasthe preferred alternative for removing the krypton from the reactor building atmosphere.

9.2.10Borough o. Royalton,

The Borough of Royalton,

Pennsylvania.

Pennsylvania submitted a resolution supportingthe cleaning up of TMI as soon as possible.

An enclosed letter to the Governor from the Pennsylvania Department of Health recommended that in an effort tominimize stress, both present and accumulative, purging of the krypton from the reactor building be accomplishedas soon as possible and in as brief a time period as possible.

by the NRC and EPA staffs that itg.2.11

An enclosed letter to the Governor from the Pennsylvania Department of Public Welfare stated that making a decision on purging and proceeding in a responsible fashion could in the long run minimize stress and reduce thepotential for anxiety and depression among the population that lives near TMI.
9.2.6

riiooletownsorougn council,) elueoore.n

the recoenended purging alternative andThis resolution stated that their support was based on determinations

is safe and proper to purge the Kr-85.

National Council on Radiation Protection and Measurements INCRP).

The NCRP, in addition to the UCS, was specificallypurging operation.

requested by the Governor of Pennsylvania to review the proposed

The NCRP submitted a response in which they stated:

At the request of Governor Thornburgh of Pennsylvania, the National Council on Radiation Protection andMeasurements ()CRP) has examined scientific material relating to the health effects of krypton-R5, updated
its Report No. 44 on krypton-8R published in 1975, and estimated the doses to the public and the risks
associated with them for tce amounts of krypton-Rh expected to be released as a result of the proposed
venting at the Three Mile Island nuclear power plant.
The findings are that the maximum doses likely tobe received by any person are very small.

State of Maryland.

The State of Maryland responded with two sets of comments, Their first response addressed the staff's recommendation in the basic Environmental Assessment (NUREG-0662),while their second response addressed Addenda 1 and 2 of
NUREG-0662. In their first response (March 31, 1980), the State of Maryland agreed with the NRCstaff recommendation that purging the reactor building atmosphere to the environment is the best available option. They did,
however, recommend that real-time environmental and meteorological monitoring be used for dose-rate monitoring andreduction during purging operations to ensure that the offsite doses are estimated accurately and minimized. They
also stated this was the proper time to make a decision regarding the decontamination of the reactor building
atmosphere and that this action should be considered apart from the Programatic Environmental Impact Statement
being prepared by NRCon all TMI-2 decontamination activities. They note that no benefit would be served by adelay and that, instead, delaying the decision would result in "a substantial loss." In their second response(April 22, 1980), they stated that the fast purge described in Addendum2 of NUREG-0662(a five-day purge over a
two-week period) does not offer any net psychological advantage and that this option should be rejected in favorof a purge program which would use real-time meteorological data to minimize the highest offsite dose.

Superficial beta radiation to the skin is the primary potential health concern; however, in the total population within 50 miles no cases of skin cancer would be expected from the doses likely to be received.
The risk to the maximally exposed individual member of the population at the plant boundary is estimatedto be equivalent to the risk of skin cancer resulting from exposure to a few hours of sunlight, which is
known to be the principal cause of skin cancer in the general population.
Ohe dose expected from the penetrating radiation is about 100 times less than that from the superficial
radiation and the risk of inducing cancer is correspondingly smaller.
The NCRP concludes that the exposures likely to be received as a result of venting are not a valid basis
for concern with.respect to health effects.

9.2.12Natural Resources Defense Council

tNRDC).

The NRDCprovided a response by phone in which they supported the recommended purging operation by stating:9.2.7 Member of the Pennsylvania House of Representatives.
One member of the Pennsylvania House of Representative! submitted as a comment a letter he had sent to all elected
officials in his legislative district requesting that they join him in his call to come together and furnish theleadership necessary to accomplish a safe and expeditious cleanup at TMI. He also submitted several responses he
had received in support of his call. Another member submitted a letter in which he stated: "Vent it!"

Provided that the amount of radioactive materials to be vented are what they are reported to be (forexample in NUREG-0662), and provided that the venting procedures are appropriately conducted, then the
public health risks (somatic and genetic consequences) associated with venting the TMI-2 containment are
not significant, that is, sufficient to warrant exclusion of this option.

9.2.13

Other Comments Sopsorting Controlled Purging.

In addition to the commentsfrom these government agencies,

officials, and scientific organizations,comments

sipporting the recommended purging alternative were also received from approximately 30 nongovernmental
tions.

C-41

These included the Pennsylvania Chamber of Commerce,

Lebanon Valley Chamber of Commerce, Greaterorganiza-

9-7York Area Chamber of Coimnerce, Hanover Area Chamber of Commerce,

Harrisburg Area Chamber of Commerce,

Association of Commerce & Industry, Manufacturers'

performed.
assessment.

and various businesses in the TMI area,

approximately 150 private individuals and members of the professional community.

Science Aoolications.

Inc.

to perform such an

The TMI Legal Fund submitted a response in which they stated their opposition to the recommended purging
They sunvarized their opposition into the following three concerns:

and

operation.

Those comeenting typicallysoon to permit continuation of the required cleanup activities.
1.

9.2.14The Union of Concerned Scientists was suggested as a possible organization

Harrisburg-Hershey Area Tourist Promotion Agency,

American Association of Meat Processors,

recommended that controlled purging be performed

Lancaster

Association of York, Pennsylvania, Greater and Central

Pennsylvania Building and Construction Trades Council,
Harrisburg Hospital,

9-8

There is no emergency at hand.

Data may be collected and containment facility equipment may be inspected andmaintained without removal of the krypton-85 gas.

(SAD).

There is adequate time to implement an alternative systemfor krypton-8S removal from the containment building atmosphere.
At the request of the Conoission,

the NRC Office of Policy Evaluation (a Commission staff office),

contracted with

SAL to perform an independent technical evaluation of the purging alternative and Selective Absorption Process
(Ref.

43).

2.

SAI's conclusions and recommendations were:

Venting of krypton-A5 gas into the air which surrounds TMI-2 carries definite genetic and carcinogenic risks
to the people of nearby communities.
For a population which has already endured severe psychological stress,
the proposed venting will only exacerbate this state of stress.

From the points of view of feasibility, effectiveness practicality and the health and safety there isto choose between the two alternatives.
little3.

From the point of view of psychological stress on nearby populations, purging is the best alternative
because it can be carried out in the least time with the fewest newsworthy incidents.
From the points of view of schedule and cost, controlled purging
cheaper and can be started within days.
Therefore itisis the best alternative

because it

The proposed venting cannot be controlled due to meteorologic uncertainty.
The monitoring as described by
the NRC is incapable of providing sufficient information for the protection of people in communities
surrounding TMI-2.

is
They also urged that .data collection be initiated, that the containment building equipment be inspected andmaintenance begun at TMI-2, but that the krypton-A5 gas be retained until an alternative system has been installed

our opinion that the SAP should not be adopted as a substitute for controlled purging.

for its safe and efficient removal.
9.3

Comments Opposino the

Recommended Pornino Alternative

Approximately 500 responses opposing the purging alternative recommended by the NRC staff were received.
inthese comments was a resolution by the County Commissioners of Dauphin County,

release of the krypton-85.

Pennsylvania,

The TMI Legal Fund response also stated that (1) the draft Environment Assessment did not adequately evaluate thepotential health effects of'the purging operation, (2) an independent assessment of the purging operation should

Included

opposing the

The reasons stated for their opposition werebe obtained,(3)

Environmental

Impact Statement was an illegal action,

the segmentation of the reactor building atmosphere decontamination effort from the Programmatic(4) the monitoring program and criteria were insufficient,the krypton being approximately five times drnner than air will therefore settle into low-lying areas suchas valleys and basements in the absence of adequate convection.
and (5)(a) the health of humans, animals and plants nearby cannot be fully guaranteed, (b) the full health
implications of low level radiation exposure are not known, (c) health studies on human thyroids andvarious ailments afflicting animal life have not been completed to determine what effect, if any,
previously released low level radiation has already had on humans and animals in the TM1 area, (d) otheroptions remain for the removal of the krypton-b5 which have not been assessed independently by experts
outside the NRC or Metropolitan Edison Company, (e) experience of the last thirty years from radiation
exposure to indigenous populations near nuclear sites indicates clear health risk and resultant increased
health problems from varying exposure levels to radioactive particles, (f) radiation and exposure measurement standards currently being used by the NRC and Metropolitan Edison Company are based on experiments
and standards discredited by recently completed Heidelburg Studies and serious questions as to theiraccuracy and validity therefore exists in the scientific community.

In addition to the above-noted comments,

additional comments opposing .the recommended purging alternative werereceived from approximately 10 nongovernment organizations (including the Office of the Provost, Capital Campus,
the Pennsylvania State University;

the National Audubon Society; Taxpayers Association of Lackawanna County;
Heathcote Valley Alliance; Air and Water Pollution Patrol; Lehigh-Pocono Committee of Concern; and various
businesses in the TMI area); and from approximately 485 private individuals.
Their reasons for opposing therecommended purging operation included the following:(1) that the public be exposed to no additional radioactivethat one or more of the other alternatives for decontamination evaluated in the draft
Environmental Assessment be used to eliminate or minimize the release of Kr-85 to the environment, (3) that there
effluents from TMI, (2)The lower Swatara Board of Commissioners,
opposition to the purging

Dauphin County,

Pennsylvania, passed a resolution initially stating

into the atmosphere but further stating that they would accept the final recommendation

is no perceived or recognizedof the Union of Concerned Scientists.

need for the decontamination (several

entombed in its present condition),(4)

from the schools for summer vacation,
The Newbury Township Board of Supervisors,

York County,

the release of krypton-85 into the atmosphere; however,
The Mayor of Lebanon, Pennsylvania,
native cleanup methods.

Pennsylvania,

also submitted a resolution which opposedmonitoring program,and (6) that an independent assessment of the recommended purging operation be first performed
by a citizen-dominated group.

no specific reasons for their opposition were provided.

submitted a statement opposing the purging alternative and urging that alter-

which would not release radioactive material

into the atmosphere,

persons suggested that the facility bethat any purging operation be delayed at least until students are released(5) that any purging operation should be accompanied by a more extensive

9.4

be employed without

delay.

NRC Staff Responses to Comments Opposing the Recommended Purging Alternative

A detailed discussion of the health effects associated with the various alternatives for decontaminating thereactor building atmosphere has been incorporated into Section 7.0 of this document.
The NRC staff has determinedthat the potential for adverse radiological health effects to the public due to utilization of any of the

A member of the House of Representatives of the Commonwealth of Pennsylvania submitted a response in which herequested that the recommended purging operation be delayed at least until an independent assessment could be

decontamination alternatives is

C-42

negligible &nd that the publichealth and safety will not be adversely affected by.

r

7-

9-9

a

a

9-10

the purging operation.
Therefore, since the recommended purging operation can be accomplished without significant
risk to the health and safety of the public, and since the purging operation can be implemented immediately as

Control of the purging operation will be accomplished through frequent (at least hourly) monitoring of the
The DOE meteorological forecasting
existing meteorological conditions and reactor building effluent flow rate.

recommended in Section 5.0, the NRC staff recommends that use of the purging alternative be authorized soon,and monitoring capabilities

will utilize this information in conjunction with radiological monitoring program
results and will be communicated to the control room to assure that the cumulative doses to the public in any

rather than waiting for installation of one of the other decontamination methods.

sector will not exceed those in
At the request of Governor Thornburgh of Pennsylvania,
Addenda was extended to May 16, 1980.

The reason for the Governor's

request was to permit sufficient time for

The NRC staff disagrees with allegations that separating the reactor building atmosphere decontamination effort
This is supported by CEQ's comments, noted insimpactStatement was illegal,
from the Programmatic Environmental

completion of an independent assessment of the decontamination operation by the Union of Concerned Scientists
The Governor specifically requested.the UCS to perform such an assessment so that he could receive(UCS).

In their report to the Governor,

information from the bOroadest range of knowledgable sources available.

The basis for the staff position

Section 9.2.1.

the UCSauthorize such an action when it

UCS concluded that direct radiation-induced health effects from exposure to Kr-85 even from t0e Met
These conclusions are similar to those reached by the NRC and
Ed/NRC proposed venting would be absent.
Met Ed.

In Addendum 2 to NUREG-0662, the NRC staff evaluated and recommended a variation

because of the delays to permit comments on decontamination alternatives,

recommends this variation in the purging alternative.

However,

for the reasons describedalternative evaluated in

the NRC staff no longer

The extended comment period has also delayed the purging

operation until at least the beginning of the school summer vacation period,
mentators.

in the purging alternative which

was performed before about mid-May to take advantage of expected favorable meteorology.

provided it

However,a delay requested by several com-imperative that this action be taken.

this action must be taken are discussed indetail in Section 5.0.

five times denser than air,basement$ as suggested by several commentators.
low-lying areas.

The physicalitwill not settle into low-lying areas orproperties of gases (as expressed in the physicalprevent the settlenent of low concentrations of denser gases into

,laws that describe the dispersion of gases)

Although several commentators did not recognize or acknowledge the need"for decontaminating the reactor building,is0979 Statement of Policy andwhich clearly reserved the option tostated:Although krypton gas is approximately

in Section 5.0, the NRC staff now recommends that the purging

Section 6.2 be accomplished without further delay.

the NRC staff believes that it

Impact Statement,

The development of a programmatic impact statement wilI not preclude prompt Commission action when
The Connission does recognize, however, that as with its Epicor-Il approval action, any actionneeded.
taken in the absence of an overall impact statement will lead to arguments that there has been an
inadequate environmental analysis, even where the Comnission's action itself is supported by an environAs in settling upon the scope of the programmatic impact statement, CEQ can lend
mental'assessment.
For example should the Commission before completing its programmatic statement decide assistance here.
that it is in the best interest of the public health and safety to decontaminate the high level waste
water now in the containment building, or to purge that building of its radioactive gases, the Commission
Moreover, as stated in thewill consider CEQ's advice as t. the Commission's NEPA responsibilities.
Commission's May 25 statement, any action of this kind will not be taken until it has undergone anenvironmental review, and furthermore with opportunity for public comment provided.

an elapsed purging time of approximately 120 hours over a two-weekperiod,is the Commission's November 21,

Notice of Inteet to Prepare a Programmatic Environmental

stated:would permit the purge to be completed in

Section 7.0 of this assessment.

the public comment period for NUREG-0662 and its twoin the reactor building atmosphere is

The krypton concentration

concenitration as naturally occurring krypton in the earth's atmosphere.

The staff's reasons for believing thatat approximately the same

The naturally occurring krypton is

uniformly distributed throughout the earth's atmosphere as is the krypton in the reactor building's atmosphere; inThis staff position was also supported my theneither case has the krypton settled into

UCS in their report to the Governor of Pennsylvania:

9.5

The Union.of Concerned Scientists (UCS) Study Group believes that ultimate decontamination of the plant
Decontamination must include complete removal of the damaged fuel rods and ofis an absolute necessity.
The plant cannot be sealed and walked
the contaminated water in the containment sump and elsewhere.
This would constitute a negligent disposal means for a very large quantity of radioactivity.
away from.
Important quantities of these toxic materials would ultimately find their way into the environment
during the tens or hundreds of thousands of years that some of them will remain hazardous.

9.5.1

Other Comments on the Recommended

low-lying areas.

Purging Alternative

Introduction

The NRC staff received approximately 105 responses providing either specific comments on the five alternative
methods evaluated in NUREG-0662 for decontaminating the reactor building atmosphere or suggestions for additional

Accordingly, UCS has concluded that the krypton must be removed from the TMI reactor building so that an
The problem is how to do this in a manner which
orderly program of decontamination can be undertaken.
protects the safety of the workers who may be Exposed to the krypton and also safeguards the physicaland mental health of members of the public who may also be exposed.

methods for accomplishing the required decontamination.

9.5.2

Member of Congress

The UCS did however conclude that in their opinion a delay in removal of the krypton of up to a year and a half
would not pose an undue-risk to the health and safety of the public,
substantive progress in

A Member of Congress from Pennsylvania submitted a comment opposing the purging operation and recommending that

Such a delay would of course Postpone any

the overall cleanup program and as stated in Section 5.0, the NRC staff believes that thethe Selective Absorption Process be used.

alternative, it
The radiologicalin

Section 8.0.

ohamitoring programs for the TMI site and surrounding area consist of several programs described
In the opinion of the NRC staff, these programs with EPA having the lead for federal agencies,as

A cadre of about 50 local residents have been trainedis approved.

DOE monitoring program.

EPA will supplementinareas of expected maximum dose.

at his request,

Committee on Science and Technology.

into operation at TMI.

to participate in theparties,

its existing fixed munitoring stations with mobile units positioned

Reports of measurements will be made daily by EPA to the public and media.

C-43

House of Representatives

The Congressman also requested Oak Ridge National Laboratory (ORNL) tosystem of adequate capacity could be placed

ORNL subsequently reported that with "best efforts" being exerted by all concernedsuch a system could be operational at TMI in 13 months.

assessment of

The six-month implementation time wasby a member of the staff of the U.S.

reassess their time estimate for when a Selective Absorption Process

The on-going monitoring programs will be supplemented by the DOE program described in Section 8.0 if

the purging alternative

would be the least expensive alternative to implement.

based on a review performed,

designated by the Executive Office of the President) will provide an adequate monitoring of the recommended purge
operation.

This recommendation was based upon the Congressman's belief that the

Selective Absorption Process could be placed into operation in six months and that except for the purging

cleanup program should progress in a timely manner.

The TMI Program Office also requested an

toe proposed schedules for fabrication and installation of such a system by the Reactor Construction

7m

9-12

9-11

and Engineering

9,5.9

The Reactor Construction andSupport Branch of the NRC's Office of Inspection and Enforcement.

Engineering Support Branch concluded that the six-month schedule proposed by the staff of the Conmittee on Science
They further concluded thatand Technology was unrealistic and that the 13-month ORNL schedule was optimistic.

Environmental Coalition on Nuclear Power (ECNP)

A commentfrom the ECNP recommended that rather than implementing the purging alternative, the krypton be removed
from the reactor building atmosphere by one of the other alternatives (charcoal adsorption, gas compression,

their minimum schedule estimate would be 16 months with their best estimate being even longer.

cryogenic processing,
controlled conditions.

9.5.3

U.S. Department of the Interior

operation,
if any,The Department of the Interior commented that the draft report did not discuss what effects,

The ECNP further stated that if
atmosphere)

krypton from the reactor building atmosphere.
System described and evaluated in

rapidly,

An evaluation of the proposal submitted by the MITRE

reasons.

removal could be accomplished by one of theas in a "puff release."

As noted in

Section 6.2,

to reduce

the radioactivity in the TMI-2 reactor building atmosphere to maximum

permissible concentrations would require the transfer of about 23 million cubic feet of air. This transfer would,
in turn, pressurize the TMI-1 reactor building to 170 psig, a pressure significantly in excess of its design

International Business Machines Corporation (IBM)pressure of 60 psig.
report copyrighted inthere until

purge the TMI-2 reactor building atmosphere to the environment

The NRC staff has reviewed- these suggested alternatives and considers both of them unacceptable for the following

Corporation and the NBC staff reasons for not recommending its use are included in that section.

A technicaland (2)

there were at least two other(1) transfer the gas (the TMI-2 reactor building

operation to the Cryogenic

This proposed method would be similar in
Section 6.6.

to the TMi-S reactor building and store it

other decontamination alternatives,

The MITRE Corporation submitted a coement proposing to use a cryogenic air separation plant for removing the

9.5.5

their recommendation wasvnot implemented,

alternatives which have not been evaluated by the NRC staff:

MITRE Corporation.Processing

the NRC staff continues to recommend that the purging alternative

be selected as the method for decontamination of the reactor building atmosphere.-recommended purging operation will have no significant effect on fish or wildlife resources or on their habitats.
9.5.4

and because of the delays (16 months or longer) associated with the implementation of any of the otherdecontamination alternatives which do not purge,

the proposed

As noted in Section 7.1, therelease of krypton would have on fish and wildlife resources and their habitats.

or selective absorption) and then transferred to home unpopulated place for release underBecause of the negligible adverse radiological health effects of the proposed purging

1979 by IBM was submitted as a comment.

Radioactive Noble Gas Waste.in Amorphous Alloy," describes a method for long-term storage of Kr-85.

Use of thisto minimize the duration of the recommended purge operation.

As noted incryogenic distillation tower similar to the Cryogenic Processing System described in Section 6.6.
that section, construction and operation of such a system would require a minimum 20 month delay which for the
Therefore,transfer of the gas is not a viable alternative.

In preparing Addendum 2 to NUREG-0662, the NRC staff evaluated variations in

storage method requires that the Kr-85 first be separated from the reactor building atmosphere by use of areasons discussed in Section 5.0 of this document are considered unacceptable.

Therefore,"Encapsulation ofThis report,

the purging alternative in

an attempt

In this evaluation, the staff determined that it

would not be advisable to purge the reactor building as rapidly as physically possible since such a purge would
most probably result in beta skin-doses in

no further actions haveunrestricted areas in excess of the design objectives of 10 CFRPart 50,

Appendix I (Ref.

9.5.10Pennsylvania Dutch Visitors Bureau (PDVB)

15).

been taken on this comment.

9.5.6

Pennsylvania State University

The Pennsylvania State University submitted a comment suggesting the use of an oxygen

The PDVB suggested that all future news releases relating to releases of radioactivity contain an explanation (inlayperson's terms) of physiological and environmental impacts.
The NRC TMI Program Office has issued an easy-to-liquefaction unit. -ThisThe liquid oxygen would then beunit would concentrate more than 99% of the krypton in the liquid oxygen product.

understand report that answers questions most frequently asked about the proposed purge of krypton from the reactor
building.
This report states in layman's terms the potential health impacts likely to occur when the krypton ispassed through a bed of adsorbent material such as silica gel where the krypton would be selectively adsorbed.
The separation of the krypton from the oxygen could be done either onsite or offsite.
unit would be similar to the Cryognic Processing System evaluated in Section 6.6.

Such an oxygen liquefaction

released.

Copies~of the report, "Answers to Questions about Removing Krypton from Three Mile Island, Unit 2
Reactor Building "(NUREG-0673) are available free of charge by writingto the Division of Technical Information

Due to the time required forconstruction and operation of such a unit (a minimum of 20 months), use of this method is not recommended.
9.5.7

Science Applications

A comment infrom SAL.

Inc.

9.5.8

In their proposal,

The proposed method would use a selective adsorption process.

SAI estimated that

9.5.11

Due to this delay in system

the NRC staff does not recommend further consideration of this proposal.

itand the radioactive wastes within it

should be entombed.

However,since itD.C.

20556.

In addition,

Section 1.0 was

final assessment report for the layperson.
alternatives for

Hershey Entertainment & Resort Company (HERCO)

purging operation be performed soon.

damaged fuel be removed from the reactor to prevent either its potential
environment over very long time periods,

Washington,

HERCOrequested that the purging operation be scheduled (consistent with safety) either prior to or just after the
peak June - August tourism season.
For the reasons described in Section 5.0, the ARC staff recommends that the

Policy Center

is imperative

The informationin Section 7,0 is provided to alleviate public concerns

about the health effects of the purging operation, which have been determined to be negligible.

The Environmental Policy Center submitted a comment suggesting that rather than decontaminating the reactor
building,

Nuclear Regulatory Commission,

Section 7.0 of the final aisessment also describes the health effects of toe various
decontaminating the reactor building atmosphere.

the form of a proposal to remove the krypton from the TMI-2 reactor building atmosphere was received

Environmental

U.S.

written to provide a fairly complete discussion of the entire

such a system would require nine months for design, construction and checkout.
availability,

and Document Control,(SAI)

that therecriticality or eventual escape to thethe entombent suggestion is not considered a viable alternative.

C-44

mm

m

I

-

m

m

i

I

m

•

m

U0

9-14

9-13

95.12

m

ranging.
Oak Ridge National Laboratory (ORNL)

Theyncluded suggestions

contents at high elevations,(I) to purge the reactor building atmosphere into balloons and release theto evacuate the residents in the TMI area during the purging operation, and

(2)

(3)

to modify the charcoal adsorption process to minimize the quantity of charcoal required.
Some persons urgedthat NRC staff members and officials be present in the TMI area during the purging operat)ons, expressed concern
about possible releases of other radioactive materials, questions differences in the quantities of Kr-85 reported

ORNL suggested a possible mechanism for alleviating some of the public concern regarding the proposed purge
Their suggestion was to encourage and fund local radiation monitoring efforts

operation.

oversee this effort.

The DOE monitoring program described

Approximately 50 local

by ORNL.

for the duration of the

They further suggested that the Commonwealth of Pennsylvania should be requested to assist orplanned release.

by the licensee (44,000 curies) and by the NRC staff (57,000 curies) and worried that additional quantities offission products are continuing to be generated.
One person recommended that the cleanup operation be performed

in Section 8.0 will function essentially as suggested

residents have been trained to participate

in monitoring the recommended purgeby the Naval Reactors Branch of DOE.

operation.

9.5.13Councilman and Director Department of Public Safety,

The Councilman and Director Department of Public Safety,

City of Lebanon,

City of Lebanon,

A number of letters suggesteo that the krypton gas be placed in

Pennsylvania recommended a delay in the
responsible,

high in the atmosphere.

The Governor's request for participation by the Union of Concerned Scientists may be a step inthis direction."

Such a delay was granted and the UCS submitted their report to the Governor of Pennsylvania on May 15,

the purging proposal advanced by the NRC staff.

He further stated:"To minimize stress,

commit all of the resources at my disposal to assure the residents of the area, as
indeed,The

A large number of balloons would be required and they would have to be of immense volume becaure krypton-85 is aheavier-than-air gas which would require the addition of helium gas or lift
capability to the balloons as a volume
ratio of approximately 30 times that of krypton-85.
Moreover, the probability for a balloon burst is fairly high.

I also am prepared to

I am now persuaded,that thisBased on the National Oceanic and Atmospheric Administration experience with high-altitude weather balloons,a safe one."West Shore School

chance of no balloon burst
winds.

Districtis

The West Shore School District requested that approval of the purging operation be postponed until
schools in

19b0.

the Commission proceeded with

Governor subsequently stated that be was prepared to support the purging decision if

the TMI area have closed for the summer.

the summer during the week of June 9.

This probability,transported as a gas), would

The Regional Planning Council for the Baltimore, Maryland area commented that while in previous statements it
supported the position that there should not be a release of radioactive material
itit

the Environmental Assessment fails to mention a deadline for release of the gas.
operation be delayed until the Union of Concerned Scientists

They recommended that the purgethat the purging operation be performed soon and prior to completion of the Programmatic Environ-noticeto-all pertinent officials,

to the press,

Additionaluse of this concept

the advantages ofis not recommended.

in Section 7.0, the adverse radiologicalhealth effectsof the recommended purging operation

evacuation of the local residents is neither

required nor recommended.

The suggested variation in

the charcoal adsorption process recommends that three containers of charcoal

used.

the reactor building atmosphere would be filtered, dried,

Gn this variation,

refrigerated,advance of the purge operation so that monitoring

The NRC staff intends to provide at least a ten-day advancekrypton with increasing humidity,
holdup isstill obtained at high humidity,

the proposal suggests,

and to the public for the controlled purging operation.

cycles.

Although the charcoal

this ability is only decreased in magnitude,
and desorption would not be easy.

cannot be expected as easily as stated.

itloses its ability to adsorb
isnot eliminated.

Therefore,

Sihce this concept is

Significant

transfer of krypton, as

the basis for the entire

the rest of the proposal simply does not follow and its further consideration is not recommended.

Comments from Individuals
Several suggestions were made that NRC staff members and officials be present in the TMI area during the purging
The reasons for these suggestions included that their presence would be a demonstration of confidence
in statements by the NRC staff that the radiological health effects are negligible.
Members of the NRC professional

operations.
In addition to the above-noted comments,

approximately 90 additional responses were received from individuals who

provided specific comments on the alternative methods evaluated in NUREG-G662 or suggestions
for accomplishing

to be

and passed overkrypton breakthrough occurred in the first container.
The krypton in this firstcontainer would then be desorbed by admitting heated and humidified air. The desorbed krypton would betransferred to a second refrigerated container of charcoal for storage.
The adsorption and desorption in the

proposal,
9.5.16

as discussed

first container would then be repeated for several

stations can be established by Maryland officials.

and since the probable disadvantages outweighrefrigerated charcoal until

for the reasons stated in

Impact Statement.

They also requested that Maryland health officials be notified in

Solutions would

use of balloons forstress of some residents in the TMI area due
since the radiological health effects associated withtransporting and remotely releasing the Kr-85 gas,

will be negligible and, therefore,

study requested by the Governor of Pennsylvania was

Since the UCS study has now been completed, the NRC staff recommends,

mentalHowever,

They also commented that

Section 5.0,

Finally,

Recommondations that local residents be evacuated during any purging operation were based on the assumption thatan evacuation would protect residents from any radiological hazards associated with the release of the Kr-85.

hasfrom the cleanup process before

completed.

In summary,the recommended purging operation are negligible,

does recognize the need for timely action by the NRC whenfinds that public safety requires release of material before the EIS is completed.

and disposal of the contaminated balloons.

to the obvious visibility they would provide.

Planning Council

the preparation of an Environmental Impact Statement,

increase toe overall probability of a premature balloon burst.

transporting radioactive gas may further aggrevate the psychological

They further stated that most of these schools will close for

The decision to extend the public comment period on NdREG-0662 to May 16,

using balloons inRegional

theis in the range between 75 to 85%, but can drop as low as 50% during periods of gusty
coupled with the large number of balloons that would be necessary (assuming krypton-P8

then need to be devised for retrieval
after the

198P effectively granted this request.

9.5.15high-altitude balloons and transported for release

Although high- altitude balloons are technicallyfeasible as an alternative to controlled
purging, their use could increase the risk of an uncontrolled release that could result in higher radiation
exposures to the workers and the public than would occur from the alternatives discussed in this report.

publicinformation source which may enjoy a greater degree of public confidence than that now experienced by the NRC.

9.5.14other persons suggested that any necessary maintenance and repairs

Pennsylvania

purging operation and asked for "a stronger, more concerted effort to establish a factual,plan is,Severalwithin the reactor building could be performed by workers dressed in protective clothing without prior removal of
the Kr-PS.

the required decontamination.

The additional

for additional methods

staff would be at, and in the vicinity of,comments or suggestions were broad

C-45

TMI during purging operations to oversee these operations.

S

9-15

10-1

Concerns were expressed regarding the possible releases of radioactive materials other than Kr-85 from the reactor
building,

especially radioactive isotopes of cesium and strontium.

As noted in Section 4.0, the concentrations ofairborne radioactive particulate matter in the reactor building atmosphere is

low and the purge exhaust filter

system will remove essentially all of the particulate matter in the exhaust stream, thereby ensuring that there
will be no significant dose effects associated with the releases of other radioactive material.
10.0

Public Information Activities

Concerns were also expressed that additional quantities of fission products are continuing to be generated orreleased to the reactor building atmosphere and that this activity may be released during the purge.

In an effort to better inform the public in the area around Three Mile Island about the contents of the draft

These

Environmental Assessment (NUREG-OhA2, and Addenda I and 2), NRC has conducted 38 informational meetings andconcerns were based upon the variations between source terms used by the licensee in his submittal of November 13,
1979 (Ref.

1) and those used by the NRC in

NUREG-0662 (March 1980);

activities.

As noted in Section 4.2, these variations

The staff also issued an easy-to-understand report that answers

removing the krypton from the reactor building.

were not due to the generation of additional fission products or their release to the reactor building atmosphere

Copies of the report,

Krypton from the Three Mile Island Unit 2 Reactor Building" (NUREG-0673),

but were due to improved techniques in sampling and analyzing the samples.

to the Division'of Technical Information and Document Control,
A suggestion was made that by Presidential

Executive Order,

D.C.

complete responsibility for the cleanup program at TMI

U.S.

frequently asked questions about"Answers to Questions about Removing
are available free of charge by writing

Nuclear Regulatory Commission,

Washington,

20555.

be assigned to the Naval Reactor Branch of DOE and that the cleanup decisions should be removed from publicdebate.

The stated bases for these suggestions were that the cleanup action needs to progress

Most of the meetings held were planned by the NRC, although some were organized by other interested groups, atimmediately andwhich NRC officials were invited participants.

that the TMI-2 plant was not designed to house large amounts of gaseous krypton, radioactive water, or damaged
nuclear fuel for long periods of time.

all of the conditions encountered during and following the accident,it

The licensee,with appropriate support from the NRC, EPA and DOE professional
Therefore,

operation to another organization.

Congress has enacted legislation making the NRC responsible

the U.S.

Environmental Protection Agency and thefor environmental

EPA

monitoring in the vicinity of the

TMI site, while state DER personnel explained the community monitoring program and other state functions related(Seeto the clean-up of TMI Unit 2.

staff, has sufficientexpertise to perform the necessary cleanup operations.
Moreover,Members of the U.S.

Resources (OER) were usually invited participants at these meetings.

officials outlined their agency's program and responsibilities

is now and is expected to continue toisolate the radioactive wastes from the environment provided necessary actions are taken on a timely basis.
Section 5.0).

Pennsylvania Department of Environmental

Although the TMI-2 facility was not specifically designed to accommodate

At these meetings,

groups of people who had an interest in

there is no present need to assign the cleanup

NRC officials expressed their willingness to meet with otherreceiving additional information on the Environmental Assessment or clean-up operations at Unit 2.

for licensing activities pertaining to civilian nuclear power reactors and NRC regulations allow for public
participation inThis effort of comowunicating with the public fell into three broad categories:

the licensing process.

15 public meetings and meetings with interested citizens groups,

Several comments were made to the effect that any necessary maintenance and repairs within the reactor building
could be performed by workers dressed inprotective clothing prior to removal of the Kr-85.

However,

16 meetings with elected officials, andas rioted in

7 press conferences and appearances on public information radio and television shows.

Section 5.0, only preliminary measurement and planning activities can be performed in the reactor building prior
to the-removal of the Kr-85.

Therefore; the Kr-85 must be removed to permit any maintenance or repair activities
10.1

within the reactor building.

Public Meetings and Meetings with Interested Groups

On March 19, 1980,

NRC conducted a public meeting in Middletown to inform local citizens of the contents of thedraft Environmental Assessment.

Following this initial meeting,

NRC officials attended similar gatherings insurrounding communities at the request of state and local officials.
The NRC staff also met with a wide variety of interested groups which included:

Chambers of Commerce
Civic Service Organizations
Medical Associations
School Board Officials
Religious Leaders
Teacher Organizations
Three Mile Island Alert
Meetings with the Capitalsioner Hendrie,

C-46

Forward Group and Three Mile Island Alert were attended by Chairman Ahearne and Commis-

respectively,in

addition to NRC staff participation.

mL-

-L

dM~of-W-.r-

10-2

10.2

11-1

11.0 References

Briefings for Elected Officials

In addition to meeting with Governor Thornburgh,

Harold Denton,surrounding Three Mile Island.
counties closest to TMI:

1.

Director of the Office of Nuclear Reactor

Regulation, and other members of the NRC staff met with various city officials"Three Mile Island Unit 2 Reactor Building Purge Program Safety Analysis andMetropolitan Edison Company,
Environmental Report,"from major metropolitan areas

November 13, 1979.

Docket 50-320,(PDR)*

Meetings were held with the Comnissioners and other officials from the four

Dauphin,

Lancaster, York, and Lebanon.

2.

Five briefings were also conducted in different

U.S. Nuclear Regulatory Commission, "Environmental Assessment for Oecontamination of the Three Mile
Island Unit 2 Reactor Building Atmosphere - Draft NRC Staff Report for Public Comment," USNRC Draft

geographic locations for elected officials from the Boroughs and Townships which surround Three Mile Island.

10.3

report NUREG-0662, March 1980.

(DTIDC)

Union of Concerned Scientists,"Decontamination

Press Conferences and Television and Radio Appearances3.

Harold Denton held several press conferences in central Pennsylvania,

one of which was held jointly with Governor

Thornburgh to discuss the Environmental Assessment.

Deputy Program Director,

John T. Collins,

appeared on several television and radio talk programs where listeners or panel
the Environmental Assessment.

These appearances

Report to the Governor of Pennsylvania, May 15,

of Krypton-85 from Three Mile Island Nuclear Plant," A
18oo. (PDR)

TMI Program Office,members asked questions concerning

4.

Letter from R. H. Vollmer,

NRC, to R. C. Arnold, Metropolitan

Building Atmosphere Cleanup,

by Mr. Collins were in addition to his numerous other television

Docket 50-320,

Edison Co.,

December 18, 1979.

Subject:

Reactor Containment

Subject:

Additional(PFR)

and radio interviews concerning a wide range of topics relating to activities at the TMI site.
S.

Letter from J.

NRC, to R. F. Wilson, Metropolitan

f. Collins,

Edison Co.,

Information Request for Preparation of Environmental Assessment,

Docket 50-320,

December 18,

1979.

(PDR)
A.

Metropolitan Edison Co.,

Letter from R. F. Wilson,

to J. F. Collins,

Questions on Reactor Containment Building Atmosphere Cleanup,

NRC, Subject:

Docket 50-320,

Response to 33

January 4,

198D.

(PDR)

7.

U.S.

Nuclear Regulatory Commission,

Environmental

0.

February 11, 1980.

U.S. Nuclear Regulatory Commission,
Appendix B, Table I.

10.

"Statement of Policy and Notice of Intent to Prepare a Programmatic(PDR)

U.S. Nuclear Regulatory Commission, "Order by the Director of the Office of Nuclear Reactor Regulation,"
DocketSO-320,9.

Impact Statement."(POR)
Rules and Regulations,

Metropolitan Edison Companyr "Technical Evaluation
April

11. U.S.

10. 1980.

Title 10, Code of Federal Regulations

Report for Submerned Demineralization System (SOS),"(PDR)

Nuclear Regulatory Commission,

Rules and Regulations.

Title 10, Code of Federal Regulationsof Production and Utilization Facilities," March 1975,"Licensing

Part 2D,(PL)

Appendix

I,"NumericalPart 50,

Guides for

Design Objectives and Limiting Conditions for Operation to Meet the Criterion as Low as Practicable forRadioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."

12.

U.S.

Environmental Protection Agency,

Part 190,

13.

License DPR-73,

Rules and Regulations,

Title 40,

Standards for the uranium Fuel Cycle,"Three Mile Island Nuclear Station,
Operating

14.

"Environmental

Unit 2,February 0, 1978.

(PL)

Code of Federal Regulations

January 1977.

(PL)

Environmental Technical Specifications,

Appendix B to

(PDR)

U.S. Nuclear Regulatory Commission, Regulatory Guide 8.8, "Information Relevant

to Ensuring That

Occupational Radiation Exposures at Nuclear Power Stations Will Be as Low as Is

Reasonably Achievable."I(PON, GPO)
*For information on document availability,

C-47

see Page 11-4.

I

11-3

11-2

15.

U.S.

Nuclear Regulatory Cow ission, Regulatory Guide 1.109, "Calculation of Annual Doses to Man from29.

American Cancer Society,30.

E. Pochin,

Available from ACS, New York.

"1979 Cancer Facts and Figures," 1978.

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50,
Appendix Lo'(POR, GPO)

184-190 (1975).

"The Acceptance of Risk," British Medical Bulletin 31, 3,

Availablefrompublic technical libraries.
16.

U.S. Nuclear Regulatory Commission, "Supplement to the Final Environmental
Mile Island, Unit 2," Docket 50-320,

Impact Statement for Three

USNRC Report NUREG-0112, December 1976.

(DTIOC)

31.

J. G. Kemeny, "Reportof the President's Commission on the Accident at Three Mile Island," U.S.

17.

U.S.

Nuclear Regulatory Commission,"Population Dose and Health Impact of the Accident at the Three Mile

Island Nuclear Station," USNRC Report NUREG-O558, May 1979.

32.

(DTIOC)

M. Rogovin and G. T. Frampton,

Jr.,(NRC Special Inquiry-Group),

Commissioners and to the Public," April 5,
18.

U.S.

Nuclear Regulatory Commission,

Rules and Regulations,

Part 100, "Reactor Site Criteria,"September 1,

1978.

U.S. Nuclear Regulatory Commission,"Standards

33.

Rules and Regulations,for Protection Against Radiation,"

June 1977.

U.S. Environmental Protection Agency,

MPR Associates,
Evaluation,"

Inc.,

(PL)

34:

U.S. Environmental Protection Agency,

U.S.

Docket 50-320,

September 14, 1979.

Nuclear Regulatory Commission,

Management,

35.

(PDR)

Systems, Structures,

Regulatory Guide 1.143,

Radiation Exposure in the United States," EPA Publication"Natural

Available from EPA, Washington,

DC.

International Conference of Radiology and Radiation Biology,

A. Weinberg,
cited inF. H. Schmidt and D. Bodansky,

University of Washington,"Design Criteria for Radioactive Waste

and Components Installed in

1976.

The Energy Controversy:

36.

(PL)

U.S.

Environmental Protection Agency,"Radiological

Impact Caused by Emissions of Radionuclides

A. Parson, R. C. Riepe,

and M. J.

Stephenson,

Oak Ridge National

Laboratory,"Use ofthe ORGDPSelective Absorption Process for Removal of Krypton from the Containment Building Atmosphere atThree Mile Island, Unit 2," May 6, 1980.

23.

24.

National Council on Radiation Protection and Measurements,"Krypton-R5 in

37.

B. P. Dohrenwend,

et a]., "Technicalthe Atmosphere - With Specific38.

P. S. Houts,

et al.,To the President's

Staff Analyses Report on Behavioral Effects:

Commission the Accident at Three Mile Island," October 1979.

Tennessee 37830.

"Health-Related Behavioral(PIR)

Impact of the TSI Nuclear Incident:

Report Submitted toReferences to the Public Health Significance of the Proposed Controlled Release at Three Mile Island,"the TMI Advisory Panel on Health Research Studies of the Pennsylvania Department of Health," Part I,

May 16,

April

1980.

(PDR)

National Council on Radiation Protection and Measurements,
Biological Significance,

25.

Available from SRNL, Oak Ridge,

into theAvailable from EPA, Washington, IC.

Air in the United States," EPA Publication 520/7-79-006 (1979).
J. R. Merriman, J.

July 15,

Seattle, Washington,

The Light Over Nuclear Power,

Light Water Cooled Nuclear Power Plants."(PDR, GPO)

22.

DC.

"Three Mile Island Unit 2 Containment Atmosphere Cleanup Alternate Systems

1974,
21.

"Estimates of Ionizing Radiation Doses in the United States," EPA

Available from EPA, Washingt6n,

Title 10, Code of Federal Regulations Part 20,

ORP/SID 72-1 (1972).
20.

"Three Mile Island, a Report to the(STIOC)

1979.

Title 10, Code of Federal Regulations(PL)

Publication ORP/CSO 72-1 (1972).
19.

(DTIDC)DC, 1979.

Government Printing Office, Washington,

and Control Technology,""Krypton-85

July 1, 1975.

National Academy of Sciences, Committee on the Biologicalin the Atmosphere

Accumulation,--

Available from NCRPM, Washington,

Effects of Ionizing

Radiations,

report) "The Effects on Populations of Exposure to Low Levels of Ionizing Radiations,"

39.

(POR)

C. B. Flynn, Mountain West Research,

Inc.,"Three Mile Island Telephone Survey:

Procedure of Findings," USNRC Report NUREG/CR-1R93, October 1979.

DC.

(1979 draft

1979.

1979.

40.

Memorandum from D. P. Cleary, to W. H. Regan,

Subject:

reporting on a telephone conversation of April 21,

(PDR)

1980,

Preliminary Report on(OTIOC)"TMI-2 Atmospheric Decontamination,"

May 1, 1980,

between B. P. Dohrenwend and 0, P. Cleary.

(POR)
26.

U.S.

Nuclear Regulatory Connission,"Reactor Safety Study --An Assessment of Accident Risks in U.S.

Commercial Nuclear Power Plants," Appendix VI, WASH-1400 (NUREG-75/UO4),

October 1975,(DTIDC)

41.

Memorandum from D. P. Cleary, to W. H. Regan,
1980,

27.

National Academy of Sciences, Advisory Committee on the Biological
Effects on Populations

Effects of Ionizing Radiation, "Theof Exposure to Low Levels of Ionizing Radiation," November

1972.

Letter from W. N. Aedeman, Jr.,

to R. H. Volimer,

NRC, Subject:

Addendums 1 and 2),

dated April 11,

1980.

May 27,

between G. J. Warhect and 0. P. Cleary.

(POR)

Draft Environmental Assessment for

Decontamination of the Three Mile Island Unit 2 Reactor Building Atmosphere,""TMI-2 Atmospheric Decontamination,"
1980,

(PDR)
42.

28.

Subject:

reporting on an telephone conversation of May 9,

A. Baum, "Psychological
USORC Draft Report.

Stress and Alternatives for Decontamination of Reactor Building Atmosphere,"

To be issued as a formal NRC report in June 1980.

(NUREG-0662 plus

(PDR)

43.

Science Applications,

Inc .,"Comparison of Controlled Purge and Application of the Selective Absorption

Process Alternatives for Decontamination of TMI-2 Reactor Building Atmosphere,"bound into Volume 2 of this Assessment.

C-48

May 1980.

A copy is

.iI

I"-

I-"-

'

on"i

'

n

I

12-1

11-4

NRC documents referenced iniX

this report are available from the following sources:(POR) - USNRC Public Document Room, 1717 H Street,

N.W., Washington.

DC 20555.

Available for inspection

and copying for a fee.
(DTIOC) - Copies are available for sale from the Publications Sales Manager,
and Document Control,

USNRC, Washington,

DC 20555.

12.

Division of Technical Information

Absorbed dose - The energy imparted to matter by ionizing radiation.

free of charge from the same address.
(PhR,

GPO) - Copies are available from the NRC PDR for inspection and copying for a fee,
Government Printing Office, Washington,(PL) - Available

from a public

G1ossarSingle copies of draft reports are available

DC 20402,

Attn:

Anticipated Operational Occurrence - Miscellaneousand from the U.S.

administrative error,

Regulatory Guide Account.

conditions or actions

such as equipment failure, operator error,that are expected to occur that are not of magnitude great enough to be considered an accident.

Background radiation - Radiation arising from natural radioactive materials always present in the environment,

library.

including solar and cosmic radiation and radioactive elements inrnals,and the human body.

the upper atmosphere,

the ground, building mate-In the Harrisburg area the background radiation level is about 125 mrem per year.

Beta parcticles - Charged particles emitted from the nucleus of a atom, with a mass and charge equal

in magnitude

to that of the electron.

CFM - Cubic feet per minuteControl rod - A rod containing material that absorbs neutrons; used to control or halt nuclear fission in a reactor.
Core - fhe part of a nuclear reactor that contains the fuel (fissionable material).
the region containing

CriticalIn a reactor like that at TMI,

fuel-bearing rods.

- ferm used to describe the capability of sustaining a chain reaction at a constant level.

Cryogenic Processinj- Low-temperatue separation processes whereby materials that are normally gases are isolated

and recovered from other gases by liquifying them at low temperatures.
Cubic Centimeter (cc) - Unit for measuring volume.
Curie (Ci) - The special unit of radioactivity.
ring in a given quantity of material

Approximately 947 cubic centimeters is equal

Activity is defined as the number of nuclear transformations occur-

per unit time.

Decay heat - Heat produced by the decay of radioactive particles;

in a nuclear

reactor this heat,

resulting frommaterials

left from the fission process, must be removed after reactor shutdown to prevent the core from over-heating.

See Radioactive decay.

Dose - Denotes the quantity of radiation or energy absorbed.
fied.

If unqualified,

Dosimeter - Dose meter.

Gamma raysit

For special purposes it

refers to absorbed dose.

See Absorbed dose.

An instrument

radiation dose.

that measures

Short-wave length electromagnetic

form of ionizing radiation.

C-49

to one U.S. quart.

must be appropriately quali-

See TLD.

radiation of nuclear origin emitted from the nucleus of an atom.

A

12-2

12-3

Half-life - The time required for half of a given radioactive substance to decay.

Radiation - Energy in the form of rays (light,

heat, X-ray,radio waves) sent out through space fros atoms andmolecules as they undergo internal change.
HEPA - High-efficiency particulate filter.
Radioactive decay - The spontaneous natural process by which an unstable radioactive nucleus releases energy or
Ionization - The process by which a neutral atom or molecule acquires a positive or a negative charge.

particles to become stable.

Ionizing Radiation - Any form of radiation that displaces electrons from atoms or molecules.

Radioactivity - The spontaneous decay of an unstable atom.

or molecule is an ion.

The resulting atom

Ions become electrically charged as a result of this process.

Krvptoo-8 - An inert noble gas (itdoes not interact chemically with other chemical

During the decay process,ionizing radiation isusually given off.
elements or compounds) with a

Reactor (nuclear) - A device inwhich a fission chain reaction can be initiated, maintained,

and controlled.

half-life of 10.7 years.
Reactor buildingLET - Linear energy transfer.

A measure of the capacity of biological material

MDA- Minimum Detectable Activity.

Meteorological

Minimum level

relating the concentration (Ci/mn)(Ci/sec)of radioactive material

Reactor vessel

which accounts for site-specific meteorologicalof radioactive materials,

at a given location,

The structure housing the nuclear reactor.

-

The steel vessel

containing the reactor core; also called pressure vessel.

Rem - A standard unit of radiation dose.

to a release rate-

Unit for measuring radioactivity.

One microcurie is one-millionth of a curie (1/1,0O0,00b).

-

Unit for measuring radioactivity.

One aillicurie is one-thousandth (1/1,000)

See curie.

SelectiveAbsorbtion Process
selected material

Millicurie (mCi)

Frequently radiation dose is measured in millirems for low-level

radiation; 1,000 millirems equal one rem.

at another location.
SCFM - Standard Cubic Feet Per Minute.

Microcurie (mCi)

Also called containment building or reactor

containment building.

of radioactivity detectable with monitoring instruments.

dispersion factor (X/Q) - A factor (seconds/m3)

data in

to absorb ionizing radiation.

(gas)

-

"Standard" refers to standard conditions of pressure and temperature.

A separation process whereby a liquid is used to selectively absorb (separate) afrom a source gas stream (air).

of a curie.
Source Term - Defines an amount of radioactive material.

Millirem (mrem)One

one-thousandth (1/1000)of a rem; see remTLO (thermoluminescentdosimeter)-

A solid-state device used to measure nuclear radiation doses.

See Dosimeter.

MPC - Maximum Permissible Concentration of radioactive exposure, as specified in Title 10 Code of Federal Regulations,

Part 20, Table B.

Tritium

Ruble gases - Inert gases that do not-readily react chemically withother elements.
neon,

krypton, xenon,

Nucleartest,

formed when wind currents flow over and around the object.

(NRC) - U.S.

agency responsible for the licensing,and research nuclear reactors,

regulation,and inspection of

X/Q - See Meteorological Dispersion Factor.

as well as nuclear materials...

Order of Magnitude - Within a factor of 10.

Person-rems - Ihe sum of the individual doses received by each member of a certain group or population.
calculated by multiplying the average dose per person by the number of persons.
is expressed in person-rems.

For example,

Consequently,

It isthe collective dosea thousand people each exposed to one mrem would have a collective doseof 1 person-rem.
PSIG - Pounds per square inch gauge.

A measure of the difference in pressure above or below normal

atmosphericpressure.

rad-radioactive isotope of hydrogen.

Wake-Cavity Effect - The region of turbulance immediately to the rear of a solid body,and radon.

Regulatory Commissioncommercial,

These gases include helium,-"A

The basic unit of absorbed nose of ionizing radiation.

A dose of one rad means the absorption of 100 ergsof radiation energy per gram of absorbing material.

C-50

like a building, that isAPPENDIX D. "ENVIRONMENTAL ASSESSMENT--USE OF EPICOR-II AT
THREE MILE ISLAND, UNIT 2," U.S. NUCLEARREGULATORY COMMISSION, NUREG-0591,
OCTOBER 3, 1979

D-1

NUREG-0591
ENVIRONMENTAL ASSESSMENT:

1.0

USE OF EPICOR-II AT THREE MILE ISLAND

Proposed Action
The proposed action is to use a system, EPICOR-II, for the cleanupof radioactive contaminated waste water which has accumulated in the
Unit 2 auxiliary, building tanks because of the March 28, 1979 accident
at Three Mile Island (TMI1.
The proposed action is limited to cleanup
and storage of such waste and includes the impact of temporary storage,
packaging, handling, transportation, and burial of the solid waste
generated from the cleanup operation using EPICOR-II.

ENVIRONMENTAL ASSESSMENTUSE OF EPICOR-II

This action does not include the disposal of the decontaminated waste.
As indicated in Section 2*0 below, the disposal of this water will becovered in a separate assessment.
In addition, treatment and dispositionof water in the reactor containment building will also be covered in a
separate assessment.

AT
THREE MILE ISLAND, UNIT 2This assessment is an evaluation of the effect that the proposed action
will have on the public health and safety, and on the environment including
a consideration of occupational exposures and the risk of accidental
releases, and a discussion of alternatives to the EPICOR-I1
system.

PREPARED-.BY
2.0

OFFICE OF NUCLEAR REACTOR REGULATION

Introduction
As a result of the March 28, 1979 accident at the TMI Unit 2 facility,
a significant amount of radioactive contaminated water has been generated
and collected in Unit 2 auxiliary builoing tanks.
This waste water was
produced primarily from the following four sources:(1) an inventoryof waste water existed in Unit 2 auxiliary building tanks prior to theaccident (approximately 130,000 gallons, some of which has been usedas makeup (makeup is water which is normally added to the reactor coolant
system for the purpose of controlling reactor coolant inventory) water
to the Unit 2 reactor); (2) during the early phases of the accident,
contaminated water from the reactor containment building sump was transported to the auxiliary building and collected in various tanks; (3)letdown. (letdown is water which is normally removed from the reactor
coolant system for the purpose of controlling reactor coolant inventory andchemical and radioactivity content; it is depressurized and cooled prior toreaching the auxiliary building tanks) from the reactor coolant system has
resulted in a net increase to the inventory; and (4) normal leakage fromU. S. NUCLEAR REGULATORY COMMISSIONOCTOBER 3, 1979

0-2

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-3

system components in the auxiliary building has been a small but continuous
source of waste water to the inventory which currently exists in all of
the auxiliary building tanks (approximately 280,000 gallons). The level ofcontamination of the water in these tanks ranges from less than 0.1 to 35
uCi/ml of Cs-137.
Because of the relatively short half-life of 1-131 (8.ldays) compared to that of Cs-137 (30 years), Cs-137 has become the oominantisotopic contributor.
The quantities and activity levels of the current
inventories in the auxiliary building tanks are discussed in Section
3.3.3.

waste water in the Unit 2 auxiliary building tanks using the EPICOR-I1
system. This assessment includes discussion of potential risk of planned(gaseous) and accidental (gaseous and liquid) releases, and a discussionof alternatives to the EPICOR-II system. It does not consider the disposition of the decontaminated water following use of EPICOR-II since
this is precluded pending an evaluation of the various disposal alternatives.
Use of EPICOR-II does not preclude implementation of thevarious disposal alternatives.
This assessment is the formalization of the evaluations and regulatory
guidance that have been provided at TMI from March 28 to the present.
During that period, and on a continuing basis, the NRC on-site support
staff has been engaged in design and safety evaluation of the licensee's
proposed means for processing intermeaiate-level waste water, including
an evaluation of the need for EPICOR-I1 (see Section 2.1).
The NRC
staff concurred with the licensee that design, construction, andoperation of EPICOR-II should proceed on a high priority basis. The
NRC staff has provided design guidance and criteria for the EPICOR-II
processing system, the building housing the system, the building exhaust
filtration system and the process vessel vent filtration system. The
NRC staff has monitored and inspected the design, construction, andpreoperational testing of EPICOR-II since its inception.
The
EPICOR-II system which has evolved from this regulatory effort has
been designed for remote receipt, handling, and processing of contaminated water from the TMI Unit 2 auxiliary building with minimal
occupational exposure and no adverse impact on the health and safetyof the public.

Following the March 28 accident, Metropolitan Edison Company (the licensee)
initiated the design and construction of a system, the design basis ofwhich was to decontaminate water with an activity level up to 100 uCi/llof 1-131 and Cs-137, the principal radionuclides present in the waste waterfor radiological dose considerations. As indicated in Table 2, theactivity level of 1-131 and Cs-137 in the water to be treated in
EPICOR-II is less than 40 uCi/ml.
The design and construction of anew processing system was necessary for the following reasons. The
existing liquid waste processing systems for Units 1 and 2 were designed
for processing water with significantly lower levels of activity thancurrently exist in the Unit 2 auxiliary building tanks. For example,
the expected reactor coolant concentration of Cs-137 during normal
operation of the plant is 0.018 uCi/ml or a factor of approximately
2,000 times lower than the highest Cs-137 concentration presently in
In addition, the contaminated condition
the auxiliary building tanks.
of the Unit 2 auxiliary building after the accident rendered the building
unusable for the purpose of continuous, planned processing of the invenThetory of waste water from the building radwaste control panel.
recognized need for a new processing system resulted in the developmentof the system which is now known as EPICOR-II.*

2.1

Need for Decontamination
The March 28 accident at TMI Unit 2 and subsequent recovery operations
have generated a substantial amount of contaminated water which iscontained in the reactor building and in tanks in the auxiliary building(see Section 3.3.3). Although these buildings are of high integrity
such that the contaminated water can be positively controlled for anindefinite period, there are several reasons why decontamination of thewater would be beneficial.
Available capacity of the tanks in the auxiliarybuilding'is needed in the event that pumping of water from the reactor
building is, necessary to protect the operability of reactor building components and systems which maintain continued safe shutdown of the facility.
The waste water in the auxiliary building continues to be a source of
exposure to personnel needing entry into the auxiliary building. The continued safe shutdown of TMI Unit 2 depends upon the operability of originalIn response to a complaint for injunctive relief filed by theCity of
Lancaster, Pennsylvania, in the United States District Court for theDistrict of Columbia, the United States Nuclear Regulatory Commission
directed its staff to prepare an environmental assessment regarding
proposals to decontaminate and dispose of radioactively contaminated,
waste water from the TMI 2 Unit 2 facility. The assessment is to be
divided into several portions of which this is the first. This portion
deals with the proposed decontamination of the intermediate-level***Epicor,-Inc., Linden, N.J.

**Intermediate-level waste is defined as waste having 1-131 and Cs-137
concentrations greater than 1 uCi/ml but less than 100 uCi/ml.

D-3

5 -

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plant equipment located in the auxiliary building and the use of adoitional
equipment being installed in the course of completing modifications inprogress.
The surveillance and maintenance of this equipment and personnel
exposures associated with these actions, which are necessary to assure maximum
reliability, are adversely affected by radiation levels associated with storedliquid.
Approximately 50 workers per day are currently provided access to theauxiliary building for decontamination, operations and construction purposes.
Although occupational exposure to these workers (approximately 10 mrem/worker/
day; or about 15 man-rem for each month that the situation remains unchanged)
is within regulatory limits, any reduction in dose resulting from the removalof radioactive water stored in the auxiliary building tanks is considered apositive action.
The total exposure from this source is primarily a functionof the elapsed time to deciding to remove and process the water.
The removal of stored contaminated water will have the additional benefitof permitting decontamination - now precluded by high radiation levels of some areas of the auxiliary building, including rooms housing reactor
coolant bleed tanks, neutralizer tanks, and the miscellaneous waste
holdup tank.
Therefore, it is important to process the inventory ofwater in the Unit 2 auxiliary building tanks in order to iniinobilize theentrained activity and thereby reduce potential souces of environmental
and occupational exposure and provide surge capacity for water transferredfrom the reactor building.
The EPICOR-Il processing system has been
specifically designed and constructed for the purpose of processing THI 2
intermediate-level waste water and represents the best alternative for desired
decontamination of that waste (see Section 5.0, Alternatives to the Use of
EPICOR-II).
3.0

EPICOR-Il System

3.1

Housing of EPICOR-II in the Chemical Cleaning Building
The EPICOR-II system is housed in an existing on-site structure called
the chemical cleaning building. This building was originally intended
to be usea in the chemical cleaning of the steam generators for TI41
Units 1 and 2.
It is a rectangular shaped building with dimensionsof 48 feet wide by 6U feet long by 52 feet high.
The foundation of
the building and the walls up to a height of 13.5 feet above thebasement floor are concrete and the upper walls and roof are ofstructural steel.
The foundation of the building is designed to seismic Category Icriteria (i.e., able to withstand the effects of the safe shutdown earthquake) as are the primary concrete walls and structural steel frame.

A floor drain system is incluoed in the design of the Chemical Cleaning
Building. The drain system routes leakage from pumps, and other components,
possible overflows from tanks, demineralizers, and the demineralizer/filter
to a lined stainless steel sump.
The floor of the Chemical Cleaning Building
and up to a height of three feet on the walls is covered with a strippable
coating.
In the event of a spill, decontamination of the floor can beaccomplished by flushing with clean water or a decontamination solution.
The containments and decontamination solution are then routed to the sumpfor processing.
3.2

Modifications for EPICOR-II
In order to convert the chemical cleaning building for use in decontaminating intermediate-level waste, several modifications were madeto the bui-lding.
These included the following:
1.

The installation of the EPICOR-II system (vendor supplied equipment)in the building. Specifically, a prefilter/demineralizer, a cation
bed demineralizer, a mixed bed demineralizer, precoat and chemical
addition tanks and associated pumps, pipes, valves, andinstrumentation for the EPICOR-II system;

2.

The addition of shield walls around EPICOR-II equipment. The shieldwalls were added for the protection of personnel involved in theoperation of this system (a description of the shielding is contained in Section 4.0);

3.

The addition of an overhead monorail hoist system. The hoist system
was provided for removal and replacement of the demineralizers
and prefilter/demineralizer.
The monorail system extends from thenorth side of the building above the prefilter/demineralizer throughthe south end of the building extending 18 feet outside the building
over a cask loading area at which point the shielded prefilter/demineralizer and demineralizer casks can be loaded onto a truck;

4.

The chemical cleaning building was made into a low leakage confinement building by spraying the interior of the structural steel
portion of the building with an epoxy sealant. The sealant wasadded to prevent air and radioactive material outleakage from thebuilding;

5.

The addition of an exhaust ventilation filtration system to maintainthe chemical cleaning building at a negative pressure.
This also
minimizes air outleakage and directs air flow through the filtration
system. This system includes filtration of the air through a

-

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- 6-

1. Processing pumps (5)The addition of a TV monitor control building directly adjacent to thenorthwest section of the chemical cleaning building. Since operationof the EPICOR-Il system is by remote means, this building is proVideo for remote system operations where the EPICOR-II system canbe controlled.
In addition, there are six TV monitors located at
different points in the chemical cleaning building to provide forremote viewing of the system during normal operation.

2.

Transfer pump3.

Prefilter/demineralizer ý containing precoat material and cation bed resin

4.

Demineralizers

5.

Miscellaneous waste holdup tank - located in the TMI Unit 2
auxiliary building.

6.

Clean wastes receiver tank (formerly the rinse hold tank)7.

Off-spec water receiving/batch tank (formerly
solution tank)

Design of the EPICOR-II System

8.

Chemical cleaning building sump pump

The EPICOR-I1 system is a liquid radwaste processing system supplied
by EPICOR, Inc. The system is designed to decontaminate by filtrationand ion exchange radioactive contaminated water contained in the auxiliarybuilding tanks of TMI Unit 2 and to transfer this decontaminated waterto Unit I or other tanks for storage. Plans are currently being formulated
to allow for the disposition of the decontaminated water from Unit 2.
Ion exchange is the process by which radioactive ions are removed fromsolution inthe contaminated water by resins in the ion exchanger.
The
use of filtration and ion exchange in the treatment of radioactive waste
water is standard practice in nuclear power plants and the principles uponwhich they are based are described in NUREG/CR-Ul411 and NUREG/CR-U1432,
respectively.

9.

Monorail hoist system

10.

Ventilation filtration system

6.

3.3

prefilter, a high efficiency particulate air (HEPA) filter, a charcoal
adsorber and a final HEPA filter. The purpose of this filtration
system is to remove radioiodine and radioactive materials inparticulate form present in the air before it is released to theenvironment.
A new building was constructed, directly adjacentto the east side of the existing chemical cleaning building, tohouse the air filtration equipment;

The EPICOR-1I system is designed to function in such a manner as to limit
gaseous releases of radioactive material to the environment to levels whichare "as low as is reasonably achievable," in accordance with 10 CFR Part
450.34a and 10 CFR Part 205.
In addition, it is designed to be operated
and maintained in such a manner as to maintain exposures to plant personnel
to levels which are "as low as is reasonably achievable," in accordancewith the guidance given in Regulatory Guide 8.86.
3.3.1

Description of the EPICOR-II System
The EPICORE-I1 system consists of the following components, all of which
are located in the chemical cleaning building except as noted. A functionaldescription of these components is given in the discussion below:(2)- one cation bed followed by a mixed bed

the chemical cleaning

A simplified flow diagram of the EPICOR-I1 system is shown in Figure 1.
The EPICOR-I1 liquid waste processing system operates at essentially atmospheric pressure in the following manner.
The miscellaneous waste holdup tank
(MWHT)is located in the auxiliary building of Unit 2 and receives water fromthe specific auxiliary building and fuel handling building tanks*.
Water
from tanks in the fuel handling building can be routed directly to the
EPICOR-I1
system, however, for operational purposes water stored in thefuel handling building will be routed through the (MWHT)to EPICOR-II.
Water in the Unit 2 auxiliary building tanks can reach the EPICOR-II system
only by being routed to theMWHT.
Prior to processing in EPICOR-Il, thewater is analyzed for radioactivity and chemical content to provide estimatesof activity buildup on the ion exchange resins and the need for required
chemical addition for system optimization.
The first processing pump is used to pump water from the MWHTto theprefilter/demineralizer in the chemical cleaning building through the yard
piping.
The piping is enclosed in a shielded guard pipe, the open end ofwhich terminates inside the chemical cleaning building.
The prefilter/demineralizer contains a precoat material which enables it to remove particulate
radioactive wastes (e.g., activated corrosion products) and other suspended
solids. The prefilter also contains cation bed resin which is highly
efficient for the removal of cesium and other cationic radionuclides fromthe waste stream (removal efficiency greater than 90%).
After passing*It was realized during the early planning stages after the accident that additionalliquid storage capacity would be required.
Space was available in the Unit 2 fuel.
pool to locate six storage tanks with a combined volume of 110,000 gallons.

D-5

- 9-

-8-

through the prefilter/demineralizer, the water is circulated by the processing pumps through the two demineralizers arranged in series. The first
demineralizer also contains cation resins which also makes it highly
efficient for removal of cesium and other cationic radionuclides fromThe second dethe waste stream (removal efficiency greater than 90%).
mineralizer contains mixed resins (cation and anion) which are efficient
for removal of both cationic and anionic radionuclides, including cesium andAfter processing, the water
iodine (removal efficiency greater than 90%).
is collected in the clean water receiving tank (CWRT)which has a capacityof 133,000 gallons.
In the CWRT the water will be sampled and analyzed
If the analysis shows that the processed
for nuclide identification.
waste contains concentration of radioactivity below predetermined limits,
the water will then be transferred to the TMI Unit 1 or 2 liquid waste
management system to be held for ultimate disposition. Those predetermined
limits will be specified in the system operating procedures and in theplant radiological effluent technical specifications.
Processed waste which
is not suitable for transfer to TMI Unit 1 or 2 liquid waste management
system will be pumped to the off-spec water receiving/batch tank (OWRT)
which has a capacity of 95,000 gallons. Water in this tank will berecycled through the EPICOR-II system for additional processing.
The monorail hoist system consists of a 20-ton hoist mounted on a monorailwhich extends from above the prefilter/demineralizer, across the top of thedemineralizers and to approximately 18 feet outside of the chemical cleaning
The purpose of the hoist system is tobuilding over the cask loading area.
provide for removal and replacement of the demineralizers and prefilter/demineralizers when they have reached the maximum radioactivity loading permitted by the operating procedures or become chemically depleted. The
radioactivity loading is limited by contact radiation dose rate readingson the vessel to meet personnel handling requirements as discussed in
Section 4.0. The operation of the monorail hoist system is done remotely byuse of a closed circuit TV system located in the control building adjacentto the chemical cleaning building.
The chemical cleaning building ventilation system maintains a negative
pressure in the building. The exhaust ventilation system consists of aheating unit, moisture separator, a filtration unit, a fan assembly, a
Building exhaust airradiation monitor, and a weatherproof enclosure.
is passed through a moisture separator and an bO KW heater to remove
moisture from the air and lower its relative humidity to improve theiodine-removal capabilities.
The air is then passed through thefiltration unit which consists of a prefilter, a high efficiency
particulate air (HEPA) filter, a charcoal adsorber and a final HEPA
filter. The HEPA filters are used to remove radioactive material
in particulate form, while the charcoal adsorber is used to remove any

D-6

The fan assembly draws
radioiodine that may be present in the offgas.
air from the building and exhausts it through ducting to a local stackat the roof line of the chemical cleaning building. The radiation
monitor installed in the discharge duct from the fan samples the air
in the fan discharge line. Measurement of the ventilation system exhaustraoioactivity is provided both locally and remotely in the control
building in the event that radiation levels in the effluent stream
exceed a predetermined level.
These predetermined levels will be specified in the system operating procedures and in the plant radiologicaleffluent technical specifications.
The chemical cleaning building sump is a stainless steel lined pit locatedAny water from process vesselin the northwest corner of the building.
A
overflow or from other equipment leakage is collected in the sump.
sump pump transfers water from the sump to the OWRT. The sump pumpstarts automatically on a high level indication in the sump.
3.3.2

Sources of Radioactive Water
The EPICOR-II system will process the approximately 400,000 gallons
of intermediate level waste water currently contained in TMI'Unit 2
auxiliary building tanks. Waste water that is acceptable for processingin the EPICOR-II system is that which has Iodine-131 and Cesium-137
Water
concentrations of less than 100 uCi/ml (intermediate level waste).
that has higher radioactivity than intermediate level waste will be thesubject of a separate environmental assessment. The tanks in TMI Unit 2
auxiliary building which are to be processed using the EPICOR-II system
are the following:
1. Reactor coolant bleed tanks (3);.2. Miscellaneous waste holdup tank;3.

Auxiliary building sump;

4.

Auxiliary building sump tank;5.

Neutralizer tanks (2);6.

Waste evaporator condensate tanks (2);7.

Contaminated drain tanks;

8.

Miscellaneous sumps (4);9.

Fuel Handling Building tanks; (tank farm).

-I11-

-10-

3.3.3

Volume and Activity of the Water to be Processed by the EPICOR-II System
Table 1 contains a listing of waste water inventories stored in TMI Unit 2
auxiliary building tanks which are intended to be processed by the EPICOR-II
system. Table 2 contains a listing of principal radionuclide concentrations
present in the waste water for radiological dose considerations for each of
the sources in Table 1. Table 3 lists the half-lives of the principal radi6nuclides listed in Table 2.
The liquid volumes are established from tank level measurements taken byplant personnel.
Activity levels are established from liquid samples
All liquids
analyzed by in-plant staff, as well as by Babcock & Wilcox.
processed through the EPICOR-II system will have activity levels of lessCs-137 will be the predominant and controllingthan 100 uCi/ml of Cs-137.
isotope at the time these liquids are processed.

3.4

5.

For the clean water receiving tank and the off-spec water receiving/
batch tank, an overflow line with a loop seal is provided near the
top of the tank. The overflow line routes any tank overflow to thechemical cleaning building sump.
Tank level indication is provided
on the control panel in the control building;6.

All system components which have flexible hose connections areprovided with drip trays to collect leakage.
Tubing from these drip
trays is routed to the nearest floor or equipment drain;

7.

All system liquid piping is welded stainless steel to prevent systemleakage.
All installed fittings and hoses have pressure ratings thatexceed the maximum discharge pressure of the pumps used.
All discharge
hoses have a pressure rating of 600 psig or greater. All hoses andfittings will be hydrostatically tested prior to use. Pump diaphragms
are designed to rupture at pressure greater than 125 psig.
Themaximum available air pressure to drive the pumps is 100 psig (thusprotecting diaphragm integrity).
All hose connections are taped andwrapped with plastic to contain drips from fittings.

8.

All auxiliary building tanks are vented and operate at atmosphericpressure.

Design Features for Spill Prevention
There are a number of design features built into the EPICOR-II system toprevent spills of radioactive water. The following is a listing of thesefeatures and a discussion of each:
1. The piping carrying radioactive contaminated water from the miscellaneous waste holdup tank in the auxiliary building through the yard
to the EPICOR-II system in the chemical cleaning building is enclosed
Radiation shielding has been
within a four-inch diameter guard pipe.
provided around the guard pipe to minimize personnel exposure (seeSection 4.0 for a discussion of radiation shielding and personnel
exposure);2.

All system overflow lines run to the chemical cleaning building
sump.
The sump pump routes all collected leakage to the off-specwater receiving/batch tank. The sump pump is started either
If pump start
manually from the control panel or automatically.
i's automatic, it occurs when the sump level reaches a presetheight.
A high sump level alarm is also provided on the control
panel in the control building;3.

Water level in the prefilter/demineralizer is maintained by a levelOn high level, an alarm will sound at theprobe and a solenoid valve.
pump control panel in the control building;4.

Level instrumentation in the demineralizers is similar to that for
The high level alarm for the demineralizer
the prefilter/demineralizer.
will annunciate in the control building;

There are also design features to prevent spills of radioactive contaminated water from the tanks in the auxiliary building which are to beprocessed in EPICOR-II.
These features have been previously evaluatedand found acceptable in the Safety Evaluation Report related to theoperation of the Three Mile Island Nuclear Station, Unit 2.7 As indicated in that document, these design features will include level instrumentation which will alarm in the control room, and curbs and drains which
Also, thewill collect liquid spillage and retain it for processing.
release of all processed liquids from TMI Unit 2 is through the TMI Unit 1
or 2 discharge lines. Piping systems are designed so that transfers ofprocessed water can be made between the EPICOR-II system, Unit 1, and Unit
2.
In addition the capability also exist for transferring water to onsite tanks outside the plant and not interfaced with discharge pathways.
Water transferred to Unit 1 or back to Unit 2 will be placed in tanks
and isolated from all other plant liquid systems. However, it is possible
for valves to leak and for operators to make errors in valve line-up andrecontaminate the processed water. To prevent the unauthorized releaseof liquids from the site, existing radiation monitors in the dischargelines from Units 1 and 2 which alarm and automatically initiate closureof discharge valves will be used.

D-7

-

- 13 -

12 -We have also evaluated the potential consequences of a pipe break in
the EPICOR-II system inside the chemical cleaning building.
From aradiological standpoint, the worst case pipe break is a break in theliquid waste inlet pipe to the EPICOR-II prefilter/demineralizer.
We
conservatively assumed that during the accident, the EPICOR-I1 system
operator would not monitor the system parameters for loss of liquid flow or.
processing pump shutoff from each of the three process vessels, or notice any
abnormalities on the remote TV viewing system. Further, we assumed thatthe entire contents of approximately 20,000 gallons from the miscellaneous
waste holdup tank would spill on the floor and partition iodine with afactor of 0.0075.
The partition factor (the ratio of the quantityof a nuclide in the gas phase to the total quantity in both theliquid and gas phases when the liquid and gas are at equilibrium) valueof 0.0075 is based on data presented in NUREG 0017.3
We assumed that the water is from the "C" reactor coolant bleed tank andthat the iodine concentration in the spilled water is 3 uCi/cc (thehighest concentration as of June 15, 1979).
The building air is ventilated through the chemical cleaning building air filtration system consisting of HEPA filters and charcoal adsorbers and the iodine is subjected
to an assumed decontamination factor (DF) of 20.
Assuming a conservative0
meteorological dispersion factor (derived from R. G. 1.4) . The calculated
inhalation thyroid dose to an individual at the site boundary is less than
0.001 of the 10 CFR Part 20 limit.
We have also consideredthe potential consequences of a failure of themonorail system resulting in the dropping of a liner of demineralizer~media
during liner transferoperations.
We conservatively assumed that, eventhough the liner is a carbon steel vessel, it ruptures when dropped releasing its contents to the truck loading pad. Since the demineralizer
media will be dewatered prior to removal, the contents will be a relatively
dry material which will remain on the loading pad.
In addition, we conservatively assumed that, even though there is no driving
force for the radioactivity to be removedfrom the resins, the iodine
partitions from the resin beads in a manner similar to that discussed'above
for water partitioning and becomes airborne:. Based upon the specificactivity of iodine on the resin corresponding to the iodine inlet
concentrations of 3 uCi/ml (the highest concentration as of June 15,1979) and the meteorology discussed above, the calculated inhalation
thyroid dose to an individual at the site boundary is less than 0.01 of
the 10 CFR Part 20 limit.

D-8

3.5

Design Features to Minimize Gaseous Releases
systemThere are a number of design features built into the EPICOR-I1
The following is ato minimize gaseous releases to the environment.
a listing of these features and a discussion of each:
1. The chemical cleaning building has been sealed with an epoxy sealant
to minimize both inleakage and outleakage of air;2.

An exhaust ventilation system has been added to the building to maintain the building at a negative pressure. This prevents ou'tleakageof air from the building and also routes any airborne radioactivity
in the building to the exhaust ventilation filtration system;

3.

The filtration system, consisting of HEPA filters and a charcoal
adsorber provides removal of radioactive particulates and radioiodine, respectively, from the building air before it is released
to the environment;

4.

A radiation monitor in the ventilation system ductwork provides anindication of radiation levels both locally and in the control
In addition, the radiation monitor will provide an alarmbuilding.
if the radioactivity in the release exceeds a predetermined level(this predetermined level will be specified in the system operatingprocedures and in the plant radiological effluent technicalIn.this manner, releases of radioactivity will be
specifications)..
carefully controlled within the predetermined limits set forth in
the system operating procedures and the plant radiological effluent
technical specifications;

5.

Within the plant, the system tank vents are provided with in-line
heaters, moisture separators, HEPA filters, charcoal adsorbers, andThe
HEPA filters to adsorb evolved iodine and remove particulates.
vents from the prefilter/demineralizer and demineralizers are vented tothe off-spec water receiving/batch tank;

6.

The building sump will be a covered sump.

We have calculated gaseous releases as a result of operation of the EPICORII system based on the design capabilities of the system and the contaminants in the .waste water. Based on these. calculations, we estimate therelease of Xe-133 will beless than 1 Ci and the release of 1-131 will beless than 1 x l0-4 Ci as a result of-processing all of the auxiliarybuilding water- The off-site dose, as a result of such releases, would be
insignificant (i.e., a total body dose of less than 0.0001 mrem and athyroid dose of less than 0.01 mrem; these doses are l.ess than 0.Ul%
and 0.1%, respectively, of the total body and thyroid dose design
objectives of l1 CFR Part 50, Apendix INi).

ff71 ld-mwýý- 14 -

15 -At the time of the initial writing of this environmental impact assessment
iodine-131 and Cs-137 were the principal radionuclides considered forradiological dose considerations.
As of September 28, 1979 approximately
ten half-lifes for iodine 131 have passed, thus removing iodine-131 fromthe waste.
The dissolved noble gases of xenon have likewise decreased toinsignificant levels due to radioactive decay.
Since the only release
pathway considered in this assessment are gaseous releases, the removal byradioactive decay of iodine-131 and short half life noble gases have further
reduced the risks of possible releases via the gaseous pathway.
The
calculated gaseous releases provided above establishes bounding values for
estimating the maximum impact of 1-131 and Xe-133 releases.
Due toradioactive decay the impact of off-site doses will be significantly lessthan the calculated values above.
The basis used for estimating bounding
values follows:

3.6

4.0

0

1h -0M 0inh MMErI.

Data obtained on nuclide activity levels in the reactor coolant andthe reactor coolant bleed tanks as of June 15, 1979;

2.

Data on EPICOR-II system flow rate and chemical cleaning building
ventilation rate;

3.

Design of charcoal adsorbers on the off-spec receiving tank ventand in the chemical building ventilation exhaust filtration system.

The EPICOR-II facility has radiation monitors mounted inside the leadbrick walls around the prefilter/demineralizer and the demineralizers.
The design criteria call for the prefilter/demineralizer to be changed
if the prefilter/demineralizer reaches a dose rate at contact ofThe cation bed demineralizer, mixed bed demineralizer,
1000 rem per hour.
strainer, and post-filter will be changed when dose rates at contact
We estimate that there
reach 400, 20, 3, and 3 rem per hour,-respectively.
will be approximately 50 changes of prefilter/demineralizers and demineralizers as a result of EPICOR-II processing of the intermediate level
waste water in the auxiliary building. This estimate is based on theprefilter capacity and the demineralizer ion exchange capacity.
The totalvolume of solid radwaste generated is estimated to be approximately
2500 cubic feet based on 50 changes of prefilter/demineralizers anddemineralizers.

Conformance of EPICOR-II System Desiqn with NRC Requlatory Guides
1.

The EPICOR-I1
liquid waste processing system and building housing
the system meet the design criteria of Regulatory Guide I.143.9

2.

The building ventilation system for the building housing EPICOR-II
is designed in conformance with Regulatory Guide 1.140.1O

3.

The effluent monitor for the building ventilation exhaust system
for EPICOR-II is in conformance with the requirements ofRegulatory Guide 1.21.11

4.

The radiation protection design of the EPICOR-II system, the chemicalcleaning facility, and the spent filter and resin handling systems are
consistent with the guidance of Regulatory Guide 8.8, "Information
Relevant to Insuring that Occupational Radiation Exposure at Nuclear
Power Systems will be as Low as is Reasonably Achievable."Concrete shield walls, 12 inches thick and 13.5 feet high, surround the
EPICOR-I1 processing area.
The prefilter/demineralizer is installed inside
a cylindrical concrete cask, 12 inches thick.
The cask is then surrounded bya rectangular lead brick wall, 5 inches thick.
The top of the prefilter/demineralizer is covered with a portable lead shield.
The prefilter/demineralizer is also covered by a steel lid, 5 inches thick. The lid has
is installedThe
cationbed
demineralizer
cutouts for the hose connections.
inside a cylindrical concrete cask, 12 inches thick. The cask is surrounded
by a portable lead shield and by a steel lid, 5 inches thick. The lid has
cutouts for hose connections.
Shield collars will be installed around thepipes in these cutouts on the prefilter/demineralizer and cation demineralizer.
The mixed bed demineralizer is also surrounded by a rectangular lead brick wall,
3 inches thick. The strainer is shielded with 8 inches of concrete block.
The feed line
The post-filter is shielded with 3 inches of lead brick.
from the TMI Unit 2 auxiliary building is shielded by lead bricks, 4 inches
The shield bell used to transfer the spent prefilter/demineralizer
thick.
and cation bed demineralizer onto the transport vehicle and cask provides
3-1/2 inches of lead shielding.
Concrete walls, 24 inches thick,separate the rooms through which the building is accessed from the room
A water box
containing the prefilter/demineralizer and demineralizers.
window, 18 inches thick, is included in this wall to allow direct viewingof the system from a shielded area.

The truck which is used to transfer the spent prefilters/demineralizers
and demineralizers to a temporary on-site storage facility has a cylindricalreinforced concrete shell 15 inches thick. The transfer shield bell holding

Occupational Exposure
A design criterion for the facility was that occupational exposure should
be maintained "as low as is reasonably achievable." Therefore, the design
was made consistent with the guidance of Regulatory Guide 8.8. The sections
below describe the design and operational features included to minimize
occupational exposure.
The anticipated dose rates and occupational exposures
are also described.

D-9

-

- 17 -

16 -the spent prefilter/demineralizers or cation bed demineralizer will be
The mixed bed
placed inside this concrete shell for additional shielding.
demineralizer will be lifted into this shell without a transfer bell.
After transport from the chemical cleaning building to the temporary onsite storage facility, the spent filters and liners will be transferredfrom the tranfer bell to individual shielded cells for temporary storageprior to shipment to a low level waste burial facility. As shipping casks.
become available, the liners will be hoisted from the storage cell into thetransfer bell, and, thence, to a licensed shipping cask for off-site disposal
in an approved facility.
The control building for EPICOR-II is located outside of the chemicalcleaning building. The operators can control the system in the facility
from this control building by means of remote cameras, controls andUsing the crane and transfer bell, thereadouts from instrumentation.
spent prefilter/demineralizers and demineralizers can be removed from thefacility without entering the.EPICOR-Il room. Since the hose connections
and disconnection of the prefilter/demineralizer and demineralizer process
vessels will require direct handling by personnel, quick connect/disconnect
Ladders will be provided to facilitate accesshoses and caps will be used.
to the tops of the prefilter/demineralizer and demineralizers to makeconnections. Features are included to allow flushing of piping and hoses
and to allow sampling to be performed from the outside of the EPICOR-IIroom.
The operators for EPICOR-II will be trained in the operations of the system.
This training will include numerous trial operations of the various systems
before radioactive water is processed. The EPICOR-II system uses thesame type of equipment that the operators are already experienced inoperating. Coverage by health physics personnel will be provided whenever the EPICOR-Il building is accessed.
Based on the contact dose rate limits on the prefilter/demineralizer anddemineralizers, the shielding provided for the process vessels, and thethickness of the lead brick walls, the following is a discussion of estimatedradiation dose rates.
The estimated radiation dose rates outside of the lead brick walls sur-.
rounding the prefilter/demineralizers, cation bed demineralizer and mixed
bed demineralizer are 30, 1 and 10 millirem per hour, respectively. The
estimated dose rate on top of the steel cover plates above the prefilter/
demiperalizer and cation bed demineralizer is 100 and 40 millirem per hour,
respectively, with approximately I rem per hour above the cutouts due tostreaming.
The estimated dose rate above the mixed bed demineralizer

D-10

is 20 rem per hour.
The estimated dose rate at contact with the strainer
The estimated maximum dose rate outside
and post-filter is 3 rem per hour.
the facility is 1 millirem per hour except during prefilter/demineralizer
The estimated dose rate outside of theor demineralizer removal by crane.
the facility is I millirem per hour except during prefilter/demineralizer
or demineralizer removal by crane. The estimated dose rate outside of thetransfer bell is 60 millirem per hour with the prefilter/demineralizer inthe bell and 25 millirem per hour with the cation bed demineralizer in thebell.
The estimated dose rate outside of the shield shell on the truck is
4 millirem per hour with the prefilter/demineralizer in it, 2 millirem
per hour with the cation bed demineralizer in it, and 700 millirem per
The estimated dose rate athour with the mixed bed demineralizer in it.
a distance of 50 feet from the truck for each type of vessel is less than
1 millirem per hour. For a very short time during placement into andremoval from the truck or storage cell, the mixed bed oemineralizer could
have a maximum dose rate on contact of 20 rem per hour. As discussed in
Sections 5.2.1 and 5.2.2, the estimated dose rate in both the interim
storage facility and concrete storage facility areas is 5 millirem per/hour.
To reduce occupational exposures in the interim storage facility
and concrete storage facility areas, these areas will be roped off, thus
In this way, there will be very
not permitting normal personnel access.
low levels of occupational exposures while the liners are stored onsite.
The estimated maxinmum dose to an individual at the site boundary on acontinuous basis is less than 1 millirem. This dose includes all of thehandling operation and is less than 4% of the 25 millirem annual limit
in 40 CFR 190.
Disconnections of hoses and capping of spent prefilters/demineralizers
and demineralizers will be the highest occupational dose activity
These activities require direct
associated with EPICOR-II operation.
handling by personnel in radiation fields above the prefilter/demineralizer,
cation bed demineralizer and mixed bed aemineralizer of 1OU millirem perhour, 40 millirem per hour and 20 rem per hour, respectively. Althoughradiation levels above the cutouts in the steel plates above the prefilter/demineralizer and cation bed demineralizer will be higher due to streaming,
use~of proper tools for disconnections will make exposure to thesestreaming fields unnecessary. We estimate that a prefilter/demineralizer
or demineralizer can be disconnected and capped by a trained operator inan average time of about 30 seconds.

S- 18 -- 19 -

Based on the frequency that these activities will be necessary, we estimatethat operation of EPICOR-II will cause 1-5 man-rem of occupation dose.
This exposure can be related to an increasd cancer death probability byuse of the linear, non-threshhold, dose-rate independent, dose-effectrelationship. This relationship defines the robability that an individual
dies of cancer from radiati n exposure as 10-l per year-rem.
This results
in a probability of 5 x 10-' per year that someone dies of cancer from the
5 person-rem occupational exposure, a number much closer to zero than to one,hence, it is expected that no cancer deaths will result from this exposure.
This estimate includes all activities involved in the operation of
EPICOR-JI, the handling and transfer ofliners to and from the temporarystorage facility, up to the time when the spent prefilter/demineralizer
liner and cask or spent demineralizer liner and cask is loaded on the truck
for shipment to an approved burial facility. This estimate is a very small
percentage (less than 1%) of the total annual occupational dose at a nuclear
power plant. The dose to individuals involved in the operation of EPICOR-I1
will be within the limits of 10 CFR Part 20 and maintained as low as isreasonably achievable.
The dose to individuals will be of similar magnitude
to that normally received by individual workers at a nuclear power plant (i.e.
approximately 700 millirem/year).
5.0Management of Solid Waste

5.1

Introduction
The operation of EPICOR-II will generate approximately 50 liners ofdewatered solid waste (prefilter media and ion exchange resin) which will
require on-site handling, temporary on-site storage, packaging, transportation, and ultimate burial in an approved low level waste burial
facility. The prefilter media and ion exchange resins will be changed
well before any resin degradation could occur due to radiation levels.
The 50 liners will include approximately 32 prefilter/demineralizer
liners, 8 cation bed liners, and 6 mixed bed liners.
The prefilter/demineralizer and cation bed liners are 4' diameter by 4' high cylindrical
vessels and the mixed bed liner is a 6' diameter by 6' high cylindrical vessel.
Since spent liners will be generated at a faster rate than they can be packaged
and shipped off-site, due to limited shipping cask availability, they will
be temporarily stored in an on-site facility and shipped as casks become
available. An interim storage facility has been constructed for temporary
on-site storage of spent liners until a larger concrete, weather-protected(from freeze-thaw cycles) facility can be constructed (estimated completionis November 1, 1979).
The NRC on-site staff has provided design criteria

and guidance for both storage facilities from initial conceptual design to
For the interim storage facility, the staff profinal design approval.
vided daily monitoring and inspection of the construction activities toensure conformance with design criteria.
5.2

On-Site Storage of Solid Waste

5.2.1

The Interim Storage Facility
An interim storage facility has been constructed in the Unit 2 cooling
tower desilting basin whicn can provide shielded storage for 28 spent
The facility is located inside
liners from the operation of EPICOR-lI.
the diked area of the station and is protected against the station design
The facility
basis flood (1,100,000 cubic feet per second of river flow).
consists of sixteen cells 4.5' in diameter by 8' high and twelve cells 7'
The smaller diameter cells are sized to accommodate
in diameter by 8' high.
spent prefilter/demineralizer and cation oemineralizer liners from EPICOR-I1
and the larger diameter cells are sized to accormmodate the spent mixed bed
The cells consist of galvanized corrugated metal
liners from EPICOR-Il.
cylinders which have been provided with welded steel plates to act as abase. The base plates are painted on the outside surface to inhibit
metal corrosion and the cylinder/plate weld joint was epoxied for thesame purpose. The inside surface of the cell is coated, up to a heightof several feet, with a special paint that permits the surface to be
In addition, each cell is provided with. aeasily decontaminated.
galvanized'drip pan in which the liner is placed to collect any leakage
or arippage. The leak integrity of the liner, the cells and the drip pan
will prevent migration of radioactivity from the liners to the groundwater.
In addition to that protection, a well will be drilled in the proximity ofthe storage facility which will be monitored to assure that no activity
The cells are placed on
migrates from the liners to the groundwater.
compactedearthen fill in the Unit 2 desilting basin and backfilled withcompacted earth to provide stability and shielding for the cells. The areaaround the cells is provided with a gravel base and topped with several
The area around the cells is also graded to direct
inches of asphalt.
rain water away from the cells. Each cell is provided with a 16-ton
The storage cell and plug
rectangular concrete shield plug (3' thick).
are designed to limit the contact dose rate to 5 mrem/hr or less. Alltransfers of spent liners into and out of the storage cells, incluoing
removal of and placement of the shield plugs, will be made with a mobile
crane (100-ton capacity with 110' boom) which is dedicated to the facility.
We considereo the effect of oropping of a liner in the interim storage
facility. The radiological effect of this accident will be the same as
the liner drop accident in Section 3.4.

D-II- 21 -

- 20 5.2.3
5.2.2

The Concrete Storage Facility

All solid waste from the operation of EPICOR-II will Le packaged andtransported in accordance with existing DOT and NRC regulations (i.e.
49 CFR Parts 171-179 and 10 CFR Parts 2U and 71) to a licensed burial
facility for-ultimate disposition. Section V-E of the Final Environmental
12
for Three Mile Island Nuclear Station, Units 1 and 2,
Statement (FES)
provides a discussion of the potential hazards associated with the transport of radioactive materials and estimates of the radiological impact tomembers of. the general public.
Section 5.4 of the Final Supplement(NUREG-o112) to the FES, dated December 1976, provides an update of thisThe planned shipment of packaged solid waste from the operation
discussion.
of EPICOR-II does not alter the discussion of the radiological impact
associated with the transportation of solid waste already provided in the
FES and the supplement to the FES.

The concrete storage facility will be a modular structure with each module
consisting of approximately 60 storage cells. The modules will be built
The module will be located in the proximity of theon an as-needed basis.
interim storage facility and sufficient space exists to construct up to
The module design will resemble a rectangular-shaped consix modules.
crete tube with dimensions of 57' wide by 91' long by 19' high. The
module base will be 3' thick and walls will be 4' thick for required shielding
The concrete storage facility(i.e. less than 5 mrem/hr from all surfaces).
is also located in the diked protected area of the station and is protectedfrom the station design basis flood.
In addition to the dike, the elevation of the structure will be sufficientto accommodate the station design basis flood. The module cells willconsist of concrete shielded, galvanized, corrugated steel cylinders withwelded steel base plates. The cell dimensions will be 7' in diameter by
The top shielding for the cells will be 3' thick rectangular
13' high.
concrete plugs. The plugs will be needed to prevent rain water inleakage
to the cells. The cell interior surface will be painted with a coating
The leak integrity of the liner
which will facilitate decontamination.
and the cells will prevent migration of radioactivity from the liners To
In addition to that protection, the cell base plates will
the groundwater.
be provided with a drain line leading to a sump to collect washdowns or liner
The sump will hold approximately IOO gallons and will be equipped
drippage.
All liquids collected inwith level indication and alarm on high level.
the sump will be sampled and analyzed for radioactivity, and processed as
Non-radioactive sump water (forrequired (for example, through EPICOR-I).
example, rain water) will be discharged through a radiation monitor to thestation drainage system. The sump will be designed to the seismic criteria
of Regulatory Guide 1.143. The module will be serviced by the same mobile
crane which is utilized for the interim storage facility. The module will
be capable of housing-one liner 6' in diameter by 6' high per cell or two
liners 4' in diameter by 4' high per cell, thus providing considerable
flexibility in the storage scheme. All liner transfers into or out of thecell will be as described for the interim storage facility. The module
will be designed to protect the stored liners from the freeze-thaw cycle
Shipment of liners to an
and the sump will be protected from freezing.
approved burial facility will occur as licensed shipping casks become
available.
We considered the effect of dropping of a liner in the concrete storage
The radiological effect of this accident will be the samefacility.
as that discussed for the liner drop accident in Section 3.4.

D-12

Packaging and Transportation of Solid Waste

5.2.4

Burial of Solid Waste
Section 5.4.3 of the Final Supplementto the FES provides a discussionof the environmental effects of the uranium fuel cycle, including burialof solid waste.
The planned burial of solid waste generated from theoperation of EPICOR-II does not alter the discussion of the impact
associated with the burial of solid waste already provided in the
supplement to the FES.

6.0

Alternatives to Water Processing and the Use of EPICOR-Il
There are three basic alternatives for handling the TMI Unit 2 intermediatelevel radioactive waste water. One is transport of liquids offsite, a second
is continued storage of liquid in TMI Unit 2 auxiliary building tanks, andFirst,
the third is processing to clean-the water for ultimate disposition.
Becausewe considered the shipment of contaminated water directly off-site.
of the hazards involved, such as potential spillage due to transportation
accidents and shielding requirements, and because the low level waste burial
grounds will not accept free liquid wastes for burial, the staff concludes
that packaged liquid wastes would not be an acceptable alternative.
The second alternative considered, the continued storage of water ineither the TMI Unit 2 auxiliary building tanks or additional new storage
tanks, would result, first of all, in a continued accumulation of occupational exposure in order to maintain the plant in a safe shutdown
condition.
The continued storage of I.iquid in the TMI Unit 2 auxiliarybuilding tanks, or in additional new storage tanks, represents a sourceof direct ano airborne radiation to the workers who must occupy theauxiliary building to maintain the plant in a safe shutdown condition
including such activities as taking samples, making plant modifications,operating the gaseous radwaste system, taking radiation surveys, performing

- 22 -

- 23 -

maintenance activities on system components, and decontaminating theaffected areas of the entire building. The worker problems associatedwith water storage are exacerbated by required water movements due towater inleakage or the need to move water from one tank to another toprovide surge capacity. The staff estimates this is presently resulting
in an occupational exposure of about 15 man-rems for each month this situation remains in its present state.
Furthermore, the inability to perform
required maintenance activities in the auxiliary buidling has an ultimate,deleterious impact on releases of radioactive materials in gaseous effluentsto the environment because of leakage from components which contain affectedgas.
Second, and more important, there is little remaining surge capacity
for additional liquid waste left in the TMI Unit 2 tanks. As of July 3, 1979,
a total of about 280,000 gallons of waste water had been collected in TMI
Unit 2 tanks, leaving approximately 25,000 gallons of available surge capacity.
(The surge capacity is the amount of tank storage capacity available
to receive additional inputs).
With daily water inleakage rates ranging
from 0.2 to 1.0 gpm from components within the auxiliary building, the waste
water inventories are increasing on a daily basis- further reducing theavailable surge capacity.
If surge capacity is lost, this creates potential
problems such as tank overfloVs, system spillage, etc.. Available surge
capacity is needed not only for daily inleakage; but also for receipt ofcontainment building water, should the need arise for transfer.
The levelof water in the containment building is also rising (due to continuouscomponent leakage) and poses a threat to components in the lower
elevations of the building.
Should a contingency arise, some water inthe containment building may have to be transferred to available TMI
Unit 2 tankage to prevent the failure of components necessary for thecontinued safe shutdown and rehabilitation of the facility.
Storage of water could be accomplished in additional new storage tanks,
which would have to be constructed especially for this purpose, butthese new storage tanks would represent a source of occupational exposure
similar to that for the Unit 2 auxiliary building tanks.
In addition,
the addition of new tanks would do little to relieve the inmediate surge
capacity problem discussed above since it would take a long period of time
to construct tanks, and a building to house these tanks, which would
meet the design criteria required for components to hold this radioactive
water.
The third alternative is processing the water to remove the radioactivity.
By processing the waste water in the auxiliary building tanks, the major

D-13

source of direct and airborne radiation is removed and chemically boundon an immobile matrix (i.e. prefilter and resin material).
Processingof waste water also reduces the likelihood of tank overflows (dueto limited surge capacity) and subsequent transport of the contamination to the environment.
There exists three (3) options for processing
the water:
1. Existing Radwaste Systems
TMI Unit 2 water can be processed in the existing TMI Unit 1 or 2
radwaste systems.
However, since these systems are not specificallydesigned for handling intermediate-level wastes, the systems are notcapable of producing water of sufficient quality for discharge.
In
addition, the overall recovery would likely be delayed since water
recycling back through the system would have to occur to achieve
water capable of satisfying release requirements.
The effects of
the overall accident would be expanded to equipment and plant systems(Unit 1) not now exposed to the accident produced intermediate-level
waste.
2.

New EPICOR-II Radwaste System
The new EPICOR-I1 Radwaste System is specifically designed to processintermediate-level waste and, therefore, it is capable of producing
discharge quality water by means of a proven technology (i.e., ion
exchange methodology).
The system is operational allowing a recovery
sequence to proceed in an orderly, timely fashion.
Although it is a
newly constructed system, sufficient time is available to fully test it
and demonstrate its operability, reliability, and operator proficiency.

3. New Radwaste Systems
The most viable alternative to a filtration/demineralization process
for the cleanup of intermediate-level waste is the process ofevaporation and subsequent condensation of the distilled water.
An
evaporation process was rejected on the basis of the long lead timerequired to make the system available (at least six months).
In
addition, systems employing evaporators are not as reliable asfiltration/aemineralization systems due to such evaporator problems
as pump failure and tube failure, resulting in evaporator outages
3
approximately 30% of the time.
Thus, a system employing
evaporators would be less efficient in reducing the large inventoryof intermediate-level waste.
Based on operating experience at otherplants, the required additional maintenance on an evaporator system
due to the evaporator outages would result in higher occupational
exposures than for a filtration/demineralizer system. Special design
provisions could mitigatge this difference, however.

- 24 --

It is therefore concluded that protection of the public health and safety
would be enhanced by the processing of the contaminated water to the
maximum extent possible since ifmmobilization of the activity currently
held in the liquid would render this activity a less likely source of
public or occupational exposure.
It is also concluded that the bestalternative is to process intermediate-level waste through a system
specifically designed for that purpose, namely, the EPICOR-II processing
system.
The earlier the decision to proceed with water processing(irrespective of the method) is made, the less the total accumulated
exposure, occupational and public, is likely to be.
Once the water isremoved from the auxiliary building tanks , the dose resulting fromthe ultimate decontamination of structures and components will be
incurred regardless of the method used for processing of the water.
7.0

Evaluation of Impacts

9.0

Summary
Our evaluation supports the conclusion that the proposed EPICOR-II
system is acceptable because:
1. The design of the EPICOR-I1 system meets or exceeds the guidance
given in Regulatory Guide 1.143, 1.140 and 1.21;
The system design is such as to prevent spills of radioactive water;even in the unlikely event of a spill, our evaluation of the consequences of this event show that they are insignificant;3.

The system design is such that releases of radioactive material ingaseous effluents will be insignificant;

The design and operational considerations to minimize occupational
exposure are consistent with the guidance given in Regulatory Guide 8.8;5.

The occupational exposure due to system operationand handling andstorage of solid waste corresponds to less than 1 percent of thenormal annual average for a nuclear power plant;

6.

The dose at the site boundary due to direct radiation from the system
operation and handling and storage of solid waste will be a small
percentage of the limits of 40 CFR 190.

Conclusion
We have determined, based on this assessment, that the proposed use of
EPICOR-I1 for the processing of contaminated waste from the TMI Unit 2
auxiliary building will not significantly affect the quality of thehuman environment. Therefore, the Commission has determined that anenvironmental impact statement need not be prepared, and that, pursuant
to 10 CFR 51.5(c), issuance of a negative declaration to this effectis appropriate.

Since the major source of direct and airborne radiation in theauxiliary building will be removed by processing the intermediate-level
waste water through EPICOR-Il, the occupational exposure would be lessthan the exposure incurred by leaving the waste water in storage.
Also,
by processing the waste water to allow for component maintenance anddecontamination activities, the off-site releases in gaseous effluentscan be reduced from current levels. Therefore, we conclude that theprocessing of the auxiliary building contaminated water through
EPICOR-II will not have an adverse impact and will probably lessen
the impact of the already contaminated water.

2.

4.

Based on our estimate of gaseous releases during operation of the EPICORE-Il
system, including a release due to an accidental spill, and our estimateof occupational dose and our estimate of direct radiation off-site, we conclude that the operation of this system does not constitute a significant
We further conclude that the health and safety ofenvironmental impact.
the public will not be endangered by operation of the system in the proposedmanner and that such activities will be conducted in full compliance with
the Commission's regulations.

The processing of contaminated waste by the EPICOR-II system willentail exposure to workers as described above and releases of small
amounts of Xe-133 and 1-131 to the environment.
Occupational exposuresof less than 5 man-rem constitute about I percent of the anticipated
man-rem exposure for one year of normal facility operation.
Off-site
exposure is expected to be less than one mrem which is well withinapplicable NRC and EPA guidelines.

8.0

25 -

D-14

0

Un

'0n
rC

CO

0

ý0

co

mo

0•

0•

CD
0>

r)

-4
so
I-

1-03

oc

0)

E

0)0

o•'
CO

0 m 1'00

0L La
I-.
W

-(0c4

so

ý2

FROM
UNIT 2
TANKS

I

YARD

GLARI

•1

PIPE

0

TO UNIT 1
FOR ULTIMATEDISPOSITION
LIQUID WASTE FLOW PATHS

I---VENT

I
I
I
I

--

HEADER

OFF-SPEC

CLEAN

WATER
RECEIVING
TANK

WATER
RECEIVINGTANK-ATMOSPHERE

I
I
I
I

CHEMICAL CLEANING BUILDINGGASEOUS WASTE FLOW PATHS
Figure 1. Flow Schematic of EPICOR II Processing System

LEGEND:
H = HEPA FILTERC = CHARCOAL FILTERF = FANTABLE 2
TABLE 3

CONCENTRATIONS OF PRINCIPAL NUCLIDES IN TMI UNIT 2
AUXILIARY BUILDING TANKS TO BE PROCESSED BYEPICOR-I1 CORRECTED FOR RADIOACTIVE-DECAY TO 6/15/79
uCi/mlRADIOACTIVE HALF-LIVESOF PRINCIPAL NUCLIDES

Reactor Coolant
Bleed Tank A

Reactor Coolant
Bleed Tank B

Reactor Coolant
Bleeo Tank C

1-131

1.9

2.8

3.0

Cs-134

6.5

7.6

7.7

Cs-1 36

0.28

0.29

0.28

Cs-1 37

28

.35

35

Ba-i 40

O.U9

0.3

0.29

H-3

0.23

0.27

0.29

Radioactive Hal f-Lives

Neutralizer
Tank A

Neutralizer
Tank B

Miscellaneous Waste
Holdup Tank Auxiliary
Building Sump andSump Tank; Miscellaneous Sumps

1-131

0.15

0.18

1.0

Cs-134

0.56

0.72

2.4

Cs-136

0.01

0.02

0.08

Cs-137

2.5

3.3

10.1

.01

0.03

0.8

101

*NA

*NA

0.98

*NA

Ba-14O
H-3*Not analyzed as yet.

'

Evaporator
Condensate
Tanks; Contaminated'Drain Tanks
10-1
10-1

10-1

H-3 levels are estimated to be less than U.2 uCi/ml.

D-16

1-131

8.08 days

Cs-1342.07 years

Cs-13612.9 days

Cs-13730 years

Ba-l 40

12.8 days

H-3

12.2 years

i

REFERENCES

1. NUREG/CR-0141, "Use of Filtration to Treat Radioactive Liquids inLight-Water-Cooled Nuclear Reactor Power Plants," September 1978.
2.

NUREG/CR-0143, "Use of Ion Exchange to Treat Radioactive Liquids inLight-Water-Cooled Nuclear Reactor Power Plants," August 1978.

3.

NUREG-UOI7, "Calculation of Releases of Radioactive Material in
Gaseous and Liquid Effluents from Pressurized Water Reactors(PWR-GALE Code)," April 1976.

4.

10 CFR 50.34a, "Design Objectives for Equipment to Control Releasesof Radioactive Material in Effluents, Nuclear Power Reactors".

5.

10 CFR 20,

6.

Regulatory Guide 8.8, "Information Relevant to Ensuring that
Occupational Radiation Exposures at Nuclear Power Stations will be
as Low as is Reasonably Achievable", Rev. 3, June 1978.

7.

NUREG-0107; Safety Evaluation Report related to operation ofThree Mile Island Nuclear Station, Unit 2, Docket No. 50-320,
September 1976.

8.

Regulatory Guide 1.4, "Assumptions Used for Evaluating the Potential'
Radiological Consequences for a Loss of Coolant Accident for PWRs".

9.

Regulatory Guide 1.143, "Design Guidance for Radioactive Waste
Management Systems, Structures and Components Installed in LightWater-Cooled Nuclear Power Plants", quly 1978.

10.

Regulatory Guide 1.140, "Design, Testing, and Maintenance Criteria
for Normal Ventilation Exhaust System Air Filtration and Adsorption
Units of Light-Water-Cooled Nuclear Power Plants", March 1978.

11.

Regulatory Guide 1.21, "Measuring, Evaluating and Reporting Radioactivity
in Solid Wastes and Releases of Radioactive Materials in Liquid andGaseous Effluents from Light-Water-Cooled Nuclear Power Plants",
Revision 1, June 1974.

12.

Final Environmiental Statement Related to the Operation of Three Mile
Island Nuclear Station Units 1 and 2, NUREG-0552, December 1972.

13.

Code of Federal Regulations, Title 10, Part 5U, Appendix I, "Numerical
Guides for Design Objectives and Limiting Conditions for Operations
to Meet the Criterion 'As Low As is Reasonably Achievable' forRadioactive Material in Light-Water-Cooled Nuclear Power Plant
Effluents.""Standards for Protection Against Radiation".

D-17

i JR

mm

M

I I

APPENDIX E.

E.1

FISH AND FISHERIES OF YORK HAVEN POND AND CONOWINGO POND OF THE
SUSQUEHANNA RIVER AND UPPER CHESAPEAKE BAY

THE YORK HAVEN POND FISH COMMUNITY

Fifty-six species of fishes were recorded in York Haven Pond during the period 1974-1978.1 2
Catches by seine, trapnet, and electrofisher have shown the most abundant were spotfin shiner,
spottail shiner, tessellated darter, sunfishes (redbreast,-pumpkinseed),rock bass, smallmouth
bass, channel catfish, quillback, carp, walleye, black crappie, white crappie, white sucker, andbluntnose minnow.'Some species show patterns of abundance or distribution that correspond withpreferred habitat or spawning period. 2
For example, the relative abundance of sunfishes andsmallmouth bass (especially juveniles) is greater in the east channel (Fig. E.1) than in otherareas studied in the York Haven Pond, perhaps because of the shallow, slow-moving nature of theeast channel and to the food resources that are abundant there.
York Haven Pond fish larvae first appear in mid- to late April with peak densities occurring
about one month after the first larvae are taken, generally late May to mid-June. 3 ' 4 The mostabundant species have been carp, spottail shiner, spotfin shiner, quillback, channel catfish,
pumpkinseed/bluegill, tessellated darters, and banded darter.
In 1978 and 1979, respectively, 32
and 30 total species were recorded during ichthyoplankton sampling.
Generally, larval densities
have been highest in the east and west channels.
Carp, quillback, and banded darter have been in
relatively high abundance in the center channel along the western shore of Three Mile Island.
An annual tagging program has been used to study the movements of York Haven Pond fishes since1974.3,4
Most recaptures of tagged fish have been within York Haven Pond (bounded by Fall and
Hill islands to the north and Red Hill and York Haven dams to the east and south--Fig. E.1), andall the species studied have exhibited movements upstream, downstream, and across channels within
the pond.
Fishes also have moved out of the pond both upstream beyond Fall Island and downstream
over the York Haven Dam. 2 ' 4
Movements out of the pond have been most frequent among smallmouth
bass, rock bass, and walleye.
Downstream movements have been to within a few kilometers of theYork Haven Dam.
Upstream movements have been primarily within the river proper, but movements
into tributaries (Swartara Creek, Juanita River, west branch Susquehanna River, Chenango River)also have occurred.
Upstream angler recaptures of tagged smallmouth bass and rock bass have been
principally in the river between Fall Island and Harrisburg.
Most walleye recaptures have beenin the river near Sunbury, Pennsylvania, about 105-107 km upstream from TMI, although a few
walleye have been taken in the Susquehanna River and the Tioughnioga River in New York State(428 km and 468 km distant, respectively).
Food Habits of York Haven Pond Fishes
The predominant source of food for the .fishes of York Haven Pond is the bottom invertebrate
community, primarily aquatic insects, crayfish, and amphipods (scud).
Other categories of fooditems- are filamentous algae, detrital material, oligochaetes (aquatic worms), molluscs (snails),
and small crustacean species (copepods, ostracods, cladocerans).
Fish also serve as a foodsource, but are secondary to the invertebrates, except for walleye, which is a strict carnivore
7
2
of fishes. The basic food web of the fishes is simplified in Figure E.2 into categories of "eater types"
based upon the food organisms that predominate in stomachs of the species studied.
Most of thefishes eat a wide variety of organisms, but usually a few types (e.g., crayfish) or groups (e.g.,insects) dominate the diet.
The next and highest link in the food web of York Haven Pond is man,fishery.

E-1

through the recreational

E-2

N

ST. JOHN'S:::
SAND BEACH

kr- ISLAND,,o,

PA FISH
CIOMM. ACCESSHO)MESFIT 1 INTAKE
UN~lIT 2 INTAKE.........

...
1
VI,
.V
P BLIC ACCESS
TMINS
(SIh
(I
COMBINED 2-UNIT

SHELLEY
ISLANDz::

GOLOSBORO
MARINA... ::FISH ING CREEK_. . ......

. ..... ..

RED 1

2

HOMES,0
DOCKS,BOATS(CONRAD'S?

MARINA)

(EAS

....

HOMES...........
0 ...

::

MILE

ISLAND=.
_dL.• BRIDGE-10-T DAM)::4::2::..........
.THREE
BA.SLAN.E...

9

DI•SCHARGE-L.

ISLAND.........
...........................
.............

...... DA\y0asitt-Owll*

FLOW

500 m

YORK HAVENGENERATING STATIONFISHERMAN ACCESS (PLATFORM]

Figure E.1.

York Haven Pond of the Susquehanna River Showing the Location ofThree Mile Island and the Nuclear Station, the Generalized Flow
Patterns in the Channels and over the Dams, and the Peripheral
Facilities that Contribute to Use of the Pond by Fishermen andBoaters.

to -

E-3

Figure E.2.

Generalized Categories of "Eater Groups" of the Fishes in York Haven Pond
The circle in the center represents the foodof the Susquehanna River.
resources consumed by the pond fishes that are listed by eater group
The large dark arrows indicate the major foodaround the periphery.
resource of each group, while the small arrows indicate the secondary
The fishes in parentheses are species thatfood resource(s) of a group.
occur in York Haven Pond but for which the food preference studies wereconducted in the North Branch Susquehanna River upstream of Three Mile
Island.

E-4
Fisheries
The recreational

fisheries of the Three Mile Island vicinity have been studied since 1974.2-7

Angler creel surveys have been conducted on two weekend days and two weekdays per month in fourareas near Three Mile Island:
the York Haven Pond (including the waters of the east, center, andwest channels from Fall and Hill islands at the north to Bashore Island and the York Haven Dam at
the south--Fig. E.1); the Red Hill Dam; the York Haven Dam; and the York Haven Generating Station(hydroelectric) tailrace.
Fishing at the Red Hill Dam, York Haven Dam, and in the tailrace area
occurs on the downstream sides and thus is not within the pond formed by the York and Red Hill
dams.
Data on recreational fishing in the TMI vicinity (at all four survey areas) during 1974-1979
are given in Table E.1.

Table E.1.

Estimates of Recreational Fishing in
Vicinity of TMI, 1 9 7 4 - 1 9 7 9 a
Fish

Fish

Hours

Year

Anglers

CaughtKeptFishedc/eb

1979

13,96229,396

7,306

24,5461.20

1978

14,08927,9769,490

27,992

1.00

1977

7,791

12,0895,341

14,7730.82

1976

12,26519,992

6,623

21,341

0.94

1975

11,287

16,253

8,578

21,2200.77

1974

10,837

15,714

7,044

19,9400.79

aBased on data from four survey areas:

York Haven Pond,

Red Hill Dam, York Haven Dam,

andYork Haven Generating Station.
(From:
G.A. Nardacci and Associates, "An Ecological Studyof the Susquehanna River near the Three Mile Island Nuclear Station, Annual Report for 1979,"
Ichtyological Associates, Inc., Etters, PA, April 1980.)
bc/e = catch/effort, or the number of fish caught divided by the number of hoursý fished.

The most frequently caught species have been smallmouth bass, channel catfish, walleye, rockbass, sunfishes, carp and suckers.
The bulk of the harvests in the pond during 1977 and 1978,
respectively, were smallmouth bass (44% and 61%), channel catfish (25% and 13%), sunfishes (15%and 14%), and rock bass (15% and 9%).
Smallmouth bass, rock bass, and sunfishes (predmoninantly bluegill, pumpkinseed, and redbreast)
have been caught in greater numbers in the pond than below either dam or in the tailrace, althoughsmallmouth bass frequently are taken in all survey areas.
Walleye are commonly taken below thedams and at the tailrace area but have been caught infrequently in the pond, based on creel.
surveys.
Channel catfish have been caught relatively infrequently at the east dam, but have beencommon in other areas surveyed, with the most caught in the tailrace area.
The pond has accounted
for about 36% and 31% of all fishes caught in the vicinity during 1977 and 1978, respectively,
for 29% and 40% of the total anglers, and 29% and 44% of the total hours fished. Overall, smallmouth bass catches have been greatest during May-June, rock bass during May, channel catfish
during July, walleye during May, and sunfishes during June-July.
Fishing localities within York Haven Pond are indicated by the places of angler recaptures oftagged fishes.
The concentration of recaptures in specific areas could be related to availability of fishes and nearness to access facilities (Fig. E.1)'

E-5
The fishing year on York Haven Pond in the Three Mile Island vicinity extends principally from
April through November; some fishing occurs prior to April and after November, but is dependent
on weather and river flow conditions.
Fishing effort on the pond, in terms of number of anglers
and number of hours fished, is at a maximum during June and August.
The fishery harvest foranglers on the pond has been highest during spring and fall.
The monthly catches and harvests on
the pond relative to the total of all areas surveyed have been lowest during spring and late falland highest during summer and early fall.
The majority of anglers are fishing on the pond then,so that the relative catches and harvests are highest on the pond at that time.
During 1977 and1978 about 75% of the anglers were from York and Dauphin counties in Pennsylvania.
Bycreelsurvey area fished, the angler residence tended to reflect their proximity and access to theriver.
At least nine other Pennsylvania counties were represented by anglers fishing in thevicinity.
There were only a few out-of-state anglers.
Of the anglers interviewed in 1977, 65%
reported that they ate their catch (or at least some of their catch), 17% released all theycaught, and 3% gave away their catch.
In 1978, the percentages were 74%, 26% and 9%.
E.2

THE CONOWINGO POND FISH COMMUNITY

The common fishes in Conowingo Pond are the gizzard shad, white crappie, channel catfish, bluegill, pumpkinseed and spotfin shiner.
The largemouth and smallmouth basses and walleye areimportant species to the recreational fishery, although their population abundance is small
relative to the commonly occurring species.
Fifty-six species were collected from the pond andtributaries during a nine-year study period (1966-1974).
Some additional species and hybrids
have been introduced in planned stocking programs.
The gizzard shad, which was accidently introduced in 1972, has increased in abundance, while thewhite crappie has declined drastically in recent years.
The gizzard shad competes with the white
crappie for the same zooplankton food resource.
Two hybrids, striped bass X white bass and thetiger muskie, were introduced by the Pennsylvania Fish Commission during 1977-1978 in an attempt
to control the expanding gizzard shad population.
Although the mean density of gizzard shadyoung declined in 1977-1978, it is too early to give unqualified credit to the hybrid introduction program in bringing about this reduction.
The white crappie population has not rebounded tolevels recorded in 1972 and prior years.
The common species (gizzard shad, white crappie, channel catfish, pumpkinseed, bluegill, andspotfin shiner) are widely distributed in the pond.
Less common but important game species, suchas walleye and smallmouth and largemouth bass, are more limited in.distribution.
The largemouthbass is more common in the lower part of the pond, while smallmouth bass and walleye are foundprimarily in the upper part of the pond, between Holtwood Dam and the Muddy Run Pumped Storage
Plant.
During winter, the thermal plume produced by the Peach Bottom Atomic Power Station(located at about mid-pond) appears to be attracting gizzard shad and, their predator, the walleye.
Of the species studied in tagging experiments, white crappie was the only one to exhibit an
obvious seasonal movement pattern within the pond.
In mid-spring, movement is generally upstream.
Approaching winter, the white crappie move to the lower part of the pond and congregate at themouths of creeks.
Materials that are transported into Conowingo Pond and incorporated in the food web may ultimately
be removed, in part, via the recreational fishery, to man.
The food habits of selected importantfish species illustrates the various pathways (Table E.2).
Fisheries
The fisheries of Conowingo Pond have been described from studies made in 1958-1960,8 1966-1970,9
the winters of 1973 through 1977,10 and the 13-month period from August 1977 through August
1978.11
Based on the studies conducted in 1958-1960, it was concluded that white crappie had the greatest
influence on the average catch per effort and resulting harvest from Conowingo Pond.
The crappies(mostly white crappie) made up 48 to 55 percent of the catch during the study period,' the catfishes (channel, white, brown bullhead and yellow bullhead) contributed 27 to 37 percent, andsunfishes (bluegill, pumpkinseed, rock bass, green and redbreast) contributed 6 to 16 percent.
Only three other species constituted more than 1 percent of the catch for any one year of thestudy period-- smallmouth bass (2.6 percent in 1960), largemouth bass (1.5 percent in 1960) andyellow perch (2.5 percent in 1958).
Catch per effort for white crappie ranged from 0.49 fish perhour in 1959 to 0.27 fish per hour in 1960.

Table E.2.

Food Habits of Conowingo Pond Fishes
Food Itemsa
Zooplankton

Species/Sizeor Age Group

Detritus

Insect Larvae

Phytoplankton

Amphipoda

Cladocera

R

R

A

A

A

A

A

A

A

A

Copepoda

Rotifera

Chironomids

Others

A

R

C

C

Fish

Other

White Crappie
Young
Adult

C

Gizzard Shad
6-25 mm26-50 mm
51-80 mm

C
A

C

A
m

Channel Catfish<190 mm>190 mm

A

A

C

C
C

A

Bluegill<10 mmR

41-100 mm
>100

A

A

A

A

A

A

A
C (terrestrial
insects)

A

Pumpkinseed<1i0 mm>110 mm

A
A

A

C

C'

A
A

Smallmouth Bass
21-80 mm

CC

A

>80 mmWal leyeaTable entries indicate frequency 'with which fish of a given size or age utilize the specified food item:
C = common, R = rare.

AA
A = abundant,

A (crayfish)

E-7
Observations made in the period 1966-1970 indicated no substantial change in the nature of therecreational fishery as had been described from the 1958-1960 study.
Although no creel survey
was made in the 1966-1970 period, it was observed that most fishing was done from small boats inshallow water along shore or from shore at a limited number of accessible sites.
During thisperiod it was observed also that a substantial winter fishery existed in the lower part of thepond.
Results of the winter fishery survey indicate that a total of 18 species were caught during themonths of December through March, with white crappie making up 91 percent of the average winterharvest (Table. E.3).
Next in average relative abundance was the bluegill at 7 percent.
Theother 16 species contributed the remaining 2 percent of the average winter harvest.
The wintercatch per effort (number caught per angler-hour) averaged 2.03 for all species combined and 1.85
for white crappie (Table E.4).
The estimated winter fishing pressure averaged 9202 anglers.
Ofthe anglers interviewed, more than half were from the Baltimore area, and most of the others
lived within 15 miles of Conowingo Pond.
Winter angling was primarily from shore (61 percent)and through the ice (33 percent), as compared with boatfishing (6 percent).
The concentration of
winter fishing in the lower pond reflects the movement pattern of white crappie as previously
noted.
The winter fishery of Conowingo Pond was compared to the year-round fishing through the creel
survey made over the 13-month period from August 1977 through August 1978.
Results indicate thatthe winter angling from December 1977 through March 1978 accounted for 11 percent of the effort
expended over the 13-month survey period.
Angler-hours were estimated at 303,980 for the 13
months.
The harvest rate (fish kept per angler-hour) was much higher during winter than during
the 'rest of the year.
For the 13 months, a total of 5305 fish representing 22 species and 2 hybrids were counted in thecreel samples (Table E.5).
Of those fish caught, an average of 45.5 percent were kept (i.e.,
harvested).
Using the catch and -harvest rates, the 13-month harvest was estimated to total
113,981 fish weighing 25,381 kg.
White crappie and sunfishes dominated the catch in the lower pond.
was dominated by smallmouth bass and channel catfish.

The catch in the upper pond

The angler population was primarily local residents (42 percent), but included some Baltimore
area residents (25 percent).
The rest were about equally divided between residents from distancesof 15 to 40 miles (17 percent) or from distances greater than 40 miles (16 percent).
In comparison with the recreational fishing in the vicinity of TMI (see Table E.1), the estimatednumber of fish harvested in Conowingo Pond is 15 times greater than the six-year average value
for the TMI vicinity.
The hours fished in Conowingo Pond were 14 times greater than the six-year
average value for the TMI vicinity.
The harvest rate in Conowingo Pond (i.e., number of fish
kept + number of hours fished) for the 13-month survey was 0.38 fish/hour.
A similar calculation
using the average values from columns 4 and 5 of Table E.1 indicates that the harvest rate in the
TMI vicinity is 0.34 fish/hour. Though the harvest rates are comparable, the species dominating
the harvests are different between the Conowingo Pond and the York Haven Pond.
The Conowingo
Pond harvest is typically dominated by white crappie (which contributed 51 percent of the harvestin the August 1977-August 1978 survey period).
In the York Haven Pond, smallmouth bass was thedominant species harvested in the calendar years 1977 (44 percent) and 1978 (61 percent)..
E.3

THE UPPER CHESAPEAKE BAY FISH COMMUNITY

Fifty-one fish species have been recorded for the lower ten miles of the Susquehanna River fromthe Conowingo Dam to the river mouth (Fig. E.1).1 2 The most abundant have been the anadromous
clupeids (alewife, blueback herring, American shad), white perch and channel catfish. 12 ' 13
Included in the species inventory are freshwater families of salmonids (trout), esocids (pikes),
catsotomids (suckers), cyprinids (minnows and carp), ictalurids (catfish), centrarchids (sunfish
and bass), and percids (perches and darters); brackfish water families of antherinids (silversides) and cyprinodontids (killifish); anadromous families of clupeids (shad and river herrings),
percichtyids (striped bass; and white perch--a freshwater species); and one catadromous family of
anguillids (American eel).
This stretch of the river is used for spawning by several species of fishes during the spring,
including the anadromous clupeids1 2 '1 3 and striped bass (rockfish).
The fish community of theupper Bay (Susquehanna River mouth to Annapolis) consists of many species and is seasonallyE-8

Table E.3.

Species Composition of Fish Kept by Anglers In Conowingo Pond
Based on 1973-1977 Winter Fishery Survey
Grand Total

Species

1973

1974

1975

1976

1977

Number

Percentage

White crappie

5,998

3,130

489

3,599

649

13,865

91.1

Bluegill

411

36

546

40

31

1,064

7.0

Largemouth bass

12

1

5

85

8

111

0.7

Channel catfish

11

24

-

2

3

40

0.3

Brown bullhead

27

-

2

4

1

34

0.2

Black crappie

17

2

2

4

2

27

0.2

Otherb

21

13

2

21

17

74

0.5

aModified from Table 4.6-4 of "Peach Bottom Atomic Power Station Postoperational Report No. 9 on the Ecology of Conowingo Pond for the period ofJuly 1977-December 1977," Muddy Run Ecological Laboratory, March 1978.
bCarp, yellow perch, gizzard shad, smallmouth bass, pumpkinseed, yellow bullhead, golden shiner, white sucker,
fish, and rock bass.

Table E.4.

brown trout, muskellunge,

redbreast sun-

Winter Fishing Pressure and Catcha per Hour of Fishes inConowingo Pond, 1 9 7 3 7 1 9 7 7

Number of anglers interviewed
Number of anglers counted

Total

Avg.

1973

1974

1975

1976

1977

1077

813

423

881

489

3683

736.6

1937

1072

673

1715

724

6121

1224.22099.01441.0673.42256.71035.37505.41501.1

Number of fish caught

6497

3206

1046

3755

711

15215

3043

Number of fish (all species)/hour

3.10

2.22

1.55

1.66

0.69

-

2.03

Number of white crappie/hour'

2.86

2.17

0.74

1.60

0.63

-

1.85

Number of hours fished (angler-hours)

aModified from Table 4.6-1 of "Peach Bottom Atomic Power Station Post-operational

ReportNo. 9 on the Ecology of Conowingo Pond for the Period of July 1977-December 1977," Muddy
Run Ecological Laboratory, March 1978.

E-9
Table E.5.
Species Composition and Estimated Harves•by Anglers in Conowingo Pond, August 1977-August 1978

Estimated Harvest
SpeciesNumberCaughtPercentage
Kept

NumberNumber/hr

Weight (kg)kg/hr,Whitecrappie

1437

79.9

57,2960.19

11,440

3.14

Sunfishesb

1268

30.7

16,5640.05

1,748.

0.48

Smallmouth bass

781

44.3

15,035

0.05

6,191

1.70

Channel catfish

1281

24.6

14,599

0.05

2,095

0.57

Carp

181

34.2

2,641

0.01

2,147

0.59

Largemouth bass

161

28.0

2,366

0.01

1,089

0.30

Yellow perch

60

61.7

1,880

0.07

43

74.4

1,260

0.01
e

246

Bullheadsc--

Walleys

50

42.0

677

e

425
-

0.12

e

25,381

6.97

Otherd

43

46.5

943

Total

5305

45.5

113,891

0.38-

aModified from Table 4.6-3 of "Peach Bottom Atomic Power Station Post-operational
Report No. 9 on the Ecology of Conowingo Pond for the Period of July 1977December 1977," Muddy Run Ecological Laboratory, March 1978.
blncludes rock bass, redbreast sunfish, green sunfish, pumpkinseed, and bluegill.
clncludes white catfish, yellow bullhead,dlncludes American eel,shorthead redhorse,muskie.
eLess than 0.01.

and brown bullhead.

gizzard shad, goldfish, golden shiner, white sucker,

black crappie, striped bass x white bass hybrid,and tiger

composed of freshwater, estuarine, and anadromous forms.
The more freshwater areas at the headof the Bay will have a species assemblage similar to that of the lower Susquehanna River.1 2 '1 3
Forty species have been recorded from *the Susquehanna Flats, with less than half that number
comprising the majority of individuals taken, both in number and weight. 13 The most abundantspecies are white perch, bay anchovy, blueback herring, alewife, killifish, spottail shiner,
sunfish, silversides, striped bass, spot, and hogchoker.
Annual shorezone seining is conductedin many areas of the Chesapeake Bay, Maryland, by the Maryland Fisheries Administration.' 4Themost abundant species found in 1977 and 1978 included Atlantic menhaden, Atlantic silversides,
bay anchovy, gizzard shad, rough silversides, spot, spottail shiner, striped bass, and white
perch." 4
The less-salinity tolerant fishes occur in the tributaries and on the flats, and to alesser degree into the bay (i.e., yellow perch).
Other more estuarine or marine species occur as
far up the bay as the Sassafras River or to the southern limits of the flats (i.e., bluefish,
winter flounder).' 5
Many truly estuarine and anadromous fishes occur throughout this upper Bay area and many use it
as spawning and nursery grounds.
Prominent among the spawners there are the freshwater residents
plus such species as the herrings (American shad, alewife, blueback), white perch, striped bass,
sliversides, winter flounder, hogchoker, and bay anchovy.' 5 In addition to the use of this area
as a nursery by those species that spawn there, several species that spawn either in the ocean ormuch farther down the Bay near the mouth also utilize this upper Bay area as nursery grounds.
Spot, croaker, and weakfish have concentrated nursery areas in the Elk River and in the Bay
proper between Poole's Island at the south and Spesuite Island at the north.'s Hogchoker spawn
over much' of the Chesapeake Bay, including the southern limits of this upper Bay area (Magothy

E-10River-Chester River area), but have concentrated nursery areas in the upper Bay tributaries andin the Bay proper from about Poole's Island at the south to the Susquehanna Flats.iS
The Chesapeake and Delaware Canal 6 also supports fish populations similar in composition to thoseof the northern Bay tributaries.1
Several species spawn in the canal, most notably white perch
and striped bass.'17 ' 8 The canal appears to have become one of the most important striped bass
spawning grounds in the entire Chesapeake Bay region, and it has been suggested that the canalprovides a favorable alternative to the now-destroyed historical spawning grounds in the lower
Susquehanna River.' 7 Striped bass spawning stocks occur in several aquatic systems throughout
the mid-Atlantic and northeast regions, but the major contributor to the Atlantic coastal fisheryis the Chesapeake Bay stock.19
The most productive areas of the Bay are those areas of low salinity in the upper bay and thecorresponding portions of the major tributaries. 2 0 The upper Bay is a major spawning and nurseryarea, and together with the Chesapeake and Delaware Canal, probably is the largest of all spawningareas in the Bay.1 6 Biomass per unit of area, particularly of marsh plants and fishes, is vastly
greater on these nursery grounds than it is seaward. 2 1 These low salinity areas of the upper bay
are rich in food resources for young fishes' 5 ' 2 1 and contain the largest populations of important
phytoplankton and zooplankton during the seasonal occurrence of larval and juvenile fishes.
Endangered fish species for the Chesapeake Bay area include the Maryland darter (Etheostoma
sellare) and shortnose sturgeon (Acipenser brevirostrum). 2 0 The Maryland darter occurs in theeastern Piedmont drainage to the Bay,41 but not the Bay proper.
Presently, it is known only from
Deer Creek, a tributary to the Susquehanna River 3 to 3.5 miles downstream of the Conowingo28
Dam.
It has not been recorded in the Susquehanna River proper in the vicinity of Deer Creek.
Shortnose sturgeon has been recorded from the Potomac River during the latter 1800s from Stillpond
Neck (just south of the Sassafras River) in 1976 (one specimen), and from the Elk River in 1978
Shortnose sturgeon are present in the Delaware River and Delaware Bay. 26(four specimens). 2 4 ' 2 5
Although no specimens have been recorded from the Chesapeake and Delaware Canal, the possibility
exists for migratory movements between the two estuaries. 2 6 Therefore, the specimens recorded
during 1976 and 1978 from the Chesapeake Bay might have been of Delaware River origins.
Some other important species of Bay fishes, although not considered endangered, have become
severely reduced in number during recentyears.
Commercial catches of American shad have declined
severely in recent years1 2 ' 2 7 - 2 9 prompting the State of Maryland to close the fishery (sport andcommercial) during 1980, beginning on April 8 and continuing for 120 days.
Hickory shad, blueback herring, and alewife also are at very low population levels in the Bay.
Populations of.
striped bass have declined in recent years. 3 0
The Upper Chesapeake Bay Shellfish Community
Soft-shelled clams (Mya arenaria) generally occur in water with a depth less than 20 ft near the
shoreline of both sides of Chesapeake Bay. 'They are found from the northern Bay generally below
Poole's Island south to about the Potomac River.' 5 Hard clams (Mercenaria mercenaria) are limited
to the higher salinity areas of the lower Bay, but extend into Maryland in the Tangier and Pokomoke
Sound areas of the eastern shore' 5 ' 3 1 They are not found in water where the salinity is lessthan 15 parts per thousand.' 5 The American oyster (Crassostrea virginica) is distributed throughout much of Chesapeake Bay and occurs in Maryland waters from the Maryland-Virginia border northto about the Poole's Island area, as well as into most of the more saline tributaries upstream toa mean salinity of about 7-8 parts per thousand. 15 Oysters require firm bottom to prevent sinking
and smothering and normally are found attached to shells, stones, and other hard objects.
They
are subtidal and generally occur in water between 8 and 25 ft deep.' 5 Great accumulations ofoyster shells are a significant bottom feature of the Chesapeake Bay.
Perhaps the greatest
contribution any single mollusc makes toward the ecology of the Bay is the formation of shellbars and reefs made by oysters. 3 1 Individual molluscan species utilize varied means of obtaining
nutrition.
Some are filter-feeders (soft-shelled clam, oyster) and/or detrital feeders.
They,in turn, provide food for a variety of animals, including other molluscs, fish, crabs, and water,fowl, as well as for man. 3 1
The blue crab (Callinectes sapidus) is widely distributed along the Atlantic and Gulf coasts, but
is most abundant and best known from the Chesapeake Bay.' 5 Blue crabs occur from areas of nearly
fresh water to full-strength sea water.
In the low salinity areas of the upper Bay and its
tributaries, male crabs predominate.
Females tend to congregate farther downstream and down-bay
where salinities are greater.
Mating occurs in the middle and upper Bay and its tributaries from
June through October.
After impregnation, the females migrate toward the lower Bay and the

I

I

E-11
higher salinity spawning grounds.
Female crabs will not return to northern Bay areas until thefollowing spring, while the majority of males remain in the fresher waters-, most overwintering in
the muddy bottoms of deeper channel waters.
Blue crabs spawn in the high salinity waters near
the mouth of the Bay during the summer.
At hatching, the larval crabs become planktonic." 5Bluecrabs occur to the head of the Bay, including the Susquehanna Flats area and in the lower portions
15of its tributaries.
Food Habits of Upper Chesapeake Bay Fishes
The fish fauna of the lower Susquehanna River downstream of Conowingo Dam consists of a broad
compliment of "eater types", including fish eaters, fish and invertebrate eaters, bottom feeders,and plankton/invertebrate eaters.
Food habits have been studied for only a few species of fish in this stretch of the river--white
crappie, gizzard shad, white perch, and channel catfish.' 2They rely predominantly on bottom
invertebrates, plant material, and fish as food sources.
In decending order of occurrence instomachs:
white crappie ate insects, crustaceans, fish, and plant material; gizzard shad ate
plants, insects, detritus, and crustaceans; white perch ate insects, crustaceans, plants, andfish; and channel catfish ate plants, insects, fish, crustaceans, and detritus.
Other studies offishes in freshwater areas surrounding the Chesapeake Bay describe the food sources of alewife as
predominantly crustaceans (copepods and ostracods) and those of American shad as insects andostracods. 2 4 White perch feed on fish, crustaceans, worms, insects, and to a much lesser degree
on plant material. 2 4
Striped bass are carnivorous, feeding on fish, crustaceans, worms, andinsects, 2 4 and in the lower portion of the Susquehanna River they forage on spawning clupeids.12
The walleye is noted as being the only truly piscivorous (fish eater only) resident species inthis stretch of the river.12
The food habits of fish in the less saline areas of the upper Bay (especially the Susquehanna
Flats and nearby tributaries) will be similar to those described for the lower ten miles of theSusquehanna River, with benthic Jnvertebrates'as a primary food source.1 2
In the Chesapeake andDelaware Canal, benthos also are of considerable importance as food for resident and migratory
fishes. 3 2 The fish fauna of the upper Bay consists of a broad compliment of "eater types" across
many trophic levels, including fishes that feed on plankton, invertebrates, other fish, plantmaterial, and detritus. 2 4 Feeding habits vary between species and with the size of a given
species.
Larval fishes feed on small forms, notably on zooplankton.
In this upper Bay area,
copepod and cladoceran zooplankters are important food sources for larval fishes.1 5 One copepod
species, Eurytemora affinis, is especially important because it is most abundant at the sameplace and time as the newly hatched larvae of many species of fish. As fish grow, food preferences often change from small organisms--to larger ones (invertebrates or small fish)--to stilllarger forms (fish, crabs, molluscs), depending on the species and its trophic level or "eatergroup".
General. Distribution of Major Fishery Harvests
The soTt-shelled clam is found in the bay almost exclusively in Maryland waters.
Commercial
harvest concentrations occur only in certain areas between the Chester River at the north and the15
Potomac River at the south.
Virginia reported no landings of soft-shelled clams for 1975 or
1976,33,34 while Maryland's exceeded 1.2 million and 1.7 million pounds for those two years.
Hard clams are found in Maryland waters only near the Maryland-Virginia border in the Tangier andPokomoke Sounds.
A small fishery exists there based on the use of escalator harvesters.'s
Maryland reported only a small harvest of hard clams in 1975 (13,900 pounds) 3 3 and no harvest in
1976.34 Virginia's reported landings were in excess of 600,000 pounds and 800,000 pounds in 1975
and 1976 respectively.
Oyster beds occur in the Bay generally beginning at the north near Poole's Island and extending
southward into most of the sounds, lower tidal creeks, and lower portions of the major tributaries.
The majority of oysters harvested within the Bay come from Maryland waters.
Blue crabs are harvested in vast quantities throughout most of Chesapeake Bay and in the middle
and lower portions of most tidal creeks and tributaries.' 5 Commercial potting for crabs begins
near the Spesutie Island area at the lower end of the Susquehanna Flats and occurs throughout
most of the Bay proper and the tidal portions of the Potomac River.' 5 Recreational crabbing in
Maryland waters occurs primarily in nearshore areas and in tidal creeks, beginning at about theE-125
Aberdeen-Sassafras River area and extending southward along much of the Bay shoreline area.1
Although no figures are available on the total recreational crab harvest levels, it is substantial.

Fishing (commercial and recreational) tends to be located in the areas where concentrations offishes exist, and usually is seasonal in nature.
Fishing for anadromous species (shad, herrings,
striped bass) occurs in the tributaries and other spawning areas during the spawning runs.- Other
species are fished when they enter the Bay waters for summer and fall feeding, such as menhaden
and bluefish.
Fisheries of The Susquehanna from Conowingo Dam to'the River Mouth
Commercial fishing occurs in the lower ten miles of the Susquehanna River for American shad,striped'bass, river herrings (alewife, blueback herring), catfish, and baitfish.1 2 ' 28 ' 2 9 The
fishery is ranked as "excellent" and the usage as "heavy". 2 9 In recent years, catches of shad.
have declined baywide,1 2 ' 27 - 29 thus more emphasis has been placed on striped bass, with shadbecoming more of an incidental catch in the Susquehanna River. 2 9 Recreational fishing occurs inthis reach of the river for several species by both river bank and boat anglers. 13 A creel
survey conducted during the spring of 1970 recorded the capture of 7738 fishes (4705 kept, or aharvest rate of 60.1%) by 1607 anglers who fished for a total of 8315 hours (0.93 fish caught perangler hour).1 3
Of those anglers who responded, 52.4% resided in Maryland, 45.2% resided in
Pennsylvania, and 2.4% were from other states.
The predominant species caught were White perch(41.3% of the total), river herring (28.0%), American shad (9.0%), channel catfish (6.4%), stripedbass (4.3%), yellow perch (3.5%), bullhead catfish and hickory shad (1.8% each), sunfishes andcrappies (1.5% total), largemouth and smallmouth bass (0.9%), and others (1.4%, including walleye,carp, eel, suckers, quillback).
Fisheries of the Upper Bay
Soft-shelled clams are harvested generally beginning at about the Chester River in the southern
portion of the upper Bay area; the northern-most Chesapeake Bay distribution of oyster beds is in
the area between Poole's Island and Annapolis; and blue crabs are harvested (commercial andrecreational) throughout most of this area from the southern flats to Annapolis.
Finfish are commercially harvested in almost all waters of the upper Bay region, including theSusquehanna Flats, many tidal creek areas,and the Chesapeake and Delaware Canal.1 6 ' 2 8 ' 2 9 Fishingin the flats area is principally for striped bass (rockfish), shad and herrings, eels, catfishes,
white perch, and menhaden.
The area has been rated as "fair" to "excellent" for commercial
fishing. 2 9 Commercial fishing also occurs in the open Bay proper south of the flats for striped
bass, perch, shad, alewives, eels, and blue crabs. 2 9 These areas are heavily fished and provide
29
Winter fishing primarily is for striped bass.
nearly year-round fishing for various species.
Fishing is rated as "fair" to "excellent".
The most recent data available on the sport fishery are for the year 1976 for the upper Bay areafrom Poole's Island at the north to the Choptank River at the south. 35 The total harvest byanglers fishing from private and charter boats was estimated to be about 4.5 million pounds, ofwhich about 2.9 million pounds were bluefish.
Blue crabs ranked second in abundance, with stripedbass third.
Based upon the data derived during the 1976 sport fishery survey plus the results ofprevious surveys, an estimate of the total sport fishery was made for all Maryland waters of the
Chesapeake Bay.. 3 5 The total 1976 sport fishery harvest for finfish was estimated to be about
14.4 million pounds, while the sport harvest for blue crabs was estimated to be about 3.2 million
pounds.
Within the 1976 survey areas, the commercial harvest was less than the sport catch forstriped bass, bluefish, white perch, spot, and croaker.

References
1.

C.R. Hickey, Jr., and R.B. Samworth, "Non-Radiological Consequences to the Aquatic Biota andFisheries of the Susquehanna River from the 1979 Accident at Three Mile Island Nuclear
Station," U.S. Nuclear Regulatory Commission, NUREG-0596, November 1979.

2.

G.A. Nardacci and Associates,
Mile Island Nuclear Station,
Etters, PA, July 1979.

"An Ecological Study of the Susquehanna River near the Three
Annual Report for 1978," Ichthyological Associates, Inc.,

E-13
3.

G.A. Nardacci and Associates, "An Ecological Study of the Susquehanna River in the Vicinityof the Three Mile Island Nuclear Station, Annual Report for 1977,"' Ichthyological Associates, Inc., Etters, PA, April 1978.

4.

G.A. Nardacci and Associates,
Mile Island Nuclear Station,
Etters, PA, April 1980.

5.

W.A. Potter and Associates, "An Ecological Study of the Susquehanna River in the Vicinity of
the Three Mile Island Nuclear Station, Supplemental Report for 1974," Ichthyological Associates, Inc., Etters, PA, April 1975.

6.

G.A. Nardacci and Associates, "An Ecological Study of the Susquehah6'6a River in the Vicinityof the Three Mile Island Nuclear Station, Supplemental Report for 1975," Ichthyological
Associates, Inc., Etters, PA, May 1976.

7.

G.A. Nardacci and Associates, "An Ecological Study of the Susquehanna River in the Vicinityof the Three Mile Island Nuclear Station, Supplemental Report for 1976," Ichthyological
Associates, Inc., Etters, PA, November 1977.

8.

D. Plosila, "Lower Susquehanna River Sport Fishery Survey, 1958-1960," pp. *55-78 in:
R.R. Whitney (ed.), "The Susquehanna Fishery Study 1957-1960," Maryland Dep. Res. and Ed.
and the Susquehanna Electric Company, Contribution No. 169, 1961.

9.

T.W. Robins, "Fisheries Conditions in Conowingo Reservoir and Connecting Waters from 19661970:
A Summary," in: "Supplement No. 1, Part Two, Applicant's Environmental Report Operating License Stage, Peach Bottom Atomic Power Station Units 2 and 3," Philadelphia ElectricCompany, November 1971.

10.

"Peach Bottom Atomic Power Station Post-operational Report No. 9 on the Ecology of Conowingo
Pond for the Period of July 1977-December 1977," Muddy Run Ecological Laboratory, Drumore, PA,
March 1978.

11.

"Peach Bottom Atomic Power Station Post-operational Report No. 11 on the Ecology of.Conowingo
Pond for the Period of July 1978-December 1978," pp. 4-49 through 4-60, Muddy Run Ecological
Laboratory.
Drumore, PA, March 1979.

12.

J.W. Foerster, "Assessment of the Effect of Hydroelectric Water Discharged from the Conowingo
Dam on the Spawning Fish in the Lower Susquehanna River, Final Report," Goucher College,
Towson, MD, 1976.

13.

W.R. Carter, III, "Ecological Study of Susquehanna River and Tributaries below the Conowingo
Dam," Project No. AFSC-1, for the period January 1, 1967 to March 31, 1971, Maryland Fisheries Administration, Department of Natural Resources, 1973.

14.

J.G. Boone, "Estuarine Fish Recruitment Survey.
Job I - Shore Zone Seining in Maryland
Tidewater for Fish Distribution and Abundance," Project No. F-27-R4, for the period July 1,
1977 through June 30, 1978, Maryland Fisheries Administration, Annapolis, MD, 1978.;15.

A.J. Lippson, "The Chesapeake Bay in MarylandHopkins University Press, Baltimore, MD, 1973.

16.

"Final Environmental Statement Related to the Proposed Summit Power Station Units 1 and 2,"
U.S. Atomic Energy Commission, 1974.

17.

R.K. Johnson, and T.S.Y. Koo, "Production and Distribution of Striped Bass '(Morone
saxatilis) Eggs in the Chesapeake and Delaware Canal," Chesapeake Science 16(1):39-55, 1975.

18.

"Final Environmental Impact Statement Supplement, Inland Waterway Delaware River to Chesapeake
Bay Delaware and Maryland, Chesapeake and Delaware Canal and Approach Channel," U.S. Army
Corps of Engineers, Philadelphia, PA, 1977.

19.

T.J. Berggren, and J.T. Lieberman, "Relative Contribution of Hudson, Chesapeake, and Roanoke
Striped Bass, Morone saxatilis, Stocks to the Atlantic Coast Fishery," Fishery Bulletin76(2):335-345, 1978.

"An Ecological Study of the Susquehanna River near the.Three
Annual Report for 1979," Ichthyological Associates, Inc.,

An Atlas of Natural Resources,"

The Johns

E-14
20.

"Chesapeake Bay, Existing
Baltimore, MD, 1973.

21.

M.L. Wass, "A Check List of the Biota of Lower Chesapeake Bay," Special Scientific Report
No. 65, Virginia Institute of Marine Science, Gloucester Point, VA, 1972.

22.

D.S. Lee, A. Norden, C.R. Gilbert., and R. Franz,
and Delaware," Chesapeake Science 17(3):205-211,

23.

"Critical Habitat Proper for Maryland Darter," U.S. Fish and Wildlife Service, Endangered
Species Technical Bulletin 5(9):5-6, Department of the Interior, Washington, DC, 1980.

24.

S.F. Hildebrand, and W.C. Schroeder, "Fishes of Chesapeake Bay," Bulletin of the U.S. Bureauof Fisheries.
Vol. XLIII, Part I, 1928.
Reprinted for the Smithsonian Institution by
T.F.H. Publications, Inc., Neptune, NJ, 1972.

25.

M.J. Dadswell, "Synopsis of Biological Data on the Shortnose Sturgeon Acipenser brevirostrum
LeSueur 1818," Fisheries and Oceans Canada, Biological Station, St. Andrews, New Brunswick,
Canada, (undated).

26.

M.T. Masnik, and J.H. Wilson, "Assessment of the Impacts of the Salem and Hope Creek Stations
on Shortnose Sturgeon, Acipenser brevirostrum LeSueur," U.S. Nuclear Regulatory Commission,
NUREG-0671, 1980.

27.

J.W. Foerster, and S.P. Reagan, "Management of the Northern Chesapeake Bay American ShadFishery," Biol. Conserv. 12:179-201, 1977.

28.

W.R. Carter, III and D.R. Weinrich, "Tidewater Fisheries Analysis of American Shad Fisheryin Maryland Waters," Maryland Fisheries Administration, Department of Natural Resources, Wye
Mills, MD, 1980.

29.

"Survey of Commercial Finfishing Areas in the Upper Chesapeake Bay, Final Report to the
Maryland Department of Natural Resources," the Maryland Watermen's Association, Inc.,
Annapolis, MD, 1978.

30.

Commercial
1979.

31.

A.J. McErlean, C. Kerby, and M.L.
Vol. 13, Supplement, 1972.

32.

L.E. Cronin, D.W. Pritchard, T.S.Y.
Chesapeake and Delaware Canal," pp.
Press, New York, 1977.

33.

"Chesapeake Fisheries, Annual Summary 1975," Current Fisheries Statistics No.
Marine Fisheries Service, NOAA, 1978.

7407,

National

34.

"Chesapeake Fisheries, Annual Summary 1976,"
Marine Fisheries Service, NOAA, 1979.

7702,

National

35.

H.J. Speir, D.R. Weinrich, and R.S. Early, "1976 Maryland Chesapeake Bay Sport Fishing
Survey," Fisheries Administration, Maryland Department of Natural Resources, Annapolis, MD,
1977.

Conditions Report

Fisheries News 12(3),-Summary,"

U.S.

"A List of the Freshwater Fishes of Maryland
1976.

Maryland Department of Natural
Wass,

Army Corps of Engineers,

Resources,"Biota of the Chesapeake Bay,"

Annapolis,

MD,

Chesapeake Science,

Koo, and V. Lotrich, "Effects of Enlargement of the
18-32, in:"Estuarine Processes," Vol. II, Academic

Current Fisheries Statistics No.

APPENDIX F.

REUSE OF ACCIDENT WATER

Large volumes of contaminated water were generated by the accident, and treatment of this accident water, using the systems discussed in Section 7.1, could result in equally large volumes ofHowever, large amounts of water will
liquid effluents in the form of processed accident water.
If
be needed for decontamination and defueling operations and to shield systems and equipment.
processed water meets certain criteria, it may be used to sati'sfy these water needs and thus
The NRC has requested
minimize the volume of additional water contaminated during the cleanup.
the licensee minimize the use of water and cross-contamination.'In this appendix, the processed accident water available for reuse is characterized, potential
reuse applications and the limitations associated with reuse are identified, and the environmental impacts of reuse are assessed.
F.1 EFFORTS TO DATE AND SPECIFIC CONSIDERATIONSAs of September 1, 1980, about 501,000 gallons of AFHB accident water had been processed throughAn additional 68,000 gallons had been processed through November 1980.
the EPICOR II system.
This processed accident water, plus an additional 174,000 gallons of slightly contaminated water,
The characteristics, volumes and storage locais currently stored within the plant for reuse.
The average concentrations and radioactivity
tions of this water were presented in Table 7.3.
inventories for all significant isotopes in this 743,000-gallon inventory are presented in
The
As shown, this water contains 359 Ci of tritium and about 0.8 Ci of cesium.
Table F.1.
As disquantities of other isotopes present are less than 10 percent of the cesium content.
cussed in Section 7.1, there are about 700,000 gallons of unprocessed accident water in theThus, about
reactor building sump plus another 96,000 gallons in the reactor coolant system.
Since there are no practical
1,540,000 gallons of processed water could be available for reuse.
industrial-scale systems available that can remove tritium from this accident water, it will betritiated.
Reuse of processed accident water could result in occupational radiation exposure during the
To ensure compliance with "as low as reasonably achievable" (ALARA) prinreuse application.
ciples, guidelines for reuse of processed accident water have been established for the following
two applications:Remote and Semiremote Decontamination
The gross specific activity and tritium concentrations of processed accident water used
for these applications should be maintained at levels below those that could lead toworker exposure in excess of guidelines established, in 10 CFR Part 20.
'Shielding
The average gross activity of all radionuclides except tritium should be less thanThis ensures that the radiation level at the surface of the spent fuel0.01 pCi/mL.
The average tritium concenpools and fuel transfer canal is below 2 to 3 mrem/hr.
tration in this water shall be maintained to ensure airborne activities will be lessthan the 10 CFR Part 20 limit for worker exposure.
Comparison of these guidelines to the characteristics of the 743,000 gallons of processed accident water instorage indicates that this water is suitable for reuse in both applications.
F.2

ALTERNATIVES CONSIDERED

The management of processed water to maximize reuse during the cleanup requires consideration of
the volume of water available, its suitability for general reuse and the specific reuse applications, and the relationship between the time when it becomes available and the time
F-1

F-2

Table F.1.

Major
Radjonuclides

Radionuclide Inventor• of Processed
AFHB Water in Storage
Averageb
Concentration(pCi/mL)
1.28 x 10-1

3.59 x 102<

8.4 x 10-6

< 2.4 x 10-2<

8 x 10-6< 2.3 x 10-2

6

< 2.7 x 10-2

H-3
Cr-51
Co-58

Totalb'cCuries

Co-60<

9.7 x 10-

Ru-106<

7.4 x 10-6

< 2.1 x 10-2

Sb-125<

6.1 x 10-6

< 1.7 x 10-2

Cs-134<

9.1 x 10-5

< 2.5 x 10-1<

2 x 10-4
6.6 x 10-6

5.7 x 10-1
< 1.8 X 10-2

Cs-137Ce-144aAverage in all tanks shown on Table 7.3.
bAll values except tritium (H-3)

are rounded to two

significant figures.
cBased on volume of 743,000 gallons.

when it is needed for a particular reuse application.
These parameters are, in turn, affected by*a wide range of conditions that could arise during the cleanup.
Thus, all the alternative combinations of' availability versus reuse applications cannot be addressed.
Those sets of alternatives which bound availability and also bound potential reuse applications can be considered.
These sets of bounding conditions are presented below.
F.2.1

Availability

Processed accident water availability is shown as a function of time in Figure F.1.
Time "zero"corresponds to initiation of reactor building sump water processing.
About 743,000 gallons ofprocessed AFHB accident water are in storage. 'This represents the volume currently available forreuse.
The maximum volume shown is about '1,540,000 gallons.
This represents the additional
processed water that could result from processing reactor building sump water and reactor coolant
system water.
Two alternatives for processing this accident water are shown in Figure F.1 tobound the time frame for availability.
As shown, the maximum volume will be available between
about 6 months and 13 months after processing is initiated.
F.2.2

Potential Reuse Applications

Processed accident water could be used for many of the operations that require large volumes ofwater.
The potential uses include:-

Decontamination of the Reactor Building.
Between 70,000 and 230,000 gallons may berequired to perform the semiremote decontamination operations on the reactor building
interior as described in Section 5.2.
The most likely volume is about 150,000 gallons.

-Shielding for Processing Equipment.
If a zeolite-based system is used to treat reactor
building sump water, the equipment will be installed in spent fuel pool B. About
230,000 gall-ons of water will be needed to shield this equipment during operation.

-

Defueling.
Prior to removal of the reactor vessel head and during defueling operations,about 1,040,000 gallons of borated water will be needed to fill spent fuel pool B(230,000 gallons), the cask pit (30,000 gallons), spent fuel pool A (440,000 gallons)
and the fuel transfer canal (350,000 gallons).

. 1. 1II
F-3

1600-

/

1400o
•

1200o

/

//

=
0

Inl

/

10001
800

Minimum
743,000 gallons

0

600
400
_

200
0

CASE

-®BESTi

Q

Assumes 700,000 gallons in reactor building
sump, 100,000 gallons of recycled deconwater, 70,000 gallons of RCS water ore.processed by one. system, at 2 gpm (86,000•gal/mo) on a once-through basis. Change .

Assumes 700,000 gallons in reactor
building sump processed by one
system at 3 gpm (130,000 gal/mo).
RCS liquid processed simultaneouslywith a second system.

E I

WORST. CASE

•inslope reflects feed and bleed processingof RCS liquid in some system at 2 gpm.

I

I

i

i

I

i

I

I

I"

i

I*

0

3

6

4

12

15

18

21

24

27

30

I~

TIME (months)
Figure F.1.

Processed Accident Water Availability.

RCS Flushing.
Following defueling, the reactor coolant system will be flushed withwater to attempt to remove particulates and radioactivity that could be mobilized
during defueling.
About 250,000 gallons of water will be needed for this flushing.
RCS Decontamination.
After flushing, the reactor coolant system will be decontaminated.
The volume of water needed depends on the techniques used.
The staff estimates thatabout 100,000 gallons will be needed if the CAN-DECON technique is used.
If the othertechniques being considered are used, e.g., AP-Citrox, APAC, NS-1, or OPG, about
500,000 gallons, or about five reactor coolant system volumes, of water will be required.
Processed accident water also could be used to satisfy post-cleanup program needs.
uses include:-

The potential

Shielding.
Spent fuel assemblies and high-radiation-levelpackaged waste could be
stored underwater in the spent fuel pools and cask pit. About 690,000 gallons of water
would be required.

F-4Startup Inventories.
Refueling and startup, if such activities are permitted, would
require a minimum inventory of 100,000 gallons to refill the reactor coolant system andabout 300,000 gallons in the borated water storage tank to meet technical specifications.
These potential uses of processed accident water are summarized in Table F.2.
The needs varywith time, and processed water used to satisfy one need can be processed again and recycled tosatisfy a future need.
The extremes considered for water volumes and timing of these reuseapplications during the cleanup program are illustrated inFigure F.2.
Time "zero" shown on
this figure represents the initiation of processing water in the reactor building sump.
The major difference between the two cases considered is the elapsed time to complete decontamination of the RCS.
Under assumed best-case conditions, this can be accomplished over a 24-month.""period; worst-case conditions require a 36-month period.
For both cases the staff has assumed
that water used for shielding can be used during defueling without retreatment, that only thefuel transfer canal is emptied after defueling, and that primary system flush water is retreatedand used during primary system decontamination.

Table F.2.

Summary of Potential Uses of Processed Accident Water

Potential Use

Volume(gallons)

Remarks

During Cleanup Program1.

Decontamination of building surfaces

150,000

Can be processed with sumpliquids.

2.

Shielding for processing equipment.

230,000

Can also be used for defueling withouttreatment.

3.

Defueling

4.

RCS flushing

5.

RCS decontamination

1,040,000
250,000

Borated water needed.
Can be treated and used fordecontamination in Item (5).

100,000 to 500,000

After Cleanup Program
1.

Shielding in spent fuel pools

2.

Startup inventory

690,000= 100,000

Borated water.
Depends on whether TMI-2 isrestarted.

I

L

F-5

Minimum Needs (solid line)

1600
1400
0

0

0

1200
1000

A. Fill SFP 'A' to cover processequipment - 230,000 gallons.
B. Process RB/RCS liquid waste.
C. Fill SFP's and FTC for defueling!,040,000 gallons.
D. Perform defueling - assumes 50,000gallon makeup.
E. Empty FTC - 350,000 gallons.
F. RCS flushing - 250,000
gallons.
G. RCS decon - minimum
100,000 gallons.

1,540,000 gallons
Maximum Availability

I

A !,/
®

I®®
-o

-LJ

800-

743,000 qallons
Current Availability

600F

V~V

Maximum Needs (dashed line)

00 I.. Gross decon of RB - 100,000 gallons. -2. Fill SFP 'A'to cover process equipment
230,000 gallons.
liquid
3. Processwaste. recycled decon water, RB/RCS

C0

400 k

])4. Fill SFPs and FTC for defueling - 1,040,000 gal.

1~
200F

5. Perform defueling- assumes 50,000-gallon

120

j
0

/

0

3

makeup.
6. Empty FTC- 350,000 gallons.
7. RCS flushing - 250,000 gallons.
8. RCS decon - maximum 500,000 gallons.

I

I

I

I

6

9

12

15

I

I

I

I

I

18

21

24

27

30

to H. Dieckamp,

GPU,

TIME (months)
Figure F.2.

Potential

Processed Accident Water Needs.

Reference
1.

Letter from J. Ahearne,
January 12, 1981.

U.S. Nuclear Regulatory Commission,

33

36

-

APPENDIX G - ENGINEERING CONSIDERATIONS FOR TREATMENT OF TMI-2 ACCIDENT-GENERATED LIQUID WASTE

G.1

INTRODUCTION AND SUMMARY

Nine alternative systems were considered for treatment of TMI-2 liquid wastes:(1) the submerged
demineralizer system (SDS), (2) a modified SDS, (3) the EPICOR II system, (4) a modified EPLCOR II
system, (5) a zeolite/evaporator system, (6) a zeolite/EPICOR II system, (7) an SDS/EPICOR II
system, (8) an evaporator/resin system, and (9) a bitumen/resin system.
The data and assumptions
used to characterize the liquid waste to be treated by these systems and the performance characteristics of system components and overall systems are presented in this appendix.
The assumptions used to estimate the quantities and characteristics of the process solid wastes generated
through use of these systems are also presented.
A matrix of the liquid waste sources that could require treatment and the alternative treatment
systems evaluated in this Appendix for treatment of these liquids is presented in Table G.1.*
As shown, 27 liquid waste/treatment system combinations were evaluated.
The data and/or assumptions used to characterize liquid waste prior to treatment are presented in
Section G.2.
The data and assumptions used to characterize the performance of the alternative
treatment systems are presented in Section G.3. These data and assumptions characterize representative performance parameters for the systems described; the actual performance of a particularsystem will vary from the assumed parameters.
However, the assumed performance parameters havebeen applied' consistently and provide a reasonable basis for comparing the relative performanceof the systems considered.
The assumptions used to characterize the process solids wastes that could be generated from eachsystem/liquid waste source combination are presented in Section G.4. Summaries of the processedwater characteristics are presented in tabular form in Section G.5. Similar tables are used tocharacterize process solid waste in this section.
To simplify the presentation of information inthis Appendix, all radionuclide inventories are presented in curies and volumes are presented ingallons.**
G.2

BASIS FOR LIQUID WASTE CHARACTERISTICS

The gross curie content of the various soqrces of liquid waste that could be treated during
cleanup of TMI-2 are shown in Table G.2. The suitability of these liquids for treatment depends
on their physical and chemical characteristics.
The characteristics of reactor building sump
water given in the table are based on the analysis of reactor building sump water samples.
Similar sample data were available for RCS primary system water.
For the other sources of liquid
waste shown in Table G.2, the characteristics of and the distribution of radionuclides in theliquid were either inferred from other available data or were assumed.
The assumptions used tocharacterize sources of liquid waste are discussed below.
G.2.1

Reactor Building Sump Water

The reactor building basement contains about 700,000 gallons of sump water containing fission
products, borates, sodium hydroxide, and sediment and debris from the accident.
The pH of thewater is 8.6.1
Estimates of the amounts of dissolved and filterable materials in the water,
based on published analyses of the sump water composition, 1 ' 2 are given in Tables G.3 and G.4.
These values have been updated to September 1, 1980, to account for additional radioactive decay.
The radionuclide inventory is about 500,000 Ci and the principal radionuclides of concern are
cesium and strontium.

*Tables, figures, and references follow text.
**To obtain concentrations in pCi/mL, divide the curie content by the volume in gallons andmultiply the result by 264.
G-1

G-2
The volume of additional liquids that may be added to the sump from early reactor building decontamination operations is estimated by the staff to be 100,000 to 200,000 gallons.
Therefore, thesump could contain as much as 900,000 gallons.
The estimated radionuclide content of these
additional liquids is about 90 Ci, so their contribution to the sump inventory is negligible. Oiland grease are likely to be present in the sump liquids.
A conservative estimate of the amountof such materials is 2.4 mg/mL of liquid.
G.2.2

Reactor Coolant (Primary)

System Water

About 96,000 gallons of reactor coolant system (primary) water will require treatment.
The
radionuclide concentrations for the primary water are given in Table G.5. The average concentration of radionuclides in this water is about 5.9 x 101 pCi/mL, 3 and the total radionuclide
inventory is about 20,000 Ci.
G.2.3

Reactor Coolant System Flush and Drain Water

The reactor coolant system (RCS) water is contaminated with fission products and core debris as aresult of the accident.
Particulate material would be removed by filtration using a core filter
within the reactor vessel and additional filters on the reactor coolant system drains in order totrap particulates during the flush and drain activities.
The RCS flush and drain operations willproduce contaminated water that will require decontamination.
It was assumed by the staff thatthe effluent from all the flush and drain operations will be pumped into the reactor coolant
bleed holdup tank, from which water will be taken for decontamination.
The exact volume of waterthat will be processed during the RCS flush and drain operation is unknown, as is the exact
radionuclide concentration of that water.
The staff has estimated that 2.5 RCS volumes, or
250,000 gallons of contaminated liquid, will be processed.
It is further estimated that theliquid will contain between 20,000 Ci and 100,000 Ci of contaminants distributed in the same
proportion as in the primary water.
It is also estimated that about 2000 Ci of solid debris will
be collected on the prefilters preceding each ion-exchange treatment alternative.
The assumed
characteristics of these liquids and solids are given in Tables G.6 and G.7, respectively.
G.2.4

RCS Decontamination Solutions

The decontamination of the reactor coolant system components can be considered principally as
removal of fission-product plateout.
The staff expects that particulates would. be removed duringdraining and flushing, and plateout would be removed by use of decontamination reagents.
The liquid capacity of the reactor coolant system of TMI-2 without fuel is about 96,000 gallons.
The radioactive contamination level of the reactor coolant surface is estimated by the staff torange from 10 pCi/cm2 to 100 pCi/cm2 . This range is based upon the RCS surfaces being contaminated by a factor of 100 to 1000 times greater than horizontal surfaces in the reactor building.
The surface area of the reactor vessel and heat exchanger-tubing is about 2.25 x 108 cm2 ; therefore, the staff expects total radioactivity on the reactor coolant system surfaces to range from2000 Ci to 20,000 Ci.
This quantity of radioactivity could be removed during decontamination
operations.
The estimated volume of liquid waste varies with the technique used.
It was assumed that if the
CAN DECON technique is used, about one RCS volume of liquid waste--100,000 gallons--would be
generated on a feed and bleed basis.
It was assumed that if the more aggressive chemical techniques are used, about five RCS volumes--500,000 gallons--would be generated.
The distributionof radionuclides in these liquids (exclusive of tritium), regardless of the volume generated, wasassumed to be the same as that in the RCS primary system water.
G.2.5

AFHB Chemical Decontamination Solutions

About 2200 gallons of these liquids were generated through September 30, 1980.
Through this same
period about 80 percent of the areas requiring "hands on" cleanup were finished.
Since theremaining areas have higher levels of contamination and are more difficult to decontaminate, it
was assumed that about three times as much liquid, or about 7000 more gallons, would be generated
through completion.
The estimated activity to be removed was 60 Ci, which- is about 50 percent of
the activity in the liquids already generated.

II

U

G-3
G.2.6

RB Chemical Decontamination Solutions

The estimated volume of these liquids is 30,000 to 50,000 gallons, the average volume of 40,000
gallons is assumed in this appendix.
The radionuclide distribution in these liquids was inferredfrom swipe samples taken during reactor building entries.
The major contaminants considered were
cesium and strontium.
G.2.7

Summary

The estimated curie content in each of the liquid waste sources described above is listed inTable G.8.
Tritium is shown only for reactor building sump water and primary system water, sincethese sources plus the AFHB water already processed comprise the accident-produced tritium inventory.
If processed water is reused for the other applications shown on Table G.8, the tritiumcontent present in the effluent after treatment will correspond to what was in the processedwater prior to reuse.,
G.3

BASIS FOR TREATMENT SYSTEM PERFORMANCE CHARACTERISTICS

To compare alternative treatment systems on a relative basis, the performance of the systems
considered was inferred from (1) the performance of the EPICOR II system used to cleanup AFHB
liquids, (2) laboratory-scale tests on zeolite-based ion-exchange systems, and (3) the performanceof similar systems used to treat liquid wastes containing radionuclides and chemical contaminants.
of the same or similar species to those present in TMI-2 liquids.
The assumptions used to characterize treatment system performance are conservative relative to the decontamination factors that.
could be achieved.
Moreover, the actual performance of any treatment system can be adjusted byvarying operating criteria to achieve the decontamination factors desired for a particular sourceof liquid waste.
Therefore,: while the performance of the systems described in this appendix will
vary, the staff believes that the performance characteristics presented below are representativeand provide a consistent basis for comparing alternative treatment systems.
The performanceparameters which characterize each of the systems considered are discussed below.
G.3.1

Submerged Demineralizer System (SOS)

One treatment process considered for decontaminating the sump water is the submerged demi.neralizer
system (SDS) described by Met-Ed and (with chemical engineering in greater detail) by Brooksbank
and Armentol and by Campbell et al. 2 The process consists of removal of solids by filtration,
followed by removal of cesium and part of the strontium by use of an inorganic zeolite ion exchanger
The remaining ionic radionuclides are removed by use of a cationic'resin bed followed by a mixed
resin bed.
A process flow diagram is shown in Figure G.1.
Filtration would be accomplished by the use of disposable cartridge filters. 2 The volume offilter waste was calculated by assuming a filter loading of 2.8 x 10-1 m3 per Ci.A As further
characterization of sump particulate progresses, the exact filtration media may be modified.
The results of laboratory tests suggest a modified submerged demineralizer system would improve
the removal of cesium, strontium, and antimony, which are the major radionuclides in the effluentof the SDS process. 4 The modification involves the expansion of cation resin volume to 40 ft 3 (afivefold increase).
This modification is expected to change the character of the waste solution
by adsorbing sodium on the cation column, releasing H to change the acidity of the waste solution entering the polishing column.
According to laboratory tests, the polishing column as
modified is expected to absorb antimony and effect further reduction of cesium and strontium. A
process flow diagram is shown in Figure G.2.
In the preparation of this flowsheet and in the analysis of the application of this process to
specific liquid waste sources, the staff made several assumptions concerning decontamination
factors (DFs) and breakthrough volumes for various ions.s' 6 These assumptions for both systems,
along with pertinent references, are given in Table G.9.
G.3.2

EPICOR II

SystemThis system has been used to decontaminate AFHB water and is described fully in Appendix D.
Actual performance data for a batch of AFHB water processed through this system is shown in
Table G.1O.
The decontamination factors used to evaluate EPICOR II on a comparative basis thatwere inferred from these data are shown in Table G.11.
A process flow diagram for EPICOR II ispresented in Figure G.3.

G-4
G.3.3

Modified EPICOR II

This system uses a zeolite ion exchanger in place of the EPICOR II first-stage prefilter ion
exchanger. 7 ' 8Since the EPICOR II cation exchange vessel is comparable in size to the cation
vessel in the modified SDS, and the size of the mixed-bed ion exchanges are also comparable, theperformance of this system should be comparable to the modified SDS.
Therefore, the inferredperformance characteristics of this system are the same as those shown in Table G.9 for themodified SDS.
A process flow diagram for this system is shown on Figure G.4.
G.3.4

Zeolite/Evaporation

The zeolite/evaporation process consists of removal of solids by filtration (when necessary),
followed by removal of cesiumand part of the strontium and other radionuclides by use of an
inorganic zeolite ion exchanger.
The radionuclides remaining after this step are removed by anevaporation treatment process.
The relevant evaporator properties are given in Table G.12.
The
performance characteristics of the mixed-bed ion exchanger used to polish condensate were assumed
to be the same as those shown in Table G.9 for the modified SDS system.
A process flow diagram
for this system is shown on Figure G.5.
G.3.5

Zeolite/EPICOR II

The zeolite/EPICOR II process consists of removal of solids by filtration, followed by removal ofcesium and part of the strontium by use of an inorganic zeolite ion exchanger.
The zeolite
treatment reduces the radioactivity levels of the process stream for input to the EPICOR II
system.
EPICOR II is an 'ion-exchange system designed to process liquid waste-with radionuclide
concentrations between 1 and 100 pCi/mL.
A process flow diagram is shown in Figure G.6, andassumed decontamination factors are shown in Table G.13.
G.3.6

SDS/EPICOR II

The combination of two complete treatment systems can be used, as demonstrated 6y the SDS/EPICOR II
alternative, to offset process characteristics that may exclude either process alone as a feasible
alternative.
In this case, the SDS system may not provide adequate decon-tamination factors, andthe radionuclide concentration of the sump liquids exceeds the specification for influent liquids- to.EPICOR II.
The SDS system was discussed previously in Section G.3.1 and the EPICOR II system..was. discussed in Section G.3.2.
A process flow diagram for the combined systems is shown in
Figure G.7 and combined decontamination factors are shown in Table G.14.
G.3.7

Evaporator/Resin

The evaporator/resin process consists of evaporation followed by treatment of the condensate byuse of a cation resin and a mixed-bed ion-exchange resin.
The relevant evaporator properties andthe ion exchanger decontamination factors are given in Table G.15.
A flow sheet for this process
is given in Figure G.8.
Filteration would be a preliminary step to diminish formation of foam. 9
It is assumed by the staff that 0.1 percent of the radionuclides contained in the condensate
stream would be carried off as aerosols or gaseous material that would have to be treated. The.volume of this stream was not estimated, but it should be possible to remove this material byfiltration of the off-gases.
G.3.8

Bitumen/Resin

In the bitumen/resin process alternative, liquids would be concentrated by evaporation and directly
incorporated into bitumen.' 1 , 12 The bitumen product would be formed during the evaporation stepby mixing the waste stream with bitumen.
The evaporator condensate would be treated further by
cation and mixed-bed resins.
A flow diagram for this process is given in Figure G.9.
The decontamination factors and other relevant parameters assumed for the evaporation/bituminization stepand for the ion-exchange steps of this process are given in Table G.16. As with evaporation, it
was assumed that a gaseous effluent carrying 0.1 percent of the condensate would be formed.
G.3.9

Summary

The systems characterized above are composed of successive treatment stages or components, witheach stage contributing to the overall performance of the system.
The performance parameters foreach component in each system are summarized in Table G.17.

I I

I

I

I
II

I

I

G-5
The overall performance of a system can be characterized by the decontamination factor achievedby all components in a system.
The overall decontamination factors for all the treatment systems
considered are summarized in Table G.18.
This table was used to determine the characteristics ofeffluents that would arise when systems are used to treat various liquid waste sources.
G.4

BASIS FOR PROCESS SOLID WASTE ESTIMATES

Treatment of liquid waste with the systems described above will lead to the generation of processsolid waste.
This waste will consist of expended zeolites, expended organic resins (cation andmixed bed), filter cartridges, evaporator bottoms, and bituminized liquids.
The basis for estimating the characteristics of thesewastes is discussed below.
G.4.1

Expended Zeolites

Zeolites are used for first-stage removal of gross amounts of cesium and strontium.
For cleanupof reactor building sump water, these water ion-exchange media are used in lots of six vessels
containing 8 ft 3 of zeolites each.
Thus, waste Volumes were estimated in lots of 48 ft 3 zeolite
each.
Each vessel was assumed to contain a minimum of 10,000 Ci and a maximum of 120,000 Ci.
The distribution of the Cs and Sr radionuclides in the waste was obtained from the curie differential across the ion-exchange vessels using the zeolite decontamination factors in Table G.9.
For liquids other than reactor building sump water, the estimated loading was 10,000 Ci pervessel.
Where SDS-type systems were used, waste was generated in lots of six vessels, but themodified EPICOR II system was assumed to generate vessels one at a time.
The radionuclide distributions of Cs and Sr were obtained from curie differentials across the vessel using zeolite
decontamination factors in Table G.9.
G.4.2

Organic Resins

The organic resins that could be generated from treatment of liquids with the EPICOR II systemwere estimated from experience to date.
This experience indicated that about 99.5 percent of theactivity was removed by the prefilter vessels and 0.5 percent was removed by the cation andmixed-bed vessels.
Of the 0.5 percent, removed in the last two stages, it was assumed that 0.475
percent (95 percent) of the activity was removed by the cation vessel.
The distribution of theradionuclides in EPICOR II waste was inferred by assuming that the last two'stages of an EPICOR IH
system had the same decontamination factors as the cation and mixed-bed ion-exchangers in themodified SDS (see Table G.9).
For SDS type systems, cation organic resins were assumed generated in lots of two beds each 3
3(2 at 8 ft 3 or 2 at 40 ft ) and mixed-bed vessels were generated in lots of one bed or 115 ft
each.
Vessels were replaced based on curie loading, not breakthrough.
The distribution ofradionuclides in these wastes was determined from the curie differential across the vessels using
the decontamination factors in Table G.9.
For modified EPICOR II systems, both cation and mixedbed vessels were assumed to be generated in lots of one bed each--30 ft 3 for cation and 110 ft 3
for mixed bed.
For other systems where organic resins were used for polishing, such as evaporator/resin andbitumen/resin, the polishing train was assumed to consist of one 30-ft 3 cation vessel arid one
110-ft 3 vessel, and one vessel of each type was required for distillate/condensate polishing.
G.4.3

Filters

Filtration was considered necessary for pretreatment of reactor building sump water and RCS flush
and drain water.
For reactor building sump water, filter performance was based on the solids content of the r~actor
building sump water (see Table G.4), the size, and the assumed filter loading of 2.8 x 10- 1 m perCi.
For RCS flush and drain water, it was assumed that 2 percent of the influent curie inventory for
Cs, Sr, Ce, Ru, Co, Te, Zr, and Nb would be suspended solids removable by these same filters.

I

G-6

G.4.4

Evaporator Bottoms

Evaporators were considered for first-stage treatment of certain liquids, as well as for polishing.
For first-stage treatment, it was assumed that the volume reduction factor varied between 10 and
30 for chemical-based liquids and was.100 for aqueous liquids. The curie content and radionuclide
distribution in the bottoms was determined from the differential between the radionuclide invenThe gross concentration of the bottoms wastory in the influent and that in the distillate.
obtained by dividing the bottoms radionuclide inventory by the reduced volume.
G.4.5

Bituminized Solids

An extruder/evaporator is considered for first-stage treatment of certain liquids.
To characterize the waste from this system, it was assumed that the volume reduction factor was 20 andthat one part by volume of the evaporator bottoms v'as combined with one part asphalt. Thus, 100
gallons of influent 'would produce 10 gallons of bituminized solids consisting of 5 gallons ofconcentrated waste and 5 gallons of asphalt.
The curie content and radionuclide distribution in the bituminized solids was determined fromthe differential between the radionuclide inventory in the influent and that in the distillate.
The gross concentration in the bituminized waste was obtained by dividing the bottoms radionuclide
inventory by twice the bottoms volume.
G.5

SUMMARY OF RESULTS

The liquid and process solid waste effluents that could arise from treatment of TMI-2 liquids
with various treatment systems were characterized by liquid waste source.
These characterizations, in terms of radionuclide inventories, are presented below.
The characteristics of the process solid waste characteristics are based on the individual stage
decontamination factors presented in Table G.17 and the assumptions described above in Section G.4.

Characteristics of Liquid Effluents (processed water)

SourceVolume (gal)

Reference

RB Sump Water

700,000

Table G.19

RCS Primary System Water

96,000

Table G.20

RCS Flush & Drain Water

250,000

Table G.21

RCS Aqueous Decon Solutions*

100,000

Same as Table
G.20

RCS Chemical Decon Solutions*

500,000

Table G.22

RB Chemical Decon Solutions

40,000

Table G.23

*Mutually exclusive alternatives

I

N

Table G.1.

(A)

Treatment Alternatives Suitable for TMI Liquidsa

(B)

(0)

(C)

(F)

(E)

(G)

(H)

Type of Liquid to be Processed

Treatment System
Alternative

AFHB
ChemicalDecontamination
Solutions

Reactor
Building
Sump Water

Reactor
Building
Decontamination Water

Reactor
Building
Decontamination
Chemicalsc

Reactor Coolant System
Cooli"gWater

Flush and
Drain
WaterdDecontamination
Watere1. Zeolite Alternatives(a)Zeolite/resin (SDS)(b)

Zeolite modified
resin (Mod SDS)

*

*

A

A

(c) Zeolite/evaporator

*

*

*

*

(d)

Zeolite/EPICOR II

A

A

A

(e)

SDS/EPICORIIT

*

A

*

(f)

Modified EPICOR. II

*

*

2.

EPICOR II

3.

Evaporator/resin

4.

Bitumen/resin

aNote:*(f)* indicates system to be discussed as an alternative method.

bAlternative in the event this water is not processed along with reactor building sump water.
cChemical properties of these liquids are not compatible with purely ion-exchange alternatives.
dIon-exchange processes provide adequate alternatives.
eprocessing of CAN DECON decontamination solutions will probably require system alignment changes.
fOnly if

reactor building decon water collected separately from the reactor building sump water.

A*

Decontamination
ChemicalscG.-8

Table G.2.

Estimated TMI-2 Liquid Waste Summary

Source of Liquid Waste
1.
2.
3.
4.
5.

6.

AFHB chemical decon solutions
Reactor building sump water
RCS water
RCS flush and drain water
Reactor building decon solutions(a) Water based(b) Chemicalb
RCS decon solutions(a) Water based(b) Chemical.

Volume(gallons)

Curie Inventory
In.Untreated Liquid
Maximum
Minimum

7,000
700,000'96,000
250,000

60
500,000*20,000
20,00060
500,000,
20,000100,000

1 5 0 , 0 0 0a

90
10

90
10

2,000
2,000

20,00020,00040,000a100,000a
500, 0 0 0 a

aprocessed water could be used for these cleanup activities.
bThe RCS water-based and chemical

decontamination processes are mutually

exclusive.
Either the water-based or chemical process will be. used in thedecontamination of the RCS.

Table G.3.
Estimated Concentrations of Dissolved
Contaminants in Reactor BuildinR,;ump Water
as of September 1, 1980

Contaminant

Sump Water
Concentration(pCi/mL)

H-3
Cs-137
Cs-134
Sr-90
Sr-89
Zr-95
Nb-95
Ru-106
Sb-125
Te-125m
Te-127m
Te-129m
Ce-1441-129

9.5 x 10-1
1.6 x 102
2.4 x 101
2.6
7.x 1072
2 x 10-5
1 x 10-s
3 x 10-3
2 x 10-2
5 x 10-4
5 x 10 -4
2 xlO- 4
2 x 10-3
1.2,x 1 0 -s5

Contaminant,
U
Pu
Na
B
Cl
Al
Ca
Cu
Fe
K
Li.
Ni
P
Rb
S
Zn

Sump Water
Concentration(pg/mL)
2.8 x
3.3 x
1.2 x
2.0 x
1.5 x

10-2
10-5
103

103
101

3
10
10
1.8
4
1.6
3
3 x 10-1
3 x 10-1
9
5 x 10-iaThe reactor building sump water volume is 700,000 gallons.

bFrom R.E.

Brooksbank and W.J. Armento, "Post Accident Cleanupof Radioactivity at the Three Mile Island Nuclear Power
Station," Oak Ridge National Laboratory, ORNL/TM-7091,
February 1980; and D.O. Campbell, Hot Cell Studies," Oak
Ridge National Laboratory, presentation to Central
Public Utilities and U.S. Dept. of Energy staff members,
January 31, 1980, corrected for decay.

I

G-9

Table G.4.
Filterable Solids inReactor Building Sump Wae% asof September 1, '1980

Radionuclide.Sump Water
Concentration(PCi/g)Cs-137
Cs-134
Nb-'95
Zr-95
Ru-106
Ru-103Ce-141
Ce-144
Co-58
Co-60
Sr-90
Ag-110m
Sb-125
Te-127m

7.1 x 10-1
1.1 x 10-1
1.7 x 10-3
3.7 x 10-3
1.8 x 10-1
1.4 x 10-4
3.8 x 10-6
8.3 x 10-2
7.7 x 10-4
1.1 X 10-2
8.6
5.9 x 10-3
2 x 10-1
2.7 x 10-1

aTotal solids

13 x 101 kg(assuming solids content ofapproximately 0.5%).

bFrom R.E. Brooksbank and
W.J. Armento, "Post-Accident
Cleanup of Radioactivity at theThree Mile Island Nuclear Power
Station," ORNL/TM-7081, February
1980, corrected for decay.
Table G.5.
Estimated Concentrations of Contaminants in theReactor Coolant System asof September 1, 1980

Radionuclide

Concentrationa(pCi/mL)

H-3
Cs-137
Cs-134
Sr-90
Sr-89
Zr-95
Nb-95
Ru-106
Sb-125
Te-125m
Te-127m
Te-129m
Ce-144Co-58

8 x 10-2
2.9 x 101
4.5
2.3 x 101
2.4
5 x 10-4
8 x 10-4
1 x 10-' 3
4 x 106 x 10-3
3 x 10-1
1 x 10-3
3 x 10-2
2 x 10-4

aFrom "TMI-2 Data Base Update,"released by Argonne National
Laboratory, J.E. Robinson,
December 23, 1980.

I

I

I

G-10

Estimated ConTable G.6.
centrations of Contaminants
in Reactor Coolant System
Flush and'Drain

Radionuclide

Concentrationa(pCi/mL)
5.2 x 101
8.1
4.1 x 101
4.3
9.0 x 10-4
1.4 x 10-3
1.8 x 10-1
7.2 x 10-3
1.1 x 10-2
5.4 x 10-i
1.8 x 10-3
5.4 x 10-2

Cs-137
Cs-134
Sr-90
Sr-89
Zr-95
Nb-95
Ru-106
Sb-125
Te-125m
Te-127m
Te-129m
Ce-144aConcentrations based on maximum
inventory of 100,000 Ci, withradionuclide distribution thesame as primary system water.

Table G.7.
Estimated
Radioactivity Contained in
Solid Debris in Reactor
Coolant System Flushand Drain Water as of
September 1, 1980

Radionuclide

Total
Curiesa

Cs-137
Cs-134
Sr-90
Sr-89
Zr-95
Nb-95
Ru-106Ce-1447.4 x 101
1.5 x 101
1.5 x 102
1.2 x 101
7.2 x 101
8.5 x 101
2.5 x 102
1.4 x 103

Total

-'

2.1 x 103

aBased on assumption that
input stream has been
filtered to'remove essentially all of the fueldebris prior to processing.

Table G.8.

Summary of Liquid Waste Radionuclide Inventories

RCS Flush andDrain Water a

RCS Decontaminstion solutions

Reactor Building
Decontamination
Solutions

AFHB Decontamination Solutions

9.9 x 103

4.9 x 104

9.9 x 103851

6.6 x 104

1.5 x 103

7.5 x 103

1.5 x 103

2

8

Sr-90

7.0 x 103

7.8 x 103

3.9 x 104

Sr-89

1.9 x 1028.2 x 1024.1 x 103

7.8 x 103
8.2 x 1021-129

3.2 x 10-2

NA

NA

NA

Zr-95

5.3 x 10-2

1.7 x 10-1

8.5 x 10-'1.7x 10-'Nb-95

4.9 x 10-2

2.7 x 10-1

1.4

2.7 x 10-1

Ru-106

1.0 x 101

3.4 x 101

1.7 x 102

3.4 x 101

Ru-103

1.8 x 10-3

NA

NA

NA

Sb-1255.6 x 101

1.4

7

1.4

-

Te-125m

1.3

2

10

2

-

Te-127m

4.8

1 x 1025 x 1021 x 102-

Te-129m

5.3 x 10-1

3.4 x 10-1

1.7

3.4 x 10-1_

Ce-144

1.6

1 x 10'5 x 1011 x 10'-Ce-141

4.9 x 10-s

NA

NA

NA

Co-60

1.4 x 10-1

NA

Co-58

1 x 10-2

6.8 x 10-2NA
3.4 x 10-1NA
6.8 x 10-2

Aq-110m.

7.7 x 10-2

NA

NA

NA

2 x 104

1 x 105

2 x 104

Major
Radionuclide

Reactor Building
Sump Water

Reactor Coolant
System Water

H-3

2.5 x 103

2.7 x i01

Cs-137

4.3 x 105

Cs-134

1

Total(rounded)aMaximum inventorybMaximum inventory

5 x 10510

of 100,000 Ci.

If minimum of 20,000 Ci removed values shown will be reduced by a factor of 5.

of 20,000 Ci.

Ifminimum of 2000 Ci removed values shown will be reduced by a factor of 10.-60

Influent

Spent
CationBed Resins

Spent
Zeol ite*6 @ 8 ft3 each**2 @ 8 ft3 eachtl @ 115 ft3

Figure G.1.

Effluent

Process Liquids

Process Liquids

J
Process Flow Diagram for Submerged Demineralizer System.

Spent
Mixed
Bed Resins

W-

Influent

Process Liquids

Spent
ZeoliteI

Elm

Effluent

Process Liquids

Spent
CationBed Resins

Spent
Mixed
Bed Resins*6 @ 8 ft3 each**2 @ 40 ft3 each3
ti @ 115 ft

Figure G.2.

Process Flow Diagram for Modified Submerged Demineralizer System.

G- 14

Table G.9.
Process Decontamination Factors and BreakthroughVolumes for Submerged Demineralizer Type Systemsa
Exchange Material

SDS Value

Modified SDS Value

200 column volumes

200 column volumes

5 x 104
8.5 x 10 2
1
1

5 x 10 4
8.5 x 102

8 ft 3 volume

40 ft 3 volume

Cs

1

10

Sr

1

3

Ru

1

3

Ce

1

2.5

Sb
Other cationsc

1
1

1
1

Anions

1

1

Cs

2

6

Sr

2

2

Ru

2

5

Ce

2

2

I
Sb

2

2
1i00

All other soluble species

22

Zeolites
Breakthrough volumeb
Decontamination factors
Cs

Sr
Other cations
AnionsCation Exchange Resin (H+ form)

1
1

Decontamination factors

Mixed-Bed
Decontamination factors

aReferences:
D.O. Campbell, E.D. Collins, L.J. King, and J.B. Knaver, "Evaluation of Submerged Demineralizer System (SDS) Flow Sheet for Decontamination of HighActivity-Level-Water at the Three Mile Island Unit 2 Nuclear Power Station,"
Oak Ridge National Laboratory, ORNL/TM-7448, July 1980.
R.E. Brooksbank and W.J. Armento, "Post-Accident Cleanup of Radioactivity at
the Three Mile Island Nuclear Power Station," Oak Ridge National Laboratory,
ORNL/TM-7081, February 1980.
R.L. Schwoebel, "The Management of Radioactive Waste:
an Alternative," PB-254737, pp. 307-323, 1976.

Waste Partitioning as

K.H. Lin, "Use of Ion Exchange for the Treatment of Liquids in Nuclear Power
Plants," Oak Ridge National Laboratory, ORNL-4792, December 1973.
b"Breakthrough volume" is the processing volume that necessitates replacement orregeneration of the resins; 200 column volumes for all data.
CExcept H+, Na+, and Li+.
dExcept H+.

L

G-15

Table G.10.

IsotopeH-3
Cs-137
Cs-134
Sr-90
Sr-89
1-129
Nb-95
Zr-95
Ru-103Ce-144Ce-141
Co-58
Co-60
Ag-110m
Sb-125
Te-125m
Te-127m
Te-129m
Ru-106
1,

NU

-

Not

EPICOR-II Performance for Batch No.
pCi/ccInfluent

pCi/ccEffluent

4.3 x 10-2
5.6 x 101
9.2
5.9 x 10-1
6 x 10-1ND
1.9 x 10-5
1.2 x 10-4
9.9 x 10-t
1.7 x 10-3
1.6 x 10-s
2.1 x 10-4
8.7 x 10-5
1.8 x 10-5
1.2 x 10-3
2.7 x 10-4
ND
ND
5.1 x 10-4

4.3 x 10-2
< 3.4 x 10-6
< 5 x 10-6
1.8 x 10-6
8.6 x 10-6
ND
< 4 x 10-8
< 5.9 x 10-8
< 9.4 x 10-8

41--AFH8 Water
Approximate
DF
1

107

107
105
i0
ND
103

103

< 8.5 x 10-7

103
103

1.9 x 10-7

103

< 2.9 x 10-6
< 4.6 x 10-6

10
10
10

<

< 4.1 x 10- 7< 3.1 x 10-8
< 7 x 10-9
ND
ND
< 6.9 x 10-7

104
103

ND
ND
1.03

uetected.

Table G.11.

Decontamination Factors Assumed
for EPICOR-II Systema

Radionuclide

Decontamination
Factor

Cs
Sr
Ru
Ce
1
Sb

107

All Other Soluble Species

103

alnferred from EPICOR II

105
103
103.
10D
103

performance on AFHB

water.
blnferred from EPICOR-I processing experience.

-

M

I

I

I

Influent

Process

Spent Cation
Bed Resins-

Spent IonExchange Media•1@ 30 ft3**1@ 30 ft3
tl@ 110 ft3

Figure G.3.

Effluent

Process Liquids

Process Flow Diagram for EPICOR II System.

Spent Mixed
Bed ResinsComponents from EPICOR II

Influent

Zeolite

Bed*
Process Liquids

=!

Resin
CationBed•'

Process Liquids

Resin
Mixed
Bedt

-

I-.

Spent
ZeoliteSpent
CationBed Resins

Spent
Mixed
Bed Resins

3
i1 8 ft
3**I @ 30 ft
3tl @ 110 ft

Figure GA.4 Process Flow Diagram for Modified EPICOR II

System.

Effluent

G-18

Table G.12. Decontamination Factors, Volume Reduction
Factors and Breakthrough Volumes Assumedfor Zeolite/Evaporation Processing
FactorValue

Zeolites
Breakthrough volume a
Decontamination factors
Cs
Sr
Other cations
Anions200 column volumes
5 x 104
8.5 x 102
I
1

Evaporatorb
Volume reduction
Decontamination factor
Anions -.
All other ions

.100
103
104

Cation Exchange Resin (H+ form)
Decontamination factors
Cs
Sr
Ru
Ce
Sb
Other cationsc
Anions

10
3
3
2.5
1
1
1

Mixed-Bed
Decontamination factors
Cs
Sr
Ru
Ce
I
Sb
d
All other soluble species

6
2
5
2
2
100
2,

a"Breakthrough volume" is the processing volume thatnecessitates replacement or regeneration of theresins; 200 column volumes for all data.
bFrom H.W. Godbee, "Use of Evaporation for the Treatment of Liquids in the Nuclear Industry," Oak Ridge
Laboratory, ORNL-4790, September 1973; andAmerican Nuclear Society, "American National
Standard Liquid Radioactive Waste Processing
System for P'ressurized Water Reactor Plants,"
ANSlN199-1976,
ANS-55.1.
c++.+CExcept H , Na+, and Li.
dExcept H+.

lapors andAerosols

Influent

Effluent

Process LiquidsI
Spent
ZeoliteEvaporator
BottomsI,

Spent
Cation Bed
Resins

"1@ 30 ft3 3
W 115 ft

Figure G.5.

Process Flow Diagram for Zeolite/Evaporation System.

Spent
Mixed Bed
ResinsZEOLITE/EPICOR II ALTERNATIVE

Influent

Process Liquids

ZeoliteBed*

EPICOR II
SystemEffluent
v

C

Spent
ZeoliteSpent EPICOR II
Ion-Exchange Media(see Fig. 'G.3)'6@ 8 ft3 each

Figure G.6.

Process Flow Diagram for Zeolite/EPICOR II System.

G-21

Decontamination Factors andTable G.13.
Breakthrough Volume Assumed for
Zeolite/EPICOR II Process

FactorValue

Zeolites
Breakthrough volume

200 column volumes

Decontamination factors
Cs
Sr

5 x 104
8.5 x 102

Other cations

1

Anions1

EPICOR II
Decontamination factorsa
Cs
Sr
Ru
Ce
I

107
10-9
103

10,3

Sb
All other soluble species

103

alnferred from EPICOR II performance on AFHB water.
blnferred from EPICOR I processing experience.

InfluentEffluent

Process Liquids

Spent Cation
Bed Resins

Spent Mixed
Bed Resins*6 @ 8 ft3 each**2 @ 8 ft3 eachtl @ 115 ft3

Figure G.7.

Process Flow Diagram for SDS/EPICOR II

System.

Spent EPICOR II
Ion-Exchange Media

G-23

Decontamination Factors and BreakthroughTable G.14.
Volumes Assumed for SDS/EPICOR II Process
Value

FactorSDS

Zeol ites
Breakthrough volume
Cs
Sr

200 column volumes
5 x 10 4
8.5 x 102

Other cations
AnionsCation Exchange Resin (H+ form)

1
8 ft 3 volume

Decontamination factors
Cs
Sr

1
1

Ru

1

Ce
Sb

1

'Other cations
Anions111

Mixed-Bed
Decontamination factors
Cs
Sr

2
2

RU

2

Ce

2

I

2

Sb

1

All other soluble species

2

EPICOR ii
Decontamination factorsa
Cs

107

Sr
Ru
Ce
I

-N

Sb
All other soluble species

103
10 b

alnferred from EPICOR II performance on AFHB water.
blnferred from EPICOR I processing experience.

G-24

Table G.15.
Volume Reduction Factor and'Decontamination
Factors Assumed for Evaporation/Resin Process
FactorValue

Evaporator
Volume reduction

102a

Decontamination factor
IodineAll other ions

10 3 b104

b

Cation Exchange Resin (H+ form)
Decontamination factors
Cs
Sr
Ru
Ce
Sb
Other cationsc
Anions

10
3
3
2.5
1
1
1

Mixed-Bed
Decontamination factors
Cs
Sr
Ru
Ce
1
Sb
d
All other soluble species
aFactor of 100 for water-based influents.

6
2
5
2
2
100
2
For chem-

ical decontamination solutions with relatively highsolids/chemical content range of 10 to 30 is more
appropriate
bFor detergent wastes the decontamination factors forall species are assumed to be 100.
CExcept H+, Na+, and Li+.
dExcept H÷"

N•

N

Elr

Vapors &Aerosols

Influent

Condensate

CationResinProcess Liquids"ResinMixed.

4n r'

r.,nnr-,+nBottoms

UUlI.LJI

L

+in
a

um

Bed Resins
3

1@ 30 ft
3
°1@ 115 ft

Figure G.8.

=

Bed**

Bed*

LVaPUI aUI
I

Effluent

Process Flow Diagram for Evaporator/Resin System.

n +n "A;vt

J

UIli
"

IIA•U

Bed Resins

crnr-

/apor andAerosols

Influent

Bitumen
Waste

Spent
Cation Bed
Resins3<1@ 30 ft
3-"1@ 115 ft

Figure G.9.

Effluent

Process

Process

Process Flow Diagram for Bitumen/Resin System.

Spent Mixed
Bed Resins

G-27

Table G.16.
Decontamination Factors andVolume Reduction Factors Assumed for
Bitumen/Resin Process
FactorValue

Evaporation and Bitumenization.
Concentration factor

3 to 20

Decontamination factors
103b

Cs

2 x

Sr

1 x 104b

Ru

102

I

102

B

102

Other cations

102C

Other anions

102C

Cation Exchange Resin (H+ form)
Decontamination factors
Cs

10

Sr

3

Ru

3

Ce

2.5

Sb

1

Other cationsd

1

Anions1

Mixed-Bed
Decontamination factors
Cs

6

Sr

2

Ru

5

Ce

2

I

2

Sb

100

All other soluble speciese
aBased on G. Lefillatre,2"Progress in theTechniques of Bituminizing Liquid Effluentsof Pressurized Water Nuclear Power Plants,"
BNWL-TR-196, August 1976.
bBased on CRNL/SUB-79/13837/2, "State of the
Art Review of Radioactive Waste Volume
Reduction Techniques for Commercial Nuclear
Power Plants".
cAssumed.
dExcept H+,
eExcept H+.

Na+, and Li+.

Table G.17.

Summary of Decontamination Factors for TMI-2 Treatment System Components

Modified SOS
and Other
Cation Beds

Modified SDS
and Other
Mixed Beds

Evaporatora

Extruder/Evaporator

2

10
3

6
2

1 x 10 4
1 X 10 4

2 x 10 3
1 X 10 4

1

2

3

5

1 X 10 42
1 x 10

1

2

2.5

2

1 x 10 4

1 x 10 2

-

2

-

2

1x

103

1 x 10 2

3

1 x 10 2

104

1 x 1023

1 x 10 2

ZeoliteFirst-StageSDS Cation

SDS Mixed
BedCs

5 x 10 4

1

2

Sr

2

1

Radionuclide

8.5 x 10

Ru
Ce
I

-

Sb

Other cations
AnionsAll'other soluble species

1
1

1

1

-

1

-

2

aFor detergent wastes all decontamination factors are 100.

1 x'10 2

1 x 101 x

1 X 10

1
2

1 x 102

Radionuclide

SDS

_

N

t-I=m~r

Table G.18.

Summary of Overall

Modified
SDS

Zeolite/Evaporator

Zeolite/EPICOR IISDSEPICOR II

Decontamination Factors for TMI-2 Treatment Systems

EPICOR II

Modified
EPICOR II

Evaporator/
Resin (nondetergents)

Bitumen/Resin

Evaporator/
Resin (detergents)

6 x 105
6 x 104

1.2 x 105
6 x 104

6 x 1036 x 102

1.5 x 105

1.5 x 10?

1.5 x 1034

5 x 102

5 x 10 22

2 x 103

2 x 1022 x 102

1 x l0 5

1 x 10 4

1 x

Cs

5

1 x 103 x 106

3 x 10 9

5 x 101

1X

Sr

1.7 x 103

5.1 x 1Q3

1.7 x 107

8.5 x 107

1,7 x 1081 x 105

3 x 10 6
5.1 x 103Ru2

1.5 x 101

5 x 104

1 x 1032 x 1031 x 103

1.5 x 101

4

3

3

3

Ce

2

2 x 10

5

I

2

2

Sb

1

1x

3

10 2

1 x 10101

2 x 10

2

1 x

10 7

1 x 102 x 10101010

1 x 10 55

5 x 101 x 10 3

1 x 10 3

1 x 10 3

1 x 10 2

4

1

1

1

1

1 x

10 4

1 X 1021 x 10 3

10 4

Other cations

1

1

1 x 10Anions1

1

1 x 103

1

1

1

1

1 x 1031 x 1021 x 1022

2

2

1 x 1031 x 1031 x 1032

2

2 x 1022

All other soluble species"3Table G.19.

Major
Radionuclides
in Stream
H-3
Cs-137
Cs-134
Sr-90
Sr-89

Total Curiesof Radioactivity in
Influent (Ci)
2.5 X 103
4.3 x 105
6.6 x 104
7.0b x iv
1.9 X 102

Radionuclides in Liquid Effluents from Treatment of Reactor Building Sump Water

Total Curies ofRadioactivity
in Spent
Filters (Ci)Pre-processed
Liquid (Ci)SOS (Ci)

2.5 x 103

2.5 x 103

Treatment Alternatives
ZeoliteZeoliteModified
Evaporation
EPICOR II
SOS (Ci)
(Ci)
(Ci)

SOS
EPICOR II(Ci)

2.5 x I03

2.5 x 103

2.5 x 103

2.5 x 103

1.4 x 10-4

8.6 x 10-7

4.3 x 10-7

2.2 x I0-5

1.3 x 10-7

6.6 x 10-8

9.2

4.3 x 105

4.3

1.4

6.6 x 104

6.6 x 10-I

1.4 x 10-'2.2 x 10-2

1.1 x 102

6.9 x 103

4.1

1.4

4.1 x i0-4

8.1 x I0-5

4.1 x 10-s

1.9 x i0 2

1.lx 10-1

3.7 x 10-2

1.1 x i0-s

2.2 x 10-6

1.1 x 10-6

3.2 x 10-2

1.6 x 10-2

1.6 x 10-2

1.6 x 10-5

3.2 x 10-3

3.2 x 10-3

Zr-95

3.1 x 10-2
5.3 x 10-2

4.8 x 10-2

5.0 x 10-3

2.5 x 10-3

2.5 x 10-3

2.5 x 10-3

5.0 x 10-6

5.0 x 10-6

Nb-95

4.9 x 10-2

2.2 x 10-2

2.7 x 10-2

1.4 x 10-2

1.4 x 10-2

1.4 x 10-2.

2.7 x 10-s

2.7 x 10-s

Ru- 106

1.0 x 101

2.3

7.7

3.9

0.51

1.5 x I0-4

7.7 x 10-3

3.9 x 10-3

Ru-103

1.8 x 10-3

1.8 x 10-3

0.0

0.0

0.0

0.0

0.0

0.0

Sb-1255.6 x 101

2.6

53

53

5.3 x 10--

5.3 x 10-4

5.3 x 10-2

5.3 x 10-2

Te-125m

1.3

1.3

0.7

0.7

0.7

1.3 x 10-3

1.3 x 10-3

Te-127m

4.8

1.3

0.7

0.7

0.7

1.3 x 10-3

1.3 x 10-3

Te-129m

5.3 x 10-1

5.3 x 10-1

2.7 x 10-1

2.7 x 10-1

2.7 x 10-'

5.3 x 10-4

5.3 x 10-4

Ce-144

1.6

1.1

0.5

0.25

0.10

2.5 x 10-5

5.0 x i0-4

2.5 x 10-4

Ce- 141

4.9 x 10-5

4.9 x 10-s

0.0

0.0

0.0

0.0

0.0

Co-60

0.7 x 10-I

0.7 x 10-'

0.7 x 10-'

1.4 x 10-ý,

1.4 x 10-4

Co-58

1.4 x 10-i
1.0 x 10-2

0.0
1.4 x 10-1
1.0 x 10-2

0.5 x 1O2

0.5 x 10-2

0.5 x 10-2

1.0 x 10-5

1.0 x I0- 5

Ag-110m

7.7 x 10-2

7.7 x 10-2

3.9 x 10-2

3.9 x 10-2

3.9 x 10-2

7.7 x 10-5

7.7.x 10-5

1-129

Total

5 x 105

3.5!~
0Table G.20.

Radionuclides

in Liquid Effluents from Treatment of RCS Primary System Watera

SDS (Ci)

ModifiedSDS (Ci)

Treatment Alternatives
ZeoliteZeoliteSDS
EPICOR II
Evaporation
EPICOR II
(Ci)
(Ci)
(Ci)

EPICOR II(Ci)

Modified
EPICOR II(Ci)

2.7 x 101

2.7 x 101

2.7 x 101

2.7 x 101

2.7 x 101

2.7 x 101

2.7 x 101

2.7 x 10'

Cs-1379.9 x 103

9.9 X 10-2

3.3 x 10-3

3.3 x 10-6

3.3 x 10-3

1.5 x 10-2

5.0 x 10-4

5.0 x 10-7

9.9 x 10-9
1.5 x 10-9

1 0 -4

1.5 x 103

2.0 x 10-8
3.0 x 10-9

9.9-x

Cs-134

1.5 x 10-4

5.0 x 10-4

Sr-90

7.8 x 103

4.6

1.5

4.6 x 10-4

9.2 x 10-5

4.6 x 10-5

7.8 x 10-2

Sr-89

8.2-x 102

0.48

0.16

4.8 x 10-5

9.6 x 10-6

4.8 x 10-6

8.2 x 10-3

0.16

1-129

NA

NA

NA

NA

NA

Zr-95

8.5 x 10-2

8.5 x 10-2

8.5 x 10-2

1.7 x 10-4NA
1.7 x 10-4NA

1.7 x 10-1

1.7 x 10-4NA
8.5 x 10-2

Nb-95

2.7 x 10-1

1.4 x 10-1

1.4 x 10-1

1.4

2.7 x 10-4

2.7 x 10-4

2.7 x 10-4

1.4 x 10-1

Ru-106

3.4 x 101

1.7 x 101

2.3

6.8 x 10-4

3.4 x 10-2

1.7 x 10-2

3.4 x 10-2

2.3

Ru-103

NA

NA

NA

NA

NA

1.4 x 10-2

1.4 x 10-s

1.4 x 10-3NA
1.4 x 10-3NA
1.4 x 10-3NA
1.4 x 10-2

Total Curiesof Radioactivity in
Influent (Ci)

H-3

Major
Radionuclides
in Stream

Sb-1251.4

1.4

Te-125m

2.0

Te-127m

1.0 x 10 2

1.0

1.0

1.0

2.0 x 10-3

2.0 x 10-3

2.0 x 10-l

1.0

50

50

50

1.0 x 10-1

1.0 x 10-1

1.0 x 10-1

50

Te-129m

3.4 x 10-1

1.7 x 10-1

1.7 x 10-1

1.7 x 10-'

3.4 x 10-4

3.4 x 10-4

3.4 x 10-4

1.7 x 10-1

Ce-144

1.0 x 101

5.0

2.0

5.0 x 10-4

1.0 x 10-2

5.0 x 10-s

1.0 x 10-2

2.0

Ce-141

NA

NA

NA

NA

NA

NA

NA

NA

Co-60

NA

NA

NA

NA

NA

NA

NA

3.4 x 10-2

6.8 x 10-5

6.8 x 10-5

6.8 x 10-5NA
3.4 x 10-2

NA

NA

NA

NA

NA

Co-58

6.8 x 10-2

3.4 x 10-2

3.4 x 10-2

Ag-110m

NA

NA

NA

Total

2.0 x 104

aBased on assumptions RCS aqueous decontamination solutions will be the same for maximum 20,000 Ci case.

0Table G.21.

Radionuclides in Liquid Effluents from Treatment of RCS Flush and Drain Water

Total
Curies ofRadioactivity in
Influent

Total
Curie
Activity in
Spent
Filters (Ci)

Total
Curie
Activity in
Filtered
Water (Ci)

4.9 x 104

9.8 x 1024.8 x 104

Sr-90.

7.5 x 10-1
3.9 x 104

1.5 x 102
7.8 x 102

7.4 x 103
3.8 x 104

Sr-89

4.1 x 103

8.2 x 101

1-129

NA

NA

Zr-95

8.5 x 10-1

Nb-95
Ru-106

1.4
7
1. x 102

Ru-103NA

Sb-125
Te-125m

Major
Radionuclides in
StreamTreatment Alternative
ModifiedSDS (Ci)

ZeoliteEvaporator(Ci)

ZeoliteEPICOR II(Ci)SDSEPICOR II(Ci)

EPICOR II(Ci)

Modified
EPICOR II(Ci)* 4.8 x 10-1
7.4 x 10-2

1.6'x 10-2

1.6 x 10-s

9.6 x 10-8

4.8 x 10-8

4.8 x 10-3

1.6 x 10-2

2.5 x I0-3

2.5 x 10-6

1.9 x 10-8

-7.4 x 10-9

7.4 x 10-4

2.5 x i0-3

2.2 x 101

7.5

2.2 x 10- 3

4;5 x 10-4

2.2 x 10-4

7.5

4.0 x 103

2.4

0.78

2.4 x 10-4

4.7 x 10-5

2.4 x 10-5

3.8 x 10-'
4.0 x 10-2

1.7 x 10-2
2.8 x 10-2

8.2 x 10-I

4.1 x 10-1

4.1 x 10-1

4.1 x 10-1

8.2 x 10-4

8.2 x 10-4

8.2 x 10-4

4.1 x 10-1

1.4 x 10-3

1.4

X

10-3

1.4 x 10"-7.0 x 10-1

3.4 x 10-2

X

10-2

1.7 x 10-'11

7

SDS (Ci)

H-3
Cs-137
Cs-1340.78

7.0 x 10-1

7.0 x 10-1

1.7 x 102

85

* 11

3.4 x 10--

1.7 x 10-1

8.5

1.4 x 10-1

6.9

6.9

6.9 x 10-2

6.9 x 10-5

6.9 x i0-3

6.9 x 10-3

6.9 x 10-2

10
5 x 102

2.0 x 10-1

9.8

4.9

4.9

4.9

6.9 x 10- 3
9.8 x 10-3

9.8 x I0-3

9.8 x I0-3

4.9

10.0

490

250

4.9 x 10-1

4.9 x 10-1

4.9 x 10-'250

3.4 x 10-2

1.7

250
8.5 x 10-1

250
8.5 x 10-1

8.5 x10-'

49

25

10

2.5 x 10-3

2.5 x 10-2

1.7 x 10-3
4.9 x 10-2

8.5x 10-1

1.0

j.7x
10-3
4.9 x 10-2

1.7 x i0-3

Ce- 144

1.7
5 x 101

Ce- 141

NA

Co-60

NA
3.4 x 10-1

6.8 x 10-3

3.3 x 10-

1. 7 x 10-'

1.7 x 10-I

1.7 x 10-1

3.3 x 10-4

3.3 x 10-4

3.3 x 10-4

1.7 x 10-I

Te-127m
Te-129m

Co-58
Ag- 110m

NA

Total

1 x 105

NA means information not available.

1.4

7.0 x 10-1

10

G-33

Table G.22.
Radionuclides in Liquid Effluents from
Treatment of RCS Chemical Decontamination Solutions

Treatment Alternatives

Total Curiesof Radioactivity in
Influent

Evaporation
Resin (Ci)Cs-1379.9 x 103

1.7

8.3

Cs--134

1.5 x 103

2.5 x 10-i

1.3

Sr-90

7.8 x 103
8.2 x 102

Major
Radionuclides
in Stream

BitumenResin (Ci)W-q---

Sr-89
1-129,

x 10-2x 10-2
101

13

1.3

x

1.4

1.4

x

NA

10-2

10-4

Zr-95
Nb-95
Ru-106

1.7 x 10'8.5 x 10-2

8.5x

2.7 x 10-1

1.4 x 10-i

1.4

x 10-

3.4 x 10-1

2.3 x 10-4

2.3

x

Ru-103
Sb-125NA

1.4 x 10-4

1.4 x

Te-125m
Te-127m

2.0
1 x 102

Te-129m
Ce-144Ce-141

3.4 x 10-i

Co-60
Co-58

NA
6.8 x 10-2

Ag-110m

NA

Total

2 x 104

1.4

1.0 x 101

3

10-4
10-4

1.0

1.0 x 10-250

5.0 x 10-'

1.7 x 10-i
2.0 x 10-2

1.7 x 10-3
10-2'
2.0 x

3.4 x 10-2

3.4 x I0-4

NA

NA means information not available.

Table G.23.
Radionuclides in Liquid Effluents from Treatmentof AFHB/Reactor Building Decontamination Solutions

Major
Radionuclides
in Stream

Total Curies
in Influent

Treatment Alternatives
Bitumen/
Evaporator/
Resin
Resin

Cs-1375.9 x 109.8 x 10-3

4.9 x 10-4

Cs-1341 x 101.7 x 10-3

Sr-90

1

1.7 x 10-3

8.3 x 10-s
1.7 x 10-4

Total

7 x 10G-34
References--Appendix G
1.

R.E. Brooksbank and W.J. Armento, "Post Accident Cleanup of Radioactivity at the Three Mile
Island Nuclear Power Station," Oak Ridge National Laboratory, ORNL/TM-7091, February 1980.

2.

D.O. Campbell, "Hot Cell Studies," Oak Ridge National Laboratory, presentation to General
Public Utilities and U.S. Department of Energy staff members, January 31, 1980.

3.

"TMI-2 Data Base
December 23, 1980.

4.

D.O. Campbell,
E.D. Collins,
L.J. King,and J.B. Knaver,"Evaluation of Submerged
Demineralizer System (SDS) Flowsheet for Decontamination of High Activity-Level Water at theThree Mile Island Unit 2 Nuclear Power Station," Oak Ridge National Laboratory,
ORNL/TM-7448, July 1980.

5.

R.L. Schwoebel, "The Management of Radioactive Waste:
PB-254737, pp. 307-323, 1976.

6.

K.H. Lin, "Use of Ion Exchange for the Treatment of Liquids in Nuclear Power Plants," Oak
Ridge National Laboratory, ORNL-4792, December 1973.

7.

Letter from G.K. Hovey, Metropolitan Edison Company - TMI-2, to TMI Program Office,Nuclear Regulatory Commission, "Future EPICOR II Operation," January 13, 1981.

U.S.

8.

H. Lowenberg, U.S. Nuclear Regulatory Commission,
dated December 1980.

1980,

9.

H.W. Godbee,, "Use of Evaporation for the Treatment of Liquids in the Nuclear Industry," Oak
Ridge National Laboratory, ORNL-4790, September 1973.

10.

"American National Standard Liquid Radioactive Waste Processing System for Pressurized Water
Reactor Plants," American Nuclear Society, ANSI N199-1976, ANS-55.1.

11.

G. Lefillatre, '"Progress on the Techniques of Bituminizing Liquid Effluents of Pressurized
Water Nuclear Power Plants," Battelle Northwest Laboratory, BNWL-TR-196, August 1976.

12.

"State of the Art Review of Radioactive Waste Volume Reduction Techniques for Commercial
Nuclear Power Plants," Oak Ridge National Laboratory, ORNL/Sub-79/13837/2, April 1980.

Update,"releasedby Argonne

National

Laboratory - J.E.

Robinson,

Waste Partitioning as an Alternative,""Trip Report," for December 16-18,

APPENDIX H. ENGINEERING CONSIDERATIONS RELATEDTO IMMOBILIZATION OF RADIOACTIVE WASTESThe primary waste streams from a radwaste water-treatment facility are liquids containing concentrated radioactive elements, wet solid wastes and particulate solids.
Immobilization of thesewastes (e.g., to a monolithic form) may be required prior to offsite shipment and disposal.
This
immobilization step may be accomplished by a variety of processes.
The technologies currently in
use are applied almost exclusively to liquids, sludges, ion-exchange resins, and similar watercontaining wastes.
The characteristics of four major systems are compared in Table H.1.
Cement solidification and bitumen solidification are mature technologies.
Cement systems areused worldwide; bitumen systems have not been used in the United States, but are in use at several foreign nuclear facilities.
The characteristics of the two systems are summarized inTable H.2; differences are discussed later. The urea-formaldehyde (U-F) polymerization reaction
produces a corrosive liquid by-product, which is a major problem with that system.
Polymericsystems other than U-F based systems are being investigated and their development is continuing.
H.1

UREA-FORMALDEHYDE

Immobilization of radioactive wastes in urea-formaldehyde (U-F) is a well-developed technology.
Several U.S. companies market U-F systems that have been used extensively on wastes from various
nuclear fuel cycle sources, 1 thus providing many years of operational experience.
The U-F system is a polymeric process.
There is no chemical reaction between U-F and the radioactive wastes.
The matrix materials, after being mixed with radioactive waste, are made to form
long-chain molecules of organic polymer that trap the waste within their structure. 2 An acidic
catalyst such as H3 P0 4 , NaHS0 4 or H2 S0 4 , 3 which adjusts the pH to 1.5 ± 0.5, is used to achieve
polymerization.
Additional process modifications have been proposed to reduce the generation ofliquids formed in polymerization.
The effectiveness of these process modifications have not been
fully evaluated at this time.
H.1.1

Process Alternatives

The waste and polymer are combined in one of the following types of mixers: 2 the in-line static
mixer, the in-line mechanically driven mixer, the in-drum compressed air sparge mixer, or thein-drum paddle mixer.
For in-line mixing, after a good mix of the monomer and waste has beenobtained, the mixture is delivered to a drum for filling.
As filling takes place, the catalyst
is added.
The mixture will start to gel immediately.' The gel times vary, depending on temperature and pH, but range from a few minutes to several hours.`' 3 For the in-drum mixing, thecatalyst, polymer, and radioactive waste are added to the drum and then mixed.'
H.1.2

Product Formulations

Aqueous waste solutions are mixed with the U-F in the proportions dependent on the specific waste
streams.
To minimize the amount of catalyst required, dilute solutions of strong acids may be
used to adjust the pH for highly buffered solutions, such as partially neutralized boric acid.
U-F is also used to encapsulate solid waste materials suci as filter sludge and ion-exchange
resins.
The waste solid is usually slurried with a small amount of liquid waste before being
mixed with the U-F, to improve both the handling properties and the volumetric efficiency of thesolidification process.
Typically, about one volume of the U-F is used for each four to six
volumes of slurry. Because the U-F and slurry water essentially fill the pore spaces between thesolid particles, little or no volume increase is incurred.
Certain wastes, including soap solutions and concentrated sodium sulfate, are difficult to entrap
in U-F.
However, monolithic sodium sulfate products can be obtained using fresh U-F, by diluting
to less than 10 wt % sodium sulfate before adding the U-F, or by adding calcium chloride to
4 5
precipitate excess sulfate. 'H-ITable H.1.

Comparison of Available Radwaste Immobilization Technologiesa

Urea-Formaldehyde

Cementb

BitumenVinyl Ester
StyreneMonolith

Monolith

Monolith

Monolith

1000-1300

1500-2000

1000-1300

1100-1300

Moderate (0.6-1.0)

Moderate(0.75)High (>2)

Moderate

Mix fluidity

Good

Poor

Fair

Good

Mixer cleanability

Good

Poor

Fair

Fair to good

Good
Reduced efficiency
Fair
Reduced efficiency
Poor
Poor
Good
Good, may require
pH adjustment

Fair
Good
Good
Good
Poor
Fair
Fair
Fair

Good
Fair
Not recommended
Good
Fair
Fair
Fair
Good; hazardous
with Mn0 2 sludge

Good
Good
Good
Good
Good
Good
Good
Good

Faire
Fair
Good
Acceptable
No
No
Poor

Very good
Good
Fair
Acceptable
No
No
Acceptable

Good
.Fair
Fair
Marginal/poor
Yes
Yes
Poor

Very Good
Fair
Good
Acceptable
Not ignitable
Flammable
Acceptable

Comparison Factor
Product form
Product density,

kg/mi3

Volumetric efficiencyd

Product quality
Boric acid solution
Na2 SO4 solution

NaNO3 solution
Alkaline solution
Laundry detergent solution
Organic liquids
Ion-exchange resins
Sludges
Safety and handling
Product stability
Shelf life of agent
Conveyance/metering
Toxic/breathing hazard
Product flammability
Agent flammability
Off-gassing

-=

AI

Table H.1.

Comparison Factor
Long-term product storage
Leach resistanceContinued

Urea-Formaldehyde

Cementb

BitumenVinyl Estpr
StyreneModerate

High

High

Tensile/compressive strength
Product corrosiveness
Biodegradability
Residual free liquid
Water-holding capability

Fair
Fair
Fair
AlwaysPoor

Moderate
to high
Good
Good
Good
SeldomGood

Freeze/thaw resistance

Fair

Good

Good
Good
Good
Fair
Fair
Fair
Should not occur
Should not occur
Water evaporationGood
during preparations
Good
Good

aFrom "Alternates for Managing Wastes from Reactors and Post-fission Operations in the LWR Fuel Cycle,"
ERDA 76-43, Energy Research and Development Administration, Washington, DC, May 1976.

bM. Brownstein, "Radwaste Solidification with Cement," in "Waste Management '79," Proceedings of the
Symposium on Waste Management held at Tucson, Arizona, February 26-March 1, 1979. Rates cement having
additives.
cFrom R.M. Neilson, Jr., and P. Colombo, "Solidification of Liquid Concentrate and Solid Waste Generated
as By-products of the Liquid Radwaste Treatment Systems in Light Water Reactors," in "Management of
Low-level Radioactive Waste, Vol. 1, Pergamon Press, Elmsford, New York, 1979. [These characteristicsof the vinyl ester styrene process are presented here as an example of the organic polymer immobilization
method.]dRatio of the as-generated waste volume to the solidified waste volume.
eLoses water and strength in open system.

-r

H-4

Table H.2.

Summary of Bitumen and Cement Immobilization System Characteristicsa

Characteristic

BitumenFacility Performance
Drums processed/plant-yr
Hours processed/plant-yr
Capacity factor
Unit processing time, drums/hr
Experience

Cement

5,590
1,880
0.21
3.0
Proven

2,530
3,130
0.36
0.81
ProvenEffluents
DirectAirborne (to environment)

12

H3
Other
Secondary radioactive wastes,
volume/plant-yr
Trash
HEPA filters
Waste concentrate
Process Distillate
Scrap
Oil filters-

4of input
1 * 101 x 10- 4 of input
1 * i0-13 of input

12

-

H3
Other

-

1 * 10-4 of input
1 x 10-4 of input
1 x 10-13 of input

10 m,

10 m332 m31 m
560 m3
1 m3
3
0.3 m

3.2 m33
1 m
None 32.4 m
None

2 x 106 MJ/plant-yr
12 - 1 x 10-6 of input.
H3 - 1.0 of input
Other - 3 x 1O_12

3 x 105 MJ/plant-yr
12 - 1 x 10-6 of input
H3 - I x 10-3
Other - 3 x 10-12

Utility Requirements,
volume/plant-yr
Electricity
Water
Process air
Process steam

3 x 10s
5 x 1022 x 104
1 x 106

1 x 10s kWh
1 x 102 m3
3
2 x 104 m
None

Personnel,
man-yr/plant-yr

3.5

3.5

Exposure = 1
Potential > 1 (slightly)
Exposure > 1 (slightly)
Potential > 1 (slightly)

Exposure = 1
Potential = 1
Exposure = 1
Potential = 1

800
Dose rate > (250)450 kg/drum
Leach rate = 1
Radiation resistance = 1
Combustible
Plast'ic

Dose rate = 1
390 kg/drum
Leach rate
1
Radiation resistance = 1
Non-combustible
FriableIndirectHeat
Airborne (to environment)

Safetyb
Chronic occupational
Acute occupational
Chronic public
Acute public `Product Characteristicsc
Average drum dose rate
WeightLeach resistanceRadiation resistance
Combustibility
Mechanical shock resistanceaFrom J.W. Voss,

kWh
m3
m3
kg

"Comparison of Bitumen and Cement Immobilization of Intermediate- and Low-

level Radioactive Wastes," in "Waste Management, '79," Proceedings of the Symposium on Waste
Management held at Tucson, Arizona, February 26-March 1, 1979.
bChronic and acute exposures are ranked here as one for cement.
For bitumen, except for chronic
occupational, these quantities are expected to be larger, and are listed as being greater thanone.
cThe dose rate of the cement product is assigned a value of one.
The bitumen product is
expected to be substantially higher, and is listed as being greater than one.
The leach andradiation resistances of the product are estimated to be equal, and are listed as being one.

I

I

I

I_

H-5

A number of materials
6
characteri sti cs.
H.1.3

can be added to the U-F formulation to improve its strength or leaching

Product Properties

The properties of the solidified waste depend on the amount of liquid and/or solid immobilized
In an open system, the solid readily loses liquid by evaporation at the surface.
within the U-F.
Some drying of the product does not affect the mechanical integrity of the block, but the solid
may become friable if completely dehydrated.
It has a density slightly
The properly solidified U-F product is a homogeneous monolithic solid.
Generally, as the ratio of liquid to U-F increases, the product strength
greater than water.'decreases and leachability increases. 7 During immobilization, no detectable exothermic reaction
occurs that might cause radionuclide volatilization. 2 U-F solidified products are not consideredflammable because of their water content.
The quantity of free standing liquid
Free standing liquid is always observed in U-F waste forms.
*increases over a period of time as the U-F polymerization continues, and also is a function of
the waste/U-F ratio employed. 8 Free standing liquid in U-F has essentially the same 'concentrationof Cs-137, Co-60, and Fe-59 as the input waste stream, independent8 of waste/U-F ratio. A small
decontamination factor has been observed in the case of strontium.
Free standing U-F liquid has also been observed to be acidic, having approximately the same pH as
This has resulted in cases of rapid corrosion of
the waste/U-F mixture after catalyst addition.
steel containers and premature loss of container integrity.
H.1.4

Summary9

Useful features
follows:of the U-F radwaste solidification

systems that make its use attractive are as

The U-F and catalyst can be stored as liquids, and transfered by simple pumping,
The system uses in-line rather than powered mixers,
The system is adaptable to use of air sparge mixing systems,
Volumetric packaging efficiencies are generally in the range of 55% to 65%.
Problems with the use of U-F as a radwaste solidification agent are:U-F is a condensate polymer; water is produced as a by-product of polymerization,and this water becomes contaminated by the waste and is corrosive.
U-F physically encapsulates the waste; therefore, the waste is not chemically bound, theU-F matrix is subject to shrinkage, and waste liquid is released from the matrix due toshrinkage.
The solidified product is not of uniform quality; mixing ratios are difficult to control;the .acid catalyst must be uniformly mixed; and free acid will attack shipping containers,
causing leakage.
Agent has a short shelf life; an increase in the viscosity occurs with age and this decreases
the agent feed rates during polymer addition to the waste.
The overall considerations with regard to use of the U-F solidification system are that it is thelowest-cost chemical solidification agent presently available, its price is competitive with
However, even though the free liquid may becement and additive systems at current prices.
It is unlikely that current U-F products
drained, subsequent generation of liquid will continue.
Thus, thiscan meet free standing liquid criteria at the commercial low-level disposal sites.
alternative has little
practical application to TMI.

I

I

I

I

H-6

H.2

CEMENT IMMOBILIZATION

Cement solidificationof radioactive wastes, both with and without additives, has been common
practice internationally for many years in order to simplify transport and storage and to reduce
the possibility of release of radionuclides to the environment.
Portland cements are most commonly used for wet solid waste solidification, although high-alumina and pozzolana cements arealso used.
Cement normally is used with an inert aggregate to form concrete, and the nature of the aggregate
largely determines the strength of the concrete.
Cement blocks prepared from waste concentrates
and sludges will generally have less strength than conventional concrete.
The strength is particularly dependent on the total salt content of the waste solution and of the cement block. A
fairly narrow range exists for the described values of the ratio of basic and acidic oxides in
the final product.
If the ratio is reduced too much by the constituents of the waste, thestrength of the cement block will decrease significantly.
Poor mechanical strength can result incracking and spalling of the cement, thus increasing the surface area available for possible
leaching.
3
The cement systems that are commercially available use external, in-line, or in-container mixers.
Each supplier of commercial cement systems offers variations in process-equipment, immobilization
agent and additives.

H.2.1

Process Alternatives

Wet solid wastes, or liquid wastes, can be mixed with cement either by an in-line or an in-drum
process.
The basic differences between the two processapproaches are illustrated in simplified
form in Figure H.1.
For the in-line process, cement and wet waste are introduced into the mixer/
feeder unit for intimate mixing.
Discharge of the mixture to the solidification container is the
final step after mixing has been accomplished.
For the in-drum mixing system, drums are gravimetrically prefilled with cement and a mixing weight added.
The drums are transferred to thewaste fill mixing station, filled with waste, capped and mixed.
A second filling procedure isoffered to improve drum capacity utilization to more than 75% capacity limit.
The solid waste materials are pre-conditioned within a waste tank to provide proper waste chemistry and sufficient moisture for mixture with the dry cement.
Binding agents such as portland
type II or type III cement, or sodium silicate in either dry or liquid form, are injected bymeans of a separate feed system.
The continuous in-line mixer approach offers several, advantages.
Fil-ling is rapid, an empty
container can be filled at approximately 1.5 cubic foot per minuteý The in-line system permits
filling of both 55-gallon drums and large-volume containers, and also permits radioactive filter
cartridge packaging for disposal, but involves a mixer feeder.
For an in-drum system, cycle timein the drum station is about two or three drums per hour.
Certain coating materials, such as polymers or bitumen, can be applied to cement to cover or fill
the pores and thus lower the leach rate.
Soak techniques have been developedat Brookhaven
National Laboratory' 0' 11 to impregnate the pores of concrete with a styrene monomer which is thenpolymerized in situ by heating to 50° to 70'C.
This system has been demonstrated to be effective
12
for the immobilization of high-level tritiated aqueous waste in polymer-impregnated concrete.
Shales also can be added to improve Cs leach rates.
H.2.2

Product Formulations

The optimum proportions of cement and waste vary with type of waste to be immobilized.
Maximum
waste contents are typically 75 wt % for solid waste materials or 33 wt % for aqueous solutions
and slurries.
Cements require a minimum proportion of water to obtain a workable.mix; minimum
water/cement weight ratios are about 0.22 and 0.25 for high-alumina and portland cements, respectively.
Some waste solids (e.g., ferric and aluminum hydroxide s'ludges, filter sludges, zeolites,
and ion exchange resins) will absorb or retain large amounts of water.
Water must be suppliedwith the solid to prevent these wastes from sequestering the required water from the cement andproducing a dry, unworkable mix.
Excess water will result in a layer of free water on the surface of the solidified product.
Absorbents such as vermiculite can be added to the cement to increase the amount'of water thatcan be solidified.
Without absorbents, the maximum water/portland cement weight ratio is about

H-7

CHEMICALSDRYCEMENT
HOPPER

SODIUM
SILICATEFILLPORTCEMENT PRODUCT IN
DRUMS (OR CASKS)
TO STORAGE

FROM CONCENTRATED-STORAGE SYSTEMSLURRYCEMENT PRODUCT IN
DRUMS TO STORAGE

Figure H.I.

In-Line (top) and In-Drum (bottom) Mixing Process for Incorporating Radwaste
in Cement.
Source: M. Brownstein, "Radwaste Solidification
with Cement,"in "Waste Management '79," Proceedings of
the Symposium on Waste Management,
Tuscon, AZ, 1979.

H-8

0.5; with vermiculite, diatomaceous earth, or similar absorbents, the maximum weight ratio can beas high as 0.7 to 1.1.
For cement solidification, free standing water is avoidable.
Minimization of free-standing water is primarily a matter of proper selection of the waste/binder ratio,
taking into account the water content of the waste.
Limited amounts of organic liquids can be incorporated in cement by addition of a dispersing
agent.
Aqueous concentrates containing up to 15% dispersed organic liquid have been solidified. 6
Small amounts of organic liquids absorbed on vermiculite can also be incorporated in cement.
Typical published waste/cement formulations are presented in Table H.3.
The data show thatsolutes of waste solutions and slurries can be incorporated in cement products at salt/cement
weight ratios up to about 0.5, although the more typical ratios are about 0.15 to 0.3
Typicalformulations of the portland cement-sodium silicate process are shown in Table H.4.
H.2.3

Product Properties

For radwaste/cement immobilization processes the characteristics of each waste must be considered
individually because of the possible interaction between the waste constituents and the cement.
One such interaction is the effect on the setting of the cement matrix.
Setting may be unaffected,
accelerated or retarded by the waste components.
For example, boric acid retards the setting of
portland cement and if sufficient boric acid is added, the cement may never harden.
The degree
to which the waste interacts with the cement depends both upon the amount of the interacting
constituent and the manner in which it is added (e.g., solid salt addition as opposed~to salt insolution; mixing mode).
Special additives can be used to improve the setting properties and/or the volumetric efficiencyof the cementing process.
Sodium silicate, added as a concentrated solution at about 10% of thewaste volume, has shown considerable promise for this purpose. 5 '1 3 Not only does sodium silicate
provide a good set for boric acid solutions, it also lowers the volume-increase factor fromabout 2 with conventional cement formulations to about 1.4 when solidifying reactor waste concentrates.
The sodium silicate formulations are designed to minimize waste product volumes andare not intended to produce high-strength products.
Densities of the products with sodium silicate additives are in the range of 1300 to 1500 kg/m 3 . Other solidified product densities range
from about 1500 to 2000 kg/m 3 , depending primarily on water content.
It was demonstrated that boron-containing radwaste sludge (36,000 ppm boron) from PWR's can beincorporated into cement by addition of slaked lime because in the presence of sufficientcalcium
the formation of tri-calcium aluminate is not inhibited by the boric acid.1 4 Other additives,
listed in Table H.5, were determined by laboratory experiment to also overcome the inhibiting
properties of boric acid.
Cement is an open-cell structure because of the porosity that develops while the cement cures.
As such, it is permeable to water and susceptible to radionuclide loss by leaching and exchange.
Certain isotopes are more firmly fixed in the cement matrix than others, and are less leachable.
Strontium, cobalt, rare earths, plutonium and americium are tightly bound, whereas cesium is lesstightly bound.
However, certain species of clay, such as bentonite and Grundite (commercial name6clay), can be added to the formulation to improve the cesium retention.
for a type of illite2
Leach rates ranging from 2 x 10-1 to 0.1 g/cm -day, based on studies with radioactive tracers,
have been measured for cement. The leach rate depends on factors, including the tracer used, the15'1 6leachant, the waste type, and the cement-waste formulation.
An experiment 8 was conducted in which'portland cement was used employing waste/binder ratios that
resulted in the presence of free standing water that had essentially the same concentration of
Cs-137 as the input waste stream- however, significant decontamination occurs with Sr-85 andCo-60, presumably due to ion exchange effects in the cement.
The radiation stability of cement in some cases is excellent.
No deterioration in strength orleachability occurs at an integrated dose of 109 rads (Co-60 gamma rays) for cement products
containing up to 30 wt % sodium nitrate.' 0 Although the presence of water, nitrates and otherradiation-unstable compounds can create gaseous radiolysis products, this is not a serious prob6
lem because the gases produced are absorbed in the porous cement matrix.

H-9
Table H.3.

Typical Cement/Radwaste Formations
Weight Ratio of Waste Constituent to Cement

Waste TypeDry Waste Salt

Total Water

SOLUTIONS AND SLURRIES
25 wt% Na 2 SO4a

0.12

0.37

70 wt% NaNO 3 slurryb'c

0.52

0.22

30 wt% NaNO 3 solutionbc

0.15

0.35

Neutralized HN03- Al(NO 3 ) 3 d

0.37

0.37

20%-25% water treatment sludged'e

0.09-0.17

0.27-0.51

30%-40% evaporator sludgef

0.28-0.35

0.42-0.53

BWR reactor waste 9h

0.17

0.51

400 g/L evaporator concentrated

0.33i

0.70

Conc.

Weight Ratio of Waste Constituent to Cement
Dry Solid Basis

Wet Solid Basis

Solid

Water

Solid

Acid digestion process residuej

0.12

0.37

A1 2 0 3 -ZrO 2 calcineb,c

2.4

0.25

Fly ashbc
Fe/Al hydroxide sludgebc
Diatomaceous earthbc

0.33

0.30

3.1

2.0

4.9

0.22

50

0.42

1.1

0.25

67

Linde AW-500 zeolitebc
Amberlite 200 cation resinb'c
BWRbead resins, recommended9 k

1.21

1.0

1.3
2.0

0.23

39

0.83

1.1

1.7

0.23

50

0.25

0.56

0.51

0.31

50

0.25-1.0

0.45-1.3

0.26

1.19

0.51

0.94

0.04-0.28

0.48-1.3

Water

Wt% Water in
Wet Sludge

SOLIDS AND WET SLUDGESBWRbead resins, rangegk
BWRfilter sludge, recommendedg'lBWRfilter sludge, range gl

50
50
50

aFrom H.W. Heacock and J.W. Riches, "Waste Solidification - Cement or Urea-Formaldehyde," Paper
74-WA/NE-9 presented at the American Society of Mechanical Engineers' Winter Annual Meeting,
New York, November 17-22, 1974.
bFrom Brookhaven National Laboratory Progress Reports for "Development of Durable Long-term
Radioactive Composite Materials," Report Nos. 1 through 10, Upton, New York, July 1972 throughApril 1975.
cFrom Brookhaven National Laboratory Progress Reports for "SRL Long-term Waste Storage Support
Progress," Report Nos. I through 8, Upton, New York, July 1973 through January 1975.
dFrom "Treatment of Low- and Intermediate-level Radioactive Waste Concentrates," Technical
Report Series No. 82, STI/DOC/1O/82, International Atomic Energy Agency, Vienna, Austria, 1968.
eMiscellaneous flocculating and scavenging agents.
fFrom R.H. Burns, "Solidification of Low- and Intermediate-level Wastes," Atomic Energy Review
9:547-599, 1971.
gFrom H.L. Loy and D.C. Saxena, "Processing and Packaging of Solid Wastes from BWR's," in"Proceedings of the Third International Symposium on Packaging and Transportation of Radioactive
Materials," held in Richland, Washington, August 15-20, 1971, CONF-71081, Vol. 1, pp. 478-489,
U.S. Atomic Energy Commission, Washington, DC, 1971.
hAssumed to be % 25% sodium sulfate.
Plus 0.13 kg of vermiculite per kg cement.
JFrom "Commercial Alpha Waste Program Quarterly Progress Report, October-December 1974," HEDL-TME
74-41, C.R. Cooley, compiler, Hanford Engineering Development Laboratory, Richland, Washington,
February 1975.
kPreneutralized with sodium hydroxide to prevent swelling and crumbling.
ICellulose fiber filter aid, powdered resins, etc.

H-10

Table H.4.

Formulations for Solidifying Ragwastes with Portland
Cement-Sodium Silicate
Weight Ratioof Waste to
Solidifying
AgentsVolumeIncrease Factor

Waste Type

Dry
Waste

TotalbWater

With
Silicate

Without
Silicate

Bead resins (50 wt% water)

0.77

1.1

1.04

1.00

Powdered resin sludge (50 wt% water)

0.81

1.3

1.03

1.19

Diatomaceous earth (60 wt% water)
10 wt% boric acid

0.54
0.11

2.1
0.99

0.77
1.46

1.54
1.92c

25 wt% Na2 SO4

0.46

1.4

1.33

1.92

a"Alternates for Managing Wastes from Reactors and Post-Fission Operations in the
LWR Fuel Cycle," ERDA 76-43, Energy Research and Development Administration,
Washington, DC, May 1976.
bExcludes water added with sodium silicate solution.
CFree water is absorbed at this formulation, but the cement remains soft.

Table H.5.

Portland Cement Admixtures to aOvercome Boric
Acid Inhibiting Properties

Chemical Formula

Common Name

Gram Molecular Weight

NaOH

Caustic soda

40.0

CaO

Calcium oxide

56.1

Ca(OH) 2

Slaked lime

74.1

Na2 CO3

Washing soda

106.0

Na2 SiO 3(Metal)122.1

aFrom M. Brownstein,"Radwaste Solidification with Cement,"

sodium silicate

in "Waste

Management '79," Proceedings of the Symposium on Waste Management
held at Tucson, Arizona, February 26 to March 1, 1979.

H-11

Also, portland type II cement waste forms containing BWR precoat filter cake with diatomaceous
earth (slurry) were prepared and exposed to Co-60 gamma radiation, and the effect of irradiation
8
Total doses of 105
on the subsequent leachability of cesium and strontium was determined.1
to 108 rad were employed.
An exposure rate of 1.3 x 106 R/hr was used.
Irradiation appeared tohave no effect on the rate of cesium or strontium release from portland type II cement waste
form.
Because of the complex chemistry involved in cement solidification,

laboratory tests are recom-

mended for each new waste requiring solidification.
H.2.4

Summary of Cement Solidification System

Features of cement/radwaste solidification

systems that make its use attractive are as follows:

Can produce a monolithic structure of adequate strength with no free liquid,
Adaptable to reliable, easily operated,and proven processing systems,

May produce a homogeneous reproducible product from batch to batch without extensive
modification to the operations system,
Can be designed into an operating system so that the operating environment is nonexplosive, non-flammable and free from other chemical hazards,
Can be designed to use in-liner mixing without expensive processing equipment.
Problem areas which have been reported are as follows:
Difficulty with mixing equipment,
Difficulty with dusting and spread of cement to floor drains,
Batch type systems require greater personnel experience during filling and capping operations,Difficulty in cleaning mixing equipment;
ment and spills, anduse of excessive flush water for cleaning equip-

Reduced packaging efficiency.
Considerations

for the use of cement solidification systems are:Complex equipment is not required,
Most systems offered are fully automatic and remotely operated and meet current ALARA
criteria,
Cement offers greater self-shielding,
disposal costs,

which allows for reduced transportation andInexpensive additives are available to insure complete solidification with highly concentrated salts that are produced by waste volume reduction systems and to improve leachrates.
H.3

BITUMEN IMMOBILIZATION

Bitumen is a term used for a mixture of high-molecular-weight hydrocarbons found in natural beds
but more commonly obtained as a residue in petroleum or coal-tar refining.
Bitumen has certain
properties that are advantageous for immobilizing low- and intermediate-level radioactive wastes.
It is chemically inert, insoluble in water, has good coating properties and possesses a degree ofplasticity and elasticity. These properties have led to several applications in foreign nuclear
facilities, but the use of bitumen in the United States has been limited to laboratory and pilot
plant development studies.' 9 - 3 1 Several types of bitumen are available.
They are obtained bydirect distillation of petroleum, air-injection oxidation of petroleum oils (blown bitumen), andcracking of heavier fractions (cracked bitumen). Direct distillation bitumen is the most widely
used.
Blown bitumen is more radiation resistant but has a lower ignition temperature.
Bitumenemulsions in water are available and may provide some advantage in the initial mixing of waste
and bitumen.
As any substance found in nature, bitumen can vary from batch to batch.
AdverseH- 12effects are minimized by using named products that are produced in various grades,such physical properties as softening point, flash point, ductility, and hardness.

depending on

The working temperature for waste bituminization processes is 1500 to2300 C. Although the elevated temperature is a disadvantage when compared with the cement or U-F solidification processes, the high temperature eliminates most of the water originally present in the waste andsignificantly reduces the waste volume to be stored. The resulting condensate is, however, an
addition low-level liquid waste requiring treatment for disposal.
H.3.1

Process Alternatives

Both batch and -continuous bituminization units have been developed for the immobilization ofradioactive wastes.
A batch stirred-evaporator process has been developed in Europe; a continuous turbulent film evaporator process has been developed by several interests worldwide; and ascrew extruder process has been developed in Europe at Marcoule, France, and Karlsruhe, Germany.'
Chemically treated wastes and bitumen are fed separately into the extruder.
Oils and tars are
separated out as a condensate, and the bitumen-immobilized product is discharged into drums for
disposal.
H.3.2

Product Formulation

Bituminization processes have been used to immobilize the solids content of a wide variety of
wastes, including neutralized evaporator concentrates and sludges, ion-exchange materials andresins, incinerator ashes, sand, vermiculite and others. 6
In general, bitumen products withsatisfactorily high mechanical strength and low leach rates may contain about 40 to 60 wt %solids.
Although ion-exchange resins have been incorporated into bitumen, they have a tendency
toward excessive frothing on mixing with hot bitumen.
Nitrate-form anion resins in bitumen
decompose during storage.
Therefore, incineration of resins prior to incorporation into bitumen
may be preferred, though-this.would require a separate facility.
Bitumen can also be used as a coating or sealing material for wastes.
The Atomic Energy Research:
Establishment, Harwell, U.K., has demonstrated incorporation of up to 50 vol % plastic waste inbitumen by allowing hot bitumen-sludge mixtures to flow onto the waste contained in the productstorage drum. 6 This technique can also be used to encapsulate other solid wastes.
H.3.3

Product Properties

The bitumen products are normally noncorrosive to mild steel.
Bacterial attack on bitumen products appear insignificant although long-term tests are needed to confirm this. 3 2 The thermal
stability of bitumen products is good at ambient to moderate temperatures, fair at moderatetemperatures (they soften), and poor at high temperatures (they ignite). 3 3 - 3 8
Certain salts can have adverse effects on the properties of the product. The most widely studied
are the nitrates and nitrites because of their wide usage and their potential as oxidants that
increase the fire hazard.
The base bitumen alone does not spontaneously ignite at temperatures
up to 4501F.30 The bitumen burns more vigorously if appreciable quantities of oxidizing compounds are present (e.g., sodium nitrate, sodium nitrite, and manganese dioxide) that decompose.
...
at temperatures encountered during combustion.To avoid volatilization; boric acid must be neutralized before being incorporated in bitumen;
however, sufficient sodium hydroxide must be added to form the metaborate (Na/B=1) rather than
the tetraborate (Na/B=0.5) to avoid hardening problems. 30
Bitumen products have leach rates., based on actinide tracers, of 10-3 to 10-7 g/cm2 -day; leachrates based on alkali and alkaline earth tracers are up to 1000-fold greater.
Cesium leach rates
can be lowered by a factor of 2 to 10 by incorporating 2 wt % Grundite (commercial name for a
type of illiteclay) and sodium metasilicate in the bitumen. 3 9 Addition of coprecipitants andneutralization to form hydroxides are also beneficial in reducing leach rates.
Storage temperatures should be kept below 60 0 C to avoid separation of salts and bitumen. 30 Some products
containing high sodium hydroxide contents have been shown to degrade following immersion inwater.
The radiation stability of bitumen products is adequate to about 109 rads but should be evaluatedfor each case.
The characteristic effect of radiation damage is swelling of the product (up toH-13

70% volume increase at 10 9 rads for the less porous products) as a result of the generation of
To accomodate potential
gases such as hydrogen, methane, carbon dioxide, and carbon monoxide.
swelling, storage containers are not completely filled (typically 60% to 80%).
The high flammability of some of the radiolytic gases may possibly be a detonation problem with storage containers or areas containing hydrogen or methane.
H.3.4

Summary of Bitumen Solidification System

Useful features of bitumen radwaste solidification systems that make it

attractive are:Bitumen is a thermoplastic material which solidifies naturally upon removal of process
heat, guaranteeing solidification and recoverability.
Bitumen is a naturally waterproof material and is highly resistant to leaching.
Produce products by mechanical mixing bitumen with wastes.
required to complete the solidification process.
Oil in the feed can be tolerated.

No chemistry or additives are

Bitumen systems can provide volume reduction due to water evaporation,
contained and recycled or treated as waste.

but water must be

Problem areas which have been reported are as follows:
Bitumen is combustible, and there is evidence that the incorporation of oxidizing agentsincreases the fire risk,
Bitumen systems require heat input to sustain fluidity during processing,
Properties of bitumen vary from batch to batch,
Solvents may cause solubilization of the bitumen product.
Generation of detonable gases.
Considerations for the use of bitumen solidification systems are:
The product is low in weight but has a high volumetric efficiency,
Bitumen is a nonstratifying binder that produces a homogeneous product,
The product has excellent environmental
Bitumen is
H.4

stability and is noncorrosive,

low in cost and readily available.

ORGANIC POLYMER IMMOBILIZATION PROCESS

Several U.S. companies are actively marketing polymeric processes for radioactive waste immobilization. 9
In most of these processes, radioactive waste is homogeneously mixed with organic
polymer.
The mixture is fed to a drum, a catalyst and promoters are added, and the productsolidifies by polymerization.
Each vendor offers variations in polymers and catalysts, as wellas in processing characteristics.
Detailed information on product characteristics is limited
because of the lack of extensive commercial experience with them.
H.4.1

Process Alternatives

Both organic and inorganic waste materials havebeen satisfactorily incorporated in thermoplastic
polymers such as polyethylene. 3 0 ' 4 0
Most of this work has been performed by a batch process inlaboratory equipment.
Bitumen systems require heat input, while polymer processes are exothermic.
Simulated wastes typical of those generated in light-water reactors (e.g., boric acid, ionexchange resins, and filter sludges) have been incorporated in water-extensible polyster resin. 4 'The polyesters are supplied with contained promoters to decompose any peroxides present, untilorganic peroxide catalysts are added to initiate polymerization and gelling of the resin.
Thefeasibility of the process has been demonstrated, but further work is needed to commercialize theprocess.

H-14

Operations havebeen carried
A proprietary promoter-catalyst polymer system is being marketed.
out using this process to solidify radioactive wastes in 55-gallon drums at five U.S. facilities
and at three Japanese facilities. 9
In all cases, the process produced a homogeneous monolithwith no free liquid.
The polymer is a vinyl ester styrene which is used in combination with a promoter and a catalyst
to produce a solidified waste product.
The vinyl ester is an addition polymer and does notproduce free water.
The principal features of this solidification process that have beenreported 9 are as follows:
Principal Features:

Vinyl Ester Styrene Solidification

Chemical:Vinyl ester plus promoter and catalyst.

System:Batch process using in-container mixing.

Waste
Adaptability:

Handles liquid and slurry wastes with pH in the range of
2.5 to 11.0.

Packaging
Efficiency:

60 to 70 volume percent.

Transport
Efficiency:

Solidified waste density in the range of 60 to 80 pounds per
cubic foot.

Radiation
Stability:

No significant physical degradation of solidified waste fromdoses in excess of 109 rads.

Heat
Resistance:

Solidified waste does not melt,
10 minutes.

Leach
Resistance:

Solidified waste meets or exceeds leach requirements of DOT and
IAEA transportation requirements.
Leach resistance is better than
UF and cement products.

sublime or ignite at 1,000°F for

These solidification process systems are batch processing with in-container mixing.
In laboratory work, test specimens were made using simulated boiling water reactor and pressurized water
reactor evaporator bottoms, mixed-bed ion-exchange resins, filter aid materials and decontamination solvent wastes. 4 2
In addition, samples obtained from actual power plant operations were
43
successfully solidified.
The vinyl ester styrene solidification process utilizes chemicals which are more expensive thanthe materials required for U-F, cement, or bitumen solidification.
Laboratory testing, however,has indicated the process produces stable products with low leachability for a variety of waste
streams.
There is, though, a lack of experience with full-scale solidification systems using
vinyl ester styrene.

References --Appendix H

1.

"Alternates for Managing Wastes from Reactors and Post-Fission Operations in the LWR Fuel
Cycle," ERDA 76-43, Energy Research and Development Administration, Washington, D.C., May
1976.

2.

W. F. Holcomb and S. M. Goldberg, "Available Methods of Solidification for Low-Level Radioactive Wastes in the United States," USEPA Report ORP/TAD-76-4, U.S. Environmental Protection Agency, Washington, D.C., 1976.

3.

R. M. Neilson, Jr., and P. Colombo, "Solidification of Liquid Concentrate and Solid Waste
Generated as By-Products of the Liquid Radwaste Treatment Systems in Light Water Reactors,"in "Management of Low-Level Radioactive Waste," Vol. 1, Pergamon Press, Elmsford, NY, 1979.

4.

H. W. Heacock, "Alternate Nuclear Waste Solidification Processes," in "Proceedings of the
Symposium on Waste Management" held at Tucson, Arizona, March 24-26, 1975.

E

00.

- -I

I

I

I

H-15

5.

H. W. Heacock and J. W. Riches, "Waste Solidification - Cement or Urea-Formaldehyde," Paper
74-WA/NE-9 presented at the American Society of Mechanical Engineers' Winter Annual Meeting,
New York, November 17-22, 1974.

6.

R. H. Burns, "Solidification of Low- and Intermediate-Level
9:547-599, 1971.

7.

J. H. Leonard and K. A. Gablin, "Leachability Evaluation of Radwaste Solidifier with Various
Agents," Paper 74-WA/NE-8 presented at the American Society of Mechanical Engineers' WinterAnnual Meeting, New York, November 17-22, 1974.

8.

R. M. Neilson, Jr., and P. Colombo, "Properties of Solidified Radioactive Wastes from Commercial LWRs," BNL-NUREG-24752, Brookhaven National Laboratory, Upton, NY, 1978.

9.

C. W. Mallory, "Chemical Radwaste Solidification Process," in Proceedings of the Symposium
on Waste Management held at Tucson, Arizona, February 26-March 1, 1979, 1979..,

10.

Brookhaven National Laboratory Progress Reports for"Development of Durable Long-term Radioactive Composite Materials," Report Nos. 1 through 10, Brookhaven. National Laboratory,
Upton, NY, July 1972 through April 1975.

11.

Brookhaven National Laboratory Progress Reports for "SRL Long-term Waste Storage Support
Progress," Report Nos. 1 through 8, Brookhaven National Laboratory, Upon, NY, July 1973
through January 1975.

12.

R. M. Neilson, Jr., P. Colombo and W. Becker, "Immobilization of Tritiated Aqueous Wastes in
Polymer Impregnated Concrete," BNL-22900, Brookhaven National Laboratory, Upton, NY, 1977.

13.

H. W. Heacock, "Alternative Nuclear Waste Solidification Processes,"'75, University of Arizona, Tucson, July 1975.

14.

H. Witte and R. Koster, "Recent Developments in Low- and Intermediate-Level Waste Fixation
by Cement," in Ceramics in Nuclear Waste Management, CONF-790420, Conference Sponsored by
The Nuclear Division, American Ceramics\Society, and U.S. Department of Energy, held inCincinnati, OH, April 30-May 2, 1979.

15.

R. M. Wallace, H. L. Hull, and R. F. Bradley, "Solid Forms for Savannah River Plant HighLevel Waste," DP-1335, Savannah River Laboratory, Aiken, SC, December 1973.

16.

"Savannah River Laboratory Quarterly Report - Waste Management,"
DPST-73-125-1, Savannah River Laboratory, Aiken, SC, 1973.

17.

P. Colombo and R. M. Neilson, Jr., "Properties of Radioactive Wastes and Waste Containers,"
BNL-NUREG-50617, Quarterly Progress Report, July-September 1976, Brookhaven National Laboratory, Upton, NY, January 1977.

18.

P. Colombo and R. M. Neilson, Jr., "Properties of Radioactive Wastes and Waste Containers,"
BNL-NUREG-51042, Progress Report No. 11, October to December 1978, Brookhaven National
Laboratory, Upton, NY, June 1979.

19.

"Bituminization of Radioactive Wastes," Technical Report Series No.
International Atomic Energy Agency, Vienna, Austria, 1970.

20.

"Management of Low- and Intermediate-Level Radioactive Wastes," STI/PUB/264,
Atomic Energy Agency, Vienna, Austria, 1970.

21.

H. Witte, J. Herzog, and R. Christ, "Disposal of Radioactive Wastes from Nuclear Power
Plants, Part I:
Test and Part II: Appendices."
Nukem GmbH and Transnuclear GmbH, Wolfgang
bei Hanau/Main, NUKEM-73, April 1972, ORNL-tr-2684, Oak Ridge National Laboratory, Oak
Ridge, TN.

22.

W. Drent and H. Eschrich, "Bituminization of Radioactive Wastes - Bibliography,"Eurochemic, Mol. Belgium, June 1972.

Wastes," Atomic Energy Review

in Waste Management

January-March

116,

1973,

STI/DOC/10/116,

International

ETR-274,

I

I

H-16

23.

I. Larsen, "Incorporation in Bitumen of Low-Level Radioactive Waste Water Evaporator Concentrate at the Danish Atomic Energy Commission Research Establishment (RIS)" Report No.
RISO-276, Ris, Denmark, October 1972.

24.

Y. Sousselier et al., "Conditioning Wastes from Power Reactors," paper presented at the 1973
Winter Meeting of the American Nuclear Society held in San Francisco, CA, November 11-16,
1973.

25.

W. Bahr, W. Hild, and W. Kluger, "Bituminization of Radioactive Wastes at the Nuclear
Research Center Karlsruhe," Paper presented at the 1974 Winter Meeting of the American
Nuclear Society held in Washington, D.C. on October 27-31, 1974.
(See also Karlsruhe Report
KFK-2119, Karlsruhe,,Germany, October 1974.)

26.

G. Lefillatre and J. Leconnetable,
and Application Fields," Trans. Am.

27.

E.. Detilleux et al., "Medium Level Waste Bituminization Plant and Engineered Storage Facility
at Eurochemic," Trans. Am. Nucl. Soc., 20:658, 1975.

28.

G. Meier and W. Bahr, "The Incorporation of Radioactive Wastes into Bitumen, Part I:
The
Bituminization Plant for Radioactive Evaporator Concentrates at the Karlsruhe Nuclear
Research Center," Karlsruhe Report KFK-2104, Karlsruhe, Germany, April 1975.

29.

J. E. Stewart and R. Herter, "Solid Radwaste Experience in Europe Using Asphalt," Paper
presented at the American Society of Mechanical Engineers Conference held in Portland,
Oregon, September 28-October 1, 1975.,

30.

C. L. Fitzgerald et al., "The Feasibility of Incorporating Radioactive Wastes in Asphalt or
Polyethylene," Nucl. Appl. Technol. 9:821, 1970,

31.

"Chemical Technology Division Annual Progress Report for Period Ending March 31,
ORNL-4682, Oak Ridge National Laboratory, Oak Ridge, TN, July 1971.

32.

W. Drent, "Effects of Microorganisms on Bituminous Materials - A Literature Review,"
Eurochemic, Mol, Belgium, June 1972.

33.

J. A. Herickes and W. Shicker, "Safety Characteristics of Waste-Asphalt Products," Summary
Report TR-PL-9278, December 1966.. (Work performed under contract P.O. No. 2064 with Atlantic
Research Corporation, Alexandria, VA).

34.

W. G. Courtney and D. R. Forshey, "Investigation of Potential Hazards of Asphalt Fixation
Wastes," Final Report No. 4066, July 23-October 31, 1968, U.S. Bureau of Mines, Explosives
Research Center, Pittsburgh, PA.
(Work performed under Contract No. 14-09-0050-3080 for
General Electric Company.)

35.

E. Backof and W. Diepold, "Evaluation of Thermal Mechanical Stability of Bitumen/Salt Mixtures," Institute for the Chemistry of Propellants and Explosive Materials, Berghusen/
Karlsruhe Technical Report No. 9/70, Karlsruhe, Germany, December 1970.
(In German.)36.

"Investigations on the Hazards Caused by Incorporating Na3 and NaN0 2 into Bitumen," Workperformed during 1970-1972 by the laboratory of Applied Chemistry of the Royal Military
School at Brussels under the' Direction of Professor E. Tits, IDL-Report No. 67, Eurochemic
Industrial Development Laboratory, Brussels, Belgium, February 1973.

37.

"Savannah River Laboratory Quarterly Report - Waste Management,
DSPT-73-125-3, Savannah River Laboratory, Aiken, SC, 1973.

July-September

1973,"

38.

"Savannah River Laboratory Quarterly Report - Waste Management,
DPST-73-125-4, Savannah River Laboratory, Aiken, SC, 1973.

October-December

1973,"

39.

"Chemical Technology Division Annual Progress Report for Period Ending May 31, 1967,"
ORNL-4145, pp. 115-22, Oak Ridge National Laboratory, Oak Ridge, TN, October 1967.

"Bituminization of Radioactive Wastes:
Nucl. Soc., 20:657, 1975.

Safety Problems

1971,"
ETR-275,

H-17

40.

N. Moriyama, S. Dojiri, and S. Emura, "Incorporation of Radioactive Spent Ion Exchange
Resins in Plastics," J. Inorg. Sci. Tech. 12:362-369, 1975.

41.

R. V. Subramanian and R. A. V. Raff, "Immobilization of Low-Level Radioactive Wastes," Paper
presented at AICE 80th National Meeting, Boston, MA, September 7-10, 1975.

42.

H. E. Filter, "The Dow System for Solidification of Low-Level Radioactive Wastes from Nuclear
Power Plants," NP-21742, The Dow Chemical Co., Midland, MI, 1976.

43.

H. E. Filter and K. Roberson, "Solidification of Low-Level Radioactive Wastes from Nuclear
Power Plants," in "Management of Low-Level Radioactive Waste, Vol. 1, Pergamon Press,
Elmsford, NY, 1979.

I

3

APPENDIX I.
1.1

JUSTIFICATION FOR RADIATION FIELDS USED IN SECTION 6BASIS FOR DOSE RATES

A value of 10 mR/hr has been used as representative of the time-integrated average radiation
field to which a worker would be exposed during work within the reactor building for the following operations:
Reactor coolant system inspection (Sec.

6.2)

Reactor pressure vessel head and upper internals removal (Sec.
Reactor defueling (Sec.

6.3)

6.4)

The staff used the following basic assumptions in making estimates of radiation fields inside thereactor building for these operations:1.

The reactor building, including all structures and the exterior of reactor components,
will have been decontaminated so that a worker's dose contribution from residual reactorproduced radioactivity inside the building is very low.*2.

The reactor primary coolant water will have been decontaminated to a level of 0.01 pCi/
cm3 , exclusive of tritium. This residual radioactivity will produce a background fieldof 2 to 3 mR/hr to workers performing operations above the surface of the water aroundthe reactor vessel, spent fuel pool, and fuel transfer canal.

3.

Over 80 percent of the operations involved in inspecting, opening the primary system,
and removing the fuel and internals will be conducted underwater with many feet ofwater shielding.

4.

Specific radioactive hot spots within the primary system, caused by plateout of fissionproduct-bearing materials and/or fuel debris, will be shielded if necessary to reduce
fields to acceptable levels for working.

Because the condition of the TMI-2 core and the exact locations of fuel debris within the primarysystem are unknown, a series of scoping calculations were performed to estimate radiation fieldlevels that might be encountered at various points around primary system components.
These
calculations, reported in Reference 1, considered a number of different cases for relocation offuel debris and for the quantities of plateout material.
All of the radioactive source terms
were based on a decay of 460 days from the accident, that is, to July 1, 1980.
The results ofthe calculations for various cases are presented in Table 1.1.
As indicated in the table, the contribution to the worker exposure rate from the reactor core-ina normal configuration is less than 1 mR/hr as long as there is at least 6½ ft of decontaminatedwater above the upper internal structure.
In practice, the amount of water will be considerably
greater than this, and exposure rates will be correspondingly less.

*Survey data from the reactor building entry of July 23, 1980, indicate general area radiationlevels of about 250 mR/hr on the 347-ft elevation.
A significant contribution to theselevels is from the sump water.
Once the sump water has been removed, hot spots shielded, andgeneral area decontamination completed, general area radiation levels should be reduced to
5 mR/hr or less.

I-I

1-2

Table 1.1.

CaseaSummary of Results of Gamma Exposure Rate Calculations
for TMI-2 Primary System

Description
Intact core in normal
configuration

Location
6.5 ft above
core upper

ExposureRate
1 mR/hr

Location
AtPV radialsurface on

ExposureRate.
<1 mR/hrcore centerinternalsb

6-inch-thick fuel debris
bed atop upper plenum
plate (19% of total
core fuel)Outside surfaceof RV head(air inside)

1.1 R/hr

Outside surfaceof RV head
(H2 O inside)

1.5 mR/hrc0.25-inch-thick. fueldebris bed atop steam
generator tube sheet

Outside surfaceof SG head(air inside)

3.2 R/hr

Outside surfaceof SG head
(H20 inside)

0.12 mR/hr

Outside surfaceof RV head

266 mR/hr

Outside surfaceof RV head

128 mR/hr("d90% of a fuel assembly)

0.050-inch-thick plateout
layer inside RV head(air inside).

e0.050-inch-thick plateout
layer inside.28-inchdiameter RV inlet pipe

Outside surfaceof pipe(air inside)(H 2 0 inside)

205 R/hr

Outside surfaceof pipe(H2 0 inside)

73 mR/hraCalculations for less severe conditions also were made and the exposure rates werecorrespondingly lower.

1).

One of the uncertainties is the exact location of fuel debris within the TMI-2 primary system.
To scope this situation, two limiting cases were calculated, cases b and c in Table IT.1.*
Forcase b it was assumed that there is a six-inch-thick bed of U02 fuel debris (corresponding to19 percent of.the entire core) on top of the upper plenum plate (see Fig. 6.1), The resulting..
maximum exposure rate adjacent to the reactor vessel'head from this source was calculated to be
1.1 R/hr if the reactor vessel head contained air rather than water.
If the vessel head were
flooded with water, the exposure rate would be reduced to 1.5 mR/hr.
Case c in Table 1.linvolves a situation in which fuel debris are located in the upper portion of
the steam generator.
For purposes of the calculation it was assumed that a 0.25-inch-thick bedof U02 debris was spread uniformly across the upper header of the steam generator (corresponding'to about 90 percent of the fuel in a single assembly or 0.5 percent of the total core inventory):
As shown in the table, the exposure rate immediately outside the steam generator head was calculated to be 3.2 R/hr when the head contains air, and 0.12 mR/hr with the head flooded with water..
The estimated exposure, rates with the steam generator inspection hatch open were excessively high(greater than 1000.R/hr).

Cases d and e in Table 1.1 were developed to analyze the effect of varying amounts of plateout offission-product-containing material at different points in the system. In case d, it was assumed
that a 50-mil-thick layer** of material was spread uniformly on the inside surface of the reactor*The estimates of U02 debris bed thicknesses for these two cases should be considered "upper
limits" based upon present knowledge of the condition of the TMI-2 reactor core.
It isexpected that the amount of fuel debris in these locations is actually considerably less thanthe values used in this analysis.
**These estimates of plateout material thicknesses should be considered to be "upper limits" based
upon the total quantities and rates of settling of suspended material.
In fact, layers (exclusive of trapping in crevices) more than a few mils thick are unlikely.,

e#

1-3
pressure vessel head.
The exposure rate at the outside surface of the RV head was calculated to
be 266 mR/hr with air inside the vessel head and 128 mR/hr with the head flooded with water.
For
a section of 28-inch-diameter primary system inlet piping with a 50-mil-thick* layer of plateoutmaterial (case e) an exposure rate of 204 R/hr was calculated when the pipe was filled with air.
This would drop to 73 R/hr if the pipe were flooded with water. For a lO-mil thickness* of plateout material, the exposure rate was about 15 R/hr.
These calculations indicate that the exposure rates adjacent to various components in the TMI-2
primary system depend upon the locations of fission product plateout and/or fuel debris within
the system.
The significant factor is that for the most part, these exposure rates are rela.tively low and can be further reduced to acceptable levels by flooding with water, even for theextreme situations that were analyzed.
Based on the results of these calculations, on the assumptions listed above about containment building background levels, and on the exposure to be expected from the primary system water, it is the staff's engineering judgment that a time-integrated
value for an exposure rate to a typical worker during the time he is actually performing workwithin the TMI-2 reactor building on the operations under discussion would be no greater than
10 mR/hr. This is believed to be conservative because:
1.

The exposure calculations, described above, are for source terms as of July 1, 1980,
and will be further reduced by the time the actual work starts because the fuel fission
product activity is currently decaying with a half-life of about 7.6 months.

2.

The hot spots probably will give dose levels lower than those given in the scoping
calculations since the amount of fuel displaced to other parts of the system is not
likely to be as large as assumed.

3.

The plateout hot spots should be much less than that estimated in the scoping calculations since it is expected that most of this material will be removed during the primary system cleanup.

4.

In practice, the hot spots will be shielded.

The assumption that the reactor building has been decontaminated is based upon the staff's belief
that reactor defueling and subsequent decontamination will be lengthy operations, lasting perhaps
one to three years, and will require a large number of skilled and well-trained workers.
Clearly,
the decontamination of the reactor building will be a difficult job and will require a large workforce (see Sec. 5.2).
The effort to decontaminate the reactor building first, and then to defueland decontaminate the reactor, is expected to yield a significant reduction in both total occupational dose and in the time required to complete the reactor defueling and cleanup, (as compared
to what would be expected for a partial or limited reactor building cleanup).
It is desirable to minimize the number of people that exceed their dose limits before the work iscomplete. This means that the work must be conducted in as low a radiation field as is practical.
For this reason, partial or incomplete decontamination of the reactor building before reactor
defueling and RCS decontamination has not been considered practical.
Additionally, it may beappropriate to use special tooling and equipment if general radiation levels are higher than
10 mR/hr.
As a practical matter (in addition to being good radiation protection practice), the averageradiation that skilled workers can operate in over long periods of time performing complex operations should be relatively low.
This is because of the limits on the number of skilled workers
and their availability for a large project like the TMI-2 cleanup.
For example, based upon aquarterly occupational dose of 1 rem (see Appendix L), the continuous exposure rate would be
2 mR/hr.
If an average worker availability (to work in radiation areas) factor of 25 percent
over a quarter-year is used, the exposure rate increases to 8 mR/hr.
Similarly, for an availability of 10 percent, the exposure rate increases to 20 mR/hr.
Because of the considerable additional training and preparation required for the skilled workers
who will perform the primary system inspection, decontamination, and core removal, it is necessary that the radiation fields for the bulk of the operations be kept relatively low (< 10 mR/hr)
so as to maintain a reasonably high individual worker availablility,
This is because of the*These estimates of plateout material thicknesses should be considered to be "upper limits"based upon the total quantities and rates of settling of suspended material.
In fact, layers(exclusive of trapping in crevices) more than a few mils thick are unlikely.

1-4
limited size of the pool of reasonably skilled personnel available,
plus. the significant investment in training and preparation that must be made in each worker before he can perform any
useful work.
In summary, the actual radiation fields that workers will be operating in during the inspection,
primary ve'ssel opening, and core and reactor internal removal phase of the TMI-2 cleanup will
range from a few mR/hr to as high as perhaps several R/hr (for short time periods), based upon
detailed calculations of expected gamma dose rates at various parts of the primary system.
The
net effect of working in these fields for a typical worker over the work shift is an average
field of 10 mR/hr (and a corresponding dose rate of 10 mrem/hr) based upon evaluations of thework to be performed, the area where the worker would be, and how long the work might take.. Asstated above, this is believed to be a conservative (overestimate) calculation of the actual
average field to which a worker would be exposed.
1.2

EXPERIENCE WITH SURRY STEAM GENERATOR REPLACEMENT

For the steam generator replacement activities at the Surry Power Station Unit 2 (a 775-MWe
Westinghouse PWR), the cumulative occupational dose was 2140 person-rem for a labor effort of871,600 person-hours, or an average rate of about 2.5 mrem/hr.
On this particular project, theoriginal estimated labor and exposure was 233,600 person-hours and 2060 person-rem, respectively,
for an average rate of about 9 mrem/hr.
So in practice, the estimated average dose .rate of
9 mrem/hr was a significant overestimate.
(

At Surry the specific steps taken to maintain ALARA exposures were:
1.

Periodic working area cleanup in the containment building.

2.

Maintaining a high water level in the steam generator as long as possible--this resulted
in a dose-rate reduction of about a factor of ten and saved about 630 person-rem.

3.

Use oi temporary shielding' in the lower steam generator cubicles resulted in a significant reduction of exposure and saved about 2700 person-rem.

4.

Decontamination of parts that were to be reused resulted in savings of many-person-rem..

5.

To reduce the radiation exposure time, the various crafts involved received extensive
training in the activities' to be performed by making "dry runs" on full-scale piping
mock-ups.

Reference
1.

Memorandum from D.J. Malloy to J.B. Heineman, "Dose Rate Calculations for Selected Illustrative Examples in the Primary System of TMI-2," Argonne National Laboratory, April 4,
1980.

El

APPENDIX J.

DOSE CONTRIBUTION FROM VARIOUS NUCLIDES IN GASEOUS RELEASESThe inhalation or ingestion of a given radionuclide at a concentration equivalent to the maximum
permissible concentration (MPC) will cause the recipient to incur what is termed the maximum
permissible dose.
Thus, MPCs are a measure of dose potential and in a mixture of nuclides, theMPC of a nuclide may be used as a measure of the dose contribution of that nuclide to the total
dose potential from a mixture of nuclides that may be i'nhaled or ingested.
In this appendix, gaseous effluent streams that are known to contain radionuclides other thanH-3, Cs-137, Cs-134, Sr-90, and Sr-89 are analyzed for relative contributions of individual
radionuclides to the dose potential.
Potential doses from the respective constituents are treatedas being proportional to the number of MPCs represented by those constituents using the MPC
values for unrestricted release to air given in 10 CFR Part 20, Appendix B. The most restrictive
MPC value (either for the soluble or insoluble radionuclide) was used for each constituent.
The technique used for the analyses was to calculate the number of MPCs represented by a particular nuclide.
The concentration of each nuclide was divided by its MPC value to obtain thenumber of MPCs.
The number of MPCs for all nuclides was summed and the percentage contributionof each determined.
Cesium and strontium contributed more than 99% to the total.
Tables J.1 through J.3 show the analyses for airborne releases attributable to the formation ofaerosols from the processing of contaminated liquids.
The effluents analyzed arise from theprocessing of the following contaminated liquids:
those from the sump water in the reactor
building, the primary water in the reactor coolant system, and sump water that was in the AFHB.
Because of the'assumptions made in calculating releases for any given contaminated liquid, therelease values are considered applicable to each of the alternative processes considered.
In the case of effluents resulting from the processing of the sump water from the reactor building, it is notable that the actinides, uranium and plutonium, were not found to be significant.

J-1

J-2

Table J.1., Analysis of Potential Dose Contribution of Radionuclides
in Airborne Effluents (due to aerosol formation) from Processing
Reactor Building Sump Water

Radionuclide

Concentration(VCi/mL)

MPC(PCi/mL)

Number of
MPCs

Percentage ofTotal MPCs

H-3

9.5 x 10-1

2.0 x 10- 7

4.8 x 10 6

< 0.1

0

3.2 x 1011

68
13

Cs-137

1.6 x 102

5.0 x 10-1

Cs-1342.4 x 101

4.0 x 10-10

6.0 x 1010

Sr-90

2.6

3.0 x .10-11

8.7 x 1010

19
< 0.1

Sr-89

7.0 x 10-2

3.0 x 10-1o

2.3 x 1081-129

1.2 x 10-s

2.0 x 10-11

6.0 x 10s

< 0.1

Zr-95

2.0 x 10-5

1.0 x 10-9

2.0 x 104

< 0.1

Nb-95

1.0 x 10-s

3.0 x 10-9

3.3 x 103<

0.1

Ru-106

3.0 x 10-3

2.0 x 10-10-1.5 x 107< 0.1

Sb-1252.0 x 10-2

9.0 x 10-1o

2.2 x 107

< 0.1

Te-125m

5.0 x 10-4

4.0 x 10-9

1.3 x 105

< 0.1

Te-127m

5.0 x 10-4

1.0 x 10-9

5.0 x 105

< 0.1

Te-129m

2.0 x 10-4

1.0 x 10-9

2.0 x 10s

< 0.1

Ce-144

2.0 x 10Q3

2.0 x 10-1o

1.0 x 107

< 0.1

U

9.3 x 10-9

3 x

10-12

3.1 x 103

<

Pu(U)

3.3 x 10-6

6 x

1 0 - 1 4a5.5 x 107-< 0.1

Pu-241

1.7 x 10-5

3 x 10-12

5.7 x 106

< 0.1

Total

aPu- 2 3 8 , Pu-239, Pu-240, and Pu-242.

0.1

100
MPC values for these isotopes are the same.

SI

I

J-3

Table J.2.
Analysis of Potential Dose Contribution of Radionuclides
in Airborne Effluents (due to aerosol formation) from Processingof Primary Water from the Reactor Coolant System

Radionuclide

Concentration(pCi/mL)

MPC(pCi/mL)

Number of
MPCs

Percentage ofTotal MPCs

H-3

8.0 x

2.0 x 10-7

4.0 x 105

< 0.1

Cs-13710-2

2.9 x 101

5.0 x 10-1o

5.8 x 1010

7

Cs-1344.5

4.0 x 10-1o

1.1 x 1010

1

Sr-90

2.3 x 101

3.0 x 10-11

7.7 x 1011

91

Sr-89

2.4

3.0 x 10-1o

8.0 x 10 9

1

1-129

0

2.0 x 10-11

Zr-95

5.0 x 10-4

1.0 x 10-9

5.0 x 105

< 0.1

Nb-95

8.0 x 10-4

3.0 x I0-9

2.7 x 105

< 0.1

Ru-106

1.0 x 10-1

2.0 x 10-1o

5.0 x 108<

Sb-1254.0 x 10-3

9.0 x 10-1o

4.4 x 106

< 0.1

Te-125m

6.0 x 10-3

4.0 x 10- 9

1.5 x 10 6

< 0.1

Te-127m

3.0 x 10-1

1.0 x 10-9

3.0 x 108

< 0.1

Te-129m

1.0 x 10-3

1.0 x 10-9

1.0 x 106

< 0.1

Ce-144

3.0 x 10-2

2.0 x 10-1o

1.5 x 108

< 0.1

Total

0.1

100

Table J.3.
Analysis of Potential Dose Contributions ofRadionuclides in Airborne Effluents (due to aerosol
formation) from Processing AFHB Sump Water

Radionuclide

Concentration(pCi/mL)

MPC(pCi/mL)

Number of
MPCs

Percentage ofTotal MPCs

H-3

4.3 x 10-2

2.0 x 10-7

2.2 x 105

< 0.1

Cs-1375.6 x 101

5.0 x 10-1o

1.1 x 1011

71

Cs-1349.2

4.0 x 10-1o

2.3 x 1010

15

Sr-90

5.9 x i0-'

3.0 x 10-11

2.0 x 1010

13

Sr-89

6.0 x 10-'

3.0 x 10-1o

2.0 x 109

1

1-129

2.0 x 10-11

Zr-95

1.2 x 10-4

1.0 x 10-9

1.2 x 10s5

< 0.1

Nb-95

1.9 x 10-s

3.0 x 10-9

6.3 x 103

< 0.1

Ru-106

5.1 x 10-4

2.0 x 10-1o

2.5 x 106

< 0.1

Sb-125

1.2 x 10-3

9.0 x 10-10

1.3 x 106

< 0.1

Te-125m

2.7 x I0-4

4.0 x

I0-9

6.7 x 104<

8.5 x 106

< 0.1

Te-127m
Te-129m
Ce-144Total

0.1

1.0 x 10-9
1.0 x 10-9
1.7 x 10-3

2.0 x 10-1o

100

I I

U

APPENDIX K.

ECONOMIC COST BASIS

The cost estimates contained in this statement are intended to indicate the relative magnitude of
the costs for the various alternatives.
The estimates are not intended, nor should they be used,
for detailed planning.
Constant calendar year 1980 dollars have been utilized in these costestimates, with no attempt being made to account for the time value of money or potential inflationary factors.
The economic costs are based upon estimates of costs for various operations, equipment, andfacilities that can be directly, related to a given alternative.
Operations, equipment, andfacilities that are not alternative-dependent are not included i~n the main text of the PEIS.
Further, no attempt has been made to anticipate costs that could be incurred because of regulatory or licensing actions, availability of financial resources, and cost of replacement power.
Thus, the economic data presented here and elsewhere in the PEIS are for the purpose of comparison
among alternatives.
No attempt has beenmade to develop an overall consistent set of coasts thatcan be summed to arrive at a total cost estimate for the entire cleanup.
in particular, contingency costs have not been included.
Where cleanup operations have already been completed (such as the AFHB water decontamination
using the EPICOR II system) actual costs based on licensee data are included for completeness.
For cleanup work not yet initiated, costs have been estimated on the basis of best information
available.
The quality of this information is quite variable, ranging from highly reliable costs
for transportation to highly speculative costs for defueling. Much of the economic cost information in this statement is in the highly speculative area because many of these operations havenever been performed and the working environment has not yet been fully characterized.
As aresult, many of the costs have been estimated without benefit of any actual experience; nevertheless, the staff believes that these cost data should be useful as relative cost comparisons.
K.1

KEY ASSUMPTIONS AND DEFINITIONS

The following key assumptions and definitions have been applied to the development of all costingdata.
Manpower Rates.
For purposes of estimating costs, manpower rates have divided into two categories--professional and hourly.
A rate of $60,000 per man-year has been used for professional
effort rates.
The professional category includes management, technical professions, supervisors,and consultants.
A rate of $40,000 per man-year has been used for hourly effort rates.
Thehourly categoIry includes: common labor, clerical, maintenance, crafts, and equipment operators.
These rates have been estimated by the licensee to be reasonably representative for these twocost categories.'
Direct Costs.
Direct costs are defined as those costs that are directly associated with a physicalactivity or alternative.
The basis for this cost element is the person-hour numbers found in the
PEIS as they relate to the individual alternatives.
Indirect Costs.
Indirect costs are defined as those costs associated with supporting a given
cleanup activity.
This cost element includes items such as certain types of health physics
support (some health physics costs are considered as direct costs, depending on the activity),
crane operators, plant operators, training, testing, procedure preparation, etc.
Indirect costs
are added to the associated direct costs to obtain the manpower costs when they appear in the"Economic Costs" sections of the PEIS.
Consumables.
Consumable costs are those associated with expendible items, such as protective
clothing, boots, gloves, face masks, rags, mops, brushes, chemicals, small hand tools, etc.
Equipment.
Equipment consists of special tooling and commercially available hardware that will
be needed for the cleanup. When available, commercial rates have been used.
For special tooling,

K-1

K-2
the staff has estimated the cost based upon tooling that is similar in complexity and function to
the special tooling that may be needed.
In all cases where special tooling may be needed, thecosts included engineering design, materials, fabrication, and checkout testing.
Overhead Costs.
The cost estimates cited in this document include only direct costs of cleanup,
not associated overhead.
In the context of the PEIS, overhead includes all of the costs tomaintain and operate the plant in a safe shutdown condition regardless of the particular alternatives employed to clean up the plant.
As an example of this division of costs, Section K.3 ofthis appendix includes a listof the various facilities that have been provided, are being constructed, or may be constructed in the future in support of the overall cleanup program.
Thislisting does not include those that are alternative-dependent, meaning that the needs. would-vary
depending on what cleanup alternatives are-selected. ' These facilities are listed in Section K.2
with the appropriate cleanup activity. The listing in Section. K.3 includes those facilities thatare of a general support nature and yet are clearly necessary to support the cleanup program in
total.
In a similar fashion, costs associated with the following functions have been. classified
as overhead.
Maintaining the plant in a safe shutdown condition
Plant security costs
Licensing costs
Operating and maintenance costs for equipment and facilities not required to maintain.the plant in safe shutdown condition. or directly related to cleanup alternatives
General plant support services, including laundry services,, general. plant stores,
materials handling- receipt, inspection, general plant engineering, medical services,
reproduction services, and general housekeeping..
Administrative functions, including plant management, plant planning and scheduling,purchasing, quality assurance, personnel administration, and contract administration
Certification testing in support of licensing requirements.
The dominate cost factor in cleanup of the TMI-2 plant most likely will be overhead.
By theirvery nature, the overhead costs are highly sensitive to the cleanup schedule, and are thus further
dominated by regulatory actions and the -availability of financial resources.. Since regulatory actions and the availability of financial resources cannot be realistically anticipated at thistime, no attempt has been made to project an overall cost for the cleanup of TMI-2.
K.2
K.2.1

COSTING METHODS EMPLOYED FOR SECTIONS 5 THROUGH 9
Section 5--Auxiliary and Reactor Building and Equipment Decontamination

Cost estimates for Section 5 were developed by two different methods.
Where costs have alreadybeen incurred by the licensee, such as cleanup of the AFHB, costs estimates have been based upon
percentage of the work completed and information supplied by the licensee.
For cleanup operations still in the planning stages, costs have been developed based upon estimated direct personhours and upon the following cost elements:
tooling design and fabrication, personnel training,procedure preparation, operation of direct support facilities, expendable equipment and materials,
and essential services.
Tooling Design and Fabrication.
Compared to the total cost, tooling is not expected to be amajor expense item.
The tooling for the AFHB and reactor building decontamination consists ofhydrolasers, modified vacuums, special rigging, and'an assortment of small hand tools. Other
than minor modifications to adapt commercially available tooling for special use, design engineering is quite modest.
Personnel Training.
The staff has only included training costs that are associated with thespecific work activity to be performed.
Because the large majority of the work is manual labor,
extensive special training is not anticipated.
A major exception is for work that will requirelarge numbers of people in relatively high radiation fields.
This major exception is the worstcase reactor building decontamination.
The staff has assumed a $400/worker training and processi'ng burden because of the large number of workers involved.

-.-

M

=

ý

M

K-3
Procedure Preparation.
Depending upon the particular activity, the' staff has estimated procedure
preparation effort as a percent of direct effort. As an example, the staff has estimated that
30 percent of the operating effort for the reactor containment service building would be needed
to prepare the operating maintenance procedures.
Operation of Support Facilities. Operation of thes'e facilities has also been included in thecost estimates.
The principal facility in this category is the reactor containment service
building.
Costs were developed for the following elements: work control, material handling,
health physics monitoring, building maintenance, plant engineering, receipt inspection, tool
decontamination, tooling repair, building supervision, quality assurance, records, and contamination control.
Expendable Materials and Equipment.
Expendable materials and equipment costs include such items
as chemicals, tenting, filters, and cask liners.
Essential Services.
Essential services were estimated for electrical power, steam, plant air,and ventilation. In all cases, the staff assumed that the basic service was available onsite andwould have to be modified or rerun to the point of need.
K.2.2

Section 6--Reactor Defueling and Primary System Decontamination

Development of cost estimates for this section were made using the person-hours of work estimatedfor the various alternatives described in the section.
In addition to the direct person-hours,
the following cost elements were included: tooling design and fabrication, mockup costs, training,procedure preparation, and expendable materials and equipment.
Tooling Design and Fabrication. Several special purpose tools will be required for this activity.
Because serious design of these tools will require a better knowledge of the potential damage tothe reactor core; very little preliminary design has thus far been accomplished. The staff has,
however, examined the range of core conditions that may exist and has determined that adequate
technology exists for developing the required tooling.
The method used to estimate the tooling costs was to look at the functions to be performed,
visualizing the tool(s) needed to perform each function, and then drawing a comparison, based
upon engineering judgment, between previously developed tooling of a similar function and complexity.
As an example, the tooling costs for the hydraulic suction equipment consisted of:

Item

Cost
(thousands ofdollars)

Conceptual design

10

Engineering and drafting

100

Design review

10

Testing
Modifications after testing

30
30

Fabrication and procurement

100

Installation and checkout

100

Subtotal
Additional tooling for training
and backup
Total

380
200
580

Mockup Costs.
The use of mockups for engineering design aids and the training of operators is
considered vital. Costs for these mockups also have been included in the 'staff's estimates. The
staff has assumed that mockups would be needed for portions of the RPV, core, core support structure, and upper internals.

K-4
Costs for training of the operating crews were estimated by determining the number ofTraining.
crews that would be required, outlining the generic subject to be covered by the training, thenestimating the training time required.
As an example, the staff estimated that about 40 hours of
training will be required for each crew member during defueling.
Procedure Preparation.
Procedure preparation costs estimated by the staff varied widely, dependingon the activity involved.
The staff estimated that for defueling the costs for procedure preparation would probably exceed the costs for the actual physical labor required to remove the fuel.
Expendable Materials and Equipment.
When the staff judged that expendable materials and equipment would be needed to conduct an activity that was unique to the particular activity, the costsof such expendables were also included.
Examples included are:in-line filters, cask liners,
special cleaning chemicals, and debris containers.
Expendable'materials and equipment that would
normally be available from plant stores were not included.
K.2.3
K.2.3.1'

Section 7--Liquid Processing and Disposal
Processing Cost Estimates

The processing costs were developed from the Appendix G process flow-sheets.
Based upon theseflow-sheets, a hypothetical operating crew was established with appropriate allowances made forprocess system maintenance and downtime.
Consumable materials, such as ion-exchange media,
filter cartridges, and chemicals, were estimated on a perunit volume of process influent.
Finally, services were estimated for such items as water, electrical power, and other utilities.
The net result of this technique was calculation of a cost per Unit-volume of process liquid
influent.
As an overcheck, these unit volume costs were compared to actual costs of operating
EPICOR II as provided by the licensee.
The cost per gallon of influent to be processed is summarized in Table K.1.
The unit costs
consist of two components:(1) the actual labor of operating the facility, and (2) the materials
consumed in the process, such as zeolites, filters, and resins.
The major variation in theseunit costs is in the consumable component.
The capital costs for the alternative facilities are shown in Table, K.2.
Indirect support costs have also been included and are tabulated in Table K.3.
These indirect
costs consist of operating, maintenance, procedure preparation, engineering, surveillance, andhealth physics assistance.
K.2.3.2

Disposal Cost Estimates

Processed liquid disposal costs were developed on a unit-volume basis for onsite operations andtransportation/disposal costs. The results of these unit volume costs are presented in Tables K.4
and K.5.
Estimated facility costs for cases in which an alternative required an onsite facility for either
storage, treatment, or immobilization prior to disposal are presented in Table K.6.
The unit operating costs presented in Table' K.4 are composed of direct labor, indirect labor, andmaterial costs.
The direct labor costs were developed by analyzing the process and establishinga hypothetical operating crew to perform the work, and then, based upon an influent volumetricrate, -establishing a cost per unit volume.
Appropriate allowances were made for supervision,
health physics coverage, engineering surveillance, and direct analytical support where needed.
Indirect labor costs were developed based upon estimates of support activities that would beneeded.
The support activities included items such as preparation of operating procedures,process qualification runs, and technical support by engineering and quality assurance.
Needs for materials, principally cement, were estimated based upon material mix ratios and thenconverted to material cost per unit of influent volume.
The transportation and disposal cost per unit volume of influent are shown in Table K.5.
Transpdrtation costs were based upon commercial rates assuming one-way unshielded shipments to either
Richland, Washington, or West Valley, New York.
Disposal Costs were based upon NECO burial
charges in effect as of October 1980.

Table K.1.

Process Alternative
Considered
1.

AFHB

Costs of Liquid Processing per Gallon of Influent (dollars/gallon)

Reactor
Building
Sump

Reactor Building
Decontamination(Water)1.65-

ChemicalDecontaminationof AFHB andReactor Building

RCS

RCS
Flush and
Drain

RCS
Decontamination (Mild
Chemical)

1.60

1.55

1.60

RCS
Decontamination(Chemical)

Zeolite Alternatives(a)Zeolite/Resin (SDS)(b)

Zeolite/Modified
Resin (Mod SDS)

-

1.65

-

-

1.65

1.60

-

(c)

Zeolite/Evaporator

-

2.05

-

-

1.80

1.90

1.90

(d)

Zeolite/EPICOR II

-

1.85

-

SDS/EPICOR II

-

1.90

-

1.60
2.10

1.80
1.90

1.80

(e)

-

(f) Mod EPICOR II

..

1.50

1.85
4.35

2.

EPICOR II

3.

Evaporator/Resin

4.

Bitumen/Resin

1.75

-

2.00

-

2.70

--

1.00

-

2.25

-

U1I

1.00
2.25

K-6

Costs of Liquid
Table K.2.
Processing Facilities(thousands of dollars)
Process Alternative
1.,

Zeolite Alternatives(a)Zeolite/Resin (SDS)

6,000

(b)

Zeolite/Modified
Resin (Mod SDS)

6,500

Zeolite/Evaporator

9,000(d) Zeolite/EPICOR II

12,200(e)

SDS/EPICOR II

12,200(f)

Mod EPICOR II

7,200

(c)

K.2.4

Cost

2.

EPICOR II

6,200

3.
4.

Evaporator/Resin
Bitumen/Resin

3,000
7,500

Section 8--Solid Waste Packaging and Handling Costs

The costs of waste management depend on the characteristics of the waste generated and on thealternative steps in the waste management cycle.
These costs include the considerations discussed below.
J

Conditioning.
Conditioning is a, step which refers to those operations that transform either
concentrates produced during treatment or untreated materials into forms suitable for transportation or disposal.
Conditioning includes immobilization, which converts radioactive wastematerial in the form of liquid and process solids into a stable monolithic form with the radioactive materials homogeneously dispersed within it.
Conditioning costs include labor, services,and consumables such as immobilization~materials.
Packaging and Handling.
Packaging refers to placement of the radioactive material into a disposable container.
Package handling refers to those operations that involve movement of containers within the facility.
The costs include labor and disposable containers, as appropriate.
Unit costs for the various alternative processes associated with a given waste type are given in
Tables K.7 and K.8.
These costs were developed using applicable assumptions described in the
text of this document and from data available from similar radioactive waste management operations.
Materials, services, and direct effort costs were prepared for these major steps in thewaste management cycle. An applicable multiplier was then applied to the resulting person-hours
of work effort to obtain the additional effort required from supporting groups, such as indirect
operations, supervision, training, procedure preparation, maintenance, health physics, engineering,laboratory, and analysis.
The summation of these costs was then reduced to dollars per unit
volume of waste generated.
The cost evaluation of services included items such as electrical power, steam, instrument air,demineralized water, cooling water, etc.
Packaging and handling include the costs of disposable
containers (materials), effort required to move packaged waste within the plant, and effort
required to load it on or into a vehicle for transport.
Effort requirements for handling packaged
waste are shown in Appendix N as a function of waste and package type.
K.2.4.1

Process Solids Waste

Waste volumes resulting from application of a given treatment process for the various waste types
shown are given in Table K.9.
The costs of associated facilities are given in Table K.10. The
applicable waste volumes were multiplied by the associated unit cost numbers presented inTables K.7 and K.8 with appropriate facility costs added, to develop the bounding costs describedin Sections 8.1.6 and 8.2.6 of the PEIS.

SJON

Indirect Manpower Cost Estimates (thousands of dollars)

Table K.3.

Process Alternative
Considered
1.

AFHB

Reactor
Building
Sump

Reactor Building
Decontamination(Water)ChemicalDecontaminationof AFHB andReactor Building

Low

High

RCS
Flush and
Drain

RCS

RCS
Decontamination (Mild
Chemical)

RCS
Decontamination(Chemical)

Zeolite Alternatives(a)Zeolite/Resin (SDS)

-

685

-

407

724

384

283

(b)

Zeolite/Modified
Resin (Mod SDS)

-

700

-

427

752

403

-

-

(c)

Zeolite/Evaporator

-

798

-

516

866

503

383

-

(d)

Zeolite/EPICOR II

-

848

-

SOS/EPICOR II

-

883

-

910
1040

590
599

476
-

-

(e)

593
621

(f)

Mod EPICOR II

-

-

-

434

734

416

--

336

-

404

704

386

-

-

-

306

-

2.

EPICOR II

529

-

3.

Evaporator/Resin

-

-

155

-

-

-

4.

Bitumen/Resin

-

-

310

-

-

-

-

650

K-8

Table K.4.

Unit Operating Cost for Disposal of TMI-2 Liquids(dollars/gallon)

1.

2.

(a)

Stored in tanksa(b)Immobilized in concrete a

Estimated Total
Operating Cost

NA

NA

NA

NA

0.42

0.12

0.56

1.15

River discharge

0.095

0.011

Evaporation ponds

-

NA
NA

0.106
-

Discharge to the environs(b)a CntcMaterials

Long-term onsite storage

(a)

3.

Indirect Labor
Cost

Direct Labor
Cost

Disposal Alternative
Considered

Offsite disposal(a) Immobilized and shippedb(b) Immobilized and shippedc

-

-0.56

0.56

-

(c)

Deep well injection

0.10

NA

NA

0.10

(d)

Ocean disposal

0.10

NA

NA

0.10

nf

bRichland,-nAlC"Will-

a

+

A
•ltA
"lLUUCU

"l

T
ku
,aui

Var
r. .J

Washington.

cWest Valley,

New York.

Table K.5.

Transportation and Disposal Costs for TMI-2
Liquids (dollars/gallon)

Disposal Alternative
Considered
1.

2.

3.

Transportation and
Disposal Costs

Other
Costs

Long-term onsite storage(a)Stored in tanks

NA

34,000a(b)

Immobilized in concreteNA35,000a

NA
NA

NA
240f

Discharge to the environs(a)River discharge(b)

Evaporation ponds

Offsite disposal(a)Immobilized and shippedb

3.54

NA

(b)

Immobilized and shippedc

2.25

NA

(c)

Deep-well(d)

Ocean disposald

3.50
4.60

2.80e

injectiond

aonsite storage and maintenance cost (dollars/year).
bRichland,

Washington.

cWest Valley,

New York.

dAssumes 500-mile trip.
eCost for offsite solidification in concrete prior to ocean disposal.
fSurveillance and maintenance cost for four-year period.

------Lý

-K-9

Facility Costs for Disposal of TMI-2
Table K.6.
Liquids (thousands of dollars)
Facility Cost
Estimate

Disposal Alternative
Considered1.

2.

Long-term onsite storage(a)Stored in tanks

4,700

(b)

Immobilized in concrete

250

Discharge to the environs
NA(a) River discharge
3.

258

Evaporation ponds(b)Offsite disposal(a)Immobilized and shippeda

250

(b)

Immobilized and shippedb

250

(c)

Deep-wellNA(d)Ocean disposal

aRichland,

injection

NA

Washington.

bWest Valley,

New York.

Table K.7.

Waste Conditioning--Unit Costs
Conditioning Costa

Waste Type

DirectPackaging

Dewatering

Immobilization
CementVES-

Negligible$26.50/ft 3$60.00/ft 3

SludgeZeolitesb
Organic resins
Filters$1000/ft-

3

Negligible-

Compaction_$60.00/ft$26.50/ft

3

3

....

-

-

$3.09/gal.

$6.10/gal.

-$3.09/gal.

$17.60/gal.

Chemical decontaminnation solutions--$0.32/ft 3

Trashalncludes labor, materials,--

Negligible

Evaporator bottoms

Incinerationand services,does not include facility cost.

bIncludes treatment and handling at an interim DOE facility prior to final disposal.

$1.48/ft 3

K- 10

Table K.8.

Waste Packaging and Handling--Unit Costs
Packaging and Handling Cost
DirectPackaging

Waste Type
Sludge-Zeolites-

Organic resins.
Filters

Immobilization
CementVES$8/f t 3$106/ft 3$11/ft 3$11/ft 33$145/ft 3

Dewatering-$145/ft$43/ft 3-

Evaporator bottoms

-

-

-

Chemical decontamination solutions
Contaminated equipment$3/ft 3

Irradiatad
hardware$3/ft3

Noncompactabletrash$3/ft 3

Noncompactable/
noncombustible
trash$3/ft 3$145/ft 3$1.50/gal.

$1.70/gal.

$1.25/gal.

$1.25/gal.

aFor waste of greater than 200 mR/hr use $800/liner.

Table K.9.

Process Solid WasteVolumes
Considered in Costing

VolumesWaste Form

Minimum

Maximum

1.

Accident sludge
Zeolites

250 ft 3
80 ft 3250 ft 3
430 ft 3

Organic resins
High-specific-activity resins

1000 ft 3

2400 ft3

2220 ft 3

5310 ft 3

470 ft 3

560 ft 3 .

06154 gal2.
3.

Low-level resins
4.

Filters

5.

Evaporator bottoms

AI

I

.

K-11

Table K-10.

DirectPackaging

Waste Type

Waste Facility Costs (thousands of dollars)

Immobilization
Dewatering
CementInterim
Liner
Storage

VES

ISWSFaSludge

-

100

3,720

3,320

-

775

Zeolites

-

100

-

-

6,300

775

Organic resins

-

100

3,720

3,320

6,300

775

Negligible

-

-

-

-

775

.Evaporator bottoms

-

-

3,720

3,320

-

775

Chemical decontamination solutions

-

-

3,320

-

775

Filters

alnterim solid waste staging facility.

K.2.4.2

Decontamination Solutions

The costs involved in the conditioning of the liquid chemical decontamination solutions andsubsequent packaging and handling were developed by estimating the unit costs for conditioning(Table K.2-7) and the unit costs for packaging and loading (Table K.2-8).
Based upon quanity
estimates that varied from 47,000 gallons to 550,000 gallons, costs were developed.
Costs forthe processing facilities, cement and vinyl ester styrene immobilization are presented inTable K.2-11.
It was assumed that the decontamination solution wastes would be immobilized with either vinyl
ester styrene or cement, and packaged in 55-gallon drums.
It should be noted that depending upon
the quantities to be immobilized, vinyl ester styrene immobilization produces both the highest
cost and the lowest cost.
Cement immobilization techniques lie within the bounding cases.
The
reason for this apparent inconsistency is that for the case where a rather small quantity(47,000 gallons) is to be immobilized, the facility costs are relatively inexpensive compared tothe cement facility.

Table K.11.

Decontamination Solution Immobilization Costs(thousands of dollars)
VES Immobilization

Cost Element

Best Case

Cement Immobilization

Worst CaseBest Case

Worst Case

3 ,320 a

Facility

828

3,720

3,720

Operating cost886

10,311

204

2,374

1,714

13,631

3,924

6,094

TotalsaThis facility was previously estimated for the worst case cost in Section 8.116; thus the maximum cost for bounding estimates is the dewatering.cost of $10,311.

I

I

K-12
K.2.4.3

SolidsSolid waste materials consist of trash, contaminated equipment, irradiated hardware and fuelassemblies.
These wastes are described in Section 8.3, and the estimated costs for their management are presented below.
Trash
To quantify management costs,

this solid waste was divided into three categories:

Combustible--Trash that can be processed through the incinerator, with incinerator ash
immobilized, packaged in 55-gallon drums, and shipped in a shielded or unshielded
configuration as dictated by radioactivity level.
This material would be incinerated
in a small unit with a throughput of 250 pounds per hour.
At an average trash densityof 8 lb/ft 3 , this throughput corresponds to about 33 ft 3 /hr.
The estimated cost of
this incinerator is $5.6 million.
The crew was assumed to consist of one operator.
After incineration, the ash would be immobilized.
Costs were based on using cement forthe binder material.
Compactible--Trash that can be processed through a compactor, packaged in 55-gallon
drums, and shipped unshielded.
The staff has estimated the cost of this compactor to
be about $180,000.
Noncombustible, noncompactible--No treatment or conditioning is required for thesematerials.
This trash is packaged in LSA boxes and shipped unshielded.
The operator
labor required to package these materials in such boxes and to handle them wasestimated from Appendix N, Table N.2.
The unit costs for these three categories of trash are shown in Table-K.12.
in dollars per cubic foot of material prior to treatment.

Table K.12.

Estimated Unit Costs for Management of Trash(dollars/ft 3 )Treatment

Conditioning

Packaging &Handling

Combustible trash(55-gallon drum)

1.30

0 . 18 a

0.09

Compactible trash(55-gallon drum)

0.32

NA

0.71

Noncombustible,
noncompactible
trash (LSA box)

NA

NA

2.97

Waste Type and Container
1.
2.
3.

aCement immobilization of ash.
by about $0.70/ft 3 .

K.2.4.4

These unit costs are

Use of vinyl ester styrene increases cost

Contaminated Equipment and Irradiated Hardware

Some of the contaminated equipment and irradiated hardware can be packaged in wooden LSA boxes
and shipped in an unshielded configuration.
The unit costs for management of these materials are
essentially the same as those described above.
Thus, for these low-activity materials, the total
estimated costs in Section 8.3.6 were based on costs of $930 and $1130 per LSA box.

I

K-13
Some of these materials could have radioactivity levels that require shielded shipment.
The
operator labor required to package and handle these materials was estimated from Appendix N,
Table N.4. As shown, about 3.5 operator hours would be required to package and handle the volume
of material compatible with shipment in a 70-ft 3 liner.
K,2.5

Section 9--Cost of Storage,

Transportation and Disposal of Solid Waste

The cost elements in this final step of the radioactive waste management cycle cover the incremental and total costs involved in the transportation of the solid waste from TMI and the subsequent offsite storage, treatment (if applicable) and disposal charges.
In general, the costelements are (1) shipping cask use or rental, (2) transportation, and (3) commercial burial.
Thebasic approach and methodologies used to quantify these cost elements and the incremental values
are discussed below.
For the purpose of bounding disposal costs, the costs associated with both the maximum transit
distance to Hanford (Richland), Washington, and the minimum distance to West Valley, New York,are determined for both the best- and worst-case number of shipments.
The 'shipment and disposal costs for low-level waste (LLW) are based on direct shipment offsite toa disposal facility and include shipping cask use charges, transportation charges, and emplacement
costs.
The estimated bounding costs for transportation and disposal of the various types of LLW
are shown in Table K.13.

Table K.13.

Low-Level Waste Transportation and Disposal Costs(thousands of dollars)

Number of Shipments
Type of Waste

Transportation and
Disposal Cost Ranges

Best Case

Worst Case

148

295

1196 - 2471

1,509 - 3,3276984865 - 1000

1,331 - 1,615

Zeolite/resin(reactor building)a9

37

115 - 490

176 - 741

RCS processes

1265

145 - 713

225 - 1,154

Shielded drums

41

91

225 - 500

.487 - 1,081

Miscellaneous shielded
waste

17

206

61 - 1104

177 - 2,850

2607 - 6278

3,905 - 10,768

Unshielded waste

West Valley

HanfordIon-exchange material(shielded)
EPICOR II

Totals(AFHB)

aTransportation and disposal costs for the zeolite liners have been assumed
to be the same as those used for the high activity prefilters.

I

K-14
K.3

FACILITIESA tabulation of the various facilities that may be needed to support the TMI-2 cleanup is presented
in Table K.14.
Provided is a tabulation of those facilities that are classified as general
support andthose that are directly associated with a given alternative.
The general support
facilities are those considered as being needed to support cleanup regardless of the alternatives
selected.
They consist of such facilities as hot chemistry laboratory, laundry, etc.
Becausethese facilities are independent of the alternatives selected, no attempt has been made toestablish costs.
The staff used four methods to develop cost data for the facilities discussed in Section K.2:
(1) when costs have already been incurred by the licensee, costs and/or cost-to-complete data
have been used (examples are EPICOR II and the SDS); (2) when facilities have not yet been
designed and engineering specifications not yet developed, but have been identified by thelicensee as possibly needed, the licensee's cost estimates have been used after review by thestaff.
Facilities such as the containment service building is an example; (3) when facilities
have been identified by the staff as possibly needed, but for which little
or no information
exists regarding specifications, the staff has used engineering judgement based upon previous
construction costs of somewhat similar facilities (examples of these types of facilities aremockup pools and filter backflush facilities); and (4) in the case of facilities for which little
or no information exists but which are single-process oriented, the staff has useda standard
2
procedure developed by the U.S. Environmental Protection Agency to estimate costs.

Table K.14.

General Support Facilitiesa

Liquid Radwaste Processing Building (Evap)
Personnel Access Facility (PAF)
Decontamination Demonstration Facility (DDF)
Low Level Counting Facility (LLC)
Sewage Treatment Facilities
Search-Entry Facility
Warehousing
Administration Building
Security Administration Facilities
TLD Facilities
Time Office and Brass Alley
Resin Solidification Facility (RSF)
Equipment and Material

Radwaste Staging:

Medium-High (RSFH)

Equipment and Material

Radwaste Staging:

Low (RFSL)

Laundry Facility (LF)
Low Level Waste Processing (LLWP)Hot Chemistry Laboratory (HCL)
Proposed Processed Water Storage Tanks (Up to 8 additional tanks)
New Permanent Security Fence
Interim Security Fence
aBased on BECHTEL Drawing No. 2-COA-0001,

Rev.

3.

K- 15

References--Appendix K
1.

Memorandum from R.J. McConnell, Argonne National Laboratory, to Distribution,
Discussion at TMI, September 24, 1980," dated October 2, 1980.

"PEIS Costing2.

"A standard Procedure for Cost Analysis of Pollution Control Operations,"
Protection Agency, EPA-600/8-79-O18AB, June 1979.

Environmental

U.S.

I-

,APPENDIX L.

AVERAGE INDIVIDUAL QUARTERLY DOSE LIMITS USED IN
DETERMINATIONS OF WORK FORCE ESTIMATES

In 10 CFR Part 20.101(b), the occupational dose of radiation workers of up to 3 rem whole-bodyper quarter (three months) is permitted if the workers meet certain conditions relative to previous cumulative dose record, age, and the licensee's determination of the workers' cumulative
occupational dose to the whole body.
Those who do not meet these conditions are restricted tomuch lower doses.
In its radiological protection program, the licensee has established administrative check points
for occupational dose which are more stringent than the regulatory limits of 10 CFR Part 20.
These administrative check points indicated in the licensee's Radiation Protection Manual, Administrative Procedure 1003, are stepped to make it difficult for individuals to approach the 3 rem
per quarter regulatory limit and thus greatly reduce the potential for violating this limit:
0-

1 rem per quarter

Administrative check point to ensure compliance with
10 CFR Part 20

1 - 2 rem per quarter

Written authorization required from Radiation
Protection Supervisor (RPS)

2 - 3 rem per quarter

Written authorization
Supervisor

requiredfrom

RPS and Unit

The NRC staff recognizes the value of this approach and the fact that its application results in
occupational doses that rarely exceed about 1 rem per quarter.
Therefore, for the purpose of
estimating the major work force requirements for the decontamination operations, the staff allowed
for an average individual dose of 1 rem per quarter in TMI-2 cleanup operations.
However, by useof 1 rem per quarter for its calculations, the staff does not intend to preclude individuals
being allowed to receive up to 3 rem per quarter, should it be necessary, nor are such doses
prohibited by the licensee's procedures.
Indeed, for some special operations, it may be prudent
to allow individuals to receive up to (but riot over) the 3 rem per quarter limit to accomplish atask in the optimal manner and reduce overall person-rems (e.g., a highly skilled employee).
Use of a higher individual dose would result in a reduction in the number of exposed individuals
required to do the work, but these trained personnel would then be expended earlier in the decontamination process and would be unavailable for further radiation work during the quarter.

L-1

EL

..'b'•-FNTS

APPENDIX M.

"LONG-TERM ENVIRONMENTAL RADIATION SURVEILLANCE
PLAN FOR THREE MILE ISLAND"
U. S.

F ; ':'ORD

ENVIRONMENTAL PROTECTION AGENCY
iN,7i.ODUCTIOCN

Wcu,: the '.,c. := rwouse

AFPFZIX A.:-:.tn-

A-P:I:-,jX

rý-l

-.
7i"
tin 74.
svisont,,olkP7PADIXC.

.c~ng-Tet N ni tring

1;-ee -- l e Island L.!i,-era.urejhlance

ProgramStations

AiPBE.[bIX D.

LPA TLD Locations

APPY:LDIX E.

Descr4ttion

APF'VERDIX F.

Three Mile island i'ower Plant Salpling Locations

AFPENUDIX c.

Pennsylvania Lepartment of Env'iom.ental Resources Bureauof Water Quality Mlanagcment Program for Monitoring Ra,•tevater
Discharges from Three Mile Island

APPEN.DIX H.

Key Staff and Offices

I-of NRC TLD Locations

for Long-Term Monitoring Program at TMI

FOREWORD

The protection of people and the environment from unnecessary exposure
to ionizing radiation from radioactive material that may yet be released
from the Unit II reactor at the Three Mile Island nuclear generating station
is of utmost importance to the Federal Government as well as to the Commonwealth of Pennsylvania.
It is essential that the involved Federal agencies work close.ytogether to provide the most credible environmental radiation monitoringdata.
To this end, the Executive Office of the President designated theI. S. Environmental Protection Agency as the lead agency for monitoringradiation in the environment surrounding Three Mile Island.
The technical staffs of the Nuclear Regulatory Commission, theU. S. Public Health Service (of the Department of Health and Human Services,formerly the Department of Health Education & Welfare), the U. S. Departmentof Energy, the Commonwealth of Pennsylvania, and the State of Maryland
participated with the U. S. Environmental Protection Agency in the
preparation of, and have concurred with, this plan.

Stephen J. Gage
Assistant Administrator for
Research and Development
U. S. Environmental Protection

Agency

iii

11-2

a

tn~

Is

a~n

iN7 R. '- C I I ON
1

In dc-.elc' ng the criginal plan, careful consideration was given to thetypes and quantities of radionuclides that were in the Reactor Containment
The
Building, the Auxiliary Building, and the Fuel Handling Building.
licensee's surveillance plan (Appendix B), which is 'closely monitored by
the Nuclear Regulatory Commission (NRC), was also considered.

lHouse-medc. Lx the W tAgency
te i'trection
U.S. E:'xir-:..
I
a' the lead Federal agencv for conducting a cn"prehensive long-term
eivironmental radiation surveill~nce program-a as follou-up to the March 28,
accident at the Unit 11 reactor of the Threp Mile Island nuclear
1979rmc: ) . Before im-plementing this lon'teimerating station (ApprinOi . -lewe d the general plan ou tl ineIoIIlan, zl • Fe deral atg cies :'o.em rud
e
April
1J,
- 9,
it
Tile 1 .S .
or.
rcc
ns tt t.: the cha ot 'ing conditio
mt
i iluiredL

The long-term surveillance plan provides for increased surveillance if
a release is anticipated, if planned activities
increase the potential for a~az-

En~ir * :ental Protection Agenc. has c, ordinaten
ir ,
vt-d Fct :.>.r l a c c ies
t .c1
e Cc::nthc .

if

release. or

the ea forts of thenn ssn-. -a ni a.

a release occurs unexpectedly.

Since ti.i purcing or venting'f}.rypton-85 was completed in July 1990,
remaining in the Reactor Containment
there are two comparcments of radioactivity
the core and primary coolant.
(1) the sumop water on the floor and (2)Building:

The 7u.llic releseof dica obtained iv the Federal agencies involved
the !'og-terw menltoring program will be through the U.S. Environmental: .. te-cti.n Acency lEYA).
Motever, data will simultaneously be provided
tc thE - hor Federal participants and to the Bureau of Radiation Protectior
In
(xRP)
\f
the Pennsa-Ivania iepartment of Environmental Resources (DER).
its
statutory responc: 'aý.:ill this preclude any agency from fulfillingc'T•.s purpose of the long-term.
program is fourfold:environmental

radiation

to providc c measure of the radiological quality of tie environment in the vicinity of the Three Mile island nuclear power
facility
during a period when large quantities of radioactive
material will be dealt with during cleanup of the facility,2)

to provide a basis for informing
mental levels of radioactivity,

4)

LAYLE 1surveillance

1)

3)

There are approximately 650,000 gallons of contaminated water in the
The concenReactor Containment Building (approximately eight feet deep).
trations of radionuclides in this water as of 7/14/80, according to the NRCI,
are shown in Table I.

CONCENTRATIONS OF MAJOR PRADION"UCLIDES IN WATER
WITHIN THE REACTOR CONTAINHENT BUILDING*
7/14/80

the public as to the environ-to provide confirmation and feedback regarding the success incontrolling releases of radioactive material to the environment,
andto provide an in-plac e monitoring program ready for immediate
use if an accidental release should occur.

This long-term surveillance program. is not a subsitute for, but is in addition
to and independent of, the environmental surveillance program conducted by theMetropolitan Edison Company, operators of the nuclear power station.

Radionuclide

Concentration(uCi/cc)

Half-Life

3H

0.98

12.16 years

89Sr

0.63

52.7

days

90S.t

2.75

27.7

years

29.6

2.05 years

172.8

30.0

137Cs

years

*The concentrations of radioisotopes listed in this Table are "best estimates"
based upon a limited sampling program.
More precise measurements will be madeas the decontamination process continues.

The uncertainty of the type and timing of cleanup 6peraticons as well as
the changing concent:ations of radionuclides i; containment necessitates
periodic reassessment of any mcnitoring plan.
This document represents thesecond revision of the Long-Term. Environmentol Radiation Surveillance Plan
for Three Mile Island dated September 27, 1979.
The first
revision is dated
March 17, 1980.

iLetter dated July 18, 1980 from John T. Collins, Deputy Program Director, T11
Program Office to Erich Bretthauer, Project Director, EPA, Middletown, PA.

-I-

M-3

SittVEILLAI.CE PLAN

Plans: fur treatment
ente!-r'n the Reactor Containment Building and the,tter C,.,ins Watur re beir
developed.
These plans will be implement-in late '160 ct the ,.ar i est.
There is alsays an extremely remote possibility that contaminated water inthe Reactor Containment Building could accidentally be released to theSusquehanna River prior to removal of contaminating radionuclides.
This loprovides for prompt Jetesrrination of the extent uf any release followed by
notification of appropriate authorities responsible for taking protective
actions.
-e radionnuolide concer.trations, as provided by. NRC, of ap-rcximately 96,0u0
gallons of pri!:nry .:o-tant in the i'eactor, as of July 21, 1980 are shown in
Table 2.

TABLE 2

CONCENPRATIONS OF M'iAJOR
RADIONUCLIDES IN THE PRIMARY REACTOR COOLANT*

7/21/80

Radionuclide

Concentration(uCi/cc)

Half-Life.09

12.26 years.05

10.76 years

311
85Kr
89Sr

2.4

52.7

days

23

27.7

years

4.9

2.05 years

ROUTINE SURVEILLAnCE PROGKRXThe normal or routine surve-illance responsibilities of the various Federal
agencies are as follows:
Environmental Protection Agency
EPA will operate a network of eighteen continuous air monitoring stations(Figure 1) at radial distances ranging from 0.5 miles to 3.5 miles from TMI.
(After January 1, 1981, it is planned to reduce this network to thirteen
Each station will include an air s.cmpler an2 a -am~a rare recorder.
stations.)
A list of sampling locations is shown in Appendix C. Tie air sampler units
sample at approximately 2 cfm and the samples will be collected from eachCurrently the particulate
station and analyzed on at least a weekly basis.
filters are changed three times weekly and the charcoal cartridges (iodine
analysis) are changed weekly. All samples are analyzed by gamma spectroscopy
at EPA's ru1 Field Station in Middletown using a Ge(Li) detector with a lower limit
1 7
of detection for 1311, or 3 Cs of approximately 25 pCi (0.15 pCi/m3 for a 48
hour sample).
Each monitoring station will have a gamma rate recorder for measuring andRecorder charts will be collected and readrecording external exposure.
on the same schedule used for air sample collection. Charts will be
reviewed in Middletown and storaged at EPA's Environmental Monitoring and.
Support Laboratory in Las Vegas, Nevada.
Thermoluminescent dosimeters (TLD's) will be placed at each monitoring station
as well as at a representative number of population centers surrounding TMI.
Locations are shown in Appendix D. These dosimeters will be read on aquarterly basis.
8

90

5r

137Cs

30

30.0

years

The concentrations of radioisotopes listed in this Table are "best estimates"
based upon a limited sampling program.
More precise measurements will be madeas the decontamination process continues.

-3-

Additional air samples will be collected and analyzed for 3H and 5Kr at the
TMI Observation Center, Goldsboro, Middletown and Bainbridge stations.
Effective January 1, 1981 the Bainbridge sampler will be shifted to York Haven.
Continuous monitoring of the radiological outfall to the Susquehanna River
will also be conducted as an alert mechanism to avoid contamination ofdownstream drinking water supplies.
An EPA system which continuously draws
water from the outfall and provides a graphic presentation of the count rate(or c.oncentration)ina holding reservojr is

opyS[tional.

The system has asensitivity of less than 100 pCi/l for 3I 'or
Cs for the concentrationof the liquid in the counting reservoir.
A two-stage pumping system is used,with water from the outfall being collected in a sediment trap, prior tobeing pumped to the counting reservoir. At a flow rate of 1.0 I/minute fromthe outfall to the sediment trap and 0.5 1/minute to the counting reservoir,
90% of equilibrium between the outfall and the counting reservoir will bereached in approximately 17 minutes.
Thus an outfall concentration of
approximately 1,200 pCi/l of 137Cs will initiate the alarm system in 17 minutes.
A concentration of 3,000 pCi/l in the outfall will initiate the alarm inless than 5 minutes.
At the present time the alarm level is set at 1,000
1 7
pCi/l based on 3 Cs as the limiting radionuclide.
This corresponds to1/2( of the r:mTm perm.issible concentration as specified in the Code of
Ye.
•I
.
t.:
: Title 1 0. Par t 20 .

'

m

- - e

0
S;"

;"

CD
jn

O

(

.
C:
:3 C

3~

ga-mna emitting radionuc--desat the TMI- Field Station ahnd for tritium at theDapartment of Energv

CA
0
-

NI

Sa:-.,les will also 1- collected and analyzed from other,- is asap.propriate.
The outfall
samples will be gamma scannc:-C
THI Field
Station Laboratory where the minimum sensitivity for thesý -,:-ples is about
13 1
37
35 pCi/I for
1 o, 1 Cs for a 10-minute count.
EPA will also analyze
Susquehanna River water sampled daily by the Commonwealth of Pennsylvania at
the City of Lancrster intake, as well as River water sampled upstream from TMI
These samples will be analyzed at the EPA TH'I Field Station(City Island).
which has a minimum sensitivity
for 1311 of 10 pCi/l for a 100-minute count.
3
The Commonwealth will then perform H, gross-alpha and gross-beta arsisacs
be perfored
Strontium-89 and Strontium-90 analyses villcn these samples.
9t.-eekly composite samples by EPA.
Detection limits for
za:iJ -jSr are
5 pCi/l and 1 pCi/l, respectively.
Weekly grab samples of -&ater and sedimentwill be collected from the east sedimentation pond on TMI and analyzed for
DER Laboratory.

>

G>

-- --

-The
-O-

-

)-

0

Department of Energy (DOE) will provide soil and vegetation analyses atse.en sites
semiannually.
In-situ
gamma spectrometry analyses will be
conducted at these seven plus one additional site.
TLDs are also in placemonitoring locations., If levels of
as well as at four stateat these sites
radionuclides demonstrate any increase above background levels, the samples

j

.

-

©

-

/

.

will be subjected to detailed radiochemical analyses.
to supply accident--•

Nuclear Regulatory
C_

C -

"

-Dlocated

S=

support0J-'"samples

U.S.
"The

•of

The Nuclear Regulatory Commission (NRC) will operate one air
sampling stationin the middle of the reactor complex.
The air
sample will be changed

The NRC will place two sets ofat 59 locations as shown in Appendix E.
Each set contains two lithium
borate and two calcium sulfate phosphors. Both sets will be read on a monthly
basis, however, flexibility
exists to read one set at more frequent intervals
should conditions warrant.

-*.

L.

Commission

weekly and be analyzed by gamma spectrometr

)TLDs
. C)

•

_

M

modeling

area radiological monitoring.

Sand

n

DOE will also continue

response services such as meteorological

Public Health Service

U.S. Public Health Service (PHS), Food and Drug Administration (FDA) willdefer further monitoring of foodstuffs and milk in favor of a close following
the Commonwealth of Pennsylvania's Department of Environmental Resources(DER) routine surveillance program.
FDA ray, at its
option, split
appropriate
with the Commonwealth for confirmation.
PHS/FDA will,

however, be prepared to reinstitutefoodstuffs and milk sampling program in the eventfrom Unit II.

/

M-5

and/or upgrade its

formerof an unexpected

releaseCommonwealth of Pennsylvania
The Department of Environmental Resources of the Commonwealth of Pennsylvania
sampling stations; one at the Evangelical
will operate three continuous air
Press Building in Harrisburg, one at the TMI Observation Center and one infollowed by asample will consist of a particulate filter
Each airGoldsboro.
The samples will be exchanged weekly, the particulate air
charcoal cartridge.
samples will be gamma scanned and beta counted for reactor relaced radionulide'.
routine surveillance
The Commonwealth's milk sampling has reverted to its
program, which consists of monthly milk sampling at two dairy farms near ti,
reactor related gamrea
The milk samples will be gamma scanned for allsite.
emitting radionuclides.
The Commonwealth will place TLDs at 10 locations shown in
TLDs will be read monthly.

The

Appendix VI.

As part of a'routine QA/QC program with the licensee, the Commonwealth will also
The-produce and fish samples willcollect local produce and fish in season.
be analyzed by gamma spectroscopy for any reactor related radionuclides.
The Commonwealth also participates with EPA, as previously discussed,monitor the principal aqueous outfalls of the Reactor.

The Maryland Department of Natural Resources is conducting approximately
quarterly sampling of fish, shellfish, aquatic vegetation and sediments in
Stations begin in
the lower Susquehanna River and upper Chesapeake Bay.
Holtwood Reservoir and terminate below the mouth of the Sassafrass River.
The sampling strategy is primarily to detect the environmental distributionof radionuclides discharged during the normal operations of the Peach Bottom
Knowledge of the levels of discharge from Peach
Atomic Generating Station.
Bottom and the resulting environmental concentrations provides an empiricalbasis for the prediction of effects from any discharges proposed from the
The Holtwood Reservoir Station provides opportunity for
Three Mile Island.
detection of TMI effects prior to interference by Peach Bottom effluents,
thus providing a basis for estimating the fractions of downstream detectable

Air sampling will serve as a measurement of inhalation exposure as well as anindicator of potential contamination of milk and food crops.
Should a prolonged airborne release occur, supplemental air monitoring stations will beestablished.
The contingency plan for release of contaminated water above the licensee's
permitted level for discharge to the Susquehanna River is set forth inAppendix G.
The plan includes prompt confirmation of the released activity
by analyses of grab and composite samples followed by notification of the
impact of the release to downstream users.
Details of the joint EPACommonwealth of Pennsylvania plan are described in Appendix G.
In addition
to the notification procedures of appropriate Pennsylvania agencies describedin Appendix G, the Director, EPA PHII Field Station will notify EPA's
Region III Office and EPA's Office of Radiation Programs of the details of
the release including anticipated impact to the adjoining states.
EPA's
Region IIl Office will then be responsible for notifying adjoining states.
This plan does not alter
the NRC standard operating procedures for notificationof the EPA Regional Office.

that are due to TMI.

In the event of an emergency, MD DNR will duplicate
the anticipated time of maximum impact.

Pennsylvania Department of Environmental Resources (PA DER) health Phvsinsa
personnel may also provide monitoring capability as appropriate.
During certain in-plant cleanup operations where an increase in the rate ofgaseous releases may be expected, additional survey teams may be deployed to
TMI by the EPA, the PHS, the NRC and PA DER.
The DOE helicopter may also be onstandby in the Harrisburg area for such operations.
(These criticalpoints in the cleanup will be identified by the NRC as much in advance as possible.)toState of Maryland

concentrations

In the event of a release of airborne radicactivity in excess of Lhe licensee's
EPA-TMi Field
Technical Specifications limits, the Director, technician
dit csvd be
ma_7i*-az_
EPA health physics
notified by the NRC and an
Positioning the EPA health physics technician will be the responsibility of the
Director, EPA-TMI Field Station until additional NRC personnel can be summonedI
to the site from the NRC Regional Office in King of Prussia. Pennsylvania.
The NRC health physics personnel would be supported by radiation mnnitoring
equipment and analytical capabilities, insluiding the N:RC Region I moailt
la6oratory.
Additional NRC personnel would he an-sits within two hours;
the location of the mobile laboratory at the time of the occurrence would
dictate its
response time.
The Senior NRC Site Kepresentative %ill a!isurethat the Director, `PA-TI Field S-ttion has access t-: curr-en: release data
and meterological information. "In addition, trie EmEignncy Coordination
Center of the DOE will be notified by the NRC and c-at-be requested to pr-:videaerial measurements and plume tracking.
The response time for an aircraft
to reach TNI can be expected to be from 2-3 hours under normal conditions
with a 6 hour maximum under virtually an: condition.

the routine sampling at

CONTINGENCY SURVEILLANCE PROCEDURES
Contingency planning for the protection of the public must address thepossibility of unplanned releases of airborne radioactivity to the generalenvironment, as well as liquid releases to the Susquehanna River.

The Maryland State Department of Health and Mental Hygiene Office ofEnvironmental Programs will provide additional monitoring capability as
appropriate.
Water samples will be taken at all
Maryland drinking water
intakes from the Susquehanna River.
These intakes are:i-ý6

W__6ý

N___

a.

:,e '

mialtir -, 1h.

: ;--.

ocat ec i-,,me diately above
R-EPORTING lNEIIQ4ATION TO THE MEDIA

2.

Conowinj

3.

Bainbridge,
err"
C.

The EPA will be the lead Federal agency responsible for distribution ofenvironmental data to the media.
All participants in this plan will keep eachof the other participants advised in advance of pending media releases
concerning TMI.
Releases will also be furnished to Metropolitan Edison Co.

2Ia

!:Tt
0 4n.

Nd.

- Port Deposit Intake,er.

1.opita!

QUALITYi ASSURAlNCE

5.

Citr

of

avre de Cre"2lk sss;.l e: - ,!i23h e÷- _- e
e.r
Dent:
co0der Mare! toa-

In addition to the internal quality control activities
practiced by the Federal
agenties and the Co-monwealth of Pennsylvania, organizations involved in TMI
monitoring will participare in the intercemparison studies listed
below.
Samples will be prepared and distributed by the Quality Assurance Division of
EPA's Environmental Monitoring Systems Laboratory - Las Vegas (E24L-LV).
The
intercomparison samples and the schedule for their distribution are as
follows:

f rm s : r, - e :avs - .ci a -.hich a r e o s:ta tiL Z"ealtn s:-. Rental Ilegietie parroits.

A listof riosn, numb-rs of ind'ividuals resoonsible for the various
is shown in Appendix F.
t-onitoting prr--'-x-sa:,7'.:
REPORTING PROCEDURES

Milk
There will be two types of data reporting procedures.
The first
type isdesigned to distribute information upon which im-sediase action might betaken and consists of informal reporting methods, while the second
procedure is designed to provide a verified data base.
!.IIEDIATE

Four-liter milk cross check samples containing potassium-40, strontium-g9,strontium-90, iodine-131, and cesium-I37 will be distributed in January, April,
July and October of 1981 to PHS, EPA, NRC, the Commonwealth ofPennsylvania, and the State of Maryland.

REPORTING PROCEDURES
Water

Each of the monitoring agencies will inform the other monitoring participantsof confirmed, positive levels of reactor-related radionuclides through the
Director, EPA TYI Field Station or his designated alternate. 'He willpromptly relay the information by telephone or in person to each Federal
Agency involved, the Commonwealth of Pennsylvania, and the State of Maryland
followed in either case by written documentation of the event.
If concentrations of radionuclides in excess of those permitted in the environment bylOCFR2D, Appendix B, Table 2, Column 2, are found outside the controlledarea, EPA shall be notified within 2 hours of discovery.
Otherwise notification shall be made by noon of the working day following discovery.

The following cross-check water samples will be distributed
the Commonwealth of Pennsylvania, and the State of Maryland.

to PHS,

EPA,

NRC,

Four-liter samples containing a mixture of photon emitting radionuclides(Cobalt-60, Ruthenium-106, Cesium-134, Cesium-I37, Chromium-51, and Zinc-65)
will be distributed during February, June and October of 1981.
Four-liter samples containing strontium-89 and strontium-90 will be
distributed in January, May and September of 1981.

Periodic meetings may be called by EPA at T"MI to discuss proposed and ongoing
operations which could impact the off-site
agencies and to exchange information.
Renortine Data into the Data Base
All data will be reported in the format previously specified by EPA.
Data
from PHS, NRC, DOE and the Commcnwealth of Pennsylvania and State of Marylasd
will be submitted to EPA monthly for inclusion in the data base.
EPA data
will also be placed in the data base monthly.
On a monthly basis, EPA will place data obtained from Metropolitan Edison
and the Commonrealth of Pennsylvania, as well as relevant data from otherorganications into the data base.
EPA will then use computer transfers totransmit monthly updates to the data base to the originating organizations forverification.
All data will be verified by the originating organization within
15 davs of reccttt.icv
errors will be referenced by sample number for
e.rr:Lct o-.
-t•i-oct--cot-: 3Zillbeande available to all participants.

Four-liter samples containing Iodine-131 will be distributed in April,
August and December of 1981.
Fifty-milliliter
samples for tritium analysis
will be distributed on a bi-monthly basis.
Each participating Agency laboratory is expected to carry out three
independent determinations for each radionuclide included in a particularstudy and to report the results
to EPA.
Upon receipt of the reports of allparticipating laboratories, the data will be analyzed.
The analysis
includes a determination of the laboratory standard deviation, calculationsof the normalized range, normalized deviation, sample standard deviation,
grand average of alllaboratories and warning and control limits.
A report will be distributed by EPA to participating laboratories containing
results of each interconparison study.
EPA will immediately notify any
participating Agency laboratory if it is determined that the laboratory crosscheck results exceed the quality assurance deviation level for any-given typeof analysis.
10-

4
f,
-7

I

S "1 tt- •

:.Z;:
cou
o (i.:croa ;nd ti:t :.otiu.nal Institute ofCenter for 'ise
Safety and Health should 1keep the EPA co.erations center informed of their
Any environmental data
or off-site.
either at the reactor site
activities,
gathered by CDC or II]OSH should be submitted to the operations center for.
inclusion in the report.
11,

CALIF
'
FOR Tlii 'N0O:-BLE JOSEPH'EMODR.!dCDD_.I
THE HO:,O'ABLE J,-IES 5CEL.ESIN;`ER
ý' STLTHE "O71-'.'GLAS
FRO:-! :JACK urs..ToS3:

SUEJ7CI

Long-Tot-c Environrecical R'a'ati:.::n::n•oi:at -:nretiilYe island

Department of Energy
The Department of Energy should continue to sample and conduct radioana4v"t-esof Three Mile Island at apt::ccrJateof soil and vegetation in the vicinity
previous analyses, should !,e promptly submitted to
These, and allintervals.
Other environmental data collected by DOE, or its
the operations center.
contraitors, such as radiation intensity measurements from helicopter flights
and dosimeter readings, saould also be. included in the combined Federal
The Department should also continue to provide meteorolog'ical support
report.

It is clear that several Federal agencies must continue to play a key role inof their safety during
Cssuring the citizens around the Three Mile island siteof cleanup.
It isshutdown and initiation!-e final stages of the plant'sC
csi:.al that the involved Federal agencies work closely together to providef
Consequentlyt a creble itenvironmental radiation monitoring data.
pursuant to the President's direction that I coordinate the assistance cff'rtsof ail Federal agencies for the Three Mile Island accident, I am hereby
designat'ing the Environmental.Protection A~ency as the lead agency for thesein addition, I am askingeach of the agencies named below"'nitorcng efforts.
:0 continue to meet the responsiililities indicated and to provide adequate
resources for those tasks.
Environmental

Protection Agencv

Ai the lead agency, EPA should assume responsibility for coordinating thecollection and documentation of the environmental radiation data obtained 1v
allof the Federal agencies involved since the accident occurred on March 28,
The EPA should continue to maintain an operations center staffed with1979.
of Three Mile Island to coordinate dataradiation-specialists in thevicinity
collection and to inform the public, through the Nuclear Regulatory
The information and data collectedradiation levels.
Commission, of off-siteby EPA should be made available to the other participating agencies on a
The EPA should also continue to operate, at an adequate level,
regular basis.
and water-borne radioactivitv.
its
environmental monitoring network for air
Finally, the EPA should prepare a.report of such environmental radioactivity
for the recently estatlisbed Presidential Commission to investigate theat the operations center,as needed.

The Environmental Protection Agency should make every effort to obtain all
pertinent environmental radiation data from the Nuclear Regulatory Comsission,
the State of Pennsylvania, and the utility.

I am very pleased with the reports I have received of the excellent
I amcooperation among the Federal agencies assisting in the Harrisburg area.
of theof cooperation will continue, and that all
confident that this spirit
the risks of. radiation
participants will maintain their vigilance until
releases are reduced to a minimum.
If you have any questions on these assignments,
Eidenberg (456-6537).

accident.
Health

Education, mnd Ielfareof
The Food and Drug Administration should continue to conduct radioanalysee
milk and food *in the vicinity of Three Mile Island at appropriate intervals.
previous analyses, should be pror.Ftly submitted to the
These, and all
Other environmental data collected by FDA, such as
operations center.
dosicreter readings, should also be included in the combined Federal report.

cc:

Chairman Joseph Hendrie,
Nuclear Regulatory Commission

A- 2

14,-B

please call me or Gene

i

i

u

in.. in. a*~u~asa

AFPE2?DIX L
APPEN'DX B (Continued)
baTROPOLITA!NEDISON TMILONG-TERM1 MONITORING PROGRA-.
Milk Network

Location

The Metropolitan Edison (Met-Ed) Monitoring Program, is a combination of the
TMI-I and TMI-2 Environmental Technical Specification required programs andincreased monitoring activities
which were initiatedafter
March 28, 1979.
The monitoring program is subject to change based upon review of the results
and requests for additional monitoring.
In no instance will the program be
reduced to less than that required by the Environmental Technical
Specifications.
All major reductions in scope or intensity will be discussedwith the NRC and the Commonwealth of Pennsylvania prior to implementation.
All air,
water, and milk sampling locations refer to a location code which
denotes location as a function of azimuth and distance from the reactor.
The
location code is shown as Table 1.

Location Code-lwine Farm (cow)Becker Farm (cow)Fishing Farm (cow)
Cellig Farm (cow)
Hardiscn Farm (goats)

Sampling Frequency Lnalysis -

7B3
14DI
201
1h:

Biweekly

radioiodine
gamma spec.
$9-9OSr

4b!

(chem.

spe.)(quarterly composite)

Air Sampler Network
Met-EdLocation

Location CodeNorth Weather Station
Falmouth Substation
Observation CenterWest Fairview
Drager Farm
MiddletownGoldsboro Air Station
North York Substation

1F2
8CI
5A1
15G1
7FI
IC]
12B1
901

Sampling Frequency Analysis:

Gross Beta
Gamma Spec.

-if

Quarterly compositeof air particulate

89-90Sr,

Charcoal Cartridge -radioiodine

Gross Beta exceeds alert

Gross Alpha,

Gamma

Met-EdLocation Code

LocationweeklyAir particulate -Water Sampling Network

level

Steelton Water Works
Swatara Creek
001 Outfall TMI½ Distance-Between 001 Outfall
and South End TMISouth End TmIYork Haven Generating Station
Brunner Island
Chickies Creek
Columbia Water Plant
WrightsvilleYork
Lancaster

Sampling andAnalysis Code

15F1
IC3
10S1

2,4
2
1

9A2
9BI
8C2
BE
6G3
7GI
7G2
902
7G3

5
5
2,4
2,3,4
6
2,3,4
3
3
3

Spec.
SAlifPLING AND ANALYSIS CODES

1.

Daily composite analyzed for radioiodine (ion-exchange
beta, tritium, and gamma radioactivity scan).

2.

Automatic compositor collects hourly samples of raw water.
Composite
samples collected biweekly.
Total composite sample for month analyzed
for tritium and gaza radiractixity(scan).

separation),

gross

F-I

I
I

TI-BLE L - 1

APPENDIX .B (Continued)

3;

Automatic compositor collects hourly samples of finished water.

Distance & Azimuth Of Sampling Locations Fcr The
Three Mile Island Nuclear Station Offsite
Emergency Radiological Environmental Monitoring Program

Composite

samples collected biweekly.
Total composite sample for month analyzed fortritium, gamma radioactivity (scan) and gross beta radioactivity.
Analyzed for 131, if the gamrma scan is positive.
89

90

4.

Quarterly composite analyzed for5.

Weekly raw grab sample composited monthly
gamma radioactivity (scan).

6.

Raw grab samples taken if
131, is found in wateror Columbia when upriver samples are negative.

Additional

Sr andLocationSr.

and analyzed for tritium andsamples from Lancaster

SamplesFish, aquatic plants, aquatic sediments. are sampled periodically
miscellaneous food products as they become available.

as well as

TLD Network

Met-EdLocation Code

Location
North Weather Station
North Bridge
Top of Dike
Top of Dike

Falmouth-Collins Substation

South TMI
Mechanical.Draft Cooling Tower
North Boat Dock
Shelly Island
Laurel Road
Observation Center
Kohr Island
S. End Shelly Island
Coldsboro Air Station
Middletown Substation
Drager Farm
Route 241
North York Substation
W. Fairview
Columbia
Changeout

1S2
2S2
4S2
5S2
8C1
9S2
1ISi
16SI
14S2
4AI
5A1
16AI
10B1
12Bl
iCI
2FI
4G1
9GI

Distance(miles)

sIS

0.4
0.7

4S2
5S2
9S2
lOSI
11S1
14S2
16S1

0.3

IA2
4A1

0.7

5AI

0.4

7AI
7A-2
9A2*
9A2
lOAl
1OA3*
1lAl
13AI*
16AI
16A2*

0.3
0.5

2S2

IBI
4B1
5B1
6BI
7B1
7B3
9Bl*
9B1
9B2*
9B3*
1OB1
12B8
16BI*
16B8*

0.2
0.4
0.8
0.1
0.4
0.2

0.5

0.5-1.0

0.5
0.8.0.2-1 .0

0.5
0.7-1.0
0.4

0.2-1.0

00
250
710
95c
18Lo
2000
2210
2930
3400

1Ci
ICl
8C1
82
1421
14C3

2.6
2.3

14D1

3.5

255o
294c,

4.4
4.1
4.1

1 60C
1600

7F1
15F1

9.0
8.7

1320
308c'

650

2G1
4G0
5GI
5G2
6GI
7G1
7G2
7G3
9G0
9G2

10.5
10
10.6
10.6
10.5
15
15
15.1
13
15

920

15GI

15

3080

Ind*
Ctrl*

0.2-2.0
0.2-2.02700-900
900-2700

00
650
860
1370
1370
1850-1910
1880
2020
191o-2130
2250
2580-281o
3320
3260-3480
50

1.1

1410

1.6

1400

1.0-2.0

172o-1940
1830
1850-194o

1.1
1.6
1.0-2.0

1.0-2.0

Azimuth'LDcation

1.2
1.1
1.0
1.5

1.5
1.0-2.0
1.0-2.0

Distance(miles)Azimuth

3E1
8E!
8E1

2.7

/0
3100
1590
1650
2850
285o

32c
680
970
970
1 20co
1240
1280
1240
1830
1840

1180

185o-1940
204o
2530

326o-3480
326o-3480*Locations so noted are part of the fish sampling program and since electrofishingis the primary collection technique, that entire area is generally fished.

15C1

7GI

- monthly

h-3

-b10

" .C

A:`PENDIX}

C CONTIIUJIE

IHMLE
ILE ISSLAND
EPA LONG-TESP> SURVEILLANCE STATIONSAir Samplers

and Garama

ASSOCIATED 70---

TIE>
:.5

51

016 Manchester Station is 7 miles from plant and detection Qf releases would
be unlikely.
This azimuth is adequately covered by the York Haven Station (017)
which is only 3 miles from the plant.

Rate Recorders

cniddleton;
P,A --

rrisbur

0;-:::.cn }1

.4

---

international:'.nocc Station2.•

hors!troo,2.0'.,iile,F

2.9

PFairouth,PA --Charles Brooks Residence

3.0

Falmouth,

PA --Dick Libhart Residence

21 5O
5

IA --

Luidonderry Township
Brooks--023 Goldsboro - Muellar Residence - Stations 31 and 23 ale essentially on thesame azimuth from the plant with Station 21 at Newberrytown well located toback up Station 31.
This is basically a duplication of coverage.

iii

Build;:

Farr. (Earl N'issley hcs-ince)

Bainbridee,

PA --Bainbridge

Fire Company

7.0

Manchester,PA --Manchester

Fire Department

3.0York Maven,

PA --

2.5

Woodside,

4.0

Newberrytown,

180

10

*

305

PA --

York Haven Fire Station
Zane Reeser

PA --Residence

Exxon Ewick Service Station

123

265

2.9

Goldsboro,

PA --Muellar Residence

31

270

1.5

Goldsboro,

PA --Dusty Miller

34

305

2.7

Plainfield,

PA --Polites Residence

A5

068

3.5

Rovaltowm,

PA --George Hershberger Residence

36

095

0.5

r.i1

*37

025

0.7

North Gate,

1T11

*38

175

0.8

South Gate,

TMI

Observation

Scheduled for deletion after January 1, 1981.
as follows:

ResidenceCenterReasons

for deletion are

1. 01L Eainhridte
Station is over 5 miles from I'll and detection of releases
would be very unlikely.
Station 013 is located on the essentially same azimuth
at 3 tiles and Irovides adequate coverage in this direction.

M-If

037-038 North and South Gate TMI.
Tnese stations are beir.g semoved because(1) adequate monitoring is provided in these areas by other stations, (2) they
have been subject to more frequent malfunction than stations located further
from heav-. traific,and (3)the stations are located where shipments ofradwaste routinely pass very close to the monitors and may occasionally be
nearby.
This creates the potential for false alarms and unnecessary effort
to confirm that no releases have occurred.

APPENDIX 1)
APEIDI

AI'ilOD: 1.
FEOIZý

LSA TODSTATION
001
002**

AZ

DIST.

240

0.2

320

5.2

ASSOCIATED TOWN
FiuhingPI

Citizens Fire Cc.

PA--.. ighsplre,

Robert Bean Culf Station

PA --Creek,

International Airport

003

325

3.5

Middletown,

PA

00-1

360

2.0

Middletov-n,

PA --Elwoods'

005

0

Rcyaltown,

PA --Londonderry Tow.nship Building.ecwville,

PA --Brooks Farm (Earl

2.6

100

019

-Harrisburg

Sunoco Station

Nissley Residenc-e)

Hoffer ARCO Service

StationSTATION

AZ

DIST.

036

095

0.5

TMI Observation

037*

025

0.7

North Gate,

TMI

038*

175

0.6

South Gate,

TMI

039+

-329

5.3

Lower Swatara,

040-

314

10.6

.Steelton,

041-

305

10.7

New Cumberland,

042

174

4.9

Conewago Heights,

PA

00GIHSISBRG

110

31.0

Lancaster,

Visitors Information Center

Lebanon,PA --John Deere Equipment Co.

PA --Myers Exxon Garage

ASSOCIATED TOWN

Elizabethtown,

130

2.9

Falmouth,PA --Charles Brooks Residence

0021HSGBKG

055

25.0

150

3.0

Falmouth,

PA --Dick Libhart Residence

003PISCbKG

275

31.0

Carlisle,

014

145

5.3

Bainbridge,

004F SGBKG+

180

25.0

Loganville,

015,*

155

6.6

Saginaw,PA -

016

10

7.0

Manchester,PA --Ianchester Fire Department

017

10

3.0

York Haven,

PA --York Haven Fire Station

019,*

205

10.7

Strinestown,

PA --

020

205

2.5

Pleasant Grove,

021

250

4.0

Newberrytown,

023*

265

2.9

Goldsboro,.025**

360

7.0

Hunanelstown,

026**

025

10.0

Hershey,

030**

180

13.0

York,

031

270

1.5

Goldsboro, PA --

034

305

2.7

Plainfield,

035

OC
$

3.5

Londonderry Township,:j;s~ canoe

011

Bainbridge

PA --Fire Company

United Methodist Church

Brenner's Mobile Service

Total stations = 34

StationZane Reeser Residence

PA --

PA.--

Exxon Kwick Service

Station

Muellar Residence

PA -PA --

PA --

PA --

K.

Keefer's

Good's ARCO

Exxon Service Station
Service Station

York Fire Station,

PA --Dusty Filler

Springetts #16
Residence

Polites Residence
PA --George Hershberger

PA

PA

6.E

PA --

Center+New Stations added*Scheduled for deletion after January 1, 1980**Reactivated stations

PA --

PA

PA --

Capitol City Airport

APPED,.IX F
NRC ENVIRONMEffTAL T0LD LOCATIONSPENNSY-LVANIA DEPA,2.ý'T OF ENVIRON'.NI-TAL RESOURCES
THREE MILE ISLAN',D I.D LOCATIONS (Frequency - monthly)

NRC
StationN-RC
Location
950

1010
1080
1630
1610
1500
1360
83°
600
10
250
,460
190

5.9 mi
3.9 mi
2.7 mi
1.8 ml2.2 mi

1.0 mi0.6 mi
0.4 mi0.5 mi

1.7 mi
0.9 mi
2.8 mi

5.2 mi358'

2.5 mi357'

2.7 mi

00°0351'

3.1 mi

3490
3430

3180

3480

4.1 mi
3.5 mi
3.2 mi5.0 mi
1.3 mi170

3.1 mi

640
440
470

3.8 mi

3.6 mi
7.6 mi00
5.1 mi60 7.4 mi
00 9.3 mi
30 12.6 mi
3120 13.8 mi
3060
2970

Station
33
3!
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59

Location
3100
5.9 ml2670
5.S mi2990
6.3 mi2670
1.2 ml256'
1.4 mi225'
1.9 mi
2000 2.1 mi
2040
2.5 mi2530
3.9 ml2590
7.3 ml2680
5.8 ml2630
4.7 m41750
3.2 mi1720
3.0 ml1770
5.7 ml1820
9.0 ml2100
8.2 ml214'
9.6 ml18512.6 ml
1330
9.0 ml1450
4.9 ml1440
4.6 ml2060
0.9 ml2300
0.5 ml2930
0.4 ml3350
0.5 ml317'
1.2 mlAzimutt and Distance from Reactor
AzimuthDistance(Degrees)(Miles)Location
TOIT

Middiecown,

Mat.

Ed.

Mill St.

356

substationTýOMI

17MI Observation BuildingTOýM,

Lauchiin residence,

TOMT 4

Squire residence,

T0>15

York Haven,

TONI6

Newberrytown,

TOMT 7

Falmouth Substation,

TONI10Goldsboro,

Bainbridge,

PA

PA Hydroelectric Plant

PA Township

Building

Falmouth,Ed.

PA

9.6 mi

7.4 miBeaver residence,

Etters,PATOMNI1 2

Highspire,

6.6

145

5.2

166

2.9

252

4.5

161

2.3

254

1.3

2864

4.6

321

5.4

Redland Acres,

PA Turnpike

Com=ission

Building

'ý- I

M-13

86

Monitoring

StationTOMII

0.5

Elizabethtowýn,PA

PA Met.

90

APPEIDIXc.: /Q"
ruprcounLat,
will
totL
to col= a Sample!a-I'
i- opartin"alysis: to confirm that the co:-ri.o'u
for l'-%:r,':oy
and to.ine
the striD chart fcT evieTonce Of high rT,,
hioaCtJ'.ye Wi]
also contact NRC/Net Ed frown the site
to obtain the ":e,atýLnirom toein-plant monitors.
The DER Bureau of Radiation Piotection a:'d otherwill be notified.
appropriate BWQM staff

PENNSYLVANIA DEPARTMENT OF ENViRONMENTAL
EI.SOUR2CES
BUREAU OF WATER QUALITY KA]NAGJý-h;T
PROGRAM FOR MONITORING WASTEWATER DISC}HARGESFROM THREE MILE ISLAUD

4.
The water sample wJll be analyzed bV gaý'3baless t'an one tentO 0! too nax-2iMuM nermiss'bleboundar'y as given by lOCFE2I.

OBJECTIVE

't1

s

to
t

a
i

The monitoringprogram for discharges from Three Mile Island and for theSusquehanna River below Three Mile

Island isdesigned for the

:he
T.
Ihe
Bureau of Radiation Prctecti n wil' .vuateof the discharge based on all available oataalyis
sample and, in consultation with the Bureau of W.ater Culiy,
EPA, determine w•hetner cn..m.streaa water -sers will 'eim.acted.

following

purposes: First, it serves as an early warning system to notify downstream water supplies and other water users should any high-level radioactive discharges occur.
Second, it provides a historical account of theradiological quality of discharges from THI and of the river to show what,
if. any, concentrations of radioactivity exist. Third, it serves as anindependent back-up to the Metropolitan Edison (Met-Ed) monitoring program.
Fourth, it should provide some degree of public confidence in any decisionsofOfln.
aandt. The Bureau of eater Quality Management will notif'v the .'canstream
to th'm hewater use-rs that an unusual occurrence has happened .bindicate
estinated impact of the discharge on their water supplies and, if apProrriate,
recomr,mend closing the water intakes until the discharge -_.asses.
"r'thor, theState of Maryland will be notified.

that are made concerning any discharges.

EARLY WARNING SYSTEM

7.
If an incident occurs, additional sampling on the river will be
initiated to trac•.the distribution of the discharge of radioactivity.

A continuous water system has been installed on the Radiological Outfall (001)
at TMI and is cooperatively operated by DER/BQM and EPA.
This system is comprised of a sodium iodide detector coupled to a single channel analyzer with
rate meter and strip chart recorder output.
The analyzer has a window widthfrom approximately 30 9ev to 700 key and is capable of detecting concentrations of 1311 and/or 37Cs of about 100 pCi/l in the counting chamber.
Anautomatic telephone dialing system will activate paging units to alert DER
Water Quality Management (WGM) and EPA personnel. The concentration levelat which the paging unit is activated is variable and will be establishedbased on the inventory of radionuclides in the contaminated water.
(As of
September 5, 1979 that level is set at approximately 1,000 pCi/l, based137
on
Cs as the limiting radionuclide.)

Samples should be collected by BWQMRegional Staff at the Yocrk haven
Grab samples
Hydroelectric Dam at Brunner Island and at the i-cute 30 Bridge.
will be collected every 6 hours and analyzed as rapidly as possible by the
EPA's TMI Field Station Laboratory.

S.AUPLING LOCATIONSI.
A compositing sampling device operates on the- main outfail from
This samples the discharge every
Three Mile Island (Discharge No. 001).
The sample is taken
20 minutes and composites it over a 24-hour period.
to the EPA TMI Field Station Laboratory in Middletown and analyzed, by "gamna scan"
The bureau of Radiation Protecticn will
to a level of 10 picocuries/liter.
then take the sample and analyze for gross alpha, gross beta and tritium to asensitivity consistent with routing surveillance protocol.

ALARM RESPONSE AND SAMPLING PLAN

personnel at City
2.
A weekly grab sample will be collected by DERE/'"This sample will be
Island, above Three Nile Island, for background data.
and for grossanalyzed by gamma scan to a level of 10 picocurJes per. literconsistent vw-t: rtoutie surveilalpha, gross beta and tritium-to a sensitivity
ne-y otntouce raciaIt is recognized that upstream facilities
lance protocol.
activity into the river.

Should the early warning system detect an unusual occurrence, a WQMstaff
member and EPA will be notified by an automatic telephone paging system.
Insuch an event, the following procedures will be utilized:
1. The designated WQMstaff member and the senior EPA representative
will make telephone contact to activate the, confirmation and notification
procedures.
2.

3.
The City of Lancaster's water intake en the Susquehanna River will
be sampled every 2-hours and con.posjted once a dfa.. This sample will be

The EPA representative will notify the NRC and Metropolitan Edisonand request examination of in-plant monitors
appropriate action if necessary.

(R.Mt-7)

taken by the City of Lancaster persnnel and tranenorted to toe Bureau of
Radiation Protecticn Labnratorv for analysis.. This sample will be analyzed
in the sa-e manner as the other river samples.

for confirmation.and

G-1

G-?

11-14

rram

AEn

SM

-

-

a-

~i

i

LA

A-PiNDIX H (Continued)/AF:AY

AL:D OFFICES FOR LONG TERJI! MONITOF:1:G

PROGRA,

TM

Pennsylvania Emergency Management Agency

OPL-'ClTITLE
IFA

D)4?:

NAMI-E[d ractor

PtoNE

F71 590-3:04

ield
e1 Station
11I Project Manager
ion III - SLA DiO.
Office of Radiaionr rograms- uarters
N
nc[
g.rcr

Williamn GirtlloL.
1 t. .iEant he:Star. FL
as.'•k(717)

533-6191

(301)

99-

557-8217(3])

9'6-6756

FTS 443-4690(301)

L24-591:

Coy

FFS 443-1960(301)

299-9172

Barrett

FTS 590-1121(717)

9&4-7211

George H. Smitt
S. N. Fasano

FTS 488-1200
FTS 590-1123

(215)
(717)

326-'
944-.

Shanbakv.1S 590-1160(717)

367-8741

FIP 233-4093
FTS 233-5555

(301)
(301)

353-5555353-5555r-ITS 552-8217
iTS 597-4394'
FT5

7]rES C:':aite CoordinCharles
NF C

DOE

Sr. !121 Site Rec.
Chief, Fuel Facility &Material Safety Branch
Chief. Site Operations
Senior Radiation
5peci alist
Chief, Environmental
Protection Public
Safety Branch
DOE Emergency Center

Lake

H.

H.

M.

L.

Joe Deal

,O5
SI0

we:.

DH&MH

Director,
Radiation

Bureau ofProtection

Director, Bureau ofh ater Quality Mgmrt.

Chief, Div.
ControlThomas Gerusky

Lewis Bercheni
Ken Walizer
James Flesher
Ernie GiovannittiBill Hiddendorf(717)

787-2480(717)

763-9041

FTS
FTS
FTS
FIS
7S

787-4317787-8184787-9665
787-8184787-5027

(717)
(717)
(717)
(717)
(717)

432-5658
667-0031
921-8765258-3440
697-099q

(301)
(301)

383-2744
383-2744

(301)
(301)

823-8328
838-8359(717)

564-B22C

684-2188(717)

684-4862

397-3501

Jack Miller(717)

Columbia
Later Co.

Charles

(717)

EPA

U.
P.

S. Environmental
0. Box 103

Middletown,

PA

GCohn

MAILING AD

3T£SSES

Protection Agency

17017

PHS

U. S. Public Health Service
c/o EPA Field Statior
P. 0. Box 103
Middleto-n, 'PA
17057

NRC

U. S. Nuclear Regulatory Commission
Three Mile Island Site
P. 0. Box 311
Middletown, PA
17057

H-I
H-2

M-15

561-1103(717)

Radiation
Robert E. CorcoranRichard Brisson235-1028

Wrightsville
Water Co.

FE!NS-SYLVAXIA:
DER

(717)

Mike Freedman

TihREE MILE ISLAU D'Vi!lIortE'

FFS 783-8150

Lancaster
Water Co.

CIordipJohn(PE2HA)APPENDIX N.

N.1

OCCUPATIONAL RADIATION EXPOSURE DURING ONSITE WASTE HANDLINGINTRODUCTION

Handling of radioactive waste generated at TMI-2 involves the following major steps that will
result in occupational radiation exposure to site personnel:-

Transfer of solid materials from source to packaging station
Waste packaging* Transfer of packaged waste to onsite staging/storage

facilities* Transfer of packaged waste from onsite storage facilities to truck loading area
* Truck and shipping cask loading* Survey of trucks and shipping casks prior to transport
The occupational dose received during each of these major steps will depend on the radiation
field in which the operations are performed, the crew size, and the time required to perform theoperation.
The bases used to estimate the occupational dose incident to each of the major steps
described above for each of the major waste forms are discussed in this appendix.
To prepare
these estimates, the staff made the following basic assumptions:
1.

Systems used to compct trash would be operated by a crew of two in a 2-mR/hr field.

2.

Drums or LSA boxes with surface radiation levels below 200 mR/hr would be handledunshielded, with distance from the package being the primary basis for reduction of theradiation field.

3.

Packages with surface radiation levels above 200 mR/hr would be handled either remotely
or within a transfer shield.
The average radiation field personnel would be exposed toduring these handling operations would be 2 mR/hr.

4.

Packaged waste stored onsite would be segregated by radiation level.
Packages withsurface radiation levels below 200 mR/hr would be stored in an area where removal will
expose personnel to an average radiation field of 10 mR/hr.
Packages with higher
surface radiation levels would be removed from storage using remote handling techniques, and the average radiation field personnel would be exposed to is 2 mR/hr.

5.

The loading of unshielded packages onto a transport vehicle for unshielded shipment
would be performed in an average radiation field of 20 mR/hr.

6.

For shielded cask shipments,
cask would be 50 mR/hr.

7.

Preshipment surveys of closed vans used for unshielded shipments and of shipping casks
would be performed in an average radiation field of 10 mR/hr.

the average radiation level at the surface of the shipping

These basic assumptions form the basis for occupational dose estimates presented below.
Since
the operations involved and the magnitude of the radiation fields will vary with waste form andpackage type, these estimates were prepared separately for each of the waste forms to be handled
and shipped offsite.
N.2

SOLID MATERIALSThe solid-material waste that could be generated consists of trash, contaminated equipment,
irradiated hardware, and filter cartridges. Once packaged, these solid materials can be divided

N-I

N-2
into two categories according to surfac6 radiation level--those below and those above 200 mR/hr.
Each of these package categories is discussed below.
N.2.1

Packages with Surface Radiation Levels Below 200 mR/hr

The waste forms expected to fall in this category include trash, contaminated equipment, and some
irradiated hardware.
These materials would be packaged either in 55-gallon drums or LSA boxes(3' x 4' x 6.5) with a volume of 80 ft 3 .
Details on crew size, work effort, radiation fields, and occupational dose for the steps involved
in handling trash packaged in 55-gallon drums from its generation through loading on a truck foroffsite shipment are given in Table N.l.
As shown, the average occupational dose is 5 personmrem per drum generated.
Details of the steps involved in handling noncompactible trash, contaminated equipment, and other hardware packaged in LSA boxes from its generation through loading
on a truck for offsite shipment are given in Table N.2. The average estimated occupational doseis 26 person-mrem per LSA box generated.

Table N.1.

Occupational Exposure from Handling of Low-Activity Trash Drums

Time
RequiredCrew
Size(minutes)

Handling Operation

Radiation
Field(mR/hr)Numberof Drums

Unit
Occupational Dose(person-mrem/drum)

Pickup and transfer topackaging area

1

5

10

Drum loading/compaction

2

6

Pickup at packaging area

2

Transfer to storage area
Placement in storage area
Pickup at storage area

0 . 5a

1.7

2

1

0.4

5

20

4b

0.83

1

5

20

4

0.42

1

3

10

4

0.13

1

3

10

4

0.13

Transfer to loading area

1

5

20

4

0.42

Placement in loading area

1

3

20

4

0.25

Truck loading

2

5

20

4

0.83

.Truck

1

15

10

90

0.03

surveyTotal

5aThe volume of waste handled in this operation is equivalent to half the volume of one
drum.
bAfter packaging, drums are transferred by forklift on four-drum
pallets.

These unit occupationaldose estimates are the basis

presented in Sections 5,

6,

N.2.2

7,

for the estimates of occupational doses

and 8 for these waste forms for drums and LSA boxes.

Packages with Surface Radiation Levels Greater than 200 mR/hr

The waste forms expected to be in this category include spent filter cartridges, some contaminated equipment, irradiated hardware, and immobilized incinerator ash.
These materials would bepackaged in 55-gallon drums and in large cylindrical and rectangular metal containers.
Details
on the steps involved in handling a typical spent filter cartridge from its generation throughsurvey of the shipping cask used for shipment are given in Table N.3.
The average occupationaldose is about 11 person-mrem per cartridge, or about 77 person-mrem per drum.
This was used toestimate spent filter cartridge handling doses in Sections 5 and 8.

U

N-3
Occupational exposure data for the steps involved in handling relatively high-level contaminated
It is based on packaging in containers
equipment and irradiated hardware are given in Table N.4.
of 70 ft3 capacity compatible with shielded shipment, with sectioning and disassembly operations
performed using remote techniques.
The average estimated occupational dose per disposable container is 38 person-mrem.
This value was used to estimate occupational doses in Sections 6 and8.

Table N.2.

Occupational Exposure from Handling of LSA Boxes

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Boxes

Unit
Occupational Dose(person-mrem/box)

Pickup and transfer topackaging area

1

5

10

0 . 2 5b3.3

Segregation

1

5

20

1

1.7

Sectioning/disassemblya

2

30

20

5

4

Box loading

2

15

20

1c

10

Transfer to storage area

1

5

20

1

1.7

Placement in storage area

1

3

10

1

0.5

Pickup at storage area

1

3

10

1

0.5

Transfer to loading area

1

5

20

1

1.7

Placement in loading area

1

3

20

1

1

Truck loading

1

5

20

1

1.7

Truck survey

1

15

10

9

0.28

Handling Operation

Total

' 26

aBased on sectioning/disassembly of 20 percent of waste received.
bVolume of waste handled in this operation equivalent to one-quarter the volume of one
box.
cAfter packaging, boxes are handled by'forklift.

Steps involved in handling incinerator ash from its generation as combustible trash through survey of the shipping cask used for drum shipment are presented in Table N.5. The average estimated occupational dose is 18 person-mrem per drum, the figure used in Sections 6 and 8 to estimate occupational exposure if trash is incinerated.
N.3

PROCESS SOLIDS

The process solids that could be generated consist of expended ion-exchange materials from the
EPICOR II system, the zeolite/resin system, and the evaporator/resin system; accident sludges;
and evaporator bottoms.
These wastes will be packaged in drums or large containers with surface
radiation levels in excess of 200 mR/hr and will be handled using remote techniques.
The basisfor estimating occupational exposure incident to waste handling for each of these waste forms is
discussed below.
N.3.1

EPICOR II

Resin Wastes

Estimates of the occupational exposure from the steps involved in handling resins generated byuse of the EPICOR II system are given in Table N.6.
The average occupational dose per resin
liner is estimated as 18 person-mrem.
The same values given in the table are applicable tohandling of the 50-ft 3 resin liners that could begenerated by the evaporator/resin system discussed in Section 7.3.
These unit occupational dose estimates are the basis for waste-handlingdose estimates for EPICOR II liners in Sections 5 and 7 and evaporator/resin system resin liners
in Section 7.

N-4

Table N.3.

Occupational Exposure from Handling of Spent Filter Cartridges

Handling Operationa

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Number of
Cartridges

Unit
Occupational Dose(person-mrem/
cartridge)

Removal from housing

2

10

20

1

6.7

Placement in transfer shield

2

5

20

1

3.3

Transfer to packaging station

1

15

2

1

0.5

Packaging in drum

2

5

2

1

0.33

Transfer to high-activity storage
Removal from high-activity storage

1
1

15
15

2
2

7b

0.07
0.07

Placement in shipping cask
Shipping cask closure

1
1

10
15

2
50

7
49c

0.05
0.25

Truck survey

1

15

10

49

0.05

7

• 11

Total
aAll handling is performed remotely.
bEach 55-gallon drum contains seven cartridges.
CEach cask contains an average of seven drums.

Table N.4.

Occupational Exposure from Handling of Irradiated Hardware
and Contaminated Equipment

Radiation
Field(mR/hr)Number ofContainers

Unit
Occupational Dose(person-mrem/
container)

Handling Operation

Crew
Size

Time
Required(minutes)

Pickup and transfer
to packaging area

1

15

10

0.25

10

Segregation

1

10

10

1

1.7

Sectioning/disassembly

2

30

0

2a

5

Container loading
Transfer to storage area

2
1

15
10

10
2

1
1

5
0.33

Removal from storage area

1

5

2

1

0.17

Transfer to loading area

1

10

2

1

0..33

Placement in shipping cask
Shipping cask closure

1
1

10
15

2
50

1
1

0.33
13'

Truck survey

1

15

10

1

2.5

Total
aAssumes 50 percent will be remotely disassembled or sectioned.

38

- Il

N-5

Table N.5.

Occupational

Exposure from Handling of Immobilized Incinerator Ash

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Drums

Unit
Occupational Dose(person-mrem/drum)

Pickup and transfer topackaging area

1

5

10

0 .a

8.3

Segregation

1

5

20

0.5

3.3

Incinerationb

2

30

2

0.5

4

Handling Operation

Immobilization and packaging

2

20

2

1

1.3

Transfer to storage area

1

5

2

1

0.17

Removal from storage area

1

5

2

1

0.17

Placement in shipping cask

1

10

2

1

0.33

Shipping cask closure

1

15

50

18 c

0.69

Truck survey

1

15

10

18

0.14

Total

'

18

aEach drum contains the equivalent of 175 ft 3 trash.
bIncinerator throughput of 350 ft3 trash per hour.
CWith drums at 2 R/hr,Table N.6.

shipping cask capacity is 18 drums.

Occupational Exposure from Handling of EPICOR II

Resin Liners

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Liners

Transfer to truck transfer cask

2

10

2

1

0.67

Transport to storage area

1

10

2

1

0.33

Transfer to storage

2

10

2

1

0.67

Place in storage

1

10

2

1

0.33

Remove from storage

1

15

2

1

0.50

Load shipping cask

1

10

2

1

0.33

Cask closure

1

15

50

1

13

Survey truck

1

15

10

1

2.5

Handling Operation

Total

Unit
Occupational Dose(person-mrem/liner)

'

18

I

I

N-6
N.3.2

Zeolite/Resin System Wastes

Steps involved in handling zeolites, resins, and spent filter catridges from the zeolite/resin
system are presented in Table N.7.
As shown, the average occupational dose per 10-ft 3 liner is
13 person-mrem.
The dose from the larger 6' x 6' liners would be similar. These unit occupational dose estimates are the basis for waste-handling doses estimated for zeolite/resin system
liners in Sections 6, 7, and 8.
N.3.3

Evaporator Bottoms and Accident Sludge

Details of the steps involved in packaging and handling evaporator bottoms and accident sludge
are presented in Table N.8.
The estimated unit occupational dose for both waste forms in theimmobilized condition is 5 person-mrem per drum.
These unit occupational dose estimates wereused as the basis for waste-handling dose estimates for accident sludges in Sections 5 and 6 andfor evaporator bottoms in Sections 7 and 8.
N.3.4

Liquids

The liquids that could be generated consist of chemical decontamination solutions.
Some drums ofimmobilized decontamination solutions will have surface radiation levels below 200 mR/hr andothers will have surface radiation levels above 200 mR/hr.
Occupational exposure information forthe steps involved in handling the low-activity drums is given in Table N.9.
The average estimated occupational dose is about 3 person-mrem per drum.
Similar information is presented forthe intermediate-level solutions in Table N.1O.
The average estimated occupational dose is also
about 3 person-mrem per drum.
These values were used to estimate occupational dose for packaged
decontamination solutions in Sections 5, 6, and 8.

-

I I

-

N-7

Table N.7.

Occupational Exposure from Handling of Zeolite Resin System Liners

Handling Operation

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Liners

Unit
Occupational Dose(person-mrem/liner)

Transfer to storage(underwater)

2

15

2

1

1

Transfer from storage(underwater)

2

30

2

1

2

Load shipping cask

1

15

2

1

0.5

Cask closure

1

10

50

1

8.3

Survey truck

1

15

10

2a

1.3

Total

13

"

alO-ft-3 liners are shipped two casks per truck.

Table N.8.

Occupational Exposure from Handling Drums of Evaporator Bottoms
and Accident Sludge

Handling Operation

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Drums

Unit
Occupational Dose(person-mrem/drum)Transfer to storage

1

15

2

1

0.5

Removalfrom storage

1

15

2

1

0.5

Placement in shipping cask

1

10

2

1

0.33

Cask closure

1

15

50

5a

2.5

Truck survey

1

15

20

5

1

Total

- 5

aExpected radiation levels will permit between four and seven drums per cask shipment.

N-8

Occupational Exposure, from HandlingDrums
Table N.9.
of Low-Activity Decontamination Solutions
Unit
Occupational Dose(person-mrem/drum)

Crew
Size

Time
Required(minutes)Radiation
Field(mR/hr)Numberof Drums

Pickup at packaging area

2

5

20

4a

0.83

Transfer to storage area

1

5

20

4

0.42

Placement in storage area

1

3

10

4

0.13

Pickup at storage area

1

3

10

4

0.13

Transfer to loading area

1

5

20

4

0.42

Placement in loading area

1

3

20

4

0.25

Truck loading

2

5

20

4

0.83

Truck survey

1

1.5

10

90

0.03

Handling Operation

.

Total
aAfter packaging,%3

drums are handled on a four-drum pallet.

Table N.1O.
Occupationalof Intermediate-Level

Exposure from Handling Drums
Decontamination Solutions
Unit
Occupational Dose(person-mrem/drum)

Crew
Size

Time
Required(minutes)Radiation
Field*(mR/hr)

Numberof Drums

Transfer to high-activity storage

1

15

2

1

0.5

Removal from high-activity storage

1

15

2

1

0.5

Placement in shipping cask

1

10

2

1

.0.33

Shipping cask closure

1

15

50

10b

1.3

Truck survey

1

15

10

10 b

0.25

Handling Operationa

Total
aAll operations performed remotely.
bAverage cask radiation level of < 20 R/hr shipped in a 14-drum cask, > 20
shipped in a seven-drum cask.

3

R/hr to 100 R/hr

I

APPENDIX 0.

I

I

I

DECONTAMINATION STATUS OF AUXILIARY AND FUEL HANDLING BUILDINGSThe decontamination status of the Auxiliary and Fuel Handling Buildings (AFHB) as of September 1,
1980, is summarized in Tables 0.1 through 0.3 for three different elevations within the buildings.
The floor plans of the Auxiliary and Fuel Handling Buildings for these same elevations areshown in Figures 0.1 through 0.3, and the area labels in the first column of the following tables
are keyed to the labels in these figures.

I

0-1

I

I

0-2

LOCATION

AREA DESCRIPTION

A

Liquid Waste Transfer Pump
Entrance Way

B1

Cleanup Demineralizer andFilter A

B2

Cleanup Demineralizer andFilter B

C

Liquid Waste Transfer Pumps

D

Evaporator Condensate Test TanksEl

Makeup Pumps Entrance Way

E2

Makeup Pump A

s

E3
E4

Makeup Pump B
Makeup Pump C

QI

Fl

Neutralizer Tanks

Q2

F2

Neutralizer Filters

F3

Neutralizer Pump RoomG

Reactor Coolant Waste Evaporator

HI

Reclaimed Boric Acid Tank

H2

Reclaimed Boric Acid Pump

Ji

Spent Resin Tank A

J2Spent Resin Tank B

•I

I
I

J3

Spent Resin Pump Room

K

Oil

Ll

Makeup Valve Rooms Entrance Nay

L2

Makeup Valve Rooms Access Corridor

L3

East Valve Room

L4

West Valve RoomMI

Liquid Waste Disposal

M2

Entry Way

NI, N2

Bleed Holdup Tanks

01

Auxiliary Sump

02

Auxiliary Sump Tank

03
PI

Auxiliary Sump Valve Room
Decay Heat Vault A

P2

Decay Heat Vault 0

Q1

Spray Vault A

Q2

Spray Vault B

R

Elevator Pit

S

Seal Injection Room

Drum Storage

Figure 0.1.

L

Valve Room

Auxiliary and Fuel Handling Buildings, 281-Foot Elevation.

I
I

0-3

LOCATION

AREA DESCRIPTION

AIntermediate Cooling Pumps/Sea]

Return Valve RoomB

Makeup DemineralizersC

Gas Analyzer RoomD

Makeup Tank and Filters

E
F1

Spent FuelCooler Area
Spent Fuel Demineralizer

F2

Spent Fuel Filters

GI

Waste Gas Decay Tank

G2

Waste Gas Filter

G3

Waste Gas Decay Tank

EB,

A

G4

Waste Gas Valve RoomH

Deborating DemineralizersKK

Miscellaneous Waste Holdup Tank

M

Mezzanine Valve RoomN

Concentrated Waste Transfer Pump

0

Seal

P1

Makeup and Purification Valve
Area Corridor

P2

Valve RoomK

Return Coolers and Filter

Figure 0.2.

LOCATION

AREA DESCRIPTIONA

Concentrated Waste Tank

B

Mix Tank AreaCFHB East Corridor

Auxiliary and Fuel Handling Buildings,

I305-Foot Elevation.

__________________

B0

I
Figure 0.3.

Auxiliary and Fuel Handling Buildings,

328-Foot Elevation.

Table 0.1.

Decontamination Status for Elevation 281 as of September 1, 1980a
Location

Area Description

Decontamination Efforts/Status

Initial Levels
Surface
Contam4- Radiati 8 nnationLevel

Present Levels
Surface
Contam4- Radiati~nLevelnation5,000

Remaining
Effortst

Initial entry made with Scott Air
Packs.
Radiac wash, decontaminatedto door.
Decon complete except for demineralizer resin. First personnel
entry with supplied air, respirators later. Hydrolaser used.
Decon will require disposal of spentresin in spent resin tank, transfer
of cleanup demin. resin, change
filter. No action taken yet.

>106

Liquid Waste
Transfer Pumps

Gross decontaminated for maintenance.

>106<50,000

1,2

D

Evaporator Condensate Test
Tanks

Floor drain removed, Radiac wash
used. Decon complete except for
filters and motors.

>106<1,0002,4El

Makeup Pumps
Entrance Way

Entrance ways. to all MP cubicles
have been decontaminated but
require additional work.

E2

Makeup Pump A

Respirators used.

Makeup Pump B

completed; light decon need,
except for strainer and rotor.
Gross decon complete.

A

Liquid Waste
Transfer Pump
Entrance Way

B1

Cleanup Demineralizer andFilter A

B2

Cleanup demineralizer andFilter B

C

E3

asee Figures2 0.1 through 0.3.
bDPM/100 cm .

CmR/hr.
dAt cubicle door.
eAt entrance to vault.

Gross decon

5,000

>106

tRemaining Efforts:
1.
Further decontamination required.
2. Transfer of fluids, changing filters,
flushing lines, -etc.
3. Complete decontamination required-not yet started.

2,4<1,000

10 ,000d1

10 ,0 0 d

2,3

10,0003,000

410,000<5,0004>100,000<25,000<5,0001,2

4. Light decontamination required.
5. Debris removal.
6. Decontamination complete.

0Table 0.1.

Continued
Present Levels

Initial LevelsaSurface
Contam4nation

Location

Area Description

Decontamination Efforts/Status

E4

Makeup Pump C

>106

F1

Neutralizer
Tanks

F2

Neutralizer
Filters
Neutralizer
Pump RoomRespirators used, initial pass reduced
smears to 5 x 105. Light decon
required.
Water was cycled in and out oftanks reducing dose rate at doorto 45 mR/hr.
Decontamination complete.
This room decontaminated several
times, still requires additional
effort. Piping needs flushing.
Further light decon required.

>106

Initial decontamination completedwith supplied air. Subsequentpasses reduced levels further.
Maintenance in progress.
Same status as H1.

>106

Seven decontamination passes reduced levels to about 2K DPM.
Final decon to be completed priorto addition of cleanup resin.
Six decontamination passes reduced levels to 2K DPM. Finaldecon to be completed prior toaddition of cleanup resin.

F3

G
H1

H2
Ji

J2

Reactor Coolant
Waste .Evaporator
Reclaimed Boric
Acid Tank

Reclaimed Boric
Acid Pump
Spent Resin
Tank A

Spent Resin
Tank BaSee Figures2 0.1 through 0.3.
bDPM/10 0 cm .
cmR/hr.

dAt cubicle door.
eAt entrance to vault.

Radiatipn
Level

Surface
ContamSnation

Rad4ation
Level

Remaining
Effortst<5,000

1,2

150d

3,000

1,2

150

<1,000

6100<1,000.

40

1,2<5,000

4<40<5,000

1

>106

50

<5,000

1

<106

125

<1,000

<24

2

<106

30

<1,000<1020tRemaining Efforts:
1. Further decontamination required.

4.

Light decontamination required.

2.

5.

Debris removal.

6.

Decontamination complete.

3.

Transfer of fluids, changing filters,
flushing lines, etc.
Complete decontamination required-not yet started.

Table 0.1.

Continued
Present Levels

Initial LevelsaLocationa Area Description

Decontamination Efforts/Status

J3

Spent Resin
Pump RoomSeven decontamination passes reduced levels to 1.5K DPM. This
area used for Radiac wash drumstorage--total decon required
prior to transfer of cleanup resin.

K

Oil Drum Storage

Li

Makeup Valve
Rooms EntranceWay

Room is being used to store Radiac
wash drums and floor drain strainers.
Storage shelves and unidentified
boxes located in room.
Room scheduled for decon after drums transferred to solidification.
Area cleaned and decontaminated.
Construction overhead, some final
decon may be needed.

L2

Makeup Valve
Rooms AccessCorridorEast Valve
Room
West Valve
Room
Liquid Waste
Disposal Valve
Room
Entry Way

L3
L4
M1

M2

aSee Figures 0.1 through 0.3.
bDPM/100 cm2 .

CmR/hr.
dAt cubicle door.
eAt entrance to vault.

Surface
Contam,nation

Radiati~n
Level

Surface
Contam4nation

Radiation
Level

<106

5

<1,0003

700<1,0006<2,0004

1<15,000<200

1<20,000<200

1<2,000Hydrolaser has been used on floor
with good results.
Hydrolaser has been used on floor
with good results.
High level decontamination has
been done. Hydrolaser used.
Some decontamination completed.

>106

<250

<30,000

1

>106

<100

<20,000

1

TRemaining Efforts: .
1. Further decontamination required.

4.

2.

5. Debris removal.

3.

6

<200

Hydrolaser has been used on floor
with good results.

<10,000

Remaining
Effortst

Transfer of fluids, changing filters,
flushing lines, etc.
Complete decontamination required-not yet started.

6.

Light decontamination required.

Decontamination complete.

CTable 0.1.

Continued
Initial LevelsaLocation

Area Description

NI,
N2

Bleed Holdup
Tanks

01

Auxiliary Sump

02

Auxiliary Sump
Tank

03

Auxiliary Sump
Valve Room
Decay Heat
Vault A

P1

Decontamination Efforts/Status
Gross decontamination complete.
Maintenance required for final
decontamination.
Sump needs desludge, total clean
and decon. Priorities being established on shielding, desludge, anddecon. Hydrolaser used. Filterschanged.
Commenced tank desludge, continues
when Aux. Sump Filters 3A & 3B arechanged.
High-level decontamination performed
with high pressure wash.
High level decon done once. Further
decon will proceed after mini-decay
heat system is operable and the
decay heat system can be flushed.
Decay heat vaults are shielded.

P2

Decay Heat
Vault BTwo decontamination passes. Highradiation levels due to contained
liquids. Further decon required
after flushing. Decay heat vaults
are shielded.

Q1

Spray Vault A

Two cleanup and decon passes completed. Further decon work needed.

aSee Figures 0.1 through 0.3.
bDPM/100 cm2 .

CmR/hr.
dAt cubicle door.
eAtentrance to vault.

Surface
ContamSnation

Radiation
Level

Surface
Contam4nation

Radiation
Level

>106

>30,000<50,000<7,000

1

5,000

1

2,000

1,2

<1,0001,2<3 , 0 0 0 e

<3 e

1,2

<3 , 0 0 0 e<3,000e

1,2<12,000

1

>106

3,300

>106

3.

1,200

<50,000

Remaining
Effortst

C>106

tRemaining Efforts:
1. Further decontamination required.
2.

Present Levels

Transfer of fluids, changing filters,
flushing lines, etc.
Complete decontamination required-not yet started.

75,000<400,000

4.

Light decontamination required.

5.
6.

Debris removal.
Decontamination complete.

Table 0.1.

Continued
Present Levels

Initial LevelsaDecontamination Efforts/Status

Location

Area Description

Q2

Spray Vault B

No entry to date.
area.

R

Elevator Pit

Initial high-level decon complete.
Waiting on resolution of untreatedconcrete contamination problem.
Shielding installed.

S

Seal Injection
Valve Room

Hot-water flush and high-pressure
wash complete.
Contaminated concrete.
System flushing.&maintenance required.

General Area

Corridors, stairwells decontaminated.
Effort continues daily to prevent recontamination.

aSee Figures 0.1 through 0.3.

Surface
Contam4nation

Radiation
Level

cmR/hr.

2.

Transfer of fluids, changing filters,
flushing lines, etc.
3. Complete decontamination required-not yet started.

Remaining
Effortsf
3
1>106

bDPM/100 cm .

dAt cubicle door.
eAt entrance to vault.

Surface
ContamSnation

125,000e

High radiationtRemaining'Efforts:
1. Further decontamination required.

2

Radiatipn
Level50,000<100,000

1,2,5<1,0000

4.

Light decontamination required.

5. Debris removal.

6. Decontamination complete.

W

ýZmi

10

Table 0.2.

Decontamination Status for Elevation 305 as of September 1, 1980
Initial Levels

Locationa

Area Description

A

Intermediate
Cooling Pumps/
Seal Return
Valve Room
Makeup Demineralizers
Gas Analyzer
Room
Makeup Tank
and Filters
Spent Fuel
Cooler Area

B
C
D
E

F1

Spent Fuel
Demineralizer

F2

Spent Fuel
Filters
Waste Gas
Decay Tank
Waste Gas Filter
Waste Gas Decay
Tank

G1
G2
G3

aSee Figures 0.1 through 0.3.
bDPM/100 cm2 .cmR/hr.
dAt cubicle door.
eAt entrance to vault.

N MW_= Nor-

Decontamination Efforts/Status
High level decontamination done.
Spill area and hot spots require
further work. Filters changed.

Surface
Contam4nation>106

Present Levels

Radiation
Level

Surface
ContamSnation

Radiatip
Level

2,500

<5,000<30

1

5 ,000d

2,3

<300

2,4

10 ,000d

2,3

No entry to date
High level decontamination complete. Filters changed.
No entry to date.
Decontamination completed.
Used
for storage of Radiac wash drums.
Construction area.
Decontaminated. Previous Radiac
drum storage area. Filters needchangeout.
Decontaminated, filters changed.
Floor decon complete, tankinspected.
Decon complete, tank inspected.
Decontamination of cubicle
complete.

<100,000<5,00010 , 0 0 0 d

700

Remaining
Effortst<1,0004<1,0004<1,0004

10,000<1,0002,000<1,000<1,000

<4

4

<1

4
2

tRemaining Efforts:
1.

Further decontamination required.

4.

Light decontamination required.

2.

Transfer of fluids, changing filters,
flushing lines, etc.
Complete decontamination required-not yet started.

5.

Debris removal.

6.

Decontamination complete.

3.

0
'.

I

Table 0.2.

Continued
Initial Levels

Locationa

Area Description

G4

Waste Gas Valve
Room

Decontamination complete.
struction underway.

H

Deborating
Demineralizers
Misc. Waste
Holdup Tank

Decontamination complete.

K

M
N

0

P1

P2

Mezzanine Valve
Room
Concentrated
Waste Transfer
Pump
Seal Return
Coolers andFilter
Makeup and Purification Valve
Area Corridor
Valve RoomaSee Figures 0.1 through 0.3.
bDPM/100 cm2 .
c mR/hr.

Decontamination Efforts/Status

Surface
Contamnnation

Con-

Present Levels

Radiation
Level

Surface
Contamnnation

600<1,0004<1,0006<80,000

1,2-

Decontamination will continue whentank flushed. Filters need to bechanged.
Floor decontaminated. High dosefrom sludge in MWHT.
Maintenance required to stop leak.

3,000

No entry to date for decon.

3,000

Floor decontaminated several
times--more will be required.

150

No entry to date for dec6n.

<10,000

Radiatipn
Level<15,000<10,000

200,000

2,3<6,0001

1 0 , 0 0 0d4.

2.

5. Debris removal.

3.

Transfer of fluids, changing filters,
flushing lines, etc.
Complete decontamination required-not yet started.

6.

1,2
4

tRemaining Efforts:
1. Further decontamination required.

dAt cubicle door.

Remaining
Effortse

Light decontamination required.

Decontamination complete.

0
C

1E -

Table 0.3.

Decontamination Status for Elevation 328 as of September 1,

Initial Levels

LocationaA
B

C

Area Description
Concentrated
Waste Tank
Mix Tank AreaFHB East Corridor

Decontamination Efforts/Status

Surface
Contamnnation

Decontamination complete.
Initial decon complete. Maintenancerequired on leaking components prior
to final decon.
North section decontaminated,south section high dose rate

-

U

1980

Present Levels

Radiation
Level

Surface
Contamination-

3,000<1,0002<10,000

1,2

1,000

2,4

200,000

Radiatin
Level

Remaining
Effortsefrom N2 filters.

aSee Figures 0.1 through 0.3.
bDPM/IO0 cm2.

CmR/hr.

TRemaining Efforts:
1. Further decontamination required.
2. Transfer of fluids, changing filters,
flushing lines; etc.
3. Complete decontamination required-not yet started.

4.

Light decontamination required.

5.

Debris removal.

6.

Decontamination complete.

0
!-

U

Eu

III

APPENDIX P.

J_

I

I

CHEMICAL SYSTEMS FOR DECONTAMINATION OF PRIMARY SYSTEM COMPONENTS

The staff assumes that 60 to 90 percent of the contamination remaining in the primary reactor
coolant system after drain/flush operations will be present as activation and fission productplateout located in the corrosion product film. The remainder will be small amounts of particulate matter not removed by the drain/flush operations.
Films on stainless steel and other highnickel alloys are not easily removed and require either corrosive treatments or some conditioning
step to change the film characteristics.
Films formed on surfaces of primary coolant systems of
nuclear reactors have been investigated, and satisfactory procedures have been developed forremoving these films and decontaminating the surfaces.'
Nuclear reactors can be decontaminated by use of relatively concentrated reagents (5 to 15 wt %)or dilute reagents (1000 wt ppm).
Decontamination with both concentrated and dilute reagents has
proven successful in lowering radiation levels.
The dilute reagent decontamination process isdesigned for relatively frequent decontaminations but does not remove as much contamination as do
the concentrated reagents.
All chemicals used for the TMI-2 reactor coolant system decontamination would be high-purity
reagents (reagent grade) with very low concentrations of Cl-. and F- (ions that can cause stresscorrosion).
The chemical reagents used in decontamination normally are obtained in concentrated
form and require dilution with water.
Large tanks with mixing capability are required to prepare
the solutions.
The TMI-2 reactor bleed tanks or the borated water storage tank could provide
this capability.
P.1

OXALIC-CITRATE-PEROXIDE PROCESSThe solvents formulated to dissolve the films on stainless steel and high nickel alloys, described below, do not dissolve uranium oxide (U0 2 ) particulate matter.
If significant amounts of
U02 particulates remain following the flushing/draining operations, an oxalate-peroxide solvent
application may be required to remove the particulates prior to application of one of the conventional decontamination processes.
In general, oxalate-peroxide solutions for fission productdecontamination from metal surfaces are superior to conventional decontamination solutions andhave low corrosion rates on carbon steel (less than 0.00001 inch/hr).
Of nearly a hundred formulations studied, the one having the best combination of long life, low corrosivity, high solvency
for U02 , decontamination power, safety, and ease of waste disposal was an aqueous solution of
0.4 molar (M) oxalic acid, 0.16 M ammonium citrate, and 0.34 M hydrogen peroxide adjusted to
pH 4.0 with ammonium hydroxide.'This solvent is applied at 85 to 95 0 C for several hours.
P.2

OPG PROCESSThe chemical equation for the OPG (oxalic-peroxide-gluconic) solution is Na2 C2 0 4. 'It consists of
0.025 M H2 C2 0 4 , 0.5 M H2 0 2 , 0.013 M gluconic acid, and 0.045 M sodium gluconate at a pH of 4.5.
It is relatively fast acting, one to four hours at the 80 0 C process temperature, and it is compatible with carbon steel, stainless steel, Inconel, Zn-2 and Al.
Oxalic acid is well known for
its efficacy in removing rust from iron and is so used in cleaning compounds for automobile
cooling systems.
Preparations containing oxalic acid have been studied for the defilming anddecontamination of nuclear reactors along with the simultaneous dissolution of U02 . 2 Thesestudies have proven the solution's effectiveness in the processes by achieving decontamination
factors as high as 1000 on stainless steel.
The process has been effectively applied throughout
the nuclear industry.
The solution was used for fuel particulate dissolution during decontamination of the PRTR reactor.
Several system volumes (one to five) might be needed if fuel particulate dissolution is necessary
in order to achieve the desired decontamination.
The processing of the resulting contaminatedsolution would be similar to that described for the alkaline permanganate processes described
below.

P-1

I

I

P-2
The advantagesof this process are (1) it has been successfully used to dissolve U02 and decontaminate reactors, (2) it accomplishes both function's simultaneously and, (3) high decontamination
factors are achieved.
The disadvantages are (1) large quantities of chemical reagents would be
required, (2) although the process is compatible with reactor materials, some corrosion does
occur, and (3) additional chemical decontamination may be required after fuel particulate dissolution is complete.
P.3

CAN-DECON PROCESSThe CAN-DECON proprietary process* would involve the addition of dilute (0.1 wt %) chemical
reagents to.the liquid in the~reactor coolant system.
The solution of acidic reagents would
attack a portion of the corrosion product layer and release particulates and dissolved material
to the solvent.
The particulate material would- be removed by filtration. Cation resins would
remove the corrosion products from the complex and regenerate the reagent--a process that would
minimize the quantity ofireagent required.
A commercially available reagent, Nutek L-106** (citric-oxalic-EDTA type) has been used in thisprocess at the Douglas Point Reactor. 3 The solvent is recirculated at up to 1500 C for several
hours in a carbon steel system or for up to several days in a stainless steel system.
Corrosion
rates are 0.0001 inch/hr for carbon steel and less than 0.00003 inch/hr for stainless steel.
The
staff expects that there would be no deleterious aftereffects with the process and that decontam4
ination factors of 6 to 8 would be achieved.
The dilute chemical CAN-DECON decontamination technique would require little
additional equipment
beyond that needed for conventional decontamination processes using strong reagents.
Since
CAN-DECON is a one-step process, no draining or flushing of the system would be required during
the decontamintion treatment.
The treatment utilizes a cation resin to strip radionuclides fromthe process chemicals during the decontamination operation.
This effectively regenerates theprocess solution.
When the process was completed, the reagent and remaining dissolved corrosion
products would be removed by mixed-bed resins or a cation bed and a mixed bed in series.
The advantages of this process are (1) it is a one-step process, (2) secondary waste streams areminimized, and (3) the process already has been used in reactor decontamination (Canadian reactors).
Disadvantages are (1) modest decontamination factors, and (2) long reagent contact time.
P.4

ALKALINE PERMANGANATE-CITROX PROCESSThe alkaline permanganate (AP)-citric acid-oxalic acid (Citrox) process has been used successfully for the decontamination of stainless steel and Inconel parts of reactor systems. 3 's
For
TMI, the procedure would consist of two steps:
an AP pretreatment at 105 0 C for 4 hours, followedby rinses, then further cleaning by a solution of organic acids (citrox) at 800 C for 8 hours andmore rinsing.
Heat would be supplied by the pump heat or a heat exchanger.
From 1 to 5 primarysystem volumes of radioactive waste could be created during this process. 6 More than 80 percentof this estimated process liquid volume (-400,000 gallons) could be expected to have low radioactivity levels in a recycle stream.
This large volume/low radioactivity stream would represent
the rinse liquids.
High decontamination factors (up to 1000) have been experienced with AP-citrox treatments.
Anaverage decontamination factor of 10 to 100 could be expected from treatment of the TMI-2 primarysystem by this method.
Evaporation and solidification methods would be used for final disposal of the chemical solutions.
It might be necessary to treat the AP solution to reduce-the permanganate prior to final
treatment.
The rinse water would be treated with ion-exchange resins prior to disposal.
Alkaline permanganate is 10 weight percent sodium hydroxide and 4 weight percent potassium permanganate; citrox is 0.2M oxalic acid, 0.3 M citric acid, and 0.02 M corrosion inhibitors.
About
80,000 kg (88 tons) of chemicals would be required for the chemical decontamination program.
Corrosion rates for 304-stainless steel and Inconel-600 resulting from use of these reagents arevery low (0.0000004 in/hr); 5 however, the presence of sulfate would accelerate the corrosion of*London Nuclear services,

Ltd.,

Niagara Falls, NY.

**Formulated and marketed by Nuclear Technology Corporation, Amston,CT.

I I I I I I I I

I-P-3
Inconel-600 and care would have to be taken to exclude it from the system.
Corrosion rates forcarbon steel and 400 series stainless steel are 0.0001 to 0.0006 in/hr. 5 Each solution is appliedat temperature for about 4 hours.
The advantages of this process are (1) it has been successfully used worldwide to decontaminate
reactors, and (2) high decontamination factors could be expected.
The disadvantages are (1) large
quantities of chemical• reagents would be required, (2) carbon steel and 400-series stainlesssteel would corrode slightly in these decontamination solutions, (3) the AP waste stream is astrong oxidant and might require additional treatment.
(This is normally handled by mixing thewaste AP with the waste acid stream to neutralized each stream).
P.5

ALKALINE PERMANGANATE-AMMONIUM

CITRATE

Alkaline permanganate-ammonium citrate (APAC) would be a two-step process, nearly identical to
the AP-citrox process.
Ammonium citrate concentration would be 0.4 M. Ethylene-diamine-tetraacetic acid (EDTA) complexing agent (0.01 M) would be added to the system to prevent redepositionof certain solubilized fission products.
The APAC treatment was used as part of a multistep process to decontaminate the Plutonium Research
Test Reactor (see Section 1.5), a pressurized water reactor. 5 A modified6 APAC procedure has beenused several times, to decontaminate high-alloyed materials in the field.
Corrosion, application temperatures, and application times are very similar to the AP-citrox
process; however, decontamintion factors achieved with the APAC process are normally 2 to 10
times lower.
The advantages and disadvantages of this system would be similar to the AP-citrox
process.
P.6

DOW CHEMICAL NS-1

The Dow Chemical NS-1 process has been successfully tested and used in decontamination applications. 2
Present planning for the decontamination of Dresden I includes the use of this process. 7 The process is proprietary; therefore, detailed information on its composition and use is
not available.
It is, however, a concentrated process applied at -250'F and 35 psi which resultsin high decontamination factors--lO to 100.
Application time for this solvent is on the order of
two to four days.
Corrosion of Inconel and Type 304 stainless steel is 0.0000004 in/hr.and ofcarbon steel is 0.0002 in/hr. Application of the chemical solution is followed by rising. Water
contamination concentrations and processing methods for this application are expected by thestaff to be similar to those described for the alkaline permanganate alternatives.
About 70 percent of the water volume necessary could be expected to have low levels of radioactivity andrepresents the rinse liquids.
This volume would be a recycle stream and as such would represent
a sizable reduction in the overall liquid inventory required.
The advantages of this process are (1) it has been successfully used to decontaminate reactor
components, and (2) waste volumes generated are less than with the two-step solvents.
The disadvantages are (1)-solvent contact times are long, and (2) corrosion is slightly higher than withthe other processes.
References
1.

J.A. Ayres, "Equipment Decontamination with Special Attention to Solid Treatment,"
Pacific Northwest Laboratories, BNWL-R-90, Richland, WA, June 1971.

2.

J.A. Ayres. "Decontamination of Pressurized Water Reactors," in: "Decontamination of Nuclear
Reactors and Equipment," J.A. Ayres, Ed., The Ronald Press Co., New York, 1970.

3.

P.J. Pettit, et al., "Decontamination of the Douglas Point Reactor by the CAN-DECON Process,"
Materials Performance, pp 34-38, January 1980.

4.

A.B. Meservey, "Peroxide-Inhibited Decontamination Solutions for Carbon Steel and Other
Metals in the Gas-Cooled Reactor Program:
Progress Report, November 1959 - July 1962," Oak
Ridge National Laboratory, ORNL-3308, January 1963.

5.

T.S. Drolet and W.B. Stewart, "Design Considerations for PHWR Decontamintion," Conference on
Decontamination and Decommissioning of Nuclear Facilities, Sun Valley, ID, September 16-20,
1979.

Battelle,

P-4
6.

W.K. Kratzer, "Decontamination of the Hanford N Reactor in Support of Continued Operation,"
UNC Nuclear Industries, Inc., UNI-SA-62, Richland, WA, August 1979.

7.

D.E. Harmer and J.L. White, "Results to Date of the Dresden-1 Chemical Cleaning," Conferenceon Decontamination and Decommissioning of Nuclear Facilities, Sun Valley, ID, September 16-20,
1979.

I I

I

APPENDIX Q.

ONSITE STORAGE FACILITY

To date, two concrete storage modules have been completed and the base of a third has been constructed.
The concrete waste storage facilities are modular structures with each module consisting of 60 storage cells. The modules are built on an as-needed basis and are located in the
Unit 2 desilting basin.
Sufficient space exists in the desilting basin to construct up to six
modules.
The module design resembles a rectangular-shaped concrete cube with dimensions of 57 ft
wide by 91 ft long by 19 ft'high.
The module base is 3 ft thick, and walls are 4 ft thick forrequired shielding (i.e., less than 5 mR/hr from all surfaces).
The storage facilities arelocated in the diked, protected area of the station and this, in addition to their elevation,
protects the structures from the station's design basis flood.
The cells will prevent migration of radioactivity from the liners to the groundwater.
The cells
within each module consist of concrete shielded, galvanized, corrugated-steel cylinders withwelded steel, base plates.
Each cell is 7 ft in diameter by 13 ft high.
The top shielding foreach is a 3-ft-thick rectangular concrete plug.
The plugs are needed to provide shielding andprevent rain from leaking into the cells. The cell interior surfaces are painted with a coatingthat will facilitate decontamination.
The cell base plates are provided with a drain line leading to a sump to collect washdowns or
liner drippage.
The sump holds about 1000 gallons and is equipped with level indication thatalarms on high level.
All liquids collected in the sump are sampled and analyzed for radioactivity and processed as required (for example, through EPICOR I).
Nonradioactive sump water isdischarged to the station drainage system. The sump is designed to meet the seismic criteria ofRegulatory Guide 1.143.
The module is serviced by the same mobile crane used for the interim
storage facility.
The module is capable of housing one liner 6 ft in diameter by 6 ft high percell, or two liners 4 ft in diameter by 4 ft high per cell.
All liner transfers into or out of
the cell are made with a 100-ton mobile crane.
The module is designed to protect the stored
liners from the freeze-thaw cycle, and the sump will be protected from freezing.
The concrete storage facility can be used for storage of other high-specific-activity wastes
which would be handled in a manner similar to that described for the EPICOR II waste.

I-

0-1

I

APPENDIX R.
R.1
R.1.1

PROPOSED ADDITIONS TO TECHNICAL SPECIFICATIONS FOR TMI-2 CLEANUP PROGRAM*

PROGRAM DESIGN OBJECTIVESApplicability

Applies to releases
operation of Unit 2.
R.1.2

I

of radioactive

effluents resulting from the cleanup and decontamination

Objective

To ensure that the cleanup program is designed to meet the ALARA concepts of 10 CFR Parts 20
and 50 and that the program is designed to result in environmental impacts consistent with thoseevaluated in the final PEIS (1981) for Unit 2.
R.1.3

Specification

The releases of radioactive materials in gaseous and liquid effluents from TMI-2 during eachcalendar year shall be limited to the following criteria for offsite individuals:

R.1.4

(a)

The dose or dose commitment from liquid effluents shall be less than or equal to 3 mremto the total body and to less than or equal to. 10 mrem to any organ.

(b)

The air dose due to noble gases in gaseous effluents shall be less than or equal to
10 mrad for gamma radiation and less than. or equal to 20 mrad for beta radiation.

(c)

The dose from radionuclides (other than noble gases) in gaseous effluents shalllimited to less than or equal to 15 mrem to any. organ.

be

Bases

This specification is provided to assure that.the design objectives of Appendix I to 10 CFR Part
50 are not exceeded.and to assure that actual environmental impacts are consistent with those
assessed in'the PEIS.
Requiring that the numerical design objectives of Appendix I to 10 CFR Part 50 are met willassure that the radiation dose received by the public during the cleanup operation is equivalent
to or below that from a normal operating reactor.
These doses are likely to have negligible
health effects to individuals of the population.
The background radiation in the area amounts toabout 116 mrem per year, 36% of which comes from cosmic radiation, 39% from terrestrial radiation,and 24% from internal radiation (mainly K-40 deposited in the body).
On the basis of comparisonof the doses calculated here to those of natural background radiation, it is suggested that thehealth effects over the period from the onset of the accident through the completion of thecleanup operation are non-existent, especially in consideration of the fact that natural background radiation in the U.S. varies from one location to another within a range of about 70 to
310 mrem per year.

*This appendix describes technical specifications of general applicability throughout the cleanup
program.
Additional specific technical specifications may be necessary for particular cleanup
activities and can only be developed in that context.
Thus such additional technical specifications must await specific proposals for cleanup activities from the licensee.

R-1

I

\

I

R-2
R.2

RADIOLOGICAL REPORTING REQUIREMENTS

R.2.1

Applicability

Applies
Unit 2.
R.2.2

to radioactive

effluents resulting from the cleanup and decontamination operation of

Objective

To provide the NRC with dose estimates which are based on actual releases.
R.2.3
(1)

R.2.4

Specification
The following information shall be submitted to the Director of the Regional Office.
This
information shall be submitted on a calendar quarter basis (January-March, April-June,
July-September, and October-December) and shall be submitted no later than 30 days following
the end of each calendar quarter.
(a)

Estimates of the amounts and types of radioactivity that were released to the environment during the quarter and during the calendar year. This shall include estimates of
the total activity of each nuclide and the time rate of release of each nuclide.

(b)

Estimates of populations and maximum individual doses which occurred during the calendar
quarter and during the calendar year shall be provided.
The estimates shall be basedon actual hydrological and meteorological conditions which occurred during the releases.
Calculational methods shall be those of U.S. NRC Regulatory Guides 1.109 (Revison 1,
October 1977), 1.111 (Revision 1, July 1977), 1.112 (Revision O-R, April 1976)
and
1.113 (Revision 1, April 1977).
These calculations shall be based on estimates ofactual population distributions during the releases and shall take into consideration
factors such as boating or fishing recreation.
Bases

The purpose of these specifications
design objectives.

isto assure that the programs generally conform. to their

APPENDIX S.

S.1

CALCULATIONS OF DISCHARGE OF PROCESSED ACCIDENT WATER TO THE ATMOSPHEREINTRODUCTION

This appendix presents the methodology used to consider the natural evaporation alternative
discussed in Section 7.2.3.4.
discrete evaporation,
evaporation rates.

Two different models were used.

Model one,

represents a worst case for offsite doses since it

Model two,

worker exposure since it

referred to as no-wind evaporation,referred to asisbased on maximum

represents a worst case foris based on static conditions above the evaporation pond.

These twomodels bound the releases that could arise from implementing the natural evaporation alternative.
S.2

MODEL ONE - DISCRETE EVAPORATIONIn this case,the average monthly pond surface temperature has been assumed to be equal to theaverage monthly air temperature (dry bulb).
dose rates because it

This is a conservative assumption with respect toyields conservatively high evaporation rates.

Itis also assumed that the

air above the pond is continuously replaced due to wind, so that the HTO concentration in the
air above the pond is essentially zero.

This means no HTO molecules will condense from the air

and reenter the pond as will some H2 0 molecules.
molecule",Thus,

will be higher than the H2 0 evaporation rate,

the net HTO evaporation rate, "per"per molecule".

The effect of the

opposite of this assumption also will be considered.
The evaporation rate of HTO per unit area of the pond is given by':ET = K ((NT/NW)PTo-Y

Where:ET = evaporation

rate of HTO (ft/day)

NT/NW = mole ratio of HTO to H2 0 in the pond (dimensionless)
PTo = saturation vapor pressure of HTO at the temperature of pool surface (mm Hg)
PT = actual vapor pressure of HTO in the bulk atmosphere above the pool surface (mm Hg)
K = a parameter that is constant for a given set of meteorological conditions (ft/day
mm Hg).

1P
S-1

S-2
The evaporation rate of H2 0 per unit area of the pond is given by':-N

EW = K (Pwo - PW)

Where:
EW = evaporation rate of H2 0 (ft/day)
PWo = saturation vapor pressure of H2 0 at the temperature of the pool surface (mm Hg)
PW= actual vapor pressure of H2 0 in the bulk atmosphere above the pool (mm Hg).
Therefore,

ET/EW = ((NT/Nw)

PTo - PT)/(PWo - PW)"

When there is wind, the bulk atmosphere above the pool will continually be replaced by air
containing no HTO vapor. Therefore, it was assumed that PT = 0. It also can be assumed that
PTo = PWo"
With these assumptions,
ET/EW =-(NT/NW)/(1In this analysis,
temperature,

w/Pwo).

-

it will be assumed that the bulk air temperature equals the pool surface

which means that Pw/Pwo = RH (relative humidity).

general during each hour of the day.

Pool surface temperature would be expected to be less than

air temperature during the daytime but greater at night.
rates are computed as monthly averages,

This assumption is not valid in

However,in this analysis,so.the assumption is considered reasonable.

Therefore,
ET = EW (NT/Nw)/(I

RH),

or
E= C-Eý/(1 - RH)
Where:

Ej = evaporation rate of HTO (gal/month)
C = activity (pCi/gal)Eý = evaporation rate of H2 0 (gal/month)
RH = Relative humidity
To incorporate the assumption of wind,

Ew was estimated using the Penman equation 2 :evaporation

L_

S-3
E

=

Pwo (1 - RH)(0.5 - U2 /100)(1.138 x 10-3)

where U2 = wind speed (miles/day) at 2 meters above the surface of the pond. The total evaporation rate EW can then be calculated using the assumed pond area of 60,000 ft 2 .
The parameters substituted in the above equation except PWo were taken from Table S.1.

The

value for PWo was estimated from the monthly temperature and from Reference 4.
Initially a time frame of one month was assumed.
tions.
used:This resulted in gross changes in concentra-

In order to "smooth out" these changes, the following assumptions and methodology were
(1) all the water is presumed to be ponded on July 1; (2) the pond is allowed to evaporate

for two weeks, i.e., losing HTO, which was followed by an influx of one-half the monthly precipitation; (3) from the evaporation loss and precipitation, a new concentration was calculated
at the end of the two weeks and the process repeated for successive time periods.
The results of this approach are presented in Table S.2 for a three-month period.

As shown,

80 percent of the initial HTO inventory is released. Figure S.1 presents these same results
and also includes an extrapolation of the discrete model results. This extrapolation assumes aconstant exponential slope (e-1.0 4 t)*, which means that the HTO concentration in the pond will
be reduced by a factor of 10 about every 2.2 months. At this rate, the HTO concentration in
the pond will approach the natural concentrations in the river (200 to 400 pCi/L) in about 1.3
years. Under natural conditions, concentrations will be reduced asymptotically.
To determine the effect of monthly climatology a similar analysis was conducted based on
ponding the water in January. Figure S.2 shows the results of this case. As shown, it takes
about 6 months to release 80 percent of the HTO and the extrapolated exponential slope (e-0"88t
means it requires about 2.6 months to reduce pond HTO concentrations a factor 10. Under these
conditions,

HTO concentrations approaching those naturally occurring in the river are attained

over about a 21-month period.
A reduction in the initial HTO concentration by filling the pond to 2.5 million gallons increases
At an initial concentration of 0.3 pCi/mL.
the time required to reach background concentrations.
and a pond volume of 2.5 million gallons, HTO concentrations in.the 200 pCi/L to 400 pCi/L range
January ponding would increase this to about
are reached in 36 months with July ponding.
56 months.
S.3

MODEL TWO - NO-WIND EVAPORATIONThis case is principally concerned with possible HTO concentration in the environs of the pond,
which may be above MPCa (MPC in air, 40-hour week) for workers. The assumptions used in theanalysis were:*The "slope" indicates that at two different times, tI and t2,
C /C2

=

exp(-1.04(tl-t2))

S-4
Table S.1.

Mean Monthly Meteorological

Data at Harrisburg Airport

Month

Dry-Bulb
Temperature ('F).

Relative
Humidity.(%)

Wind
Speed (mph)

Precipitation(inches/month)

Jan

30.1

67

8.4

2.57

Feb
Mar
Apr

32.3
41.0
52.8

67
65
60

9.2
9.7
9.3

2.42
3.22
2.98

May

63.1

63

7.8

3.76

Jun

72.0

67

6.9

3.11

Jul
Aug

76.1
73.9

68
72

6.3
6.0

3.70
3.22

Sep

67.0

71

6.2

2.66

Oct

55.8"

67

6.6.

2.57

Nov

43.8

67

7.9

3.19

Dec

32.6

66

8.1

3.07

Total

36.47

Source: "Local Climatological Data, 1977, Harrisburg, Pennsylvania,"
U.S. Dept. of Commerce, National Oceanic and Atmospheric Administration, U.S. Environmental Data Service.

Table S.2.

HTO Releases to Air for July Ponding
Pond HTO
Inventory as
Percent of.
Originala

Incremental
Release (Ci)

Cumulative
Release (Ci)

PondConcentration(PCi/mL)

0

0

0.50

100

July 1-15

730

730

0.39

75

July 15-31

570

1300

0.30

55

Aug 1-15

390

1690

0.23

42

Aug 15-30

310

2000

0.18

31

Sept 1-15

180

2180

0.15

25

Sept 15-30

140

2320

0.12

20

Time Frame
Zero

a2900 Ci of HTO in 1.54 million gallons.

S-5

100,

-I
I0

0

E

1-2
C)

C-)

2-P
C-)
a-)

-4

10

-5,

0

2

Figure S.1.

4

6

14 16
8
10 12
PONDING TIME (months)

18

20

22

HTO Concentration Versus Time for Water Ponded in July.

24

S-6

100

x

0--

-,

DISCRETE E
MODELEXTRAPOLATMODEL RESI

-2

E

Io-

C5s
!a

CC)

I
L~

-4

0

CLU

0

Io-5
INITIAL PONDING JANUARY

0

I

I

I

I

2

4

6

8
10 12
14
16
PONDING TIME(months)

Figure S.2.

I

18

20

22

HTO Concentration Versus Time for Water Ponded in January.

24

S-7
* The atmosphere is static--no wind
* The proportion of HTO molecules to H2 0 molecules is the same in the vapor and liquid
state* No allowance is made for possible dispersion in the local environs of the pond.
Two cases are considered--average monthly meteorological conditions and a realistic extreme.
In either case the concentration of HTO above the pond can be calculated from:

HTO air=

HTO water (d)(RH)

Where:HTO air = concentration in air (pCi/mL)
HTO water = concentration in water (pCi/mL)d = density of 100% saturated water vapor at temperature t (mL/g x 10-6),
Figure S.3,

Reference 4

RH = relative humidity
S.3.1

Case 1--Average Monthly Meteorological

Conditions

From the temperature values in Table S.1 and Figure S.3, the density of 100% saturated water
vapor may be estimated (Table S.3).
above the ponds.
precipitation,

It

It

i.e.,

Substituting in the previous equation gives the HTO activity

should be noted that no allowance was made for possible dilution with
HTO water is constant over time and,is shown in Figure S.4 that without dilution,exceeded during the summer months,
base month,it

thus, represents a worst case.

is reasonable to expect that MPC a will be

under the previously stated assumptions.

Using July as aaddition of 657,000 gallons of water would reduce the HTO concentration to

0.36 pCi/mL in the pond.

This would ensure that MPCa in the pond environs for this month would

not be exceeded.
S.3.2

Case 2--Daily Realistic Extreme

Daily temperatures in the summer months may be expected to rise to 90°F with a relative humidityof 90 percent.

Assuming this to be a realistic extreme leads to a possible concentration in thepond environs of 14.4 x 10-6 pCi/mL,or nearly three times MPCa on site.

In this case,theactivity of the ponded water would have to be about 0.17 pCi/mL so as not to exceed MPCa*

This

would be accomplished with the addition of some 3 x 106 gallons to dilute the water in the worst
case.

S-8

E05
--

e

5o

0

30

I-"
i-.

m 20
00

o)
>-

cn

0
-2

Figure S. 3.

40

60

TEMPERATURE(OF)

Density of 100% Saturated Water Vapor versus Temperature.
Source: C.J. Wiesner, "Hydrometeorology," chapman andHall, Ltd., London, 1970.

Table S.3.

Density of 100% Saturated Water Vapor,
Relative Humidity, and HTO Air
as a Function of Timea

d

RH

Month

(mL/g x 10-6)(%)

HTO Airb(pCi/mL x 10-6)

Jan

5.9

67

2.0

Feb

6.0

67

2.0

Mar

8.0

65

2.6

Apr

10.8

60

3.2

May

14.0

Jun

17.0

63
67

4.4
5.7c

Jul

20.3

Aug

68
72

6 . 9c

18.0

Sep

15.5

71

5 . 5c

Oct

12.0

67

4.0

Nov

8.3

67

2.8

Dec

6.3

66

2.1

6 . 5caAssume HTO water constant at 0.50 pCi/mL.
bMPC is 5 x 10-6 pCi/mL.
aCExceeds
MPGa without dilution of pond water.

S-9

7

6

0
-J

5

E

4
0
C-

3
C:)

2

I

0
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
MONTH

Figure S.4.

Monthly HTO Concentrations above the Pond as Calculated Using Model Two.

S-10
References - Appendix S

1. J.H. Horton, et al., "Tritium Loss from Water Exposed to the Atmosphere," Savannah River
Laboratory, E.I. du Pont de Nemours and Co., Aiken, SC, in: Environmental Science andTechnology, Vol 5, No. 4, April 1971.
2.

C.J. Wiesner,

3.

"Local Climatological Data, 1977, Harrisburg, Pennsylvania," U.S. Dept. of Commerce,
National Oceanic and Atmospheric Administration, U.S. Environmental Data Service.

4.

A. Miller, "Meteorology," Charles E. Merrill Publishing Co.,

5.

J.L. Baldwin,"Hydrometeorology,"

Chapman and Hall,

Ltd.,

London,1970.

Columbus, OH, 1971.

'"Climates of the United States," U.S. Dept. of Commerce,

Atmospheric Administration,

Washington,

DC,

1973.

National Oceanic andU

APPENDIX T.

THE BEHAVIOR OF SORBABLE RADIONUCLIDES IN THE

SUSQUEHANNA RIVER AND CHESAPEAKE BAY

T.1.

BEHAVIOR OF RADIONUCLIDES IN SUSQUEHANNA RIVER

Radionuclides

entering the Susquehanna

the river flow.
concentrated

River at TMI will move in the downstream direction with

Some radionuclides will remain in the dissolved state, while others will becomein suspended and bottom sediments and aquatic organisms.

river will be in the form of tritiated water (HTO
and physicalbehavior of tritiated water istheas compared to normal water, H2 0).

The chemical

basically that of ordinary water with regard tomobility, interaction with suspended particles,
By contrast,

Tritium discharged to theand general dilution.

isotopes Cs-134 and Cs-137 have an appreciablesuspended sediments and to concentrate in aquatic organisms.

tendency to be adsorbed onto

The isotopes Sr-89 and Sr-90 have asmaller tendency to be adsorbed onto sediments and will exist primarily in the dissolved state.
The fate of sorbable radionuclides such as cesium introduced into the Susquehannadepend on a number of physicaland chemical factors.

River will

At steady state, the radionuclides will be

partitioned between the suspended sediment and the water according to the relationship:
6

F
w

10
106 + Kd C

(Ti)

where:
Fw is the fraction of the radionuclide remaining dissolved in the water,
Kd isthe distribution coeffient between sediment and water, mL/g,

C sed is the concentration of suspended sediment,

and

mg/L.

No direct measurements of Kd were available for Susquehanna River sediments,
made based on measurements
River basin.
Study,'

in other East Coast rivers and on the minerology of the Susquehanna

One of the most usefulstudies of radionuclides

in rivers was the Clinch Riverin which the migration of low-level radioactive waste seepage was extensively measured in

a complicated river basin with multiple dams.

It was found that the sorptive properties of thesediment were largely dominated by the clay fraction, and that illite,
accounting for about 60 percent of the clay in the Clinch River,cesium.

but estimates can bea micaceous clay mineral

had the greatest affinity for

An inventory of an approximately 21-mile reach of the Clinch River,release to the backwaterarea at Watts Bar Dam,

T-1

from the point of

indicated that about 21 percent of the cesium

T-2
Only about 0.2 percent of thereleased over a 20-year period remained in the bottom sediments.
released strontium remained on sediments, however, which demonstrates that strontium interaction
with sediment is

not strong.

Measurements of Kd in the clay deposits along of the Clinch River

ranged up to about 88,000 mL/g for cesium in a study by.Carrigan et al. ,2have obtained much lower values in sediments of the Clinch River.

but other investigators

Jenne and Wahlberg 3 reportsediments of a tributary of the Clinch River showed a cesium Kd of between 650 and 1000 mL/g.
Schell et al. 4 reported an average value of 1355 mL/g.
Extensive studies on the behavior of radionuclides in the Hudson River estuary indicate that up
to 90 percent of the cesium near the Indian Point Nuclear
sediment

duringfreshwaterconditions.

Plant was in the form of suspended

Measurements of cesium Kd of the suspended

indicate values of up to 3 x 105 mL/g.

Once again,

illitesediment

is the dominant clay mineral of the

Simpson et al. 5 estimate that about 20 percent of the radiocesium entering the

Hudson River.

'Hudson River accumulates in the bottom sediments (although a portion of that is removed by maintenance dredging).
Eaton et al. 6 state that illite
inference,is one of the dominant clay minerals of the Coastal Plain,of the Susquehanna River.

be 10 percent sand, 50 percent silt,
Suspended sedimentand byMoving sediments in the Susquehanna River are estimated toand 40 percent clay.'loads in the SusquehannaRiver range from 5 to.i500 mg/L..

Typical sedimentloads downstream of Conowingo dam are 10 to 30 mg/L, with no obvious correlation to river flowrate
for flows below 100,000 cfs. 7

Since itis estimated that, in years withno major floods,

two-thirds of the sediment passing Harrisburg

is trapped in the river above Conowingo Dam,half toaveragesediment loads near the TMI plant probably are in the range of 20 to100 mg/L.
Equation (T1)

has been evaluated in Figure T.1 for the range of Kd and sediment load values.

discussed above.

It

isclear that the fraction of sorbable radionuclides associated with sedi-ments can vary over a wide range.

An estimate of the importance of sediment to the transport ofcesium in the river and bay will be discussed later.
Of the sorbed radionuclides attached to the sediment,

part will be trapped behind the downstream

dams and the rest will be transported into the Chesapeake Bay.
behind the dams will depend on the flowrate of the river.
there are no major floods,

The portion that becomes trapped

As previously .noted,

in years where

between half and two-thirds of the sediment transported past Harrisburg

does not pass Conowingo Dam,

which is the last dam before the bay. 7

The phenomenon of sediment

trapping by dams is a result of the reduced velocity and turbulance in the reservoirs behind thedams, which allows the particles to settle *out of suspension.
tiveness

The phenomenon increases in effec-

as the particle size increases.

Most of the sorbed radioactivity will be associatedwith the very fine clay fraction of the suspended sediment.
It is likely, therefore, that the
sediment passing the dams willsorbed radioactivity.

become enriched in the clay fraction which carries most of the.

-

T-3

1.0

1

0.9

3 ---I

3

0.8
•

0.7

.q

0.6

0

0

0.5

.o
Cr
0

.-

0.4

S

0.3

3x104

105

0.2
0.1

0

10

20

30

40

50

60

70

80

90

100

Sediment Concentration, Milligrams/liter

Figure T.1.

Fraction of Radionuclide Remaining in Dissolved State.

During normal years, 50 to
Most sediment transport occurs episodically during flood events.
60 percent of the sediment that does discharge at Conowingo Dam passes during the spring freshet*when flows are high due to snow melt. Between 1966 and 1976, the discharge of sediment from theSusquehanna River was about 50 million metric tons. Of this amount, about 30 million metric tons
was due to Hurricane Agnes in June 1972, and 10 million metric tons was due to Hurricane Eloise
It is estimated that the Agnes flood had a recurrence interval of greaterin September 1975.
8
than 1000 years, and the Eloise flood had an estimated recurrence interval of about 50 years.
For flows greater than 400,000 cubic feet per second, sediments that have deposited behind thedams are apparently eroded and transported into the northern Chesapeake Bay. A flood of this7
Contaminated sediments therefore
magnitude would have a recurrence interval of about six years.

*A "freshet" is a sudden rise in the. level of a stream caused by heavy rains or the rapid
melting of snow or ice.

I1

T-4
would collect to a certain degree behind the Susquehanna dams,

but would not reside there indefi-

nitely since they would be flushed into the Chesapeake 'Bay during major floods.

Although sedi-ments contaminated with radioactivity would be resuspended during such floods,

they would simul-

taneously be diluted by the large quantity of flowing water.
T.2

BEHAVIOR OF RADIONUCLIDES IN CHESAPEAKE BAYRadionuclides

discharged to the Susquehanna River at Three Mile Island will be carried in thedownstream direction toward the Chesapeake Bay.

The Chesapeake Bay (Figure T.2)

which fresh water from the rivers and salt water from the ocean mix.

is an estuary inSalinity varies from prac-

tically zero at the mouths of the rivers up to about 35 parts per thousand in the open ocean.
Substancesthat enter Chesapeake Bay mostly or entirely in the dissolved form eventually will betransported

to the sea from the combined effects of advection by fresh water and dispersion

caused by the astronomical
known volume of the bay,tides and wind wave activity.

V, and the average flowrates of the rivers, q,

flushing time

is

bay;

because of sediments,

areas,

however,

The "flushing time",V/q,based on theis about one year.

The

indicative of the rate at which a dissolved pollutant would be purged from thenonideal mixing, and entrapment in the complicated backwater

small traces of radioactive contamination probably would linger for several years.*

The bulk of the sediments passing into the Chesapeake Bay, probably more than 75 percent, will bedeposited in the upper bay in the region known as the "turbidity maximum". 9

Eaton et al. 6 suggestthat some Susquehanna River-derived sediment would be. deposited as far as the mouth of the Potomac
River.

Direct measurementsof radionuclides released

from the Peach Bottom Nuclear

Plant inConowingo Pond suggest that sediment deposition of cesium is at the maximum at the mouth of theSusquehanna River,tectable beyond.'
during floods,0

has decreased by two orders of magnitude by the Sassafras River, and is undeThe measurements may not have included the periods of major sediment transport

however,which would both dilute and disperse contaminated sediment further into

the bay to levels probably too low to detect.
Of the substances that are significantly adsorbed by sediment,
important because of its long half-life,
nuclear waste.
sediments.

cesium, is the most radiologicallyhigh dose and bioaccumulation factors,

and abundance inCesium behaves as a monovalent cation and primarily undergoes ion exchange with

There

is

strong evidence from other estuaries that cesium is at least partiallydesorbed from contaminated sedimentsin the presence of salt water because of the "common ion

effect" and will reenter the water column.

Cesium-134 and Cs-137 contamination on bottom sedi-ments near the Indian Point Nuclear Plant on the Hudson River estuary disappeared
corresponding to a half-life of about one year."at a rate

The major mechanism identified for the disap-

pearance of cesium appears to be leaching by salt water intruding up the estuary during periods*There is no expectation that radionuclides released from the TMI cleanup would be detectable in
the water, fish, or sediment beyond the site vicinity.
Background levels of nuclear fallout,
previous normal releases from TMI Units 1 and 2, and releases from the Peach Bottom Nuclear
Plant would obscure the very small releases to be expected from TMI.

T-5

Figure T.2.

Chesapeake Bay (from Reference 6).

T-6
of low flow.

Similarly,

Patel

et al.1 2 observed that the apparent loss of Cs-137 in Bombay

Harbor was consistent with an equivalent half-life of about two years.

A certain portion ofcesium that has been sorbed onto sediment probably will not be desorbed in the salt water.
of the cesium will become practically irreversibly
clay minerals,

such as illite,

sorbed into the crystal

Somelattice of certainin fresh water and will not desorb to a great extent in the salt

water.13
Cesium in dissolved form has a much smaller tendency to be sorbed by sediment once in salt water.13
Therefore,cesium entering the brackish portion of the Chesapeake Bay in a dissolved state will

largely remain dissolved.
The radionuclides Sr-89 and Sr-90 would have little

tendency to be adsorbed by suspended sediments

either in the freshwater or saltwater regions of the SusquehannaRiver and Chesapeake Bay andtherefore would be transported predominantly in the dissolved phase.
T.3

ESTIMATES OF EXTENT OF CESIUM INTERACTION WITH SEDIMENT IN SUSQUEHANNA RIVER AND
CHESAPEAKE BAY

Measurements
Cs-134by the State of Maryland," 0

releasedfrom theindicate that the highest sediment concentrations ofPeach Bottom Nuclear Plant were 160 pCi/kg in Conowingo

640 pCi/kg at the mouth of the river.

Pond andA very approximate and conservative estimate of the frac-tion of Cs-134 that has become associated with river sediments can be made by assuming that of
the sediment discharge in the Susquehanna River passing Harrisburg during non-flood years, about
half falls above Conowingo Pond and is Contaminated to a level of 160 pCi/kg.
The remainder isassumed to settle in the upper portion of Chesapeake Bay and is
640 pCi/kg.

Itcontaminatedto a levelofisestimated that between

the years 1966 and 1974, the annual average sediment7
load passing Harrisburg during years with no major floods was about 1.9 million metric tons.
Under the above assumptions,itabout 0.19 Ci of Cs-134 would be associated with the sediment.

Ifis conservatively assumed that all of the Cs-134 on the sediment came from the 1.62 Ci released

at Peach Bottom during the second quarter of 1979,
be associated with sediment,
phase.

then less than 12 percent of the Cs-134 would

and the remainder must have been carried away in the dissolved

The above calculation isconservative because (1)the concentrations of Cs-134 on sedi-ments used were the highest point values reported for Conowingo Pond and the Chesapeake Bay and(2)

the levels probably reflect previous inputs of Cs-134 from the Peach Bottom and the Three

Mile Island Plants.
T.4

CONCLUSIONS

Some of the radionuclides,

particularly cesium,

released from the cleanup operations atTMI will

become associated by the process of sorption with suspended river sediments.

Contaminated sedi-ments may accumulate to an extent in the reservoirs behind York Haven, Safe Harbor,

Holtwood,

Conowingo Dams,

Much of theremainingbut these sediments will be largely flushed during major floods.

andsediment will be carried downstream and settle primarily in the upper Chesapeake Bay.

T-7
A portion of the cesium associated with the sediment will desorb in the presence of salt water
and will

reenter the water column.

Measurements of the concentrations of Cs-134 on sediments ofConowingo Pond and the upper Chesapeake Bay indicated that probably less than 12 percent of theradiocesium released from TMI will ever become assocated with sediment.

The relative importanceof sediments to the radioecology of the Susquehanna River and Chesapeake Bay therefore will be
minor.
IL

References
1.

E.G.

Struxness,

and F.L.
ORNL-4035,
2.

P.H.

P.H.

Carrigan Jr.,pp.

Carrigan,

R.J.

Pickering,

rials of the Clinch River,

4.

5.

Churchhill , K.W.

Cowser,T. Tamura,

R. Forbes,

7.

8.

D.J.

Nelson"Radioactive Materials in Bottom Mate-Part A, Investigation of Radionuclides in Upper Portion of SediLaboratory,

ORNL-3721,

Supplement 2A,

p.

47,

March 1967.

E.A. Jenne and J.S. Wahlberg, "Role of Certain Stream-Sediment Components in Radioion Sorption," U.S. Geological Survey Professional Paper 433-F, 1968, cited in "Critical Review:
Radionuclide

Transport,

Radionuclide

Adsorption/Desorption Mechanisms,"

C.E.

Cowan,

W.R.

Schell; T.H.

Sediment Transport,

and F.L. Thompson,
Sibley,Radionuclides

in Aquatic

NUREG/CR-0803,

p.

H.J.

C.R. Olsen,

Simpson,29,

and Water Quality Mathematical

NUREG/CR-1322,

by Y. Onishi,

p.

8.69,

A. Eaton, V. Grant,

A. Sanchez and J.R.

Clayton Jr.,

Environments,

III," U.S. Nuclear

Part

R.M.

Trier,and S.C. Williams,

forRegulatory Commission,and M.G.

Gross,

October 8,

M.G.

Gross,

Schubel,"Suspended

M. Karweit,

Susquehanna

River

pp.

106-110,

June 1978.

U.S.

Nuclear

Regulatory

W.B.

to Northern

Cronin,J.R.

Chesapeake Bay,

Commission,

1976.

"Chemical Tracers for Particle Transport in the Chesapeake
1980.

Sediment Discharge of the1966 to 1976,""Probability

The Design Basis Flood Condition,"
1977.

Arnold,"Man Made Radionuclides and Sedi-

10:75-83,

dated July 1,

E.M.

February 1980.

Estuarine and Coastal Marine Science,-

Serne,

and"Distribution CoefficientsBay,"

Phenomena

R.J.

Modeling;

August 1980.

mentation in the Hudson River Estuary," Science 194:178-183,
6.

R.J. Morton,

50-70, April 1967.

ment," Oak Ridge National
3.

M.A.

Parker, "Comprehensive Report on Clinch River Study," Oak Ridge National Laboratory,

Estuaries,

of Occurrence

internal

memo,

Vol.

1,

No.

2,

of Design Basis Natural

H. R. Denton to M. W. Libarkin,

T-8
9.

J.R.

Shubel,"Suspended Sediment Discharge of the Susquehanna River at Conowingo Maryland

during 1969,"
10.

R. McLean,
Office,Chesapeake Science 13:53-58, March 1972.

Appendix C to letter from J.

Long to Dr.

U.S. Nuclear Regulatory Commission,

B. Snyder,

dated November 20,

Program Director, TMI Program
1980.

(Includedin comments,

Appendix A).,
11.

S.M.

Jinks and M.E.

"Environmental
J.N.
12.

"Radiocesium Transport in the Hudson River Estuary," Ch.

Toxicity of Aquatic Radionuclides - Models and Mechanisms,".M.W.

Stannard (eds),

B. Patel,

Wrenn,

S. PatelAnn Arbor Science Publishers
and S. Pawar,"Desorption

Estuarine and Coastal Marine Science 7:49-59,
13.

L.M.

Hairr,Ann Arbor,of Radioactivity

MI,

pp.

Miller and

207-228,

1976.

from Nearshore Sediments,",

1978.

"An Investigation of Factors Influence Radiocesium Cycling in Estuarine Sedimentsof the Hudson River," Ph.D.
pp.

Inc.,

11 in:

IV-1 to IV-6,

1974.

thesis, New York University,

School of Engineering and Science,APPENDIX U.

DECOMMISSIONING OF TMI--2

Decommissioning is defined as the preparation of a facility for retirement from active service
and placement of the facility in such a condition that future risk from the facility to public
safety is within acceptable bounds.
The achievement of this rather broad goal, via three possible alternatives, is the subject of this appendix.
Included are a review of appropriate technology, estimations of the radiation dose to workers and to the public, other potential environmental impacts, and estimations of the costs that would result from the decommissioning of TMI-2.
Much of the information presented here is based on earlier conceptual studies of decommissioning
large light-water nuclear power reactors which had operated routinely throughout a normal operating lifetime,'- 3 adapted as appropriate to fit the atypical post-accident circumstances at TMI-2.
Cost estimates are made in terms of mid-1980 dollars, with no predictions made of future interest
or inflation rates.
U.1.

POSTULATED FACILITY STATUS FOR DECOMMISSIONING

Under normal circumstances, decommissioning follows the orderly shutdown of a facility at the endof its planned operating life. The situation at TMI-2 is significantly different from normal,
with the containment building and the auxiliary and fuel handling building severely contaminated,and much of the fuel core damaged.
A major cleanup effort is currently underway.
This cleanup
effort is the principal subject of the programmatic environmental impact statement (PEIS) as
related to decontamination and disposal of radioactive wastes resulting from the March 28, 1979
accident at TMI-2, of which this decommissioning analysis is a small part. As discussed in
Section 2.2.1, there is no significant difference in the initial cleanup activities (initial
decontamination, reactor defueling, and RCS decontamination) whether it is planned to decommission
or to restart the facility. Thus, the current planned cleanup efforts are carried to the point
where either work to restore the plant to service could begin or decommissioning could begin.
This is illustrated by the simplified decision-point diagram shown in Figure U.I.
In terms of
the schedule shown in Figure 1.4, active decommissioning efforts would begin at the conclusionof the fuel debris dissolution and the chemical decontamination of the reactor coolant system andassociated systems.
As a practical matter, the earlier cleanup efforts contribute to the total
decommissioning effort, but for convenience in this analysis, decommissioning is necessarily
treated separately from the initial cleanup.
To'obtain estimates of the total impact, the impacts
from the initial cleanup should be added to the impacts from decommissioning.
The irradiated fuel elements and debris are assumed to be stored in the spent fuel pool in theauxiliary and fuel handling building (AFHB) at the start of decommissioning.
Shipment of theirradiated fuel to an away-from-reactor fuel storage facility (AFR), reprocessing plant, or someother disposal facility is assumed to begin when decommissioning begins and to continue until all
irradiated fuel has been removed from TMI-2.
However, lack of a suitable facility to receive thefuel may result in its retention in the spent fuel pool in the AFHB for an extended period oftime, in effect converting that portion of TMI-2 into an AFR.
For the decommissioning analyses, it is postulated that the washdown of the containment building
and the installation of temporary shielding has resulted in general-area radiation dose rates on
the operating floor (347-ft level) in the 5-10 mR/hr range, and on the lower levels of the containment building in the 30 mR/hr range.
Building surfaces are assumed to have smearable contamination levels in the 3000-4000 dpm per 100 cm2 range, exclusive of hot spots.
U.2

GENERIC DECOMMISSIONING CONSIDERATIONSRegardless of the alternative chosen for the decommissioning of TMI-2, there are certain genericconsiderations involved.
These generic decommissioning considerations include:
Staff organization,
Planning and preparation,
U-1

U-2

TREATMENT OF
CONTAMINATED
WATER ANDDECONTAMINATI ON
OF AFHBRESTART

EAL

DECOMMISSIONINITIALINITIAL

DECONTAMINATION
OF CONTAINMENTBUILDING SURFACESDECONTAMINATION
OF CONTAINMENTBUILDING SURFACESREMOVAL OF WATERREMOVAL OF WATER

AND SLUDGEFROM

AND SLUDGE FROMCONTAINMENT SUMPSCONTAINMENT SUMPSDEFUEL REACIGR AND]
PLACE FUEL IN SPENTFUEL POOL IN AFHB

DEFUEL REACTOR AND
PLACE FUEL IN SPENTFUEL POOL IN AFHBDISSOLUTION OF FUELDEBRIS AND CHEMICALDECONTAMINATION OF
REACTOR COOLANT
SYSTEM

DISSOLUTION OF FUELDEBRIS AND CHEMICALDECONTAMINATION OF
REACTOR COOLANT
SYSTEM

REFURBISH AND*RESTART THE NUCLEAR
STEAM SUPPLY SYSTEM

THE NUCLEAR STEAM
SUPPLY SYSTEMI-.

DECOMMISSIONSHIP THE
SPENT FUEL 4-SPENTOFFSITE*NOT WITHIN THE SCOPE
OF THIS PEI S

Figure U.1.

Simplified Decision-Point Diagram.

RETAIN THE
FUEL
ON S ITE

U-3
Equipment requirements,
Decommissioning methods, andAdditional requirements (e.g.,quality assurance and environmental

surveillance).

In addition, cost estimates for the decommissioning alternatives are developed based on unit cost
factors common to all three decommissioning alternatives.
This section provides a discussion ofthese considerations.
U.2.1

Decommissioning Staff Organization

A decommissioning organization is created within the utility at the start of planning and preparation. A cadre of experienced personnel already exists within onsite post-accident recovery
teams.
Staffing requirements are identified, and critical positions are filled with key engineering and operating personnel from these units.
Additional training needs are identified and thepersonnel are trained as required to fulfill their roles in the organization.
The primary decommissioning activities are postulated to be performed on a two-shift, 5-day-weekbasis.
However, selected support activities (i.e., system decontamination and draining, radwaste
system operation) and security functions are carried out on three shifts, around-the-clock, 7 days
per week.
In addition, the main control room is manned full time for operation of essential
systems and services.
Detailed knowledge of and familiarity with the facility being decommissioned increases theeffectiveness of the decommissioning staff.
This is particularly true for TMI-2 because of thespecial circumstances involved.
Consequently, for TMI-2 decommissioning, positions are assumed
to be filled, whenever possible, with personnel involved in the cleanup operations to provide
continuity, capitalize on experience gained during cleanup, and minimize training requirements.
Any additional training required to perform decommissioning tasks would be provided, with special
emphasis given to the use of new and unique equipment and procedures.
Specialty contractors and consultants are postulated to be hired as needed to assist in areas
outside the licensee's expertise or capability.
The needs for such specialties are identified
during the planning and preparation phase preceding the actual decommissioning, and contractual
agreements are concluded as early as possible to ensure the uninterrupted completion of thedecommissioning project.
The specialty contractors anticipated to be required for the decommissioning alternatives considered are shown in Table U.1.
U.2.2

Planning and Preparation

In planning and preparing for decommissioning, data must be gathered and analyzed, detailed work
plans and procedures must be developed, and-regulatory requirements must be satisfied.
These
considerations are discussed in the following sections.

Table U.1.

Specialty
Contractor

Specialty Contractors for Decommissioning
Decommissioning Alternativea
Function

Explosive specialists

Breaking up biological shield

Hauling contractors

Transport of packaged radioactive
materials to disposal site

Temporary radwaste
handling & solid•fication support

Radwaste handling and final
cleanup after inplant radwaste
systems are decontaminated anddeactivated

DECON

SAFSTOR

ENTOMB

X

X

X
X

X

aX denotes contractor applicable to decommissioning alternative.
bAssumed to be available onsite because of cleanup operations preceding decommissioning.

XU-4
U.2.2.1

Data Gathering and Analysis

A large body of data is gathered and analyzed during the planning and preparation phase fordecommissioning.
These datahelp fulfill the regulatory requirements discussed in
Section U.2.2.3, particularly the inventory of radioactive materials and the various safety
analyses.
In addition, they provide the bases for planning decommissioning tasks and selecting
appropriate methods and equipment.
Included in this activity is a comprehensive survey of radiation dose rates and contaminationlevels within the facility. This survey, taken after chemical decontamination of the RCS, provides
information for determining additional decontamination and temporary shielding requirements.
Italso provides data on radiation dose rates likely to be encountered during the various decommissioning tasks.
U.2.2,.2

Development of Detailed Work Plans and Procedures

Detailed work plans and procedures are developed based on information gathered during data gather-.
ing and resultant analyses and provided to the NRC with the license amendment/decommissioning
order request.
These detailed plans and procedures contain all the information required toactually carry out the decommissioning tasks.
They address the following items:
Decommissioning methods,
Schedules and sequences of events,
Radioactive waste management,
Contamination control,
Radiological and industrial safety, andEquipment requirements.
Quality assurance (QA), security, and environmental constraints are also considered.
The approvedplans and procedures cover all aspects of the decommissioning project.
U.2.2.3)Regulatory Requirements

The licensee must comply with the applicable regulatory requirements and other constraints as
discussed'in Section 1.6. The current status of such requirements should be reviewed prior to
the start of actual decommissioning operations.
The major requirement is anticipated to be thenecessary documentation (similar to that discussed in Appendix R) for any additional amendments
to the facility nuclear license to prepare for the continuing care period.
In requesting amendments, the licensee must provide:A description of the current facility status,
A current inventory of the onsite radioactive materials,
A description of the proposed decommissioning activities, including sequence, schedule,.
and estimates of worker radiation exposure,A description of the proposed measures to minimize radioactive releases,,
Any additional changes to the technical specifications, andSafety analyses of both the proposed activities and the specification changes.
This information becomes the decommissioning plan.
In addition to the aforementioned documentation, the licensee must submit an environmental reportýas well as security and safeguards plans.
Updated information concerning the financial qualification of the licensee may also be required.
The following information would also be required:A description of the ultimate facility status,
A description of future decommissioning activities, if any (including radioactive material
disposal and site decontamination) and the associated environmental and safety precautions,
Safety and environmental impact analyses of future decommissioning activities, if any., andany resultant releases, andSafety and environmental

impact analyses of the plant in its ultimate status.

I.

U-5

U.2.3

Equipment Requirements

Equipment requirements for decommissioning fall into two general categories:
Inplant systems and services essential to the decommissioning effort, andSpecial tools and equipment.required to carry out the decommissioning tasks.
The requirements in each of these categories are described below.
U.2.3.1

Essential Systems and Services

All or parts of certain facility systems and services must remain in place and in service until
all radioactive material is either removed or secured in place, to prevent the release of significant quantities of radionuclides (or other hazardous materials) to the environment.
Some systems
and services are required for cleanup and disassembly activities.
Other systems provide personnel
health and safety protection.
The essential systems and services are listed in Table U.2, together
with the justification for retaining each.

Table U.2.

Essential Systems and Services for Decommissioning

Justification

System or Service
Electrical PowerOperation of electrical equipment, including HVAC,
lighting, and radiation monitoring

HVAC Systems

Ventilation and radioactive contamination confinement

Water Supply (service anddomestic systems)

Decontamination,
water

Fire Protection System

Health and safety

Compressed Air Systems(control and service)

Operation of pneumatic controls and tools; personnel
fresh air supply

Communications Systems

Facilitate and coordinate decommissioning activities

Radiation Monitoring Systems

Personnel safety considerations

Radwaste Systems

Treatment of radioactive liquids and solids

Spent Fuel Cooling and Cleanup
SystemCleanup and cooling of water in spent fuel storage pool
while spent fuel is there, and during defueling andreactor vessel/internals removal

Closed Cooling Water Systems

Secondary cooling of other systems

Chemical Feed System

Radwaste handling and water demineralization

Fuel Oil System

Auxiliary power

Security Systems

Public safety and plant protection considerations.

cleanup,fire protection, and potableL__

As areas within the facility are readied for demolition or secured for storage, the essential
systems and services in these areas are deactivated and, if contaminated, removed as required.
Continuous service to the remaining work areas is maintained as long as necessary.
For decommissioning by SAFSTOR or ENTOMB,
continuing care period.
These include:
Electrical power,
Radiation monitoring systems, andSecurity systems.

certain systems and services are required during theU-6
U.2.3.2

Special Tools and Equipment

Any special equipment required to complete the decommissioning project at TMI-2 is identified
during planning and preparation.
Designs and specifications are prepared for each item required.
When the item is procured, it is inspected to verify that it meets specifications and complies
with applicable QA and safety requirements.
It is then tested to ensure that it performs as
required.
The testing also serves to train personnel in the use of the equipment and provide
pertinent data on its operation.
The requirements for special tools and equipment needed to decommission TMI-2 by any of the threealternatives are shown in Table U.3, together with the functions of each item.
Many of the tools
and equipment needed for decommissioning are not part of the plant's normal operating complement.
However, as noted in the table, many of the items are assumed to be available at TMI-2 as aresult of the cleanup operations preceding decommissioning.

Table U.3. Special Tools and Equipment for Decommissioning

Item

Number Required for:DECON
SAFSTOR
ENTOMB

Major Function

Underwater Manipulatora

1

0

0

Positioning and movementof underwater cutting
devices

Underwater Plasma-Arc Torcha

2

0

1

Underwater Oxyacetylene
Torcha201Sectioning reactor vessel
and internals, steam
generators, tanks, andcutting piping, equipment,

Arc Saw

1

0

1

Portable Plasma-Arc TorchPortable Oxyacetylene

4
2

2
.2

4
2

Guillotine Pipe Saw

10

2

10

Cutting piping

Power-Operated Reciprocating
Hacksaw10

2

10

Sectioning piping and equipment

Closed-Circuit, HighResolution TV Systemsa

2

2

2

Observation of remote or.
underwater operations

Underwater Lights andPeriscopesa

ARb

AR

AR

Illuminating and observing
underwater operations

Underwater Tools (e.g.,
Impact Wrenches, Bolt
Cutters, Tongs)a

AR

AR

AR

Underwater disassembly,
handling, and packaging
operations

Submersible Pump with
Disposable Filtera
High-Pressure Water Jeta

5

2

5

Rapid cleanup and drainingof pool water

2

2

2

Surface decontamination

Scaffolding

AR

AR

AR

Safe access to heights

Safety Nets

AR

AR

AR

Protect personnel working
on elevated equipment andstructures

Shielded Vehicle with
Manipulator Arms andInterchangeable Tools

1

1

For remote operations inareas with high-radiationdose rates

and structural members;
welding

Torch

U.

U-7

Table U.3.

(Continued)

Number Required for:DECON

SAFSTOR

ENTOMB55

5

Decontamination of liquidand solid radwaste equipment

4

4

4

Decontamination of drain
systems

Power-Operated Mobile Manlift

9

3

9

Safe access to heights

10-Ton Mobile Hydraulic Crane

3

0

3

Removal and packaging
of contaminated piping andequipment

10-Ton Forklift

6

I

6

Handling materials and loading
trucksRigging Materials (e.g.
Chokers, Grapples,
Winches)

AR

AR

A•R

Handling of piping and equipment

Concrete Drill with HEPAFiltered Dust Collection
System4

1

4

Drilling holes in concretefor blasting or surface spalling

Concrete Surface Spaller

4

1

4

Removal of contaminatedconcrete surfaces

Front-End Loader (LightDuty)

3

1

3

Cleanup and packaging
tasks

Vacuum Cl~aner (HEPAFiltered)

3

3

3

Cleanup tasks

Portable Xentilation
Enclosure

10

3

1.0

Contamination Control

Filtered-Exhaust Fan Unit

4

4

Contamination control

Supplied-Air Plastic Suit

250

100

25 50

Polyurethane Foam Generator

2

2

2

Contamination control
during HVAC work

Paint Sprayera

0

4

0

Immobilization ofcontamination

Item
Mobile Chemical Decontamination Unit
Mobile Chemical Mixing
and Heating Unit

Major Function

Personnel respiratory
and body-surface brotection from radioactive
contaminantsaAssumed to be available onsite because of cleanup operations preceding decommissioning.
bAR - As Required.

U-8
U.2.4

Decommissioning Methods

The methods and associated equipment used to accomplish the various activities involved in decommissioning a nuclear facility such as TMI-2 fall into four major categories:• Decontamination,
Equipment disassembly,
Radioactive waste packaging and shipping, andContamination control.
Each of these methods is required, in varying degrees, in all of the decommissioning alternatives.
These methods are discussed below.
U.2.4.1

Decontamination

Three basic methods can be used to remove radioactive materials from contaminated surfaces:(1) dissolution of the surface film containing the radionuclides, (2) physical cleaning of thesurface, and (3).physical removal of the contaminated structural material.
The first two methods
are discussed at some length elsewhere in this PEIS (Chapters 5 and 6) and are not consideredfurther here.
Therefore, only physical removal of contaminated structural material (the third
method) is described here.. During facility decontamination, removal of both metal and concretesurfaces may be required.
However, the techniques for metal-surface removal are the same as
those for equipment disassembly, discussed in the next section. The.present di'scussion is thus
limited to concrete removal.
Some concrete in nuclear facilities such as TMI-2 is contaminated below the surface and cannot be
decontaminated to release levels by physical surface cleaning alone.
In addition, some of theconcrete and structural steel in the biological shield surrounding the reactor vessel is activatedas a result of neutron bombardment.
In both instances, the structural materials must be physically removed and disposed of during decommissioning.
Several criteria must be considered when selecting a material-removal method for a particularlocation in the plant.
The method chosen should minimize personnel radiation exposure and airborne contamination dispersion.
In addition, the size and weight of removed materials must
facilitate packaging and shipping for offsite disposal.
The major methods available for concrete removal are:Blasting,
Core boring and hydraulic spalling,
Flame cutting, andThermic lance cutting.
Of particular interest are the blasting techniques for bulk removal of concrete and the spalling
techniques for localized removal of concrete surfaces.
Flame cutting-and thermic lance cutting
are both of less interest, primarily because of the copious quantities of toxic gases and/or
smoke produced.
Bulk Concrete Removal
A very effective way to remove and segment the activated concrete in the biological shield iswith explosives. 4 Because the shield's interior can be easily enclosed within ventilationconfinement envelopes, dust and airborne contamination can be effectively controlled.
Placementof blasting mats over the affected region prevents flying debris from penetrating the confinement
envelopes.
Fog sprays of water, typically used from 1 minute before to about 15 minutes after
blasting, help settle dust from blasting.
Although blasting sequences are designed to minimize
airpressure surges, the ventilation enclosures must be designed to withstand those pressure
surges that do occur.
Similarly, attention must be given to the building ventilation system toprevent surge damage to filters, with monitoring of the system to verify its continued integrity.
After blasting, the area is inspected and surveyed to verify that all contamination is removed
and that all explosives have detonated.
The area may then be protected (by painting or by heavy
fire-resistant plastic or canvas) to prevent recontamination during subsequent blasts.
The
procedure for explosive decontamination of concrete is described in Section F.1.3 of Reference I
and in Section G.1.3 of Reference 3.
Concrete Surface Removal
A number of techniques can be used to remove contaminated concrete surfaces in nuclear facilities
such as TMI2.
A comparison of the major techniques is presented in Table U.4. 5

-

U-9

Table U.4.

Technique
Sandblasting

Jack hammer
Pneumatic or
Hydraulicimpactor
Concretespallerwith airdrill
to makeholesComparison of Major Concrete Surface Removal Techniques

Limitation
Contamination embedded
in pores not effectively removed
Awkward to use on walls
Limited to large accessible facilities
Awkward to use on
irregular surfaces
or in cramped
quarters

Type of Rubble Produced

Size of
Air Filtration
System Required

Relative
Removal Speed

Small particles

Large

Slow

Medium-size pieces andsmall particles
Medium-size pieces andsmall particles

MediumMedium Fast

Medium

Fast

Small

Medium Fast

Medium-size pieces andsmall particles

Sandblasting, where the surface is mechanically eroded away, removes only a minimal surface
thickness and produces large quantities of small, contaminated particles. Sandblasting primarily
removes paint and a little of the concrete surface.
It does not effectively remove contaminationfrom the pores in the concrete or from expansion joints. 6 A large exhaust and air filtration
system is needed with this method to control contaminated dust. This technique is relatively
slow if the contamination penetrates beyond a thin surface layer (see Section 5.2.3.1).
Two surface removal methods usedmore extensively than the rest are jack hammers and impactors.
Jack hammers, powered by compressed air, are readily available and are easily operated by one 6
man. They are used to chip off the surface material deep enough to remove the contamination.
Because they are difficult to position on walls and ceilings, jack hammers are used primarily on
floors. Impactors (or hoe rams), similar in operation to jack hammers but much larger, have beenused successfully in several decontamination projects. 5 ' 6 An impactor, powered either pneumatically or hydraulically, uses a-pick chisel point that is driven into the concrete surface
with high-energy impacts several times per second. A medium-size air filtration system is necessary to control the dust produced by both of these surface removal methods.
The last technique, use of a concrete spaller, permits localized concrete removal to depths of 2
to 3 inches with no explosions and very little dust. (The principal source of dust is the drilling of the hole into which the splitting tool is inserted.)
A dust shield with a vacuum attachment
minimizes the spread of contaminated dust and can be used to collect all but the largest piecesof rubble. The spaller is operated by inserting the expanding bit into a predrilled hole andactivating the device hydraulically, causing the concrete surrounding the bit to be spalled off.
The spaller is small, lightweight, and fully portable, and can be readily adapted to remote
operation.
For rapid removal of large surface areas, a number of the devices can be ganged
together with a corresponding set of concrete drills and operated as a unit. Because the spacing
between and the pattern of the holes are important parameters in the effectiveness of this technique, arrangement of the concrete drills and the splitting tools into a fixed-geometry array
would ensure a relatively uniform removal pattern. Combining these ganged units with a vacuumtransfer system for rubble removal would result in a fast and dust-free concrete removal method,
one ideally suited to decommissioning facilities such as TMI-2. (See Section G.1.3.2 of Reference 3 for further discussion of concrete surface removal.)
U.2.4.2

Equipment Disassembly

Decommissioning of TMI-2 would require the disassembly and removal of the various contaminatedequipment systems. The equipment must be segmented into pieces small enough to facilitate either

U-10
onsite entombment or packaging for offsite shipment and disposal,
alternative selected.

depending on the decommissioning

Underwater Manipulator
The underwater sectioning'of the neutron-activated reactor vessel and vessel internals requires amanipulator to handle the cutting equipment and other underwater tools involved.
The equipment
must be operable under 30 to 50 feet of water, in intense radiation fields.
It is assumed thatthe existing fuel-handling bridge crane with its fuel-element handling boom can be adapted tothis task, as postulated for the removal of the RPV head and internals and the core examinationand defueli'ng (Sections 6.2, 6.3 and 6.4).
It iIsalso assumed that,.after modification for thecleanup tasks, no significant additional'modification will be required to meet the needs fordecommissioning.
Cutting Methods and Equipment
The principal.equipment anticipated to be used for cutting activated and/or contaminated items
are the oxyacetylene torch, the plasma-arc torch, and the arc saw.
This equipment can be usedeither under water or in air.
In addition, linear-shaped explosive charges may be used in special
cutting applications.
The oxyacetylene torch *isa relatively common device and, therefore, is
not discussed here; further information is available in Reference 7.
The other items are describedbriefly below.
(More detailed information is presented in Appendix E of Reference 1 and Appendix Gof Reference 3.)
Plasma-arc cutting employs an extremely. high-temperature, high-velocity, ionized-gas arc thatmelts and continuously removes metal in. the work piece to produce a high-quality, saw-like cut.
The process can be used to cut any metal.
If inert gases are used, the cutting is dependent on
thermal energy alone, but increasedcutting speeds can be achieved using oxygen-bearing gases
when cutting materials such as mild steel or cast iron, because the chemical energy resulting.
from reaction of the oxygen with the base material is added to the arc heat.
The electricalcircuit is similar to that used for tungsten-arc welding.
The plasma-arc cutting process can be used in air or under water.
It is especially adap'table toautomation and is thus useful when highly radioactive material is to be cut (e.g.., the pressure 4 6
vessels of the Elk River Reactor in Minnesota and the Sodium Reactor Experiment *inCalifornia). 'As it is not necessary to start the cut at the edge of the plate, the plasma-arc torch is particularly adaptable to cutting holes in large plates and.vessels.
It is'also well adapted togouging applications, including pad washing and scarfing.
However, because of the short torch
standoff distance, plasma-arc cutting is not suitable for some applications, particularly intight spaces; air carbon-arc cutting can be used for such work.
Plasma-arc cutting is preferred
where it is possible.
The arc saw, a state-of-the-art metal-cutting device, is currently being developed for contaminated-equipment segmentation, with initial development and demonstration work already completed. 8
The device uses a charged, rotating blade to provide the cutting'arc.
The blade rotation helps.
to sweep removed materials from the kerf. Cutting. can be accomplished remotely, either in air orunder water, with automatic positioning and .tracking of the saw blade during cutting operations.
All equipment except the blade is commercially available, but modifications are necessary.
Blades can be made in any well-equipped machine shop, and can be, scaled to match the cutting
requirements of the particular job.
A major advantage of the arc-saw over other saws is that if, because of position change or vibration, a portion of the work piece falls against or pinches the blade, the point of contact sparkerodes away because the'"electrical leading edge" of the blade is transferred to the point ofcontact.
This reduces the potential for binding of the blade.
Consequently, the arc saw can cut
through a variety of materials, shapes, and loose components that would be difficult to cut withconventional saws.
The use of self-contained, linear-shaped explosive charges is an economical and expedient methodof reducing the size of equipment and piping to allow further processing or packaging for disposal.
This method minimizes personnel radiation exposure and is particularly advantageous in areas withhigh-radiation levels.
Linear-shaped charges have been used extensively in the last 15 to 25
years. 9 '' 0 Recently, such methods have been used to segment and remove neutronactivated components and contaminated systems (e.g., fuel-pool liners and piping) that are not amenable toconventional removal techniques. 6 '11

I

U-11
A linear-shaped charge consists of an inverted-V-shaped tubular casing filled with an explosive.
The principle behind use of the linear-shaped charge is that, as the detonation wave collapses
the inverted V, the casing material becomes a jet of extremely hot metal particles traveling atvery high velocity.
These particles then tear through the material to be cut. The melting andsubsequent fusing of the casing material with the base material being cut, together with theragged edges of the finished cut, can make electropolishing of those edges very difficult. 1 2Therefore, in-situ decontamination (either chemical or mechanical) prior to explosive cutting is
recommended to minimize unnecessary waste of strategic materials.
Clamp-on charges, available
commercially, eliminate many problems in placement, handling, and detonating.
The number ofcharges that can be detonated at one time is limited only by the blast effect on nearby equipment.
Shock-wave and fragment damage can be reduced appreciably by placing blast curtains orother barriers in the vicinity of the detonation to disrupt the shock wave and intercept the
fragments.
U.2.4.3

Radioactive Waste Packaging and Shipping

The decommissioning of TMI-2 by any of the three alternatives considered would produce significant quantities of radioactive wastes requiring proper packaging and shipping to an authorized
disposal site. These radioactive wastes resulting from decommissioning can be classified asfollows:
Combustible or noncombustible,
Activated or contaminated, and
Wet or dry.
The bulk of the decommissioning wastes from TMI-2 would be dry, noncombustible, and either activated or contaminated.
They include the activated reactor vessel and internals, the activatedand contaminated concrete from the biological shield, contaminated concrete from walls and floors,and contaminated piping and equipment.
The contact radiation dose rates from these materials
vary from a few mrad/hr to thousands of R/hr.
Different types of packaging and shielding are
required, depending on the radiation levels involved.
Section 8 of this PEIS describes radioactive waste packaging and shipping for the TM1-2 cleanup
operations preceding decommissioning.
Most of the types of decommissioning wastes are thoroughly
covered in Section 8 and, therefore, they are not discussed further here.
The following discussion covers the remaining packaging and shipping requirements for decommissioning.
The specificquantities of the various waste types produced for the three decommissioning alternatives are
given later, in the sections of this appendix that detail the alternatives.
Disposable steel cask liners are used for packaging, shipping, and burying the bulk of the activated materials from the reactor vessel, the vessel internals, and the biological shield.
Specially constructed steel boxes are used where size and radiation exposure considerations makepackaging in cask liners unfeasible.
In some cases, lead shielding must be added to the packages
to reduce the surface dose rates of the containers to acceptable limits.
In other cases, lessactivated component pieces are used to surround the more-activated pieces to provide the required
shielding without sacrificing part of the container volume.
Where external contamination levels allow, certain equipment items (e.g., heat exchangers andsmall tanks) will be packaged by capping the piping connections with welded metal covers andusing the items' outer shells as the containers.
Larger items, such as the steam generators, may
be cut into sections, after which each section is capped and handled as its own container.
All disposal shipments are assUmed to be made by exclusive-use trucks, in accordance with theregulations and considerations described in Section 9.
A formal accident control and recovery
plan is assumed to be developed prior to the first.radioactive shipment of decommissioning waste.
The plan is to provide for rapid and orderly utilization of utility, carrier, state, and municipal
emergency personnel, as well as NRC radiological assistance teams, as required in the event thatany transportation accident occurs.
Procedures for control of contamination, radiation exposure,bodily injury, and property damage are included in the recovery plan.
Also included are proceduresfor salvage and recovery of the radioactive shipment.
U.2.4.4

Contamination Control

Many decommissioning activities, particularly the cutting operations required for equipment
disassembly, have the potential for generating significant amounts of airborne radioactive

U-12
contamination.
In addition, decommissioning involves operations in areas with smearable radioactive contamination; the movement of personnel, equipment, •and materials in these areas canresult in the further spread of radioactive contamination.
To'prevent significant radioactive
releases to the environment and to minimize the personnel hazard and the potential for widespreadcontamination of work areas, contamination control is required.
Radioactive contamination control can be divided into three basic approaches:
Local mitigation of contamination sources,
Collection of contamination, andIsolation of contaminated areas.
These approaches are discussed below.

(See Appendix G of Reference 3 for further information.)

Local Mitigation of Contaminated Sources
Mechanical or physical measures can be used to limit the spread of radioactive contamination.
Two methods that have been successfully used are (1) water sprays to reduce airborne dust dispersion.and (2) painting of contaminated surfaces to prevent smearing.
The wetting of dust with water or other liquids is one of the oldest methods of contamination
control and.can be very effective if properly used. 'Water sprays are widely used to control
fugitive dust emissions from construction sites, and the spraying of water containing detergent(as a wetting agent) has been used in the nuclear industry to reduce dust concentrations in
air.' 3 Water sprays can be used in combination with other contamination control techniques, andare commonly used for dusty operations such as concrete removal. 6
Strippable coatings can be used to seal porous surfaces (e.g., concrete) to prevent penetrationof contamination.
Paint can also be used to seal smearable contamination already present on
surfaces to prevent subsequent contamination spread. 6 Painting is especially useful in hightraffic areas, where smearable contamination is likely to be picked up and spread around on shoecovers and equipment wheels.
(See Section 5.1.3.1)
Collection of Contamination
Collection of radioactive contamination before it can be dispersed (preferably as it is generated) reduces the need for cleanup subsequent to decommissioning activities, particularly those
activities that generate significant airborne contamination. Various collection methods can beused, with the use of vacuum collection and portable ventilation systems being the most common.
Contaminated materials can be collected as they are generated using vacuum systems. A dust
shield with a vacuum attachment can be installed on the tool (e.g., concrete spaller or scrubber)being used. 5 ' 6 As the contaminated dust is generated, .it is drawn into the vacuum system anddeposited in a collection drum.
The outlet air is filtered (with roughing and HEPA filters) toprevent the collected contamination from being expelled. Various designs for vacuumcollection
systems are possible, depending on the required operating characteristics. A number of systems
suitable for decommissioning work with little or no modification are available commercially.
Portable ventilation systems can be used to confine and collect airborne particulates generated
during decommissioning operations., 6 ,General design information concerning such systems is discussed at length in Reference 14.
Two portable ventilation systems, a work enclosure and a fume
exhauster, are described here.
A portable ventilation enclosure is simply a portable "room" with a self-contained ventilation
system that can provide ventilation control at various work locations during decommissioning.
The enclosure unit may take whatever shape best performs the required function at a particularlocation. A simple, rectangular open-faced box will suffice for many applications. Roughing
filters are installed at both the inlet and the outlet of the enclosure unit, and a flexible duct
couples the enclosure to the cart-mounted ventilation system that consists of a large squirrelcage blower drawing through a high-efficiency particulate air (HEPA) filter preceded by a glassfiber roughing filter, all mounted on a wheeled cart. Radiation detection devices are used tomonitor the buildup of radioactive material on the filters. A differential pressure gauge isinstalled across the HEPA filter to monitor the increasing pressure drop as particulates build up
on the filter. Filters are changed when either the dose rate from the collected radioactive
particles or the differential pressure across the HEPA filter reaches a predetermined level.

U-13
Another type of portable filtered ventilation system, a fume exhauster, has an electrostatic
precipitator coupled with a roughing filter, HEPA filter, air-handling motor, squirrel-cageblower, and one or two free-standing intake ducts.
The fume exhauster is used to collect radioactive and nonradioactive particulates at the point of generation.
This high-volume ventilation
system captures all types of particulate matter with efficiences of greater than 97% for theelectrostatic unit and at least 99.95% for the HEPA filter. The advantages of this unit are its
portability, ability to handle large volumes of particulate-laden air, and generation of relatively
small amounts of solid wastes (HEPA filters).
Buildup of radioactive materials on the precipitator and filters is monitored as described above.
The electrostatic precipitator is flushed
and the filters are changed when either the dose rate from collected radioactive particles or thedifferential pressure across the HEPA filter reaches a predetermined level.
Isolation of Contaminated Areas
One method of controlling contamination is the use of barriers to isolate contaminated areas fromthose with lesser or no contamination.
Isolation is an important tool during continuing care aswell as during active decommissioning.
One type of barrier commonly used in the nuclear industry to isolate contaminated areas is a'greenhouse."
A greenhouse is constructed by covering a framework, usually steel scaffolding or
fire-resistant wood frame, with fire-resistant plastic sheeting and sealing all joints.
Overlapping flaps of plastic are generally used for the door. The greenhouse is connected either tothe plant ventilation system or to a portable system to prevent outward leakage of contamination
by drawing a slight vacuum on the greenhouse. 5 Greenhouses can be semi-permanent, portablestruc-tures that can be moved from one location to another as needed, but are more often temporaryconfinement structures that are dismantled and discarded after each job.
In many cases, construction of a complete greenhouse is unnecessary.
A simple plastic curtain partitioning off one
section of a room may be all that is required to isolate a contaminated area. The type anddegree of isolation required depends on the equipment or structures involved, the associatedlevel and mixture of radioactive contamination, and the decommissioning operation being performed.
Prior to the continuing care period for SAFSTOR or ENTOMB, portions of the facility containing
significant amounts of radioactive contamination that are not removed during active decommissioning must be isolated from the remainder of the facility.
Potential pathways for the migrationof contamination from these areas are blocked by the installation of physical barriers.
Besides
acting as contamination control barriers, the barriers are designed to discourage unauthorized
personnel entry into contaminated areas, so structurally substantial barriers are used.
Piping,ventilation ductwork, equipment penetrations, and doors and hatches are sealed as necessary.
Pressure-equalization lines are then installed between the isolated interior spaces and theoutside environment to prevent pressure differentials (due to temperature or atmospheric pressurechanges) from developing.
The lines are equipped with replaceable HEPA filters to prevent contamination from being entrained in the air flow out of the buildings.
U.2.5

Additional Requirements

Most decommissioning requirements relate directly to the removal or stabilization of onsite
radionuclides.
However, there are additional requirements that serve to ensure the timely,
effective, and safe completion of the work. The major additional requirements, which are
discussed here, are quality assurance and environmental surveillance.
U.2.5.1

Quality Assurance

A complex project such as the TMI-2 decommissioning requires QA planning from the earliest stages.
As each detailed decommissioning procedure is developed, the QA portions are included.
Current
regulations and guides that could apply to decommissioning are discussed in Section F.4 ofReference 1 and Chapter 5 of Reference 3.
U.2.5.2

Environmental

Surveillance

Environmental surveillance is of concern during the decommissioning of any nuclear facility andparticularly during the decommissioning of a facility such as TMI-2 where the decommissioning
process may be complicated by unusual and unforeseen difficulties.
The following objectives areU-14
relevent to the environmental surveillance for the decommissioning project:
Detection of sudden changes and evaluation of long-term trends of (radionuclide) concentrations in the environment, with the intent of detecting failure to adequately control
releases and then to initiate appropriate actions;
Assessment of the actual or potential exposure of people to radioactive materials or radiation
present in their environment, or estimation of the probable upper limits of such exposure;
Determination of the fate of contaminants released to the environment,
detecting previously unconsidered mechanisms of exposure; andwith the intent of

Demonstration of compliance with applicable regulations and legal requirements concerning
releases to the environment.
The required levels of environmental surveillance for active decommissioning (the period of
decommissioning activity immediately following the TMI-2:plant cleanup) would differ from thosefor the continuing care period (required for SAFSTOR and ENTOMB).
The environmental surveillance program for the active phase of TMI-2 decommissioning is expected
to be a continuation of the program for the preceding cleanup period.
This program is detailedin Appendix M and summarized in Chapter 11 of this statement.
The program is subject to change
based on review of the results obtained and any requests for additional monitoring.
It is anticipated that the level of effort required will be reduced as the contaminated materials are removed
from the site and the associated potential for radioactive release is reduced.
An abbreviated version of the environmental monitoring program for active decommissioning would
be carried out during continuing care.
Special surveillance requirements would be included for
emergency situations involving radionuclide releases (e.g., fire or malicious acts) that'would
require prompt emergency actions to minimize public risk. Changes in background radiation levels,in environmental radiation accumulations (e.g., fallout from nuclear weapons testing), andespecially in land usage and population distribution may, over a period of years, justify modifications to the continuing care surveillance program.
The program is anticipated to be reviewed
and revised as appropriate at the following times:
After.all fuel and *source material have been removed from the plant,
Approximately 10 years after decommissioning is completed,andAfter 10 half-lives of Co-60 decay (approximately 53 years), economic advantages of further
decommissioning effort are ascertained by the owner, and environmental monitoring conceivably
could be reduced or even eliminated.
As experience is gained and a data base is developed, modifications to the environmental program
can be expected.
U.2.6'Unit Costs

The decommissioning cost information developed in this statement is based on unit cost data
presented in Appendix I of Reference 1 and Appendix M of Reference 3.
The cost data presented in
the references are based on late-1977/early-1978 costs.
For general cost items (e.g., labor,materials, and equipment), the base data have been adjusted by a factor of 1.17 to account for
escalation to current (mid-1980) costs, based on the Handy-Whitman Index's and the Chemical
Engineering Plant Cost Index.1 6 Transportation costs for shipping radioactive wastes to a disposalsite are increased on a per-mile basis in accordance with escalation in the published rates of acarrier licensed to transport radioactive materials.1 7 Other adjustments are made as required toadjust for differences in assumptions between this statement and the reference studies (e.g., theshipping distance to a low-level waste disposal site is assumed to be about 2300 miles in thisstatement as opposed to 500 miles in the reference studies).
U.2.7

Activated Materials Inventory

The quantities of radionuclides present in the activated materials at TMI-2 are estimated byinterpolation of the curves of radionuclide growth versus effective full-power years (EFPY) given-J"n Figure C.1-4 of Reference 1 at the point of 0.26 EFPY (the accumulated exposure on TMI-2).

=

U-15
The interpolated fractions of activity relative to the activity after 30 EFPY are given in
Table U.5 for the principal radionuclides present in the activated reactor vessel internals,
together with the inferred specific activities and estimated surface dose rates. The values
given in Table U.5 are for the most highly activated region of the vessel internals, at the core
mid-plane.

Table U.5.

Radionuclide

Estimated Specific Activities and Surface Dosesfrom Reactor Vessel Internals of TMI-2

Fraction of
Activity, Relative
to 30 EFPY

InferredSpecific Activity(Ci/m 3 )Estimated Surface
Dose Rate(Rad/hr)

Co-60

0.032

30,40016,000

Fe-55

0.05

65,000

0.005

Ni-59

0.008

6

0.0007

Nb-94

0.008

0.04

0.016

In general, the levels of induced radioactivity in the structural materials of TMI-2 are in therange from 1 to 5% of the values that would be present after 30 EFPY.
Since Co-60 is the dominantradioactive species produced, its fractional production factor in TMI-2 (0.032) can be appliedwith minimal error to the values presented in Appendix C of Reference 1 to obtain reasonableestimates of the quantities of activated materials present in TMI-2 at the time of the accident.
Based on the quantities of radioactivity given in Table C.1-4 of Reference 1, the total activity
in the reactor vessel internal components in TMI-2 at the time of the accident is estimated to be(4.82 x 106 Ci x 0.032), or 1.54 x 10s Ci.
In the reactor pressure vessel, the total activity is
estimated to be (1.92 x 104"Ci x 0.032), or 611 Ci.
In the concrete biological shield, the total
activity is estimated to be (2000 Ci x 0.032), or 64 Ci.
U.2.8

Contaminated Materials

The principal radionuclides present on external surfaces in TMI-2 are Cs-137 and Sr-90.
Theradiation fields from radionuclides deposited on the interior surfaces of the RCS and associatedpiping and equipment may also be dominated by Cs-137, although significant quantities of Co-60
are probably present also.
Since Cs-137 is the principal radionuclide contributing to the radiation fields within the plant, the decrease in radiation dose rates with time will be controlledlargely by the half-life of Cs-137 (%30 years).
This condition is different from the reference decommissioning studies'- 3 where Co-60 is thedominant radionuclide, controlled by its 5.7-yr half-life, and extensive surface contamination is
not a major problem.
Thus, deferring decommissioning action at TMI is less effective in reducing
radiation dose than would be the case at the reference reactors.
The longer half-life of Cs-137
also lengthens the time that an entombment structure would have to retain its integrity, morethan 300 years, until the contamination has decayed to unrestricted release levels.
U.3

IMMEDIATE DISMANTLEMENT (DECON)

DECON is the removal from the site of all materials having radioactivity levels greater thanpermitted for unrestricted use of the property.
Thus, all radioactively contaminated equipment,tanks, pumps and piping; the reactor vessel and internals; and activated and contaminated concretemust be removed, packaged, and shipped to an authorized radioactive waste disposal site.
Radiation surveys of the decontaminated facility and site must show that residual levels of radioactivity do not exceed those given in Table 1 of Regulatory Guide 1.86, which appears as Table 1.1
in this report, in order for the nuclear license to be terminated.
As a result, large expenditures of personnel radiation exposure, disposal site space, and money are made in exchange forthe fairly prompt release of the facility and the site for other uses.

U-16
An additional factor favoring the DECON alternative is that a knowledgable work force is available(from the facility operations staff) to perform the decommissioning work.
The elimination ofcontinuing security, maintenance and surveillance requirements for the unit are not very significant benefits for TMI-2 because these services are readily provided by the other unit on thesite (TMI-1).
Decommissioning via DECON would preclude storage of the irradiated fuel in-the
AFHB beyond the length of time-required to ship the fuel to an offsite facility since, by definition, all radioactive materials must be removed.
The continued use by TMI-1 is postulated forsuch facilities as the chemical cleaning building (EPICOR-II), EPICOR-I, the radiochemistry hotlab, and the solid radwaste staging modules.
The resin solidification and mid-high level radwaste
staging facility (if built) is also postulated to remain in place for service with Unit 1.
U.3.1

Decommissioning Activities for DECON

Once the irradiated fuel has been placed in the spent fuel pool in the AFHB, the fuel debris has
been dissolved and removed, and the reactor coolant system and associated fluid handling systems
have been chemically decontaminated, disassembly,.disposal, and further decontamination canproceed'promptly.
Work begins in the reactor containment building, proceeds through the AFHB,
and concludes with the service and control buildings.
The turbine building and other onsite
structures (except for the EPICOR-II building and any other as-yet constructed waste treatmentbuildings) are assumed to be uncontaminated.
The estimated duration of each event during DECON is shown in Figure U.2.
decontamination of the facility is estimated to require nearly four years.

The disassembly and

YEARS AFTER START
OF DECOMMISSIONING
DECOMMISSIONING ACTIVITY

0

I

2

3

DECON OF CONTAINMENT BLDG.
DECON OF AFH BLDG.

4

*

-

I

DECON OF OTHER BUILDINGSCONTROL AND SERVICESCONTAINMENT SERVICE

LIQUID RADWASTE (IF BUILT)I--SHI PMENT OF SPENT FUEL
TREATMENT AND DISPOSALOF RADWASTE

Figure U.2.

U.3.1.1

Duration of DECON Activities.

Containment Building

The postulated sequence and schedule for major tasks for disassembly and decontamination of thecontainment building is shown in Figure U.3, together with postulated crew sizes and estimatedexposure hours.
The associated worker radiation doses are given in Section U.3.4.

-

-

-

-

-

~-

-

I

I

-

/I MONTHSAFTERSTARTOF DECOMMISSIONING
TASKS

1
----

REMOVE
ANDPACKAGEAIR COOLERSREMOVEANDPACKAGEFUELSTORAGERACKS

2

3

4

5

6

7

8

9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36

14/100011
14/10OD/1

W--1
150011.5REMOVEANDPACKAGEBLDG. SPRAY SYSTEMREMOVEANDPACKAGECOREFLOODINGTANKS

14/1000/1

SEGMENTANDPACKAGEREACTORVESSELHEAD

71500/1

SEGMENTANDPACKAGEVESSELINTERVALS

4211850016

REMOVEANDPACKAGERCS ANDVESSELMIRROR INSULATION

71500113511560015

SEGMENTANDPACKAGEREACTORPRESSURE VESSEL:'REMOVEANDPACKAGEPRESSURIZER, PIPING
ANDVALVES

1414300/4
141670016

i-

REMOVEANDPACKAGERCS PUMPS ANDPIPINGi

SEGMENTANDPACKAGESTEAMGENERATORSAND STEAMLINES

28f720013
14/1000/1

SEGMENTANDPACKAGEREACTORDRAIN TANK,PUMP ANDPIPINGREMOVEANDPACKAGELETDOWNCOOLERS-

14/1 000/1

REMOVEANDPACKAGELEAKAGECOOLERS
14/110001

REMOVEANDPACKAGES.G. HOTDRAINCOOLERANDPUMPC
14/3000/3

REMOVEANDPACKAGEREMAINING PUMPSANDPIPING
14/2000/2

REMOVEANDPACKAGE
ACTIVATEDCONCRETE

14/20001/2

REMOVEANDPACKAGE
FUELTRANSFEREQUIPMENT
ANDREFUELING
POOLLINER

14/1500/1.5

REMOVEANDPACKAGEREFUELING
CRANE

14/120001/8

REMOVEANDPACKAGECONTAMINATED
CONCRETE

1413000/3

REMOVE,SEGMENT
AND PACKAGEPOLARCRANE

14/2000/2

REMOVE
ANDPACKAGE
VENTILATIONSYSTEM

14/2000/2

SURVEYFOR RESIDUAL RADIATION
4FINAL"HOT SPOT" DECONTAMINATIONTORELEASELEVELS--4

SHIPPING OF RADIOACTIVE MATERIALS-

4

7/20001/4

12119000112

I
LEGEND:
THIS SCHEDULE
COULDBE SIGNIFICANTLY INFLUENCED
BYMANYFACTORSTHATARENOTPRECISELY KNOWNATTHIS TIME. THESEINCLUDE,BUTARENOTLIMITEDTO, THEEXACTRADIOLOGICAL CONDITIONS ENCOUNTEREDUPONCOMPLETIONOF
INITIAL DECONTAMINATIONEFFORTS,FINANCIAL LIMITATIONS, REGULATORYACTIVITIES. CRAFTLABORANDMATERIALAVAILABILITY, ANDAVAILABILITY OF
OFFSITE OR ONSITE RADWASTEDISPOSAL CAPABILITY ON A TIMELYBASIS.

DIRECTSTAFFPER DAY/EXPOSURE HOURS/CALENDARMONTHS
P-PCONTINUOUS OPERATIONS OVERTHETIME SPAN SHOWN---INTERMITTENT OPERATIONS OVERTHETIME SPAN SHOWNTOTALS: PERSON-MONTHSPERSON-HOURSEXPOSURE-HOURS

Figure U.3.

1,188
226.160
110.300

Postulated Sequence and Schedule of Tasks for DECON of theContainment Building.

U-18
Disassembly begins with the removal and packaging of the containment air coolers.(if not previously removed), the fuel storage racks, the containment spray system, and the core flooding
tanks, thus freeing most of the 305-ft level for use as a packaging and storage area for packaged
materials pending shipment offsite.
The fuel transfer canal is now available for segmentationand temporary storage-of the activated, portions of the reactor vessel internals and for temporarystorage of activated segments of the reactor pressure vessel while the vessel is being sectioned.
-Removal of the decontaminated structures is not required to terminate the nuclear license andthus is not considered in this analysis.
The disposition of the released structures is at theowner's option.
The estimates of direct labor hours, waste volumes, and costs are derived largely by comparison
with the results of previous conceptual-decommissioning studies,1' 3 adjusted for the sizes andmasses of equipment, levels of contamination or activation in the materials, distance to thedisposal site, and escalations in costs from the time of the reference studies to mid-1980.
It is assumed that the reactor vessel head, the upper plenum assembly, and the core support
structure are successfully removed intact during defueling and cleanup and are reinstalled forthe chemical decontamination of the reactor'coolant system, in which the RCS pumps are used forrecirculation of the decontamination solution and final flushing.
The head is removed and. sectioned for packaging.
The upper plenum assembly and the core support structures are removed andsectioned and stored temporarily under water'in the fuel transfer canal.
The water level in thecanal is lowered to about the 322-ft level to remove theseal plate and the mirror insulation
surrounding the vessel.
The water level in the vessel is lowered to just below the planned levelfor cutting.
The vessel is cut into segments that are temporarily stored in the fuel-transfer
canal prior to packaging.
As the reactor vessel is drained and cut, the-remainder of the RCS.isdrained for sectioning.
Removal and-packaging of the pressurizer and piping is followed bysectioning and removal of the RCS pumps and piping.
Sectioning of the steam generators andremoval of the steam export lines and valves is followed by removal and packaging of the letdown
coolers, the steam generator hot-drain cooler, the leakage coolers, the reactor drain tank, theoil-shielded drain tanks, the incore instrumentation drives, and assorted pumps and equipment on
the 282-ft level.
Removal of some of these items will require removal of sections of the shield walls surroundingthem.
The lower sections of the vertical' tendons are most likely contaminated and will have tobe removed for disposal.
Those portions of the concrete biological shield in the vicinity of thefuel core that have been activated by :neutron bombardment are.removed and packaged.
The refuelingbridge crane, the fuel transfer equipment, and the liner of the fuel transfer canal are removed
and packaged.
The outer 2 to 3 inches of concrete is removed from concrete surfaces. that were
subjected to standing contaminated water, principally the concrete floor:"of. the 282-ft level andthe first 9-10 feet of wall surfaces rising from the 282-ft level and the surfaces of.-the tendon
gallery. Other concrete surfaces are removed as dictated by radiation survey data.
The polar
crane is either decontaminated to release levels or is dismantledand packaged.
Removal andpackaging of the remaining ventilation equipment'precedes the radiation survey to determine thereleasability of the containment building.
Any areas found to have radioactivity levels exceeding those levels set for release are cleaned or removed.
At this point the containment building
is available for non-'nuclear use or demolition, at the owner's option.
Disassembly, decontamination, and disposal of the radioactive materials from the. containmentbuilding are estimated to require about 226,000 direct labor hours, including 110,000 hours ofwork in radiation zones.
Transport workers and workers at the waste disposal site are notincluded in these estimates.
U.3.1.2

Auxiliary and Fuel Handling Building

With the reactor core stored in'the spent fuel pool', the first activity to get underway in the
AFHB is the shipment of the spent fuel to a storage facility, a reprocessing plant, or a disposal
facility offsite. Assuming an IF-300 cask (capacity 7 elements) is used, With an 18-day roundtrip cycle, 26 round trips by rail will be required to remove the 177 fuel elements, or about
16 months elapsed time.
Availability of another spent fuel shipping cask of similar capacity
would reduce the 'fuel shipment period to about 8 months.
Additional shipments may be required toremove packaged fuel debris.

U-19
The postulated sequence and schedule of tasks for disassembly and decontamination of the AFHB isshown in Figure U.4. The general plan of attack is to start on the upper levels, removing systems
no longer needed, and proceed toward the lower levels. The spent fuel pool cleanup system willremain in service until shipment of spent fuel is completed.

MONTHS AFTERSTART OFDECOMMISSIONING
1 2, 3 4 5 6. 7 8 9 1011 1213 14 115
1,61

TASKS

SHIP SPENT REACTOR FUELREMOVE
SURGE TANKS, NEWFUELRACKS,HYDROGEN RECOMBINER

2,6 27 2,8 ý 3,0 ,13? 33 *435 3637

IB
189 20 21 22 23 24

6380015; ONE CASK

-4 TWOCASKS
281/200011

1442000/2

REMOVEMIXTANKS, PUMPS AND PIPINGREMOVE
H2 EXHAUST SYSTEM, SEAL
RETURN, INTERMEDIATE AND NUCLEARSERVICE COOLERSYSTEMS

i.--14/400014

14/3000/3

REMOVE
WASTE GAS SYSTEM

1413000/3

REMOVE
REACTOR COOLANT MAKEUP SYSTEMREMOVEEMERGENCY BOOSTER PUMPS.
SPRAY PUMPS, OIL DRUM STORAGEREMOVENEUTRALIZER SYSTEM, BORIC
ACID SYSTEM

I

414/4000/4-

i14/600016

REMOVESPENT FUELCOOLING SYSTEM

141200012

REMOVE
MAKEUP AND PURIFICATIONDEMINERALIZERS

141200012

REMOVESPENT RESIN SYSTEM ANDWASTEHOLDUP TANK

1-41200012

REMOVE
REACTOR COOLANT EVAPORATORSYSTEM

141200012
14/1300013

REMOVECOOLANT HOLDUP AND CONTAMINATEDWASTE TANKS.- 1413000/3

REMOVEINSTRUMENT RACKS ANDMOTORCONTROL CENTER

141200012

REMOVE
SUMP PUMPS, FILTER ANDTANKREMOVEBUILDING VENTILATION SYSTEMS:
REACTOR BUILDINGAUXILIARY BUILDINGFUELHANDLING BUILDING--

14/1000/1
14/100011-4 1411000/1

REMOVECONTAMINATED CONCRETE

281800014

4-COMPREHENSIVE RADIATION SURVEY

14/2000/2

7/2000/4

CLEANUP REMAINING HOTSPOTSPROCESSING AND SHIPPING RADIOACTIVE
MATERIAL

4----------

241/800/20

LEGEND:
THIS SCHEDULE COULD BESIGNIFICANTLY INFLUENCED BY MANY FACTORS THATARE NOTPRECISELYKNOWN
ATTHIS TIME, THESE INCLUDE, BUTARENOTLIMITED TO. THEEXACTRADIOLOGICALCONDITIONS ENCOUNTERED UPON COMPLETION OFINITIAL DECONTAMINATION EFFORTS, FINANCIAL
LIMITATIONS, REGULATORYACTIVITIES, CRAFT LABOR AND MATERIAL AVAILABILITY, AND
AVAILABILITY OFOFFSITE OR ONSITE RADWASTE DISPOSAL CAPABILITY ONATIMELY BASIS.

DIRECT STAFFPER DAY/EXPOSURE HOURS/CALENDAR MONTHS-- --CONTINUOUS OPERATIONS OVERTHETIME SPAN SHOWNINTERMITTENT OPERATIONS OVER THETIME SPAN SHOWNTOTALS:

Figure U.4.

PERSON-MONTHSPERSON-HOURSEXPOSURE-HOURS

Postulated Sequence and Schedule of Tasks for DECON of the
AFH Building.

1,436
252, 820
138,800

U-20
The waste handling and treatment system will remain in service until all other radioactive fluid
handling systems are removed.
The outer 2 to 3 inches of concrete is removed from concretesurfaces that were subjected to contaminated water spills.
Removal and packaging of the building
ventilation equipment is the final action preceding the radiation survey to determine the releasability of the AFH building.
Any areas found to have radioactivity levels exceeding those levels
set for release are cleaned or removed.
At this point the AFH building is available, for nonnuclear use or demolition, at the owner's option.
Disassembly, decontamination, and disposal of
the radioactive materials from the AFH building is estimated to require about 252,800 direct
labor hours, including about 138,800 hours of work in radiation zones.
Transport workers andworkers at the waste disposal site are not included in these estimates.
U.3.1.3

Other Buildings

Other buildings associated with TMI-2 that contain quantities of radioactivity are the control
and service building, the containment service building, and the liquid radwaste processing building (if built).
It is postulated that the chemical cleaning buil'ding (EPICOR-II), EPICOR-I, theradioachemistry hot lab, the resin solidification and mid-high level radwaste staging facility(if built), and the solid radwaste staging modules will remain onsite and be servicable for use
with TMI-1.
Control and Service Building
Radioactively contaminated equipment in this building is limited to the contaminated drain systemand the isolation valve tanks and pumps on the 280-ft level, the monitoring and soiled laundryareas on the 305-ft level, and the decontamination filter assembly on the 351-ft level.
Since
all systemsand services are controlled from this building, it will be the last to be decontaminated.
Containment Service BuildingThis structure is basically an extension of the containment building, enclosing the equipment
hatch and providing a staging area for shipping packaged material from the containment building.
It is postulated that decontamination efforts in this building are limited to surface cleaning,since most of the materials are already packaged before removal from containment.
"Liquid Radwaste Processing BuildingThis structure does not presently exist and its contents can only be postulated.
Likely systems
include a radwaste evaporator and a liquid waste solidification system.
Removal of these systems
is delayed until decontamination of the containment and AFH buildings is complete.
Summary of Other Buildings
Disassembly, decontamination, and disposal of radioactive materials from the other buildings are
estimated to require about 22,000 direct labor hours, including about 18,000 hours in radiation
zones.
U.3.2

Waste Volumes from DECON

The volumes of activated or contaminated material postulated to be packaged for disposal, during.
DECON of TMI-2 are estimated by comparing sizes and masses of the TMI-2 materials with similarmaterials analyzed in a previous study.1' 2 Using the methods described in Reference 2, scaling
factors are constructed based on the ratio of the mass of the TMI-2 component to the mass of thereference component.
These mass ratios, or scaling factors, are applied to the volumes and costs
estimated in Reference I to obtain estimates for TMI-2.
Where mass ratios could not be readily
constructed, an overall scaling factor based on energy output, as derived in Reference 2, isemployed (0.84).
The resultant waste volumes are summarized in Table U.6.
The volume of contaminated concrete is postulated to be 20% greater than given in Reference 1,
reflecting the large areas of TMI-2 that were subjected to standing contaminated water for extended
periods of time.
The other values generally reflect the physical size or configuration of TMI-2
compared with the Reference plant.

U-21

Table U.6.

Estimated Volumes of Radioactive Waste
Arising from DECON of TMI-2

Scaling Factor

Estimated Burial
Volume (ft 3 )Truck
Shipments

Reactor vessel w/headand internals

0.94

15,600156

RCS pumps, piping andpressurizer

0.83

9,100

22

17,70026

Components

Steam generators

0.83

Activated concrete

1.0

25,000-49

Contaminated concrete

1.2

455,000

889,

Contaminated equipment

0.84

127,000

34

Miscellaneous radwastes

1.0

22,000180

671,000

1,356

TotalsaValues rounded to three significant figures.

U.3.3

Effluents and Releases to the Environment

The atmospheric release of radionuclides is assumed to be the only source of radiation to the
public from routine decommissioning operations.
All liquid radioactive wastes generated duringdecommissioning operations are assumed to be sent to the plant liquid waste storage system or toother tanks designated for temporary storage of these solutions.
The wastes are then assumed to
be processed through the waste concentration and solidification system, and the decontaminatedwater released to the environment.
All systems designed to control the release of hazardous
material to the environment or to noncontaminated portions of the facility are assumed to be inoperation during the decontamination activities and subsequent'waste processing.
The primary sources of radioactive effluents from routine decommissioning operations are therelease of contaminated liquid aerosols during decontamination, the release of contaminatedvaporized metal during equipment removal, and the release of contaminated concrete dust duringdecontamination or removal of concrete structures.
An analysis of the generation of airborne radioactivity during DECON operations at a large PWR isgiven in Appendix J of Reference 1, with the results of that analysis summarized in Table U.7.
The values given in Table U.7 have been adjusted downward from those developed in Reference 1 toreflect the smaller amount of activated corrosion product deposited on piping interiors (-.4 percent of the amount postulated in Reference 1), the smaller amount of activation in the concrete
bioshield (-.5 percent of the amount postulated in Reference 1), and adjusted upward to reflect
the assumption of a less effective HEPA filter system than was postulated in Reference 1.
Thereleases postulated here do not include releases from possible accidents involving transport ofspent reactor fuel from the site to a disposal facility.
From Reference 1, the compositions of the reference radionuclide inventories considered in theanalysis are presented in Tables U.8, .9, .10, and .11.

U-22

Table U.7.
Postulated Releases of Airborne
Radioactivity to the Environment
During DECON Operations

ReferenceRadionuclide
Inventory

DECON
Operation

Airborne
Releases(pCi)

Segmenting contaminatedequipment

4

6

Activated concrete removal

3

0.2

Contaminated concrete
removal50.0016

Water-jet cleaning

5

9.8

Table U.8.

Reference Radionuclide Inventory 2,
Activation Products - Lower Vessel

Carbon Steel

Fractional Radioactivity Normalized to Reactor Shutdown at Decay Times of:Radionuclide

Shutdown

10 Years

30 Years

Mn-54

5.3 x 10-2

1.6 x 10-5

-a

Fe-55

8.2 x 10-1

6.3 x 10-2

3.7 x 10-4

2.1 x 10-6

Fe-59

3.1 x 10-2

-

Co-58

7.5 x 10-

50 Years

100 Years

-3

Co-60

8.5 x 10-2

2.3 x 10-2

1.6 x 10- 3

1.2 x 10-4

1.6 x 10-7

Ni-59

3.6 x 10-5

3.6 x 10-s

Ni-63

4.3 x 10-3

4.0 x i0-3

3.6 x 10-s
3.5 x 10-3

3.6 x 10-5
3.0 x 10-3

3.6 x 10-5
2.1 x 10-3

Mo-93

1.5 x 10-6

1.5 x 10-6

1.5 x 10-6

1.5 x 10-6

1.5 x 10-6

9.0 x 10-2

5.5 x 10-3

3.2 x 10-3

2.1 x 10-3

Totals1.0

aA dash indicates values less than 1 x 10-1o.

U-23

Table U.9.

Reference Radionuclide Inventory 3, Concrete Activation
Products - Biological Shielda

Fractional Radioactivity Normalized to Reactor Shutdown at Decay Times of:Radionuclide

Shutdown

10 Years

30 Years

50 Years

100 Years

Ar-39

1.14 x 10-3

1.11 x 10-3

1.05 x I0-3

1.00 x 10-3

8.78 x I0-4

Ca-41

2.01 x 10-4

2.01 x 10-4

2.01 x 10-4

2.01 x 10-4

2.01 x 10-4

Ca-45

1.05 x 10-'2.30 x 10-8

Mn-54

4.83 x 10-3

1.05 x 10-6

Fe-55

8.65 x 10-1

6.64 x 10-2

3.91 x 10-4

2.30 x 10-6

-

Co-60

1.92 x 10-2

Ni-59

3.42 x 10-s

5.15 x 10-3
3.42 x 10-s

3.71 x 10-4
3.42 x 10-5

2.67 x 10-5
3.42 x 10-5

3.73 x 10-8
3.42 x 10-5

Ni-63

4.02 x 10- 3

3.75 x 10-3

3.27 x 10-3

2.84 x 10-3

2.01 x 10-3

1.0

7.70 x 10-2

5.32 x 10-3

4.10 x 10-3

3.12 x 10-3

Total

-

aThe radionuclides listed include only those whose half-life and/or initial concentration resultin a significant contribution after one year's decay and/or one hundred year's decay.
bA dash indicates values less than 1 x 10-1o.

Table U.10.

Reference Radionuclide Inventory 4, Neutron-Activated Corrosion
Products Deposited on Piping Internal Surfaces

Fractional

Radioactivity Normalized to Reactor Shutdown at Decay Times of:Radionuclide

Shutdown

10 Years

30 Years

Cr-51

2.4 x 10-2-a_

1.1 x I0-5

Mn-54

3.6 x 10-2

SFe-59

8.2 x

Co-58

4.6 x 10-i

Co-60

3.2 x 10-1

Zr--955.6 x 10-2

Nb-95

5.6x 10-2

Ru-103

2.6 x 10-2

Cs-137

1.2 x 1 0 -3

Ce-1416.6 x 10-2

Totals1.0

50 Years

100 Years

-

-

-

-

8.6 x 10-2

6.2 x 10-3

4.4 x 10-4

6.0 x 10-7

9.5 x 10-4

6.0 x 10-4

3.8 x i0-4

1.2 x 10-4

8.7 x 10-2

6.8 x 10-3

8.2 x 10-4

1.2 x 10-4

1 0 -3aA dash indicates values less than 1 x 10-10.
NOTE: The activities are based on actual data from the Turkey Point Reactors extrapolated to
7 years of commercial operation.

U-24

Table U.11.

Reference Radionuclide Inventory 5, Radioactive Surface Contaminationin the Reference PWR
Fractional Radioactivity Normalized to Reactor Shutdown at Decay Times of:Radionuclide

Shutdown

10 Years

30 Years

Mn-54

1.4 x I0-3

4.2 x 10-7

-a
a

Fe-55

2.2 x 10-2

1.7 x 10-3

Fe-59

8.7 x 10-4

Co-58
Co-60

7.5 x 10-3
7.5 x 10-2

2.0 x 10-2

Sr-89

1.2 x 10-3

-

Sr-90

6.9 x 10-4

Y-90

6.9 x

Zr-95

2.5 x 10-4

Nb-95

2.5 x 10-4

Te-129m

3.1 x 10-4

1-131

1.4 x 10-2-

Cs-134

1.2 x 10-1

Cs-136
Cs-137

50 Years

100 Years

9..9 x 10-6

5.7 x.10- 8-

1.4 x 10-3

1.0 x 10-4

1.4 x 10-7--

5.4 x 10-4

3.4 x 10-4

2.1 x 10-4

6.3 x 10-s

5.4 x 10-4.

3.4 x I0-4

2.1 x I0-4

6.3 x 10-5

4.1 x 10-3

4.8 x 10-6

5.4 x 10-9-

1.1 X 10-3
7.5 x 10-1

5.9 x 10-1

3.7 x 10-i

2.4 x 10-1

7.4 x 10-2

1.0

6.2 x 10-1

3.7 x 10-1

2.4 x 10'-

7.4 x 10-2

Totals

1 0 -4aA dash indicates values.less than 1 x 10-1o.

U.3.4

Environmental

Impacts

The environmental impacts associated With the decontamination and disassembly of a nuclear powerreactor are contained in three general categories:(1) the radiation dose to the workers involvedin the disassembly, packaging, and transport of the radioactive materials from the site to adisposal facility; (2) the radiation dose to the public resulting from releases of radioactivity
from the site during decommissioning operations and from radiation emanating from shipments ofradioactive waste while in transit on public highways or railways; and (3) the commitment of
space in a low-level radioactive waste burial ground for the disposal of the radioactive materials*from the plant.
The impacts associated with each of these categories are discussed in the following sections.
U.3.4.1

Estimated Occupational

Radiation doses from DECON Activities

The radiation dose accumulated by the workers performing DECON activities is estimated by multiplying the average local radiation dose rate for a given task times the number of worker exposure
hours estimated for that task, and summing over all tasks.
The average local dose rates forgeneral areas in the containment building and the AFH building are given in Table U.12.
Also
given are cumulative exposure hours for persons.working in those general areas (taken from
Figures U.3 and U.4), the computed cumulative dose to the workers accomplishing tasks in thoseareas, and the total radiation dose received by workers while performing DECON activities.
These
radiation doses include only the doses resulting from external exposure and do not include any
potential doses that might result from inhalation or ingestion of radioactive material during thedecommissioning operations.

U-25
The estimated dose received by the transportation workers during the transport of packaged radioactive wastes, based on an assumed realistic dose rate for each shipment as given in Section 9.5.1.1 (56 mrem/trip/driver),is given in Table U.13.
The estimated dose received byrailway workers during the transport of the spent reactor fuel, based on information developed in
Section 11.4.1 of Reference 1, is also given in Table U.13.

I

Table U.12.

Estimated Cumulative Radiation Doses Received by Workers
During DECON Operations/

Average
Local
Dose Rate(mrem/hr)

DECON
Operation
Area

Worker Exposure
Hours in the
Area

Cumulative
Radiation
Dose(person-rem)Containment Building

5-10
30

25,00037,700

240
125
1,130

2

138,800

278

2

18,00035

347-ft level305-ft level282-ft level

47,600

AFH Building
All levels
Other Buildings
All levels

1,810

TotalaaTotal rounded to three significant figures.

Table U.13. Estimated Cumulative Radiation Doses Received
by Transport Workers During DECON Operations

WorkerType
Truck Drivers
Train Crew

Dose/Shipment(mrem/driver)

Number of
Shipments

56

1,400

120

26

Total
aAssumes two drivers/truck, two brakemen/train.

Cumulative
Radiation Dose(person-rem)
156.8a
6.2a
163

U-26
U.3.4.2

Offsite Doses from DECON Activities

The dose estimates presented here for DECON activities are based on the source terms of Table U.7
and on the assumption that decommissioning activities take place 10 years after the TMI-2 accident.
The calculational models used to make these estimates and the interpretation of their results aredescribed in Appendix W. The significance of these doses and their human health and environmental
consequences are discussed in Section 10.3.
The dose estimates to the maximum-exposed individual
are listed in Table U.14.
The 50-mile total body population dose received by the human population
during this DECON operation is estimated to be 6 x 10-s person-rems.
The estimated radiation dose to the public resulting from transport of radioactive materials
offsite is presented in Table U.15 for both truck and rail transport.

Table U.14.
Estimated Doses to the Maximum-Exposed Individualfrom Normal Decommissioning Activities (DECON)

Location

Pathway

Total-Body

Dose (mrem) a
Bone

Nearestgardenb

Inhalation
Ground Shine

1.4 x 10-7
7.2 x 10- 7

3.1 x 10-7
7.2 x 10-7

2.6 x 10- 7
7.2 x 10-7

Vegetable Use

3.2 x 10-6

1.4 x 10-5

1.3 x 10-s'

4.1 x 10-6

1.5 x 10-s

1.4 x 10-s

Inhalation
Ground Shine

1.2 x 10-7
6.9 x 10-7

1.7 x 10-7
6.9 x 10-7

1.7 x 10-7
6.9 x 10-7

Goat Milk Use
Total

8.4 x 10-6
9.2 x 10-6

6.5 x 10-5
6.6 x 10-5

7.6 x 10-5
7.7 x-1O-s.

Inhalation
Ground Shine

1.5 x 10-7
1.1 x 10-6.

2.0 x 10-7
1.0 x 10-6

2.1 x 10- 7
1.0 x 10-6

Vegetable Use
Cow Milk Use

4.6 x 10-6
3.1 x 10-6

2.0 x 10-s
2.4 x 10-5

1*9 x 10-5
2.8 x 10-5

9.0 x 10-6

4.5 x 10-5

4.8 x 10-5

Total
Nearestmilk goat

Nearest cow
and garden

Total

Liver

aDoses were calculated for total-body, GI-tract, bone, liver, kidney,
thyroid, lung and skin. The maximum three organ doses are listed in thistable. Doses were calculated for four age groups: adults, teenagers,
children, and infants. The highest dose estimates for each age group are
listed. The dose estimates for the total-body pathway are for adults.
The dose estimates for the bone and liver pathways for the nearest garden
and nearest cow and garden locations are for children, and for the nearest
goat location are for infants.
bThe basis for selecting the special locations is described in Appendix W.
The actual locations are: Nearest garden = 1.05 mile east-northeast,nearest milk goat = 1.02 mile north, and nearest cow and garden= 1.05 mile east.

U-27

Table U.15.
Estimated Cumulative Radiation Dose Received
by the Public During Transport of Radioactive Wastes from DECON

Type of Shipment

Number of Shipments

Dose/Shipment(person-rem)

Radioactive
material (truck)

1,40.00 . 0 5 3a

Spent reactor
fuel (rail)

26

Total

0 .0 29 3b

PublicRadiation Dose(person-rem)
74.2
0.76
75

aBased on data given in Section 9.5.1.2.
bBased on data given in 11.4.1 of Reference 1.

U.3.4.3

Other Environmental Effects

Other impacts on the environment surrounding the TMI station resulting from DECON of Unit 2 will
be similar to those discussed in Section 10.6, but of lesser magnitude because there will be
fewer workers involved in DECON and because gross contamination cleanup efforts will have been
completed before the start of decommissioning.
It is anticipated that decommissioning of Unit 2 would reduce the level of anxiety and psychological stress among local residents.
.Completion of decommissioning will reduce the number of persons employed at the TMI site, thus
reducing the local payroll, at least temporarily.
U.3.5

Estimated Costs for DECON

The principal cost items in DECON are labor, waste disposal, spent fuel disposal, and energy.
Other costs include special equipment, specialty contractors, licensing and insurance, andmiscellaneous supplies.
The bases for the costs presented here are given in Appendix G and
Section 10 of Reference 1, and are adjusted for escalation between early-1978 and mid-1980, as
discussed in Section U.2.5. The*costs are summarized in Table U.16, with the estimates of theprincipal cost items developed in the following sections.
U.3.5.1

Decommissioning Labor Costs

The basic decommissioning crew is postulated to consist of seven members:a crew leader, autility operator, two laborers, two craftsmen, and a~health physics technician.
The averagesalary cost per hour per crew member (developed from data given in Table 1.1-1 of Reference 1,
escalated by 17%) is $15.12.
From Table 10.1-2 of Reference 1, the ratio of crew labor cost to
total decommis~sioning labor cost is 2.24. The direct decommissioning crew labor hours for the
principal bui-Idings and activities are given in Table U.17, summarized from Section U.3.1.
U.3.5.2

Radioactive Waste Disposal Costs

The,.radioactive materials requiring disposal during DECON of TMI-2 consist of three maincategories:
neutron-activated,;surface-contaminated, and miscellaneous radwaste such as filters,
ion exchangelres'ins, solidified radioactive fluids. and combustible wastes.
Estimates of thecost of disposing of these materials are summarized in Table U.18, and packaging and shipping
information for each type of material is discussed briefly in the following sections.

U-28

Table U.16.

Summary of Estimated DECON Costs

Cost in Millions ofMid-1980 Dollars

Category0,Decommiss-ioning labor
Direct7.196

Support

8.923

Radwaste disposal

13.791

Spent fuel shipment

2.496

Energy4.620

Other costs
Supplies

1.820

Equipment

0.960

Contractors

0.640

Nuclear insurance

0.940

Licensing fees

0.060

Subtotal

41.44625% contingency

10.361

Totala51.8

aTotal rounded to three significant figures.

Table U.17.

Activity

Estimated Labor Costs for DECON

Direct Crew
Hours

Labor Costs
in Millions of Dollars
Direct Crew
Total

Containment building

200,816

3.037

6.803

AFH building

135,520

2.050

4.592

Other building

22,176

0.335

0.750

Radwaste processing
and shipping

112,020

1.694

3.795

Spent fuel shipping

5,280

0.080

0.179

475,812

7.196

16.119

Total

U-29

Table U.18.

Estimated Costs for Disposal of Radioactive Wastes from DECONI

BurialRadioactive
Material'

Number of
Shipments

Container
Costa

Cask
Rentalb

Transport
Costs

Handling
ChargesVolume(ft 3 )

Chargesa

Neutronactivatedsteels156

124,800

280,000

88,92032,136

15,600248,040774,696

Neutronactivatedconcrete

49

92,120-181,300-

25,000217,500

490,920

Contaminatedequipment

82

154,160-

303,400

39,850154,000

1,339,800

1,837,210

Contaminatedconcrete889

1,670,850-

3,289,300-

455,000

3,958,500

8,918,650

Miscellaneousradwastes

180

151,800

324,000

1,026,000

54,60022,000212,872

1,769,272

1,356

2,193,730

604,800

4,888,920

126,586

671,600

5,976,712

13,790,748

Total

aAssumes cask liner cost of $800,

LSA Box cost of $470,

Total
Cost

special container cost of $6000/box.

bAssumes a rental fee of $300/day and a 6-day cycle for each shipment.
cAssumes a transport cost of $5700/round trip, $3700/one-way.
dAssumed to average $350/cask liner, overweight objects @ $87.50 + (0.02/lb >10,000 lb).
eAssumes burial charges of $8.70/ft 3 , liner and curie surcharges as given in current NECO price list.

Neutron-Activated Material
Because of the rather short exposure history of the TMI-2 reactor vessel and its internals, thelevels of neutron-induced radioactivity in structural components are low compared with the levels
expected to be found in a reactor that has operated for 30-40 years.
As a result, it is anticipated that the activated materials could be shipped in unshielded cask liners within shieldedshipping casks.
Based on the information developed in Section U.3.2, it is estimated that 156
single cask shipments of activated materials will be required.
The neutron-activated concrete
from the biological shield will require 49 truck shipments in unshielded LSA boxes.
Contaminated Equipment
The contaminated equipment, pumps, piping, heat exchangers, etc.,
boxes.
From Table U.6, 82 truck shipments will be required.

are packaged in unshielded LSA

Contaminated Concrete
The contaminated concrete removed from building surfaces during physical decontamination ispackaged in 3556 unshielded LSA boxes and will require 889 truck shipments.
Miscellaneous Radwaste
The filters, ion exchange resins, solidified radioactive fluids, and combustible wastes resulting
from DECON are packaged in a variety of containers.
Based on information presented in Table G.4-6
of Reference 1 and on cask-liner-costs of $800 each and 55-gal-drum costs of $20 each, the container
costs will be $151,800.
Cask rentals will total $324,000, and 180 truck shipments will be required.

U-30
U.3.5.3

Spent Fuel Disposal Costs

Assuming that the 177 fuel bundles are shipped in a large rail cask (IF-300) that can carry sevenbundles per shipment, 26 shipments are required.
The spent-fuel-receiving facility is assumed to
be located 1500 miles from TMI-2, and an 18-day round-trip cycle is maintained.
The transportation costs are assumed to be $33,000 per trip.
A cask rental of $3500/day is
assumed.
Thus, the cost for removing the spent fuel from the TMI-2 facility is ($3500/day)(18 days/trip) + $33,000/trip = $96,000/trip, for a total of $2.5 million for 26 trips.
Nocharges are included for handling and eventual disposal of the fuel at the final destination.
U.3.5.4

Energy Costs

Energy usage during decommissioning is comprised of electrical and fossil energy, in roughly
equal amounts.
The cost of energy is estimated in References I and 3 to be about $3.5 million in1978 dollars.
Assuming an escalation factor of 32%, the energy costs are estimated to be$4.6 million.
U.3.5.5

Other Costs

Other cost items include miscellaneous supplies, special equipment, specialty contractors, nuclear
insurance, and licensing fees.
It is assumed that the cost of these items as presented in Reference 1, when escalated by 17%, are appropriate for the TMI-2 analysis.
Based on Table 10.1-1 ofReference 1 and Table 10.1-1 of Reference 3, these items are estimated to be $1.82, $0.96, $0.64,$0.94, and $0.06 million, respectively.
U.4

SAFE STORAGE FOLLOWED BY DEFERRED DECONTAMINATION (SAFSTOR)

This section contains the details of SAFSTOR for TMI-2.
Information is included on those activities required to place (preparations for safe storage) and maintain (safe storage) the radioactive facility in such condition that the risk to safety is within acceptable bounds under theconditions of the NRC license.
Since materials having radioactivity levels above unrestrictedlevels are still
onsite, the nuclear license remains in force throughout the SAFSTOR period.
SAFSTOR is completed by subsequently decontaminating the facility to levels that permit releaseof the facility for unrestricted use (deferred decontamination), thus permitting termination of
the nuclear license.
SAFSTOR satisfies the requirements for the protection of the public while minimizing, in various
degrees, the initial commitments of time, money, occupational radiation exposure, and regulated
waste disposal site space.
Since TMI-2 is on a multiple-reactor site, SAFSTOR is assumed tominimize the combined impacts of preparations, continuing care, and deferred decontamination.
This advantage is offset somewhat by the need to maintain the nuclear license and by the associatedrestrictions placed on the use of the property.
The SAFSTOR alternative requires continuing
physical security and surveillance of structural integrity sufficient to ensure public protection.
The information presented in this section includes:
Considerations for SAFSTOR,
Methods, equipment, and other information,
Decommissioning activities,
SAFSTOR schedules and manpower estimates,
Estimated external occupational radiation doses for SAFSTOR
Estimated costs for SAFSTOR, andDeferred decontamination.
U.4.1

Considerations for SAFSTOR

Initially, the reactor defueling and chemical decontamination of the RCS are assumed to be completed, as shown in Figure S-1 of the summary.
At this point, 4-1/2 to 5 years of cleanup activities have been carried out before SAFSTOR activities are begun.
The planning and preparation phase is carried out simultaneously with the last months of mandatory
cleanup activities.
Without detailed study of the time required, it is postulated that theplanning and preparation phase spans about 18 months for SAFSTOR.
SAFSTOR activities are assumed
to start immediately after a comprehensive radiation survey is updated.

U

U-31
Planning and preparation includes the following considerations:Staff selection and training,
Regulatory requirements,* Data gathering and analysis,
Development of detailed work plans and procedures,
Design, procurement, and testing of special equipment,
Selection of specialty contractors, andRemoval of unneeded spent fuel storage racks (optional).
These considerations are discussed generically in Section U.2.
U.4.2

Methods, Equipment, and Other Information

Decommissioning methods, special tools and equipment, and essential systems and services used toprepare TMI-2 for SAFSTOR are discussed in this section. These methods and considerations, inorder of their presentation in the following sections, are:Decontamination, deactivation, and sealing methods,
Spray painting,Transfer of contaminated equipment and materials,
Decontamination and isolation procedures,
Special tools and equipment, andEssential systems and services.
U.4.2.1

Decontamination, Deactivation, and Sealing Methods

The decontamination methods that have been used in the decontamination of the AFHB also are used
for SAFSTOR. The methods are discussed in detail in Section 5.1.2 and 5.2.2 and are not repeated
here. 'Selected decontamination tasks may proceed concurrently. The primary concern is to ensurethat no recontamination of clean areas occurs and that air leaving a given area flows through afilter system or, in the case of liquid effluents, through the existing contaminated waste systems.
The particular method used to decontaminate, deactivate, and seal each system or piece of equipment
is identified during the planning phase.
In general, all systems not necessary to prevent the
spread of contamination are deactivated. Additional considerations are discussed in Section 5.1.3
and 5.2.3.
For SAFSTOR, portions of the facility that contain significant amounts of radioactivity are
isolated by tamperproof barriers.
Indirect access routes, however unlikely, are determined fromas-built drawings and sealed. Such routes may include, but are not limited to, access throughlarge vessels, tanks, or large-diameter pipes.
Barriers are constructed by welding or bolting
and sealing steel plates to block potential pathways of unauthorized entry or contamination
migration.
Polysulfide rubber is used extensively as a sealant because it is durable and flexible.
In the HVAC systems servicing these isolated areas, vents with HEPA filters are installed toallow for changes in air pressure and temperature; however, the systems themselves are deactivated.
Contaminated drains are decontaminated and building sumps are decontaminated and secured. In
some cases, after the sump pumps are decontaminated and/or removed, steel plates are welded inplace to cover the sump area.
U.4.2.2

Spray Painting

After the loose, readily removable contamination is removed by the physical cleaning methods
described in Section 5.1.3, and 5.2.3, the rooms or areas and their associated equipment are
thoroughly spray painted before isolation or removal procedures begin. Whenever possible, allcontaminated surfaces, both inside and outside, are coated to prevent the entrainment of radioactivity in the air during the active decommissioning tasks or during subsequent surveillance andmaintenance activities.
In general, if the contamination on a surface cannot be removed by wiping or washing using standard decontamination solutions, it is painted to fix the contamination in place. An example is aconcrete surface that has been penetrated by contaminated liquids. While the surface might becleaned initially, the subsurface contamination can migrate to the surface and be dispersed by

U-32
On protected, interior surfaces with essentially no traffic or
air movement and/or foot traffic.
adverse environment, the paint coatings can be expected to last almost indefinitely.
Part of thesurveillance program is to monitor painted areas for deterioration of the coatings and to recoatthem as necessary.
U.4.2.3

Transfer of Contaminated Equipment and Materials

Unsalvageable,
contaminated equipment and other miscellaneous noncombustible items may betransferred to other secured, onsite retrievable storage areas, as described in Chapter 8.
Likewise, wastes consisting of trash, expended EPICOR II resins, and chemical decontamination
solutions will be handled using the methods described in Section 8 and Appendix H.
It is anticipated that before transferring small equipment items, the items are carefully spraypainted to immobilize any contamination.
Freshly exposed surfaces are immediately painted toprevent dispersal of contamination.
The disconnected items are carefully bagged and transferred
to a retrievable storage area.
The equipment and ductwork remaining in the work area is physicallydecontaminated as described in Section 5.2 and spray painted as previously described.
U.4.2.4

Decontamination and Isolation Procedure

The 13-point procedure given below isfor SAFSTOR:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.

postulated to be used to prepare the contaminated areas

Conduct.initial radiation survey.
Vacuum interior surface areas.
Deactivate nonessential systems and equipment.
Clean building interior surface areas and exposed surfaces of equipment and piping.
Clean remaining hot spots.
Apply protective paint.
Transfer, as feasible, contaminated equipment and materials.
Decontaminate and seal vent systems.
Install HEPA-filtered vents.
Deactivate remaining nonessential systems and equipment.
Install intrusion, fire, and radiation detection systems as necessary and provide for onssite
readout and servicing.
Conduct final radiation survey.
Secure the structure.

U.4.2.5

Special Tools and Equipment

Fewer special tools and equipment are required for the preparations for SAFSTOR than for DECON.
No decontamination of highly activated material- or equipment is necessary, thus eliminating
the need for and expense of special remote handling equipment.,
A listof special tools and equipment postulated for use in preparations for SAFSTOR,
with their functions, is given in Section U.2.2.
U.4.2.6

together

Essential Systems and Services

During preparations for SAFSTOR, certain facility systems. and services must remain in placeand in service for contamination control, for industrial or personnel safety, and to aid in
the completion of decommissioning tasks.
These systems and services are the same as thosedescribed in Section U.2.2 and are not repeated here.
As areas within the facility are secured for continuing care, the essential, systems and services
in these areas are deactivated as described previously.
Continuous service to the remaining
work areas is maintained as required.
After placing the facility in SAFSTOR, certain systems and services are required during thecontinuing care period.
These systems and services are listed in Table U.19, together withthe justification for retaining each.
The equipment in these systems. is inspected andrenovated to ensure adequate reliability before the surveillance and maintenance period begins.
In addition, it is assumed for this analysis that for as long as fuel is stored at TMI-2 theintrusion alarm systems within the facility and on the perimeter fence are modified as necessary
to provide surveillance capability by the existing onsite security force.

i~

U-33

Table U.19.
Systems and Services Required
During the Continuing Care Period
Systems and Services
Electrical power

Operations of electrical equipment,
including lighting, surveillancemonitoring, and radiation monitoring
systems and alarms

Fire protection system

Health and safety

In-Plant communications
system (telephone)

Personnel safety considerations

Security systems

U.4.3

Justification

Public safety and plant protection
considerations, including fuelstorage (a recognized optional
consideration)

Decommissioning Activities

The postulated facility status for the start of all of the decommissioning alternatives used forthis analysis is described in Section U.1 and is not repeated here.
The decommissioning activities
for SAFSTOR start with the shipment of the irradiated fuel assemblies and recovered spent fuelpieces to a disposal facility. The fuel shipments continue relatively unabated until all irradiated fuel is removed from TMI-2.
The schedule for the fuel shipments, including manpower, estimated occupational doses, and associated costs, are the same as those described in Section U.3
for DECON.
At the start of SAFSTOR decommissioning activities for TMI-2, prodigious amounts of various types
and sizes of shielding materials, special tools, equipment, instruments, in-place staging, andother beneficial but currently undefined hardware will be in-place arid/or onsite and ready to use
for active decommissioning.
Undoubtedly, this material will aid in the decommissioning effort.
On the other hand, all material that was previously used must be assumed to be contaminated tovarying degrees as a result of the post-accident recovery and cleanup efforts for which it was
originally purchased.
Therefore, whether any such material is reused for SAFSTOR activities (anadvantage and cost savings) or is simply in the way (a costly disadvantage), it must eventuallyeither be decontaminated, disposed of as radwaste, or reused elsewhere.
The potential volume ofthis onerous material is currently unknown and therefore is not addressed in this analysis.
A comprehensive radiation mapping of the reactor containment building and the AFHB is completed.
The objective of this mapping (both the initial effort and those of an ongoing nature that occur
throughout the preparations for continuing care) is to:(1) acquire and update technical dataneeded to plan for additional decontamination, (2) assess the current condition of the buildings
and equipment, and (3) provide necessary maintenance for equipment needed during the preparations
for continuing care to prevent radioactive releases or to implement decontamination activities.
The technical data needed include current radiological surveys, isotopic analyses, and radiologicalmapping to identify hot spots and assess decontamination requirements and likely locations for
additional shielding/radiation barriers.
The mapping and assessment is postulated to consist of
entries of* relatively long duration during which detailed surveys of radiation fields, including
ductwork and other equipment, are made.
The TMI-2 site and pre-accident support facilities are
given a comprehensive radiation survey and are assumed in this analysis to be released for unrestricted use without further effort.
The duration of events during SAFSTOR preparations for continuing care is shown in Figure U.5.
The decontamination and preparations for continuing care of TMI-2 is estimated to require about
30 months.

I__ I

U-34

YEARS AFTER START
OF DECOMMISSIONING
DECOMMI SSIONING ACTIVITY

0

1

2

I

I

3
-

I

4
__

CLEANUP AND FIXATION OF CONTAINMENT BLDG.
CLEANUP AND FIXATION OF AFH BLDG.
CLEANUP AND FIXATION OF OTHER BUILDINGSHCONTROL AND SERVICEHCONTAINMENT SERVICE
LIQUID RADWASTE PROCESSINGHSHI PMENT OF SPENT FUELPROCESSING AND SHIPPING OF RADWASTE

Figure U.5.

Duration of Activities Preparing for Safe Storage.

A brief discussion of the postulated preparations for SAFSTOR of the TMI-2 unit
the following sections.
U.4.3.1

is presented inContainment Building

Post-accident recovery and cleanup activities are assumed to have left the containment building
in a radiological condition such that additional decontamination is required (see Section U.1 fordetails).
As mentioned earlier, the chemical decontamination of the RCS and intertied systems isassumed to be completed following the defueling and disabling of the reactor.
Radiation andcontamination levels allow for controlled but continuous access of decommissioning workers into
the containment building.
Large amounts of the shielding materials used for the massive postaccident cleanup effort are assumed to either be in place or readily available to use for decommissioning activities in the containment buirlding and elsewhere.
Other materials and equ.ipmentin this category also may prove useful to the overall decommissioning effort (see Section 6.1.5).
Decommissioning parameters (e.g., volumes of waste, occupational dose, and total costs) aredirectly impacted by the radiological condition of the buildings at TMI-2 at the start of the
preparations for continuing care.
What these conditions will be is unknown; however, in Section U.1, the postulated facility status is discussed.
In addition, several assumptions are
considered as necessary preconditions to clarify this SAFSTOR decommissioning analysis for thereactor containment building.
These assumptions are given in the following paragraphs.
For the fuel transfer canal(FTC)

the following assumptions apply:

1.

Ultimate disposition of tritiated water has not currently been decided.

2.

The FTC is decontaminated with water jets as it is drained; water is processed before being
returned to storage after defueling operations; additional decontamination (including hot
spots) is followed by painting.

3.

Decontamination of fuel storage racks is reasonably effective;
painted and left in storage during continuing care.

therefore the racks are

U

U-35
For general decontamination efforts
tions are made:in the reactor containment building,the following assump-renovated,

and left in-place

1.

Essential building systems and services have been restored,
after the post-accident recovery cleanup effort.

2.

The upper boundary radiological condition for the general decontamination activity is estimated to require a 60:40% mixture of water-jet and hands-on work, respectively, for all
surfaces requiring additional decontamination before being painted.

3.

The decontamination efforts described in the above assumption are assumed to be used on
one-third of the total inside surface area of the building, including equipment therein.
(Itshould be recognized that the same surfaces in all cases will not necessarily require
both methods of decontamination.)

4.

Waste solution generation rates are based on:
2
Water-jet methods at about 6 gpm; 2-person crews; and a cleaning rate of about 500 ft /hr/crew.
2
Hands-on methods at about 25 gph; 4-person crews; and a cleaning rate of about 165 ft /hr/crew.

5.

Two 4-person crews/shift, using a man-lift, are required for painting.
The painting rate
per crew is estimated to be about 2500 ft 2 /hr.
Since it is assumed that all building internalsurfaces have been decontaminated at least once by this time, all building surface are
painted, thus immobilizing any remaining contamination.

6.

A minimum of 56,000 gallons of contaminated water from semi-remote decontamination and about
6,800 gallons of decontamination liquids are estimated to require processing.

7.

Of the four alternatives for equipment decontamination, only in-place decontamination andcertain disposal activities are considered necessary during the preparations for continuing
care.

8.

The sump water processing system is assumed to have been removed.

9.

Processed accident-generated water (i.e., all radionuclides removed except tritium) is used
for all water-jet washing activities so that the total inventory of contaminated water is
not increased.

10.

Hot spots that were shielded earlier will either be decontaminated or the shielding left inplace, depending on surveillance, maintenance, and survey worker'-s needs during continuingcare (an ALARA consideration).

Finally, the RPV shielding blocks are assumed to be placed above the'reactor in their normal
position for the continuing care period.
The estimate of the work required to prepare the reactor containment building for continuing careis based on the analysis of necessary decommissioning activities, including the assumptions justgiven, previous studies, 1 - 3 and engineering judgement.
In general, the work involves additionalsemi-remote and hands-on decontamination activities of the type previously described in Chapter 5.
As a result of predefueling decontamination work, it is anticipated that the levels of radiation/
contamination at the start of the preparations for continuing care will be the same as thosepostulated in Section U.1.
The sequence and schedule of events for preparing the reactor containment building for the continuing care period is given in Figure U.6.
U.4.3.2

Auxiliary and Fuel Handling Building

Once the comprehensive radiation mapping of the AFHB (see Section U.4.3) has been completed thenext activity to get underway is the shipment of the spent fuel and recovered spent fuel pieces
to a storage facility, a reprocessing facility, or a disposal facility offsite.
Assuming an
IF-300 cask (capacity seven elements) is used, with an 18-day round-trip cycle, 26 trips will be
required to remove the 177 fuel elements, or about 16 months elapsed time.
Availability of
another spent fuel shipping cask of similar capacity would reduce the fuel shipment period toabout 8 months.
The postulated sequence and schedule of tasks for the preparations for continuing care of the
AFHB is shown in Figure U.7.
For the start of decommissioning activities in the AFHB, it isMONTHS AFTER START OF DECOMMISSIONINGTASK

1PREDECOMMI SSIONING FACILITY RADIATION MAPPING

-

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

1]7 8

6155011

DECONTAMINATIONa
347-ft LEVEL
305- ftLEVEL
OSTG CUBICLES AND EQUIPMENT
RPV HEAD AND CAVITY
282 -ft LEVEL
305-1f LEVEL ENCROACHMENT AREA

16/410/0.6
16/29010.3
161330/0.3
S16/170/0.1
16/680/0.6
18/64010.3

CHEMICALLY DECONTAMINATE DRAIN SYSTEMSPAINTING (ALL REQUIRED SURFACES)

4--- 10/550/1... •16/2300/1.1

PROCESSING AND SHIPPING OF RADWASTE:
16/1056/0.5.

OPROCESS DECONTAMINATION WATER-JET WATER (-56, 000 GALLONS)-oPROCESS HANDS-ON CHEMICAL DECONTAMINATION SOLUTIONS(-6,800 GALLONS)*PROCESS SOLID, DRY TRASH (-150 COMPACTED DRUMS)OPROCESS DRAIN DECON FLUIDS (-7,900 GALLONS)-----

16/1875/1.2
2/210/0.6-

ISOLATE AND SEAL EQUIPMENT AND AREAS AND INSTALL
HEPA-FILTERED VENTS

16/3240/1.5
12/1580/1

8/530/0.5

DEACTIVATE UNNECESSARY UTILITIES

5/660/1

INSTALL INTRUSION, RADIATION MONITORING, AND FIRE ALARM
SYSTEMS-

FINAL RADIATION SURVEY

aDECONTAMI NATION INCLUDES: (i) SEMI -REMOTE DECONTAMI NATION, (2) HANDS -ON
DECONTAMI NATION, AND (3) REMOVAL OF POST-ACCI DENT RECOVERY MATERIALSAND EQUIPMENT LEFT IN PLACE TO AID THE PREPARATIONS FOR CONTINUING CARE.
THIS SCHEDULE COULD BE S IGNIFICANTLY INFLUENCED BY MANY FACTORS THAT ARENOT PRECISELY KNOWN AT THIS TIME. THESE INCLUDE, BUT ARE NOT LIMITED TO,
THE EXACT RADIOLOGICAL CONDITIONS ENCOUNTERED UPON COMPLETION OF INITIALDECONTAMINATION EFFORTS, FINANCIAL LIMITATIONS, REGULATORY ACTIVITIES,CRAFT LABOR AND MATERIAL AVAILABILITY, AND AVAILABILITY OF OFFSITE ORONSITE RADWASTE DISPOSAL CAPABILITY ON A TIMELY BASIS.

Figure U.6.

C

0'1

4/350/1
LEGEND:
DIRECT STAFF PER DAY/EXPOSURE HOURS/CALENDAR MONTHSCONTINUOUS OPERATIONS OVER THE TIMESPAN SHOWN---- .INTERMITTENTOPERATIONS OVER THE TIMESPAN SHOWNTOTALS: PERSON-MONTHS149
PERSON-HOURS
25, 838EXPOSURE-HOURS 15,421

Postulated Sequence and Schedule of Tasks for SAFSTOR of theReactor Containment Building.

m

MR

MONTHS AFTER START OF DECOMMI SSIONING
1 2 3 4TASKSSHIP FUEL(26 SHIPMENTS)

56

7 8 9 10 11

12 3 14 15 16

Z 18 1?9221 2?2613800/3: ONECASK-- USED4

2,6 27282? 9 3 33 3? 3

_4 3•

-iTWO CASKS USED

461550/1-----.-PREDECOMMISSIONING FACILITY
RADIATION MAPPING

I--- --

GENERAL CLEANUPDRAIN SFP, WATER-JET CLEAN, AND
STABILIZE CONTAMINATION (ALSO
SEE PROCESSING OFRADWASTE, BELOW)

4/26010.5
-

I----

--

DECONTAMINATION (ALLLEVELS; INCLUDESEQUIPMENT AND STRUCTURAL SURFACES)

410/32011

1617890/5.6-4- 106550/11

CHEMICALLY DECONTAMINATE DRAIN
SYSTEMS

161500012.3

PAINTING (ALLREQUIRED SURFACES)ISOLATE AND SEAL EQUI PMENT"AND AREAS
AND INSTALL HEPA-FILTERED VENTS

4

-

4I

1217400/4.7
4-- 8/550/0.5

DEACTIVATE UNNECESSARY EQUIPMENT AND
UTILITIESINSTALL INTRUSION, RADIATION MONITORING
AND FIRE ALARM SYSTEMS

10/600/1

PROCESSING AND SHIPPING OFRADWASTE:" PROCESS DECONTAMINATION WATER-JET
WATER AND SFP WATER (-757, 000 GALLONS)

I 16!15,12016.9* PROCESS HANDS-ON CHEMICAL DECONTAMINATION SOLUTIONS (-21,500 GALLONS)-61616480/3" PROCESS SOLID, DRY TRASH (,-600 COMPACTEDDRUMS).

CA

- --

----

--

---

2/800/2.3

16/3240/1-5" PROCESS DRAIN DECONTAMINATION FLUIDS(-7,900 GALLONS)

4/350/1

FINAL RADIATION SURVEY

LEGEND:
THIS SCHEDULE COULD BESIGNIFICANTLY INFLUENCED BY MANY FACTORS THAT ARE NOTPRECISELYKNOWN ATTHIS TIME. THESE INCLUDE, BUTARE NOT LIMITED TO,THEEXACT RADIOLOGICALCONDITIONS ENCOUNTERED UPON COMPLETION OFINITIAL DECONTAMINATION EFFORTS, FINANCIAL
LIMITATIONS, REGULATORY ACTIVITIES, CRAFT LABOR AND MATERIAL AVAILABILITY, AND
AVAILABILITY OFOFFSITE OR ONSITE RADWASTE DISPOSAL CAPABILITY ONA TIMELY BASIS.

DIRECT STAFF PER DAY/EXPOSURE HOURS/CALENDAR MONTHS-ICONTINUOUS-.-

OPERATIONS OVER.THE TIME SPAN SHOWNINTERMITTENT OPERATIONS OVER THETIME SPANSHOWNTOTALS:

Figure U.7.

PERSON -MONTHS
446
PERSON-flOURS
78,462EXPOSURE-HOURS 53,910

Postulated Sequence and Schedule of Tasks for SAFSTOR of the
AFH Building.

I

U-38
assumed that all radioactive liquids in tanks and systems that are unneeded for subsequent decommissioning activities have been drained and processed.
This assumption appears to be reasonable
based on decontamination efforts to date and on the status of those still to be completed (seeSection 5.1 and Appendix 0).
In general, decontamination activities start on the upper levels and proceed toward the lower
levels.
The spent fuel pool cleanup system will remain in service until shipment of spent fuelis completed.
Since considerable post-accident decontamination work, both initial and follow-on, will have been
done prior to the start of decommissioning, it is assumed that the radiological conditions in the
AFHB are somewhat improved over those described in Section U.1 for the reactor containment building.
In practical terms, this means that similar contamination activities (semi-remote and hands-on)
will be necessary to prepare the AFHB for continuing care, but to a lesser degree than in thecontainment building, because of the generally lower overall average radiation/ contaminationlevels.
However, since it is necessary to decontaminate and/or immobilize a greater total surface
area in the AFHB than in the reactor containment building, the result will be a net increase inoccupational hours consumed and volumes of wastes produced.
U.4.3.3

Other Buildings

The other buildings associated with TMI-2 that contain any quantities of radioactivity are thecontrol and service building, the containment service building, and the liquid radwaste processing building (if built).
It is postulated that the chemical cleaning building (EPICOR II),EPICOR-I, the radiochemistry hot lab, the resin solidification and mid-high level radwaste staging
facility (if built), and the solid radwaste staging modules will remain onsite and servicable foruse with TMI-1.
Control and Service Building
Radioactively contaminated equipment in this building is limited to the contaminated drain systemand the isolation valve tanks and pumps on the 280-ft level, the monitoring and soiled laundryareas on the 305-ft level, and the decontamination filter assembly on the 351-ft level.
Since
all systems and services are controlled from this building, it will be the last to be decontaminated.
Containment Service BuildingThis structure is basically an extension of the containment building, enclosi'ng the equipment
hatch and providing a staging area for shipping of packaged material from the containment building.
It is postulated that the decontamination effort in this building is limited to surface cleaning,since the materials are mostly already packaged before removal from containment.
Liquid Radwaste Processing BuildingThis structure does not presently exist and its contents can only be postulated.
Likely systems
include a radwaste evaporator and a liquid waste solidification system.
Decontamination anddeactivation of these systems is delayed until decontamination of the reactor containment and AFH
buildings is complete.
U.4.4

Waste Volumes from SAFSTOR

Preparing TMI-2 for safe storage will produce radioactive wastes from four different sou-rces:
1.
2.

Water-jet cleaning liquid from the reactor containment building and water-jet cleaning
liquid, plus SFP draining liquid, from the AFH building,Hands-on chemical decontamination solutions from all sources,

3.

Dry,

4.

Chemicalsolid waste from all sources,anddecontamination solutions from contaminated drains.

A summary of the estimated radioactive waste volumes from all four sources is given in Table U.20,
along with estimated numbers and types of containers postulated used for disposal and/or storage
and their estimated burial volumes..

Table U.20.

Locationa
RCB

SourceEnd ProductWaste Form

Waste
Processing
MethodResin
FilterEPICOR-II

Hands-ondecontamination

Concreted

Solidification

6,800 galSolidification

Water-jetConcreted
Compactedd
materialResin

decontamination

FilterHands-ondecontamination
Drains DECON
solutionDry, solid waste

Compaction
EPICOR-II

Estimated
Number andType of Disposable
Waste Containers
55-gal drum at
50-ft 33
7.5 ft /eachLinerAmount& Units

Water-jetdecontamination

Drains DECON
solutionDry, solid waste
AFHB

Estimated Volumes of Radioactive Waste from Preparing TMI-2
for Safe Storage

56,000 gal

_c
1

10

Estimated
BurialVolume(ft 3 )

-

500
7.5

217

-

1,627.5

7,925 gal

182

-

1,365

726 drumsd
757,000 gale145-

1,087.5
6,750

135
6

45

Concreted

Solidification

21,500 gal

677

5,077.5

Concreted
Compactedd
material

Solidification

7,925 gal

182

1,365

d
Compaction

2,970 drums

Total

594

-

4,455

2,004

145

22,280aRCB is the reactor containment building; AFHB is the auxiliary and fuel handling building.
bThe number of significant figures shown is for computational convenience and does not imply precision of tha
degree.
cDash (-)

means not applicable.

dCompacted at a 5:1 ratio.
eIt is postulated that the SFP is water-jet cleaned step-wise as itis being drained; 700,000 gallons of thisamount represents the SFP inventory, with the remaining 57,000 gallons being generated from all AFHB waterjet cleaning activities.

t

U-40
U.4.5

Effluents and Releases to the Environment

Under normal storage, transportation, and disposal conditions, no routine effluents or releases
from the waste packages or transport vehicles are expected. "Normal" transport is the situation
when transport occurs without unusual delay, loss or damage to the package, or an accident involving the transporting vehicle.
The various types of packages that may be used to ship the TMI wastes are designed to prevent any
releases during storage, handling, transportation, or disposal operations if their integrity is
maintained. Thus, no impact on the environment from this source will occur.
The atmospheric release of radionuclides' is assumed to be the only source of radiation to the
public from 'outine decommissioning operations. All liquid radioactive wastes generated duringdecommissioning operations are assumed to be sent to the plant liquid waste storage system or toother tanks that are designated for ,temporary *storage of these solutions. The wastes are thenassumed to be processed through the waste concentration and solidification system. All systems
designed to control the release of hazardous material to the environment or to noncontaminatedportions of the facility are assumed to be in operation during the decontaminationactivities andsubsequent waste processing.
The primary source of radioactive effluents from routine decommissioning operations while preparing
the plant for safe storage is contaminated liquid aerosols that result from the various decontamination activities.
An analysis of the generation of airborne radioactivity during decommissioning operations at alarge PWR is given in Appendix J of Reference 1, with the results of that analysis summarized inTable U.7. Only one of the DECON operations listed in Table U.7 is of significance during the
preparations for safe storage: water-jet cleaning, with a postulated release of about 10 pCi.
The release involves the radionuclide mixture defined as Reference Radionuclide Inventory No. 5,
as listed in Table U.11.
The releases postulated in Table U.7 do not include releases frompossible accidents involving transport of spent reactor fuel from the site to a disposal facility.
U.4.6

Environmental Impacts

The environmental impacts associated with the decontamination and minor disassembly operations
performed while preparing TMI-2 for safe storage are contained in three general categories:(1) the radiation dose to the workers involved in the disassembly, packaging, and transport of
the radioactive materials from the site to a disposal facility; (2) the radiation dose to the
public resulting from releases of radioactivity from the site during decommissioning operations
and from radiation emanating from shipments of radioactive waste while in transit on public
highways or railways; and (3) the commitment of space in a.low-level radioactive waste burial
ground for the disposal of the radioactive materials from the plant. The impacts associated witheach of these categories are discussed in the following:sections.
U.4.6.1

Estimated Occupational Radiation Dose from SAFSTOR Activities

The radiation dose accumulated by the workers performing SAFSTOR activities is estimated bymultiplying the average local radiation dose rate for a given task.times the number of worker
exposure hours estimated for that task, and summing Over all tasks. The average local dose rates
for.general areas in the reactor containment building, the AFH building, and other buildings are
given in Table U.21.
Also given are cumulative exposure hours for persons working in thosegeneral areas, taken from Figures U.6 and U.7, the computed cumulative dose to the workers accomplishing tasks in those areas, and the total radiation dose received by workers while performing
SAFSTOR operations.
The estimated dose received by the transportation workers during the transport of packaged radioactive wastes, based on an assumed realistic dose rate for each shipment as given in Section 9.5.1.1(56 millirem/trip/driver), is given in Table U.22. The estimated dose received by railway workers
during the transport of the spent reactor fuel, based on information developed in Section 11.4.1
of Reference 1, is also given in Table U.22.

U

U-41

Table U.21.

Estimated Cumulative Radiation Doses Received
by Workers During SAFSTOR Operations
Average
Local
Dose Rate(rem/hr)

Estimated
WorkerExposure
Hours

Cumulative
Radiation
Dose(person-rem)a

0.017

550

9.35

0.005
0.010
0.030
0.030
0.030
0.003
0.001
0.006

410
290
330
170
680
640
550
2,300

2.05
2.9
9.9
5.1
20.4
1.92
0.55
13.8

0.002

1,056.

2.11<0.001

1,875

0.65

0.003

210

0.63

<0.001

3,240

0.6

0.005
0.003

1,580
530

7.9
1.59

Install intrusion, radiation
monitoring and fire alarm systems

0.002

660

1.32

Final radiation survey

0.003

350

1.05

0.003

3,800

11.4

0.005
0.004

550
260

2.75

0.004

1,320

5.28

0.002

7,890

15.78

0.001

550

0.002

5,000

10

Isolate and seal equipment and areasand install HEPA-filtered vents

0.005

7,400

37

Deactivate unnecessary equipment andutilities

0.001

550

Location and Task
Reactor Containment Building
Predecommissioning facility radiation
mapping
Decontamination:
347-ft level305-ft level
OSTG cubicles and equipment
RPV head and cavity
282-ft level305-ft level encroachment area
Chemically decontaminate drain systems
Painting (all required surfaces)
Processing of radwaste:
Process Decontamination Waterjet water (-.56,000 gallons)
Process hands-on chemical
decontamination solutions(,6,800 gallons)
Process solid, dry trash (n150compacted drums)
Process drain decon fluids(,\7,900 gallons)
Isolate and seal equipment and areasand install HEPA-filtered vents
Deactivate unnecessary utilities

Auxiliary and Fuel Handling Building
Ship fuel (26 shipments)
Predecommissioning facility radiation
mapping
General cleanup
Drain SFP, water-jet clean, andstabilize contamination (also see
processing of radwaste, below)
Decontamination (all levels; includes
equipment and structural surfaces)
Chemically decontaminate drain systems
Painting (all required surfaces)

1.04

0.55

0.55

U-42

Table U.21.

Location and Task
Install intrusion,(Continued)
Average
Local
Dose Rate(rem/hr)

Estimated
WorkerExposure
Hours

Cumulative
Radiation
Dose(person-rem)a

0.001

600

0.6

0.002

15,12030.24<0.001

6,480

2

0.003

800

2.4

'-0.001

3,240

0.6

0.002

350

0.7

0.003

5,000

15

radiation monitoring

and fire alarm systems
Processing of radwaste:
Process decontamination water-jet
Water and SFP water(-v757,000 gallons)
Process hands-on chemical decontamination solutions(,21,500 gallons)
Process solid, dry trash(^600 compacted drums)
Process drain DECON fluids(-.7,900 gallons)
Final radiation survey
Other BuildingsAlllevels

218b

Total

aThe number of figures shown is for computational accuracy and does not imply
precision to that many significant figures.
bRounded to the nearest person-rem.

Table U.22.
Estimated Cumulative Radiation Doses Receivedby Transport Workers During SAFSTOR Operations

WorkerType
Truck drivers
Train crew

Dose/Shipment(millirem/driver)

Number of
Shipments

Cumulative
Radiation Dose(person-rem)

56
120

114
26

1 2 . 8a6 . 2aTotal
aAssumes two drivers/truck, two, brakemen/train.

19

U-43

U.4.6.2

Offsite Doses from SAFSTOR Activities

The dose estimates presented here for the SAFSTOR decommissioning operations are based on thesource terms described in Section U.4.5 and on the assumption that decommissioning activities
The
take place 10 years after the TMI-2 accident (11.4 micro-curies of reference inventory 5).
calculational models used to make these estimates and the interpretation of their results aredescribed in Appendix W. The significance of these doses and their human health and environmental
The dose estimates to the maximum-exposed individual
consequences are discussed in Section 10.3.
The 50-mile total body population dose received by the human population
are listed in Table U.23.
during these activities is estimated to be 7 x 10-s persons-rems.

Table U.23.
Estimated Doses to the Maximum-Exposed Individualfrom Normal Decommissioning Activities (SAFSTOR)
Dose (mrem)a
Location

Pathway

Total-Body

Bone

Liver

Nearest b
gardenInhalation
Ground Shine
Vegetable Use

1.6 x 10-7
6.4 x 10-7
*3.6 x 10-6

3.6 x 10-7
6.4 x 10-7
1.6 x 10-5

3.0 x 10-7
6.4 x 10-7
1.5 x 10-s

4.4 x 10-6

1.7 x 10-5

1.6 x 10-5

1.4 x 10-7
6.1 x 10-7
9.7 x 10-6

1.9 x 10-7
6.1 x 10-7
7.5 x 10-5

2.0 x 10-7
6.1 x 10-7
8.8 x 10-5

1.0 X 10-s

7.6 x 10-5

8.9 x 10-s

1.7 x 10-7
9.4 x i0-7
5.3 x 10-r
3.6 x 10-6

3.9 x
9.4 x
2.4 x
1.8 x

I0-7
10-5

10-5

3.3 x 10-7
9.4 x i0-7
2.2 x 10-5
1.7 x 10-5

1.0 x 10-s

4.3 x 10-5

4.0 x 10-'

Total

,Nearest
milk goat

Inhalation
Ground Shine
Goat Milk Use
Total

Nearest cow
and garden

Inhalation
Ground Shine
Vegetable Use
Cow Milk Use
Total

aDoses were calculated for Total-body,

Gl-tract,

10-7

bone, liver, kidney,

thyroid, lung and skin. The maximum three organ doses are listed in thistable.
Doses were calculated for four age groups:
adults, teenagers,
children, and infants.
The highest dose estimates for each age group are
listed. The dose estimates for the total-body pathway are for adults.
The dose estimates for the bone and liver pathways for the nearest
garden and nearest cow and garden locations are for children, and for thenearest goat location are for infants.
bThe basis for selecting the special locations is described in Appendix W.
The actual locations were:
nearest garden = 1.05 mile east-north-east,nearest milk goat = 1.02 mile north, and nearest cow and garden= 1.05 mile east.

The estimated radiation dose to the public resulting from transport of radioactive materials
offsite is presented in Table U.24 for both truck and rail transport.

U-44

Table U.24.

Estimated Radiation Dose Received by the Public
During Transport of Radioactive Waste
from SAFSTOR Operations

Type of Shipment

Number of
Shipments

Dose/Shipment(person-rem)

PublicRadiation Dose(person-rem)

114

0 .053a6.04

26

0 . 0 2 9 3b

0.76

Radioactive
material (truck)
Spent reactor fuel(rail)
Total

6.8

aBased on data given in Section '9.5.1.2.
b~ased on data given in Section 11.4.1 of Reference 1.

U.4.6.3

Other Environmental Effects

Other impacts on the environment surrounding the TMI station resulting from SAFSTOR of Unit 2
will be similar to those discussed in Section 10.6, but of lesser magnitude because there will be
fewer workers involved in SAFSTOR and because gross contamination cleanup efforts will have been
completed before the start of decommissioning.
Continued storage of the bulk of the radioactive materials onsite during SAFSTOR might tend tocontinue the existing levels of anxiety in the local community, even though the readily dispersible
materials have been solidified and packaged.
Not shipping these materials to a disposal sitewould tend to reduce the anxiety levels among the populace along the transport routes until
deferred decontamination takes place.
The number of persons

employed at the TMI

site will be reduced when Unit 2 has been placed insafe storage, thus reducing the local payroll.
U.4.7

Estimated Costs for SAFSTOR

The principal cost items for SAFSTOR are labor, waste disposal, spent fuel disposal, and energy.
Other costs include special equipment, specialty contractors, licensing and insurance, and miscellaneous supplies.
The bases for the costs presented here are given in Appendix H and Section 10
of Reference 1, and are adjusted for escalation between early-1978 and mid-1980, as discussed in
Section U.3.5.
The costs are summarized in Table U.25, with the estimates of the principal cost
items developed in the following sections.
U.4.7.1

Decommissioning Labor Costs

The basic decommissioning crew is postulated to consist of seven members: 'a crew leader, autility operator, two laborers, two craftsmen, and a health physics technician.
The averagesalary cost per hour per crew member developed from data given in Table 1.1-1 of Reference 1.
escalated by 17%, is $15.12.
From Table 10.2-2 of Reference 1, the ratio of crew labor cost to
total decommissioning labor cost is 2.63.
The direct decommissioning crew labor hours for the
principal buildings and activities are given in Table U.26, summarized from Section U.4.3.
U.4.7.2

Radioactive Waste Disposal Costs

The radioactive materials requiring disposal during SAFSTOR of TMI-2 consist of the sources andend product waste forms given in Table U.20; these are:Resins and filters from water-jet decontamination,
Hands-on and drains decontamination solutions, andDry, solid waste.
Estimates of the costs of disposing of these materials are summarized in Table U.27.

I

U-45

Table U.25.

Summary of Estimated Costs for SAFSTOR
Cost in Millions ofMid-1980 Dollars

CategoryI

Decommissioning labor
Direct1.887

SupportRadwaste disposal

3.044

Spent fuel shipment

2.496

EnergyOther costs:

2.64

Supplies'Equipment
Contractors
Nuclear insurance
Licensing fees

1.044
0.088
.0.1230.344
0.045

Subtotal

12.9251.214

25% contingency

3.231

Totala.

16.2

aTotal rounded to three significant figures.

Table U.26.

Activity

Estimated Labor Costs for SAFSTOR

Direct Crew
Hours

Labor Costin Million of Dollars
Direct Crew
Total

Containment building

16,616

0.251

0.660

AFH building

45,550

0.689

1.812

Other buildings

15,206

0.230

0.605

Radwaste processing
and shipping

42,134

0.637

1.675

Spent fuel shippinga

5,280

0.080

0.179

124,786

1.887

4.931

Total
aBased on Table U.17.

I

I

I

I

I

Table U.27.

Radioactive
Material
Dry,

Number of
Disposable
Containersa

solid wastes

Decontamination
solutions

Solidification
Costa(

Estimated Costs for Disposal of Radioactive Wastes from SAFSTOR

Container
Costs ($)

Estimated
NumberRequiring
Shielding-Cask
RentalCosts$)

Number of
Shipments
Shielded/ f
Unshielded

Transportation
Costs
($)I

Handling.
Costs ($)

BurialVolumes(ft 3 )

Burial
Costý
(5)

Total
Disposal
Costs ($)

739

0

14,780224

28,80016/6

125,400

11,2005,550

49,570229,750

1,258

15,59025,16000

0/18

102,600

0

9,435

82,090225,440

Water-jet and SFP
liquids
Filters

7

0

140

7

1,800

1/0

5,700

350

53

500

8,490

Resin

145

10,27072,500145

131,400

73/0

416,100

50,7507,250

68,880749,900

Totali

2,149

25,860112,580376

162,000

90/24

649,800

62,30022,288201,040

1,213,580

7
aBased on Table U.20.
bAssumes solidification costs of $1.77/ft3 and based on the internal volumes of the specific container that is used.
cAssumes 55-gal steel drum cost-of $20 each and 50-ft 3 steel cask liner of $500 each.
dAssumes rental fee of $300/day, a 6-day cycle for each shipment, a maximum of seven drums per cask,

and one 50-ft 3 container per cask.

eAssumes two casks per shipment.
fAverage load is about 88 unshielded drums for dry, solid wastes.
weight considerations.

An average laod for concrete drums is about 73 unshielded drums, based on

gAssumes a transport cost of $5700/round trip, $3700/one-way.
hAssumed to average $350/cask liner, overweight objects $@87.50 + (0.02/lb >10,000 Ib).
iAssumes burial charges of $8.70/ft 3 , liner and curie surcharges as- given in current NECO price list; surface dose rates assumed to be 0.21 to
1.00 R/hr for those drums requiring shielding during shipment, <0.2 R/hr for all others; rounded.to next highest $10.
JThe number of figures shown is for computational

accuracy and does not imply precision to that many significant figures.

4ý
M

U

U-47

U.4.7.3

Spent Fuel Disposal Costs

Assuming that 177 fuel bundles are shipped in a large rail cask (IF-300) that can carry seven
The spent fuel receiving facility is assumed tobundles per shipment, 26 shipments are required.
be located 1,500 miles from TMI-2, and an 18-day round-trip cycle is maintained.
A cask rental of $3500/day is
The transportation costs are assumed to be $33,000 per trip.
assumed.
Thus, the cost for removing the spent fuel from the TMI-2 facility is ($3500/day)No(18 days/trip) + $33,000/trip = $96,000/trip, for a total of $2.5 million for 26 trips.
charges are included for handling and eventual disposal of the fuel at the final destination.
U.4.7.4

Energy Costs

Energy usage during decommissioning is comprised of electrical and fossil energy, in roughly
equal amounts.
The cost of energy is estimated.in References 1 and 3 to be about $2 million in1978 dollars.
Assuming an escalation factor of 32%, the energy costs are estimated to be $2.64
million.
U.4.7.5

Other Costs

Other cost items include miscellaneous supplies, special equipment, specialty contractors, nuclear
insurance, and licensing fees.
It is assumed that the cost of these items as presented in Reference 1, when escalated by 17%, are appropriate for the TMI-2 analysis.
Based on Table 10.2-1 ofReference 1 and Table 10.2-1 of Reference 3, these items are estimated to be $1.044, $0.088,$0.123, $0.344 and $0.045 million, respectively.
U.4.8

Deferred Decontamination

As mentioned elsewhere in this statement, it is preferable to restrict decommissioning alternatives to those that do not imply use of the TMI-2 site for storage of radioactive materials-beyond the normal operating lifetime of the other nuclear power reactor present on the site,which is approximately 30 years.
To terminate the nuclear license after a safe storage period of
about 30 years would probably require the dismantling of all originally contaminated systems todemonstrate their releasability.
Therefore, it is assumed that essentially the same operations
and waste volumes as described for DECON in Section U.3 could be expected, but with less total
occupational radiation dose because of decay of the radioactive contaminants.
The types and quantities of manpower used for surveillance and maintenance and the radiation
doses present in the plant will determine the cumulative occupational radiation exposure during
the continuing care period.
Based on Table H.4-4 of Reference 1, an occupational radiation dosein the range of 10 to 14 person-rem would be accumulated during the first 30 years of continuingcare.
Less than 4 person-rem total radiation dose would be accumulated during the subsequent
70 years.
Because a larger fraction of the total radioactivity present in TMI-2 is Cs-137 than
was the case -in the reference study, the cumulative dose may be somewhat larger than given in
Reference 1.
Based on the detailed cost estimates developed in Appendix H of Reference 1, and escalated by 17%
for inflation, annual continuing care costs of about $60,000 are 'stimated for TMI-2, excluding
the environmental monitoring program described elsewhere in this PEIS.
The same basic activities
decontamination.

that are performed

during DECON are also performed during deferred

The cost of deferred decontamination of TMI-2 after the plant has been placed in safe storage andmaintained for some period of continuing care can be estimated using the cost results reported in
the reference studies.1' 3 These results are summarized in Table U.28.

U-48

Table U.28.

Comparison of DECON and Deferred Decontamination Costs
from Reference Decommissioning Studies
BWR Study

PWR Study
Cost($ millions)% of DECON
Cost

Cost
($ millions)% of DECON
Cost

DECON

34 . 1 ab100

4 3 .6d100

Deferred decontamination after
10-30 years

2 9 .0 ac

85

3 5 .5e81

Deferred decontamination after
50-100years

22.5

6
66

2 6 . 4e61

Decommissioning ActivitybaFrom Table 10.1-1 of Reference 1.
bCost for facility demolition is deleted, $6.41 million + 25% contingency$8.01 million.

cFrom Table 10.4-1 of Reference 1.
dFrom Table 10.1-1 of Reference 3.
eFrom Table 10.4-2 of Reference 3.
The percentages of DECON cost for deferred decontamination after 10 to 30 years and after 50 to
100 years, from the reference studies, are averaged and used to estimate the cost of. deferred'decontamination for TMI-2, based on the DECON cost estimated in Section U.3.5 of this statement.
These estimated costs for deferred decontamination of TMI-2 are given in Table U.29.
Radiation doses and radionuclide releases during decommissioning are related to the radionuclide
inventory in the facility at the time the decommissioning activities take place.. The doses andreleases from deferred decontamination would be less than those for DECON (estimated previously
in Section U.3.4 of this statement) because:(1) the radionuclide inventory in the facility
would beý reduced by the decontamination efforts associated with the preparations for continuingcare and (2) the radionuclide inventory would decline during continuing care according to the
decay characteristics of the inventory.
Since the radioactivity of the dominant Cs-137 will have
only decayed to one-half its initial value after 30 years of safe storage, the utilization of
personnel unfamiliar with the facility and the refurbishment of systems and services needed forthe final decontamination will result in radiation doses to the workers only slightly less thanwere estimated for DECON.
Some reductions in radiation could be expected after 100 years of safe.storage, since the Cs-137 radioactivity would have decayed to about one-tenth of its initialvalue.
It is assumed that applicable shielding and contamination control is used during deferreddecontamination in the same manner as during DECON.
No quantitative estimates are made here forthe doses and releases from deferred decontamination.
However, based on the results of previous
studies 1 ' 3 it is anticipated that the doses and releases resulting from all phases of SAFSTOR(preparations for SAFSTOR, continuing care, and deferred decontamination would not exceed thoseresulting from DECON alone.

Table U.29.

Comparison of DECON and Deferred Decontamination Costs
for TMI-2% of DNCON

Cost in Millions ofDecommissioning Activity

Cost

Mid-1980 Dollars

DECON

100

52.8

Deferred decontamination after
10-30 years

83

43.8

Deferred decontamination after
50-100 years

63

33.3

aAveraged from values in Table U.28.

U-49
U.5

ENTOMBMENT (ENTOMB)ENTOMB means to encase and maintain property in a strong and structurally long-lived material(e.g., concrete) to assure retention until radioactivity decays to an unrestricted level.1 8 For
this analysis, it is assumed that entombment takes place within that portion of the containmentbuilding below the floor at the 305-ft level and within the cavities enclosed by the 0-ring andbiological shield structure.
These areas are already reasonably well enclosed within structurally
strong concrete walls and/or floors, and can be completely enclosed with nominal effort.
Accessto the containment building via the airlocks located on the 305-ft level must.be. maintained topermit bringing in radioactive materials for placement and, ultimately, structural materials forthe entombment barriers.
The remainder of the facility is decontaminated to levels permitting
unrestricted use of the space, with all radioactive materials removed and either placed within
the entombment structure or shipped offsite for disposal.
A reinforced-concrete entombment
barrier is then poured at the 305-ft floor level of the containment building and at the tops ofthe shielded cavities in the D-ring structure.
All penetrations through the containment wall into the entombment structure area are capped andfilled with concrete.
The containment-building airlocks are used to move contaminated materials
from other buildings into the containment building for placement in the entombment structure.
When the entombment is completed, the larger airlock is sealed, and the smaller airlock is securely
locked and fitted with an intrusion-alarm device.
(The smaller airlock remains operable to allow.
entry into the containment building for inspection purposes during the continuing care of theentombed plant.)
The upper portion of the containment building serves as a secondary barrier
over the top of the entombment structure.
If the radioactivity entombed at. the site includes significant levels of long-lived neutron
activation products (e.g., Ni-59 with an 80,000-year half-life and Nb-994 with a 20,000-year
half-life) as are present in the reactor vessel and internals, the required retention period~may
be exceedingly long (i.e., tens of thousands of years.or more), depending on the acceptable.
release limits for residual radioactivity.
This implies that the entombment structure mustremain inviolable for extensive periods of time.
There is currently no reasonable assurance ofsuch long-term integrity for man-made structures of this kind.
In addition, ENTOMB will likely,.
require continuation of the utility's nuclear license (and the associated financial and surveillance commitments) in perpetuity, unless either the long-lived radioactivity is removed. initiallyor the entombment structure is reopened (at some later time) and the materials stored inside aredisposed of offsite.
The latter 'case involves an additional decommissioning step, deferred.
decontamination, that is complicated by the necessity to break into and remove radioactive materials from a structure designed to retain its integrity under any but the most severe conditions.
In effect, ENTOMB creates a permanent onsite waste repository unless either deferred decontamination ultimately takes place or all long-lived radionuclides are initially removed, in whichcase ENTOMB still represents long-term onsite storage of significant quantities of radioactive
materials (long-term meaning beyond the normal operating lifetime of a power reactor, which isabout 30 years).
As discussed previously in this statement, alternatives that involve permanent waste disposal
onsite at TMI appear to be neither technically feasible nor compatible with current national
policies and regulatory guidelines for radioactive waste disposal.
It is unlikely that TMI could
be qualified for permanent disposal of either high-level or low-level wastes because of suchfactors as nearby population densities and hydrology.
(See Chapter 3 of this statement for
further details on these factors.)
It is the staff's position that TMI should not become a permanent waste repository site. Hence,
alternatives involving temporary onsite waste storage that would greatly increase the effort
required for subsequent removal and offsite storage are regarded by the staff as unacceptable.
Based on the aforementioned considerations and constraints, ENTOMB appears to be an unacceptable
alternative for the decommissioning of TMI-2.
It should also be noted that the costs for ENTOMB,
including the required expenditures for continuing care and deferred decontamination, are similar
to those for DECON.
Overall (including continuing care and deferred decontamination), ENTOMB isa more difficult and time-consuming alternative.
It thus appears that ENTOMB, as compared toU-50 ,
DECON and SAFSTOR, is the decommissioning alternative of last resort for TMI-2 and would be
acceptable only if severe constraints were placed on the other two alternatives.
The estimates of labor hours, waste volumes, and costs for ENTOMB are derived largely from thosefor DECON because many of the activities required for the two alternatives are the same,. particularly those activities outside of the entombment structure area.
Estimates for activities
unique to ENTOMB are derived largely by comparison with the results of previous conceptual decom2
missioning studies,1'
adjusted as required for specific plant parameters and for cost escalationfrom the reference studies' base costs.
U.5.1

Decommissioning Activities for ENTOMBAs stated previously in Section U.3.1, it is assumed that by'the time the irradiated fuel has
been placed in the spent fuel pool in the AFHB and the reactor coolant system and associatedfluid handling systems have been chemically decontaminated, the necessary regulatory approvals
will have been received so decommissioning can proceed promptly.
Work begins in the reactor
containment building, proceeds through the AFHB, and concludes with the service and control
buildings.
The overall time schedule of ENTOMB activities is shown in Figure U.8 and is very similar to thatshown previously for DECON.
The duration of activities in the containment building is extended
somewhat to allow adequate time to move contaminated materials from the AFHB into the entombment
area. The duration of radwaste shipping activities remains the same, although less material isshipped offsite during ENTOMB than during DECON.
The overall duration of ENTOMB for TMI-2 isestimated to be nearly four years.

YEARS AFTER START
OF DECOMMISSIONING
DECOMMISSIONING ACTIVITY

01

2

DECONTAMINATION AND ENTOMBMENT
OF CONTAINMENT BLDG.
DECON OF AFHBDECON OF OTHER BUILDINGSCONTROL AND SERVICECONTAINMENT SERVICE
LIQUID RADWASTE PROCESSINGSHI PMENT OF SPENT FUEL
TREATMENT AND DISPOSAL OF RADWASTE

Figure U.8.

Duration of ENTOMB Activities.

.3

4

I

U-51
The major differences between activities for ENTOMB and those for DECON are in the containmentbuilding.
Activities in other portions of the plant are essentially the same for both alternatives.
U.5.1.1

Containment Building

ENTOMB requires removal of all radioactive materials outside of the postulated entombment structure.
Therefore, ENTOMB activities in the containment building outside of the entombment structure area
are the same as the corresponding DECON activities (described previously in Section U.3.1.1)
except that only some of the resulting radioactive wastes require packaging for offsite shipment
and the remaining wastes are placed inside the entombment structure. DECON activities inside theentombment structure area are deleted and replaced by unique ENTOMB activities.
Piping thatpenetrates the postulated entombment structure is cut off at all points of penetration and theopenings are sealed with welded steel plates.
In addition, other piping and equipment that may
impede the movement of radioactive materials into the entombment structure is removed and placedin a more convenient location in the structure. Additional hatchways are cut through the floor
at the 305-ft level to facilitate the movement of materials into the area. After the entombment
structure is filled with radioactive materials, all penetrations through the structure (e.g.,
piping penetrations, hatchways, and stairwells) are sealed with cast-in-place reinforced concrete.
The tops of the cavities in the D-ring shield structure are also sealed. After completion of theentombment structure, appropriate security and surveillance systems are installed in the decontaminated upper portion of the containment building, and all utilities not required during continuingcare are disconnected.
Then; the larger air-lock is sealed and the smaller one is fitted with an
intrusion alarm and locked. Continuing care of the entombment structure commences at this point.
Total person-hours and exposure hours associated with ENTOMB activities are postulated to be thesame as for DECON (226,160 and 110,300, respectively).
U.5.1.2

Auxiliary and Fuel Handling Building

ENTOMB activities in the AFHB are essentially the same as those for DECON (Section U.3.1.2).
The
major difference is that only some of the radioactive material removed is packaged and shipped
offsite for disposal; the remainder is moved to the containment building for placement in theentombment structure. Total person-hours and exposure hours are postulated to be the same as for
DECON.
U.5.1.3

Other Buildings

ENTOMB activities in the other TMI-2 buildings are postulated to be the same as those for DECON,
as described in Section U.3.1.3.
Total person-hours and exposure hours are assumed to be thesame as for DECON.
U.5.2

Waste Volumes from ENTOMB

The volumes of radioactive material originating outside the postulated entombment structure andrequiring either placement in the entombment structure or shipment offsite for disposal are
estimated from those shown previously for DECON in Table U.6.
The first four items for DECON(reactor vessel with head and internals, RCS equipment, steam generators, and activated concrete)originate inside the entombment boundary and do not apply here.
Contaminated equipment (notincluding the steam generators and the RCS pumps, piping, and pressurizer) and miscellaneousradwastes are assumed to be essentially the same for both alternatives.
The percentage of contaminated concrete from DECON originating outside of the entombment boundary, derived from Tables G.4-4
and G.4-5 of Reference 1, is estimated to be %89%. The resulting volumes~of radioactive material
generated during ENTOMB are summarized in Table U.30.
Only part of the radioactive waste arising from ENTOMB can be placed in the entombment structure;
the rest requires packaging and shipment offsite for disposal.
Based on information presented in
Reference 19, the free volume available for entombment in the D-ring shield structure is estimatedto be 172,480 ft 3 . Additional entombment volume estimated to be available below the 305-ft level
floor is 124,720 ft 3 . Thus, the total volume available for entombment of radioactive materials
at TMI-2 is about 297,200 ft 3 . Because of the variety of shapes and sizes of both the volume
available within the entombment structure and the contaminated materials to be stored there, as
well as the difficulty in placing materials in some portions of the structure, a volume utilization
efficiency of 50% is assumed. Therefore, up to 148,600 ft 3 of the radioactive waste originating
outside the entombment structure can be placed inside, reducing the volume that requires packaging

Li

U-52

Table U.30.

Estimated Volumes of Radioactive Waste
Arising from ENTOMB of TMI-2
Fraction of Volume

Component

Estimated Burial

for DECON

Volume (ftContaminated concrete

0.89

393,700

Contaminated equipment

1.00

127,200

Miscellaneous radwaste

1.00

22,000Total

for offsite shipment and disposal to 394,300 ft 3 .
from ENTOMB of TMI-2 is summarized in Table U.31.

3)

542,900

This apportionment of the wastes resulting

It should be noted that not all of the waste originating outside the entombment boundary isreadily amenable to placement in the entombment structure.
Large equipment items present particular problems in this regard.
Thus, care must be taken in apportioning the particular items tomaximize worker efficiency and minimize radiation doses associated with equipment disassembly andhandling.
U.5.3

Effluents and Releases to the Environment

During ENTOMB, as during DECON (Section U.3.3), the atmospheric release of radionuclides isassumed to be the only source of radiation to the public from routine decommissioning operations.
(Effluents and releases from waste transportation activities are discussed separately in Chapter 9of this statement.)
All liquid radioactive wastes generated during decommissioning are assumed
to be sent to the plant liquid waste storage system or to other tanks designated for temporarystorage of these solutions.
The Wastes are then assumed to be processed through the waste concentration and solidification system.
ýAll systems designed to control the release of hazardous
material to the environment or to noncontaminated portions of the facility are assumed to be
operating during the decontamination activities and subsequent waste processing, to minimize thepotential impacts of these activities.
The primary sources of radioactive effluents from routine decommissioning operations are therelease of contaminated liquid aerosols during decontamination, the release of contaminatedvaporized metal during equipment removal, and the release of contaminated concrete dust duringdecontamination or removal'of concrete structures.
Based on an analysis of the generation of airborne radioactivity during DECON operations at alarge PWR, given in Appendix J of Reference 1, a summary of the results of such an analysis for
ENTOMB is presented in Table U.32.
The releases postulated here do not include releases frompossible accidents involving transport of spent reactor fuel from the site to a disposal facility.
From Table U.6., the total contaminated equipment removed during DECON (including the RCS equipment
and the steam generators) is 154,000 ft 3 while, from Table U.30, the total removed for ENTOMB is127,200 ft 3 .
The! releases for segmenting contaminated equipment during ENTOMB are thus -83% of
those given in the reference for DECON.
The releases during removal of contaminated concrete in
the reference study are based on 6912 ft 3 of concrete removed (see Table G.4-4 of Reference 1),
as compared to an estimated 393,700 ft 3 postulated to be removed for ENTOMB of TMI-2 (seeTable U.30).
Thus, the release reported in the reference is adjusted by a factor of -57 toaccount for the differing volumes of concrete considered.
The rest of the releases reported inTable U.32 are drawn directly from the reference because the operations considered are the samefor either DECON or ENTOMB.
The compositions of the reference inventories of radionuclides
considered in the analysis were presented previously in Tables U.8 through U.11.

im

U-53

Table U.31. Apportionment of Radioactive Waste
Arising from ENTOMB of TMI-2
Estimated Burial
Volume (ft 3 )Component
Total waste originating
outside entombment
boundary

542,900a

Waste entombed onsite

148,600

Waste packaged and shipped
offsite for disposal

394,300.

aFrom Table U.30.

Table U.32.
Postulated Releases of Airborne
Radioactivity to the Environment
During ENTOMB Operations

ENTOMB
Operation

ReferenceRadionuclide
Inventorya

Airborne
Release(pCi)

Segmenting contaminatedequipment

4

5

Contaminated concrete
removal50.0014

Water-jet cleaning

5

9.8

aThe reference radionuclide
Section U.3.3.

inventories are presented inU-54.

U.5.4

Environmental Impacts

The environmental impacts associated with ENTOMB of a nuclear power reactor are contained inthree general categories:
the radiation dose to the workers involved, the radiation dose to the
public, and the commitment of disposal space in a low-level waste burial ground. The impacts
associated with ENTOMB for each of these categories are discussed in the following sections.
U.5.4.1

Estimated Occupational Radiation Doses from ENTOMB Activities

The radiation dose accumulated by the workers performing ENTOMB activities is estimated by multiplying the average local radiation dose rate for a given plant area times the number of worker
exposure hours estimated for that area, and summing over the entire project. The average Vocal
dose rates for general areas in the containment building and the AFH building are given in
Table U.33. Also given in the table are cumulative exposure hours for persons working in thosegeneral areas, taken from Section U.5.1, the computed cumulative dose to the workers accomplishingtasks in those areas, and the estimated total radiation dose received by workers while performing
ENTOMB activities. Worker exposure hours in the various areas outside the containment building
are assumed to be the same for ENTOMB as for DECON.
For the containment building, it is assumed
that only half as much exposure time is required at the 282-ft level for ENTOMB as compared with
DECON, with proportionally more time at the 305-ft level to make up the difference.
The estimated dose received by the transportation workers during the transport of packaged radioactive wastes, based on an assumed realistic dose rate for each shipment as given in Section 9.5.1.1 (56 millirem/trip/driver), is given in Table U.34. The estimated dose received byrailway workers during the transport of the spent reactor-fuel, as derived in Section U.3.4.1 for
DECON, is also given in the table.
U.5.4.2

Offsite Doses from ENTOMB Activities

The dose estimates presented here for ENTOMB decommissioning operations are based on the source
terms described in Section U.5.4, Table U.32, and on the assumption that the decommissioning
activities take place 10 years after the TMI-2.accident.
The calculational~models used to makethese estimates and the interpretation of their results are described in Appendix W. The significance of these doses and their human health and environmental consequences are discussed in
Section 10.3.
The estimated doses to the maximum exposed individual are listed in Table U.35.
The 50-mile total body population dose received by the human population during these activities
is estimated to be 6.x 10-s person-rems.
The estimated radiation dose to the public resulting from transport of radioactive material
offsite is presented in Table U.36 for both truck and rail transport.
U.5.4.3

Other Environmental Effects

Other impacts on the environmentl surrounding TMI resulting from ENTOMB of Unit 2 will be similar
to those discussed in Section 10.6, but of lesser magnitude because there will be fewer workers
involved in ENTOMB and because gross contamination cleanup efforts will have been completed
before the start of decommissioning.
It is anticipated that the decommissioning of Unit 2 would reduce the level of anxiety and psychological stress among local residents.
Completion of decommissioning will reduce the number of persons employed at the TMI site, thus
reducing the local payroll, at least temporarily.
U.5.5

Estimated Costs for ENTOMB

The principal cost items for ENTOMB are labor, waste disposal, spent fuel disposal, and energy.
Other costs include special equipment, speciality contractors, licensing and insurance, andmiscellaneous supplies.
The costs presented here are based largely on those for DECON, presented
previously in Section U.3.5.
Additional information used to estimated costs is drawn from Section 4 of Reference 2. The costs for ENTOMB are summarized in Table U.37, with discussions of
the principal cost items presented in the following sections.

U-55

Table U.33.

Estimated Cumulative Radiation Doses Received
by Workers During ENTOMB Operations
Average
Local
Dose Rate(mrem/hr)Worker Exposure
Hours in the
Area

Cumulative
Radiation
Dose(person-rem)Containment Building
347-ft level-547,600240

305-ft level282-ft level

5-10
30

43,90018,800220
564

AFH Building
All levels

2

106,800

213

Other Buildings
All levels

2

18,00035

Operation
Area

Total

1,272

TableU.34.
Estimated Cumulative Radiation Doses
Received by Transport Workers During
ENTOMB Operations

WorkerType

Dose/Shipment(mrem/driver)

Number of
Shipments

Cumulative
Radiation Dose(person-rem)

Truck drivers

56

755

84 .6aTrain crew

120

26

6 .2a

Total
aAssumes two drivers/truck, two brakemen/train.

91.

U-56

Table U.35. Dose Estimates to the Maximum-Exposed Individualfrom Normal Decommissioning Activities (ENTOMB)a

Location

Pathway

Total-Body

Dose (mrem)
BoneNearest b
gardenInhalation
Ground Shine

1.4 x I0-7
6.9 x 10-7

3.1 x I0-7
6.9 x 10-7.

2.6 x 10-7
6.9 x 10-7

Vegetable Use

3.2 x 10-6

1.4 x 10-5

1.3 x 10-s

4.3 x 10-6

1.5 x 10-5

1.4 x 10-5

Inhalation
Ground Shine

1.2 x 10-7
6.6 x 10-7

1.7 x 10-7
6.6 x 10-7

1.7 x 10-7
6.6 x 10-7

Goat Milk Use

8.4 x 10-6

6.5 x 10-5

7.6 x 10-5

Total

9.2 x 10-6

6.6 x 10-5

7.7 x 10-5

Total
Nearestmilk goat

Nearest cow
and garden

Liver

Inhalation

1.5 x 1 0 -7

3.4 x 10-7

2.9 x 10-7

Ground Shine
Vegetable Use

1.0 x 10-6
4.6 x 10-6

1.0 x 10-6
2.0 x I0-5

1.0 X 10-6
1.9 X 10-5

Cow Milk Use

3.1 x 10-6

2.4 x 10-5

2.8 x 10-5

Total
8.9 x 10-6
4.5 x 10-5
4.8 x 10-5
aDoses were calculated for Total-body, GI-tract, bone, liver, kidney,
thyroid, lung and skin. The maximum three organ doses are listed in thistable. Doses were calculated for four age groups: adults., teenagers,
children, and infants.
The highest dose estimates for each age group are
listed. The dose estimates for the total-body pathway are for adults.
The dose estimates for the bone and liver pathways for the nearest garden
and nearest cow and garden locations are for children, and for the nearest
goat location are for infants.
bThe basis for selecting the special locations is described in Appendix W.
The actual locations are: nearest garden = 1.05 mile east-north-east,nearest milk goat = 1.02 mile north, andnearest cow and garden = 1.05
mile east.

Table U.36. Estimated Cumulative Radiation Dose
Received by the Public During Transportof Wastes from ENTOMB
Cumulative
PublicRadiation Dose(person-rem)

Type of Shipment

Number of
Shipments

Dose/Shipment(person-rem)

Radioactive
material (truck)

755

0 . 0 5 3a

40.0

Spent reactor
fuel (rail)

26

0 .0293b

0.76

Total
aBased on data given in Section 9.5.1.2.
bBasedBsdon data given in Section 11.4.1 of Reference 1.

41

-

nm

.

I

I

I

U-57

Table U.37.

Summary of Estimated Costs for ENTOMB
Cost in millions of

Category

Mid-1980 Dollars

Decommissioning labor
DirectSupportRadwaste disposal
Spent fuel shipment

8.503
2.496

EnergyOther costs

4.620

Supplies
Equipment
Contractors
Nuclear insurance

1.820
0.960
0.510
0.940

Licensing fees
Subtotal

0.050
36.01825% contingency

9.004

Total

45.020

Annual continuing care costs

U.5.5.1

7.196
8.923

0.040

Decommissioning Labor Costs

Labor cost estimates for ENTOMB are developed based on the person-hour totals presented in Section U.5.1 and the labor cost assumptions used in Section U.3.5.1 for DECON. The direct decommissioning crew hours and theresulting labor costs are summarized in Table U.38.
U.5.5.2

Radioactive Waste Disposal Costs

The radioactive materials requiring offsite disposal during ENTOMB of TMI-2 consist of surfacecontaminated equipment, and concrete and miscellaneous radwaste (e.g., filters, ion exchange
resins, solidified radioactive fluids, and combustible wastes).
Estimates of the costs for
disposing of these materials are summarized in Table U.39, based on the disposal cost estimatesand assumptions given for DECON in Section U.3.5.2 and on the waste volumes from ENTOMB given
previously in Section U.5.2.
All of the miscellaneous radwastes are assumed to be shipped offsite. In addition, %71% of the contaminated equipment and concrete generated outside the entombment structure is assumed to be shipped offsite, for a total of 394,300 ft 3 of waste disposed ofoffsite (see Table U.31).
U.5.5.3

Spent Fuel Disposal Costs

Spent fuel disposal costs are the same for ENTOMB as for DECON.
The total cost for spent fueldisposal is $2.5 million, as derived previously in Section U.3.5.3.,
U.5.5.4

Energy Costs

Energy costs for ENTOMB are assumed to be the same as those for DECON,
derived previously in Section U.3.5.4.

or $4.62 million, asU-58

Table U.38.

Estimated Labor Costs for ENTOMBLabor Cost in
Millions of Dollars
Direct Crew Hours

Direct Crew

Total

Containment building

200,816

3.036

6.803

All others

274,996

4.160

9.318

Total

475,812

7.196

16.119Activity

Table U.39.

Estimated Costs for Offsite Disposal of Radioactive Wastes from ENTOMB
BurialRadioactive
Material

Number of
Shipments

Container
Cost

Cask bRentalTransport
Costs

Handlin 8
ChargesVolume,(ft 3 )Charges

Total
Cost

90,900790,830.

1,217,500

Contaminatedequipment

Contaminatedconcrete
Miscellaneousradwastes
Total

25

334,170-

92,500550

1,033,530-

2,035,000-

281,400

2,448,180

5,516,710

180

151,800

324,000

1,026,000

54,60022,000212,872

1,769,272

755

1,419,400

324,000

3,153,500

54,600394,300

3,451,882

8,503,482

aAssumes cask liner cost of $800, LSA box cost of $470, special container cost of $6000/box.
bAssu'mes rental fee of $300/day and a 6-day cycle for each shipment.
cAssumes a transport cost of $5700/round trip, $3700/one-way.
dAssumed to average $350/cask liner, overweight objects @ $87.50 + (0.02/lb >10,000 lb).
eAssumes burial charges of $8.70/ft 3 , liner and curie surcharges as given in current NECO
price list.

U-59
U.5.5.5

Other. Costs

Other cost items include miscellaneous supplies, special equipment, specialty contractors, nuclear
insurance, and licensing fees.
It is assumed for ENTOMB, as it was in Section U.3.5.5 for DECON,
that the costs of these items as presented in Reference 2, when escalated by 17%, are appropriate
for theTMI-2 analysis.. Based on Table 4.5-1 of Reference 2 and Table 10.3-1 of Reference 3,
these items are estimated to be $1.82, $0.96, $0.51, $0.94, and $0.05 million, respectively.
Continuing care, involving surveillance and maintenance of the entombment structure, is estimatedto cost about $40,000 annually (see p. 4-10 of Reference 2 and p. 10-15 of Reference 3).
Thus,for example, a continuing care period of 100 years would add about $4 million to the cost of
TMI-2 ENTOMB.
U.5.6

Deferred Decontamination

As discussed previously in Section U.5, deferred decontamination must follow ENTOMB if it becomesdesirable to terminate the nuclear license of the facility. This deferred decontamination following ENTOMB, though not analyzed here in detail, is anticipated to be an extensive project.
Although there is less radioactive material to remove from the plant (because of some offsite
disposal during the initial phase of ENTOMB) and this remaining radioactive material is consolidated in a relatively small portion of the facility, the operation is complicated by the necessity
to break into the entombment structure (designed to retain its integrity under any but the most
severe conditions) and remove the more-or-less randomly placed radioactive materials stored
inside.
Therefore, the costs for deferred decontamination following ENTOMB are anticipated to be
similar to those for deferred decontamination for SAFSTOR (see p. 2-14 of Reference 3), given
previously in Section U.4.8.
The radiation doses and radioactive releases associated with deferred decontamination are expected
to decrease with the entombment time in accordance with the radioactive decay of the entombedmaterials.
However, it should be noted that (1) the doses and releases associated with segmenting
and removing the neutron-activated materials, avoided during the initial phase of ENTOMB, would
certainly be encountered during deferred decontamination and (2) these doses and releases will
not decline significantly after about the first 100 years of entombment because of the long
half-lives associated with the remaining activation products (see Figure 7.4-1 of Reference 1).
Thus, the overall total doses and releases for ENTOMB and deferred decontamination are anticipatedto be only a little
less than those for DECON alone.
Furthermore, any savings in doses andreleases resulting from ENTOMB could be more reasonably achieved by SAFSTOR, particularly because
SAFSTOR involves simpler, less time-consuming procedures and lower overall costs than ENTOMB.
References--Appendix U
1.

R. I. Smith, G. J. Konzek, and W. E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Rference Pressurized Water Reactor Power Station," NUREG/CR-0130, June 1978.

2.

R. I. Smith and L. M. Polentz, "Technology, Safety and Costs of Decommissioning a Reference
Pressurized Water Reactor Power Station," NUREG/CR-0130 Addendum, August 1979.

3.

H. D. Oak, G. M. Holter, W. E. Kennedy, Jr., and G. J. Konzek, "Technology, Safety and Costsof Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672, June
1980.

4.

"Final Program Report, AEC-Elk River Reactor,"
River, Minnesota, September 1974.

5.

J. M. Halter and R. G. Sullivan, "Contaminated Concrete Surface Layer Removal," presented at
Fourth International Conference on Contamination Control, Washington, DC., September 10-13,
1978.

6.

W. D. Kittinger, B. F. Ureda, and J. W. Carroll, "Experience and Techniques in Atomics
International's Recent Decommissioning Programs,"
presented at Health Physics Society
Annual Meeting, Philadelphia, Pennsylvania, July 8-13, 1979.

7.

T. Banmeister and L. S.
pp. 13-49 through 13-51,

COO-651-93,

United Power Association,

Elk

Marks, "Standard Handbook for Mechanical Engineers," 7th Edition,
McGraw-Hill, Inc. 1967.

U-60
8.

G. A. Beitel and M. P. Schlienger, "Arc Saw Testing," ARH-LD-147, Atlantic Richfield Hanford
Company, Richland, Washington, and Schlienger, Inc., San Rafael, California, July 1976.

9.

"Dupont Blaster's Handbook," 15th Edition, 1969.

10.

M. A. Cook, "The Science of High Explosives," American Chemical Society Monograph Series,
Reinhold Book Corporation, New York, New York, 1968.

11.

K. D. Kok, B. D. Linse, and S. J. Basham, Jr., "Use of Linear-Shaped Explosive Charges for
Reactor Dismantling," Trans. Am. Nucl. Soc. 22:635, 1975.

12.

R. P. Allen, et al., "Electropolishing as a Decontamination Process: Progress and Application," PNL-SA-6858, Pacific Northwest Laboratory, Richland, Washington, April 1978.

13.

D H. Card, "Early Waste Retrieval Interim Report," TREE-1047,
Laboratory, EG & G Idaho, Inc., pp. 19-40, February 1977.

14.

N. I. Sax, "Dangerous Properties of Industrial, Materials," Fourth Ed., Van Nostrand Reinhold
Company, Section 2, "Industrial Air Contaminant Control," by B. Feiner, pp. 40-115, 1975.
"Handy-Whitman Index of Public Utility Construction Costs," Bulletin No. 105, Section B-6,

15.

Idaho National Engineering

Amended January 1, 1979.
16.

Chemical Engineering Plant Cost Index, "Chemical Engineering," June 30, 1980, p. 7 .

17.

MF-I.C.C. No. 195, "Local Commodity Tariff No.
Joplin, Missouri, August 1980.

18.

G. 0. Calkins, "Plan for Reevaluation of NRC Policy on Decommissioning of Nuclear Facilities,"
NUREG-0436, Rev. 1, Supplement 1, August 1980.

19.

"Three Mile Island Nuclear Station, Unit 2, Final Safety Analysis Report," Amendment 35,
Docket-50320-186, Table 042.1-10, p. $3-42-lbb, Metropolitan Edison Co., Reading, Pennsylvania,
November 20, 1975.

1045-E," Tri-State Motor Transit Company,

ASSESSMENT OF GROUNDWATER LIQUID PATHWAY FROM LEAKAGE OF

APPENDIX V.

CONTAINMENT WATER AT THREE MILE ISLAND,

The staff has conservatively estimated the concentrations

UNIT 2of radioactivity that would occur in

the Susquehanna River from the leakage of radioactive water in the reactor building.
The Unit 2 reactor building has approximately 700,000 gallons of radioactively contaminated wateron the basement floor (reactor building sump water).

Major quantities of.tritium (0.95 pCi/mL),

Cs-137 (163 pCi/mL),

Cs-134 (24 pCi/mL) and Sr-90 (2.61 pCi/mL) are dissolved in this water.

postulated accident

is

The

a breach of containment that allows part of this contaminated water toescape to the ground.
The reactor building water level was. 290 ft MSL in April 1980, as shown in Figure V.1.
responding groundwater level was 285 ft MSL.

Under these circumstances,would be less than two-thirds of the 700,000 gallons.
influence of river stage and rainfall,

however.

The cor-the maximum water loss

The water table fluctuates under the

For the purposes of this computation,

the staff

assumed that 470,000 gallons of the water was lost to the groundwater.
V.1

RELEASE MECHANISM

There isno realistic mechanism that would result in release of large quantities of the radio-

active water to the environment.
vatively

For the purposes of this study,

it was arbitrarily and conser-

assumed for the transport of Sr-90 and Cs-137 that water released

from the reactor

building by a non-mechanistic crack failure would seep into the ground over an area equal to thatof the entire reactor building floor.
was 10-2 to 10-3 cm/s.'
it

The range of permeability values for the surficial soils

On the basis of these conservative assumptions,the staff estimated thatwould take from 0.25 to 2.5 days for all the 470,000 gallons of water to seep away.

A morerealistic seepage rate would be much smaller than this and would be limited by the size of thecrack in the containment.
river of about 0.006.1

The natural water table has a measured slope in the direction of the

The staff estimated that the travel time under normally occurring watertable conditions would range from 350 days to 7060 days.
almost certainly longer than the minimum,-however,1.

The actual

gradient is

The true groundwater travel time isfor the following reasons:probably smaller than that reported during construction of thesite because much of the natural land surface is now covered with impermeable concrete
and is also well drained; and

V-i

V-2
-310'-

Grade 305.0'-300'-

3/8" Liner
Plate

F/z
Reactor Building Water Level 290.0'-290'-(April 80)
2' Concrete Baseabove Liner
Reactor Building

Ground Water

1/4" Liner Plate

Floor

285.0'(April 80)

282.5'
m

"•

Sump

•,

Bottom276.5'

|p

J

•Jl •

Floor 280.6'

xxOME

iN
-270'-

Pit.
STendon261.5'-260'Aux Bldg. Floor 258.5'
Typ.

-250'-

Figure V.1.

Reactor Building.

V-3
2.

A traveltime of 350 days would require a recharge to the water table of about 50 per-cent of allrain falling onto the land.
Typical groundwater recharge would be only afew percent of the rainfall after evapotranspiration and runoff in a well-graded area..

The released contaminated water would recharge the water table, creating a local groundwater"mound" which would perturb normal flow.
The effect of the 470,000-gallon volume of contaminatedwater on the water table would be substantial,

but of short duration.

It

is possible to demon-

strate by way of an example that the perturbation of flow in the water table can be neglected forthe most important radionuclides,

Sr-90 and Cs-137,

which have large liquid pathway dose factors

and relatively long half-lives.
Because of sorption of radionuclides on the soil,transport of sorbed radionuclides

reactor containment to the river would take a minimum of tens of years.

from theIn a ten-year period,

the quantity of groundwater flowing directly under the reactor building under the assumptions
used to calculated 350-day groundwater time would be approximately 1.5 x 107 gallons,to the 0.47 x 106 gallons in the reactor building.
therefore,

provide only a few percent,nuclides to the river.

at most,in the reactor building could,of the water necessary to transport sorbed radio-

Radionuclides that are not sorbed,

affected by the perturbation in groundwater flow,AI

The water

as comparednotably tritium, would be significantly

however.

Transport in the groundwater would take place through the unconsolidated material and weathered
bedrock underlying the site.

The unconsolidated material is sand,silt,

and gravel.

The bedrockis

red siltstone.

itis virtually impossible to contaminate groundwater units other than the water table since they

Although there

are under artesian pressure.

is evidence of some fracturing of the bedrock under the site,

Leakage from the artesian aquifer would be in the outward direction

only.2
There were apparently no chemical

analyses performedon these materials that would indicate towhat extent the radionuclides in the contaminated water would be retarded.
retardation are not reliable for realistic assessments,
values have been chosen.
of soils and rocks. 3
isand for lack of field data,conservative

Field and laboratory data have been compiled for sorption on a number

The lowest sorption coefficient,Kd,for unconsolidated material reported

1.4 mL/g for strontium and 22 mL/g for cesium in quartz sand.

vial materials

Literature values ofValues for siltstone and allu-

such as that at the TMI site would be expected to be higher, but the above low

values are chosen for conservatism.
The retardation coefficient,which isrelated to Kd,

isthe ratio of the speed at which thegroundwater moves relative to the speed of the sorbed substance,
equal to 1:

Rd

'+

p Kd
n

and is always greater than orV-4
whe're p is the density (g/mL)of the medium and n is the total porosity.

2.0 g/mL and a total porosity. of 0.15 are chosen,
V.2

Rd is

If

a typical density of

24 for strontium and 294 for cesium.

TRANSPORT MODEL FOR SORBED RADIONUCLIDES

A simple transport model is proposed to calculate the flux of sorbed radioactivity to the river.
Consider the conservative

situation wherein the 470,000 gallons of reactor building sump water

seeps into the water table over an area the size of the. floor of the building.
occurred quickly compared to the movement of thenatural water,
the water table would resemble the rectangular pulse shown in
was eluted by the flowing groundwater,in

As the contamination

the front and back end of the square pulse would becomeof Figure 2.

Dispersion in thedeposits may be too small to diminish the concentration in the center ofthe pulse significantly (the basesItthe seepage

then the-concentrationprofile

Figure V.2(a).*rounded by diffusion and dispersion as, shown in parts.(b) and (c)unconsolidated alluvial

If

for this conclusion are given in Sec.

V.5 of this appendix).

is, therefore, conservatively assumed that the concentration in the center of the pulse remains

the same as when it

wasfirst released except that itisreduced to account for radioactive

decay.
The pulse flows into the Susquehanna River at a rate determined by the groundwater flow rate, theretardation coefficient, and the decay coefficient:

AxRd

Mu
exp (

Flux =
2Rd
where) curies/dayuM

the source term of the radionuclide,Pthe length of the pulse,u= the groundwater velocity,

Rd= the retardation coefficientX= the decay coefficient,x= the distancecuries (2/3 of contaminated water)

ft
ft/day

-1dyi
=

day-

0.693

half-life in days

from the leading edge of the pulse to the river.

*For computational expediency, it is assumed in the model that the leaked reactor building sump
water enters groundwater instantaneously.
The resulting concentrations in the. Susquehanna Riverwould not be highly sensitive to the rate of leakage if interdiction by removal of the source
term is not taken into account.

V-5

ft

Reactor

~Xt

"

C

0

U

Time 2

Figure V.2.

For the present example,

Elution of Radionuclides.

the parameters chosen are given below:

Parameter

Sr-90

Cs-137M, curies

4610

2.88 x 105

Rd

24

294

t½, years

29

30.1

k,

feet

150

150

u,

ft/day

xft

1.7
600

1.7
600

The maximum fluxes of Sr-90 and Cs-137 calculated are 1.25 and 0.016 Ci/day,

respectively.

The

leading edge of the pulse would" reach the river in 23 years for Sr-90 and 284 years for Cs-137.
By the time the radionuclides reach the river, radioactive decay will have reduced the Sr-90 to
2660 Ci and the Cs-137 to 416 Ci.
V.3

TRANSPORT OF TRITIUM

Unlike the Sr-90 and Cs-137,

the flux of tritium into the Susquehanna River would depend to adegree on the flow induced in the groundwater by the large volume of the spill.

The flux ofV-6
tritium is estimated by assuming that the dissolved radioactivity is released to the water tablefrom aninstantaneous point source.

the water table with no mixing.

The circle of contaminated water displaces fresh water in

The contaminated water then moves with the ambient velocity of

the groundwater towards the Susquehanna River,sorbed nuclides behind.

carrying with it

the dissolved tritium, but leaving

Details of this model are given in Section V.6 of this appendix.

The maximum flux of tritium is estimated to be 1.9 X 10-4 Ci/s into the Susquehanna River.
V.4

SURFACE WATER DILUTION

The release of Sr-90 and Cs-137 to the Susquehannaleft unchecked.

River would continue over a long period if

Since doses are usually calculated over a period of at least one year,

thelogical choice of a stream flow would be the reciprocal mean flow of 12,600 cubic feet per second(the derivation of this value is discussed in Sec. 3.4.1).
All downstream drinking water users
on the Susquehanna River are located far enough downstream that total mixing of the effluent
across the channel would be expected.

Travel time to downstream users would be negligible comparedto that of the groundwater pathway.

The peak radionuclide

concentrationsin the SusquehannaRiver based on the annual average flow would be 4.05 x 10-8 pCi/mL for Sr-90, 5.1 x 10-10 pCi/mL
for Cs-137,

and 5.2 x 10-7 pCi/mL for tritium.

Furthermore,clides would occur at different times because of sorption.

the peaks of these three radionuMaximum permissible concentrations(MPC)

for unrestricted drinking water from 10 CFR Part 20 are 3 x 10-7 pCi/mL for Sr-90,
2 x 10-5 pCi/mL for Cs-137 and 3 x 10-3 pCi/mL for tritium.
The calculated river concentrations
are thus.orders of magnitude below MPC.
After the initial delay,
and 140 years,

Sr-90 and Cs-137 would continue to be released over periods of about 8.5

respectively,

although at a reduced rate once the peak concentration has subsided.

The maximum average concentration over a one-year period for the purpose of computing an annual
dose commitment would be close to the peak concentrations

for these two nuclides.

tritium would be released over a 130-day period (after a delay of 350 days),
concentration should be based on the quantity released.
released to the river.

The annual

All of theso the annual average

In this case, about 2300. Ci would beaverage concentration of tritium in drinking water would be

about 1.3 x I0-7 pCi/mL.
Minor amounts of Cs-137 would be expected to become

attached

sediments,

This would partially cleanse the waterespeciallybehind the dams on the river.

(sorbed)to suspended and bottom

column of Cs-137,

while increasing the exposure to bottom dwelling organisms and aquatic life

feeding on them.

These phenomena would be expected to have only a minor effect on dose and areneglected in the present analysis.
As described in Appendix E, alldownstream,

species of fish in York Haven Pond exhibit movement upstream,

and across the channel,

so they would be exposed to an average concentration rather

than the concentration at a single point in the channel.

Staff practicefor calculating thehighest fish exposure is to use the average concentration within 1/4 mile of the point of release.

I.

V-7
In this case, the 1/4-mile average would be the concentration in the middle channel of the Susquehanna River since the effluent first flows into this channel.
estimated to be about 25 percent of the totalcommitmentsfordrinking water,fish consumption are,river flow.

therefore,

The flow in the middle channel

isThe concentrations for annual dosefour times greater than those used for thenamely 1.6 x I0-7 pCi/mL for Sr-90,

2.1 x 10-pCi/mL for Cs-137,

and7.5 x 10-7 pCi/mL for tritium.

V.5

DISPERSION FROM AN AREA SOURCE

The concentrationin an aquifer downgradient of an instantaneous nondecaying source strength of

1 curie has been shown to be:Cn1

X (x,t) Y (yjt) Z (z,t) (Ci/ft 3 )edwhere ne is the effective porosity,
directions,

respectively.

4and X, Y, and Z are the Green's functions in the x, y,

The Green's functions describe

the spreadingand z

in their respective

coordinate directions and are independent of each other.
I.

The X Green's function describes

spreading in the x direction, which in this case is the direc-

tion of flow for the groundwater.

For an area source of length k in the direction of flow asshown in Figure V.2:
+
X

where

{erf
[2P

ut

(x -k

4Dxt/Rd d

4Dxt/Rd

ut
d

}d

x

is the distance from the center of the source,kis the length of the source,ftuis the groundwater velocity,

ft/dayt

is time, days

Dx

is the dispersion coefficient,

Rd

is the retardation coefficienterf

is the error function.

ft 2 /dayAs the center of the pulse reaches the river in Figure V.2:t -xRd
ud(V2)

(Vi)

ft

7

V-8
Equation (VI)reduces to:1
X = 9 erf (arg)where arg
If

4

(V3)

2/2
2

D x /uwe postulate that longitudinal

dispersion is unimportant in diminishing the concentration of

the pulse, then the functional dependence of X on Dx and tis

zero or small.

Such a condition is

met by:erf (arg) close to 1.0.
As a criterion for specifying that dispersion has less than a 5 percent effect on the concentration ,at the center of the pulse we may state:erf (arg) > 0.95.
The error function is a monotonically increasing function that approaches unity.
erf (arg)= 0.95,or within 5 percent of unity.

2/2

arg -

4D

For arg = 1.38,

Therefore:> 1.38(V4)x/u

The dispersion coefficient is related to velocity in the x direction:
D= uu

(V5)

where D is the dispersivity,
Therefore equation (V4)

V/2

reduces to:> 1.38

-4
ox
22
or

ft.

N

-- > 30.5(V6)

A typical dispersivity in unconsolidated sand would be u =.0.3 ft. 5 For the£2
TMI case 2 = 150 ft., x = 600 ft. Therefore, L= 125, which is greater than 30.5.
Evenox
if o = 1.0 feet, L2 = 37.5. We must, therefore conclude that longitudinal dispersion

Ux

could have less than a 5 percent effect on diminishing the maximum groundwater concentration
at the TMI site.

V-9
V.6

FLUX OF TRITIUM FROM INITIAL SPILL*

The volume of water that leaks into the water table will alter the water level and induce flow of
its own.
This flow will carry dissolved radionuclides, especially those such as tritium which
are not easily sorbed.
In an isotropic, homogeneous aquifer of infinite lateral extent and of constant thickness, the6horizontal flow of groundwater can be estimated by the partial differential equation:
a2 h + a2 hl-1ah
ax-X;ia- ý T
where

h

(V7)

is the piezometriclevel,

ft,
2

P

is the transmissivity = ft

neis the effective porosity,kis the permeability,his the thickness of the aquifer,t

is time, days,/day,ft/day,and x and y. are the coordinates,

ft,

ft.

A conservative model of this induced flow assumes that the water ispoint into a continuous,

instantaneously injected at a

isotropic medium of infinite extent as shown in Figure V.3.

By analogy

to the transport of the heat from a line source in an infinite cylinder" the water surface elevation h can be predicted as a function of time:

h

where

Q
r

•Q
exp ( ne4otf4t

2

)

(V8)

is the quantity of water injected, ft 3 ,is the radial distance of a given point from the point (x + ut, y ),moving with the pore velocity u, where (xo, yo) is the point of groundwater

release,and the other terms are as previously defined.
This equation is correct only for confined aquifers where the thickness of the saturated layer
does not.vary.
In the present situation, the aquifer is unconfined, so is also the piezometriclevel.

Some error will be introduced,

especially for short times and distances close to thepoint of release.

*This analysis was performed for 100% of the reactor building sump water volume escaping.
flux of tritium would be approximately two-thirds of the value presented here.

The

V-10
(a) Plan View
Pore Velocity uLRiver
Point of
Injection(b) Cross Sectional View

Mound

Orginal
Water
Table

Figure V.3.

Spread of Contaminated Water from Large Volume Releases.

In the reference plane of the center of the spreading mound, which is moving with the ambient
groundwater pore velocity u, the flow is away from the center at radial velocity Ur:
UrIf-- k/n
r

e

8
8

Qkr

tn 2

exp(-r/4t)

2

(V9)

the conservative assumption is made that contaminated water will exactly displace fresh water
the radius of the circle of contaminated water will grow at the radial velocitNin the aquifer,
Ur:

t

r

t

fUrdt = f
Qkr
2 2 2 exp (-r2/4pt) dt
o 8Tne P t
0

kl10

El

V-1l
Equation (VIO)issolved by numericalintegration.

Integration isfacilitated by a change ofvariables:

~t=-

'

1
z

(VII)

2

Which yields the equationr

Qkrz2 2fexp (-r 2 z2/41)

dz

(V12)

1 4nnez

2

The integration takes place in the reverse direction, since at z
condition for z = 0 for the radius is the maximum

r (t

cc)

0, t =.

The initial

Q

(V13)

r=n H
e

For the present case, the parameters for Equation (V13)are:

Q = 93583 ft3*
k = 28 ft/day
H = 25 ft
n

e

=0.1
= kH/ne = 7000.

The radius of the circle for the present case as a function of time is
The expanding circle travels with the ambient pore velocity.

shown in Figure V.4.

The flux of contaminant (curies/ft 3 )into an intersecting river can be approximated by the integral
Y

Flux = 2 f

X(H + h) une Ce-dy,curies/day

0

where

X

is the decay coefficient-In 2
half-life

y2 = r2 _ L2

*It

is now assumed that only 2/3 or about 62,400 cubic feet (470,000 gallons) will escape.

(V14)

V-12
Asymptote

Q = 93584 it
H = 25 ft
K = 28 ft/day

70

e

0.1

60
50
40
30
20
10
0
0

5

10

I
15

II

20

25

I

II

30

35

40

1'45

Time - Days

Figure V.4.

L=

Radius of Contaminant Circle vs Time.

- ut,

h is defined by Equation (V.8), andC = activity concentration, Ci/mL.
This integral may be evaluated analytically:

Flux = e-t

u ne C { 2HY +

exp (

4

) erf (

)

(V15)
U

2n e

For the present case,C = 0.95 VCi/mL and half-life = 12.33 years.

Equation (V15) is shown in Figure V.5.

The flux calculated from

Since the travel time for the contaminated water will be

V-13
24
22=

2018-

1616

Q
0H

01

1414C
L

=93584 ft
25 ft=28 ft/day=K= 0.951A Ci/mi Tritium

12-

1086-

42
0I
250

270

290

310

330

350

370

390

410

430

Time - Days

Figure V.5.

hundreds of days in this case,itreached maximum radius at the river.
Flux (max)safe to say that the circle of contamination has nearly
The appropriate maximum flux is therefore

2Hr(max) u ne C exp (-X tmax)

where
_ X

max

is

Flux of Tritium into River.

u.

For the present case,x = 600 ft
u = 1.7 ft/day
C = 0.95 pCi/mL.

(V16)

V-14
The maximum flux of tritium is therefore
Flux (max)which is2.8 x 10-4 Ci/s,*

in close agreement with the more precise Equation (V15).

References--Appendix V
1.

"FinalSafety Analysis Report,

Edison Co.
2.

and Jersey Central Power & Light Co.,

T. Nicholson,

0.

Isherwood,-

R.B. Codell,Section 2.4.13,'1974.

Unit 2 - Groundwater Study," April 19,

1979.

"Preliminary Report on Retardation Factors and Radionuclide Migration,"

Livermore Laboratory, A3.44,
4.

Unit 2," Metropolitan

Memorandum to TMI-2 file, Hydrologic Engineering Section, "Three Mile Island

Nuclear Station
3.

Three Mile Island Nuclear Station,

Lawrence

August 1977.

"NRC Workbook on Hydrologic Dispersion," U.S.

Nuclear Regulatory Commission, tobe published as a NUREG document in 1981.
5.

J.F. Pickens,
Paper No.

6.

Merrit,and J.A. Cherry,

D.B. McWhorter,and D.K. Sunada,
Fort Collings,

H.S. Carslaw and J.C. Jaeger,
London,"Studies of Dispersion in a Sandy Aquifer,"

H-62 presented at AGU Spring meeting, Washington, DC,

Publications,
7.

W.F.

CO,

"Ground-Water

1977.

Hydrology and Hydraulics,"

Water Resources

1977.
"Conductionof Heat in Solids,"

Oxford University Press,

1959.

*For 2/3 of the-volume escaping, the flux would be approximately 1.87 x 10-4 Ci/s.

APPENDIX W. CALCULATION MODELS AND PARAMETERS USED IN ESTIMATING DOSES,AND INTERPRETATION OF MODEL RESULTS
W.1

ATMOSPHERIC RELEASESThe calculational methods used to estimate doses from atmospheric releases due to routine decontamination or accidental atmospheric releases are those described in Regulatory Guide 1.109. The
computer code which the NRC staff uses which contains these methods is designated GASPAR and its
use is described in the "User's Guide to GASPAR Code," NRC report NUREG-0597. 'Regulatory Guide
1.109 models are appropriate *for short-term releases with certain minor adjustments in application and parameter values, even though the models were originally developed for normally operating
reactors (long-term releases). These adjustments and the parametric values used in the code aredescribed below.
It was assumed the period of time over which an individual consumes contaminated food was one
year and that the releases occurred uniformly over this period of a year. This modeling approachis realistic for the normal decontamination program because most of the releases will be madeover fairly long time periods (3 months to over .1year), hence, the assumption of uniform annual
release rate is reasonable.
It is useful to apply the uniform annual release rate assumption to short-term releases, as well
as lo"ng-term releases, and the principal difference is in how the results are interpreted. The
short-term accidental release requires special interpretation for two reasons.
In the firstplace, it is impossible to predict meteorological conditions at the time of an accident, andsecond, it is impossible 'to predict the season during which an accident may occur. As a result
it is also impossible to predict vegetable garden production, or cow pasture use (average annual
rates of veg *etable production and cow pasture use were assumed). For normal releases, the correctinterpretation of the results is that they describe the expected maximum doses that actually will
occur offsite. These represent maximum values because locations are also chosen that will resultin highest doses. On the other hand, for the short-term release, (1) the wind could be in someother direction where the doses would likely be smaller, (2) whatever the direction of the wind,
the actual atmospheric dispersion could be very different from the average value in that direction, and/or (3) there may or may not be cows on pasture or garden production, depending on
season and wind direction. The most important uncertainty in the accident calculation is theinability to predict the actual meteorological conditions and, thus, dispersion during an accident.
For this reason, the hourly atmospheric dispersion parameter values for the location resulting inhighest doses are used. This means the results for accidents should be interpreted as worst
location expected values, rather than worst location actual values. The uncertainty in thevalues that could occur is discussed below. Table W.1 lists the tables of Regulatory Guide 1.109
where model input parameters and problem specific parameters which were used in the calculations
can be found.
The atmospheric dispersion parameters that were used are described below and were selected toassure that calculated doses overestimate potential actual ones. The value used for the nearest
residence and garden calculation was not selected on the basis of the actual nearest residence!
garden but was selected on the basis of the actual residence/garden where the annual meteorological relative depo 'sition rate was highest. The values selected for goat milk and cow milk consumption were also selected on the basis of the highest meteorological relative deposition rate.*
The meteorological parameters used for normal releases represent annual average long-term conditions whereas the meteorological parameters used for accidental releases represent short-term
conditions.

*Locations of gardens, cows, and goats were taken from the Three Mile Island Nuclear Station
Radiological Environmental Monitoring Program Annual Report for 1979.

W-1

W-2

Table W.1.

Table Numbers of Regulatory Guide 1.109 where Input
Parameters Can Be Found, and Problem-SpecificParameters Used in the PEIS

Parameter

Table Numbers

Usage factors for maximum exposed individual

E-5

External dose factors

E-6

Dose conversion factors

E-7 through E-14

Other parameters

E-15

Problem- and Site-Specific.Parameters:

Value

Period of long-term buildup

1.0 year

Fraction of year vegetables taken from garden

0.5

Fraction of year cows on pasture

0.5

Fraction of year beef on pasture

1.0

Fraction of year goats on pasture

1.0

For population dose estimates, the population projected for the year 2010 was used.
It wasconservatively assumed that all milk, meat, and vegetables consumed by this population was produced
within the 50-mile radius.
Production rates were assumed to be uniform within the 50-mile radius,and consumption rates were those of Table E-4 of Regulatory Guide 1.109.
The availability of an onsite meteorological measurement program provides a real time source of
information to assess the consequence of radioactive gaseous releases due to TMI-2 cleanup activities.
Two approaches for evaluating release dispersion were taken.
The first represents acontinuous release from the plant, which, although it may be less than 1 year's duration, can be
identified by the annual long-term average relative concentration that affects the surroundings.
The second represents a short duration release evaluation which may be used to. represent an
accident such as a fire or filter failure, both of which are of short duration.
Both the long-term (continuous release) and the short-term release assessment models determine
the relative concentration of radioactive gaseous. effluents (x/Q) as a function of distance fromthe release point, based on atmospheric stability, wind speed, and wind direction.
The meteorological models incorporate the release height and building wake influence in a manner that maximizes the x/Q at ground level and thus the possible dose for a receptor at the point of interest.
The long-term analysis method is described in Regulatory Guide 1.111 and the short-term method is
described in Regulatory Guide 1.145.
The accuracy of atmospheric transport models used here have been reviewed recently in two publications of the Oak Ridge National Laboratory.1' 2In general, the accuracy of the models is a,function of sampling time, terrain and vegetation, or a unique meteorological environment such asa valley wind or a sea breeze.
The uncertainty in determining the maximum concentration ofradioactivity in a plume at short downwind distances within 10 km for a ground-level release ingenerally uniform terrain with steady winds is estimated to be ± 20 percent.
The range of theratio of the predicted to observed concentrationfor specific locations within 10 km was 0.1
to 10.0, with the Gaussian plume model used for estimating downwind air concentrations of radionuclides.
In complex wooded terrain 'conditions, such as around TMI, the Gaussian model for short-term
releases overestimates the concentrations under poor diffusion conditions of stable atmosphereand low wind speeds when compared to actual measurements.
The amount of overestimation may range
from 50-500 times the value observed.
Annual average release evaluations have been shown generally to be within a factor of two to four for regional distances (out to about 100 km) dependingon the terrain conditions.

U

W-3
The relative concentrations given in Tables W.2 through W.6 below reflect the analysis for times
that the wind blew towards the point of interest and are based on onsite data collected in the
period 1971 through 1975.
Table W.2 lists the special locations for which maximum individual dose calculations are made.
Atmospheric dispersion parameters for normal releases' and for accident release are listed in thetable.

Table W.2.

Locations for Maximum Exposed Individual Dose Calculation andAtmospheric Dispersion Parameters

Dispersion Parameters

x/Q(s/m 3 )Locationx/Q (decayed)
(s/m

3

)

x/Q (decayed-depleted)
(s/m

3

)

D/Q
(m-2)

Routine Releases
Nearest garden(ENE, 1.05 mile)

1.93 x 10-6

1.88 x 10-6

1.67 x 10-6

3.22 x 10-9

Nearest milk goat(N, 1.02 mile)

1.74 x 10-6

1.71 x I0-6

1.51 x 10-6

3.10 x I0-9

Nearest garden andmilk cow(E, 1.05 mile)

2.13 x 10-6

2.08 x 10-6

1.84 x 10-6

4.74 x 10-9

2.9 x 10--

Accident Releases

Nearest garden(ENE,

1.9 X 1O-7

1.05 mile)

Nearest milk goat(N, 1.02 mile)

1.9 X 10-7

2.9 x 10-s

Nearest garden andmilk cow(E, 1.05 mile)

2.0 x 10i--

1.9 x 10-7

The method used for determining the accident relative deposition rate assumed, at the time of therelease, 100% of the effluent went to the receptor location during the entire release.
Thedeposition analysis uses a method described, in Regulatory Guide 1.111.
No decay values for theaccident x/Q are provided since effluent moving at 0.5 meters per second (1.1 mph) would takeless than 1 hour to reach the nearest locations and little
decay would have taken place.
Tables W.3 through W.6 list
the atmospheric dispersion parameters for each sector element used tomake the population dose calculations for normal atmospheric releases.
Population dose calculations. are not made for accidental atmospheric releases.
W.2

RELEASES TO THE RIVER

The calculational methods used to estimate doses from routine decontamination liquid releases or
accidental liquid releases are those described in Regulatory Guide 1.109.
The computer code
which the NRC staff uses that contains these methods is designated LADTAP and its use is describedin the "User's Manual for LADTAP-II," NRC report NUREG/CR-1276.
Regulatory Guide 1.109 models
are appropriate for short-term releases with certain minor adjustments in application and parametervalues, even though the models were originally developed for normal operating reactors (long-term
releases).
These adjustments and the parameter values used in the code are described below.

Table W.3.

Directionfrom Sitex/Q (s/mr3 ) Values Used in Population Dose Estimates (no decay - no depletion)
Segment Boundaries (in miles)
3-4
4-5
5-10

0.5-1

1-2

2-3

S

2 .840E-06a

1.037E-06

4.987E-07

3.116E-07

2.200E-07

SSW

1.879E-06

6.848E-07

3.267E-07

2.030E-07

SW

2.279E-06

8.278E-07

3.974E-07

WSW

2.999E-06

1.081E-06

5.189E-07

W

3.931E-06

1.434E-06

WNW

3.721E-06

NW

10-20

20-30

30-40

40-50

1.116E-07

4.395E-08

2.209E-08

1.419E-08

1.022E-08

1.428E-07

7.199E-08

2.807E-08

1.401E-08

8.953E-09

6.430E-09

2.481E-07

1.752E-07

8.888E-08

3.499E-08

1.760E-08

1.131E-08

8.153E-09

3.242E-07

2.290E-07

1.164E-07

4.594E-08

2.316E-08

1.491E-08

1.076E-08

6.866E-07

4.275E-07

3.012E-07

1.523E-07

5.961E-08

2.985E-08

1.912E-08

1.376E-08

1.344E-06

6.482E-07

4.065E-07

2.879E-07

1.470E-07

5.842E-08

2.961E-08

1.912E-08

1.383E-08

3.549E-06

1.291E-06

6.259E-07

3.934E-07

2,791E-07

1.427E-07

5.687E-08

2.886E-08

1.864E-08

1.349E-08

NNW

2.697E-06

9.797E-07

4.763E-07

2.999E-07

2.131E-07

1.093E-07

4.371E-08

2.226E-08

1.441E-08

1.044E-08

N

2.858E-06

1.037E-06

5.030E-07

3.164E-07

2..246E-07

1.150E-07

4.591E-08

2.335E-08

1.510E-08

1.094E-08

NNE

3.116E-06

1.133E-06

5.510E-07

3.471E-07

2.467E-07

1.266E-07

5.068E-08

2.582E-08

1.672E-08

1.212E-08

NE

3.182E-06

1.154E-06

5.554E-07

3.476E-07

2.458E-07

1.251E-07

4.951E-08

2.501E-08

1.612E-08

1.164E-08

ENE

3.264E-06

1.197E-06

5.781E-07

3.602E-07

2.561E-07

1.304E-07

5.157E-08

2.601E-08

1.673E-08

1.207E-08

E

3.612E-06

1.313E-06

6.279E-07

3.909E-07

2.755E-07

1.393E-07

5.459E-08

2.736E-08

1.754E-08

1.262E-08

ESE

3.462E-06

1.246E-06

5.965E-07

3.721E-07

2.626E-07

1.332E-07

5.250E-08

2.646E-08

1.703E-08

1.229E-08

SE

3.622E-06

1.306E-06

6.215E-07

3.858E-07

2.712E-07

1.367E-07

5.328E-08

2.661E-08

1.703E-08

1.224E-08

SSE

3.996E-06

1.451E-06

6.942E-07

4.323E-07

3.046E-07

1.541E-07

6.043E-08

3.031E-08

1.944E-08

1.400E-08

a 2 . 8 4 0E-06 = 2.840 x 10-6.

Table W.4.

Directionfrom Sitex/Q (s/m 3 ) Values Used in Population Dose Estimates (2.26-day decay - no depletion)

Segment Boundaries (in miles)
5-10
4-5

10-20

20-30

30-40

40-50

9.504E-08

3.279E-08

1.412E-08

8.001E-09

5.172E-09

1.284E-07

6.110E-08

2.088E-08

8.922E-09

5.027E-09

3.235E-09

1.594E-07

7.667E-08

2.667E-08

1.156E-.08

6.657E-09

4.244E-09

3.051E-07

2.119E-07

1.030E-07

3.663E-08

1.626E-08

9.364E-09

6.110E-09

4.033E-07

2.796E-07

1.355E-07

4.807E-08

2.135E-08

1.234E-08

8.081E-09

3.874E-07

2.707E-07

1.332E-07

4.851E-08

2.198E-08

1.281E-08

8.417E-09

5.972E-07

3.682E-07

2.564E-07

1.249E-07

4.440E-08

1.962E-08

1.127E-08

7.338E-09

9.558E-06

4.566E-07

2.827E-07

1.975E-07

9.690E-08

3.491E-08

1.562E-08

9.023E-09

5.891E-09

2.823E-06

1.012E-06

4.819E-07

2.977E-07

2.076E-07

1.015E-07

3.632E-08

1.615E-08

9.313E-09

6.081E-09

NNE

3.064E-06

1.095E-06

5.199E-07

3.200E-07

2.223E-07

1.075E.07

3.759E-08

1.636E-08

9.325E-09

6.060E-09

NE

3.138E-06

1.122E-06

5.295E-07

3.251E.07

2.257E-07

1.095E.07

3.878E-08

1.714E-08

9.858E-09

6.432E-09

ENE

3.208E-06

1.156E-06

5.449E-07

3.333E-07

2.305E-07

1.108E-07

3.843E-08

1.666E-08

9.500E-09

6.180E-09

E

3.561E-06

1.276E-06

5.980E-07

3.652E-07

2.525E-07

1.217E-07

4.265E-08

1.875E-08

1.079E-08

7.069E-09

ESE

3.413E.06

1.211E-06

5.680E-07

3.472E-07

2.402E-07

1.156E-07

4.038E-08

1.766E-08

1.014E-08

6.637E-09

SE

3.576E-06

1.273E-06

5.946E-07

3.626E-07

2.505E-07

1.207E-07

4.240E-08

1.873E-08

1.083E-08

7.127E-09

SSE

3.939E-06

1.410E-06

6.608E-07

4.035E-07

2.790E-07

1.344E-07

4.708E-08

2.066E-08

1.186E-08

7.750E-09

0.5-1

1-2

2-3

3-4

S

2 . 7 9 3 E-06a

1.002E-06

4.707E-07

2.873E-07

1.984E-07

SSW

1.846E-06

6.609E-07

3.077E-07

1,867E-07

SW

2.245E-06

8.027E-07

31771E-07

2.305E-07

WSW

2.961E-06

1.054E-06

4.968E-07

W

3.884E-06

1.399E-06

6.586E-07

WNW

3.684E-06

1.317E-06

6.264E-07

NW

3.500E-06

1.256E-06

NNW

2.664E-06

N

a2 .79 3 E-06 = 2.793 x 10-6.

x/Q (s/m 3 ) Values Used in Population Dose Estimates (8-day decay with plume depletion)

Table W.5.

Directionfrom Site

Segment Boundaries (in miles)
4-5
5-10

0.5-1

1-2

2-3

3-4

S

2.531E-06 a

8. 759E-07

3.981E-07

2.377E-07, 1.615E-07

SSW

1.674E-06

5.784E-07

2.606E-07

1.547E-07

SW

2.032E-06

7.001E-07

3.177E-07

WSW

2.676E-06

9.160E-07

W

3.508E-06

WNW

10-20

20-30

30-40

40-50

7.553E-08

2.514E-08

1.049E-08

5.788E-09

3.656E-09

1.047E-07

4.867E-08

1.605E-08

6.650E-09

3.657E-09

2.304E-09

1.897E-07

1.289E-07

6.038E-08

2.017E-08

8.453E-09

4.684E-09

2.968E-09

4.159E-07

2.488E-07

1.694E-07

7.969E-08

2.690E-08

1.143E-08

6.405E-09

4.099E-09

1.215E-06

5.507E-07

3.284E-07

2.230E-07

1.045E-07

3.503E-08

1.481E-08

8.284E-09

5.296E-09

3.323E-06

1.140E-06

5.210E-07

3.132E-07

2.140E-07

1.014E-07

3.471E-08

1.495E-08

8.473E-09

5.470E-09

NW

3.166E-06

1.093E-06

5.012E-07

3.015E-07

2.060E-07

9.737E-08

3.304E-08

1.405E-08

7.862E-09

5.021E-09

NNW

2.405E-06

8.299E-07

3.819E-07

2.303E-07

1.577E-07

7.486E-08

2.561E-08

1.099E-08

6.193E-09

3.977E-09

N

2.551E-06

8.787E-07

4.033E-07

2.428E-07

1.660E-07

7.865E-08

2.679E-08

1.144E-08

6.420E-09

4.109E-00

NNE

2.778E-06

9.571E-07

4.397E-07

2.648E-07.

1.810E-07

8.552E-08

2.891E-08

1.220E-08

6.775E-09

4.296E-09

NE

2.839E-06

9.765E-07

4.446E-07

2.663E-07

1.814E-07

8.536E-08

2.880E-08

1.221E-08

6.830E-09

4.363E-09

ENE

2.909E-06

1.011E-06

4.612E-07

2.760E-07

1.878E-07

8.812E-08

2.946E-08

1.233E-08

6.823E-09

4.318E-09

E

3.221E-06

1.111E-06

5.025E-07

2.994E-07

2.031E-07

9.498E-08

3.169E-08

1.331E-08

7.396E-09

4.702E-09

ESE

3.088E-06

1.055E-06

4.773E-07

2.848E-07

1.935E-07

9.062E-08

3.028E-08

1.271E-08

7.045E709

4.465E-09

SE

3.232E-06

1.107E-06

4.980E-07

2.959E-07

2.005E-07

9.349E-08

3.113E-08.

1.307E-08

7.276E-09

4.634E-09

SSE

3.564E-06

1.228E-06

5.555E-07

3.310E-07

2.246E-07

1.050E-07

3.507E-08

1.474E-08

8.195E-09

5.213E-09

a\2.531E-06 = 2.531 x 10-6.

Table W.6.

Directionfrom Site

D/Q (1/M 2 ) Values Used in Population Dose Estimates
Segment Boundaries (in miles)
4-5
5-10

0.5-1

1-2

2-3

3-4

S

4.720E-09a

1.458E-09

5.803E-10

3.171E-10

2.016E-10

SSW

2.723E-09

8.413E-10

3.348E-10

1.829E-10

SW

3.654E-09

1.129E-09

4.492E-10

WSW

5.251E-09

1.622E-09

W

8.044E-09

2.485E-09

WNW

7.223E-09

NW

10-20

20-30

30-40

40-50

8.658E-11

2.685E-11

1.064E-11

5.682E-12

3.517E-12

1.163E-10

4.994E-11

1.549E-11

6.138E-12

3.278E-12

2.029E-12

2.455E-10

1.560E-10

6.702E-11

2.078E-11

8.237E-12

4.399E-12

2.723E-12

6.456E-10

3.528E-10

2.242E-10

9.631E-11

2.987E-11

1.184E-11

6.321E-12

3.912E-12

9.890E-10

5.404E-10

3.435E-10

1.475E-10

4.575E-11

1.813E-11

9.683E-12

5.994E-12

2.232E-09

8.880E-10

4.853E-10

3.084E-10

1.325E-10

4.108E-11

1.628E-11

8.695E-12

5.382E-12

5.862E-09

1.811E-09

7.206E-10

3.938E-10

2.503E-10

1.075E-10

3.334E-11

1.321E-11

7.056E-12

4.367E-12

NNW

4.630E-09

1.431E-09

5.693E-10

3.111E-10

1.977E-10

8.492E-11

2.633E-11

1.044E-11

5.574E-12

3.450E-12N

5.431E-09

1.678E-09

6.677E-10

3.649E-10

2.319E-10

9.961E-11

3.089E-11

1.224E-11

6.538E-12

4.047E-12

NNE

5.712E-09

1.765E-09

7.022E-10

3.837E-i0

2.439E-10

1.048E-10

3.248E-11

1.287E-11

6.875E-12

4.256E-12

NE

5.722E-09

1.768E-09

7.034E-10

3M844E-16

2.443E-10

1.049E-10

3.254E-11

1.290E-11

6.887E-12

4.263E-12

ENE

5.927E-09

1.831E-09

7.286E-10

3.982E-10

2.531E-10

1.087E-10

3.371E-11

1.336E-11

7.134E-12

4.416E-12E

8.725E-09

2.696E-09

1.073E-09

5.862E-10

3.726E-10

1.600E-10

4.962E-11

1.967E-11

1.050E-11

6.501E-12

ESE9.701E-09

2.997E-09

1.193E-10

6.517E-10

4.142E-10

1.779E-10

5.517E-11

2.187E-11

1.168E-11

7.228E-12

SE

1.206E-08

3.726E-09

1.483E-09

8.101E-10

5.149E-10

2.212E-10

6.858E-11

2.718E-11

1.452E-11

8.985E-12

SSE

9.071E-09

2.802E-09

1.115E-09

6.094E-10

3.873E-10

1.664E-10

5.159E-11

2.045E-11

1.092E-11

6.758E-12

a 4.720E-09= 4.720 x 10-9.

W-8
The same assumptions were made for the liquid releases as were made for the gaseous releases
described above regarding consumption rates during releases of radioactivity.
Thus, the calculations result in estimates of the average expected value, rather than the actual value, particularly for very short-term releases.
Table W.1 lists the tables of Regulatory Guide 1.109 where model input parameters can be found.Other model parameters which are particularly relevant to liquid pathways are listed in Table W.7.

Table W.7.
Parameters Used in Maximum Individual
Dose Calculations and Dose to Biota
Calculation for Liquid Pathways
Parameter

Value

Adult fish consumption

21 kg/yr

Adult water consumption

730 kg/yr

River flow at fish location for
doses to humans

3150 ft 3 /sRiver flow at nearest water intake
for dose to humans

12,600 ft 3 /sRiver flow for dose to fishes
in river12,600 ft 3 /s

The river flow used for the,computation of maximum individual doses from fish consumption is /based on the average flow in the center channel of the river' where the releases. are made.
100%
mixing is assumed, not because 100% is expected to occur, but because as described in Appendix E,
Section E.1, all species of fish in the area exhibit considerable movement, especially over thetime required to bioaccumulate radionuclides (several days).
The river flow used for the computation of the maximum individual dose from water consumption is based on the average flow in theentire river.
100% mixing is expected by the time the effluent reaches the first downstream
drinking water intake because it is 16 miles downriver from the discharge point.
For population dose calculations, it was assumed that 2.2 million people live in the 50-mileradius around Three Mile Island and they get all their drinking water from the nearest downstream
municipal water intake. This assumption is very conservative, since the actual population drawing
water from nearby downstream locations would not be expected to approach this figure for many
years.
The dose from sport fish consumption was based on the number of fishing licenses issued
in the four counties downstream of TMI.
Approximately 50,000 are issued per year. To estimate
the fish consumption population dose it was assumed that each angler caught ten pounds of fish
per year of which three pounds consisted of edible fish flesh (see page 6, Appendix III\of the
TMI Environmental Report, 1971).
It was assumed that the downstream shoreline, swimming and boating use was 83,000 hours per year, 120,000 hours per year, and 520,000 hours per year, respectively.
Population dose estimates from all pathways were based on an assumed river flow of
12,600 ft 3 /s and uniform release of radionuclides over a period of one year.

References
1.

F.D. Hoffman,
Radionuclide
Conf.-770901,

2.

C.A. Little, and C.W. Miller, "The Uncertainty Associated with Selected Environmental
Transport Models," Oak Ridge National Laboratory, ORNL-5528, Oak Ridge, TN, November 1979.

et al., "The Evaluation of Models Used for the Environmental Assessment of
Releases," Workshop Proceedings, Oak Ridge National Laboratory, ORNLOak Ridge, TN, April 1978.

II

APPENDIX X.

CONTRIBUTORS TO THE PEIS

The overal'l responsibility for the preparation of this statement was assigned to the Three Mile
Island Program Office of the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory
Commission.
The statement was prepared by members of the TMI Program Office with substantial
assistance from other NRC components, the Argonne National Laboratory and other consultants
indicated below.
The individuals who were major contributors are listed below with theiraffiliations and functions or expertise:
NAME

AFFILIATION

NRC - Office of Nuclear
Oliver D. T. Lynch,

FUNCTION OR EXPERTISE

Reactor ReQulationJr.

TMI Program Office

Project Manager

Paul H. LeechTMI Program Office

Project Manager

Ronnie Lo

TMI Program Office

Nuclear Engineering

Richard Weller

TMI Program Office

Nuclear Engineering

Donald S. Brinkman

TMI Program Office

Nuclear Engineering

William D. Travers

TMI Program Office

Nuclear Engineering

Joseph R. Levine

Accident Evaluation Branch

Meteorology

Charles W. Billups

Environmental Engineering Br.

Aquatic Ecology/Fisheries

Clarence R. Hickey

Environmental Engineering Br.

Aquatic Ecology/FisheriesRichard B. Codell

Hydrology & Geotech.

Engr. Br.

Hydrolic Engineering

Terry L. Johnson

Hydrology & Geotech.

Engr. Br.

Hydrolic Engineering

Walter J.

Pasciak

Radiological Assessment BranchRadiological

Effects

Lynne A. O'Reilly

Radiological Assessment BranchRadiological

Effects

Michael Kaltman

Site Analysis Branch

Regional Planning Analysis

Site Analysis BranchSocial Psychology

William E. Rodak,Jr.

NRC - Office of Nuclear Materials Safety & SafeQuards
Timothy C. Johnson

Division of Waste Management

Waste Analysis

Homer Lowenburg

Division of Fuel Cycle & Material
SafetyWaste Analysis

Environmental

ImpactStudies

Program Manager (ANL)

James H. Opelka

Environmental

ImpactStudies

Project Leader (ANL)

Joel B. Heineman

Reactor Analysis and Safety

Accidents/Effluents andReleases

Donald J. Malloy

Reactor Analysis and Safety

Reactor Physics

Charles J. Meuller

Reactor Analysis and Safety

Reactor Physics

Frank J. Tebo

Reactor Analysis and Safety

Accidents/Effluents andReleases

Carl E. Johnson

Chemical Engineering

Waste Processing

Argonne National Laboratory
William J.

Hallett

X-1

X-2
NAME

AFFILIATION

Waldemar B. Seefeldt

ChemicalErnest Hutter

Experimental Breeder Reactor II

Defueling

Wayne K. Lehto

Experimental Breeder Reactor II

Decontamination

Roy J. McConnell

Experimental Breeder Reactor II

Defueling

John Poloncsik

Experimental Breeder Reactor II

Defueling

Lavaun R. Monson

Experimental Breeder Reactor II

Defueling

Ping C. Chee

Environmental Impact Studies

Radiological Effects

Thomas L. Gilbert

Environmental Impact

Decontamination

FUNCTION OR EXPERTISE
Effluents and Releases

Engineering

Studies

Other Consultants
Richard I.

Smith

Battelle Pacific Northwest Laboratory

Decommissioning Evaluations

Gregory M. Holter

Battelle Pacific Northwest Laboratory

Decommissioning Evaluations

George J. Konzek

Battelle Pacific Northwest Laboratory

Decommissioning Evaluations

Andrew S. Baum

Human Design Group

Psychology

Robert E. Berlin

Waste Management Group

Waste Transport

Peter T. Tuite

Waste Management Group

Waste Processing & Disposal

Dennis M. Myers

Rogers and Associates Engineering

Decontamination

APPENDIX Y. SCHEDULED MEETINGS FOR DISCUSSION OF TMI-2 CLEANUP DRAFTPROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT (1980)

September 3

Public Meeting - State Education Dept.,
Pa.)

Forum Auditorium.(Harrisburg,

Septembe.r 5

Susquehanna River Basin (Harrisburg,

September

16

Meeting with local

September

17

Meeting with Dauphin County Commissioners
Public Meeting with .TMI AlertPa.)

labor unions

September 18

Meeting with York County Commissioners
Public Meeting with Against Nuclear Group Residents of York (ANGRY)(York, Pa.)

September

19

Meeting with local members of clergy (Middletown,

September

22

NRC representative appeared on call-in, Radio Station WAHT, Fred Williams
Show
Meeting with West Shore local elected officials in Camp Hill, Pa.

Pa.)

September 23

Meeting with East Shore local elected officials (Middletown,

September

Meeting with local labor unions in York area

25

September 27

Meeting with American Association of University Women,

September

Meeting with Pa.

29

Meeting with Friends and Family of TMI*Public Meeting in Annapolis, Md.

October 2

Area Chambers of Commerce (Harrisburg,
Meeting with Rotary in Middletown, Pa.
*Public Meeting - Lancaster, Pa.

October 7

Reading,Pa.

Grange Association

September 30

October 6

Pa.)

Pa. )

October 8

Meeting with the Pa. Farmers Association in Camp. Hill
*Public Meeting with Newberry Township Steering Committee

October 20*Public Meeting with People Against Nuclear Energy (PANE),

October 23*Meeting with Pa.

Medical Society

October 29*Public Meeting•-

Havre de Grace,

October 31

Meeting with Lebanon Valley Chamber of Commerce

November 6
November 10

Meeting with Middletown Rotary Club
*Public Meeting - State Education Dept.,

November

12Pa.)*Public Meeting of NRC TMI Advisory Panel

November

13

November

17

Meeting of Lancaster Jaycee's*Public Meeting -. Baltimore

November

19*Public Meeting - Middletown,*Verbatim Transcripts Prepared.

Y-1

Pa.

Middletown,

Md.

Forum Auditorium (Harrisburg,

Pa.

APPENDIX Z.

HEALTH EFFECTS ESTIMATORSIn estimating the number of health effects resulting from both offsite and occupational radiation
exposures during the cleanup, the NRC staff used best estimate somatic (cancer) and genetic risk
estimators based on widely accepted scientific information.
Specifically, the staff's estimatesare based on information compiled by the National Academy of Science's Advisory Committee on the
Biological Effects of Ionizing Radiation (BEIR).'
Although a detailed discussion of the literature available on this subject is outside the scope of this document, this appendix includes:(1) information that details the bases for health effect estimators used by the NRC staff, and(2) perspective on the uncertainty associated with estimating radiation-induced health effects.
The base data used for the fatal cancer risk estimators (expressed as deaths per million personrem) used by the NRC staff can be found in Section 9.3.2, "Upper Boundfor Latent Cancer
Fatalities," in the NRC staff's "Reactor Safety Study, WASH-1400, October 1975.2 Specifically,
the data on "Upper Bound Risk Coefficients for Latent Cancer Fatalities," Table VI 9-2, for
specific age' groups were used.. Tables. Z.1 through Z.8 contain, for different cancer types, theage, specific data and calculations which, when summed in Table Z.9, yield the cancer risk estimators used by the NRC staff (131 and 135) deaths per million person-rem for workers and individual members of the public, respectively).
The WASH-1400 (October 1975) coefficients are basedon BEIR, 1972, and on new data made-available since the, issuance of BEIR, 1972.
Table Z.10 ispresented to provide perspective on the uncertainty involved in making estimates of radiationinduced health effects. The basis for each of these estimates can be found in greater detail inthe listed references.
The NRC staff's genetic risk estimator (260-genetic effects per million total-body person-rem inthe future generations of the exposed population) was derived from the 1972 BEIR report.'
Specifically, this value can be calculated by summing the geometric means of the distributions given
in Table 4, ChapterV, of that report. The geometric mean is an appropriate technique for obtaining a representative value for the 1972 BEIR report's range of 60 to..1500 genetic effects per
million person-rem.
The 1980 BEIR report listed a range of 60 to 1100 genetic effects in offspring per million person-rem. 3
In summary, several points should be emphasized.
The values utilized by the NRC staff for estimating potential health effects associated with the decontamination of TMI-2 are based on widely
accepted sci'entific information.
Even if upper range BEIR, 1980, risk estimators were used tocharacterize potential health effects from the cleanup, those health effects would remain small
compared to natural incidence.

References
1.

"The Effects on Populations of Exposure to Low-Levels of Ionizing Radiation," National
Academy of Science, Advisory Committee on the Biological Effects of Ionizing Radiation(BEIR), November 1972.

2.

"Reactor Safety Study," U.S. Nuclear Regulatory Commission, WASH-1400,

3.

"The Effects on Populations of Exposure to Low-Levels of Ionizing Radiation," National
Academy of Science, Advisory Committee on the Biological Effects of Ionizing Radiation(BEIR), 1980.

4.

"Sources and Effects of Ionizing Radiation," United Nations Scientific Committee on the
Effects of Atomic Radiation (UNSCEAR),
1977 Report to the General Assembly, New York, NY,
1977.

Z-1

October 1975.

Z-2

Table Z.1.

Calculation of Expected Leukemia Deaths for External Exposure

(A)

(B)

(C)

(D)

(E)

(F)

Age
Cohort(years)Fraction ofPopulation

Life
Expectancy(years)

LatentPerioda(years,)

Years
at
Risk

Risk
Factor.(10 6 /rem/year)

Expected
Deaths(F=AxDxE)

In utero

0.011

71.0

0

10

15

1.65

0-0.99

0.014

71.3

2

25

2

0.70

1-10

0.146

69.4

2

25

2

7.3

11-20

0.196

60.6

2'

25

1

4.9

21-30

0.164

51.3

2

25

1

4.10

31-40

0.118

42.0

2

25

1

2.95

41-50

0.109

32.6

2

25

1

2.75

51-60

0.104

24.5

2

22.5

1

2.34

61-70

0.080

17.1

2

15.1

1

1.21

71-80

0.044

11.1

2

9.1

1

0.40

80+

0.020

6.5

2

4.5

1

0.09
28.4

(23.2)

aThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational workers (ages 20-70).

Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping(estimated between 20 and 70 years).
The offsite population estimator'is based on
the 1970'U.S. population age group distribution.

I

Z-3

Table Z.2.

I

Calculation of Expected Lung Cancer Deaths for External Exposure

(A)

(B)

(C)

(D)

(E)

(F)

Age
Cohort(years)Fraction ofPopulation

Life
Expectancy(years)

LatentPeriod(years)

Years
at
Risk

Risk
Factor(10 6 /rem/year)

Expected
Deaths(,F-AxDxE)

In utero

0.011

71.0

-

0-0.99

0.014

71.3

-

1-10

0.146

69.4

....

11-20

0.196

60.6

15

30

1.3

7.64

21-30

0.164

51.3

15

30

1.3

6.40

31-40

0.118

42.0

15

27

1.3

4.14

41-50

0.109

32.6

15

17.6

1.3

2.49

51-60

0.104

24.5

15

9.5

1.3

1.28

61-70

0.080

17.1

15

2.1

1.3

0.22

71-80

0.044

11.1.

15

0

1.3

0

80+

0.020

6.5

15

0

1.3

0
22.2

(25.3)baThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational

workers (ages 20-70).

Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator is based on
the 1970 U.S. population age group distribution.

Z-4

Table Z.3.

Calculation of Expected Stomach Cancer Deaths for External Exposure

(A)

(B)

(C)

(D)

(E)

(F)

Age
Cohort(years)Fraction ofPopulation

Life'
Expectancy(years)

LatentPeriod a(years)

Years
at
Risk

Risk
Factor(10 6 /rem/year)

Expected
Deaths(F=AxDxE)

In utero

0.011

71.0

0-0.99

0.014

71.3

1-10

0.146

69.4

--

11-20

0.196

60.6

15

30

0.6

3.53

21-30

0.164

51.3

15

30

0.6

2.95

31-40

0.118

42.0

15

27

0.6

1.91

41-50

0.109

32.6

15

17.6

0.6

1.15

51-60

0.104

24.5

15

9.5

0.6

0.59

61-70

0.080

17.1

15

2.1

0.6

0.10

71-80

0.044

11.1

15

0

0.6

0

80+

0.020

6.5

15

0

0.6

0

-

-

10.2

(11.7)

aThe latent period is that period oftime between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational workers (ages 20-70).
Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator is based on
the 1970 U.S. population age group distribution.

Z-5

Table Z.4.

Calculation of Expected Pancreas and Alimentary Canal Cancer Deaths
for External Exposure(A)
Age
Cohort(years)Fraction ofPopulation

(B)
Life
Expectancy(years)In utero

0.011

71.0

0-0.99

0.014

71.3

1-10

0.146

69.4

--

11-20

0.196

60.6

15

30

0.2

1.18

21-30

0.164

51.3

15

30

0.2

0.98

31-40

0.118

42.0

15

27

0.2

0.64

41-50

0.109

32.6

15

17.6

0.2

0.38

51-60

0.104

24.5

15

9.5

0.2

0.20

61-70

0.080

17.1

15

2.1

0.2

0.03

71-80

0.044

11.1

15

0

0.2

0

80+.

0.020

6.5

15

0

0.2

0

(C)
LatentPeriod a(years)

(D)
Years
at
Risk

(E)
Risk
Factor(10 6 /rem/year)(F)
Expected
Deaths(F=AxDxE)

-

3.4

(3.9)

aThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational

workers (ages 20-70).

Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator is based on
the 1,970 U.S. population age group distribution.

Z-6

Table Z.5.

Calculation of Expected Breast Cancer Deaths for External Exposure(A)
Fraction ofPopulation

(B)
Life
Expectancy(years)(C)
LatentPerioda(years)In utero

0.011

71.0

....

0-0.99

0.014

71.3

.....

1-10

0.146

69.4

11-20

0.196

21-30

(0)
Years
at
Risk

(E)
Risk b
Factor6(10 /rem/year)

-

-

-

-

60.6

15

30

1.5

8.82

0.164

51.3

15

30

1.5

7.38

31-40

0.118

42.0

15

27

1.5

4.78

41-50

0.109

32.6

15

17.6

1.5

2.88

51-60

0.104

24.5

15

9.5

1.5

1.48

61-70

0.080

17.1

15

2.1

1.5

0.25

71-80

0.044

11.1

15

0

1.5

0

80+

0.020

6.5

15

0

1.5

0

Age
Cohort(years)-(F)
Expected
Deaths(F=AxDxE)

25.6( 2 9 .2 )caThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bAssumes 50 percent mortality.
cValues-in parentheses represent risk estimates for occupational workers (ages 20-70).

Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years). The offsite population estimator is based on
the 1970 U.S. population age group distribution.

I

Z-7

Table Z.6.

Calculation of Expected Bone Cancer Deaths for External(A)

Exposure

Fraction ofPopulation

(B)
Life
Expectancy(years)(C)
LatentPerioda(years)In utero

0.011

71.0

-

-

0-0.99

0.014

71.3

10

30

0.4

0.17

1-10

0.146

69.4

10

30

0.4

1.75

11-20

0.196

60.6.

10

30

0.4

2.35

21-30

0.164

51.3

10

30

0.2

0.98

31-40

0.118

42.0

10

30

0.2

0.71

41-50

0.109

32.6

10

22.6

0.2

0.49

51-60

0.104

24.5

10

14.5

0.2

0.30

61-70

0.080

17.1

10

7.1

0.2

0.11

71-80

0.044

11.1

10

1.1

0.2

0.01

80+

0.020

6.5

10

0

0.2

0

Age
Cohort(years)

(D)
Years
at
Risk

(E)
Risk
Factor(10 6 /remyear)(F)
Expected
Deaths(F=AxDxE)

6.9( 4 . 5 )baThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational workers (ages 20-70).
Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator is based on
the 1970 U.S. population age group distribution.

I

I

Z-8

Table Z.7.

Calculation of Expected Thyroid Cancer Deaths for External Exposure

(A)

(B)

(C)

(D)

(E)

(F)

Age
Cohort(years)Fraction ofPopulation

Life
Expectancy(years)

Latent a
Period(years)

Years
at
Risk

Risk
Factorb(10 6 /rem/year)

Expected
Deaths(F=AxDxE)

In utero

0.011

71.0

-

-..

0-0.99

0.014

71.3

10

30

4.3 x 1.0

0.181

1-10

0.146

69.4

10

30

4.3 x 1.9

3.58

11-20

0.196

60.6

10

30

4.3 x 1.6

4.05

21-30

0.164

51.3

10

30

4.3 x 1

2.12

31-40

0.118

42.0

10

30

4.3 x 1

1.53

41-50

0.109

32.6

10

22.6

4.3 x 1

1.06

51-60

0.104

24.5

10

14.5

4.3 x 1

0.648

61-70

0.080

17.1

10

7'.1

4.3 x 1

0.244

71-80

0.044

11.1

10

1.1

4.3 x 1

0.021

80+

0.020

6.5

10

0

4.3 x 1

0
12.4

(9.7)caThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bAssumes 10 percent mortality.
Values in parentheses represent risk estimates for occupational workers (ages 20-70).
Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator*is based on
the 1970 U.S. population age group distribution.

I.

Z-9

Table Z.8.

Calculation of All Other Expected Cancer Deaths for External Exposure

(A)

(B)

(C)

(D)

(E)

(F)

Age
Cohort(years)Fraction ofPopulation

Life
Expectancy(years)

LatentPeriod(years)

Years
at
Risk

Risk
Factor(10 6 /rem/year)

Expected
Deaths(F=AxDxE)

In utero

0.011

71.0

0

10

15

1.65

0--0.99

0.014

71.3

15

30

0.6

0.25

1-10

0.146

69.4

15

30

0.6

2.63

11-20

0.196

60.6

15

30

1

5.88

21-30

0.164

51.3

15

30

1

4.92

31-40

0.118

42.0

15

27

1

3.19

41-50

0.109

32.6

15

17.6

1

1.92

51-60

0.104

24.5

15

9.5

1

0.99

61-70

0.080

17.1

15

2.1

1

0.17

71-80

0.044

11.1

15

0

1

0

80+

0.020

6.5

15

0

1

0
21.6

( 1 9 . 5 )baThe latent period is that period of time between radiation exposure and the manifestationof a cancer.
bValues in parentheses represent risk estimates for occupational workers (ages 20-70).
Therisk estimator (see Table Z.9) for workers includes consideration of the workers' age
grouping (estimated between 20 and 70 years).
The offsite population estimator is based on
the 1970 U.S. population age group distribution.

Z-10

Table Z.9.

Maximum Expected Latent Cancer Deaths
Per Million Person-rem
Expected Deaths/lO6 Person-Rem

Type of Cancer

General Public

Occupational

Leukemia
Lung
StomachAlimentary canal
Pancreas
BreastBone
Thyroidb
All others

28.4
22.2
10.2
3.4
3.4
25.6
6.9
13.4
21.6

23.2
25.3
11.7
3.9
3.9
29.2
4.5
9.7
19.5

ý135

131

aAssumes 50 percent mortality/case.
bAssumes 10 percent mortality/case; all other types
assume 100 percent mortality.

Table Z.10;

Comparison of Fatal Cancer Risk Estimators
Cancer Mortality Estimators.(deaths/lO6 person-rem)

Source
NRC staff (PEIS)

135a

BEIR,

1980b

67-169

BEIR,

1972c

115-568

UNSCEAR,1977d75-175aRisk estimator used for members of the public.

For

6

workers, a risk estimator of 131 deaths/10 person-rem
was used.
This value accounts for worker age-specific(20-70) radiosensitivity.
bLinear-quadratic dose-response model for absolute andrelative projection models.
These values represent
the BEIR committee's stated best estimate.
However,.the committee also pointed out that the linear and pure
quadrate effects models also fit observed data nearly
as well.
Projected health effects from those models
would range from about 10 to 500 deaths per million
person-rem.
An update of BEIR, 1972 (Ref. 3).
cValues obtained from Table V-4, BEIR, 1980, are an
update of values obtainable in Tables 3-3 and 3-4 of
BEIR, 1972.
Range attributable to differences between
absolute and relative projection models (Ref. 1).
dRange of estimates for low-dose, low-LET radiation
(Ref.

4).

II

NRC FORm 335

1. REPORT NUMBER (AssnedOb DDC)
U.S. NUCLEAR(7 77)REGULATORY COMMISSION

BIBLIOGRAPHIC DATA SHEETNUREG-0683,

4 TITLE AND SUBTITLE (Add Volume No. ifappropriate)

Volume II

2 (Leave blank)

Final Programmatic Environmental Impact Statement related
to decontamination and disposal of radioactive wastes reJýAfg
•frCm hMf r~k 2,accident at Three Mile
7. AUTHOR(SI

3. RECIPIENT'S ACCESSION NO.
5. DATE REPORT COMPLETED
YEAR

MONTH

March
9. PERFORMING ORGANIZATION

NAME

AND MAILING ADDRESS(Include Zp Code)

D.

C.

6

(Leave blank)

8.

(Leave blank)

20555

__

12. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS1981

REPORT ISSUED

MA'hThree Mile Island Program Office
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington,

DATE

I.YE1 81__

10. PROJECTTASK/WORKUNIT NO.

(Include Zip Code)Three Mile Island Program Office
Office of Nuclear Reactor Regulation

11. CONTRACT NO.

U.S. Nuclear Regulatory Commission
Washington, D. C. 20555
13. TYPEOF REPORTPERIOD COVEREDFinal Programmatic Environmental
Statement(Inclusive dates)

Impact.

15. SUPPLEMENTARY NOTES

14 (Leave olank)

16. ABSTRACT (200 words or less)

A Final Programmatic Environmental Impact Statement (PEIS) related to the decontaminationand disposal of radioactive wastes resulting from the March 28, 1979, accident at Three
Mile Island Nuclear Station, Unit 2 (Docket No. 50-320) has been prepared by the Officeof Nuclear Reactor Regulation of the Nuclear Regulatory Commission in response to a
directive issued by the Commission on November 21, 1979.
This statement is an overall
study of the activities-necessary for decontamination of the facility, defueling, anddisposition of the radioactive wastes.
The available alternatives considered ranged from
implementation of full cleanup to no action other than continuing to maintain the reactor
in a safe shutdown condition.
Also included are comments of governmental agencies,. otherorganizations, and the general public on the Draft PEIS on this project, and staff
responses to these comments.

17. KEY WORDS AND DOCUMENT ANALYSIS

17b

IDENTIFIERS OPEN-ENDED

18. AVAILABILITY STATEMENT

Unlimited

17d

DESCRIPTORS

TERMS

19. SECURITY CLASS.tTns report)

UnclassifiedTT
Y c,,I.4SSg
20. U#CUPfIUrCI asslI
ed nhs page)

21 NO

OF PAGES

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