ML20106J132

Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28,1979 Accident,Three Mile Island Nuclear Station,Unit 2.Docket No 50-320 (Gpu Nuclear,Incorporated)

ML20106J132
Person / Time
Site:	Crane
Issue date:	10/31/1984
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0683, NUREG-0683-S01, NUREG-683, NUREG-683-S1, NUDOCS 8411010080
Download: ML20106J132 (175)

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{{#Wiki_filter:i NUREG-0683 Supplement No.1 I Final Report l ~ Programmatic Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from March 28,1979 accident Three Mile Island Nuclear Station, Unit 2 Docket No. 50-320 Final Supplement Dealing with Occupational Radiation Dose GPU Nuclear, Inc. = U.S. Nuclear Regulatory Commission TMI Program Office October 1984 ("%,, N !$$1E$00!o!$o0$$o D PDR

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I NUREG-0683 Supplement No.1 Final Report Programmatic Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from March 28,1979 accident Three Mile Island Nuclear Station, Unit 2 Docket No. 50-320 Final Supplement Dealing with Occupational Radiation Dose l GPU Nuclear, Inc. I U.S. Nuclear Regulatory Commission TMI Program Office ! October 1984 (""'%,, i

ABSTRACT 1. Proposed Action and Location: DECONTAMINATION AND DISPOSAL OF RADI0 ACTIVE WASTES RESULTING FROM THE MARCH 28, 1979, ACCIDENT AT THREE MILE ISLAND NUCLEAR STATION, UNIT 2 LOCATED IN LONDONDERRY TOWNSHIP, DAUPHIN COUNTY, PENNSYLVANIA 2. Dr. Ronnie Lo is the Project Manager for this supplement. He may be contacted at the Three Mile Island Program Office, U.S. Nuclear Regu-latory Commission, Washington, DC 20555 or at 201-492-8335. 3. In accordance with the National Environmental Policy Act, the Program-matic Environmental Impact Statement Related to Decontamination and Dis-posal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2 has been supplemented. The supple-ment was required because current information indicates that cleanup may entail substantially more occupational radiation dose to the cleanup work force than originally anticipated. Cleanup was originally estimated to result in from 2000 to 8000 person-rem of occupational radiation dose. Although nearly 2000 person-rem have resulted from cleanup operations performed up to now, current estimates now indicate that between 13,000 and 46,000 person-rem are expected to be required. Alternative cleanup methods considered in the supplement either did not result in appreciable dose savings or were not known to be technically feasible. i

SUMMARY

The Final Programmatic Environmental Impact Statement Related to Decon-tamination and Disposal of Radioactive Wastes Resulting from March 28, 1979, Accident Three Mile Island Nuclear Station, Unit 2 was issued by the U.S. Nuclear Regulatory Commission in March 1981. That document (referred to as the PEIS) stated that the most significant environmental impact of cleanup activities at Three Mile Island Unit 2 (TMI-2) would result from the radiation dose to the cleanup work force. The purpose of this supplement to the PEIS is to reevaluate the occupational radiation dose and resulting health effects from cleanup and to address additional alternative cleanup approaches using information gathered since the PEIS was prepared. As a supplement to the PEIS, this document should be considered part, of the earlier PEIS. For completeness, reference to the PEIS should be made for all aspects of the NRC's National Environmental Policy Act review of the TMI-2 cleanup, other than the radiation exposures and resultant health effects which are the subject of this supplement. When the PEIS was prepared, it was believed that 2000 to 8000 person-rem of occupational radiation dose would be i the decontamination Through May 1984,gcyrred during and defueling of TMI-2. about 2000 person-rem have been incurred in cleanup. When the PEIS was prepared, the reactor building had been entered only five times. Since then, it has been entered more than 366 times to collect data, conduct tests, perform decontamination tests and decontamination, refurbish the polar crane, remove trash and contaminated equipment, and prepare for reactor vessel head lift and fuel removal. These entries have resulted in increased knowledge of the actual conditions in the building and awareness of the penetration of contamination into surfaces and the extent of corrosion, which have greatly increased the difficulty of the cleanup task. The temperatures reached during the accident and the time between the accident and the initiation of cleanup are thought to be factors in the decreased effectiveness of cleanup procedures. Based on additional information available, decontamination workers at the plant are expected to receive a total collective radiation dose estimated at between 13,000 and 46,000 person-rem for the whole cleanup program. Doses to individual workers are limited by the health and safety standards in federal regulations. The licensee has agreed to set administrative controls that are lower than the limits in federal regulations to make sure that exposures of individual workers will be below the federal limits. Estimates of potential health effects due to exposure of the workforce have been made assuming that individual worker exposures are within regulatory limita. In the analysis in this report, it has been conservatively assumed that any exposure to radiation has a finite probability of causing cancer in the exposed workforce, and a finite probability of causing genetic abnormalities in the offspring of the exposed workforce. Using the preceding range of collective dose estimates (i.e., 13,000 to 46,000 person-rem), the staff estimates that about 2 to 6 potential premature cancer deaths may occur in the total exposed workforce, (a) In order to prepare this supplement, a cutoff date of May 11, 1984, was established for data. iii

during the remaining lifetime of the workers. In addition, a total of avout I to 3 potential additional genetic disorders may occur over all future gene-rations of the exposed workforce. The staif has used a central value for health risk estimators in estimating these health ef fects. In addition to uncertainties in collective dose estimates, there are also uncertainties in the data base used to estimate health effects. Using the most widely accepted range of health risk estimators, the staff estimates that the range of poten-tial cancer deaths extends from 0 to as high as 26 for the highest workforce exposure estimate. In a similar manner, the range of potential genetic dis-orders extends from less than 1 for the lowest workforce exposure estimate to 17 for the highest workforce exposure estimate. It is important to note that these potential cancer deaths and potential genetic ef fects, if they occur, would be added to the expected 2,000 cancer deaths among the workforce and 5,000 genetic effects in the first five generations of the workers from natural phenomena, assuming a workforce of 10,000. These potential cancer deaths and potential genetic effects, if they were to occur, would not be statistically discernable. That is, the number of health effects falls well within the statistical variations of the expected cases of cancer fatalities and genetic effects among the cleanup workers and their offspring from causes unrelated to radiation exposures during the cleanup. In accordance with the requirements of the National Environmental Policy Act, both the current cleanup plan and several alternative approaches were examined for their impact on occupational dose. The current plan calls for a dose reduction effort prior to defueling of the reactor, with primary-system decontamination and final building cleanup to follow defueling. Only one of the three additional alternatives considered in the supplement would result in an appreciably lower occupational dose than that expected to result from the current plan, but significant disadvantages are associated with this alterna-tive, as discussed below. The first alternative considers using approximately the same task se-quence as that considered the most likely approach when the PEIS was origin-ally prepared, that is, extensive cleanup of the reactor building prior to defueling. The purpose of evaluating this alternative was to determine how changing the work sequence from that of the current plan affects the occupa-tional radiation dose, given current information. In evaluating this alterna-tive, it was determined that some reduction in dose, up to approximately 10%, might be expected; however, the dose reduction is not considered sufficient to justify the delays in fuel removal. Fuel temoval delays are considered unde-sirable because the fuel continues to pose a potential risk to workers and the public and because information obtained from examining the fuel is expected to be useful in improving the safety of other nuclear power facilities. The second alternative considers phased defueling followed by decontami-nation and building cleanup. Phased defueling would involve removing fuel debris through the reactor pressure vessel head before removing the head and plenum. This approach would minimize the possibility that fuel fines would contaminate equipment and result in personnel exposure during later opera-tions. However, no net savings in dose to workers would result becoune of the need for additional work. This approach would delay fuel removal and all subsequent cleanup activities for a minimum of 18 monthn. iv -m --m-m--

The third alternative parallels the current plan through fuel removal, but then considers putting the reactor building, and possibly some of the more highly contaminated portions of the auxiliary and fuel-handling building, into a monitored, interim storage until additional decontamination activities could be performed robotically. This alternative, if found to be technically feas-ible, is expected to result in the lowest worker dose. However, there are obstacles associated with this alte rnative, including uncertainty about when robotic technology will have evolved enough to be feasible for extensive use in completing cleanup; lack of information about the feasibility and safety of interim storage; and lack of assurance that funds will be available for ultimate cleanup. These obstacles preclude the immediate adoption of this alternative; however, it may warrant further consideration after defueling is completed. No decision is required on this alternative until after the fuel has been removed. Although this supplement's estimate of the dose to the workers who per-form cleanup and the possible resulting health effects are higher than those estimated in the PEIS, it is still the conclusion of the staff, as it was when the PEIS was completed, that cleanup should proceed as expeditiously as pos-sible to reduce the potential for release of radioactive materials to the environment and to ensure that TMI-2 does not become a long-term radioactive waste disposal site. If the damaged fuel and radioactive wastes are not re-moved, the Island would, in ef fect, become a permanent waste disposal site. The location, geology, and hydrology of Three Mile Island are among the fac-tors that do not meet current criteria for a safe long-term waste disposal facility. Removing the damaged fuel and radioactive waste to storage sites that do meet all of the relevant criteria is the only reliable means for eliminating the long-term risk of widespread uncontrolled contamination of the environment by the accident wastes. l 1 l l V l l

FOREWORD This supplement to the Programmatic Environmental Impact Statement on the decontamination and disposal of waste,from Three Mile Island Unit 2 (the PEIS) was prepared by the U.S. Nuclear Regulatory Comission. TMI Program Of fice, Office of Nuclear Reactor Regulation (the staff), pursuant to the Comission's April 27, 1981, Statement of Policy related to the PEIS and the requirements of the National Environmental Policy Act of 1969 (NEPA). Assistance was pro-vided by the Pacific Northwest Laboratory under the direction of the staff.

i..f hg?l In the policy statement, the Comission states that as the licensee pro-poses specific decontamination alternatives for each major cleanup activity, glk.

g the staff will determine whether these proposals, and associated impacts that [d,fff are predicted to occur, fall within the scope of those already assessed in the PEIS. The staff may act on each proposal if the proposed activity and asso-e@ 'M ciated environmental impacts fall within the scope of those assessed in the f j,'. PEIS. If an activity and its impacts fall outside of the scope of those in the PEIS, the staff shall complete necessary reviews in accordance with NEPA. $Q, & ?: -8 One of the conclusions of the PEIS was that the most significant environ- ~[* ' mental impact associated with cleanup would result from the radiation doses received by the entire work force from cleanup activities. At the time the hN 'g%y{. PEIS was prepared, it was estimated that the cleanup would require 2000 to 8000 person-rem of occupational radiation dose. Since the issuance of the y PEIS (March 1981) and the Comission's Statement of Policy (April 1981), a p -Q substantial amount of new information about the conditions inside the reactor 7 g building has become available. Based on the new information and the apparent y 't; decrease in decontamination effectiveness due primarily to delays in initiat-p

7..;

acconplish the entire cleanup could exceed the range predicted in the PEIS. g.? ing cleanup, the staff now believes that the total occupational dose to e (To date, nearly 2000 person-rem have been required.) Therefore, this supple- ~ ... D M,I ment to the PEIS has been prepared in compliance with NEPA requirements. r .? e Information for the supplement was obtained from the licensee's Environ-mental Report and Final Safety Analysis Report (Metropolitan Edison Co. and Jersey Central Power & Light Co. 1974), from the staff's Final Environmental Statement for the operating license (U.S. Nuclear Regulatory Comission 1976), QN from the staff's PEIS of March 1981, and from new information provided by the 3N% licensee or independently developed by the staff. The staff met with the 2375 licensee to discuss items of information provided, to seek new information hQ from the licensee that might be needed for an adequate assessment, and gen-g.p. erally to ensure that the staff had a thorough understanding of the cleanup

p. 4 ?

[VA$ operations. In addition, the staff sought information from other sources that would assist in the evaluation, and visited and inspected the project site and vicinity. k .,y,. y C ("% On the basis of the foregoing and other such activities or inquiries as were deemed useful and appropriate, the staff made an independent evaluation of the THI-2 cleanup plans and operations and prepared a draft supplement ' i unigmaz vii

to the PEIS. The draft supplement was circulated to federal, state, and local governmental agencies and to interested members of the public for comment. A summary notice of the availability of the draft supplement was published in the Federal Register. - The i supplement is based was made availabic to the public,grmation on which the and all comments received were considered by the staff. in preparing this final supplement. As a result of the comments received, specific changes were made in this final supplement, specifically in the estimation and presentation of health effects. In addition, the staff has agreed to reevaluate the environmental consequences of curtailing cleanup following fuel removal. The draft supplement used information that was current to August 22, 1983. For this final supplement, a cutoff date of May 11, 1984 was used. Since that time, a major milestone in cleanup has been reached. The reactor vessel head has been removed and stored behind shielding on the head storage stand on the 347-ft elevation. The internals indexing fixture was placed on the reactor vessel, filled and covered. Both the doses to perform this work and dose rates in the building following these activities were at the low end of the expected range. J (a) NRC Public Document Room, 1717 H Street, Washington, DC 20555, and NRC TMI Program Office, 100 Brown Street, Middletown, PA 17057. viii

P CONTENTS l

SUMMARY

iii Vii l FOREWORD

1.0 INTRODUCTION

1.1 1.1 PURPOSE AND SCOPE 1.1 l 1.2 HISTORY OF OCCUPATIONAL RADIATION DOSES RESULTING FROM CLEANUP ACTIVITIES 1.2 1.3 REGULATORY AND ADMINISTRATIVE CONTROLS FOR LIMITING OCCUPATIONAL DOSE 1.5 2.0 CURRENT AND ALTERNATIVE PLANS FOR CLEANUP OF REACTOR AND AUXILIARY BUILDINGS. 2.1

2.1 BACKGROUND

INFORMATION ON CLEANUP WORK 2.1 2.1.1 Cleanup of the Reactor Building and Equipment 2.1 2.1.2 Disassembly and Defueling of the Reactor 2.8 2.1.3 Decontamination of the Primary System. 2.11 2.1.4 Cleanup of the Auxiliary and Fuel-Handling Building 2.11 2.2 CURRENT CLEANUP PLAN: DOSE REDUCTION FOLLOWED BY DEFUELING AND DECONTAMINATION. 2.14 2.2.1 Tasks and Sequencing of the Current Cleanup Plan 2.15 l 2.2.1.1 Dose Reduction 2.15 l 2.2.1.2 Reactor Disassembly and Defueling 2.15 l i 2.2.1.3 Primary-System Decontamination. 2.19 2.2.1.4 Reactor Building and Equipment cleanup 2.19 l ~ 2.2.1.5 Auxiliary and Fuel-Handling Building Cleanup 2.20 l 2.2.2 Occupational Radiation Dose Associated with the Current Cleanup Plan 2.20 ix

2.3 ALTERNATIVE 1: EXTENSIVE CLEANUP FOLLOUED BY DEFUELING 2.22 2.3.1 Tasks and Sequencing of Alternative 1. 2.23 2.3.1.1 Reactor Building and Equipment Cleanup 2.23 2.3.1.2 Reactor Disassembly and Defueling, and Primary-System Decontamination. 2.23 2.3.2 Occupational Radiation Dose Associated with Extensive Cleanup Followed by Defueling 2.24 2.4 ALTERNATIVE 2: PHASED DEFUELING FOLLOWED BY REACTOR BUILDING CLEANUP 2.25 2.4.1 Tasks and Sequencing of Alternative 2. 2.26 2.4.1.1 Fines Removal Prior to Head Lif t 2.26 2.4.1.2 Reactor Disassembly and Defueling 2.27 2.4.1.3 Primary-System Decontamination, Auxiliary and Fuel-Handling Building Cleanup, and Reactor Building and Equipment Cleanup 2.27 2.4.2 Occupational Radiation Dose Associated with Phased Defueling Followed by Reactor Building Cleanup 2.27 2.5 ALTERNATIVE 3: DEFUELING FOLLOWED BY DELAYED CLEANUP USING ROBOTICS 2.29 2.5.1 Tasks and Sequencing of Alternative 3. 2.29 2.5.1.1 Reactor Disassembly and Defueling 2.29 2.5.1.2 Interim Storage of the Defueled Reactor 2.30 2.5.1.3 Primary-System Decontamination. 2.30 2.5.1.4 Robotic Cleanup of Reactor Building and Equipment 2.30 2.5.2 Occupational Radiation Dose Associated with Defueling Followed by Delayed Cleanup Using Robotics. 2.31 2.6 ANALYSIS OF CURRENT CLEANUP PLAN AND ALTERNATIVES. 2.32 2.6.1 Analysis of Public Safety 2.33 2.6.2 Analysis of Occupational Radiation Dose 2.33 X

2.6.3 Analysis of Time Schedule 2.34 2.6.4 Analysis of Technical Feasibility 2.40 2.6.5 Summary Analysis 2.40 3.0 REVISED ENVIRONMENTAL IMPACTS. 3.1 3.1 AFFECTED POPULATION. 3.1 J 3.2 REVISED OCCUPATIONAL-DOSE ESTIMATES 3.1 3.3 POTENTIAL HEALTH EFFECTS. 3.3

4.0 CONCLUSION

S 4.1

5.0 REFERENCES

5.1 6.0 DISCUSSION OF C0KHENTS ON DRAPT SUPPLEMENT 6.1 J 6.1 PURPOSE AND SCOPE OF THE SUPPLEMENT 6.2 6.2 CURRENT AND ALTERNATIVE PLANS FOR CLEANUP OF REACTOR AND AUXILIARY BUILDINGS. 6.3 6.3 ENVIRONMENTAL EFFECTS 6.7 6.4

GENERAL COMMENT

S 6.12 6.5 UASTE MANAGDiENT 6.12 APPENDIX A - C0:CIENTS ON THE DRAFT SUPPLDIENT TO THE PROGRAMMATIC ENVIRONMENTAL IMPACT STATDIENT A.1 APPENDIX B - CONTRIBUTORS TO THE SUPPLEMENT B.1 xi

FIGURES 1.1 boses at TMI-2 Compared with Doses Per Reactor at All Commercial Nuclear Plants in the United States 1.6 1.2 Average Dose Rates at Selected TMI-2 Locations 1.7 1.3 Number of Workers Versus Yearly Occupational Dose for TMI-2. 1.9 2.1 Reactor Building 2.2 2.2 305-ft Elevation 2.3 2.3 347-fr Elevation 2.4 2.4 282-ft Elevation 2.5 2,5 Cross Section of 282-ft Elevation Showing Elevator Shaft 2.6 '2.6 Cutaway View of TMI-2 Vessel 2.9 2.7 Plan View of Auxiliary and Fuel-Handling Building. 2.12 2.8 Cutaway View of Auxiliary and Fuel-Handling Building 2.13 2.9 Occupational Radiation Dose to Complete Cleanup 2.34 2.10 Conceptual Schedule for the Current Plan 2.35 2.11' Conceptual Schedule for Alternative 1 2.36 2.12 Conceptual Schedule for Alternative 2 2.37 2.13 Conceptual Schedule for Alternative 3

2. 38 xii l

TABLES 1.1 Occupational Radiation Doses at IMI-2 from March 28, 1979, to May 11, 1984 1.5 2.1 Estimated Occupatioaal Radiation Dose for the Current Cleanup Plan 2.21 i 2.2 Estimated Occupational Radiation Dose for Extensive Cleanup Followed by Defueling. 2.24 2.3 Estimated Occupational Radiation Dose for Phased Defueling Followed by Reactor Building Cleanup 2.28 2.4 Estimated Occupational Radiation Dose for Defueling Followed by Delayed Cleanup Using Robotics 2.31 2.5 Summary Evaluation of Cleanup Alternatives 2.40 3.1 Cumulative occupational Radiation Dose Associated with Each Cleanup Option. 3.2 3.2 Comparison of Fatal Cancer Risk Estimators 3.6 xiii

1.0 INTRODUCTION

1.1. PURPOSE AND SCOPE In March 1981, the Nuclear Regulatory Commission (NRC) published the Final Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Waste Resulting from March 28, 1979, Accident i Three Mile Island Nuclear Station, Unit 2 (NUREG-0683). That document, referred to here as "the PEIS," was intended to provide an overall evaluation of the environmental impacts that would result from cleanup activities at Three Mile Island Unit 2 (TMI-2), beginning when the plant conditions were stabilized after the accident and continuing through the completion of cleanup. The purpose of this supplement is to reevaluate the impact of the radiation dose to workers, based on current information. The objective of " cleanup," as the term is used in thac document and this one, is decontami-nating and defueling the plant. The affected environment and the impacts that are not discussed here remain substantially as represented in the PEIS. As a supplement, this is not a stand-alone document. For completeness, the reader should refer to the PEIS this document suppicments. Since the issuance of the PEIS, numer>us activities (cleanup of accident-generated water, reactor and auxiliary building decontamination, reactor vessel underhead characterization, etc.) have been proposed by the licensee. These activities were evaluated by the NRC staff and determined to fall within the scope of the activities assessed in the impact statement. Completion of these activities has resulted in considerable progress toward completing the cleanup, along with obtaining new information about conditions in the reactor building and in the auxiliary and fuel-handling building and about the effec-tiveness of various decontamination activities. One conclusion of the PEIS was that the most significant environmental impact associated with the cleanup would result from the radiation dose received by the entire work force from cleanup activities. That collective dose was estimated in the PEIS to be in the range of 2000 to 8000 person-rem. Cleanup activities conducted through May 11, 1984, have resulted in approximately 2000 person-rem based on the results of self-reading dosimeters. Individual worker doses are based on the results of thermoluminescence dosimeters (TLDs), which are more accurate and somewhat lower. Although this occupational dose is still within the predicted range, thcre is substantial uncertainty about future occupational exposures, primarily because the most difficult work remains to be done and in certain areas dose rates have not declined as projected. Based on cicanup experience to date at TMI-2, it now appears that the entire cleanup could result in doses in excess of the 8000 person-rem previously estimated. Therefore, this supplement has been prepared to update the estimates of radiation dose and assess the associated environmental impacts. The doses for vaste-related tasks that are used in this supplement have been taken directly from the PEIS. These doses are expected to make only a very small contribution to the total dose from cleanup. This document, like the impact statement it supplements, is programmatic in nature. That is, the action being considered is the assessment of the cleanup, which is subject to NRC approval. In order to accurately predict the 1.1 _D

fe h_ impact of the occupational radiation dose from cicanup, the most probable sequences and methods for cleanup are evaluated. The most likely course of j-_ action, presented here as "the current cleanup plan," differs in sequence from T the most likely course of action at the time the PE1S was prepared. At that i time, the licensee was planning to begin cleanup in the reactor building with an extensive decontamination of the building and equipment. Although progress _j has been made on building and equipment decontamination, a great deal of addi- ? tional work still remains. Rather than complete building and equipment decon-q tamination before reactor disassembly and defueling as originally planned, the y 'g licensee has indicated his intention to remove the damaged reactor fuel as soon as possible. Therefore, defueling prior to complete building cicanup is 2_ the predominant feature of the current cleanup plan, which is presented and evaluated in Section 2.2 of this document. e In accordance with the National Environmental Policy Act, alternative 1- _- p courses of action are considered in this document. These alternatives were selected to be consistent with the conclusion of the PEIS that the TMI site is not suitable as a permanent repository for the accident-generated radioactive r waste. As discussed in Section 2.1.1 of the PEIS, a "no action" alternative, the option of not performing cleanup, would have the effect of converting the reactor to a permanent repository. Therefore, under all alternatives con-sidered, vastes would be removed from the site. The alternatives were also g selected to employ presently availabic technology, or, in one case, emerging robotic technology, to effect citanup operations. Within these two limita- -i tions, a wide range of cleanup alternatives is not available. As a result, ~5 the alternatives considered here differ from each other and from the current cleanup plan primarily in individual task sequence and methodology. E r-The alternatives of permanent entombment or long-term storage following defueling, although rejected in the PEIS, will be reevaluated by the NRC prior to a major expenditure of dose for reactor building cleanup (see also Sec-L tion 6.2.3). 1.2 IIISTORY OF OCCUPATIONAL RADIATION DOSES RESULTING FROM CLEANUP ACTIVITIES -h Cleanup of the TMI-2 reactor building could not begin until after the -d inventory of the noble gas, krypton-85, had been vented. Therefore, major n work in the reactor building did not begin until the latter part of 1980. p When the PEIS was being prepared, the reactor building had been entered only five times since the accident (at a total dose of about 13 person-rem), and little specific information was available on the conditions in the building. Dose estimates included in the PEIS were therefore based on limited data from the reactor building, some experience in the auxiliary and fuel-handling 9 building, experience with previous reactor accidents, and certain necessary F assumptions. In addition, the dose estimates were based on the licensee's a' cleanup schedule as of 1980, which was not constrained by funding. Since that g time, major delays in cleanup have resulted from Jack of funds and other ? causes. On the previous bases, cleanup was estimated to require between 2000 and 8000 person-rem of occupational dose. Since the PEIS was issued, the reactor building has been entered more than 366 times. Entries now typically take place several times each week and involve several workers performing a i$ variety of tasks. These entries have provided a significant opportunity to gather information on the conditions in the building. 1.2 C_ w O

At the time the PEIS was prepared, it was estimated that "once the sump water has been removed, hot spots shielded, and general area decontamination completed, general area radiation levels should be reduced to 5 mR/hr or less" on the 347-ft elevation (PEIS Appendix 1). This has not proved to be the case. The basement has been drained of highly radioactive water, and many hot spots in the building have been shielded. General-area decontamination was begun but was suspended when it was learned that little dose rate reduction was being achieved and that cleaned areas were becoming recontaminated. Workers on the 347-ft elevation currently average about 106 mrem /hr (Flanigan 1983). Estimates of the effectiveness of water draining, decontamination, and shielding in other areas of the building were likewise overly optimistic. Other factors are contributing to the diminished effectiveness of cleanup activities. As of the May 11, 1984 cut-off date for this Supplement, workers were still required to wear respirato ry protection, which increases fatigue and decreases productivity. The TM1 experience has differed from past experience in the nuclear industry in that cleanup of the reactor building was not begu.i immediately. During the intervening time, the humidity in the reactor building was 100%, and it literally rained in containment. One result of the rain was that dose rates at initial entries were lower than expected because radionuclidea had been rinsed downward. A second result was that radionuclides permeated into porous surfaces such as uncoated concrete, were incorporated into corrosion layers as iron surfaces rusted and were trapped in paint layers. The humidity in the reactor building is still high and contamination is still being spread through the air; thus, reeleaning of cleaned areas is still required, with concomitant exposure of workers. Doses from both periodic maintcaance work and repairs of breakdowns have also been and continue to be adversely affected by delay. Certain tasks, such as the testing and replacement of fire extinguishers, must be done periodic-ally whether or not any cleanup is in progress. Also, the longer cleanup activities are prolonged, the greater is the probability of failure of systems needed for cleanup, such as lighting and other electrical systems. Experience with the cleanup thus far, coupled with the desirability of removing the damaged fuel as soon as possible, has led the licensee to re-evaluate plans, strategies, and occupational doses. On March 30, 1983, the licensee transmitted to the NRC its firt t formal estimate of the dose needed to complete cleanup (Kanga 1983). This estimate, 16,000 to 28,000 person-rem, was based on defueling as soon as possible and on the assumptions that little, ,pf.g.. if any, dif ficulty would be experienced in plenum removal and that little, if yp any, concrete removal would be required. Lp.,- ge, y Because the licensee's predicted doses were outside the range given in V*~ 'h the PEIS and the assumptions did not appear overly conservative, the staff 1 undertook to independently reassess the cleanup dose. This supplement pre-sents the results of that reassessment.

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i n The cleanup effort in the reactor building at TMI-2 has focused on the c ;. ;. following activities to date: l.Y.

7 k%a 1.3 Gf.]

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mapping of radiation levels, and air sampling acquisition of data e decontamination of surfaces placement of shielding removal of sources of radiation exposure processing of the sump water e refurbishment and testing of the polar crane e assessment of the extent of core damage preparations for reactor vessel head removal. e Table 1.1 lists the occupational radiation doses received by workers since the accident. The doses are shown by activity and year, through 1983. As of May 1984, nearly 2000 person-rem had been received at TMI-2 from the cleanup operation. Figure 1.1 shows the doses at TMI-2 relative to doses at all commercial nuclear power reactors in the United States (Brooks 1983). (Throughout this document, doses are rounded to two significant digits, and current doses include those incurred up to May 11, 1984.) Although worker activities at TMI-2 have been quite different than those at operating power plants, the accumulative doses at TMI-2 since the accident have been lower than the average doses experienced at operating reactors. In 1981, the most recent year for which figures are available, the average col-lective dose at U.S. pressurized-water reactors (FWRs) was 652 person-rem per reactor (Brooks 1982). The collective annual doses at TMI-2 since the acci-dent were 490 person-rem in 1979 (some of this dose was incurred prior to the accident), 310 person-rem in 1980, 160 person-rem in 1981, 400 person-rem in 1982, 450 person-rem in 1983, and 180 person-rem in 1984 (to May 11). The average dose per worker was also lower. Workers who received measurable radi-ation exposure in U.S. PWRs received an average of 0.61 rem in 1981. At TMI Units 1 and 2, a comparable group of workers averaged 0.23 rem / person in 1979, 0.11 rem / person in 1980, 0.16 rem / person in 1981, 0.45 rem / person in 1982, and 0.89 rem / person in 1983. This data was readily available only for Units 1 and 2 together. (in each of these years except 1979, more dose was accumu-lated at Unit 1 than at Unit 2.) Work on large-scale operations in the reactor building that are both labor-intensive and occupational-exposure-intensive is now beginning or is planned for the near future. The primary operations include: placement of radiation shields + removal of the pressure vessel head removal of the plenum e removal of fuel and fuel debris e hands-on decontamination. Because of the increasing amount of work being done in the reactor build-ing, a major effort to reduce dose rates was initiated by the NRC and the licensee in late 1982. The objective was to identify and eliminate or shield as many sources of radiation exposure as possible. The dose reduction program initially focused on both the 305-ft and 347-ft elevations of the reactor building and is currently concentrated on the 347-ft elevation because this is 1.4

TABLE 1.1. Occupational Radiation Doses at TMI-2 from March 28, 1979, to May 11, 1984 Dose (person-ren) # 1979 1980 1981 1982 1983 1984 Decontamination / Dose Reduction (b) Reactor Building 0.0 12 54 180 140 6.1 Auxiliary Fuel-97 88 2.6 14 27 26 Handling Building Systems 0.5 1.8 3.1 4.9 2.2 1.9 Reactor Disassembly & 0 0 4.3 120 130 100 Defueling (b) Radioactive Waste Management (Onsite Activities) Solid Waste 14 23 8.9 7.6 15 1.4 Liquid Waste 30 11 18 12 16 3.8 Routiae Operations & Surveillance Plant Operations 73 81 32 36 78 28 Plant Maintenance 82 31 31 20 38 8.4 Support Systems 95 33 9.5 4.1 4.4 2.8 Other 95 32 0.1 0.9 0.0 0.0 TOTALS 490 310 160 400 450 180 CUMULATIVE TOTALS 490 800 960 1400 1800 2000 i (a) From self-reading personnel dosimeters; all doses are rounded to 2 significant figures. (b) Several activities, such as polar crane cleanup and refurbishment, support both building cleanup and reactor disassembly and defueling. where most of the defueling work will take place in the near future. This effort has shown some significant results, as can be seen in Figure 1.2 and as discussed further in Section 2.1. 1.3 REGULATORY AND ADMINISTRATIVE CONTROLS FOR LIMITING OCCUPATIONAL DOSE Before any cleanup activity at TMI-2 is initiated, the NRC staf f performs an extensive review of the licensee's technical evaluation report, written procedures, safety analyses, and other documentation governing the work to be performed. Permission for an activity to begin is granted only when the NRC staff has determined that the following conditions are met: 1.5 1

~ ~"" d 4.000 l MIDDLE 50"o OF BWRs =_ MIDDLE 50 o OF PWRs r m @ AVERAGE COLLECTIVE DOSE _I W 3.500 - @ MEDIAN COLLECTIVE DOSE $ TMI-2 COLLECTIVE DOSE E m_ TMI DOSES FOLLOWING "J THE ACCIDENT N -'6 RANGE OF y 3.000 - DOSES y 3 -i _ 7 E E L g 2.500 4 g 8 N F g 2.000 9 c. l m_ 3 m O W 6 1.500 d t U C T-b 1.000 A r v w A V/ A A 'Q r" 500 M w I" O 1979-1980 1981 1982 1983 YEAR FIGURE 1.1. Doses at TMI-2 Compared with Doses Per Reactor at All n Commercial Nuclear Plants in the United States 1.6

O 305' ELEVATION 05 34T ELEVATION '- TOP OF REACTOR SERVICE STRUCTURE Qs a2 lE 04 85-gem ?!S

• o*

03 = $33 ne 85 mp 02 Wr as $8 01 M M FALL FALL SUMMER FALL EARLY SUMMER FALL SPRING 1980 1981 1982 1982 1983 1983 1983 1984 FIGURE 1.2. Average Dose Rates at Selected Tiil-2 Locations safety standards are maintained the activity is consistent wfth the T!!I-2 operating license and technical e specifications e the activity does not violate NRC radiation protection regulations, including the requirement to maintain radiation doses as low as is reasonably achievable (ALARA) the activity and associated impacts fall within the scope of the PEIS. e Regulations governing occupational exposure to radiation for all NRC licensees, including the T -2 licensee, are given in Title 10, Part 20, of the U.S. Code of Federal Regulations (10 CFR 20). Two types of requirements to protect workers against radiation are set forth in 10 CFR 20. The first requirement (10 CFR 20.101) sets numerical limits on the amount of radiation a worker may be exposed to in any calendar quarter. The limit for whole-body external radiation is 1.25 rem (special limits apply to extremities--see 10 CFR 20.101) in any one quarter unicas certain requirements regard ing individual lifetime dose limits and dose records are met, in which cane the limit is 3 rem per calendar quarter. Exposure records are kept on all workers (licensee employees and subcontractors) and are reported to the workers at least annually. The NRC regularly audits the licensee's dose asses,sment and reporting activities. 1.7

The second requirement deals with the fundamental approach to radiation protsction. The principle of maintaining radiation exposures ALARA has long been a basic goal of radiation protection programs, and 10 CFR 20.1(c) states that NRC licensees should follow this principle. The basic ALARA objective is to ensure that radiation exposures are kept to the lowest icvels that are commensurate with sound economic and operating practices. The Nuclear Regula-tory Commission's Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuc1 car Power Stations Will Be As Low As Is Reasonably Achievable," (NRC 1978) expands on the elements of an effective ALARA program. These elements are reflected in the TMI-2 program, and in-clude:

1) upper-level management responsibility and authority for the AIARA program; 2) appropriate training and instruction for those at all organiza-tional levels who are involved in radiation work; 3) re. view of the design of new and modified equipment to ensure that the selection of equipment will minimize occupational radiation exposure; 4) control of access to radiation areas; 5) appropriate use of shielding; 6) extensive review of procedures, job preparation, and planning to minimize the dose required to perform specific tasks; and

7) adequate protective equipment and personnel-monitoring instrumentation.

To promote ALARA and comply with the dose limits, the licensee has estab-lished administrative radiation dose limits for workers. These administrative limits require management approval for all doses in excess of 1 rem / quarter. (Successively higher doses, up to the regulatory limits, require authorization from successively higher icvels of management (0 /C Nn: lear 1983). These administrative limits are set below the regulatory limits to ensure that no worker will be exposed to radiation in excess of the regulations. Since the accident, the maximum annual radiation doses received by workers at TMI Units 1 and 2 (not necessarily the same person each year) have been 4.5 rem in 1979; 2.1 rem in 1980; 2.1 rem in 1981; 4.2 rem in 1982; and 2.7 in 1983. (See Figure 1.3 for the number of workers versus the yearly occupational dose at THI from the time of the accident through 1983.) In addition, all operations planned at THI-2 undergo review by the licensee's health physics and radiological engineering staff to ensure that each tank is conducted in accordance with the ALARA principic. An important part of the NRC's review and approval of cleanup activities is to independently determine that the proposed work will be carried out following good ALARA practices. The sections that follow deal with the work to be performed and alterna-tive approaches to it (Section 2); the most important impact of cicanup, occupational radiation dose (Section 3); the conclusions renched in preparing this supplement (Section 4); and comments received on the draft supplement and responses to those comments are included in Section 6. 1.8

3600 3300 D $y 1200 m C 3 u.o g 900 m 23z 600 300 0 9.o 9 0 2s_O 59 9)$'!.o 2 E O ~\\o'9 3 g 4s 1 7 2s s 25 OCCUPATIONAL DOSE IN A YEAR (REM) FIGURE 1.3. Number of Workers Versus Yearly Occupational Dose for TMI-2 1.9

2.0 CURRENT AND ALTERNATIVE PLANS FOR CL EANUP OF REACTOR AND AUXILIARY BUILDINGS Chapters 5 and 6 of the PEIS address in some detail the tasks to be accomplished for cleanup of the reactor building and the auxiliary and fuel-handling building, disassembly and defueling of the reactor, and decon-tamination of the primary system. These tacks are briefly presented in Sec-tion 2.1 to provide an appropriate background for the descriptions of the plan and alternatives that follow. Section 2.1 also reflects current knowledge of the tasks to be performed and the methods available to carry them out. Sec-tion 2.2 presents the licensee's current plan for cleanup, which was evaluated in preparing this supplement. Three alternatives, developed by the NRC staff, are also presented. Alternative 1, discussed in Section 2.3, is an approach similar to that evaluated in the original PElS, that is, cleaning the building to reduce the dose rate to 10 mrem /hr or less prior to defueling. Alterna-tive 2, discussed in Section 2.4, is the removal of fuel fines and particles through the reactor pressure vessel head before head removal. Alternative 3, discussed in Section 2.5, involves putting the reactor into a monitored interim-care mode after defueling until the high-dose work of building cleanup can be performed robotically. The plan and alternatives are compared and evaluated in Section 2.6.

2.1 BACKGROUND

INFORMATION ON CLEANUP WORK Cleanup work to be performed in the reactor building can be subdivided into three principal endeavors:

1) cleanup of the reactor building and equip-ment; 2) disassembly and defueling of the reactor; and 3) decontamination of the primary system.

The first two of these may be performed in any sequence or simultaneously. The third must follow defueling. It is the variation in sequence that is the primary difference between the current plan and the first alternative. The second and third alternatives utilize slightly different methods of performing the work. Cleanup of the auxiliary and fuel-handling building is already underway and, under the current plan and Alternatives 1 and 2, would be completed as resources are available. Under Alternative 3, those portions of the auxiliary and fuel-handling building cleanup that require the greatest dose might be postponed until additional technology is developed. The physical and radiological conditions that affect these endeavors are discussed briefly below, followed by a description of the tasks involved in each phase of cleanup. 2.1.1 Cleanup of the Reactor Building and Equipment The reactor building is a cylindrical reinforced-concrete structure with a dome top, as illustrated in Figure 2.1. Levels within the building are referred to by elevation above sea level. The building is entered at the 305-f t elevation. a ien the building was first entered af ter the accident, radiation doses at this elevation averaged 430 mrem / man-hr. The placement of shielding, the removal of debris, and decontamination of the building have 2.1

top N Davt Et 413438 ft 447 9 "k E Aen **OOR EL 426 0 L [ [ lh 500 TON POLAa CRA%E ') ,l 1 N hh, TOP OF CRA%E RAfL I I ut 5 ) 6-mag CRANE % Of # l 2610% h e "k3 bt R AIL. rAo Avt MOOMbF1 .s--= 13 9 w tr%En efvp.gn limit OF MA'N M004 TRAvFL D*i % ST A'RWE LL FyEs "A D6' G M'551LE 5* ELD 5 I PENDA%f BR*DGE SwiE LD EL 370 4' \\ I I Nl h EL 36F 4 l VERTICAL C A D caste " g LAODE R GENERAt@ CMA5E l "iiii f)$ Q 1 I i EL 347 6' PRE S$uRilEn i ~ a y j lj 1J f A. =, NEUTRON d HE A0 5ERv'CE SH4LD U 5tRucTvRE TANES STE AM -~ a]., ~

aoovio, Ounn l

LaI ( r.-- ~ 4-

mpa, ;p REAcroR

%) d6 @h _[ [ ' I i =r' STEAU GENERATOR EL 305 0- _Je --i i_11 i l ) REACTOR 4 l wi n

• E ssEt 5

-.i j = .(( = f t..... l i FIGURE 4 j,. Reactor Building 2.2

43 reduced doses at this level to an average of approximately 140 mrem / man-hr in mid-1983. The dose rate for normal operation, and the target for the total cleanup effort, is on the order of 10 mrem /hr (Kanga 1983). Because radiation sources are distributed throughout the building and are difficult to remove, reducing the dose rate below the current level is expected to require greater effort than that required so far. A plan view of the 305-ft elevation is shown in Figure 2.2. Above the 305-f t elevation is the 347-f t elevation (the operating floor), which is currently reached by an open stairway. (An elevator and an enclosed stairwell are also present; however, radiation dose rates resulting from the accident have prevented refurbishment of the elevator and minimized use of the stairwell.) The 347-f t elevation is used to gain access to the reactor vessel head and service structure, the fuel transfer canal, and other areas important i for reactor disassembly and defueling. Doses at the 347-ft elevation averaged REACTOR PERSONNE L COOLANT AIR LOCK PUMP fLEVATOR g j GENERATOR ENCLOSED REACTOR STAIRWELL g COOLANT PUMP r 4 ~ COVERED HATCH CORE FLoOO TANK E #p O l I, P, \\\\ air COOLERS - aE ACTOa suiLOiNG i

1. :, '

lm ~.

• ]

d Q } e FUEL TRANSFER TUBES Q 3 i REACTOR ~* -lNTERNALS O ~*' ,J, STORAGE STAND \\ FUEL STORAGE RACK AND j TRANSFER CANAL 1,J i j ,4 V, .N CORT FLOOD TANK INCORE INSTRUMENTATION ? CABLE CHASE

• M

,=- PRESSURIZER REACTOR [ ~* COOLANT g_ PUMP STEAM GENERATOR REACTOR PERSONNEL COOLANT oPEN AIR LOCK AND PUMP STAIRWELL EQUIPMENT HATCH l FIGURE 2.2. 305-ft Elevation 2.3 l

p .T f 240 mres/ man-hr following_the accident. Shielding, debris removal, and decon-tamination have' reduced the. average doses to approximately 110 mrem / man-hr in the' summer of 1983. The target dose rate for cleanup of the 347-ft elevation ^ is in the 10-mrem /hr range. A plan v' of this. elevation is shown in Figure 2.3.. The polar crane, located at the 426-ft elevation, is reached by ladder or hoist from the 347-ft elevation. (The elevation of the crane's cab is 418 ft, j 6'in.) -The polar _ crane, shown in Figure 2.1, is necessary for numerous r activities' in support of disassembly and defueling, and will also facilitate the transportation of decontamination equipment,. directional radiation measuring devices, and shielding materials within the building. Worker doses at initial access to. the polar - crane averaged 120 mrem /hr, but. through con-siderable work to decontaminate and prepare the crane for use, the doses have i been reduced to about 80 mrem / man-hr. Doses on the reactor vessel service - structure currently average 56 mrem / man-br. Below the: 305-ft entry 1cvel elevation is the 282-ft elevation, or basement, shown in Figures 2.4 and 2.5. The 282-ft elevation contains large numbers of reactor control cables, various pumps and piping systems, the E reactor coolant drain tank (in a shielded cubicle), and other equipment. This area contained accident-generated water to a depth of about 8 feet when the . building was initially entered after the accident. Since that time, the water 'has been drained, processed, and recycled for use in decontamination. Water E LEVATOR e i = / ENCLoSEO s [ STAIRWELL o COVERED HATCH STE AM y CABLE TRAYS , GENE R ATOR ,/ A ' B ' D RING \\ / / s \\j 5 r_ MAIN FUEL ' {b ['= M ^ 1 -lNDE XING HANDUNG BRIDGE 1 . f tXTURE tlN STORAGE) / HE AD SERVtCE l I.. 7 STRUCTURE --COVERED HATCH w WITH REMoVA8LE [{ . MIS $1LE SHIELOS GRATING 1-A ' D RING COOLANT PUMP AND {' tNS RUMENT MOTOR AUGMW . SERVICE ARE A l e, STEAM t GENERATOR HATCH WITH REMOVABLE 'y* N 'N ,O' GRATING 7 HEAD STORAGE i OPE PRESSURIZER STAND STAIRWELL FIGURE 2.3. 347-Ft Elevation 2.4 c (1

STOHAGE toCAtloN PL Af f oRM i ELEVATOR E NCLOSE D STAIRWELL ,,r,. 7 STE AM ' GENERATOR 8 n D O -[.* '

• l

- HATCH [ EL 305' RE ACTOR -- . [Xb' 1 SUMP +] A 8 REACTOR - PLAT F ORMS e r W VESSEL EL 296' % STORAGE LEYDOWN ]C ~ LOCATION

• *k COOLE RS

( tx 3 a \\ [ *' .G INCORE (.' INSTRUME NT ATION g CABLF CHASE \\- REACTOR COOLANT E' DRAIN TANK STE AM T GENERATOR "A" i, -g81 nfat ' ' LEAKAGE COOLERS oPEN STAIEWELL i FIGURE 2.4. 282-ft Elevation from decontamination efforts on the upper levels has flowed into the basement, dissolving additional contamination in the basement and then removing it as - the. water was pumped out. However, the numerous structures and pieces of equipment at this-level (see Figure 2.4) make cleanup particularly difficult, and the area remains' highly contaminated, with dose rates in the range of 1 to 1000 rem /hr, depending on location and distance from the floor. Although a sample was collected from the stairway, no other entries have been made. The basement is expected to be one of the most difficult areas in the building to clean. The highest measured radiation levels at the 282-ft elevation are in the ~ vicinity of the ' elevator shaf t and enclosed stairwell. These structures, which are made of hollow concrete blocks, became saturated with the accident water and absorbed radionuclides from it. The bottom of the elevator shaft is an enclosed _ area that until recently contained highly radioactive water. Radiation from the contaminants in the elevator and enclosed-stairwell area of the 282-ft elevation have prevented use of the stairwell and elevator at upper levels as well. 2.5

'// /////////i> SE,SulC - ELEVATOR CAR / .//////////// GAP W iji I' ~ 305' ELEVATION Q;/ -::. l,. ~ ~ 3 < 8* STE E L --* ELEVATOR 2 LINER PLATE DOOR ELEVATOR CABLES AND -e HOLLOW WEIGHTS CONCRETE 'Q BLOCK WALL i 2-YEAR WATER LEVEL mnkimav ~~~ 4 YEAR WATER LEVEL lH CAULK- - @ZDT'_~ FILLED GAP ,j .,,y ,s n. y RAMP-55 % 55'- - 282' ELEVATION i g;;; [f. .y4 . M : }.. ' ; . s jr- ,1f 4" STEEL LINER PLATE //,p:.;,,;. _ _. s i., .g u '. '.9 'y 4(, ,. O .h NOT TO SCALE FIGURE 2.5. Cross Section of 282-ft Elevation Showing Elevator Shaft Because the accident-generated water remained in the reactor building for several years, radionuclides concentrated on vertical surfaces at the water surface level. This phenomenon, commonly referred to as "the bathtub ring," continues to affect dose rates on the 282-ft elevation, and possibly in other locations as well. Efforts to remove the ring by spraying from above have not been successful in reducing general-area dose rates. Although some chemicals may have a positive effect, it is expected that decontamination of concrete areas will require removal of the surface coating and some of the concrete. There is a thin layer of sludge on the floor of the 282-ft elevation, which may contribute to dose rates, and the reactor building sump is also expected to be highly contaminated. The sump is inaccessible for dose rate measurement but has recently been sampled. The cleanup of the reactor building will entail: the removal of miscel-laneous equipment and debris that were in the building at the time of the accident (ladders, scaffolding, tools, etc.); the decontamination or removal of reactor-associated equipment (air coolers, cable trays, reactor piping, etc.); the decontamination of building surfaces (both metal and concrete); and variaus support activities to ensure the safety of workers performing these tasks and to measure the effectiveness of the cleanup activities. Cleanup 2.6

activities in the reactor building have been underway for several years and are continuing. Considerable debris and equipment have been removed from the 305-ft and 347-ft elevations, and decontamination of the building and remain-ing equipment has been attempted on these elevations. Some remote flushing of the 282-ft elevation has been performed. Although decontamination using high-and low-pressure sprays of borated water has reduced the level of smearable contamination on equipment and building surfaces, these techniques have been of limited success in reducing general-area dose rates. Effective, although temporary, dose rate reduction has been achieved by the shielding of certain sources of high-level radiation, including the elevator shaf t and stairwell on the 305-ft elevation and certain floor drains. (Shielding is considered only a temporary measure because final building cleanup will require the elimina-tion of these sources.) Most tasks involved in the reactor building decontamination, reactor dis-assembly and defueling, and primary-system decontamination can be performed without access to the 282-ft elevation; therefore, cleanup of this area will be left until the later stages of the cleanup operation in all options. How-ever, the water being used for building decontamination is apparently continu-ing to leach radionuclides from sources on this elevation; hence, it is undergoing some continual decontamination. To the extent possible, pre-liminary decontamination of the 282-ft elevation will be performed remotely or semi-remotely from the 305-ft elevation. Tasks will include remote radiation surveys and video examination, water and/or chemical spraying from above through penetrations, and possibly the use of robots for cleaning and removing equipment. When dose rates permit, hands-on decontamination techniques such as those used in the remainder of the building will be employed. The ultimate cleanup objective for the 282-ft elevation is also in the range of 10 mrem /hr. Since the accident, the level of airborne radioactive material has neces-sitated the wearing of respirators for all activities in the building. (Air-borne-radionuclide concentrations during work in the building vary with the level of activity. They have averaged from 2 to 23 times the allowable concentration for a 40-hr/wk exposure without respiratory protection (Flanigan 1983 and 1984).) These respirators, while protecting the workers, tend to reduce productivity and hamper mobility. In addition, in some areas the i airborne radioactive material has redeposited on cleaned surfaces, making l decontamination only temporarily effective. Much general building decon-I tamination has therefore been suspended temporarily. The problems of airborne contamination and redeposition appear to be, at least partially, the result of j radioactive material associated with boric acid crystals in the air (Alvarez } 1983). Boric acid comes from the primary coolant and, most importantly, from ( the decontamination solutions used in the building since the accident. (The l solutions have been made from recycled accident-generated water that has been } processed by a selective ion-exchange treatment that removes radionuclides but l not boric acid.) The removal of boric acid from decontamination water is currently being investigated by the licensee. The principal radionuclides that were identified in the PEIS (pp. 5-26,

27) and reconfirmed by subsequent measurements are cesium-137, cesium-134, and

( strontium-90. Cesium-137 has a 30-year half-life and is expected to be a 1 2.7

major source of whole-body dose throughout cleanup. Cesium-134 has a 2.0-year half-life and has therefore diminished to about 25% of the accident inventory in the first 4 years following the accident. its contribution to whole-body dose rates will continue to decrease. Strontium-90 has a 28-year half-life. Therefore, it has decayed very little since the accident. It is, however, a beta-emitting radionuclide, which means that protective clothing of fers sub-stantial worker protection. This mix of radionuclides is markedly dif ferent from that of other reactors, where these radionuclides are contained within the core. In those cases, cobalt-58 (71-day half-life) and cobalt-60 (5.3-year half-life) are the principal sources of worker dose, and the dose rate to which workers are exposed can be halved by waiting 5.3 years. At TMI, the same halving of dose rate requires 30 years. 2.1.2 Disassembly and DefueJing of the Reactor A cutaway view of a typical pressure vessel for a PWR is shown in Fig-ure 6.1 of the PEIS. This drawing has been modified, as shown in Figure 2.6 of this report, to show the results of work in progress and what has been learned about the TMI-2 vessel and its contents by video camera examination and other exploratory techniques. Proceeding from top to bottom of the reactor pressure vessel, the conditions are as follows. Three of the lead screws that were previously attached to control rod drives have been uncoupled and removed to allow examination of the core and internals. A complete control rod drive assembly has been removed for further examination of the reactor vessel and internals and for characterization of the radiological conditions under the head. All of the remaining lead screws have been uncoupled. The upper plenum assembly, the device that positions the control rods in the core, appears to be relatively undamaged. Clearance between the pressure vessel and plenum is only 50 mils (50 thousandths of an inch), so the case of plenum removal is still open to question as the plenum may be warped. There are portions of damaged fuel assemblies adhering to the underside of the plenum. Beneath the plenum is a 5-foot-deep woid where fuel and control rods used to be. At the bottom of-the void is a bed of loose rubble to a depth of at least 30 inches. The Debris Defueling Working Group (Runion 1983) has estimated, but not

verified, that there are approximately 45,000 kg (100,000 pounds) of rubble and fines in the TMI-2 reactor core that are 25,000 pm (1 inch) or less in size. These estimates indicate that 5300 kg are 800 pm or less and 125 kg are 4 um or less.

The conditions below the rubble are not known. Material may be loose or may have been fused by melted nonfuel material. The lower support structures may be intact or warped. Fuel may have been deposited in the lower areas of the reactor vessel below the lower support structure. The tasks for reactor disassembly and defueling include: . visual and radiological characterization of the core and the reactor pressure vessel head preparation for head lift e lifting and storage of the head and installation of the reactor internals e indexing fixture 2.8 \\

u a a (.{)NIR f f[ li(J[] DHIVI h j ]l.!p 3 ..e n [ l j g) stuos AND gy;3 REACTOR HEAD f @) IONS' jI SERVICE STRUCTURE q CONTRCL ROD DRIVE $'f g ) J' j I 8! GUIDE TUBES .R a 11fi CONTAINING L F AD REACTOR PRESSURE ,J VESSEL HEAD [- . I 1 f h M] SCREWS (3 LE AD SCREWS REMOVED) (81 TONS) { ,./; s j h -l l f )1 SE AL PLATE f j}. ;, y* i Q, --.\\ fiO BE INST ALLED- -y-cl /. ; A".- 7

f. B c.

g-TRA SFER l l CAN AL FLOOR i ! <.l a/ N 4 i il i t fl - UPPER PLENUM r ASSEMBLY LITTLE } l !j DAMAGE APPARENT 4W l U PE ID n ena FUEL ADHERING TO Lf PLENUM TYPICAL [f l g! ' 5 FEET; _ f CORE VOID l MY = i 4 S T [4 G. j j ^ RUBBLE BED (30" DEPTH) n

j

- CORE SUPPORT STRUCTURE (112 5 TONS) p l' CORE AREA i j CONDITION UNKNOWN J _' ON III J UNKNOWN )][ lh['3 FLOW DISTRIBUTOR. s 6 COND11 ION UNKNOWN

• .,,,. q jf. A,p$ ^ j
• f

)~]j(l..f' / t ? \\1 9- / l ( t FIGURE 2.6. Cutaway View of TMI-2 Vessel 2.9

1-i i ..'. installation of water cleanup systems for the reactor vessel and fuel transfer canal .re urbishment and modification of the fuel-handling system f . removal of the plenum ,c .. removal of the fuel .. removal of the core support structure and lower internals. Initial' visual and ' radiological characterizations of - the reactor vessel and core have been accomplished. Additional underhead characterization, including 7 dose ~ rate measurements, visual inspection. (using closed-circuit television), cora topography, and water and debris sampling, is in progress. Preparations for. head lift are in progress..The uncoupling of the remaining 63-lead screws-has been completed. Handling of the lead screws is important because experience with those removed so far indicates that they may + be a ' significant source o_f.- radiation exposure to the workers. ,A test to i measure the radiation contribution'.from parked lead screws has shown that the ' radiation from the lead screws will be reduced by the planned shielding during and af ter head lift. Other preparations necessary - for head lif t. include disconnecting and removing cooling and electrical lines and overhead platforms (in progress), detensioning (complete) ' and removing head studs and ; nuts, t ' refurbishing and installing the seal plate (in progress), and attaching. the hoisting equipment. The head will be lif ted and stored away - from the work The head is highly contaminated. and plans have been made to shield it area. during storage. Once the head is-removed, the condition: of the plenum will be further assessed. Water shielding over the plenum will.be provided by placing the internals indexing fixture over it. ~ F One_or more water cleanup systems.will be installed to' treat the reactor j vessel and fuel canal water during defueling.- These will be located in-the - fuel transfer canal to use canal water as shiciding..Because of particulate. and ' dissolved radionuclides in the primary coolant, cleanup of any water'in . contact with the reactor core will be important - f or dose reduction and the t control'of airborne contamination. Plans call for refurbishing and modifying the fuel-handling system to accept fuel canisters.' The' plenum will be removed intact or,-if necessary, in pieces and stored underwater to provide radiation shielding. Loose, particulate fuel debris will be removed, followed by. larger fuel l pieces. Fuel is normally handled underwater for radiation shielding ~. When i the fuel-is removed, it will probably be placed in canisters in the water-filled fuel transfer canal. These canisters will be - tipped horizontally by the modified fuel transfer equipment and passed through the fuel transfer tube l into a fuel. storage pool in the auxiliary. and fuel-handling building. Once l most of the fuel has been removed, the core support structure and lower reactor internals. will be removed (intact if possible, otherwise in pieces) and any remaining fuel particles will be removed. 2.10 ls-l

It is not certain what effort, if any, will be made to mechanically remove fuel particles from the reactor piping system. Any particles that have been swept into the outlet nozzles of the reactor vessel may be accessible to defueling equipment through the reactor nozzles once the reactor internals are removed.

Once all the fuel accessible through the reactor vessel has been removed, defueling will be complete and the transfer canai will be drained and decontaminated. Then primary-system decontamination can begin. 2.1.3 Decontamination of the Primary System . Directional. radiation surveys indicate that reactor fuel and/or fission products are dispersed throughout the primary piping system as finely divided particles and/or as., plating.on surfaces. This material must be removed as part of the cleanup. Section 6.5 of the PEIS contains a discussion of primary-system decontamination. Since the completion of the PEIS, the Electric Power Research Institute (EPRI) has funded research into the probable distribution of radionuclides in the. primary system (Cunane and Nicolosi 1983 and Daniel et al.1983) ' and into physical and chemical methods available for decontamination (Card 1983, Sejvar and Dawson 1983. Gardner et al. 1983, and Munson et al.-1983). Although information about the distribution and removal of contamination has thus been gained, there le little additional definitive information on which to base a. task description for primary-system decontamination. Decontamination solutions may transport radionculides f rom highly con-taminated areas to less-contaminated ones. In some cases, plateout may occur in the decontaminated areas, resulting in increased dose rates. For this reason, the most. highly. contaminated portions of the system, such as the reactor vessel and piping to the pressurizer, may require mechanical decon-tamination by grit blasting or other methods before, or in place of, full-system chemical decontamination. Whether chemical or mechanical methods are used and whether the system is decontaminated all at-once or section by section, primary-system decontamina-tion will entail most or all of the following in-containment activities: opening the reactor coolant system, making connections to the reactor piping, and introducing and removing decontamination agents or equipment. 2.1.4 Cleanup of the Auxiliary and Fuel-Ilandling Building The. auxiliary and fuel-handling building has two parts that are separated by a common wall. One part contains tanks, pumps, piping, and other equipment for the processing and storage of water for the reactor and primary cooling system and for the treatment of radioactive wastes. The other part contains fuel-handling and storage equipment and facilities. The general layout of the auxiliary and fuel-handling building is shown in Figures 2.7 and 2.8. 2.11

\\ SAMPLING LINE SHIELD l IM ANS6 t R IUHF ANO vat Vt l FUfL CASK I 1 iiii STORAGE 1 l g iyyg Sk $T'F bF'L GATE ~~~~ SPENT FUE L j TRANVE R f t>gE ANO VALVt l NEW f yUEL RUIL DING A I I MAKE UP AND PURIFICATION VALVE ROOM COOtER5 [ AND hE V CONCENTRATED LIOutD-0 SPFNT FttFL COOT FRS I'l" g, y EtFVATOR WASTE PUMP D G og Mig F IL TE RS BOR ATE D W ATF R SPFNTFUFL l g E O ROOM PUMP AND RECIRC PUMP COOLING PUMPS AN AL VfE R SEAL WTu E 3 = O,,(yg q l W NT SPt NT { ] W / ENVtRo g" / O a8PM @c o'"'O, Z' 5 5 ave k ROOM i 4ARHIE N]- TANK m = ( DFMtN FIL TF RS g aj .. l p.* INTE RMEDI ATE COOtfRS K b h s ~ g g E I n i l: g VALVE ROOM - l VALVE ROOM VALVE ROOM ~ Il I DISPOSAL l .' L.,' : CONTROL """'*E l ^ u ~ WASTE W AS TE des RA ING GAS DE C AV GAS DEC Ay VALVE DF MIN. ' MtSCEL.ANEDUS WASTE ROOM HOLD ur TANK PUMPS l TANK TANK COMP-o o a A= AND SE P gna e REACTOR BU LDING J ~ . SuuP ruuP FitrERS g---p o ( ~ = ~ ~ ~ ~ ~.) I%

1. 8 i

CHt M F E E D i I\\

1. I TANK g

MOTOR CONTROL CENTER c MOTOR CONTROL CE NTE R ) I % # 8 NUCLE AR SERVICE CLOSED I 2 l/ 0 0 COOLING PUMPS i i i u I 9 MOTOR MOTOR p g ,P***.... ~ CONTROL CONTROL 0# % I NUCLE AR SERVICE COOL E RS l l 76.IeSrAI'ON j 'd _ _ $ 'Y O C) C3 no.. SU STAnON 1 I I FIGURE 2.7. Plan View of Auxiliary and Fuel-Handling Building (305-ft elevation)

i nr=== ii i l . i.- l - - ~ ~ g. P C'l.~'l. ) X ... -... = = c.:.::::: s m o ~~ ,Ii

== .. =r { e E-I. - .iP ~l l I' I II I a- =8 L a.

a. _

^ i [.f ra ~ ' ' W = ~.. - - l. I n. ,,7;,, y - = - - g . q l-g hdri {2 ? r g=== 4 49 I m' I i l_

=

, ) d=* n 3 b kI df U N h h r m .=.:

==-

g=.

=: ; i l ~ \\ / U O lk-- g_; s. FIGURE 2.8. Cutaway View of Auxiliary and Fuel-Handling Building 1 1 f I 4

The interior of the auxiliary and fuel-handling building was severely contaminated by radioactive material as a consequence of the accident. Piping systems that interface with the reactor coolant system were also highly contaminated. There are 26 such systems in the auxiliary and fuel-handling I building. Some flushing has been done, but major decontamination efforts are still required. Cleanup of the building entails the following activity: the removal of miscellaneous equipment and debris that were in the facility at the time of the accident (ladders, tools, portable equipment, etc.); the decon-tamination or removal of installed equipment (piping systems, air conditioning and exhaust equipment, cable trays, electrical and lighting equipment, etc.); the decontamination of interior building surfaces (both metal and concrete); and the removal of contaminated sludge and resins. In addition, various support activities must be performed to ensure worker safety and to measure the effectiveness of the cleanup. Cleanup activities in the auxiliary and fuel-handling building started shortly af ter the accident and are currently underway. Considerable debris and equipment have been removed, and decontamination of the building and remaining equipment has begun. Because most of the interior surfaces (walls, floors, etc.) are composed of uncoated concrete, radioactive materials have penetrated or leached into the surfaces to varying depths. The use of high-and low-pressure water sprays, wet vacuuming, concrete spalling, and manual wiping has reduced both the level of smearable contamination on building surfaces and the dose rates in halls and normally occupied areas. Some temporary dose rate reduction has also been achieved by shielding sources of high radiation (e.g., floor drains, the elevator shaf t, and various valves, piping, and pipe dead legs). Internal decontamination of tanks and piping remains to be done, including the purification demineralizers, where contami-nated resin has remained since the accident. Cleanup of several of the higher-dose-rate cubicles also remains. Support activities in the auxiliary and fuel-handling building include: perform radiation surveys to measure the progress of the cleanup effort; identify the need for shielding and/or further decontamination; and provide lighting and utilities. Support activities are also required for the repair and maintenance of equipment used in the cleanup of the f acility and for the repair of piping leaks to eliminate sources of additional contamination. 2.2 CURRENT CLEANUP PLAN: DOSE REDUCTION FOLLOWED BY DEFUELING AND DECONTAMINATION The licensee's program for cleanup of the TMI-2 reactor building, as pre-sented in Figure 1.4 of the PEIS, assumed extensive decontamination of the reactor building to significantly reduce the radiation levels prior to reactor disassembly and defueling. This sequence has been revised for several rea-sons. First, the reactor building decontamination to date has been less effective in reducing dose rates than was originally anticipated. Second, the presence of the damaged fuel in the reactor core constitutes some risk, pri-marily to workers in the reactor building (the risk results from uncertainties in the core configuration and the remote possibility of a boron dilution incident potentially leading to recriticality of the core). Third, the 2.14 u

I information that will be obtained from laboratory examination of the damaged core will be of value for the design of planned facilities and may also be of . benefit to the continued safe operation of other nuclear power facilities. Therefore, to avoid further delaying the removal of the core, the licensee has adopted a revised approach to cleanup. 1 2.2.1 Tasks and Sequencing of the Current Cleanup Plan The revised cleanup program entails the same milestones as the initial schedule, but the sequence of tasks has been altered as follows:

• dose reduction--presently underway and to continue during reactor disassembly reactor disassembly and defueling--to begin in the near future

+ primary-system decontamination--to follow defueling reactor building and equipment cleanup--to proceed as resources allow, with completion following that of other activities cleanup of the auxiliary and fuel-handling building--presently underway + and to continue, concurrently with reactor building work, until complete. 2.2.1.1 Dose Reduction The purpose of the dose reduction program is to reduce the radiation dose rates in occupied portions of the reactor building before and during reactor disassembif and defueling. These activities, which include the installation of temporary shielding and the removal of certain equipment, are well along and have helped reduce from 40 mrem to 14 mrem the average transit dose for each worker entering the building on the 305-ft elevation and traveling to the 347-ft elevation and back. Future dose reduction plans call for the continued i use of shielding, additional source identification, and the removal, decon-I tamination, or shielding of floor surfaces, cable trays, air coolers, and other sources of exposure. Dose reduction activities should also reduce air-borne radioactive contamination and the recontamination of cleaned surfaces. 2.2.1.2 ' Reactor Disassembly and Defueling Early in Period 1 or 2 of the dose reduction program, the preparatory activities that are an essential part of reactor disassembly and defueling will begin. Disassembly and defueling work is expected to continue at least into Period 4 and possibly into Period 5. The operations leading to and including the removal of the damaged core from the reactor vessel are liste,d and discussed bclow in approximate chronological order. Some will be done concurrently, and some resequencing may be necessary or advantageous as the cleanup effort progresses. Although planning is still underway, the licensee's current conceptual designs are briefly described below: 2.15

D' . Kremovaltof the reactor pressure vessel. head e _ installation of high-volume cleanup systems for the water in the. reactor 7 vessel and fuel transfer canal 4 e_ - refurbishment of.the fuel' transfer canal in the reactor building and of a 5 fuel storage pool in the auxiliary and fuel-handling building l ~ e'Tremoval of the reactor vessel upper. internals (;.lenum) removal of the reactor fuel,' followed by its placement in containers and e . transfer to the fuel storage. pool ' removal of[ the. reactor vessel lower internals (core support assembly), e followed by removal of remaining debris from the reactor pressure vessel and'draindown and decontamination of the fuel transfer canal. Removal =of the Reactor Vessel Head. Preparations for the removal of the reactor. pressure vessel.(RPV) head are currently under way.. Preparatory activities directly related to RPV head removal are expected to include:

1) controlling the level of the primary-system water; 2): decontaminating and inspecting / support equipment-and systems needed for head removal (mostly

^ completed);O3). characterizing radiological conditions under _the RPV head to ensure that~the' contamination and dose rates resulting from the head lift can . be ' safely I handled (completed);,4)' removing the ~ missile shields shown in

Figure 2.1 (completed); 5) detensioning (in progress) and removing' the RPV-l head ' studs; 6) refurbishing the reactor internals indexin's fixture (in pro-fgress),and placing it on the vessel after.the RPV head lift; and 7) fabricat-ing :a cover plate for placement on top of the installed. indexing fixture (in progress). Also, Jas part of the underhead characterization, one control rod drive mechanism has been removed. All lead screws have already been uncoupled and will be i parked in the 'RPV head service structure and -removed later, if

~ required.- _ _LWhen preparations are complete, the RPV head will be. lif ted with the polar' crane to' gain access to-the reactorzvessel internals and the fuel. -It will..be Jplaced on the storage stand with shielding. If dose rates or-con-tamination warrants, the transfer canal can be filled to facilitate head lift. The -internals indexing fixture and a cover will then be installed on top of ' the; reactor vessel to facilitate water shielding of the plenum and to provide .a: work platform for plenum inspection activities. -Installation of High-Volume Water Cleanup Systems. High-volume water-

treatment capabilities.will be needed to clean particulate and dissolved 7

radionuclides from water in the - primary system and the fuel-transfer canal both before and during the reactor disassembly and defueling. Although the ' submerged desineralizer system (SDS) currently in operation at the site is processing primary coolant,; it does-not have sufficient capacity to support defueling.. Two. separate systems are planned, each with a capacity of about i. 400 gal / min ' for filtration and 60 gal / min for ion exchange. Preliminary Ldesigns indicate that _ one of these - systems will treat only reactor vessel water, and the other will - treat water in the fuel transfer canal (Devine 3 t { 2.16

t 1983). The filter for the system servicing the reactor vessel will be de-signed to fit in modified fuel canisters and will be located in the fuel transfer canal for shiciding. The ion exchange columns are expected to be about 100-ft cask liners of mixed-zeolite ion exchange media. The columns will be shielded underwater in the transfer canal pool, or placed in a shielded cask inside or outside of containment. The filter for the system servicing the fuel transfer canal will be like those used for the reactor vessel. This entire system, which will use the existing SDS (after modifica-tion) for cesium removal, will be submerged in spent-fuel pool "A" in the auxiliary and fuel-handling building. Refurbishment of the Fuel Transfer Canal. The refurbishment of the fuel transfer canal will include the installation of the water cleanup system dis-cussed above, the refurbishment and modification of the fuel transfer equip-ment to handle fuel canisters, and the installation of the seal plate to allow filling of - the fuel transfer canal. Fuel storage racks for fuel pool "A" in the auxiliary and fuel-handling building will also be modified. Pler.um Removal. Af ter head lift and the installation of the indexing fixture, and concurrently with refurbishment of the fuel pool and preparation and filling of the fuel transfer canal, the condition of the plenum will be evaluated. The clearance between the plenum and reactor vessel wall was very small prior to the accident. It is not known whether accident conditions dam-aged the plenum in a way that would make conventional plenum removal impossible. Plenum removal will require the prior or concurrent removal of the dam-aged fuel assemblies adhering to the underside of the plenum. They may be dislodged remotely through openings in the plenum, or they may be removed with the plenum. In an undamaged reactor, the removal and storage of the plenum is norm-ally performed underwater in the fuel transfer canal so that the plenum does not contribute significantly to the occupational radiation dose. This is the current plan for TMI-2. However, if radiation levels permit, the plenum might be lif ted before the modifications of the transfer canal are complete. In this case, the plenum would be lifted into air and subsequently stored under water in part of the transfer canal. Plenum removal is not ordinarily a high-dose job; however, it may be at TMI-2, particularly if intact removal is not possible. Sectioning the plenum would require that workers spend. considerable time over the reactor vessel attaching lifting devices to the plenum, aligning cutting equipment, etc. Workers cutting the plenum would receive radiation dose f rom sources in the reactor building and from the plenum and reactor coolant. However, the addi-tional dose contribution from the plenum and reactor coolant could be fairly small, depending on the depth of water cover and the effectiveness of the water cleanup systems. 1 2.17 l L

Fuel Removal. Once the plenum assembly has. been.- removed, defueling equipment will be installed in the' canal area and the fuel will be removed. The-fuel removal. plans have ' not yet been finalized because investigations of fuel conditions are still in progress. The reactor vessel defuelin' g sequence will involve removing only that fuel material within the reactor vessel--not material that may.be lodged in other locations within the reactor primary system, such as in the coolant piping. - The removal of. fuel and particulates, f rom other. portions of the reactor primary' system are discussed in Section 2.2.1.3. The TMI-2 core contained 177 fuel assemblies. While' their exact condi-tion is uncertain, current information indicates that there are no intact fuel assemblies. The - fuel is assumed to be in a combination of the following configurations: f . fused sections--portions of fuel assemblies fused to each. other. or to structural components in such a way that they will have to be mechanically separated e core debris--includes relatively large pieces that can be. mechanically handled, and smaller pieces that will have to be hydraulically vacuumed and filtered. The initial step of defueling will be the removal of the core debris, to clear the working area in preparation for the removal of.large pieces of fuel c assemblies. The small debris will be removed first, followed by accessible loose debris that is larger than pellets but small enough to be placed in canisters. These - canisters will be temporarily stored underwater-in the transfer canal, then moved underwater through the transfer tube to the underwater spent-fuel storage racks in the fuel-handling building. This will provide space in the transfer canal for subsequent defueling operations. Large. fuel pieces will then be removed using. remote manipulators and/or .long-handled tools. Adjacent pieces may need to be separated in' order to be removed. Removal of Lower Internals. The core support assembly is a large, basket-like component in the reactor vessel that supports the fuel. elements and directs the - entering reactor coolant towards the lower portion of the l reactor core. Along with the' removal of fuel from the reactor vessel, fuel particles will be removed from the lower internals. Then the. core support structure will be removed using the internals lif ting fixture and polar crane, if possible. - If conditions require, it will be cut up for removal. As the core support assembly is removed, remaining fuel debris will also be removed and placed in transfer containers. Although the fuel and reactor core material is highly radioactive, the depth of water over the core should shield workers from all but-dissolved or very finely divided debris that becomes dispersed in the coolant. The reactor water cleanup system is expected to remove this material and provide cleaned coolant in the vicinity of defueling workers. Defueling will, however, require that workers spend considerable time in containment, during which they 2.I8

i l-b.. will. receive radiation l doses from numerous sources. Because of the time defueling requires, it will be a relatively large contributor to the radiation ' dose for cleanup. o . - Af ter i the creacto'r. has _ been defueled,. any remaining fuel, canisters and particulate - filters. from the water treatment system will be transferred through the fuel transfer canal.to the fuel storage pool. Defueling equipment ' will be _ removed y and. the transfer. canal.will be drained and decontaminated. This will complete reactor disassembly and defueling. ~ 2.2.1.3 Primary-System Decontamination ' econtamination of. the primary system will involve mechanically and/or D chemically decontaminating the, internal surfaces, as discussed in Sec-tion 2.1.3 of this report and Section 6 of the PEIS. At the completion of primary-system decontamination the_radionuclide concentrations in the primary piping system should approach those'of operating reactors. 2.2.1.4 Reactor' Building and Equipment Cleanup The cleanup of:the reactor building and equipment will be an extension of _the dose reduction effort.-with the purpose of reducing radionuclide con- -centrations'and radiation dose rates to levels approaching those in operating plants. Chemical ~and mechanical decontamination techniques will be used on ~ equipment and on building surfaces. The removal of items such as cable trays. -insulation, and portable. equipment will reduce doses and facilitate cleanup operations. Some concrete removal is expected to be required, particularly-on the 282-ft elevation. The hollow-concrete-block walls on this elevation will ) .also need to be removed. Reactor building cleanup will involve a continual sequence of identifying .the most significant contributor to radiation dose and airborne contamination, decontaminating or s otherwise. removing that source, then identifying and decontaminating or-removing the next most important source, and so on until dose rate objectives are met. This repeated process is necessary because of ~ ' the extreme difficulty. (with available instrumentation) of identifying minor contributors to radiation fields in the presence of major contributors. Cleanup will be further complicated because, once a component is cleaned, it s may become recontaminated by particulate radioactive material f rom the air or from equipment. removal or decontamination activities in adjacent areas. For this reason, it will be important to protect cleaned areas with plastic, strippable coatings, or some other covering, and to determine a sequence for cleanup activities.that will minimize recontamination. Dose rates in the reactor building (from equipment and surfaces) will be al function of the effectiveness of the cleanup actions. It is expected that a relatively.-large number of person-hours will be required - to complete the cleanup and that the dose rates will decrease ever more slowly as cleanup 2.19 4

progresses, because removing a single large source has a much greater ef fect on dose rates (per worker hour expended) than removing numerous smaller sources. 2.2.1.5 Auxiliary and Fuel-Handling Building Cleanup The overall objective of the cleanup effort in the auxiliary and fuel-handling building is to permit access to all portions of the building. Access k has been limited because of surface and airborne contamination and radiation exposure from confined sources (radionuclides inside pipe runs, resin columns, dead legs, holding tanks, etc.). Mechanical and chemical decontamination techniques will be used inside tanks and piping and on equipment and building surfaces. The removal of contaminated items that are still in the building, such as portable equipment, insulation, sludge, resins, and miscellaneous debris, will facilitate cleanup. Some concrete spalling has been done and more will be required, particularly on the concrete surfaces that were below the accident water level or were otherwise exposed to contaminated liquids. Hollow-concrete-block walls may have to be removed. The building will require some additional general cleanup, primarily of overhead areas and of cubicles and their contents. As in the reactor building, cleanup may be hampered by recontamination, and covering decontaminated areas with protective materials may be important. The cubicle areas will be the most difficult to decontaminate because of the concentration of equipment (tanks, filters, piping, etc.), the crowded work space, the need for special shielding (e.g., lead blankets), and the high contamination and radiation levels. The makeup and purification demineralizer cubicles may be the most severely contaminated because of radionuclides that were deposited in the in-line filters and demineralizer resins during the accident. The decontamination plan presented in the PEIS postulated complete decon-tamination of the auxiliary and fuel-handling building using conventional decontamination methods, including water. flushing and hydroblasting (high-pressure water flushing). Experience has indicated that these methods are not effective in reducing dose rates and are not as rapid as originally anticipated. 2.2.2 Occupational Radiation Dose Associated with the Current Cleanup Plan In order to determine the occupational radiation dose associated with the current cleanup plan, a team of nuclear-operations and decontamination specialists evaluated the work to be performed and the dose required for each task. Each task was evaluated assuming that the tasks would be performed in 'the nequence described and that occupational radiation doses would be main-tained ALARA by the proper planning and execution of each task. A great deal of information and data required for accurate estimates will become available only during the progress of cleanup (e.g., conditions inside the reactor, characterization of contamination). Because of this, the radiation dose estimate is presented as a range. The upper and lower ends of the estimated 2.20

range represent the-corresponding extremes of conditions based on an evaluation of the information presently available. Table 2.1 lists the estimated range of occupational radiation doses for cleanup performed according to the current plan. Doses for work performed to date and doses for waste management tasks (taken from the PEIS) are included. Observations regarding these estimated doses are presented in the following paragraphs. The occupational dose incurred during performance of the dose reduction task will effectively reduce the radiation doses to workers performing subsequent tasks. Eliminating this task would effectively increase the doses for later tasks. The range of estimated doses for completing reactor disassembly and defueling (2600 to 15,000 person-rem) is wide because of many uncertainties involving the removal of the reactor internals and fuel and the effectiveness of the water cleanup systems. The pleaum may be removed intact, or an extensive effort may be needed to section and remove it. The time required to transfer the fuel to canisters is likewise uncertain. If the fuel is not fused, a lower number of person-hours and a lower dose would be expected. However, if much of the fuel is fused, the dose would be much higher. The transfer canal will contain myriad small particulate sources of radiation that will be removed by the water cleanup system during defueling. If these sources are kept well underwater and transferred to fuel canisters by the water cleanup system, dose rates will be low. However, if a significant portion of these particulates forms a film on the surface of the water in the .ransfer canal, the average dose rate for the workers could be much higher. TABLE 2.1. Estimated Occupational Radiation Dose for the Current Cleanup Plan Task Person-rem Dose Reduction Program 2,000-5,100 Reactor Disassembly and Defueling 2,600-15,000 Primary-System Decontamination 56-970 Reactor Building and Equipment Cleanup 5,900-21,000 Auxiliary and Fuel-Handling Building Cleanup 500-1,400 Utility and System Maintenance 100-200 Waste Management and Transportation (*) 97-485 Dose To Date 2000 13,000-46,000 (a) From the PEIS. 2.21

The processes for primary-system decontamination have not yet been ^ identified by the licensee. The occupational dose required will be a function of the number and type of dead legs (sample liles and other areas of restricted flow)-that workers must flush, the number of repeat processes that must be performed, the. occurrence of spills resulting from leaks in the system, and the waste-handling method used. Cleanup of the reactor building and equipment will result in an estimated .5,900 to 21,000 person-rem of occupational radiation dose. As much as 80% of this dose is associated with cleanup of the 282-f t elevation. This estimate assumes that considerable decontamination of this elevation is performed from the 305-ft elevation through floor penetrations prior to entry into the 282-ft elevation. As an alternative, immersion decontamination, accomplished by filling the basement with water or other decontamination solutions and pro-cessing the water on either a batch or a continuous basis, is being, considered but.was not evaluated due to limited knowledge of its effectiveness. Exten-sive use of robotics on the 282-ft level would also reduce the dose to -workers. The robotic option is explored further as Alternative 3. Final cleanup of cubicals and systems in the auxiliary and fuel-handling building, including the processing of decontamination waste from system and tank cleanup, is estimated to require between 500 and 1400 person-rem. The maintenance of utilities, communication systems, and other essential -services during the cleanup is expected to require an additional 100 to 200 person-rem, depending on the frequency of breakdowns and the duration of the cleanup effort. Approximately 2000 person-rem have already been incurred during cleanup operations through May 11, 1984 In the opinion of the staff, if cleanup goes well, it might be completed at the low estimate of 13,000 person-rem. How-ever, even if additional problems continue to arise, cleanup should be com-pleted at less than the high estimate of 46,000 person-rem. 2.3' ALTERNATIVE 1: EXTENSIVE CLEANUP FOLLOWED BY DEFUELING As mentioned earlier, the initial cleanup plans discussed in the PEIS called for extensive decontamination of the reactor building and equipment prior to defueling. It was believed at the time the PEIS was prepared that such decontamination could be accomp'ished largely by water flushing and hydroblasting (high-pressure water fluehing). Experience to date has indi-cated that these activities are less e!.fective at reducing dose rates than had been anticipated, probably because contamination is embedded deeper in sur-faces than was expected because of delays in beginning cleanup. This alternative to the current cleanup plan calls for meeting the initial dose reduction goal of about 10 mrem /hr in occupied areas through a combination of aggressive decontauination, equipment removal, and shielding. Once this goal is met, the reactor would be disassembled and defueled and the primary system would be decontaminated. In this section, the procedures and work' sequence for decontaminating the building and equipment, disassembling 2.22

t and < defueling. the ' reactor,1 and decontaminating the - primary system are. out-ilined..and.the impact of this alternative on occupational dose is_ discussed. 2.3.1x Tasks and Sequencing of Alternative:1 Under, ; th'is': alternative, = decontamination of the' auxiliary and fuel- = handling building would = be as described in the discussion of the current ? cleanup plan.; The sequence.of ' decontamination operations in the reactor building _would consist of first' ~ removing debris and heavy deposits, and then ' cleaning : thel exposed surfaces... Cleanup efforts would begin at upper levels and proceed downward to. minimize recontamination. The majority of the

building-cleaning effort would precede defueling; however, some final cleanup

^ (would be required following defueling and primary-system decontamination. 2.3.1.1 ~ Reactor Building and Eq'uipment Cleanup ~ _. Cable trays, overhea'd' lighting, and electrical conduits are known to be significant sources. of _ occupational radiation exposure. Water flushing and .hydroblasting;are.not particularly effective at decontaminating these sources. Unless --some alternative method 'of chemical ~ decontamination, such as. foam i --cleaning or freon-cleaning, proves effective, the equipment would have to be removed to climinate these sources. Removal _of the equipment would require ' the identification' and replacement of instrument and control cables required L for safety, and-the installation of' temporary lighting and electrical outlets a needed to operate decontamination and~ defueling equipment. Chemical decon-tamination or removal.of the reactor b'uilding's air coolers would also be ~ required., Floor! drains would have to be chemically decontaminated, the -surfaces of concrete floors 'and walls would have to be removed by spalling, _l and other aggressive decontamination actions would be required. Some shield- [ . ing of. primary piping and other sources would also' be required to reach the i dose rate objective.' Such an extensive cleanup program would require extensive planning, ' testing, and source identification as well as a substantial number of workers 4 in containment. - Large occupational doses would be incurred early in the cleanup' effort. This' approach would delay the start of fuel' removal. for at t' least 1-1/2 years and possibly considerably

longer, depending on' the difficulties encountered.

2.3.1.2 Reactor Disassembly and Defueling and Primary-System Decontamination Under Alternative 1, disassembly and defueling of the reactor and decon-tamination 'of-the primary system would involve essentially the same tasks as - described for - the current plan. The difference would be that these tasks would be-performed in lower radiation fields, with only a small dose contri- -bution from radiation sources associated with the building and equipment other .than the-reactor primary system. During building cleanup, the primary coolant

would be processed in small batches through the SDS-system, as is now being done.

This; additional processing beyond what has already been done is . expected to.have a negligible effect on the quantity of radioactive material handled during defueling, or on the dose rates from this material. Theoreti- + l cally, the longer radioactive materials are in contact with reactor piping, I 2.23

4 the greater.the extent of radionuclide migration into the oxide layer of the piping and the more difficult decontamination becomes. In view of.the con-siderable time between the accident and decontamination of the primary system I (under. all-options). the delay required under this alternative to allow for building cleanup would have little effect on the case or effectivness of primary-system decontamination. Much of the dose received during' primary-l system decontamination is from material in the primary system rather than sources.in the building. Therefore, the dose for primary-system decontamina-tion in this alternative is only slightly less than the dose for the same task in'the' current plan. ~ ~ Additional building decontamination would be required durinF and follow- ~ -ing both defueling and primary-system decontamination to maintain the dose rates achieved during the initial building and equipment cleanup phase. This recleaning would result in additional occupational radiation doses. '2.3.2 Occupational Radiation Dose Associated with Extensive Cleanup Followed by Defueling The occupational radiation dose associated with this alternative was estimated in the same manner as was the dose for the current cicanup plan and is shown, broken down by tasks, in Table 2.2. The dose reduction task called for l in the. current plan does.not-appear in Table 2.2 because any of those . activities required as part of Alternative-l would be performed as part.of the reactor building and equipment cleanup, not as a separate task. l'

It was assumed that; considerable equipment would need to be removed in order-to achieve the goals for this alternative.

Because fuel remains in the - reactor, certain safety systems are required. The preservation or replacement of.these systems would require a very large number of man-hours in containnent + and a corresponding increase in worker doses. TABLE 2.2. Estimated Occupational Radiation Dose for Extensive Cleanup Followed by Defueling Task Person-rem Reactor Building and Equipment Cleanup 9,000-30,000 Reactor Disassembly and Defueling 820-6,500 Primary-System Decontamination-39-780 Reactor Building Recleaning 12-630 Auxiliary and Fuel-Handling Building cleanup 500-1,400 Utility and System Maintenance 100-200 Waste Management and Transportation (") 97-485 Dose to Date 2000 13,000-42,000 (a) From the PEIS. 2.24

Even. assuming release from some of these requirements, higher occupa-tional_ doses were estimated for-reactor building and equipment cleanup under this: alternative than under the current cleanup plan, for the following ree:ans: . Worker time in containment would be required to replace some control and utility cables to ensure that the reactor is maintained in a safe status . prior to fuel removal. The lack of a dose ' reduction program preceding cleanup would result in the1 cleanup work being done at-high dose rates and would require more worker hours for completion of this operation. (Under the current plan, some source removal is performed as part of the dose reduction program.) Even with aggressive building decontamination, there is little assurance that ' the : average 10-arem/hr target for the reactor building could be met as long as fuel and fission product contamination remained in the primary system. The goal would certainly not be met inside the D-rings or 'near primary-system piping. and components. An average working dose rate of 10 mrem /hr was, .however, assumed as the low dose rate for most reactor disassembly and Edefueling tasks. The occupational dose for primary-system decontamination was lower under -this alternative than under the current plan because of the lower general-area Edose rates. The average dose rate, however, was assumed to be somewhat above 10 arem/hr because.the workers would be close to the reactor coolant piping for much of this work. The task of maintaining reactor building cleanliness during defueling and -decontamination is new under this alternative. The level of effort that would ' be required is difficult to estimate because it would depend on. the nature of the' reactor-core debris, the' contamination control barriers provided, the work practices, the process used for primary-system decontamination, and the number and size of'any leaks in the primary system. Because the dose rates for this task would be low, the total dose involved would be relatively small. Cleanup of the. auxiliary and fuel-handling building would result in the same-dose under this alternative as under the current plan because it would be -done in-the same way. Utility and system maintenance is estimated to require approximately the same dose under this. alternative as under the current plan. The utilities - would be needed for a longer time under this alternative; however, the dose Lrates involved in maintenance would decrease earlier in the cleanup operation. If cleanup "were performed according to this alternative, fuel removal would not begin for several years. 2.4 ALTERNATIVE 2: PHASED DEFUELING FOLLOWED BY REACTOR BUILDING CLEANUP . Alternative 2 differs from the current plan and the other alternatives in that a large portion of the fuel debris would be removed as a slurry before 2.25 n

j the reactor vessel head,was lifted. Although there are currently no plans to do any defueling before the head lif t, this alternative is included because j it would minimize the potential for fuel fines to contaminate equipment and result in exposure to personnel during-later operations.. Also, there may be j safety advantages to having the- ' reactor vessel head in place as long as possible because it would provide shielding to the workers performing initial defueling tasks... Drawbacks to this alternative' include delays resulting from .the design, fabrication, and testing of equipment for phased fuel removal, and . additional equipment-costs. '2.4.1 Tasks'and Sequencing of Alternative 2 Phased'defueling would be accomplished'by altering the sequence of tasks -for. reactor defueling. The major tasks and their general sequence for phased defueling are: implementation of the dose reduction program, as described for the current plan (this program would continue throughout reactor defueling)

• -installation of water vacuum and support equipment for removing the fuel fines, and removal of the fines through a control rod drive mechanism (CRDM) nozzle in the head o' preparation for reactor vessel head removal, and removal of the head, plenum, fuel, and reactor vessel internals, as described for the current plan e' decontamination of the primary system, as described for the current plan completion of the auxiliary and fuel-handling building cleanup and the e

reactor. building and equipment : cleanup, as described for the current plan.. 2.4.1.1 Fines Removal Prior to Head Lift Under'.this alternative, a fuel debris removal system would be installed before the reactor vessel head was lifted. This system would have some of the features of the planned system for reactor water cleanup system except that canisters would be provided for the collection of relatively large quantities of fuel debris, and a system would be required for observing and manipulating the vacuum nozzle within the reactor vessel. The time required for the design and fabrication of - this. system would delay fuel removal and all subsequent cleanup efforts for at-least 18 months, perhaps longer. The debris removal system would include a water vacuum probe inserted. through a CRDM nozzle (the CRDM was previously removed for the underhead - characterization work). The vacuum would be used to remove accessible fines and ' small rubble. Debris removal would be observed by closed-circuit TV. (CCTV) ? inserted in one of the two vacant CRDM lead screw holes (the lead screws were removed for quick-scan and quick-look operations). The debris ' removal nozzle would be controlled by a cable system similar to that used for control of the CCTV cameras. Clarified borated water would be returned to the 2.26 n

reactor vessel using a third CRDM lead-screw opening. Actual debris removal would take only a few months unless nozzle plugging and visibility problems were severe, in which case it could take much longer. A substantial portion of the estimated 100,000 lb of rubble 1 inch or less in diameter might be removed in this way. The fuel canisters would require considerable shielding, either by storage underwater (which might be accomplished by filling the fuel transfer canal) or by the use of massive shielding casks. Filling the fuel transfer canal for shielding in the near future could impede the necessary refurbish-ment of the canal. The availability of adequately shielded casks has not been investigated. 2.4.1.2 Reactor Disassembly and Defueling Af ter the modification and refurbishment of the fuel transfer equipment and the removal of accessible fines from the reactor vessel, reactor dis-assembly and defueling would proceed as described for the current plan, with the exceptions noted below. Under the current plan, every effort will be made to perform a dry head lif t because refurbishment of the transfer canal will not be complete. If the head lift was delayed until the t ransfer canal refurbishment was complete, as it would be under this alternative, the incentives for dry head lif t would diminish. A wet head lift is expected to require less occupational dose. Once the head was lifted, there would be much less particulate radio-activity in the reactor coolant and therefore a diminished probability of rapid releases of dissolved cesium from the core contents as it is disturbed. This would lead to lower dose rates. Defueling aft-: head removal would also involve fewer filter changes and fewer worker hours because so much material would have been removed before head lift. Later defueling activities would be identical to those for the currcnt plan, except that under this alternative, the effort required to decontaminate the transfer canal following defueling could be somewhat lessened because of lower contaminant levels in the water. 2.4.1.3 Primary-System Decontamination, Auxiliary and Fuel-Handling Building Cleanup, and Reactor Building and Equipment Cleanup These activities would be unaffected by the defueling method; hence, for these activities, all aspects of Alternative 2 and the current plan are identical. 2.4.2 Occupational Radiation Dose Associated with Phased Defueling Followed by Reactor Building Cleanup The occupational radiation dose required to perform phased defueling followed by reactor building cleanup was estimated in the stme manner as the dose for the current plan. The total estimate and the breakdown by task are given in Table 2.3. The occupational dose needed to accomplish the dose reduction program was unchanged from that of the current plan. 2.27

4 TABLE 2.3.,' Estimated Occupational Radiation Dose for Phased Defueling Followed by Reactor Building Cleanup; Task' Person-rem Dose Reduction Program-2,000-5,100 Defueling Operation Prior to Head Lift 140-540 Reactor. Disassembly and Defueling 2,600-14,000 Primary-System Decontamination 56-970 Reactor Building and Equipment Cleanup 5,900-21,000 Auxiliary and Fuel-Handling Building Cleanup 500-1,400 Utility and System Maintenance 140-280 ~ ~ Waste Management and ' Transportation (*} 97-485 Dose To Date 2000 13,000-46,000 (a) From the PEIS. l The dose. range for removing the fuel fines prior to head lift' was estimated assuming that. either water or ' solid _ material would be used as shielding to diminish = the dose contribution from the fuel fines. s The. doses :for reactor disassembly and -defueling would be only slightly lower under this alternative than under the - current plan, because the time that would be required for-vacuuming the fines represents only-a small portion of.the time needed for fuel removal, and the dose rates in the building would remain'approximately the same. The greatest advantage ' of early - fuel removal would be - the subsequent - decrease in the-quantity of particulates _that. could (contribute to worker dose..This decrease results in the lowering of the upper-

bound assumed for the dose rates for: the balance of defueling.

The early removallof fines might also simplify. cleanup of the transfer canal, and this benefit'is reflected in the dose estimate.- 'The doses for primary-system decontamination, reactor building and equip-ment: cleanup, and auxiliary and fuel-handling building cleanup would be the same under this alternative as_under the current. cleanup plan; they would not _j be ~affected by the fuel removal procedure considered under thin alternative. l The dose required for utility and system maintenance would increase over that { of the current plan to account for the additional time that this alternative .would prolong the cicanup. (This additional time would be needed to allow for the-design, development, construction, and testing of the equipment needed for phased fuel removal.) l [. 2.28 Le t.I'

2.5 ALTERNATIVE 3: DEFUELING FOLLOWED BY DELAYED CLEANUP USING ROBOTICS A third alternative for cleaning up TMI-2 would be to clean up most or all of the auxiliary and fuel-handling building and to reduce the dose rates in and defuel the reactor, as described in the current plan; then to place the reactor and containment building in interim, monitored storage, and to perform final building cleanup using robotics sometime in the future, when appropriate technology and devices become available. While timely removal of the damaged fuel is considered essential, the option of delaying further cleanup was considered worthy of evaluation. Robotics is a rapidly emerging technology with the potential for eliminating considerable occupational radiation exposure. Robotics is already being applied to a limited degree in the auxiliary and fuel-handling building, and applications in the reactor building are being evaluated. How much time would elapse before reliable and economical robotic devices could perform a majority of the in-containment cleanup work is unknown. The most optimistic projec-tions for robotic technology indicate that adequate robots will be available before they would be required for building cleanup under the current work sequence. More realistic projections indicate that a storage period of 10 to 20 years may be required before robotic cleanup would be possible. Although maximizing the use of available robotic devices for high-dose work would be consistent with the ALARA principle, certain assurances would be required before this alternative could be adopted. The safety of the interim-care phase would require additional study and assessment. There would need to be better assurance that the robotic technology needed to accomplish cleanup would become available. In addition, provisions for financing future cleanup would need to be made. 2.5.1 Tasks and Sequencing of Alternative 3 This alternative would include the phases of cleanup discussed for the reactor building in the current cleanup plan and would incorporate an interim-storage phase as well. These are discussed below. 2.5.1.1. Reactor Disassembly and Defueling The auxiliary and fuel-handling building cleanup, dose reduction program, and reactor disassembly and defueling would proceed concurrently, essentially as described in the current plan. The areas of the auxiliary and fuel-handling building with the highest dose rat-' aght be lef t untouched. In the dose reduction program, slightly greateri g,

is might be placed on shielding rather than decontamination, and ori.

u, onu that must be occupied for reactor disassembly and defueling wJai .e tject to dose reduction efforts. The 282-f t elevation, for example, wo..d px a.,1y be lef t totally untouched to reduce the occupational radiation dose. Because the safety of the monitored interim storage period has not been evaluated, it is difficult to predict how much radioactive material, particu-larly fuel, might be allowed to remain during this phase. Although it is clear that fuel inventories should be reduced to a level whete: criticality is 2.29

inconceivable, such a criterion would require only that about half the fuel be removed. The actual quantity permitted to remain during interim storage, if interim storage were allowed, would probably be much less. Under this alternative, defueling might stop prior to final cleanup of the transfer canal, or some selected mechanical or chemical decontamination might required for those portions of the primary system that contain fuel particles. 2.5.1.2 Interim Storage of the Defueled Reactor Upon the completion of reactor defueling, the auxiliary and fuel-handling building and the containment building would be placed in an interim, monitored storage mode until robotic technology was available to perform the remaining decontamination of cubicles in the auxiliary and fuel-handling building and of the primary system and the reactor building and equipment. Interim storage would involve the maintenance of essential services (e.g., security and radiological surveillance, utilities, ventilation systems, and planning and administration), but no active program of building or equipment decontamina-tion would be conducted except as remote or robotic technology became avail-able. During interim storage, occupational radiation exposures would be restricted to those necessary to maintain the facilities in a safe and secure condition. Tasks such as repairing the ventilation systems and changing filters would account for most of the dose received. 2.5.1.3 Primary-System Decontamination Except for those activities necessary for the reactor to be considered safe for interim monitored storage, any primary-system decontamination would be done by robotics. Decontamination performed by plant workers before interim storage might include localized chemical or mechanical cleaning, but would involve only a small fraction of the occupational radiation dose incurred for complete primary-system decontamination under the current plan. Further primary-system decontamination might or might not be undertaken following interim storage of the reactor, depending on the anticipated future use of the reactor, waste disposal limitations in effect at that time, the capabilities of available robotic devices, and other factors. If decontamina-tion were undertaken by robotics, the only occupational radiation dose incurred would be from decontaminating and maintaining the robots, and possibly f rom handling and transport'_ng the waste generated; however, some of these tasks might also be done by robotics. 2.5.1.4 Robotic Cleanup of the Reactor Building and Equipment it is somewhat premature to envision in detail what tasks might be involved in robotic cleanup of the TMI-2 reactor building because most present-generation robots are severely limited in mobility, dexterity, strength, or logic. The tasks of equipment removal, building and equipment decontamination, shielding removal, and decontamination and building survey would have to be performed to complete the cleanup. The principal difference i 2.30 = ' I m IBM I g ,..m a

between this alternative and - the current. plan is that these tasks would be _ performed without' workers' routinely being in the reactor building. Occupational doses incurred during robotic cleanup of the reactor building,_ like those incurred - during primary-system decontamination using r robotics, would primarily be those from decontaminating and servicing robots and.from waste-packaging, waste-handling, and waste transportation activities that were-not done robotically. 2.5.2 Occupational Radiation Dose Associated with Defueling Followed by Delayed Cleanup Using Robotics- - The_ occupational radiation dose associated with this alternative was i estimated in' the same manner as the dose for the cleanup plan and the other alternatives. The total and. task-b reakdown estimates are presented.in- ' Table 2.4. ~ -The dose reduction program and reactor disassembly and defueling would be performed in the same way and require the same dose as under the current plan. The primary-system cleaning performed by plant workers before interim ~' storage would consist only of the localized cleaning required for the plant to 'be considered defueled. The extent of.this activity was arbitrarily chosen TABLE 2.4. Estimated Occupational Radiation Dose for Defueling Followed by Delayed Cleanup Using Robotics Task Person-rem [ Dose Reduction Program 2,000-5,100 Reactor Disassembly and Defueling 2,600-15,000

Primary-System Cleaning 11-190 Utility and System Maintenance 80-160 Interim Care of Reactor Building and Auxiliary and Fuel-Handling Building (1.7-31 person-rem per year) 0-620(,)

Auxiliary and Fuel-Handling Building Cleanup 97-1,400 Robotic Primary-System Decontamination, 300-3,500 Reactor. Building and Equipment Decontamina-tion, and Final Auxiliary and Fuel-Handling Building Cleanup- ' Waste Management and Transportation ( 97-485

Dose To Date 2000 7,200-28,000 (a) Based on 0 to 20 years of interim care.

(b) From the PEIS.. 2.31 L .,, ~,.. ,,~..--.,-...,.---.--.,,.--,.,.~-n,,_,n.,,-.

because the criteria for interim storage have not been established. A dose of 20% of that required for the full-system decontamination considered in the current plan was used. In reality, any value between zero and the maximum dose of 970 person-rem under the current plan might be possible. Utility and system maintenance would be required only until defueling, including any primary-system decontamination, was complete; therefore, doses associated with this task are lower under this alternative than under the current plan. However, a new task, interim care during the storage period, would be required. The dose incurred in maintaining the reactor building during this time would be 1.6 to 30 person-rem per year. This interim-care period might not be required, or it could continue for as long as 20 years. It is this difference that accounts for the wide range of doses presented. Cleanup of the auxiliary and fuel-handling building would be much the same under this alternative as it is under the current plan, except that areas where there are high dose rates (e.g., the insides of tanks and piping systems) might remain untouched until robotic techralogy was available. The elimination of a few high-dose jobs involving a relatively large uncertainty accounts for the dif ference between the low end of the dose range estimated for this alternative and that presented for the current plan. The high end of the dose range was estimated assuming the same treatment as under the current plan. The dose incurred for interim care of the auxiliary and fuel-handling building is estimated to be 0.1 to 1.0 person-rem per year. Primary-system decontamination, reactor building and equipment decon-tamination, and cleanup of remaining hot spots in the auxiliary and fuel-handling building would all be done robotically under this alternative. Robotic activities are, however, expected to result in some radiation dose to workers maintaining the robots and performing other activities. This dose was assumed to be between 5% of the low dose and 15% of the high dose from manual performance of the activities. 2.6 ANALYSIS OF THE CURRENT CLEANUP PLAN AND ALTERNATIVES Sections 2.2 through 2.5 described four approaches to accident cleanup at TMI-2 and presented estimates of the occupational radiation dose associated with each approach. The approaches that were selected would use available or emerging technology and would be consistent with the conclusion of the PEIS that the TMI-2 site is not suitable as a permanent repository for the accident-generated waste. This section is intended to summarize the strengths and weakness of the current cleanup plan and the three alternatives and to provide an additional basis for the environmental impact discussed in Section 3. The criteria against which the licensee's current plan and each alterna-tive were evaluated include: public safety occupational radiation dose e time schedule for fuel removal and completion of cleanup e technical feasibility. 2.32

In the following discussion, the four cleanup options are compared using these four criteria. 2.6.1 Analysis of Public Safety The safety concerns of the TMI-2 reactor are presented in the PEIS and have not changed. Therefore, they are not discussed here. However, the safety concerns will be substantially reduced when the fuel is removed. The current plan and Alternative 3 - (defueling followed by delayed cleanup using robotics) are therefore preferable according to this criterion. Alternative 2 (phased defueling followed-by reactor building cleanup) was evaluated because it appeared to have some advantages for the safety of the public and the workers. The staff now feels that any advantages of Alternative 2 are offset by the fact that it would delay defueling by at least 1-1/2 years. The public safety of the monitored, interim-storage phase that is envis-ioned as part of Alternative 3 would require additional evaluation. Although the possible release modes and affected environment are well known, the radionuclide inventories that will remain af ter defueling, the type of care that would be provided, and the duration of the care period are unknown. An evaluation of the safety of this phase would therefore be premature at this time. 2.6.2 Analysis of Occupational Radiation Dose As illustrated in Figure 2.9, the estimated dose associated with cleanup of the TMI-2 site under the current plan is considerably higher than the dose associated with - cleanup under Alternative 3 (defueling followed by delayed cleanup using robotics), and slightly higher than that for Alternative 1 (extensive cleanup followed by defueling). The estimated dose for the current plan is equivalent to that for Alternative 2 (phased defueling followed by reactor building cleanup). Although the lowest occupational radiation dose is associated with Al-ternative 3, the tasks that would be performed under this alternative, through the reactor disassembly and defueling phase, are the same as those under the current plan. Therefore, it is not necessary to make a decision for or against Alternative 3 on the basis of radiation dose at the present time. The second lowest dose is estimated for Alternative 1, extensive decon-tamination followed by defueling. The implementation of. Alternative I would preclude the use of robotics to perform the ' high-exposure job of reactor building cleanup because the building would be decontaminated in the very near future, before adequate robotic technology became available. On the basis of occupational dose, Alternative 2 (phased defueling fol-lowed by reactor building cleanup) is essentially equivalent to the current plan. 2.33

l 50,000' Y m.e 40,000 2 30,000 g i O u) m y 20,000 = = n 10,000 ~ 0 CURRENT ALTERNATIVE ALTERNATIVE ALTERNATIVE PLAN ONE TWO THREE FIGURE 2.9. Occupational Radiation Dose to Complete Cleanup 2.6.3 Analysis of Time Schedule The prompt removal of fuel and cleanup of the reactor building affects worker dose, both directly because of routine maintenance and indirectly because of ease of cleanup. An attempt was therefore made to determine the relative effect of the current plan and the alternatives on the timing of fuel removal and the completion of cleanup. To do this, four schedules (presented as Figures 2.10, 2.11, 2.12, and 2.13) were prepared to reflect the plan and the alternatives. These schedules are presented in time intervals rather than The intervals used here correspond roughly to the periods used by the years. licensee in estimating radiation dose (Kanga 1983). If resources were un-limited, an interval could correspond to 6 to 9 months. Under the best con- ~ditions of availabic resources, it probably represents 1 year; under less favorable conditions, 2 years. These schedules show the earliest probable start time and the latest start time for each activity. Because of the unique nature of many of the cleanup tasks to be performed, there is an amount of uncertainty for the duration of those cleanup tasks. Also, because of the sequential nature of many of the cleanup tasks (e.g., under the present plan, fuel removal is preceded by reactor head removal and subsequent plenum removal), the starting and finishing date of many cleanup tasks will have a cascading effect on the starting dates of subsequent tasks. Each of the 2.34

INTERVAL (a) A B C D E F G H I J K DOSE REDUCTION O O PROGRAM REACTOR DISASSEMBLY s a AND DEFUELING HEAD REMOVAL ddi PLENUM REMOVAL

• MI FUEL & LOWER-INTERNALS REMOVAL d

() h> CANAL CLEANING J PRIMARY-SYSTEM ,,,,,,[g DECONTAMINATION REACTOR BUILDING AND EQUIPMENT O O*"""*2'-

?

CLEANUP AOXlLIARY AND FUEL-HANDLING BUILDING O O CLEANUP UTILITY & SYSTEM J( ) L MAINTENANCE ~ 6 EARLY START O EARLY FINISH A LATE START $ LATE FINISH FIGURE 2.10. Conceptual Schedule for the Current Plan (a) an interval represents a time period of 6 months to 2 years - see Section 2.6.3. l l l 2.35 {

INTERVAL (a) A B C D E F G H I J K REACTOR BUILDING AND EQUIPMENT th i 0; ^ CLEANING REACTOR DISASSEMBLY [ j' n AND DEFUELING PRIMARY-SYSTEM j' ,,,,,, j g DECONTAMINATION REACTOR BUILDING < r J 4 RECLEANING AUXILIARY AND FUEL-HANDLING BUILDING C O CLEANUP UTluTY AND SYSTEM J' j '. s MAINTENANCE A EARLY START O EARLY FINISH A LATE START e LATE FINISH FIGURE 2.11. Conceptual Schedule for Alternative 1 (a) an interval represents a time period of 6 months to 2 years - see Section 2.6.3. 2.36

INTERVAL (a) A B C D E F G H I J K DOSE REDUCTION m PROGRAM - l' l I PARTIAL DEFUELING 2C PRIOR TO HEAD j g LIFT REACTOR DISASSEMBLY N 3[ m e 6 AND DEFUELING PRIMARY-SYSTEM h)....... ,,,,j(4 DECONTAMINATION REACTOR BUILDING i < r AND EQUIPMENT U C d'- i l CLEANUP AUXILIARY AND FUEL-HANDLING BUILDING O CLEANUP UTILITY AND SYSTEM Jk L MAINTENANCE { A EARLY START O EARLY FINISH A LATE START $ LATE FINISH FIGURE 2.12. Conceptual Schedule for Alternative 2 (a) an interval represents a time period of 6 months to 2 years - see Section 2.6.3. 2.37

II INTERVAL A B C D E F G DOSE REDUCTION n 2 6 PROGRAM l' l I REACTOR DISASSEMBLY g i n AND DEFUELING INITIAL PRIMARY-g' SYSTEM CLEANING INITIAL AFHB CLEANUP O O TO 20 YEARS INTERIM MONITORED gg j ,y p STORAGE ROBOTIC PRIMARY-SYSTEM DECONTAMINATION, 3, REACTOR BUILDING c JW. AND EQUIPMENT 2 5 YEARS z-5 CLEANUP AND YEARS AFHB CLEANUP UTILITY AND SYSTEM U kh MAINTENANCE A EARLY START O EARLY FINISH A LATE START 4 LATE FINISH FIGURE 2.13. Conceptual Schedule for Alternative 3 (a) an interval represents a time period of 6 months to 2 years - see Section 2.6.3. j 2.38

schedules presented in Figures 2.10 through 2.13 show an early start and early finsih sequence along with a more pessimistic late start and late finish sequence. However, the two sequences should not be completely decoupled. For example, one could have an early start and finish for one task followed by a more lengthly period necessary to complete the subsequent task. In that case, the subsequent task would have an early start date, however, the duration of the task will correspond to the late start and late finish inte rval. The actual completion date for the subsequent task would then fall between the early finish and late finish dates as illustrated in those schedules. The duration of major tasks in the various approaches to cleanup is discussed below. Under all options, reactor disassembly and defueling must await the re-qualification of the polar crane. Under Alternative 1 (extensive cleanup followed by defueling), disassembly and defueling must also await the comple-tion of reactor building cleanup. Under Alternative 2 (phased defueling followed by reactor building cleanup), disassembly and the completion of defueling must await the design, fabrication, and operation of a system to remove fines through the reactor head. For all approaches, disassembly and defueling (from head removal through transfer canal cleanup) was estimated to require a minimum of 2-1/4 intervals and a maximum of 4-1/2 intervals, illustrated in detail in Figure 2.10. Reactor building cleanup was estimated to require between 2 and 3 intervals under the current plan and Alternative 2 (phased defueling followed by reactor building cleanup). Under Alternative 1, when building cleanup would precede defueling, it was estimated to require between 2-1/2 and 4 intervals because of the need to maintain some safety systems in operable l condition. In addition, under Alternative 1, the reactor building would l require some additional cleaning following both defueling and primary-system decontamination. Primary-system decontamination was estimated to require 1/4 to 1/2 i interval following defueling for all cases in which it would be performed. Cleanup of the auxiliary and fuel-handling building was estimated to require from 1-1/4 intervals to 4 intervals, and utility and system maintenance is required under all options for as long as work is going on. As shown in Figures 2.10 and 2.13, the current plan and Alternative 3 (defueling followed by delayed cleanup using robotics) provide for the earliest defueling, completed in 3-1/4 to 6 intervals. Alternative 2 (phased defueling followed by reactor building cleanup) would delay the completion of defueling to 4 to 6-1/2 intervals. Alternative 1 (extensive cleanup followed by defueling) would have the greatest impact, delaying the completion of defueling to between 4-1/2 and 8-1/2 intervals. The completion of cleanup also varies with the alternatives. The current plan and Alternative 1 are comparable in this area, with cleanup completed between 5-3/4 and 9-3/4 intervals. Alternative 2 (phased defueling followed by rcactor building cleanup) would extend the cleanup time to between 6-1/2 2.39

and 10-1/4 intervals. Under Alternative 3 (defueling followed by delayed cleanup using robotics), final cleanup might not be completed for more than 30 years. 2.6.4 Analysis of Technical Feasibility The technical feasibility of the various alternatives was also evaluated. Alternative 3, involving delayed cleanup by robotics, would clearly have some ' drawbacks in this area. Current models have suf fered f rom reliability prob-lems. In addition, there is no assurance that robotic technology will pro-to the point at which robots could perfonn all phases of cleanup. gress However, current models are capable of some cleanup tasks, and the development of more versatile models appears to be progressing rapidly. Under Alterna-tive 1, the ability of the licensee to meet the goals set for building and equipment decontamination prior to defueling is subject to some doubt. Fuel in the primary system might preclude meeting these goals. The current plan and Alternative 2 (phased defueling followed by reactor building cleanup) were both judged to be technically feasible. 2.6.5 Summary Analysis The staff has determined that, in terms of the nature of the activities involved, the current cleanup plan, Alternative 1, and Alternative 2 all fall within the scope of the PE1S. The interim-storage phase of Alternative 3 does not. All of the options have advantages and drawbacks (summarized in Table 2.5), and all would involve an occupational radiation dose beyond that estimated in the PEIS. TABLE 2.5. Summary Evaluation of Cleanup Alternatives Criterion Current Plan Alternative 1 Alternative 2 Alternative 3 Public Safety No change (" No change (* No change (" Safety of interim storage not evaluated Occupational Dose Equivalent Equivalent Equivalent Lower Time for Fuel Early Latest Later Early Removal Time for Cleanup Early Early Later Not completed in a defined Completion time Technical Feasible Feasible with Feasible Feasibility not assured Feasibility some reservations (a) No significant change from that assessed in the PEIS. (b) The current plan and Alternatives 1 and 2 were assessed to be equivalent in terms of occupational dose. 2.40

The current plan is equal or superior to the alternatives with respect to all criteria except occupational dose; Alternative 3 would result in a lower occupational dose, but currently the technical feasibility of Alternative 3 is not assured. Alternative 1 (extensive decontamination followed by defueling) has the drawback of delaying fuel removal. There is also some question regarding the feasibility of meeting the 10-mrem / hour decontamination goal prior to defuel-ing and primary-system decontamination. Alternative 2 (phased defueling followed by reactor building cleanup) is equivalent to the current plan with respect to public safety and technical feasibility. It has the drawback of delaying both fuel removal and final building cleanup. Alternative 3 (defueling followed by delayed cleanup using robotics) is expected to be superior to the current plan with respect to occupational dose and equivalent with respect to the time for fuel removal. It would, however, result in an undefined, but possibly very long, delay in the time required to complete cleanup. The safety of the monitored, interim-storage phase could not be evaluated at the present time, but some increased risk to the public is expected to result from delaying final cleanup. The major difficulty in assessing Alternative 3 was in regard to technical feasibility. There is little doubt that the majority of building cleanup could not reasonably be accomplished using robotic technology at the present time. One can only speculate on what the state of robotic technology will be in the 0 to 20. years following defueling. The staff prefers to present Alternative 3 as an alter-native that may warrant further consideration af ter defueling is complete, but cannot be considered feasible at the present time. / 2.41

) 3.0 REVISED ENVIRONMENTAL IMPACTS -The most significant environmental ~ impact defined in the PEIS was the radiation dose to workers'during cleanup operations: it was determined in the TEIS that offsite dose is not going to be significant. The revision of the estimated occupational dose was. calculated for this supplement to the PEIS, based on new information regarding the difficulty of cleaning up the reactor building and the auxiliary and fuel-handling building. In Section 2 of this document, various alternatives for the cleanup of TMI-2 were described. Occupational radiation doses were estimated for reactor building cleanup, auxiliary and fuel-handling building cleanup, primary-system decontamination, reactor disassembly and defueling, and dose reduction efforts. In all cases, a range of values was given for the occupational dose, representing the uncertainty of the estimates. This section of the supplement discusses the revised occupational-dose estimates and resulting health effects. The discussion is divided into three sections. Section 3.1 dis-cusses the population that would receive the occupational dose from the clean-up. Section 3.2 summarizes the estimated occupational doses that would result from cleanup. Section 3.3 discusses the potential health effects associated with those estimated occupational doses. 3.1 AFFECTED POPULATION .. The only population group considered in this supplement is composed of members of the workforce who enter radiation zones at TMI-2 while conducting cleanup operations. These workers are over 18 years old (average age is 42), in good health, and primarily male. They are employed by the licensee and the licensee's subcontractors, the Department of Energy and its subcon-tractors, and the Nuclear Regulatory Commission and its subcontractors. 3.2 REVISED OCCUPATIONAL-DOSE ESTIMATES The cumulative occupational radiation dose to complete cleanup of "MI-2 is presented in Table 3.1 for each of the four cleanup options. As ducussed in Section 2.6, the current plan and Alternatives 1 and 2 are considered acceptable at this time. Of these, the current plan represents the cost probable course of action for the licensee. Regardless of which option f.s chosen, three operations are responsible for 90% or more of the total occupational dose associated with cleanup. These three operations are: reactor building and equipment cleanup reactor disassembly and defueling . dose reduction. The highest percentage of the total dose will result from reactor building and equipment cleanup. This operation is necessary to meet the cleanup objectives. 3.1

TABLE 3.1.' Cumulative Occupational Radiation Dose Associated with Each Cleanup Option ~(person-rea)- Current Cleanup Plan Alternative 1 Alternative 2 Alternative 3 Reactor Building' -5,900-21,000 9,000-30,000 5,900-21,000 300-3,500(*) and. Equipment Cleanup Reactor. Disassembly 2,600-15,000 820-6,500 2,600-14,000 2,600-15,000 and Defueling Primary-System 56-970 39-780 56-970 11-190 . Decontamination Dose Reduction 2,000-5,100 2,000-5,100 2,000-5,100 Auxiliary and 500-1,400 500-1,400 500-1,400 97-1,400 Fuel-Handling. Building Cleanup Utility and System 100-200 100-200 140-280 80-160 Maintenance Radioactive Waste 97-485 97-485 97-485 97-485 ' Management and(b) Transportation Id) 0-620 *) f 12-630(c) 140-540 Other Dose Received To -2000 2000 2000 2000 Date in Cleanup 13,000-46,000 13,000-42,000 13,000-46,000 7,200-28,000 (a).. Includes dose to robotically complete primary-system decontamination and to complete cleanup of the auxiliary and fuel-handling building. (b) ' Based on information from the PElS. (c) For recleaning of the reactor building. (d) For defueling operation prior to head lift. (e). For interim care of reactor building and auriliary and fuel-handling building for up to 20 years. 3.2

Reactor disassembly and defueling will lead to the next largest portion of the total dose. This operation is essential to the cleanup effort because it assures public safety and provides for removal of the largest quantity of radioactive material from the site. The dose reduction program is associated with approximately 10% of the total occupational dose for the current cleanup plan and Alternative 2. There is no separate dose reduction program under Alternative 1 because any dose reduction work done as part of this option would be included in reactor building and equipment cleanup. For the current plan and Alternative 2, the dose reduction program will result in lower total occupational dose for cleanup than if the program were not carried out. ine dose reduction program is part of the licensee's effort to maintain occupational radiation doses ALARA. 3.3 POTENTIAL HEALTH EFFECTS Occupational radiation exposure of the workers involved in the cleanup of TMI-2 is limited by the requirements of federal regulations 10 CFR 20. Nevertheless, even individual radiation doses less than the limit of 3 rem per quarter may have the potential for inducing health effects in the exposed workers or in their offspring. A great deal of data on the biological (health) effects of radiation has been accumulated on a worldwide basis over the past several decades. These data have been analyzed by international and national organizations responsible for radiation protection, i.e., the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR 1977), the National Academy of Sciences' Committee on the Biological Effects of Ionizing Radiations (BEIR 1980), the National Council on Radiation Protection and Measurements (NCRP 1975), and the International Commission on Radiological Protection (ICRP 1977). The findings of these organizationc, in particular the findings of the Committee on the Biological Effects of Ionizing Radiation (the BEIR Committee), are the basis for estimating radiation-related human health effects in this document. The radiation doses which a worker involved in the TMI-2 cleanup will experience in the course of that effort may result in somatic effects (effects to the body of that worker) and genetic effects (effects to the worker's yet-to-be conceived children and more remote descendents). The somatic effect typically of greatest concern is the possibility of inducing a fatal cancer; the genetic effects include a variety of inheritable changes that may result in deficiencies or health problems in future generations. Published estimates of risk factors for both somatic and genetic effects are scattered over a wide range. The staff has chosen to use the following factors: . 131 fatal cancers in the exposed workers per one million person-rem (BEIR I 1972). 220 genetic effects among the offspring of the workforce per one million person-rem (BEIR III 1980). 3.3

The work force for the TMI-2 cleanup will be exposed predominantly to penetrating radiation distributed over the whole body, so that any conse-quences will not be restricted to a particular area or organ of the body. More detailed information on the health effect risk estimators used by the staff is contained in Appendix Z of the PEIS (Volume 2). It should be stressed that these risks, or probabilities, are increments above or additions to those risks to which the entire population currently is exposed. Current public health statistics show that, for the entire U.S. population, there is a 1 in 5 probability that death will be due to some form of cancer. The normal occurrence of hereditary deficiencies and ill health in the offspring of the present U.S. population is about 1 in 9. The occupa-tional dose to the work force cleaning up TMI-2 may increase the workers' risk of death from cancer, but, as discussed below, this added risk is relatively small in comparison with the existing risk. In addition, the risk of genetic effects among the offspring of the work force may increase, but this increment is also very small compared to the natural occurrence of hereditary defi-ciencies and ill health. Potential health ef fects from occupational exposure to radiation were calculated for the work force on the basis of radiation doses ranging between 13,000 and 46,000 person-rem. For the minimum-collective-dose case (13,000 person-rem), 2 additional fatal cancers may occur. For the maximum-dose case (46,000 person-rem), 6 additional cancer fatalities may occur. These 2 to 6 cancer fatalities would be in addition to the approximately 2000 deaths from cancer that would occur naturally in a work-force of 10,000 without this occupational exposure. These 2 to 6 potential cancer fatalities would not be statistically discernable. That is, this number f alls well with-in the statistical variations of the approximate 2,000 deaths from cancer from natural cancer such that no statistically significant cases of cancer deaths among the cleanup workers would likely be attributable to radiation exposures from the cleanup. The total number of potential additional cancers, both fatal and non-fatal, from the occupational exposure would be approximately 1.5 to 2 times the number of potential fatal cancers, according to the 1980 BEIR report. Although it is possible to compute a range of probabilities for cancer induc-tion among average individual workers based on the above figures, the results of such a calculation may not bear a close relationship to actual risks since the work force size and collective dose associated with the various tasks can differ by large factors, rendering inapplicable the concept of an average individual worker. The licensee applies administrative controls for doses to its employees in order to ensure compliance with the regulations given in 10 CFR 20. These controls result in keeping most doses to less than 1 rem / quarter (see Fig-ure 1.3). Most of the workers involved in the cleanup can be expected to be in this category. The regulations of 10 CFR 20 limit the highest quarterly dose that an individual worker may received to 3 rem / quarter. Individuals are not allowed to receive exposures in excess of I rem / quarter unless there are special circumstances. For example, a compicx task that would nornally be done by a single worker might require several workers if the 1-rem / quarter 3.4

P - administrative control.were imposed. In such situations, the total exposure to the work force -' can of ten be reduced if one worker is allowed to exceed I rea/ quarter (but not the 10 CFR 20 limits)-in order to complete the task. For. an. individual worker who gets 1 res/ quarter throughout an assumed 9-year cleanup period, the total dose would be 36 rem.- For a person of age 30,.the probability of dying of cancer from normal causes is, as discussed above, about be ~ 1 in 5. - The added probability of a premature death from cancer as a result of receiving a radiation dose of 36 rem would be 1 in 210. Thus, for.the decontamination workers, the overall probability of death from cancer would be 1 in 4.9. The equivalent decrease in life expectancy from a 36-rem dose would be about 23 days. The risk for a younger worker would be greater, and for an older worker it would be less. The number of potential additional genetic effects totalled over all fu-ture generations of the offspring of the workforce is estimated to be 1 for the minimum-collective-dose case, assuming that about-one-third of the col-1ective dose is a genetically-significant dose (according to ICRP Publica-tion 26, paragraph 80, 1977, it is assumed that about one-third of the occu- - pational radiation dose is received by workers who have offspring subsequent to the radiation exposure).. For the maximum-collective-dose case, the number - would be 3. The potential number in the workers' children (i.e., the first generation of offspring) would be one-third to one-sixth of the total number of genetic effects over all generations. The normal (exclusive of occupa-tional dose) incidence of genetic disorder in 10,000 offspring would be about 1100. BEIR III indicates that the mean persistence of the two major types of genetic disorders is about 5 generations and 10 generations. In the discussion above, the staff has treated the selected risk estima-tors (131 fatal cancers, 220 genetic effects per one million person-ren) as if they were unique, accurate values. The purpose was to make the discussion understandable to the general public. Some commenters have proposed risk estimators which differ ' greatly (see Appendix A, comment letter #20 from Drs. Pisello end Piccioni and its enclosure). However, the values that the staff considers are the most reliable values are those provided by the ICRP, UNSCEAR 'and the BEIR Committee in their publications of the past dozen years, and these values fall within a relatively small range. For the range of annual individual doses reported for the TMI-2 cleanup through 1983, i.e. less than 5 rem per year, the values fall between zero and 568 fatal cancers per million person-rem for somatic effects. The staff believes that the somatic effects risk estimator may be considered with confidence to be in the range of zero to about four times the value used in this document. The staff does not consider any of the estimates to deserve representation by more than one significant figure; the use of 3 figures here only helps identify the par-ticular value and relate it to its derivation. Table 3.2 (adapted from Table 2.10 of Appendix Z of the PEIS) shows the assortment of values for the cancer fatality risk estimator published by the j BEIR Committee and by UNSCEAR since 1971. The values range from about one half that used by the staff to about four times as large. Furthermore, for collective doses consisting of exposures amounting to at most a few hundreds 3.5

I TABLE 3.2. Comparison of Fatal Cancer Risk Estimators Cancer Mortality Estimators Source (deaths /106 person-rem) 135(* NRC staff (PEIS) ) BEIR, 1980 67-169 BEIR, 1972(C) 115-568 1977(d.e) 75-175

UNSCEAR, (a) Risk estimator used for members of the public.

For workers, a risk estimator of 131 deaths / 6 10 person-rem was used. This value accounts for worker age-specific (20-70) radiosensitivity. (b) Linear-quadratic dose-response model for absolute and relative projection models. These values represent the BEIR committee's stated best estimate. However, the committee also pointed out that there are arguments that also favor the linear and pure quadratic effects models. Corresponding estimator values for the linear model are 158-403. The pure quadratic model provides estimates lower than the linear and linear-quadratic models, but values were not calculated for this case. (c) Values obtained f rom Table V-4, BEIR,1980, are an update of values obtainable in Table 3-3 and 3-4 of BEIR, 1972. Range attributable to dif-ferences between absolute and relative projection models. (d) Range of estimates for low-dose, low-LET radia-tion (UNSCEAR 1977). (e) UNSCEAR chose to not publish any revised somatic effect risk estimators in its 1982 report due to the then unresolved proposed revision of the estimates of doses received by the populations of Hiroshima and Nagasaki. 3.6

u I of millirem to an individual per year in addition to background, the BEIR Com-mittee stated that the possibility of zero is not excluded by the data. The largest estimator f rom Table 3.2, 568 fatal cancers per million person-rem, indicates 7 to 26 potential fatal cancers for 13,000 to 46,000 person-rem. The smallest, 67, indicates 1 to 3 potential fatal cancers. The values for the genetic effects risk estimators published by the BEIR Committee in their 1972 and 1980 reports, by UNSCEAR in their 1977 and 1982 reports, and a result from an ICRP Task Group, together with the estimator used by the NRC staff are all within the range of 60 to 1500 per million live-born offspring due to I rad exposure to each parent. If the largest of the estimators in BEIR, 1980, (i.e., 1100) were applied to the collective dose range of 13,000 to 46,000 person-ren and assuming one-third of the dose is genetically significant, the corresponding range of number of potential addi-tional genetic ef fects for all following generations is estimated to be 5 to

17. Use of the smallest estimator, 60, produces estimates of one or less than one.

) 1 3.7

4.0 CONCLUSION

S In this supplement to the Programmatic Environmental Impact Statement, the NRC staff has reevaluated the occupational radiation dose and the health effects associated with the proposed cleanup of Three Mile Island Unit 2. As a result of this evaluation, the staff has reached the following conclusions: All options for the TMI-2 cleanup evaluated in this supplement involve e occupational radiation doses higher than those predicted more than 3 years ago in the PEIS. The basis for these revised estimates is increased knowledge of the conditions inside the reactor building and of the effectiveness of decontamination and dose reduction efforts. The costs of'the cleanup, in terms of environmental impacts, are in the radiation exposures and potential health effects among the cleanup workers. Despite the possible increase in radiation exposures to the workers, the benefits of cleanup, especially reactor disassembly and defueling, still exceed the drawbacks. The major benefit of the cleanup will be the climination of the continuing risk of potential uncontrolled releases of radioactivity to the environment from damaged fuel or from the radioactive contamination which is distributed throughout the primary system, the reactor building, and the auxiliary and fuel-handling build-ig. It is the staff's judgment that the conclusion of the PEIS that " cleanup of the THI-2 facilities should proceed as expeditiously as reasonably possible to reduce the potential for uncontrolled releases of i radioactive materials to the environment" remains valid, at Icast through the defueling stage. . Another benefit of cleanup is the additional knowledge that would be useful for reducing the risks and consequences of possible future accidents at nuclear power plants. This earlier PEIS conclusion remains valid. While considerable information has already been obtained in the cleanup to date, much more data remains to be obtained as the focus of the cleanup is directed towards reactor disassembly and defueling. The information to be obtained increases the understanding of fission product behavior resulting from severe accidents, the metal-water reaction and St a corresponding generation of hydrogen, the management of very highly contaminated liquid and solid radioactive waste, the management of gaseous radioactive waste, decontamination methodology and techniques, radiological and physical protection of workers in highly contaminated areas, and radiation and environmental effects on materials and equip-ment. This information could be applied to current and planned nuclear power facilities in a variety of areas including plant and equipment layout and design, accident mitigation system design, instrument location and design, radioactive waste processing system design, surface coatings for contamination control and mitigation of fission product releases from severe accidencs. The only means identified in this supplement for substantially reducing the occupational dose is the extensive use of robotic technology. Under any cleanup plan that makes use of this technology, the feasibility of 4.1

~ ~ - - -, ~- -- l l

completing the cleanup will' depend on developments in robotics, which are uncertain-at ' this - time.

Because the highest dose is - associated with reactor building and equipment cleanup, adoptation of this approach can .be reconsidered-following defueling or when there are sufficient sdevelopments in robotic' technology, ~ Decontamination workers-at - the - plant will receive ~ total collective a e radiation--dose. estimated at between 13,000 and 46,000 person-rem for the whole ' cleanup program.. -These ranges are broad because of uncertainties

• about the plant ' conditions and about the amount of work that will be needed to decontaminate the reactor building and its contents.

Doses -to individual. workers are limited by the health-and safety stan- = dards in federa1 ' regulations.. The -licensee has agreed to set adminis- -trative controls that are' lower'than the limits in federal regulations to make sure that exposures of individual workers will be below the federal limits. Estimates of potential health effects due to - exposure of the workforce - have ' been made assuming that individual worker exposures are s within regulatory limits. In the analysis in this report, it has been conservatively assumed that any exposure to radiation has a finite prob-ability of causing : cancer in the exposed workforce, and a finita-prob-ability of causing' genetic abnormalities in the offspring of the exposed workforce.: Using the preceding range of collective dose estimates (i.e., 13,000. to 46,000 person-res), the staff estimates-that about 2 to 6 potential pernature ' cancer-deaths may occur in the total exposed work-force, during 7 the remaining lifetime of the workers. In addition, a ' total of about ' 1 to 3 potential additional genetic disorders may occur over all future generations of. offspring of the exposed workforce. The staff has used a central value for health risk estimators in estimating these health effects. In addition to uncertainties in collective dose estimates, there are also uncertainties in the data base used to estimate health effects. Using the most widely accepted range of health risk estimators,-the staff estimates that the range of potential cancer deaths extends from 0 to as high as 26 for the highest ' workforce-exposure estimate. In a similar manner, the range of potential genetic disorders extends from less than 1 for the lowest workforce exposure estimate'to 17 for the highest ~ workforce exposure estimate. It is important to note that these potential cancer deaths and potential genetic effects, if they occur, would be adeed to the expected 2,000 cancer deaths among the workforce and-5,000 genetic effects in the first five generations of the workers from natural phenomena, assuming a workforce of 10,000. These potential cancer deaths and potential genetic ef fects, if they were to occur, would not be. statistically discernable. That is, the number of health effects falls well within the statistical varitions of the expected cases of cancer fatalities and genetic effects among the cleanup workers and their offspring from causes unrelated to radiation exposures ~during the' cleanup. The occupational radiation dose to an individual worker will be limited to less than 3 rea/ quarter in accordance with 10 CFR 20. Based on current experience and the licensee's more stringent limits, most workers will receive radiation doses substantially below that limit. 4.2

i 1 i e' The most dose-intensive task is reactor building and equipment cleanup. unless this task is done using robotic technology. An early decision to use robotics is not necessary as long as the licensee defuels the reactor ' before reactor building cleanup. The current plan provides the most likely path for early fuel removal. Extensive building cleanup before defueling, or - the modification of defueling methods, would cause substantial, unwarranted delays in fuel-removal, with attendant risks.

• The dose : reduction program has substantial potential for lowering the total radiation dose to workers during the cleanup. ALARA considerations dictate. that a 'significant commitment of funds and managerial emphasis should continue to be placed on this effort.

Reactor building cleanup concurrent with defueling can also be expected to reduce the occupational dose by removing sources of radiation exposure 'from the work place. Other conclusions 'of the PE'S that do not pertain to occupational radiation dose remain valid. The staff concludes that the cleanup should proceed as expeditiously as possible while ensuring the health and safety of the workers and the public. All work' performed as part of the cleanup should be ' done in a manner that keeps occupational doses as low as is reasonably [ -achievable. i 4.3

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1983. An-Assessment of Chemical Processes for the Postaccident Decontamination of Reactor Coolant Systems. NP-2866. Electric Power Research Institute, Palo Alto, California. National Academy of Sciences, Advisory Committee on the Biological Effects of . Ionizing Radiation (BEIR). 1972.- The-Effects on Populations of Exposure to Low Levels of Ionizing Radiation. National Research Council, Washington, D.C. National Academy of Sciences. Advisory Committee on the Biological Effects of lonizing Radiation (BEIR). 1980. The Effects on Populations of Exposure to . Low Levels of Ionizing Radiation. National Research Council, Washington, D.C. National Council on Radiation Protection and Measurements (NCRP). 1975. Review of the Current State of Radiation Protection Philosophy. NCRP Report No. 43, Washington, D.C. National Council on Radiation Protection and Measurements (NCRP). 1980. Influence of Dose and Its Distribution in Time on Dose-Response Relations for Low-LET Radiations. NCRP Report No. 64, Washington, D.C. Runion, T. C. _ 1983. Proposed Methods for Defueling the TMI-2 Reactor Core. Report from Debris Defueling Working Group to GPU Nuclear. Sejvar, : J., and P. H. Dawson. 1982. Evaluation of Abrasive Grit--High-Pressure-Water Decontamination. EPRI NP-2691, Electric Power Research Institute, Palo Alto, California. United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR). 1977. Sources and Effects of Ionizing Radiation. Report to the U.N. General Assembly, New York. United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR). 1982. Ionizing ' Radiation: Source and Biological Effects. Report to the U.N. General Assembly, New York. U.S. Atomic' Energy Commission. 1972.. Final Environmental Statement Related to Operation of Three Mile Island Nuclear Station Units 1 and 2. AEC Docket Nos. 50-289 and 50-320. U.S. Nuclear Regulatory Commission. 1978. Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable. Regulatory Guide 8.8, NRC Office of Standards Development, Washington, D.C. 5.2 n

U.S. Nuclear Regulatory Commission. 1981. Final Programmatic Environmental Impact - Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979, Accident Three Mile Island Nuclesr Station, Unit 2. NUREG-0683, Vol.1. Washington, D.C. 1 4 L .a G 4 4 1 3 5.3 5%

+ ] i6.0 DISCUSSION OF COMMENTS ON THE DRAFT SUPPLEMENT Pursuant to.10 CFR Part 51, the' Programmatic Environmental Impact State-ment.(PEIS) related to the decontamination and disposal of radioactive wastes as a.- result ' of ' the r March 28..1979, ' accident at - Three Mile Island Nuclear Station,, Unit 2. Draf t ' Supplement 1, was transmitted in January 1984 with -a request for comments to the following federal, state, and local government Lagencies: U.S. Army Corps of Engineers'- i - U.S.~ Environmental Protection Agency '/.S. Department of. Energy U.S. Department of Health and Human Services U.S. Department of Labor U.S. Department of Interior-U.S. Department.of Interior Geological Survey ~ U.S. Department of Transportation U.S. Nuclear Regulatory Commission, Advisory Panel on TMI Cleanup L Maryland Department of Natural Resources -Maryland Department of State Planning New Jersey Department of Environmental Protection Pennsylvania Department of Environmental Resources Pennsylvania Department.of Health l Pennsylvania Department of Labor and Industry - Pennsylvania Department of Public Welfare Pennsylvania' State Clearing House. e In-addition, a notice requesting comments from interested members of. the - public was published in the Federal ' Register on > January 5, 1984, and about 300 copies were subsequently distributed. to-individuals and organizations at _their request. The staff had two formal meetings with interested members of l .the public to discuss the draft supplement and to receive comments. Those two i meetings took place in Middletown. - Pennsylvania on Feburary 15, 1984 and l.? before the Comunission's Advisory Panel' on TMI-2 Cleanup on April 12, 1984. The comments received from letters to the staff and from transcripts of the l_ two formal'public meetings are reproduced in Appendix A of this final supple-l ment.'which is reserved solely for them. The' staff's consideration of the comments received and its disposition of l' the issues involved are reflected la part by revisions in the pertinent '~ sections of this PEIS and in part by the following ' discussions. Where data corrections suggested in the' comments have been adopted by the staff, these L changes have usually been made without discussion here. The organization of l this section corresporids generally to the ordering of the chapters of the supplement; however, the discussions of comments on similar topics are grouped together. The comment letters to which these discussions apply are referenced by the numbers following the title of each response; these numbers are keyed to the Table of Contents in Appendix A. 6.1 -. --a--

6.'1, PURPOSE AND SCOPE OF THE SUPPLEMENT I 6.1.1 L' History of Occupational Radiation Doses and Update of Doses to Date (23, 33, 35) To the extent possible, the staff has grouped past doses and estimates of future doses tinto - general categories that facilitate the understanding of . cleanup activities. It is not the intent of this' supplement to take the place of the. detailed task-by-task record keeping required of the licensee, nor to - establish occupational radiation ' exposure goals for.various phases of the 6 cleanup operation.. Such activities are best u done by the. licensee with NRC surveillance and by the NRC regulatory staf f onsite, who have available the. most current information. ' 6.1.2 The Financina of Cleanup (3, 35) The question of the financing of the cleanup is important; however, it is largely - outside of the scope of this supplement, except for the. proviso that . + the supplement. assumes more-or-less-continuous cleanup progress.- .Past delays in processing the water and in re-entering the reactor build-ing are thought to have contributed.to the radiation dose, but those delays were not directly funding related. Any future contamination of concrete, 4 rusting of metal etc. because of -delays -are not Jexpected to affect doses appreciably as long as cleanup is progressing continuously. The dose that ,might be. incurred in correcting -the effects of deterioration over an interim ^ storage period of tens of years has not been evaluated. i - 6.1.3 GPU Conduct of the Cleanup Operations (14, 28, 32) i The ability of GPU Nuclear and their subcontractors to safely conduct the cleanup operations is ' under continuous scrutiny by both the NRC staff and, ' because of the importance of the TMI-2 cleanup, the NRC commissioners. y On September 29, 1980, the NRC issued a Statement of Policy with regard to the' requirement of the licensee to proceed with. the cleanup. It states that "The Commission will~ not excuse Met Ed f rom compliance with any order, regulation or other requirement imposed by this Commission for purposes of - protecting public health and safety or the environment." Although the license has been transferred to GPU Nuclear, the successor to Met Ed. as licensee, the commission 1 policy still applies. Should the licensee fail to meet its obligation, the NRC has, under. existing laws, the authority to act: to ? - ensure that the cleanup proceeds in a timely manner. 6.1.4 Restart of Unit 1 and Uparade of the Water Polisher at Unit I (13, 16, 28) Issues concerning the restart of.THI-1 are not addressed in this supple-1 ment. The' staff considers the restart of THI-1, if authorized, to be wholly independent of.the TMI-2 decontamination process. i j 6.2 i U 4 ,-m,-www,-va-newe-r+~ez,

6.1.5 Use of Hollow Concrete Blocks and Unpainted Concrete (14) When TMI was being built, an accident such as the one that took place was considered to have a low probability of occurring. Postaccident safety and environmental considerations were concentrated on mitigating the offsite consequences of an accident by methods such as terminating the accident and containing releases to the environment. The use of hollow concrete blocks and unpainted concrete has been found since the accident to contribute to the difficulties of decontamination and will result in a higher occupational dose for cleanup. In hindsight, the use of different materials would have reduced the radiation dose for cleanup and promoted the ALARA principle. 6.1.6 The Pace of Cleanup Activities (8) The NRC remains committed to the prompt cleanup of the TMI-2 reactor. The staff is constantly monitoring cleanup progress to ensure that public health and safety are safeguarded. 6.2 CURRENT AND ALTERNATIVE PLANS FOR CLEANUP OF REACTOR AND AUXILIARY BUILDINGS 6.2.1 Background Information on Cleanup Work (8, 35) Although more is being learned about the reactor building and the sources of dose, there are still significant unknowns regarding the occupational dose to complete the cleanup. These relate to the condition of the plenum and reactor internals, the effort that will be required to remove fuci and to deco taminate or remove equipment, and t"e work that will be needed at the reactor building's 282-ft elevation. The high estimate was formulated taking a very pessimistic view of these tasks, to cover all contingencies. The low estimate was formulated taking a,much more optimistic view of the effort and the initial success that it would bring in lowering dose rates. The dose estimates cover all the work to be done, independent of who performs it. 6.2.2 Cleanup Progress and Doses to Date 6.2.2.1 Update of Data (33) Several of the licensee's comments were designed to update the supplement to December 31, 1983. However, because the comment period was cxtended several times due to unforeseen circumstances, the December 31 cutoff date appeared inappropriate, and a date of May 11, 1984, was adopted as the cutoff date for incorporating data into the final supplement. The polar crane has been decontaminated by water spraying and hand wiping. The 347-ft elevation has been decontaminated by water spraying, and the floor surfaces were subsequently coated with a strippable coating that would protect the area from recontamination. Some concrete spalling is planned for this area in the near future. The 305-ft elevation has received less decontamination effort, although some work has been done. Decontamina-tion of this area is not considered an immediate priority because it will be a low-occupancy area during defueling. l 6.3 e -..i

4 The control rod drive mechanism lead screws that were removed were removed at a dose between 3 and 5 person-rem each. This would be. a maximum value for future lead screws because they can be handled by-crane now that the missile shields have been moved. However, present plans are to shield the lead screws and leave them in the head to avoid this dose. -6.2.2.2 Criticality (35) Criticality is the. name given to the nuclear chain reaction that is used - - to generate power in operating reactors. It occurs when neutrons from fis-4 ( sionable isotopes (either uranium-235 or plutonium-239) are produced in suf-- ficient quantity to ' promote additional fissions, which then release more = neutrons, creating a self-sustaining chain. reaction.. Criticality, in addition to! generating neutrons, generates. heat and a' variety of radioactive materials, many of which decay with a very short half-life. There has not been a criticality in the THI-2 core since the reactor was -shut down at the very beginning of the accident. The risk of a recriticality occurring now is extremely small but is not zero. Criticality is relatively difficult to achieve because many materials that are present in the reactor core (fission products, boron in the reactor coolant, and control rod mate- . rials) absorb neutrons and thereby tend to prevent a chain reaction.. However, a chain'of events involving the dilution of the boron and the physical segre-gation of fuel'and. control rod debris could conceivably result in criticality. -A criticality in the core at the present time would be dangerous for-workers in the building. and could seriously hamper. cleanup beyond that anticipated in the. draft supplement. There could be1some release, but this would be fairly small because the reactor building was designed to contain.such'a release. There is a vanishingly small probability of criticality in the near term, but even that low probability coupled with the hazard of extremely long-lived transuranic isotopes leads the staff to reject, as untenable, reactor disposi- _ tion schemes that would fix the core in place for tens, hundreds, or thousands i: l .of. years. t .612.2.3 Other Estimates (29)

,e.

Shortly after.the publication of the draft supplement, GPU, in a. notice - l to: workers, published.a chronology of their 'past, estimates of the dose to perfona - cleanup. 'Those ' early estimates were GPU's L inte rnal estimates for -planning purposes and had no effect-on the NRC's estimate of dose to perform ~ cleanup or the NRC's ' decision to prepare a supplement to the PEIS.- The current GPU estimates did influence the NRC. in the decision to prepare r. supplement. 6.2.3 Other Alternatives .r c ,w, .6.2.3.1 Permanent Fixation of Fuel In Place (5, 11, 34, 35) In the opinion of the NRC staff there is currently no technology for the safe, permanent fixation of the TMI-2 fuel in place. The question of the need to. remove. the fuel has been dealt with several times, including. in the m 6.4 i ~ \\ cu

original PEIS. The unacceptability of in-place fixation is not. ma terially altered by the revised occupational dose estimates. 6.2.3.2 Permanent Entombment of the Reactor Building Following Fuel Removal (14, 35) Following fuel' removal, the major source of threat to public health and safety will have been eliminated. Radiation level in the reactor building, especially in.the basement level, will remain high. This alternative suggests that current waste immobilization technology might conceivably be ' adapted to permanently entomb the remaining contamination (mainly 137 Cs with half-life of about 30 years) at the Three Mile Island site. However, under the proposed decommissioning rules currently being prepared by NRC, entombment of a facility would only be allowable if the residual radioactivity-will have decayed to a level permitting unrestricted use of the property within a period of approximately 100 years. Therefore, the ENTOMB option is not an acceptable decommissioning alternative for TMI-2, because the long-lived radionuclides resulting from the accident will still be a significant radiation source for much longer than 100 years, the time period assumed for the assured contin-uance of necessary institutional controls. The staff, therefore, does not consider this to be a viable alternative. 6.2.3.3 Alternatives of Curtailing Cleanup Efforts Following Fuel Removal and Cross Decontamination of Reactor Building and the Reactor Coolant System (31) In the response to the previous comment, we have said that an alternative that would result in the permanent entombment of radioactive wastes on the site is not acceptable.. However, there are other alternatives which do not involve the immediate completion of the cleanup of the reactor building and equipment. af ter fuel removal that merit consideration. Examples of these alternatives are:

1) the ~ alternative involving completion of cleanup robo-tically af ter an interim storage period during which the licensee actively developes the-necessary technology; 2) to place the facility into a monitored storage phase until substantial decay of the contamination has taken place.

Both of these alteratives have the advantage of significantly reducing radi-ation exposures to the cleanup workers. However, these alternatives would .also require the interim storage of the facility in its contaminated condi-tion.- The staff will evaluate the environmental consequences of the alterna-tives of curtailing cleanup efforts following fuel removal. This evaluation will be completed prior to any decision on the licensee's proposed plan of activities following fuel removal. Because the defueling and supporting cleanup activities would be much the same, an early decision on. the alterna-tives of curtailing cleanup efforts following defueling at this time is not necessary. 6.2.3.4 Decommissioning (35) Even if the decision were already made to decommission the reactor, the next step would be the removal of the fuel, and it would be done in virtually - the ' same way as it will be done under the current cleanup plan. For this reason,. an early decision to decommission is not necessary at the present 6.5

time. Likewise, the initial steps in reactor building cleanup would be the same whether the plan is to refurbish or to decommission. Thus, a decision on decomissioning is not necessary before the irradiated fuel has been removed from TMI-2, 6.2.4 Realism of Alternative 3 (13, 33, 35) Alternative 3 (defueling following by delayed dismantling) may or may not be. a real possibility. Twenty-five years ago, predictions regarding the inexpensive computers available today were not considered realistic by many people, and technology appears to be advancing faster now than it was then. We do not know whether the robots necessary to perform Alternative 3 will be available; however, it is not necessary or desirable to determine at the present time whether Alternative 3 should be pursued. The NRC elans to study Alternative 3, along with other options prior to allowing the licensee to proceed with a significant couanitment of occupational dose for building cleanup following the defueling operations. 6.2.5 Dose Estimates for Current Cleanup Plan (8) The scenarios given in the draft supplement were developed to include the full range of postulated reactor and building conditions. In determining the value of the low-range dose estimates, a reasonably optimistic view was taken regarding reactor building conditions and decontamination success. There is, l however, a possibility that individual tasks or subtasks might require less dose than anticipated. To arrive at the upper-range estimates, an exceedingly pessimistic view was used in assessing the work to be done, the dose rates involved, and the decontamination and shielding success likely to be achieved. It was, however, assumed that there would be more-or-less-continuous cleanup progress and that doses would be kept ALARA. There is, even in the high dose estimates, a possibility that a particular task or subtask might exceed the estimate given, particularly because the doses attributed to individual tasks are affected by bookkeeping practices; for example, the dose to clean the transfer canal following defueling might logically be considered part of the dose to clean the reactor building, the dose associated with defueling, or the dose required to prepare the primary system for decontamination. The NRC believes, however, that the dose for the entire cleanup will fall in the range given, barring unforeseen improvements such as the extensive use of robotics, or unforeseen difficulties such as criticality during cleanup. 6.2.6 The Term "Defueling" (8) Defueling means the removal of fuel. It will be the next major step in the cleanup of TMI-2. The use of the term is in no way intended to be euphemistic or to imply that the process at TMI-2 will in any way resemble a normal refueling at an undamaged reactor. 6.6

6.2.7 End Point of Cleanup (35) The stated end point of cleanup is to reduce the dose rates to a level that would be typical of operating plants. The figure of 10 mrem /hr has been used as typical. However, it may not be beneficial to expend sufficient worker dose to reduce dose rates to that level. Before the end of cleanup, the final disposition of the facility will have been decided upon, and the end point can be evaluated in the light of that information. If incurring worker doses to.2ake the building cleaner le not cost beneficial, then the NRC, with appropriate environmental review, would consider alternative end points based on risk-benefit analysis and the state of technology at that time. Because the defueling and cleanup activities planned for the next few years would be much the same regardless of the final dose rate, an early decision on this point is not required. 6.3 ENVIRONMENTAL EFFECTS 6.3.1 Number of Workers Involved in Cleanup (35) The precise number of workers that will be involved in cleanup is not known. If cleanup ends up requiring only the 13,000 person-rem envisioned in the low estimate and if each worker averaged 4 rem /yr, 3250 person-years would be required. For the high estimate of 46,000 person-rem, 11,500 person-years would be required. Realistically, a large number of workers who are involved in cleanup and receive some dose receive much less than 4 rem /yr, so the actual number of worker years will be greater than the values given above. (These " low-dose" workers are usually involved in preparing procedures, train-ing workers, processing waste, etc.) The total number of workers will also be a function of the turnover rate of personnel on the job. Some workers will leave for other jobs, some will retire, and others will be contractor employees who are brought onsite as temporary workers to do a specific job (concrete coring, chemical decon-tamination, etc.). The estimate of 10,000 workers given in the supplement is as good a value as is currently available, but it may be off by a large percentage in either direction. The number of health effects estimated is independent or the number of workers assumed. 6.3.2 Information to the Workers (35) All licensees of the NRC are required to train their workers in the adverse effects of radiation and in the principles and practices of radiation protection. The risk information to be included in this training is described in Regulatory Guide 8.29, " Instructions concerning the Risks from Occupational Radiation Exposure." The NRC has met with representatives of the bargaining unit employees at TMI on two occasions. The licensee has likewise held two open meetings for workers and their families. In addition, workers with complaints are free to contact the NRC at any time and are protected from adverse actions by the licensee. 6.7 1

6.3.3 Distinction Between Worker Dose and Public Dose (14) Although the NRC is fully aware that radiation workers are also part of the. general public, radiation protection regulations have historically made a distinction between those who are exposed to radiation of their own volition and those who are not. (A parallel situation exists in the occupational exposure limits for workers under OSHA regulat. ions and the environmental release limits permitted by the EPA.) Radiation limits are different for . workers because radiation workers are trained in the principles of radiation protection and are closely monitored to ensure that the regulatory limits are not exceeded. 6.3.4 How Health Effect Estimates Can Be Made When the Mechanism of Cancer Induction Is Unknown (27) The staff has provided in Section 3.3 conservative estimates of the number of cancer fatalities that may occur due to the occupational radiation exposures during the cleanup. A range of estimates is also provided. For more detailed information on the bases for these estimates, see the referenced reports by the major radiation protection organizations, e.g., BEIR 1980 Chapter II. 6.3.5 Synergistic Effects of Radiation and Decontamination Chemicals (27) i With a few exceptions (e.g. uranium miners who smoked), there is no reliable evidence for synergistic effects (see UNSCEAR 1982, Appendix L). Present estimates do not include the " synergistic effect of chemicals" except for the fact that they do take into account the best available data on radiation workers, and these workers were, in the main, also exposed to a variety of industrial chemicals, in some cases probably to a greater extent than the TMI-2 cleanup workers. 6.3.6 " Natural" Radiation (27) Webster's New Work Dictionary of the American Language, Second College Edition (William Collins +World Publishing Co., Inc. 1976) defines " natural" as "1. of or arising from nature; in accordance with what is found or expected in nature. 2. produced or existing in nature; not artificial or manufactured...." By either of these two definitions, there is most defi-nicely " natural radiation." The amount of radiation issuing from the earth's crust is diminishing, and has been since the beginning of time, although the rate of decrease is so small that it is hardly discernable during human lifetimes. The amcunt we receive from space is, as far as we know, not varying according to any trend other than the sunspot cycle. The level of the natural background radiation varies widely over differ-ent locations, with no apparent health effects to the indigenous populations. For instance, in some areas of India where people have lived for thousands of years, each individual receives about 1000 mrem /yr. This radiation is 100% natural and is in addition to the approximately 1 mrem /yr received from man-made sources. It' results in no apparent adverse health effecta or increased 6.8

incidences.of: cancer. However, it is very difficult to study this population relative to a suitable control population because of differences in culture, diet,' exposure to disease, etc. 6.3.7 Give the Full Range of Health Effects (20, 31) n The text of Section 3.3 has been revised to show the range of health effects more clearly. Drs. Pisello and Piccioni enclosed with their comment letter (Appendix A, letter. #20) a table listing a wider range of fatal cancer risk estimators. However, as stated in response to comment 6.3.25, the NRC has based ~ its risk estimates on reports prepared by the major radiation protection agencies. hi. 6.3.8-What Type of Genetic Damage Might Occur? (35) I The staff's genetic effects risk estiastes include. only those effects ' which would have a significant health impact sometime during the person's lifetime'. Irradiation has been found to cause in animals the same types of genetic ill health and deficiencies found in the populations not exposed to additional' irradiation. In humans, these may include such effects as short-limbed dwarfism, muscular dystrophy, sickle cell anemia, cystic fibrosis, hemophilia, and color blindness. Gross deformities are quite rare because such severe. genetic abnormalities are commonly eliminated by miscarriages and similar-processes. 6.3.9 Do Other Occupations Involve a Genetic Risk? (35) Exposure to certain chemicals is known to cause genetic effects. -6.3.10 The Effect on the Aging Process Must Alsc be Considered (27) No effect of irradiation at permitted occupational levels on the aging process in people has been firmly established, other than the apparent aging. l resulting from the effects of cancer.- The 1980 BEIR report says, "There is no firm evidence that exposure to ionizing radiation causes premature aging in man or that the associated increased incidence of carcinogenesis is'due'to a general acceleration of aging." Similar views are given in ICRP Publica-tion 26 and the 1977 UNSCEAR report. 6.3.11 Projected Health Effects Should be Compared With the Natural Incidence (18) Comparisons of this type have been revised and expanded for clarity. 6.3.12 Use First Generation Risk Estimators to Calculate Genetic Effects on Progeny (33) BEIR 1980,- in its concluding discussion to its chapter on genetic - effects, - shows the two methods they used to provide roughly equivalent estimates for both first generation and equilibrium effects. Nowhere do they suggest that only first generation estimates should be used and subsequent generations ignored. 6.9

'f l "rw = 1-r, 6.3.13 The NRC Staff Should Recognize That Occupational Exposure Levels in the Range of Natural Background Radiation are Considered to Represent Negligible Risks to Individual Workers (19, 33) The text has been revised to indicate that such risks may be small. 6.3.14 A Linear Model is/Is Not Overly Conservative (7, 19, 20, 29, 33) The revised text explains that the risk estimator used was selected primarily because it suitably represents the range of estimators published by authoritative organizations in the field; it was not selected primarily for its linearity, or lack thereof. 6.3.15 The Risk Estimates Based on the Linear Model Assume No Repair of Injury in the Human Body (19, 33) The 1980 BEIR report says " Reductions in dose rate may decrease the observed radiation effect per unit dose, particularly for large doses of low-LET radiation, but not for doses in the linear portion of the linear-quadratic dose response model." The TMI-2 cleanup occupational exposures are not such large doses that repair of injury plays a significant role. The risk estimators of Table 3.2 were developed for low-dose, low-dose-rate, low-LET irradiation, and thus are applicable to the TMI-2 cleanup circumstances. 6.3.16 The Potential Cancer Deaths Should be Stated as a Range from Zero to Some Number (7,19, 33) Revisions to the text indicate that zero effects are a possibility. 6.3.17 Will the Health Effects of Workers (or Specific Groups of Workers Such as pregnant Women) Be Studied? (35) Such studies might be performed if it appears that there will be enough data to produce meaningful results. However, a study performed for the NRC, "The Feasibility of Epidemiologic Investigations of the Health Effects of Low-Level Ionizing Radiation," NUREG/CR-1728 (November 1980) indicates that it is unlikely that there would be enough data. 6.3.18 The Risks of Health Effects From the TMI-2 Cleanup Occupational Radiation Exposures Should be Compared with Other Risks (18, 19, 35) In the commercial nuclear electric generating industry, with an industry-wide average annual individual radiation dose of about 0.8 rem to the whole body, the average risk to the worker (including both the radiation-related risk and the non-radiation related risk) is about equal to the occupational risk in the other public utilities and in transportation, and is less than the area of risk in the area of agriculture, forestry and fisheries and in the contract construction. The occupational radiation exposures in the TMI-2 cleanup are expected to remain comparable to others in the commercial nuclear electric generating industry. 6.10

E 6.3.19 Public Safety Must be Considered as Well as the Safety of the Workers (14, 35) l A primary objective of the defueling and cleanup of TMI-2 is to assure the public safety. The potential for accidental releases of radioactive j materials has been evaluated in the PEIS for the cleanup. l 6.3.20 Would an Exposure to 3 rems in a Relatively Short Period of Time Increase the Chances of Cancer? (35) A dose of 3 rems of low-LET (e.g. gamma) radiation is sufficiently small that the risk estimators given in Tables 3.2 and 3.3 are applicable even if the exposure occurred in a very short time. 6.3.21 "No Worker May Average More Than 5 rem per Year for Each Year Past age 18." Five rem seems high. (35) The limits of 5 rem per year and 3 rem per quarter together with the ALARA requirement, have been effective in keeping occupational exposures at l low levels for the vast majority of workers. Thus there does not appear to be l e basis for reducing these limits. 6.3.22 Risk Estimates Should be Made Giving Credence to the Works of Those Who Propose Significantly Larger Risk Estimators (1, 5, 8, 29, 34) The staff has chosen to base its risk estimators on those proposed by the major radiation protection organizations such as the UNSCEAR, the ICRP, the NCRP, and the BEIR Committee. These organizations, in preparing their recommended estimators, review and give due consideration to hundreds of related scientific. papers, including the works of those who propose eignificantly larger risk estimators. 6.3.23 Use More Recent Information on Health Effects of Irradiation (29, 34) Appendix Z of the PEIS shows that information as authoritative and recent as the 1980 report of the BEIR Committee was indeed considered. Section 3.3 has been revised to show more clearly why risk estimators derived from the 1972 BEIR report were considered suitable. Information from the 1982 UNSCEAR report serves to further. support this judgment. 6.3.24 The Uncertainties in the Risk Estimates Should be Prominently Presented (31) Additional information on the uncertainties has been included in the text. 6.3.25 Both the Range in Potential Cancer Incidence (Morbidity) and Fatalities (Mortality) Should be Reported (31, 35) Information on the potential cancer incidence has been added to the revised text. j 6.11

U 6.3.26 The Range of Consequences Due to the Occupational Doses Projected In the Draft Supplement are Greater Than Indicated Therein (29, 35) The text has been revised to show the potential range of consequences indicated by the differences in authoritative estimators. 6.4.

GENERAL COMMENT

S 4 6.4.1 "Why Haven' t Public Conunents Been Used?" (16) One of the.NRC's main purposes in issuing the PEIS and.the supplement is to allow public review of and comment on the environmental issues of cleanup. Public comments are taken into consideration when the staff evaluates the licensee's proposed actions and when the commission makes policy decisions. ' Comments that are beneficial have resulted in specific staff actions. For example, comments from representatives of the bargaining unit have resulted in reviews of the communications channel by which workers can suggest improve-ments in cleanup actions. The modifications in communications channels that resulted from the staff review will ultimately be beneficial in keeping exposures ALARA. 6.5 WASTE MANAGEMENT (35) The Department of _ Energy has agreed to take accident-generated waste that it can use for research purposes, at no cost to the utility, and to accept.other accident-generated waste for which the utility will reimburse DOE for the handling and disposal costs. Because of this arrangement, the inter-state. compacts for the handling of waste will probably affect TMI less than they will other reactors. (35) The dose to those who will perform research on or otherwise handle the waste from TMI is not discussed because it is covered in the environmental - and occupational exposure evaluations of the facilities where the waste will be dealt with. (Exposures at these facilities are also required to be as low as is. reasonably achievable considering the state of technology and the economics of the situation.) (35) The transportation of the reactor vessel, steam generators, and other components that would need to be disposed of if the reactor were decommissioned is not addressed because this topic goes beyond the scope of cleanup. If decommissioning were proposed, the evaluation of the waste transportation and disposal would be reviewed at that time. (35) The Three Mile Island site has never been evaluated as a permanent repository for radioactive waste because there has never been an intent to make it one. At the time TMI-2 was granted a construction permit, it was understood that all radioactive materials would ultimately be removed from the site.. Although the complexity of moving those materials has changed since then, this understanding has not been altered. 6.12

APPENDIX A COMMENTS ON THE DRAFT SUPPLEMENT TO THE PROGRAMMATIC ENVIRONICNTAL IMPACT STATEMENT 1 l l l l l l l

APPENDIX A . COMMENTS ON THE DRAFT SUPPLEMENT TO THE PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT L This table 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 and the page numbers of this appendix where the first page.of each. letter appears. The letter numbers are ~ used -in. Chapter 6 (Discussion of Comments on the Draft Supplement) in responding to the comments. TABLE OF CONTENTS Latter No. Page U.S. Department of Interior, Environmental Project 25 A.44 Review, Bruce Blanchard, Director

U.S. Environmental Protection Agency. 0ffice of 29 A.48 Federal Activities, Allan-Hirsch, Director l

U.S. Nuclear Regulatory Commission, Advisory 26 A.45 Committee on Reactor Safeguards, Jesse C. Ebersole, Chairman U.S. Nuclear-Regulatory Commission, Advisory Panel 31 A.54 for the Decontamination of TMI-2, Arthur E. Morris, Chairman Maryland Department of Natural Resources, 22 A.33 Thomas E. Magette, Administrator Maryland Department of State Planning, 6 A.8 Maryland State Clearninghouse for 21 A.31 Intergovernmental Assistance, Guy W. Hager, Director Regional Planning Council, Department of 23 A.34 State Planning, W. Wilson Horst, Coordinator, Metropolitan Clearninghouse Tri-County Regional Planning Commission, James R. 13 A.19 Zeiters, Executive Director ' Accord Research and Educational Associates, Inc., 20 A.29 Daniel Pisello, Ph.D. and Richard Piccioni, Ph.D. 'Bechtel National, Inc., Oak Ridge Office, 24 A.42 Valmore F. Bouchard Biomedical Metatechnology, Inc., Irwin D. Bross, 5 A.6 Ph.D., President 34 A.62 CPU (B. K. Kanga, Director, TMI-2) 33 A.56 A.1

TABLE OF CONTENTS Letter No. Page s i - Institute for Energy Analysis, Oak Ridge' 7 A.8 . Associated. Universities, Alvin M. Weinberg, Director. International-Brotherhood of Electrical Workers, 2 A.4 Local #143, Glenn A. Schaeffer, Business Manager, Local Union No. 143 New York Federation for Safe Energy, A. E. 27 A.46 Wasserbach,_ Chairman-Safety Advisory Board, James C. Fletcher, 19 A.26 Chairman Technical Assistance and Ad'visory Group, William H. 18 A.25-Hamilton, Chairman Peter Alexander and family 4 A.6 Louis M.' Busch 14 A.20 R. M. Currier 32 A.55 Charles and Genevieve B. Emerick, Sr. 15 A.21 Eric J. Epstein 3 A.5 Viola Fisher 11 A.17 Henry H. Grimm 12 A.18 ~* Alice A. Herman 16 A.22 Helen M. Hocker 17 A.23 . Donald E. Hossier. 28 A.47 M. 1. Lewis 30 A.50 Bruce Molholt 1 A.3 Bruce Molholt 8 A.9 Catherine I. Riley, Senator State of Maryland 9 A.15 Henry N. Wagner, M.D., Director Division of 10 A.16-Nuclear Medicine and Radiation Health Sciences, The Johns Hopkins Medical . Institutions Comments received at. the February 15, 1984 35(*) A.63 Public Meeting on the Draf t Supplement in Middletown, Pennsylvania Comments received at the April 12, 1984 36(") A.79 Public Meeting of the TMI Advisory Panel in Harrisburg, Pennsylvania (a) Excerpts from transcripts of public meeting. A.2

s - h, j BRYN MAWR COtt.ECE Snyder sRiN M AWR. rEN!%54V ANIA tocid g ygg g g otraarunt or snxocs 100 - 350 additional birth defects in worker's children. In 'MQ"N 6 January 1984 the face of uncertainty among the scientific community re-garding radiation risk assessment, I feel it is prudent to M r. Bernard Snyder err on the side of caution. TMI Program Office Office of Nuclear Reactor Regulations An additional caveat must be expressed concerning U. S. Nuclear Regulatory Commission worker safety during the TMI-2 cleanup operation. This past Wa shington, D. C. 20,555 year it has become evident that CPU Nuclear Corporation has economized the cleanup operation by sacrificing certain worker h Worker risk during TMI-2 cleanup safety precautions to which they had acceded earlier. Hence, in addition to higher radiation levels than earlier appreciated Dear Mr. Snyder - trithin the TMI-2 containment facility, workers are being sub-jected to higher radiation exposures than they might had CPU ! have just read the account of your news conference adhered to their original plan. yesterday concerning worker risk at TMI-2 in.which it was an-nounced that estimates of total worker exposure during the clean-A gain, please send me any published information up operation have been increased from 2,000 - 8,000 pe rson-reme or reports on reassessment of worker radiation exposure to 13,000 - 46,000 pe rson-reme. If these increased exposure during the TMI-2 cleanup operation and notice of upcoming estimates exist in some written report, I woult! very much public meetings on the topic in Harrisburg. appreciate a copy. Yours sincerely, ? The public has b3Th invited to comment on these O ~ W increased estimates of worker exposure during TMI-2 cleanup. I would like to do so here and to attend NRC meetings in the Bruce Molholt, Ph.D. Harrisburg area. Please send me announcements regarding Lecturer time and place of these meetings. Based upon BEIR-III, the new worker exposure a levels have been estimated to increase the lethat cancer burden from one to 2 6 fatalities a.nd genetic abnormalities in future generations from a maximum of two to 3 - 12. As you know, however, there is considerable disagreement among the scientific community regarding carcinogenic and mutagenic risks inherent in person-rems. Some of this scientific un-certainty is adequately aired in the BEIR-III report itself and its appendices. Much more variation in risk assessment to radiation exposure is seen if one departs from official docu. j mentation of the National Academy of Sciences and the NRC. 1 For the record, and perhaps erring on the side of human health concerns, certainly presenting a conservative extreme in radiation risk assessment, I would like to interpret new worker exposure levels in is rms of cancer fatalities and subsequent birth defects according to John Cofman's estimates (Radiation ag Human Health. Sierra Club, 1981). If we apply Dr. Cofman's estimates to the TMI-2 worker community, we can expect 48 - 172 additional cancer fatalities and approximately

e n.. r.n .,- w e n. L. H. Barrett January 30, 1984 O. '. BROTHERHOOD OF ELECTRICAL WORKERS TMI Program Office m.co. m INTERNATIONAL does not impact on other workers in the same area, and also that I the clean up procedure never becomes more important than the local UNION Noi.143 f .ggg, The members of this Local Union and the Building Trades Council have participated in the construction of Unit 2, as well as the soon navsms unnsrr clean up work since the accident March 28, 1979. Their knowledge HARRlWBURG. PENNA.17504 of the facilities and systems in Unit 2, and their experiences to date, working on the clean up, should be considered to be a vital January 10, 1984 source of information during the planning and engineering phases. Full utilization of this knowledge at this stage will result in fewer changes to "ECM's" and elimination of unnecessary and/or duplicated entries into containment which would increase exposure. Mr. Lake H. Barrett Deputy Program Director In summary, this Local Union is convinced that the clean up TMI Program Office of Unit 2 has been delayed too long. We are ready to proceed with the task at hand. We want the safety and health of our members, Dear Mr. Barretts and the public, to be the primary consideration during clean up, and we seek a procedure that would require our participation to I want to thank you for providing me with a copy of the the extent that we are able, toward the elimination of unnecessary recent draft Environmental Impact Statement supplement dealing exposure. with expected occupational radiation exposures during the clean up of Three Mile Island Unit 2. I also appreciate your willing-Thank you for this opportunity to comment. ness to meet with the Harrisburg and Central Pennsylvania Build-ing and Construction Trades Council to provide a better under-Sincerely, ?" standing and answer questions on your revised estimates and ^ 43 potential health consequences. .g, /3,,,q( I want to state that this Union continues to be cor.cerned Glenn A. Schaeffer that the safety and health of our members, and the general public, Business Manager will be the primary consideration during any future clean uP Local Union No. 143, IBEW operation. Having read the P.E.I.S. supplement I understand the need for increasing the original number of persons-rem required for clean up of TMI 2 is based on information obtained during GASamp subsequent entries into containment of TMI 2. I also understand and acknowledge that the level of doses that clean up workers have received at TMI 2 are lower than doses received by workers at the majority of NRC licensed reactors. I am convinced that those low exposure rates are due in part to the incredibly slow pace of the clean up operation, and even though increased clean up activities will also mean increased risk of exposure to our members, that clean up must proceed at a faster pace in the future because the TMI site is not suitable as a permanent, or extended, temporary repository for radioactive wastes generated by the accident. Our acknowledgement that the need for more expeditious clean up of TMI will also increase the risk of exposure to our members should not be interpreted to mean that we have no fear or concern regarding the risk involved. My position remains that ALARA programs must ensure that an individual's risk from occupational exposure is small and is kept as low as is reasonably achievable. I look to both GPUN and the NRC for assurances that increased clean up activities will not proceed beyond the ability to assure ALARA (e.g. proper coordinatinn of activities to assure that one clean up operation

Irie J. Ersteir 35 4 W. Orarge Et. Inneaster, PA 1760; January 11, t)tb I knew year act edule le busy but I would greatly aps.reciate a proert ' reply. S rol Dr. Sermard J. Snyder, prorren Director

• g.)

e mee Mile Island Prerra-Office W U. 5. Muslear neguistory Coscinatos trie .E tein Washington, D.C. *W ' ? W W. Orange St. Iancmater, PA 1793 I*ar Mr. Snyder: - After reading " Answers to Questions About Updated Estimates cf Occupational Sediatica Loses at Three ile f aland, Unit 2", e fe. g aetions have arise. in my mind and I hope you can answer them. Question 1, (p. 4 Q. 18),s '.'me repcrt maintained a link between a lack of funds and worker cafety. Eowever, in a meeting on May 11,1p'? with yourself. Joneyt Fouchard and Cemetanioner John Aheete, Contrinaioner Ahearne assured me that, " Lack of roney her never t.een a problee." Ee also stated tant he did not forece a protler resulting from lack of funce. Taere is a lack of fu=ds, and all tie while GPJ continues to use raterayer toney fer euclear prowtions and advertiseeents. Lo fou feel a diverster of GPU's funde from suelear pree.otion would facilitate the clear.up? If not, what other pressure can the NRC exert on CPU and the nuclear industry te r ese funds for the cleanup of Unit 27 Question 2. (P. $-Q. 21), e The report states that, " Die TCI alte U to not auttable se a permanent repository for radioactive wastes generate! i by the accident." I arree. However, there are new federal lava concerr.ing interstate transportation, interstate compacte t.sve arisen. and states which once welcomed wastes are having serinus reservatior_s. liow can the N31C assure the public that these new developments will not result in a long and aestly delay in transporting radioactive waste from h ee Mile I/_and? Question 3, (p. 7-G. 27),s The report states, "A radiation worker P U receive no more than 3 ree of radiation dose in any three-senth period. Ne worker may everage more then 5 rer per year for each year past age 12." In 1934 the government said that SO res a year was a " safe dope", by 1956 the government had reduced the " safe dose" level to 5 res. Do you feel that in the last 2 years technology has increased in the nuclear field far enou6h to warrant a reduction in the " safe dose"7 $ rem seemn very high since workers =ill be orposed to background radiation an other "unerpected" radiometive releases from hee Mile f aland. Also would on esposure to 3 reos in a relatively short period of tire'ineresse the chancer of cancer?

• By abort time I mean any time open within the three month period.

Question 4. (p. 10-Q. 43),a N 30tC seese estisfied the CP3 le taking every preventative measure to protect woman of chile bearing age. Esc the IGC ever done a report concerning the percentage of women who work at TMI and have had miscarriages, stillborn babies or deformed babies

• BIOMEDICAL METATECHNOLOGY,INC.

109 MAYNARD DR.. EGGERT5VitLE, NY 14226 (716)-832-4200 January 24, 1994 nr.9ernard J.Snyder Dco /.. %.1:, 'I'I** T1hree Mile Island Program office U.S. Nuclear 9aquiatory Commission '7 nai N J d i JNT,u.,@ri.e.:. fasc,.,: m.at Washinaton, DC 20555 S.' f*, es e E si KL W,;t,,3 c y g,,.4 3 v T.MI near Dr.Snyder: 24h *. ~ The enclosed letter to the New York Times is a C connentary on the mismanagement by NRC that needlessly M .6 c. w < 0.. f, .~s endanqers the health and safety of residents and workers ' M,.% .s < am,g 4, s-at T"I. If NRC took the trouble to use current risk 3 estimates, it would see the futility of its present 2*'- 9...... i..tu s- , u ,cc a. .w d. C $ clean-un nian and would leave the rods where they belona,

• h > n.s -. n t. n,g in TMI-2.

A t - M (ent...d n w

• di c a. e t..

5 iJ +$ * ( If MRC would read ny 914ECT TSTIMATFS O' LOW-lev'L

1. ADIATION 81S49 OP LUMC CANCEP AT TWO NDC-COMDL!4NT

'"2 4 '4 cwnt.d % g {g,,, 2,, ,,g,; y," y... O NUCL'As I NST A LLATIO'IS : W9Y ARP TMF MFW RISK 'STIMATES c d 20 TO 200 TIMES THE OLD OF'ICILL 'STIMATES? (nv Yale J$] jM*3,. Medicine) it would find note t%an 30 paoers listed where SA caper (54,1981.,317-329, Yale Journal of 91olooy and j-4 there are oositive health hatards from low-level radiation. It is impossible that there would be so nany indeoendent scientific reports of hazard unless the actual risks are about 100 times greater than those used by NRC in its decision-makina. Very sincerely yours, L Irwin 9.9 toss, Ph.D. President 91omedical Metatechnoloqv, Inc. 1

BIOMEDICAL METATECHNOLOGY,INC. 109 MAYNARD DR., EGGERT5VILLE. NY 14226 (716)-832-4200 tions are sacrosant but sensible nuclear management would January 24, 1984 change then to save human lives and hundreds of millions of dollars. New york Times If NRC used the risk estimates of normal science 229 U.43rd Street instead of those of

• official science *, cost-benefit Mew York City, NY 10036 analysis would favor entombaent. In a class action suit, a Three Mile Island Public Health rund was set **~ to do To the Fditors studies of low-level radiation hazards. If ti 13,000,000 would be used for the benefit of the residents, it could Coninq as it does almost 5 years after the TMI-2 orovide definitive evidence of higher health risks within 2 accident, the Tines editorial on managenent failures in years and avert the risk to TNI residents from the the nuclear industry (Jan.22,1994) shows how Inna it has clean-up. However this is unlikely to happen because the taken for the lessons of that accident to sink in.

One Connittee running the fund is dominated by the ideoloay of point is still missed: The reason nuclear management is ' official science

• that
• low-level radiation is harmless *.

so difficult is that the health hazards of low-level It has just issued an pro that virtually precludes research ionizinq radiation are so serinus. This is why a minor that could settle the issue. leak at a conventional nower plant may he reoaired in a few days while the sane leak at a nuclear plant can result in a prolonoed shutdown. The haalth hazards leave little It is gross injustice for the noney is to be used to narqin for error: any manaqenent mistake can be a fatal fund " official science' studies by the very persons who

mistake, have been the adversaries in court of litigants seekinq conpensation for radiation injuries (as is likely at TMI

?" Peoole in management are no different from other in the future) instead for the orotection of the workers %a hunan beinqs Not only do they nage mistakes hut, and residents at TMI. to make natters worse, they don't like to admit it. This is why the clean-un at TNI-2 could be more daqqerous While :he Times editorial deplores

• management by for workers and residents than the oricinal accident.

ideology *, this is hard to channe because it benefits the Nuclear seculatory comnission olan underestinated the the ideolocists in the nuclear area. What is now radiation esposures by a factor of at least 10 and the haopening at THI shows how this hurts the nublic--the health effects by a factor of 190. Although the clean-up TMI residents, the ratepayers, and the taxonvers are all has barelv started, tMPrC-1050 admits that worker exoosure goinq to pay dearly for the MDC refusal to admit its passed 1700 person-rem althounn *he lower limit for the mistake. entire clean up was originally estinated at 2000 At that time, I said the estimates were ridiculousiv low and the very sincerely yours1 NOC's new upper limit has been raised to 46000 person-rem, je from 9000 P / fM However because NRC continues to underestinate health Irwin 0.9 toss, Sh.D. risks by a factor of 100, it nersists with its original ,g< President clean-uo plan. Mut even the MRC acknowleones that th* miomedical Metatechnolony, Inc, risks to workers and residents could be virtually eliminated by an ontion called *entombnent* which would keen the fuel rods on site. This option would cut both P.S.: Ifetatechnology is the technoloov for the safe, the risks and the costs by 904 hut would require channes effective, and economical use of our powerful new in NPC regulations. For ideoloqical reasons the recula-technolonies.

"I "W'# " D OakFhdge FTS: 576-3171 insttute DEPARTMENT OF STATE PLANNING p Associated Post Offce Box 117 ter Energy son w. PassTome svassy o Urwersities Oak Fhoge. Tennessee 37830 Anaeysis sALTIMont. MaRrLAND 292ot.23Gs y HamRY MUGHas CoasSTa8eCE UCDER eovansson secanvaev January 24, 1984 Dr. Ronnie Lo Dr. Fred Bernthat Project Manager Commissioner Three Mile Island Program Office U.S. Eclest Bagulatory Commission U.S. Nuclear Regulatory Commission 1717 N Street, N.W. Washington, DC 20555 Washington, D.C. 20555 Dest Fred Reply Due February 23, 1984 1 note that NRC has modified its estimate of the number of cancers that will State Identifice. tion Number 84-1-294 newspaper account, the integrated exposure is now set at between 13,000 and State Clearinghouse Contacts Samuel Baker 1atter figure is obtained by aseming the linear hypothesis with 7,000 man-rems per cancer. RE: Draft Supplement. Sealing with Occupational Radiation Dose - Three Mile Island duclear Station Unit 2 In making thie estimate, NRC to ignoring the uncertainty in the cancer dose-response at low dose. According to the BEIR-III report, one cannot exclude a Dear Dr. toi. Iower limit for cancer induction of sero at the low individual doses (1.3 to 4.3 rams) encountered here. A more accurate and scientifically justified CO this is to acknowledge receipt of tne referenced subject. We have initiated the statement by NRC would have been "the estimated number of additional cancers Maryland intergovernmental review and coordination process as of this date. Wu lies between zero and six," not between "two and sis." Of course, the actual can expect to receive review coussents and recommendatioes on or before the reply difference between a lower limit of 2 and 0 is hardly significant-but the date indicated. If you have any questions concerning this review, please contact psychological impact could be much greater than this. A newspaper reader who the staff member noted above. learns that there may be no extr cancers I should think would be less appre-hensive than he would be were t e NRC to state, categorically, that there The State Identification Number smast be placed on any financial assistance would certainly be at least 2 cancers. application form and used in future correspondence. All of this is by way of urging NRC to re-examine its own position on the We are interested in the referenced subject and will make every effort to ensure linear hypothesis I cannot object to NRC giving an upper limit to number of a prompt review. Thank you for your cooperation. cancers per man-res; I object strongly to NRC, or anyone else, giving a lower limit different from aero when the individual exposures are no greater than e Sincerely, rems! Best wishes for a Happy New Yeart uy Sincerely, Dir or, ryland State Clearinghouse for Intergovernmental Assistance GWHI "" Alvin M. Weinberg Director Institute for Energy Analysis AMW be TELEPtecesE:3M N 7s75 oFRCE or sTaft CLiameseteriOUsE

i {; i BRYN MAWR COLLEGE i' s es)N %4ADvs. rtNN54LV ANIA 19018 DEP4atMEAT Of elGLOcv sootocs -um.+ a.utosc 8 February 1984 Comment to Dr. Bernard J. Snyder Program Director DRAFT SUPPLEKENT Three Mile tetand Programs office office of Nucteer Reactor Regalatten PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT U.S. Nuclear Regulatory Commiestem we ektaston. D. C. 20555 BELAT1!I) TO DECONTAMINATION AND DISPOSAL OF RADICACTIVE WASTES RESULTING FROM NURBO.0683 h Comments to Draft Sepplement i Progreenmatic Eavironmental Impact MARCH 28, 1979, ACCIDENT Supplement No. 1 i Statement Related to Decontamination i and Disposal of Radteactive weetse THREE MILE ISIAND MUCLEAR STATION, UdIT 2 Resultlag from March 28, 1979 A ccident. Three Mlle Island Nuclear Stattoa. Unit 2 (NUREG-0483) l l

Dear Dr. Snyder,

Enclosed you will please flad my commente y to the draft supplement PEIS for TM1-2 cleanup. j W Although NRC staff has lacrossed worker radiatten esposure espectattene ela. fold for the duration of cleanup, these maatadeed espectattene still fall short of petoottal werker exposures due to vast uncertainties in status of TMI-2 plenum, lower core and reacter vessel core eupport structures. Dissection of fused 8 February 1984 fuel assemblies, plenum and core support etructures ] will costlauausly contamtmate primary coolant with ^ particalates and fines obich must be filtered prior to chemical decontamtmattoa via the submerged de-Bruce Moli.olt, Pn.D. mineraliser system. Worst case scenarios for worker and environmental empoemres have not been taken tato Department of Biology account in the draft supplement PE15 for TMI-2 cleanup. Bryn Mawr College la addition, newer estimates of carcinogealc and mutagente riske from radiation orposure have not Bryn Mawr, PA 19010 been taken lata account etaca leeuence of the earlier i PE15 March 1981. Finauy, the draft PEIS insiste on the euphemtem "defuellag" for the moet hasardous phase of TMI-2 cleanup, the delicate removal of 100 tone of destroyed core and fuel debrte. l gn asmus9h 4'G'!!F % irac. M.11 1t. Ph. D. ,me,oeure 5 e

intreauction to persons residing near TNI-2 are not included in the Due to increased estirrates of radiation risks to workers supplement draft PEIS and were inadequately addressed during cleanuo of Three Mile Island Nuclear Station Unit 2 in the original final PEIS of March 1081. I'nless the (;MI-2) the U.S. Nuclear Regulatory Commission has been re-TMI-2 core is in danger of assuming re-criticality, there quired by the National Environmental Policy Act to issue a is no reason from the standpoint of worker or public supplement to its original Programmatin Ehvironmental Impact health considerations to push ahead with any of the Statement dealing with the TMI-2 cleanup. Increased doses three alternatives outlined in the draft supplement PEIS. to workers are now estimated at 13,000 - 4.000 person-ress, Arm >"--a risk enttmatma val t a f or inna...a anno.ur.. un from the original estimates of 2,000 - 8,000 person-reme, or it 600 46_ooo norson.rama? In my comments to the draft supplement PEIS, I will Deopite the fact that revised health risk estimates consider the following issues: exist, for example from the BEIR-III report (Biological 1) Are human risk estiastes valid for increased Effects of Ionizing Radiation, U.S. National Academy of exposures of 13,000 - 4,000 person-reest soiences, 1980), the draft succlement PEIS continues to ? 2) Is the upper limit of M,000 person-ross rely upon outdated health risk estimates for human exposure o realistiet to ionizing radiation. In Appendix & page B.1, the staff 3) What do increased riska to workers mean relies uoon risk estimates frca the 19/J SEIR report and when translated to nonworkers residin6 near ThI-27 its own flawed statistioal analysis of 1973 WASM-1400, 4) Can the most critical phase of TMI-2 core which also concluded that a TMI-2 type accident should cleanup accurately be called 'defueling*f haopen once overy 20,000 reactor-years. 5) Are core decontamination procedures developed Various risk estimates for human genotorio effects such that worker and environmental exposure risks from exposure to ionizing radiation have been developed. are minical? Descite NHC staff's insistence that their health effect 6) What are the risks inherent in delayed TMI-2 risk estimators are ' internationally accepted' (p. iii), core cleanup? many internationally recognized physicians and health Although worker risk estimates have teen increased chystoists would disarreo. For example, John Gorman, M.D., in the draft sucplement PFIS, there is every reason to former Director of IAwrence Livermore I.aboratories, in his believe that these estimates are still minimal. 31sks authoritative !!adt ation 3,nA Human 3333a (Sierra club 1981) -2

the lower reactor vessel more explicitly in describing the three lowest levels of the vessel: applies a risk estimator of one cancer per 268 corson-ress a) CCRE AREA CONDI?ICN IIMKNCWM wnloh would translate as 170 cancer deaths from 46,000 H M 2 - Q M M H OM M person-rom exposure rather than the 6 deaths calculated C) STRIBUTION - CONDITIQN UNKNCVM (p. 2.9) in the draft supplement PEIS. In addition, Gofman's risk ( h phases mine), estirates would indicate 340 additional genetic' defects among worker offspring at 46,000 person-rea exposure rather than 12 as in the draft suppleevet. PEIS. chemical decontamination: "... the most highly con-fn the unner 11 sit of M 000 earmen. ram worker aremura taminated portions of the system, such as the reactor ramitatie? vene and piping to the pru surizer, gaz require The NBC was forced to issue its draft supplement PEIS mechanical decontamination by grit blasting or other because data accumulated from hundreds of entries into the methods before, or in place of, full-system chemical TMI-2 containment building since 1980 have indicated that decontamination.' (p. 2.11, amphasis mine). worker exposures were estimated six times too low in the

• " I * * * * * * ** E *""" I"I *I# "I
• eriainal PEIS. Much of this increased worker exposure

" Clearance between the pressure vessel and the plenum ? estimate comes from realization that the TMI.2 reactor is nly 50 mils (50 thousandths of an inen), so in U core is largely melted, crumbled and fused, such that workers in core removal will be exposed to prolonged um m be wa ." (p. 2.8, mphasis mine). periods of radiation which were underestimated in March If th* Plenum is warped. it will have to be eut up, 1981. Yet, much uncertainty exists as to the state of which would be a potentially "high. dose job.* (p. 2.19) the TMI.2 core, as admitted in the draft suoplement PEIS: as erable unmtainty exists abat decontami-1) Below the upper plenus there is a core void of nation of the primary ecolant by the submerged deeine-about 5 feet where fuel assemblies have been completely ral ter system (SDS). This system is easily blocked destroyed. Under this there is a rubble bed at least y ca a H, w are p anne to res m a by 14 inches in death. "The conditions below the rubble are not known.' (p. 2.8)

• • ** *"# **"""E 2)

Firure 2.6, a cutaway view of the TMI-2 remotor and mechanical secaration which will reflood the vessel, shows this uncertainty as to the condition of 4- -3

primary coolant with fines and other particulates. eThe fuel removal plans have not yet been finalized reactor containment vessel and core. Upper and lower because investigations of fuel conditions are still estimates of dose differ by a factor of J.5. ret, as - in progress.e (p. 2.19) Continual contamination outlined above, for key sections of reactor vessel and and decontesination of primary coolant by released core cleanup, especially in the arena now refered to as fines and other particulates during fuel removal 'defueling,' considerable uncertainty exists as to what could lead to considerably higher worker exposures impediments to cleanup will be encountered once the reactor vessel is breached. Hence, it is not known wnether sensitive during this critical phase of reactor vessel cleanup. 6) The mechanics of actual fuel removal are very sessents of the cleanup operation will take weems, months or even years. These uncertainties aske a risk range estimate poorly articulated in the draft supplement P IS. None of the original 177 fuel assemblies is intact, 0 - 4,000 person-reas, a 3.5-fold range, highly unlikely. Realistically, the upper extreme of this range but the exact extent of fuel pellet fusion, crumbling e ul be increased according to the worst case scenario or the size of debris to be encountered in the bottom 1 of the reactor vessel rec ia unknown: night obtain during TMI-2 reactor vessel and core a) 'The fuel la. A&&gggL 'o be in a combination of the following configurationes What do increased risks to workers mean when translated e fused sections-- to non-workers residine near TMI-27 e core debris- ' (p. 2.19, Emphasis mine) The population residing near Three Mile Island has b)

• Adjacent pieces EAY. Atad ta AE sanarated been persistently exposed to'radionuclide releases and in order to be removed." (p. 2.19, Emphasis mine) accompanying psychelogical stress as a result of the TMI-2 accident.

7) Finally, there is considerable uncertainty as Upon various occasions since 28 March 1979 this populatien has been exposed to 20 million curies xenen-133, to worker exposure doses which will result from re-at least 26 curies iodine-131. 200 curies tritium,'43,000 moval of lower internals at the core support assembly. og conditiene require, it will be cut up for removal.' curies krypton-85 and other radionuclides in snear water and air. (p. 2.20. Dnphasis mine). The cresent core inventory of radionuclides has Tne draft supplement PEIS increases potential worker-a potential health threat far in excess of any previous exposure from 2,000 - 8,000 persen-ress to 13,000 - 46,000 5- -6

r_____________ at TMI-2. In the radionuolide inventory are actinides, stress of residents in the TMI-2 comm m ity. There would including 150,000 curies of plutonium-241, strontium-89/90, be irreparable harm, both to the psychological health of costum-137, cobalt 60 and at least 150 other radionuolide the population restains near TMI-2 and to the regard this species, all of which are dangerous to human health. population has for the U.S. Nuclear Regulatory Commission Considerable uncertainty exists se the the state of if, two years hence, a second draft supplement to the PEIS the plenum, lower core and lower internals of the core were issued according to NEPA mandate, because, upon entering support assembly which will determine the difficulty of the core, worst case scenario calculations presented worker decontamination and extent of worker radiation exposure exposures well in excess of 46,000 person-ross. (see previous section, pp. 3-6). This same uncertainty can the most critical ensam of TMI-2 core elaanun accurately be called 'defuelins"? translates as potential incroceed non-worker exoosures in residents living near Three Mile Island. There are Normally operating nuclear power reactors are defueled two notential sources of increased radiation exposures approximately annually and generally involve the replacement to persons residing near TMI-2 as a result of further of about one-third of the spent fuel assemblies with fresh fuel rods. The operation is conducted entirely by remote stages of the cleanuo operation: 1) From unforeseen mechanical failure to heavy control through a fuel canal adjacent to the reactor vessel ~ tu equipment during delicate stages of plenum, core and spent fuel rods are then stored still submerged in pools or core-support removal. These mechantoal failures adjoining the reactor. oculd include unpredictable lodgings or droppings This is far from the scenario at present at TMI-2. The of large sections of the fused core during attempted fuel canal cannot be used for 'defueltag" since none of the removal which would have high potential for both fuel assemblies which normally pass through this canal are worker and environmental ccataaination and cause intact. Instead, cranes, grappling hooks, saws, torchee semi-permanent breach of the containment vessel, and other separation and removal devices for the entirely 2) From underestimated levels of potential en. decomposed core must be apD11ed from abov+ through lifting vironmental contamination even in the absence of of a potentially warped plenum af ter reactor head removal, secidents due to the uncertainties of plenum, It is euphemistic at best, fraudulent at worst and certainly core and oore-support configurations, misleading to refer to this most hazardous phase of the TMI-2 Release of revised worker exposure estimates in draft cleanuo operation as defuelins. Perhaps rernoval af I.HEl fdar.11 suoplement 1 of the PEIS has already exacerbated psycholorical more accurately conveys the real situation. 8-

Are core decontamination nrocedures develoved such that from examing the fuel is expected to be useful in laproving worker and envirenmental exnosure risks are minimal? the safety of other nuclear power facilities." (p. 19). In the face of overwhelming ignorance concerning the Here again NRC staff's reasoning for expeditious cleanup integrities of TMI-2 plenum, core and core-support, prudence seems flawed. Of course fuel in the destroyed core is a dictates proceeding cautiously such that worker and environ

• potential risk to workers and to the pubito, but that potential msntal contaminations are kept to a minimum. This is not is all the more realized upon core decontamination and removal the tenor of the draf t supplement PEIS:

of highly hatardous high level radwestes. If hastily or in-it is still the conclusion of the staff, prudently approached, this 'notential riek' becomes real risk 1) as it was when the PEIS was completed. that cleanup and, hence, does not justify removal.* As to the usefulness should croceed 11. expeditious 17,31 consible to reduce of the highly melted and crumbled core for didactic purooses the potential for release of radiomotive materials to in imoroving the safety of other nuclear power facilities, the environment and to ensure that TMI-2 does not be-this may be a useful argument for obtaining Japanese invest-come a long-term radioactive waste disposal site.' ment in core cleanup, but it is hardly an argument that ex-(pp. iv-v, Emphases mine). ceditious cleanup is least risky, which is the subject of Neither reason expressed supports the staff's conclusion. this draft supplement to the PEIS. p b

• Expeditious
• oleanup may well release more radionuolides W*in t are the risks inherent in delaved TMI-2 cora eleanun?

4 to the envircnment than cautious cleanup, for the reasons Implied throughout the draft supplement PEIS are the outlined previously in these comments. Cautious cleanup dangers of delaying core cleanup above and beyond the ex-by no means argues for establishment of TLI-2 as a persa. plicit reason stated. Is there a danger of re-criticality nont repository for high level radioactive wartes any more in the core at TMI-27 When this same question was posed than storage of spent fuel assemblies on-site at many other durinF commentary to the initial PEIS. the possibility was nuclear reactore renders them long-term radioactive waste strongly denied. If, now, this is a real danger, or if the disoosal sites. In succumbing to this reasoning, NRC staff NRC staff assesses it may become a danger in the near future, is ruilty of a simplistic *now or never* approach, which, this danger of re-criticality of the TMI-2 core should be in the face of considerable uncertainty seems imprudent realistically included in the final suoplement PEIS. at best.

• This same ploy was used by NRC staff to justify wrypton-85 l

2) "Puel renoval delays are considered undesirable venting in June-July 1980, to protect the public from because the fuel continues to pose a potential risk to accidental krypton-85 releases:

workers and the public and because information obtained -9 l

Conclusions c .,,,,g.u, Despite the fact that worker dose estimates have - co== ,, ",7".j,,, increased six-fold since the origins 1 PEIS on TMI-2

=="==* s m u.. .un.sv a.e vann,o. cleanup, the NRC staff in its draft supploesnt retains o,,,,, [,,7,*

=

's omes==um 1ts original conclusion that cleanup proceed as expedt.. SENATE OF MARYLAND -a s co is uv .m. a==aeous. maanvtano ainoon ese tiously as possible. The NRC staff 's reasons for re ;en-tion of its earlier conclusion appear invalid. The February 13, 1984 potential for release of radioactive materials into the environment is exacerbated by core cleanup rather than Dr. Ronnie Lo Three Mile Island Program Office decreased, unless the core is in danger of re-criticality, U.S. Nuclear Regulatory Commission a potential danger not addressed in the draf t suoplement Dear Dr. Los PEIS. An alternative cautious cleanup procedure which maximizes worker protection would not enhance the chances I am in receipt of the TMI EIS draft supplement regarding occupational radiation doses. Clearly I am supportive of utilizing that TMI-2 becomes a long-term radioactive waste disposal any methodlogy that provides for the lowest possible person-rem doses. site. Furthermore, new genotoxic human dose assessments However, as the representative of a large number of people directly down the Susquehanna from TMI, I believe the ultimate U1 have been made since the last PEIS which were not taken goal at the TMI clean-up is to accomplish the clean-up in as safe and quick a manner as feasible. The people of Pennsylvania, into account in the draft supplement (Gorman, 1981). as well as those of us downstream, must be vitally concerned that delay in the clean-up process continues to force us toward event-These risk assessments when applied to 46,000 person-ualities that none of us want to see. First, the structural integrity of Unit 2 continues to deteriorate as time passes. Secondly, failure rems translate at 170 additional cancer deaths and 340 to clean-up expeditiously, brings us closer to the time when, finan-cially, utilizing the TMI site as a long-term disposal site will additional genetto defects among children of the 10,000 appear more attractive. This must n,o,t be allowed to occur. TMI-2 cleanup workers. Stellar higher risk assessments Thus, I would urge the NRC to approvo the safest methodology possible, while not jeopardizing the clean-up process, must be soo11ed to the environment and to the risk for Thank you for your consideration. ^> already aggrieved residents living near THI-2. Sincerely, In its final suoplement PEIS, it is recommended that the NRC staff substitute the misleading "defuelina" with g 'recoval of fuel debris

• and seriously consider phased Senator plenum, core end core-suocort removal strategies which sck maximise worker and nearby resident safety. - -

1 ) February 6,1984 r THE JOHNS HOPKINS AtEDICAL LYSTITUTIONS DIVISIONS OF NUCLEAR MEDICINE AND RADIA TION HEALTH SCIENCES g7, g,7,,74 3, $,,4,7 Program Director Three Mile Island Program Office Office of Nuclear Reactor Regulation us uonnt rotra sTazzr Nuc r egu ry Commission s4LDMORE. MAR YLAND 2Ho$-W9 Te rphouw J0!; 953 H$v February 13, 1984 RE: Programmatic Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from March 28, 1979 accident The Honorsble Arthur E. Morris Three Mile Island Nuclear Station, Dnit'2 Draft Supplement Dealing with Mayor, City of Lancaster Occupational Radiation Dose (NUREG - 0683 Supplement 1) 120 N. Duke Street, P.O. Box 1559 Lancaster, Pennsylvania 17603

Dear Art:

- T151s letter is to forward the State of Maryland's comments on the Supplement to the Progrsanatic Environmental Impact Statement. As lead agency for the Anticipating our meeting last night at Harrisburg, the Maryland Govern-State of Maryland for review of cleanup activities at.Three Mile Island, the or's Committee on TMI met on February 6,1984 with officials of the Power Plant Siting Program has coordinated State review of the Suppleent. Department of Natural Resources of the State of Maryland and approved unanimously the draf t response of the State of Maryland to the Supplement Maryland's principal concern continues tobe the hazard posed to its population to the Programmatic Environmental Impact Statement (NUREG 0683). A copy and resources by the presence of high level wastes, including spent fuel, at of the Maryland opinion is attached. Three Mile Island. Maryland's position has been that the " cleanup should pro-ceed as expeditiously as reasonably possible to reduce the potential for uncon-Despite the fact that the meeting in Harrisburg lasted 5 hours, I was trolled releases of radioactive materials to the environment * (PEIS,1981). ? unable to present this written opinion to the Par,el. Therefore, I would That position has not changed. ~ be most grateful to you if you could attach the Maryland response to the - .The evidence presented in the Supplement indicates that the total radiation CD recorded transcription of the Harrisburg meeting. g exposure to the work force during the cleanup will be higher than originally The Maryland response is a draft in that the Governor of Maryland has not estimated. While we in Maryland are concerned about worker exposure and advo-yet had the opportynity to review the actions of his advisory committee cate strict adherence to the ALARA principle, we note that the doses to the which ! chair. individual workers will be within the limits of 10 CFR 20, that is, no worker will receive more than 3 res/ quarter or 5 rem / year. Since I will not be able to attend the visit to TMI on March 8,1984 (our Maryland group has inspected Unit II five times over the past four years Maryland is also concerned that the selection of the cleanup plan cou'd delay and found the visits to be most instructive), I would appreciate your the cleanup process. We have reviewed the analysis of the current P an as reading the Maryland response to the Advisory Panel on March 8,1984 as I well as the three alternatives. Alternatives 1 and 2 would result in a tielay had planned to do last night if I had been given the opportunity. of fuel removal while resulting in no significant savings in occrpational exposure. Because of this delay, and the fact that little or no dose savings I hope that in the future a more balanced discussion of the issues will would be achieved Maryland considers both of these alternati.es unacceptable. De possible. Alternative 3 is more attractive because of the projected reJuction in occupa-tional exposure without delaying fuel removal. It does, however, signiff. _.+ Henry M. Wagner, Jr., M.D. ~ professor of Medicine, Radiology and Environmental Health Sciences; Director, Divisions cf Nuclear Medicine and Radiation Health Sciences kC cc: Dr. Nunzio J. pap.sino Dr. Bernard J. Snyaer

Dr. Bernard J. Snyder -2 fearvary 6, 1984 ~ ( ($ ha q, W RE: Prograssatic Environmental Impact Statement related to oecontamination h M IJ ctJi i b'O i 7 and disposal of radioactive wastes resulting from March 28, 1979 accident Three Mile Island Nuclear Station Unit 2 Oraft Septement Dealing with hdA 19 MY I Occupational Radiation Dose (NUREE - 0683, Septement 11 g \\^ttotd. cantly delay the overall cleanup while relying on the speculation that robotic M cleanup tecnnology will be available at some time in the future. Maryland is DW, . g,' b g f opposed to delaying even post-fuel removal elements of the cleanup, and there-i fore considers this alternative unacceptable. For these reasons, the State of Maryland is aposed to the three alternatives pruented, and strongly favors My ho. g. 3 the current cleanup plan. ./ Q..[t] p"a. w U g g A t.? We appreciate the opportunity to provide these comments and hope you find them - [ u5*I- & y 3;1,/ W,... wt Sincerely, g o-3 N N 1 c y Cs b( -n} ,r run Thomas E. Magette, Administrator s nuclear Evaluations /F 9 bd=1 7 fJ p n o w w )) q9 w :us p

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s comodting scientist Henry H. Grima 32 Valley Drive, R03, cam.1 ting scia. tins Annville, PA,17003. 32 Valley Drive, RDJ, Can. It nas alreecy suggested tnat tne worst of rne precicted pnenomens ao not Annville, PA, 17003. Occur. Can we go on to prove that all tne pnenonera tnat can cccur are aanageacle? Feorvary n. 1 W. Answers to some of these cuestions coula even ce scrtn a 01111on or even several Dr. teraarc J. Snycer, Program Directcr, 011110n Oc11ars 10 effort. Three rtile Island Progr3m off1Ce, .= U.S. Nuclear Pegulatcry Comission, Pecole in tnis area snould De locking for more signs tnat tne rest of the world is etnington, D.C. ICMS. willing to nelp sustain the TMI-2 clean-tc effort. We woula nave oeen well advised, rignt after the accicent, to try to sell copertunities to co some vital research in rhis coment letter is ceing written in rescanse to Ine invit3tions.;1ven in a unique situation. Nownere else in tne woric is there an eoual occortunity to MSEG-1060 anc in NUREG-0643. It seems to re im an importart ascect of te inrae stucy scme pertinent large scale proolems. All Inose going to learn from it, anc to Mlle Island accicent on Marcn :S,197?, is ceing overlookea, or is ceing Neressea use tne results, snould nelp sustain tne effert. cy t*e political ramifications of tre preclem. One of tre corcerns, e3acerestec cy Classifiec sciantific literature is not ava11acle to me. It seems to me tnat 7e tnose wno want to can tre nuclear siternative for generatirc electric cc er was ?e 'er trat a irge fracnon cf tre nuclear c*arge coulc Cansmte to ncicactive gwernment agencies in cnarge of roclear Cectric power ceveicc.ent snoulc

• ave rac eleaerte wnicn woula ce vicely aistricutea as a gas, elemortn cf mnecggr, ana snould now nave a sucstantial oevelocment program to crose tnat severe accicents can ce contained. I ncce that sucn progrsns ellSt that are rot arcwn to me. Clearly it nas ceen snown tnst tne ganeral ocpulatico can ce stanceced into m

s,.no Is it oct true tn3t TI-I cemnstrarea this e not occur in y y!Uf-W/an 3 colicies Inat can nave cisasterous long time results. It is also clear tnat a greco v er. < 3c L W

• Aulc like to see scme cuantitative etu rlu s c

istricuteo.Itseamstosetnatinistyceofinferstienwillia GoWa cf cecole esist = nose primary cojective is to deny tne caccit of tnis co'.rtrv "ae 2-Cet+ 1Nect:ry :< re ars;ec centents is avgist;e. Is a :ded,,W. fry cf cenefits of roClear generatec electric power. M snculd ce srowirq tne scr!J ~4!

eNrQy incaponcence is possiole for a nation wnicn nas inace%3te nycocaroon Src !** cortents ceing tapen? I< it is t3 ken, it aev tacic3te e rn., m... w f a-21L' *: Te enc!"9us cestn tell estith%s *"e anti-^uclear 5hcc15 iI5 -2 ge. carcon fuel resources. Insteac we grovel in fear, cemancing fero risk processes, wnicn are onysically unrealizaole. In our oemnos, we frecuently reacn tre state "ny rMicc1ctive anter131 tnat is still in va cert 31rmet st;uc %r=' +~ <~,' i'.inacle u ini anyone, excect mI workers. enere we cause ceatns and economic narcsnip ratner tnan releaving trem. Political cressure cannot cnange tne laws of tre anysical univerte. In fact, unat =e co knew 4 ;re t1*e

• read scme of tre literature acecreanving tre cis;ute accut - e says tnat tne pnysical wor 10 cannot even sense, et;cn less react to, cur political y

=aT., o ciscnarge of racicactive material in an accicent of tnis sort. As 7 Times cuellsneo material frem a erecknaven recort. Iit55Em5c'i'3 onssures. - I's N w vc!k co calculation was mace to assess tre ef'ect of cistriouting nalf *ne racUstive rne mI-2 cleanuo oelays are giving more time for tre crocesses of olffusion ano atoms in tne containnent area, cr tnelt transnutea crocucts, oy nina-ccrne corrosion to taxe noic in tne centainnent cu11cing. If we are ever gcing to 31stricution, over a large area. The person vno wrote this part of the cccument clean-vo tre acticent restoue celav can cause tre loss cf Sem mI-2 worker's I celleve. Cre c ris cc-claints was life, cecauce tre crecesses of ciffusicn anc corr:sicn re ire,cracle inc ;c n;at e dr'te a letter of cretest to 'nysics Tocay, tre verv <3ct inat ne cenevec inis districutico ce n31f tne racicac,tt.e %4:.913 en 31 tre same cace no matter wn3t colitical processes 3re ccirg. ~ hose clasirg n w

• • :emeestrate; ra nis re m 333 ce protecting lives cy continuin.g ceiay can, anc crecac1, are, causing tre ;ns ?

ret anc crcoacly ccul: rct 9accea. '"e gaaer31 cualic coas not rcerstano trat crysical scieece ;31E,i3tl;yC"C, life rigrt acv. Tre snole clean up crecess reautres tre cest nrceterce tatt un ce ~ ~ ~ ~ ' ace for CCTletely errcrecus assucctict.5, 3rc I st re reg 3 ; g'- cetairec, to achieve 3 miniu evcencitore of 11ses and eff,rt Cer*.ainif ri-

n;;ulations recresent enysl: ally unrealisaole p., ants.

Coccetence is ett g0ing to te 3sseaclec using only ceCisions ttce cv i CMac 'tincful only of pc11tical :casicerttiens. <, 09t 5 793! Sgo I afte"ced 3 svacoslum it Cacital C3Feus of PW. mis esmo a:, :-a - -d * :-;. !! 1s Ty !Tressicn t"at t*e VC is c"ar;ec 41D t*e N;43*no cf re Nc;sar Les*2n sa5 ?cer alscussicn. :n 3 crisave :cesersa-::r 23r*1cicans, en arti-cuclear 16civ10ual, I askec nlm no. re treMt erd %.V[:a,:- 4 electric cover incustry. It is succesec to weintain tnis locustrial fu cti:c ss :re n .ranium items ceu1J cecem airect'e. mis reciv nas, cy trvsMadcr. - rd !"i' CO!! ? s iVallicle 'c' tre gF e!!!! n Of E90*r*.0 00'ir. .I " e '.1% 3'i :' C# r e.,e t.,. Sirc "fie ' fe s * " ole gSs$es 363 M Icciae St;*s. I Oresur e, *r n 3H tme n5cusgly gqu !"1s courtry. Any 40 Mtrs arc are "Ct -sluirg to <!* s a . 'i i;re ps?; Tat icCut aCv %c : 4ter:3;.33 gy 3ygg y.- ccjectises irc.10 ce re%estec to resign anc #CTCec TO Cc Q '.* eCeMirr. *Fj ;"

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!"e ce13ys tatt n3ve occurrec are really oc'ning less taan sSectage, 31**c cir*c%y ' ~ tr, "!i'5cCr* * ~;;;#4. ".3 2, es!!:r c cg;; ;e : ;335ec. 3 t-j yf g7 y;j g 3! **e p00019 c' Inis ration anc !"el; cc;criunities. '.et*3 ;6! **e **I-2 ;19sMc ? 'co'31PN"! str';Crure Ocn?!steat witn 3 crec1; ;;n y,egrag ;y me *- - 9 jco core. C' 'Cs %C* WCr!J ~1s es*!*4?e:p recggc' ere is C"e durc'tmeatM ^oj*c'i** to EM 53v tre fi9 !*sult! 1re !**c!*?O '* T' VDCW i&*.C6L Te %se ? c32f.2 cetD Ms*s, "TsCe i* ~~e "a~giri. 'P n.- - c. v 4. C8 'an # ' * * *J -1er - e' - [.M' * * ;..k Ia i[. : *

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f .T A w 2 L' A. RQgg TRI-COUNTY REGIONAL PLANNING COMMISSION-Henry H. Grims 7.- tCUM BERLAND. DAUPHIN. and PER RY COUNTIES) e C""

• M 32 Valley Drive', RDJ, 2001 NORTH FRONT STREET Mvw1118, PA, 17003.

etDC. #2 sulTE 221 orner plan of act10n, Snould ce Cnalged to the use of the fuel'Cho$en. For exanple, HAR RISBURG. PENNSYLVANI A 1710' If we elect to replace nuclear with Coal, the differential Mrginal deaths SBCuld Staff Telephone 2342639 De Cnarged to coal. A small marginal increment in deatn$ Can ce genersted C0verin9 the mein alternatives. Tnis taole need not ce large, DeCause the wortnwn11e February 23, 1984, alternatives are few in OLAcer now. Future events may Constrain them even furtner. events suCn as anotner miocle-east 011 Cut-Off. REFER Filet 1984-12 U.S. Nuclear Regulatory Commission SuCn a marginal ceatn rate matrix needs to incluce all of tne cominant centh r1 Sus Office of Nuclear Reactor Regulation, aSSOClated with e3Cn metn00 Of electric pCWer generation. Tne entira crocets n*ecS Three Mile taland Program Office washington, i.C. 20555 to Ce OGScr1Dec Dy the main COntr1DutCIS to ceStn$ altCng electricity CUSIC*e:S inc Attn Dr. barnard J. Snyder tne simpliers. Tnree Contr1Dutors tnat would Surely te nee 0ec woula te mintrg tre Program Director fuel, pr0 Cessing it for use in the Convertor, anc Converting it to electric energy. Pernaos these would provice all the :1gnif1 Cant Contritutors ino woulc ce enougn to RE: acview/Co= ment TMI Unit 92, PEIS: Supplement #1-acequately represent the $1tuat10n as far 85 deatn$ and Safety are CCnce!ned.

Dear Dr. Snyder:

The present TCtn00 Of presenting the Situat1Cn is cc mletely inadequate, primarily because it encourages the presu@t10n that avoicing tne one SCtivity under At their February 23, 1984 meeting, the Tri-County Regional C1$CuS$10n will nave Ine net result of Cer0 marg 1Dal deaths. Anctner Chol e arCng Planning Commission reviewed the above noted supplement and offers the Opt 10ns ava11aDie may leaa to negative marginal deaths, that 15, toe ! Swing Of the following comments: live $. ProCaD115t1C RISK Assessment Can generste marginal r15k mati!C95 an1Cn ;an T.D u6 The proposed refocusing on reactor disassembly and defueling o as soon as possible appears to be in the best interests of > to assess tne relative safety Of Our metnocs for generating electric CC*er. I! 15 E g term occupational and public safety Certainly poss1 Die tnat tnere is enougn Safety cata now ava11aDie to mke Cet*er G ju0gements. Deatns that have alreacy ceen Occurring Over an extenaec Ceriod Snould not De per"11tted to De DruSnec as100 CeCause SCme 0011Cy advCCate C0es not like Concurs that the monitored interim storage, as proposed in. o tnem. All of tDe main Competitors nave a more tnan trivial nistory now. we may need Alternative 3, is unacceptable due to the unreliability of robotic technological advancements in the forseeable future, to keep knowing aDout all of the alternatives. We Sn0U10 Certainly Se very Careful the increase of total decontamination difficulties resulting Scout allowing any of the main Ones to De discardec, particularly if those want 99 from delays, and potential health and safety hazards: to 01Scarc it are ignoring 50me dominant pnyS1 Cal Constraint. The TMI site is not suitable as long-term repository for o iniS CCuntry needs to require advocates Of Specif1C 0011Cle$ in CCnnectiCn wi*n the accident generated radioactive waste. The Commission Safety ceCates to nave merginal Ce3th MSt!1Ces gener3ted. It Should De !*0uired therefore concurs with NRC staff conclusion that decontamin-In3t these rest Cn estaD11Sne0 Cata in the Case of all ex15 ting CICCesses. T ey ation activities should " proceed as expeditiously as must 1150 nave Some well cefined CompletenetS CICCerties. ArCCeSte$ 1^0 Oati toit possible while ensuring the health and safety of the workers 3r? COv1Cusiv inCCHelete Snculd De Caried. Entirely new prCCetSes C10 te ECre and the public." 01fficult to'nancle. They in0uld not De trD1trar11y thrown among ett3011an+2 OTocesses. For tne morent, it woulc Ce enougn to try t0 nanc;e estaC;1re0 Very truly yours, processes in tne ways outlinea aoove. I understand tnat some tentat1ve Meet '3ve ceen mace toward originating legalities to ce appliac to Cur CCntenti:nS E0ut safety. SuCn proCeoares enould ce given a lot of new attentim. A metnoc ^eact to . Se 19qally Ce'inec requir1DQ % regulatlng 3Ge*Cy t0 Ie3C* OIC0e!Sei at i!? s R. Zei s, AICP infer 1Cr to SCme reference r12w mtp1'Nm 300 to 3CO*CT In0?? tetter tnr Scae ON! ecutive Director refereece riSx. Guarantee 0 ero T15ks in 311 $1*.Lat1Cns, Or e'.en ;": 77 INT. is not 3ny Citi en*S cittnrignt. cc Dauphin County Commissioners Motentions 100u% !afety must De retCivec. Pey CCul2 -1119013 nat1Co. *e W fo PA Intergovernmental Council Oer Mencia$ 'NSt nang in !"e!e. b/f n Cerely yourS. V POR ADOCK OS000J20 8 P PDR "ry =*. O

February 23. 1984 Ct. Bernard J. Snyder 2 February 23. 1984 " estimating" stage of radioactive decontamination. (which has already proved incorrect) why wouldn't robotic cleanup provide the necessary time to proceed in safety with due Dr. Bernard J. Snyder care to minimize human radiation exposure? Program Director Three Mile Island Program Office 6. How can the NRC gain the public confidence and rectify all Office of Nuclear Reactor Regulation of its past mistakes, many of which caused the TMI incident. Nuclear Regulatory Commission when krypton-85 was regularly released into the atmosphere Washington. D.C. 20555 during " normal" operation and purposely vented into the atmosphere after the TMI incident? Dear Dr. Snyders Please consider and respond to the following comments 7 Public safety must necessarily concern the radiation exposure on the draft supplement 1 to the Programmatic Environmental of any human whether voluntary (occupational) or involuntary (non-occupational) - the public safety cannot be divorced Impact Statement related to decontamination and disposal of from employee safety. All employees are part of the public

28. 1979. Accident, radioactive wastes resulting from March and must be considered as such in any radiation dose measurement.

Three Mile Island Nuclear Station Unit 2 (NUREG-0683)s as 8. The consistent inability of the NRC to oversee, supervise, Why should the general public accept draft Supplement i forsee, plan or execute Nuclear plant construction, operation. 1. valid when Supplement 1 is an open admission by the N.R.C. or decontamination casts serious doubt upon its ability in Staff that they can only estimate the radiation doses the The NRC has to date (1) desregarded public those areas. public will be exposed to, and that their estimates are safety resulting in the 1979 TMI incident (2) underestimated (1) too low (2) little more than mathematical hypotheses (3 ) not t read upon any actual experience (4) a continuatio. substantially the theorectical radiation exposure of employees (3) failed to establish any decontamination schedule five of the errors, poor policies, lack of understanding poor years after the TMI incident (4) been unable to supply the supervision, mistakes. and continuous underestimation of technical skills or knowledge necessary to decontaminate the the serious radiation hazzards to which the general public failed nuclear reactor although that possibility existed long [" is being exposed? before the construction of TMI was begun. Wouldn't it be far more useful to have an independent group of nuclear scientiste na How can you justify the intentional radiation exposure of study the TMI problem and release their findings for public C) 2. 10.000 plus workers under ALARA requirements by selecting scrutiny and comment? sny decontaminating method other than Alternate threes defueling followed by delayed cleanup using robotics. 9 Inasmuch as th6 TMI reactor was constructed to be a source of radiation exposure to the public for at least 40 years and Why didn't the NRC forsee the incredible decontamination inasmuch as the five-year delay in beginning any significant 3 difficulties created by and compounded by failure by the decontzaination by the NRC has maximized the extent c6 total licensee to seal all exposed concrete surfaces and to require contamination at this point in time, the only item left that that the seal be renewed as required? can be minimized is public radiation exposure (including 4. Why did the NRC allow hollow-concrete-block walls within employees). Alternate three is the only alternate proposed any building subject to contaminated liquid exposure when by the NRC (although there may be others) which considers this item and therefore is the only alternative' worthy of any decontamination is impossible? serious consideration. Inasmuch as nearly five years have passed since the TMI 10. GPU Nuclear licensee decontamination proposals should not be 5

• accident." and the NRC is only in the discussion and considered, reviewed or approved in any respect by the NRC.

Many of the problems that caused the TMI incident can be traced to the NRC approval of GPU prorosals without adequate evaluation or follow-up as a matter of record. Only independent studies and evaluations made by independent nuclear scientists l

Dr. Bernard J. Snyder 3 February 23 1981+ " obr:ary 23, 1994 skilled in their areas and who are willing to put their Cs "'."C; 0603 professional reputations on the line should be utilized by the NRC. I trust that you will give my comments full and careful ,o *rm 30 :ou issioners Thank consideration and that your response will so demonstrate. you. .*r. *)errick. in the enclosed reprint, has expnssed our feelir;s tatter ry t yours than we could, but would like to add a few thoughts of our own. s unc 31r fned the slaves many. mars ago. 'the vill fne us from s Louis M. Busch rev== ment whese protection agency does not pretect and te.ose regulaterv 1610 Cherry Lane Macungie. FA 18062 Mf? does not regulate? Nat happens when the lid is' lifted, providing the cise.e w e in it should and there is no snafu? To what exposun will the workere h s'2bjacted today' in five non years? i.*111 workers fa-ilies evacuate * ' hen will a cancer study up-date in dere? vhy will this not. include all. workers including sponges" of 5:? 3 he ostrich syndrese does not eliminate any probles. After y years N. 'he People of NI an still here, asking why you would consider nstarting e- " nit 1 tefore the original accident is cleaned up; "either restarting Unit 1 in 199h nor renoving the fuel and entombir,g Unit 2 will te effective ir alleviating the fears of the People of "hne. Mile Island. Zither alta=- ative would be f:st anotrer evasten of responsibility. !Sre vnld tN financial support for sonitoring Unit 2 be founi, especially since 0?L"' 1 hes not have the funds for a "nor.al" elean-up :f Unit P Olean it a-d

lete it -- then vor y about starti g 'Jnit 1.

Sinterely. ... L... Y. 7 A .Y* k....,. >... u s. 2arles i Snevieve 1. Onerick. Cr. h?? "ill:v 9t. Mirs ire. ?A 170?k ' *1 ?'C-903'

I i l I I I I I ill I I I ll Il one reader's MY VIEW opinion A sedw of ee GeMeere ans. Scest s. Derrick earreepy is wrts, lag a dissertadse la Amarteam IJs-svarare and teneteep emmessiden r,. L. e' SCOTT S. DERRICK at ae Universar ef. - -- yc73:,;l1743-l lett ury id, tw FEB L s Officials must speak for people on TMI structed to e adam this dangerous health problem 13 Thret L'ile It1ond }. CffD n ,m REGNT EVENT 3 tadicate that the Three lAle ! stand nuclear faciety may open under the worst pas. our midst. Cffjce cf 01e at-2 f 50 0.r m ** sable conditions wie q==aans of the lategrtty and While radMan soeps teto contatament badding g,;,.,ge. ], gy o g. a g..W"rl'**. g.-'g,.3,' . ~ renabluty of plaat operasors left marssolved. Car'.ain. wans, we have learned that risk to workers has boss g *, u.... * - * " * - ly, there was ao reason for the recent NRC vote tf Ge significantly -a. -t plan tsa't to reopes TMI reactor 1. As a resuR. It is What about the rtsk to ourselvea? To our chiktres absolutely easeadal that state pub 8c officials speak and famihen? Psychologically.most of the has In ret E... * -M '., ! ;,;; -I c: c r.t S c. I with a clear. strong voice la safeguardlag the laterests been does to us not during, but stace, the 197 asal. ~ g; no, c7 37 of the people of Pennsylvesta, dest. The issue is ao longer kut the lattial acclear acci-All OF these thlags. I am convinced, have left DerJ Ir. Iny:er: dent la 1979. Had the laganaa of s and scars la the hearts and sunds of Pennsylva*na which Industry to that amas=0been suff had the woel heal for snaay years. Most of us, after Go taltiat Lose refu: tion in the 1T..vironner.tal 1:cpact Statenent caesa-ap of TMI reactor 2 base as efficient as the accident. assumed that the restart of Three Mile Island is once atain almost erolusively concerned witrt occupational people of Pennsylvania bad a rtsht to espect.the acci-was tnewttable. We teade curselves be calm. believing dcse. Phile it i n und e rs t r.P.d 3 bl e t i.at you cre very conecrne: deat woukl eow be a fading memory. Central Pennsyk that trrational panic and hystatia would omly makt a about worker expeure, ycu nuct fut forts r ore eff ort cn ut vaham would have the assurance of knowtug that bed situadon worse, the auclear reactor ta thetr andst was ta che hands of I now beneve. however. that pubus anxiety ts c.atter of ref t.cinc radiaticn er;.oeurc to the reneral public. safety. conscious. renable management and that be-nearly as bad as it can get. and that nothing can'b8 5ince cany cf your ;;eViouS deeie1on3 LRve teea b3 sed cn fart' solutiens (ad.itted tv toth the GC and G7"W'

• hind this

^ stood government regulators mined by pretending a matter.of-factness we denet

1. cheep antFant tiSe that you fut the utt.ost erp.atie en protection a

whose chief concern was pubile welfare. Pubuc aape-If a referendum wera held la Pennsylvants, the . 18 h ty mound have beca eased to the point thst and===ted populace would overwhehntasty. statewide. vote of the public at this cr1*1 cal stare of the cle:r.ut. umt reactor i could be safety restarted. againet the. restart of the Three Mile istand reactor N ander any condicans. To restart under current condi. NEED1155 to ssy. bowever.the ensuing five years tiona is rea!!y unthinkable. Yet. we are told the opta-The prtetice cf "eZec7 tion to regulation

• shencycr y:

N have been anything but reassurtas. lons of Pennsylvanians count for nothing, and ene etncienter a difficult roblen at iel cust be discontinuer.. We have learned that individuals with grew pubBc our leaders seem to shaae tocar heads helpaessly whea responsbilities have bees gustry of lies and negligence. confronted by the power of the NRC. ,ou profees to have rastered thin technoloCy, yet your We have been faced with a Nuclear Regulatory We were tattially hospitable hosts to the nucleat favorite eolut1en to yroblere enecu ttcred ia to avent* cnc Commissace which eften seems most anxious to sweep industry la our m6 dst. Our hospitality has been abused, important quesdons under some bureaucratic rug a We now are victims of an outrage all too comrnoa la FrcC1 air 3 r.o health h32ari, commismos so deeply divided that members charge recent years; industry and government falung to safe-each other with eegnsence! so.w the interests or private citizens. AU the WaaiMe 4*. ereu's scenarios are classifioc e-We have watched as problems at other plants con-We must be stetims no eore: now is the time for highly unlikely, but nany of your previous projectione and vince us that our ows acetdent was not some trible ah who love Pennsylvania tn come fo ber defense. The coleulat!:nr have been prcven insecurnte and :: ch in r.eed cf aberradon. but something which could well happen people of Pennsylvanta must speak with a unified again if the plant is not operated with teal care and voice, with postcards and lettars to their public offt-revition. rnen ycu talc ;f 1itind r.:nntc, etrin ;ent con *r:15, clats. What they must say. to Governor Thornburgh. End 77tc;heric ex;1: sic.5, to r.ct !crget your instility t: dedicados. We have learned that we art etpected te recommit Senators Specter and Heinz. congressmen. state sena-evirirthend a scent.rio tu at that t.P.ich caused the cr -1:L Three Mile Island to the same careless hands, as if tors and legislators is this: we want you to defend as aeeident* after repeated viciations pubhc trust can be regained with a unified, heparttama voice, from the organized by simply asking for it. power of the nuclearladustry and the federal govern-ICu uce "1204 e f,' C inJ* n*. 3 C70t0h in ine e1CW ;;.:

• We have learned that we are eIpected to11 splay a meat. who seem to care so httle for our welfare. If panence which we would fled Iaccrous if we were need be, you must come up with plans of your own to of tr.e elenr.c;.

1 e

c.(: t ptI c:.; nit 1 cr.cGd havt-t-

desting with, any, a drunk drtver who repents after resolve this dreadful state of affairs: for too long, we

ced Cor the clen..u; CI in;t 2.

D t. UL GZ k.Vt yG2 d fi/ cf ite 5cr4erS EM have placed our safety in the hands of those who seem pgeggggg.*iIea 'r We have sees the folly of faith to private ladustry to hold it Bghtly. You must give voice to our fear and rum te r.uct ttke 4< e.c e d c ' -

• c v c * "- ~ * ~* f1 t * *

~~~ ~ every offense. ~ and the federal government because. five years after anger:if you do not represent us now, why are yes is the accident, a workable plaa has st111 not been com-offste? Now is the time to act. Ilpe Fairief, aseampa. Test hk 1 nes-A$ I ~

'

u .. i d g y

Jer= erd J. Snyder. Pret;rar Director QI iebruary 24. 1984 g , g.: 35A [e (J. [Q 3 '0 wj G (73/f It to knorr. that tr.it 1 mill 16: radiation into the rather than " leak frec

• gf,ffeg envires=ent due to aleck 11-ittnca stera ger. crater. tube repatro.. tr.at, t.lenc with reactor vete el erbrittlecent, corrocten of crittent parts, and.

unter,olved e::erpency feed 7ater c/ste + problens cets it.c aceculo fer a f ar scre etraous neel/ent et 2VI. Are you [ 7% M'**c[.'/[,-- ready for anoti+r :.r.;or clea:up at "":' You will ther. hnvc 't ecr.;;eted r. f all cycle eit's "So leu c.:.e:rneca. /7 I sould like ycu to Ict ec knoe cf cr.e cuct ection frc: { the cereral public that has Lien icccr;cr:tcd ir.tc your cler.up e ffcrt. 4p .g, [ I know of neae. sL aw gk .,1.e.r. n. de$A'O (( 44W/m v' ' 'h-Mw, M4 g Alice A. IIer::ar. py ec:. Hon. Itichard Thorr.turgh g ~ gh cet hen. R. Jote. Eeir.r. III ect Hen. Arlen specter .A++eM ect c1111ea F. woodling s g4 j " Y" N ca .A, i i W 'un Y J +tu gr, r (C deal L J:' L../ w n e L-M L-u saTZ A.. A ' 6at 4xp .~w w.

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W.r.zans R. Haasis.1 row Dr. Bernard J. Snyder. Program Director February 27. 1984 Three Mile Island Program Office Page 2 esos Baums.9 raser. Arr. 307 PTremensa.Pawnsvi.nn 4asan3 Tas.semansiosa.se3.eaas maximum-dose case (46.000 person-rem). 6 additional cancer fatalities would result. Although it is possible to compute a range of probabilities for cancer induction among average individual workers based on the above figures, the results of such a calculation may not bear a close relation-ship to actual risks since the work force size and collective dose February 27, 1984 associated with the various tasks can differ by large factors, rendering inapplicable the concept of an average individual worker." These mortality figures were derived based on a factor of 131 fatal cancers Dr. Bernard J. Snyder. Program Director in the exposed workers per one million person-rem. Three Mile Island Program Office Office of Nuclear ReactJr Regulation We rectusnend the deletion of this discussion. Without considering such U.S. Nuclear Regulatory Conuitssion factors as the work force size and the collective dose associated with Washington, D. C. 20555 individual tasks, statements such as "6 additional cancer deaths would result

• are meaningless. Discussions of licensee administrative controls

Dear Dr. Snyder:

and the risks to individuals associated with the maximun allowable doses during given time periods (as provided in subsequent paragraphs) present The Technical Advisory Group has reviewed the Nuclear Regulatory a much clearer picture. Consnission's draft Supplement I to NUREG-0683. Programmatic Environmental Impact Statement (PEIS) on the Three Mile Island cleanup activities. 3. In the last paragraph of Section 3.3. the probability of genetic effects among the offspring of the work force should be expressed in terms of Our concerns are centered on the Section 3/3 discussion of health increased risk to the individual worker, rather than as a flat number effects. We consider the draft section somewhat misleading and recunnend based on 260 genetic effects per one million person-rem. the specific changes discussed below to provide a more realistic and y comprehendible focus: We appreciate this opportunity to review on the draft Supplement to the PEIS and trust that our conenents will be properly considered in the final r0 1. NRC's estimate for cumulative occupational radiation doses associated document. with the Current Cleanup Plan is 13.000 to 46.000 person-rem (Table 3.1). To provide some perspective on this cleanup dose, which is expected to Sincerely. occur over a five to ten year period, we reconsnend that the text include 7G ud ist Ma WdNO a comparison with several examples of consnon radiation releases in the p area. For instance. (1) persons living in the vicinity of TMI receive William H. Hamilton approximately 24.000 person-rem each year of additional exposure through Chaiman the use of natural gas in their homes (Reference 1); and (2) the total Technical Assistance and Advisory Group exposure to area residents due to potassium-40 in the blood and tissues of their bodies is approximately 43.000 person-rem / year (References 2 WHH/ep through 6). These doses assume a population of approximately 2.16 million within a 50 mile radius of the site. Hence. the annual exposure due to ec: Mr. Bahman K. Kanga. Director the cleanup will be about an order of magnitude less than the local General Public Utilities Nuclear /Bechtel TM!-2 radiation exposure due to these consnon sources, i Mr. Harold M. Burton Manager 2. In Section 3.3, the fourth paragraph states: EG&G Idaho. Inc. ...For the minimun-collecthe-dose case (13.000 person-rem) it Mr. Adrian Roberts i l is expected that 2 additional fatal cancers would be caused. For the Electric Power Research Institute

A . February 27, 1984 Dr. Bernard J. Snyder Program Director February 27, 1984 Three Mile Island Program Office Page 3 Dr. Bernard J. Snyder . Program Director Three Mlle Island

References:

1) EPA Report EPA-520/1/73-004, pages 29 through 31.

Program Office

2) Page 57 of "The Fight over Nuclear Power

• by Drs. Bodansky 0ffice of Nuclear Reactor Regulation "

and Sctnidt. U.S. Nuc1 car Regulatory Copatission L3 EPA 520/1-77-009, Pages 29 and 34. Washington, D.C. 20555 L4 Dr. Edward Teller, Wall Street Journal. July 31. 1979. i 5) J. M. Smitn, Jr., GE, " Natural Background Radiation and ~

Dear Dr. Snyder:

the Significance of Radiation Exposure" (6) National Council on Radiation Protection and Measurement The Safety Advisory Board of TMI-2, whiett was constituted early in 1980 Report Nos. 45 and 56. to provide expert scientific, engineering, and medical advice for guidance J ' for the safe clean up and recovery of the damaged nuclear power plant, ) has had the opportunity to review the December 1983 draft of Supplement '

i No. I to the Programatic Environmental Impact Statement (NUPEG 0683).

l The Safety Advisory Board of TPI-2 (SAB) wishes to submit the following 4 comments concerning the Report in general, and Supplement No.1 in parti cular. 1. The SM ts in full agreement with the NRC Staff recossendation that there should be an increase in the estimate of the collective dose equiva-i lent for workers expected to occur in the course of the TMI-2 recovery operations. The new range of the Supplement of 13,000 to 46.000 person-rem appears to represent a far mort realistic assessment than the estimates proposed in the original PEIS, particularly since so much more valuable data on the status of the damaged plant are now available, i cn 2. The SAB believes that as the clean up progresses, the ranges of uncertainties will narrow depending on the engineering techgologies developed and applied to the tasks, and as additional data becomes avail-able to define subsequent tasks. With careful planning as these procedures are carried through. the results will impact on the proposed collective dose equivalent assigned to each subsequent or concurrent major activity. Thus, while the present values proposed reflect the current status, it may be necessary to revise or at best narrow the range of estimates as the clean up of the plant progresses safely to completion. l l l 8402240$73 840227 PDR ADOCA 030003:0 p POR

4 J i l Dr. 8.J. Snyder -2. February 27, 1984 Dr. B.J. Snyder ' February 27,'1984 l 3 The SAS agrees that the conservative estimates of potentia 1' delayed 5 In this regard, the SAB wishes to draw attention to recently avaflable health effects as carried through by the NRC Staff appear to be in accord with current scientific and medical knowledge, and are consonant with radiological protection data for the clean up, 1979 - 1983. During the the methods of risk assessment used by the International Commission on five-year period since the accident, approximately 16,750 worker-years - Radiological Protection, the lmited Nations Scientific Comittee on the have been involved in the clean up process resulting in a collective dose. Effects of Atomic Radiation, the National Council on Radiation Protection equivalent of less than 1700 person-rem. Of the 16,750 worker-years, and Measurements, and the National Academy of Sciences-National Research two-thirds recorded no measurable radiation exposure, and 85% involved Council. The Board recognizes that the NRC Staff estimates are statis. doses of less than 0.1 rem per year, that is, less than the average annual tically derived numerical values and are intentionally conservative within whole-body dose received by all persons from natural sources of ionizing radiation. Moreover, a dose rate of 0.1 res per year is considerably the prudent philosophy of radiolugical protection of the workers and the . general public. The Board's assessment of the estimates as calculated less than that received from all sources (including natural background - l compels the scientific conclusion that based on current radiobiological raliation, medical and dental radiation, commercial air travel, etc.) knowledge and theory the numerical values could be considered as an upper .other than occupational exposure. i bound, and that the uncertainties associated with such risk estimates, derived as they are using linear extrapolation from the epidemiologic The SAB urges that the NRC Staff recognize that occupational exposure levels data at high doses, embrace the statistical probability that no delayed health effects could occur. in the range of natural background radiation are considered to represent negligible risks to individual workers. For example, a dose rate of 0.1 l rem per year is only one-fiftieth of the annual maximum permissible dose 4 Given the NRC Staff estimates for carcinogenic and genetic risks, -for occupational exposure recommended by national and international standard-the question arises as to how this information can be used as a basis cetting bodies (including the NRC). The Board recommends that the NRC take - l for radiation protection guidance in the very unique situation of the cognizance that the annual collective dose equivalent to the workers ccn. TMI-2 clean up. Logically the guidance or standard should be related - sists primarily of values ' considerably less than 0.1 rem. The risk of ? to risk. Whether the magnitude of the risk should be considered acceptable; developing a delayed health effect, such as cancer, from a dose of 0.1 to or not depends largely on how avoidaale f t is, and to the extent not avoid ~ rem is considered to be about 1 in 100,000 (or about 10~4 per rem) and that this order of risk is generally considered by society as a negligible able, how it compares with the risks of alternative options and those N incremental risk to the individual. ' f j normally accepted by the individual or by society in everyday lift. Accordingly, the SAB embraces the philosophy that evaluation of the adequacy The recorded data also demonstrate that approximately 965 of all TMI-2 workers have received less than 0.5 res per year, or less than lot of the annual per-of an occupational health standard, regulation, or guidelines must consider missible dose. Of the remaining 4% of the worker-years of exposure, no worker whether the potential incremental risk imposed is regarded as acceptable to ( l the worker, both in the workplace and in his way of life. While we recognite received more than the maximum permissible dose. The S AB recognizes this achievement as a particularly excellent record considering the immense such judysents are necessarily subjective, we believe that the currently engineering problems encountered and the unique nature of the work involved I proposed estimates of collective dose equivalent impose potential health in the cleanup process, risas to the workforce that should be acceptable to them, and to society in general, since the risks, in perspective, are extremely small in com-parison to other risks that are now readily accepted. The SM is pleased 6. The SAB wishes te draw to the attention of the workers and of the pub 1tc that the NRC Staff has carefully explained the relationship of these com. parisons in the PE!S supplement, that the NRC pEl$ Supplement has determined that the revised estimates of } worker exposure necessary for the clean up process (range 13,000 to 46,000 person-rem for a population of some 10,000 workers) will result in "from 2 L

.. February 27, 1984 Dr. B.J. Snyder February 27, 1984 Dr. 5.J. Snyder to the region of low doses and low dose-rates tend to a m11tiplicative to 6 additional deaths among these workers due to cancer and from 3 to 12 effect in the calculation of risk estimates. These overestimates may The SAS believes there additonal genetic defects among their offspring". serve to offset any calculations that argue that these numbers reflect is reason to expect that over the entire period of the clean up process, cancer deaths, and do not therefore represent the number of individuals the dose commitments associated with the recovery will be no greater than affected, or that they are based on absolute risk projection models those stated, and that the numerical values for potentf al health risks rather than relative risk projection models for predicting future The estimated most likely represent an upper bound, and will be less. risks to an exposed worker population. If expressed in terms of cancer statistically-derived values presented by the NRC Staff may denote a level incidence, including non-fatal cancers, estimates of risk could be of precision that is not warranted; it should emphasize, preferably, the higner by a factor of roughly 1.5 considering the predominance of men nature and ressons ttat, while the estimates are conservative, they are in the workforce. And whereas within a particular homogenous population also extremely small. Furthermore, these figures must not be taken to the projection o' future risk may probably best be done on a relative represent more than crude estimates of risk, based on the incomplete risk basis, as s t no firm conclusions can be drawn at the present as e na*ure of the data at present available. Several factors, not taken into to the appropriateness of either model for projection forward in time account in the calculation of these estimates, exist which compound the without further years of observation of irradiated populations. However, uncertainty of these numbers. First, the scientiff e evidence indicates the current evidence indicates that estimates of lifetime excess cancer that some experimental and human data, as well as theoretical con-risk may vary only by a factor of 2 or 3, depending on which projection siderations, suggest that for exposure to low-LET radf atton at low doses, model is chosen, the linear model probably leads to overestimates of the risk of most cancers, but can be used to define the upper Ifmits of risk. Second, in these calculations, no allowance has been made for the likelihood 7. The Safety Advisory Board is aware that differing viewpoints may be that the carcinogenic or mutagenic effectiveness of low-LET radf ation submitted to the N9C'which oppose the Current NRC PUS Supplement in an is reduced at low dose rates through the action of biological repair effort to challenge the range of the calculated estimates of the worter Third, the individual cancer risks used in the derivation collective dose equivalents or the potential delayed health effects that processes. of these numbers may rise or fall as the follow up of the epidemiological could occur. These positions are not unique to the clean up of TFI-2, .D study groups is extended to longer periods. Fourth, the risks have been but rather tend to apply to many of the societil activities involving the derived for the most part at high total doses (which may have been suf. use of fonizing radiation. The Board recognizea that frequently these ro ficient to inactivate potentially' susceptible cells from which a cancer viewpoints are not predicated on sound scientific evidence, but rather CD might result), and linear extrapolation could tend to overestimate risk on controversial or incomplete reports or personal statements. Several of low-LET radiation. Fifth, the numerical values of the risk estimates such reports have been published, some recently, seeming to claim degrees derived from radioecidemiological surveys are themselves crude and uncer-of cucinogenic radiation effects at low doses in humans that would be aften have wide statistical confidence lief ts. These uncertain-incampatible with the linear hypothesis being conservative, and may even tain as made even wider by uncertainty about the dose-response relation-underestimate the effects at low doses and dose-rates. Many of these ties are ship ano %e -%k projection model, studies are limited due to incomplete data bases, inadequate dosimetry, confounding factors, unconventional statistical methods, or unconfirmed results. The situations individually or collectively are not convincing However, the uncertainties tend in the main to emphas12e the Conservatism enough to argue against the conservatism associated with the linear This fs clearly the of the risk estimates as presented by the NRC Staff. hypothesis nor do they provide evidence that the risk Of Cancer from low situation where the linear hypothesis is applied and no allowance is made dose radiation is greater than indicated by conventional estimates. The for biological repair processes; where age-distribution relative to Safety Advisory Board strongly endorses the view that these claims compel potential reproductive performance is not considered; and where upper-level no scientific reason for national and interPational standard-setting anCertainties derived from high-dose and high-dose rate data and extrapolated

Dr. B.J. Snyder February 27, 1984 Accord Research and Educational Associates,Inc. groups to abandon the body of epidemiologic evidence on radf ation-induced cancer that. althcagM based on greater exposures, yields consistent and statistically stable risk estimates. Phone. p $ M 3889 8. The SAS concurs with the NRC Staff observations that extended delay in the cleanup can lead to both increased costs and increased collective dose equivalent. Further, the effects of increased costs can exacerbate delays which can increase risks of further collective dose equivalent, including that to the pubitc. Therefore, the SAB believes that the more 28 February, 1984 expeditiously the clean up can be completed, within current safety stand-l ards, the less the long tene risks to both the workers and the public. Dr. Bernard J. Snyder Program Director. Three Nile Island program Office Office of Nuclear Regulation $1ncerely, U.S. Nuclear Regulatory Commisaton Washington D.C. 20SSS y ~ ~ ~ * ' ~ Deer Dr. Snyder: Jares C. Fletcher, Chairman Safety Advisory Board In NUREG-0683, Supplement No.

1. Draft Report, cancer l

JCF/j f deaths resulting from whole-body exposure are calculated using values of 131 and 135 deaths per million person-ren exposure of workers and the general population, respectively. Table I 35 (enclosed) presents a spectrum of such values from the recent Board Members acaentific literature. In each case, the methodology recommended y3 by each author was used for calculation of excess concer deatha, Dr. John A. Auxier Dr. Merril Eisenbud assuming doses an the range O to 50 rada. Dr. Jacob I. Fabrikant Dr. Robert 5. Friedman The wide discrepancy in the values for the number of Dr. Bruce T. Lundin fatal radiation-induced cancers resulta in large part from Prof. Howard Rat ffa adoption or rejection of a linear dose / response relation in the Prof. Isorsan Rasmussen exposure range considered. It is a viewpoint shared by a large Mr. Lombard Squires portion of the actentific community that linearity of response Dr. William R. Stratton down to very low doses la the only model consistent with epidemiological reautta in humana (see references below). Uncertainty in the slope of the dose / response curve in the low-dose range has been widely discussed, with highly divergent opinions having been reached by the authora of the references cited in Table I. Translated into the expected effects from the updated estimates of 13,000 to 46,000 person-rem (which we do not endorse) the range of estimates of numbers of fatal cancers ranges from less than one to 270. Because of this broad range cf possible consequences, the staff should report all estimates of the nunter of fatal cancers per unit of populatann radiation exposure including those which differ from estimates established by the NRC or other organizations and individuals with demonstrable affiliation with the nuclear industry.

Rotblat, J.,

"The rasks for radiation workera", ault. Atom. Sci., 34 (1978) 41-44. ~ h,k ' ' ' e: l-l . [,. %,. 2,- ( '. h ' k M [l$ 5.;., ! $f _ 1. [ b j, W [ '--i ' S., 17 g.} ~P I ~ s

Redford, E.p. " Human Health Effects of Low Domes of Ionizing PISELLO AND pICCIONI: CONMENT ON NUREG-0683. Supp. 1. ENCLOSURE Radiation: The SEIR III controversy", Radiation Research, 84 (1980) 969-394. TABLE I. ESTIMATES OF WHOLE-BODY CANCER DOSE OF LOW-LET RADIATION FOR POPULATIONS OF MIXED AGES. Brown, J. Martin, "Linearity vs. non-linearity of dose Fatal Cancora response for radiation carcinogenesis " Health physica, 34 per Million (1976) 231-245. Person-rome gggggg Respectfully, RSS(1975) Dose rates below 1 res/ days central 45 estimate of cancer risk.(e) f } } Ius - BEIR(1980) 75 yr exposure et i red / yrs lineer 62 Dr. Daniel panello, Ph.D. quadratic model; absolute rank projections 4,751 Director of Reneerch cancer deaths per aillion persons arradiated.(b) A.R.E.A. 100 ICRP(1977)(c) 122 l,,, RSS(1975) Upper estimate of cancer raak.(d) Dr. Richard Piccioni, Ph.D. BEIR(1960) 75 yr exposure at I rad / yrs linear models 150 Senior Staff Scientist absolute rash protection 11.250 cancer deaths per A.R.E.A. million persona arradiated.(b) Asatatant professor ggIR(1980) 75 yr esposure et 1 rad /yr linear quadratic 160 Department of Biological models relative risk projection; 11,970 cancer deatha Sciencea per million persons irradiated.(b) Hunter College 695 park Avenue .Radford(1980) Lower estimate of concer incidence 179 y, LJ New York, NY 10C21 (260 and 550 per million person rada for males and C3 females, repsectively) averaged and converted to, mortality (approminately one-half ancidence).(e) BEIR(1980) 75 yr exposure et I rad / yrs lineer modela 385 relative tsak projection: 28,690 excess cancer deaths Enclosure (1) per million persons irradiated.(b) Redford(1980) Upper estimate of cancer incidence risk 588 (880 and 1620 per million person rede for males and females, respectively) overaged and converted to mortality (approximately one-half incidence).(e) Norgeg(1981) Two-fold increase in BEIR (1980) rash 770 (linear model, relative rish projection) due to revision of shielding factora in Hiroahama and Nagasakt.(f) 800 Rotblet(1978)(g) Gofman(1981) Central estimate of cancer done.th) 3730 Kneale et al.(1978) Doubling dose for cancer mortality 5880 estimated as 33.7 reda for menen divided by spontaneous cancer death rate of 0.198.(1) -

r PISELLO AND PICCIONI: CONMENT ON NUREG-0683. Supp. 1. ENCLOSURE continued MARYLANO 1 INE I E DEPARTMENT OF STATE PLANNING

e. Reactor Safety Study. An Assessment of Accident Riska in U.S.

301 w. PRESToN STREET Commercial Nuclear Power Planta WASH-1400 (NUREG-74-014). saLTIMonE wAnVLAND 21201 23s S United States Nuclear Regulatory Commaastc,n. Appendiu VI. HARRY HUGHES CONSTANCE UEDER page 9-33 Table VI 9-7, October 1975. sove==on. ,,e.,,,,

b. National Research Council. Advisory Committee on the February 29, 1984 Stological Effects of Ionizing Radiations. The Effects on Populations of Esposure to Low Levels of Ionizing Radiation.

Dr. Bernard J. Snyder page 146 Table V-3, Weahington, D.C.: National Academy of Program Director Sciences. 1980. Three Mile Island Program Of fice Office of Nuclear Reactor Regulation

c. Internetton Cometsekon on Radiological' Protection. Recommen.

U.S. Nuclear Regulatory Cmaission dations. ICRP Publication 25. Oxfordt Pergamon Press, 1977. Washington, D.C. 20555

d. Reactor Safety Study. Appendam VI, page 9-34. Tat le 9-4.

SUBJECT:

REVIEW AND RECOMMENDATION e. Radford, E.P. " Human Health Effects of Low Dooes of Ionazing State Identification Number MD 84-1-294 Radiation: The BEIR II controversy". Radiation Research. 84 (1980) 369-394. Applicant s U.S. Nuclear Regulatory Commission

f. Morgan.

K.2.. Letter to Science. 213. (1961) 604. Approving Authority: Same Bull. Aton. Description Draf t Supplement Dealing with Occupational Radiation

g. Rotblat. J.,,7,The ranks for radiation workers".

gg 3 p,9,44, Dose - Three Mile Island Nuclear Station. Unit 2 3,g,, 34

h. Gofman. J.W.,

Radiation and Human Health. Sierra Club Books. Recommendation: Endorsement with Comments San Francisco. 1981, page 294

Dear Dr. Snyder:

1. Kneale. G.W., Stewart. A. and Mancuso. T.H.. "Reenalyste of data relating to the Hanford study of cancer rank to The State Clearinghouse has coordinated the intergovernnental review of the radiation". an Proceedings of the Internetton Atomic Energy referenced subject. Acting under Article 8SC of the Annotated Code of Maryland Agency meeting on Late Biological Effects of Ionizing and Code of Maryland Regulations 16.02.03, the State Clearinghouse received the Radiation. Vienna, 1978 387-411 IAE-SN-224/S10 page 404. following comments: Cecil County, Reaional Planning Council and its member jurisdictions, Department of Transoortation. Department of Economic and Community Development includ fag their Maryland Historical Trust section. Department of Natural Resources. Of fice of Environmental Programs, and the Department of State Planning indicated that the statement appears to adequately cover those areas of interest to their agenc ies. Regional Planning Council noted (copy attached) that the current clean-ep procedures should continue as expeditiously as possible. They indicated that the alternatives described in the report would further dalay the removal of radioactive materials from the island and would not significantly reduce the occupational exposure. The Council also noted support for the recent IRS decision to allow tax deductions for utility contributions to the clean-up fund. The Environmental office advised (copy attached) that this response is a . 2 coordinated one generated by their office and the Department of Natural Resources. The Office further noted that both agencies (DHMH and DNR) support the current clean-up plan; however, there are reservations about the various alternatives outlined in the draf t. TELEPM0fef:In MB-1s75 oFRc8 or Start cttaassGM0uSE

Dr. Bernard J. Snyder Dates. February 28, 1984 Page 2 February 29. 1984 Lirecter "aryland State Clearinghouse Department of Natural Resources letter of February 17,1984 (copy attached) for Ir.tergavernmen;al Assistance 331 West Preston Street indicated that Maryland's principal concern continues to be the hazard posed 3altimore. MD 21201-2365 to its population and resources by the presence of high level wastes, including spent fuel at Three Mile Island. The Department noted that Maryland's position SC8 JECT: REVIEW COMMENT AND RECOMMENDATION has been that the " clean-up should proceed expeditiously as reasonably as possible to reduce the potential for uncontrolled releases of radioactive materials to the environment". That position has not changed. - The Department Stata Identification Number: 84-1-294 (See 81-8-158)- indicated that Maryland is also concerned that the selection of a clean-up plan could delay the clean up. They have reviewed the analysis of the current clean-Applicant U.S. Nuclear Regulatory Commission up plan as well as the 3 alternatives. Maryland considered alternatives 1 and 2 unacceptable as they would result in a delay of fuel removal ai.d show no signif.

== Description:== Draft Supplement Dealing with Occupational Radiation Does icant saviets in occupational exposure. Alternative 3 seems to be more attractive - Three Mile Island Nuclear Station, Unit 2 due to the reduction in occupational exposure without delaying fuel removal. Their agency concluded that Maryland f avors the current clean-up plan. Responses must be returned to the Etate Clearinghouse os or before ' 2/22/84 In response to the review request, this letter with attactmente constitutes the State process recommendation. The comments and recommendations made in this Based on a review of the notification information provided, we have determined thatt review should be considered and addressed n the development of the final statement. Check hs. The State Clearinghouse should be kept informed of any decisions made with regard

1) It is consistent with our plans, programs, and objectives (and when to t his subj ect. The Clearinghouse recommendation is valid for a period of three applicable, with the Coastal Zone Management Program and Historic ye rs f rom the date of thia letter. If a decision regarding the subject has not Preservation Standards).

been made within that time period information should be mutaitted to the Clearinghouse requestus a review update. Jggggg2) It ta generally consistent with our plans, programs, and objectives. M h t,the qualifying comment below is submitted for consideration. We appreciate your attention to the intergovernmental review process and look forward to continued cooperation.

3) It raises problema concerning compatibility with our plans. programs, or objectives, or it may duplicate existing program activities, as Sincerely.

indicated in the comment below. If a meeting with the applicant is requested, please check here AD

4) Additionah, information is required to complete the review. The

< Gu Ngar information needed is identified below. If an extension of the i / D getorf Maryland State clearinghouse i l for Intergovernmental Assistance - review period is requested, please check bare

5) It does not require our comments.

COMMENT $g See Attadmants Attactuenta ect Herbert Sachs Clyde Pyers Lowell Frederick (Additional comente may be placed on the back or on separate sheets of paper) Max Eisenberg "[ Wilson Horst (84 -024) Scrib Sheafor cc: pr. Max Eisenberg Signatures Michael Pugh William M. Eichbaum y,,,, . Office of Envirorpental programs organisstism 201 West Preston Street Address: Baltimore, Maryland 21201

~ 1 STATE OF WARYLAme e DEPARTNENT OF HEALTH AWB WENTAL MYEIENE g< 4 .[ MEMORAD UM 1,L -- -cw STATE op MastYt.Asso Dr. 8esu n==8=9 Frome DurM I M. 2/28/84 BF i yg m 8878s8887 or seafveat mesowacas j Draft Mlaumnt Dealig with %p=a andiation Doom - h Mi1* Pouuut PLasst arvens sacemass annov amatamevantions Sm@st Island sanclear staticm, Ohit 2 Ng og 7 g 7,,,,,,,,,,,,,,,,,,,,,,, '{ assensous siaos seeis asa ases gwSM M a m w statesment relates to omoon+=ia-tion arut *=r="' og we e resultarug frtaa the et==t at time h Mile Island WTm CCNTit0C putzunty 17,1984 e g skelear Station, Unit 2, has been WM W h W4 ND d n=M* inst Omtrol, Ptasar Plant Siting Program. *1Tue attached ressements a coordinated remiumme generated by both programs to the naaclear megulatory Dr. Berriard d. myder 8EALTM i 4 h 1== inn-It should be noted that both aguncies support the current .JroyaunTW w ) clean-up plan hansever, there are reservatione about the various alternativne ' Sees Mle Zeland Pragt'at Mfice } outlined in the draft. Mfies of Reclear BBactor b U.S. MacLear Ampalatory 3 on j ""'*8af= D.C..,3555 i IsJtscot j Re: Programmatic Enrironmental .****= ='* At+= *"'"' t related to escontamination disposal of radioactive wastes resulting frian unsda 28, ? 1979 accident three Mile Island Baclear station, must 2 Draft alppisemme nant tag with w u j Occupational Endiatica Does (MstBG - 5683, mustamme II 1 name Dr. 3rdera i Sugstenest to th-Programmatic myizonnental agact sta*==marThis lett es' on the i 4 j for the state of learyland for review of. cleanup activitiesr at ihree Mile As lead agency l 2algsul, the sauer Pl%t Siking Progma has coordinated State review of the Dqstemast. i 1 satryland's pruscipal'aoncera *=**=== to tie the hazard posed to its fuel, at three stLle Island.ppulation and reneuroner by thm & of hidt level was. In should Inayland's position has been that the " cleanup for== proceed as expeditiously as r==a-noy poenLhle to reduce the potential 5 = trolled relemmes of==d8=e*4ve unterials to the essrirn==r" (PE25, 4 i 1981). that pettien has not caimagne. } the. syidmace pe====*=d in the suppla===>. indicate 4 that the total i radiation egmasse to the work foram involved in the tut cleanup will be higher than origina11y estientes). IAnile we are <macerned that the yrinciple of hoogdag the abee to theos workers as low as ramsonably achievable be strictly astnered to, and the then reshctissa progran be yroperly enshamised, we note that the onens to the workers will continue to be within the federally allowed j limits of le Crn 28, that is no indivishal vorher will receive a atsee la excess i of 3 res per <3uarter or 5 res per year. 1 1 T tTVse,ones as-sess,ase.annaimmamess.as ens.ases i + i j t.

> _nis project raises taeues co'acerning compatibility with local plans or inter-governmental problene; however, a meettag with the applicant is g requested, go (Explain below) JURISDICTIOK'S CettEETS -This project is generally comeistant with local plano, but qualifying commente Cheek cae ere secessary. (Empleta below) _This jurisdiction has ao commente se this proposal. Comments ,f v nia project is consistent tutth er centributes 6e the fulfillment of local comprehensive plane, goals and objectives. This projec's raisee problems concernias compatibility with local plena, or intergovernamatal, envirmamental or civik rights issues and a meettag with the applicant g requested, nie project ralees problems concerning compatibility with local plane, or intergovernmental, enviremmental er civil rights issuess however, a meeting with the applicant is g requested. pM! This project is generally ceneistemt with local plana, het qualifying commente agn:33 TO LOCAL REFERRAL COORDINATOR Signature are necessary (ettach commente). Title Director. Planaiac atui Reeeerch k RETURN To Signature 4 bn Agency Saltimore city neelth Department Caerdinator Metropolites Cleartaghause Title M u al (D N t h W Reglemal Piemming Camacil i 2223 Berth Charles Street Agency M te d bwww t hn a Balts. ore. M.ryled alais a s g

Tams: Mr. Edmand Cuemaa DATE: January 25, 1984 TRdt Mr. Thomme C. Barris, Jr. DATE: January 25* 1984 Director, Planning Comission Director of Flanning County Office Building R F C Meeting: February 17, 1984 3430 Court House Drive R F C Meettag February 17, 1984 Westminster, Maryland 21153 Ellicott City, Maryland 21043 Joint RFC/CatSA Review Cycle (up to 60 days Joint RFC/DetSA haview Cycle (up to 60 days) SURJICT: REFCRRAL COORDINATOR REVIEW S139 TART

SUBJECT:

REFERRAL COORDINATOR REVIEW StastART ^-f ' ^ ^^ ^ ^ -ferral Source: Department of State Planning ^^^ '--^ Seferral Sources Department of State F1==atmT Freject: Draf t Supplement to IIS-occupational Radiation Does, Three Proje,ct s Draft Supplement to IIS-Occupational Radiation Dose, Three 4 Mile Island Nuclear Jtation Unit 2 Mile Island Nuchlaer Station, Unit 2 i l R & R File N ebers 84-024 R A R File lhesbers 34 034 Coments should be returned by: 1/10/96 P - te should be returned by: 2/10{84 This project has be.es forwarded to the following local departments or agencies This project has been forverdad to the following local departments or agenciso d (Check apprepriate blanks and attach comments from the reviewf ag agencies): (Check appropriate blanks and attach coments em the reviewing agencies): Planning Public Works Flamaing Public Works _ Environmental Protectico _Ihman Relatione Environmental Protectica teen Relatisms _ 0thers (Specify) Othere (Specify) i I 3= j ta N JURISDICTION'S CGetCETS JURISDICTICE'S CGRENTS Check Check One This jurisdiction has no comments on this proposal. is jurisdictica has no comments se this proposal. ] This project is consistent with or contributes to the fulfillaest of loce! This project is consistent with or contributes to the fulfillment of local comprehensive plans, goals and objectives. comprehensive plans, goals and objectives. _This project raises problems concerning compatibility with local plans, or This project ra'oes problems concerning compatibility with local plans, or intergovernmental, environmental or civil rights issues and a meettag with intergovernmental, environmental or civil gights issues and a meettag with j the applicant g requested. the applicant g requested. _This project raises problems concerning compatibilaty with local plans, or This project reisee probles concerning compatibility with local plass, or { intergovernmental, enviroceental or civil rights issues; however, a meeting intergovernmental, environmental or civil rights 1 assess housver, a meeting j with the applicant is E requested, with the applicant le set, requested. } This project is generally consisten; with I s, but qualifying coments This project is generally consistemt with local plane, but qualifying comments era necessary (attach coments), are necessary (attach comeste). v n _^ r, y J ,LM;w-RETURN 70: Signatur / s / A_ RETURN TO: Signature 7 Director Coordinator, Metropolitan Clearinghouse 7 e Coordiastor, Metropolitan Clearinghouse Tit Regional Planning Council Regional Flemming Council ' W Department of F1 mains 2225 North Charles Street Agency i 2223 North Charles Street Agency j 3altimore, Maryland 21213 Baltimore, Maryland 21218 g Date pobruary 6. 1984 3ste g 1 i j 2

s 3 TCt Mr. Thomas C. Nstrie Jr. Date: Faet Mr*. Robert S. Lynch DATE: January 25, 1944 Director of Flanning January 25, 1984 'J1 rector of Flanning 3430 Court nouse Drive 45 Seeth Main Street Ellicott City, Meryland 21043 Bel Air Meryland 21043 R F C Meettag February II, 1984 Joint RPC/QWSA Soview Cycle (up te.40 doyd Na FEMEC'T mm FCEM SU3JECTs REFERRAL C00RDINATOR REVIEW S M f " M '-- Seferral Source: Department of State Flemming -""' " " Aferrel source: Departasat of state Flaantas ' MAL PLANg-Proj ect: Draf t Supplement to EIS-occumptional Radiation Dose, Three FT83*Ct8 Draf t Supplement to EIS-Occupational Radiatici Dese, M IL Mile Island nuclear Station. Dait 2 Mile Island nuclear Station, Lait J gg R&R File Ihaber: 84-024 R & R File n ebers 34-014 i 8EEMA 9 comments should be returned by: 2/1;d84 Csemiente should be roteraad by: 2/10/94 _I J'heek One This project hee been forwarded to the following local departmante er egencies L.,,This agency has ao comenents on this proposal. (Check appropriate bleake and attach esmente from the reviewing agencies): X Planning Public W rks _This project is consistaat with or contributes to the fulfillment of local cceprehensive plane, goals and objectives. Xavironmental Protection hasen Relattens -This project ratees issues concerning compatibility with local plans or inter-governmental problems and a meeting with the applicant g requested. (Explata othere (Specify) ? below) Ca C3 _This project raises laeues conceraias campatibility with local plane or inter-governmental probless; however, e meettag with the applicant is g requested. JURISDICTICK'S C3DtEKT5 (Emplain below) Check One _This project la generally consistent with local plans, but qualifying commente are necessary. (Explain below) x This jurisdiction s.es no cesssente en this propeaal. Commente This project is consistent with or centributes to the fulfillment of local comprehenelve plane, Beal 6 and objectives. This project raises problems concerning campetibility with local plane, or intergovernmental, enviremmental or civil rights issues and e-seeting with the applicent g requested. This project reises problems conceratag compatibility with local plans, or intergovernmental, environmental or civil rights teouseg however, a meeting with the applicant is g requested. I This project to generally consistems with local plane, but qualifying comments g RETURN To LOCAL RETE 22AL COORDINATOR Signature W~ k f N J' M d * ********I (***** l Title RETURN 70: signature Agency Denare-ne er puu te m'k' Caerdinator, Metropoliten Clearinghouse Title Director Regional Planning Camac11 2223 North Charlee Street Agency Planning 4 Zoning Baltimore, Maryload 21218 mete 1/14/84

e. e -.

9B 22 l' REGIONAL PLANN! xG TO: Mr. Robert S. Lynch Dates January 25, 1984 ' *_ TO: Mr. James Noswell Date: January 24.-4986 q ---COUNCIL Director of Flanning Office of Planning & Zosing 45 South Meta Street NEE Bel Air, Maryland 21043 County Courts su11 ding 401 Bosley Avenue SF Tewoon. Neryland 21204 g St3 JECT: PROJECT REVIEW TORN 4tl SUEJE4T: PROJECT REVIEW F0Ett Referral Source: Department of State Planning "Fr '-, * --" " Referral Sources Department of State Flaaning i Projects Draf t Supplement to EIS-Occupational Radistica Dose Three i Mile Island nuclear Station Unit 2 Proj ect s Draf t Supplemet to EIS-Occupational Radiation Dope,_3res Mile Isalad Nuclear Stataan, Dmit 2 R&R File Number: 84-024 R&R File lhamber: 84-.024 Comments should be returned by: 2/10/84 Comments should be returned by: 2/10/84 Check One check One i This agency has no comments en this propose 1. X This agency has no commente en this proposal. _This project is consistent with or contributes to the fulfillaest of local -comprehensive plans, goals and objectives. This project is consistent with er contributes to the fulfillment of local comprehensive plans, goals and objectives. _This project ratees teenes conceraias campatibility with local plane er inter * -This project ratoes issues concerning competibility with local plans er inter. governmental probleme and a meettag with the ay11 cant 1,s requested. (Euplain governmental problems and a meeting with the applicant 1,,e requested. (Empleta below) below) 35 ) This project raises issues concerains compatibility with local plans or inter- -governmental p'reblaang however, a meettag with the applicant is g requested. g This project raises issues conceratsg competibility with local plans or inter-i o governmental problemog however, a meettag with the applicent is g requested. (Explain belev) (Esplein below) This project la generally consistent with local plane, but qualifying comments -This project is generally consistems with local plans, but qualifying comats are necessary. (Emplain below) are necessary. (Emplain below) Coments Comments Tnsuffielent time to review. When personnel is available 4 imoact statement will be reae artf come6ents made. Honefully this l can be done within the rient 30 days. k i a RETURN TO LDCA1, REFERRAL COORDINATOR Signatare \\. RETURN TO LOCAL RETERRAL COORDINATOR Signature I t' RAMED AB0rE p.g ( i RAMED ABOVE Director ~ j Title

• " i ra A A M4.,

Title waste f. Water cualitv unnmaement h% f {Aff17 cc: Mr. Ian J. Forrest Agency Health Department Agency L} Mr. J. James D1eter "*-' ac*aro ccuv. e .m _ 4

=% - $.s.g h eees, s eme== es a ,o e se.,m. eeeeeee. STaft oF MARYt.aNo k oEPARTesEu? oF e6ATURAL RESOURCES , qw t ,/ PowtA Plant idTasG,AT1o3B EWAGY AOudseSTR RoGJeans .g3g] h TAWES STATE oFFCI t= nema ansaarous 2 Hot oon m.am mv1SICN CF miryland is also concerried that the selection cf a clea. ;, plan coulc ,,, hCN CCNTfdC !struary 17,1984 3986 delay the cleanuo, we have reriaeed the analyris of the current clemio plan J* as well as the t.W altr mtives. Alternatives 1 and 2 would result in a delay of fuel rectal while resulting in no significant savings in wtional

.. Beard i @

naamegg %f exyneure. Because of this delay, and the fact that little or no &se savings ham IC9f" M* would be achieved, Maryland considers toth d these alternatives maccc; table. Orse l'ile Island Prograk Offlee Altermtive 3 any see awe attractive because of the projected recuction in m cf n2 clear anacter Regulation eScupational exposure without delaying fnel remoral. It hes, however, {.S. Mear Regalatwy hadan significantly delay the overall cleanup while relying on the inicertain 3*" M ME possibility that robotic clemmgs technologf any teczne arailable at same time in the futurai. Maryland is opposed to delefing even pst-fuel re: oral portions of the cleanup on the tasis of mere speculatist. related to deconh=nnation and dispsal of of Maryland fnces the current cleanup plan. ~ Per these reasons, the State Des Programmatic Enritormental Impact Statment radioactive wastes resulting fras March 28, 1979 accidmet Three Mile eIdaad nuclear Siner station, Dmit 2 Draft Saggalemmig namiing with Occuptional Radiation Dose (EIREG - 9683, Sqgalemet II /e, Mainistratcr %, g Nuclear Dralu,ations Dear Dc. Snyders Sis letter is to forward'the State of Maryland's r===nts on the ~ M mP. Ju:;te:er:t to the Progrannatic Emrircemental Engact Statment. As lead agency . Nh ecs for the State d.".aryland for review of cleanup activities at Three Mile o

land, the Power Plant Siting Progas has coordinated State review of the Cupi ammt.

t . David L. M 8"'*1 'aryland's principal cxmcern centinues to be the hazard posed to its ppdatzen and remurcas-by the gramance d high lerel wastes, including spnt

=el, at Cree Rile Island. Inuyland's psition has been that the

• cleanup s:xxld p:oceed as exceditiously as rensorably padhle to redace the potential for c2 controlled releases of radicactive materials to the enrizornent* (FEIS, 1S 11). ^:2t psition bas not changed.
• 2. cvidence presented in the supplement ir.dicates that the total

22::n ex sure to the wcet fcrce irrolved in the TMI cleanup will te higher

• tan criqinally estimated.

While we are concerned that the principle cf zeepu19 the cbse to these workers as low as reasonably achievable be strictly .cnered to, and the ese re&ctimi grograsa tm gro;mrly enstiasized, we note that

• e c: ores to tne workers will continue to be within the federally allowed li=:ts cf 18 CIR 23, that is rid individaal worker will receive a ese in excess cf 3 ran per quarter or 5 can per year.

TTY fee ones-Aaaao=6e JaMece weissagsen ases, arbones

I t 4~ e s Regiosul Plane ng Conant 222s Noveh Charin seren Bahnnare.htary.and212 s 3767 (101: 3a3-5a3a 32C10hAL PIANNINC CotttCIL Waker J ttomakryk,Jr. Ew tr eDmw RFC Heating February 17,'1984 g, J. Hush %choh, Osamese 2223 North Charles Stree.t .ita..r.. M., land m 1 MW AND RIyERRAL M Date: February 17, 1984 Froject: 84-024 Draf t Sucolament to Els-Occupational Radiation Dose. Three Mile Island Nuclear $tetton Unit 2. The EIS Belated to Department of State Planning 301 W. Preston Street Decontamination and Disposal of Radioactive Weste for the 1979 Accident at Three Mile Island Nuclear Station Unit 2 Baltimore, Maryland 21201 has been supplemented, Information indicates that cleerup will. entail more occupational radiation dose to the clean-up work force than anticipated.. Only cae of three additional , alternatives considered in t.he supplement would result in an appreciably lower occupational dose, but significant dis- , advantages are aerociated with this alternative. ,8fMF8 urce8 fepa y t of State Planning RE: Metropolitan Clearinghouse Review and Referral Memorandum, Project CGCtENT 84-024 Draft Sunlawnt to ris-The current clean-up procedure should continue as expeditiously occupational Radiat. .-se. Three g Mile Island Nuclear Station. Unit further delay the removal of radioactive asterials from the island, and would not significantly reduce the occupational State Clearinghouse # 84-1-294 esposure. Any and all additional funding should 6 a pursued to ensure the removal of contaminated asterials and N asged fuel. 3:= Den Mr. Eagers The recent IRS decision to allow tas deductions for utility contributions to the cleam-up fund to a step in the right A The attached review and referral memorandum is certification that the above

• -* referenced project has undergone review and comment by the Regional Flanning Council and a recommended action has been determined based on the Council's Recommendations EMDORSDENT IS errrlassrAED SUBJECT TO TBE ABOFE Cap 9tIXT3.

findings. Commments on this project were requested from: Anne Ar m dal County, Baltimore I utREST CERTIFT that at ice 234th aseting. held February 17 1984, City, Baltimore County, Carroll County, Howard County, Rarford County. the Regional Planning Council canestred en this asesen. sed materd Mesorande and incorporated it $ ate the edentes el that asettes. Comments from the following jurisdictions are included with the Clearinghouse 1**; Baltimore City, Anne Arundel County, Carroll County, Roward County. WatTER L K0WACCZYK, JR. We appreciate your attention to Metropolitan Clearinghouse procedures. If '*h

• " 17 f eM DATE E8"al 3

you have any questions, please contact us at 383-7110. Sincerely. 0 een Ibaret. Coordinator Metropolitan Clearinghouse Attachment Cane cown, reaeme Cowey reo weCasey $sse or t*s,maa san *oe C e, aaan an,nneecos*y sawee Cos*, s

Bechtel National.Inc. Eagaws - Consowcas Dr. Bernard J. Syndor

• * * * * * ~

February 29, 1984 s. m.v Page 2 eco om a+ r mpa. oav Teace e o n. mm om ag, m amm ATHB where dose rates were in the 5-10 R/Hr range were reduced to low mR/Hr by rapid dispersion and flushing of highly contaminated February 29, 1984 dirt from floor, walls, pump bases, etc. A particular example would be Auxiliary Sump Room where accumula-tions of dirt resulted in contact floor reading of 10-20 R/Hr with Dr. Bernard J. Synder waist high level general area of 5 R/Hr. The area was hydroblasted Program Director. TMI Program Office twice in succession and pro 3ect completed in less than one hour. office of Nuclear Reactor Regulation Total exposure for four men blasting, crew removing high rad debris, P U. S. Nuclear Regulatory Commission pad and support crew was < 1 person ren. Resultant room dose rate l Washington. DC 20555 was waist high of 100-200 mR/Hr iid floor contact of 3-5 R/Hr. Dear Dr. Synders These high readings are attributed to the sludge buildup in the sump approximately 3 feet below. Please review the following comments on NUREG 0683. Supplement No. 1 Draft Report. ITEM 1 FHB - 281 El Annulus Bleed Tank Cubicles In my collection of data and Information for this EIS supplement. Makeup Pump Cubicles A, B, and C I commented on the original numbers that were published regardin9 Decon Heat Vaults Auxiliary and Fuel Handling Building cleanup. Some were corrected. Containment Spray Vaults ), hewever. data on Page 1.4 Table 1.1, I Delleve is in error. 45 I cannot comment on the procedure and technique utilized in the con-h3 As Site Manager for VIKEM. I was very conscious of personnel radiation tainments however. I believe this statement should be clarified. exposure and maintained daily status for equal distribution of work and radiation exposure. Totals were constantly maintained, weekly Should you have any comments and/or questions, please do not hesitate summaries calculated and posted bi-weekly as Met-Ed crews had two to contact me at your ennvenience. week assignments at TMI. Sincerely, Please peruse the attached exposure sheets ar.d you will note they far exceed the published figure. For your

1. formation. they do not

[h,{ ~(( I include exposure for CNSI and Health Physics personnel who monitored t he c le anup. Valmore F. Bouchard My records indicated as follows: VFBacdw 1979 1980 Attachment VICEM 28.161 52.588 Person-Rem MET-ED 36.285 33.146 CATALYTIC 5.371 ITFM 2 l l Page 2.21 Section 2.21.5 Last paragrapn I cannot agree with the statement concluding high pressure hydro-blasting is not effective in reducing dose rates. Instances in

{ j g g y m Bang,ING BUILDING EIP050RE FOR DEcca ADEILIARY & FUEL BANDLING BETIIDING EIPOSM FOR DEC(Mi TTEIN EIP. (ar) PERS(BRIFL A9C. EIP. MT-ED EIP. (nr) PER$ M AVC. EIP. May 30 - J o e 30 9.919 118 84 Man mAan April 27 - June 30 13.424 U M"" July 1 - Sept. 30 12.982 W Dh* gg,g. 5,,,, 30 6.985 28 249 h a maan Oct. 1 - Dec. 31 13.384 36,285 159 84 Man mAan. Oct. 1 - Dec. 31 7.752 28,161 15 517 ha d e Jan. 1 - Feb. 26 7.988 65 122 Man naam Jan. 1 - Feb. 26 6.901 17 409 Mas naam Feb. 27 - March 3 831 31 27 Man mRam [ Feb. 26 - March 16 976 17 57 ha mRm March 4 - March 16 3.376 36 94 Man naam March 17 - March 30 2.610 21 124 Man mRan h rch 17 - k rch 30 3.207 32 100 Man maam ) March 31 - April 13 2.059 21 98 Maa mRam March 31 - April 7 1.592 31 51 Man maan April 14 - April 27 1.560 20 78 Man e 4 April 14 - April 27 2.765 32 86 Man mRam April 28 - May 11 2.072 16 130 Man naam April 28 - May 3.420 31 110 Man naam May 12 - May 25 1.655 15 110 Man naam May 12 - May 25 2.890 31 93 Man mRam N May 26 - J o e 16 1.407 17 83 """ " " h y 26 - June 8 1.302 30 44 Man mRam b J oe 16 - June 30 1.29, g7 77 Ma maam June 9 - June 22 3.605 28 129 Man mRam July 1 - Aug. 10 3.378 17 198 Man maan J ae 23 - July 5 1.562 29 54 Man mRam Aug. 11 - Sept. 7 5.695 18 316 Mas naam July 7 - July 20 2.666 32 83 Man nRam Sept. 8 - Sept. 13 642 16 40 Man mrem July 21 - August 3 2.515 28 90 Man mRan Sept. 16 - Sept. 28 1.419 12 118 Man mRam August 4 - Aug. 18 2.203 31 72 Man naam Sept. 29 - Oct. 13 1.473 33,146 13 113 he mrem August 19 - August 31 3.559 27 131 Man maan Sept. 1 - Sept. 14 5.324 32 166 Man mRam Sept. 15 - Sept. 28 1.201 24 50 Man maan Sept. 29 - Oct. 12 2.582 52,588 21 122 Man naam

3 .e i s AC1111 ART & ITEL RAIIDLIIIG BUII,DIIIG EIF05URE FOR DECON United States Department of the Interior EIF. (ar) FFR$0lgBEL AVC. EIF. OFFICE OF THE SECRETARY cATALTTIC WASHDIGTON. D C. 30000 AFRIL 27 - naf 17 5,371 23 192 Man mrem ER 84/45 ,.g i h 4 i Bernani J. Snyder, Preglum Dersetor Three Mile bland Program Office offies of muriser Remeter Resuistion U.S. N=elaar Regulatory Cosamismen Wasidssten, D.C. 20555 Deer Dr. Snyder: We have reviewed the draft seqqdement to the programmatie environmental impact statement related to decentamination and del of radiesetive westes rendting from the aseident on Mereh 28,1979 at the Three Mile Island Nuclear Station, Dauplain County. Pennsylvania, and have the fo5eunng conevirn. kt the besidet entitled ' Answers to questions about @ted estimates of oceupational radiation doses et Three Mine Island, Unit 2" there is a Drief reference to *a small chance p that the fuel condd begin a self --e = chain remetion* in the answer to Question 54 - (p.13L However, there are ne fonow-g questions on that important eonearn. The A muty of roeritiennity of the core is aise mentioned in the draft seqqdement (p. 2.14, A last line), but only briefly and parentheticeDy. This concern should be more fully addressed in the Anal aqqdement. We hope this comment will be helpful to you. Sincerely, , &,l - 'W Environmental Project Review e e .=9 -g

y. i l 1 l l ./ uussito sTAtts C0pO1ENTS ON ~, t peuCLEAR REGULATORY COMaelSS40N GPU NUCLEAR CORPORATION'S CLEANUP PLAN FOR TMI-2 AND e movisonv oonomTTat ose nsacTon saerouanos ON T5E NRC STAFF's DRAFT SUPPLEMENT TO THE CLEANUP i f answeevon. a. c-ammes PROGRArmATIC ENVIRONMENTAL IMPACT STATEMENT (FEIS) ACR5 $U8C0PetITTEE ON REACTOR RADIOLOGICAL EFFECT5 ( March 21. 1984 FE8RUARY 24, 1984 During a meeting on January 24, 1984, the Subcassiittee heard presen-tations by representatives of the NRC's TMI Program Office on the Mr. William J. Dircks Staff's draft supplement to the Prcgrammatic Environmental Impact Ezecutive Director for Operations Statement (PE15) Related to Decontaminrtion and Disposal of Radioactive U.S. Ihsclear Regulatory Consnission Wastes Resulting from March 28. 1979 Accident. Three Mile Island Nuclear Washington

• DC 20555 Station. Unit 2.

This supplement was issued for comument in December. 1983 and deals with occupational radiation doses associated with the. Dear Mr. Dircks*~ cleanup effort. On February 24, 1984, the Subcasseittee met again and SU8 JECT: REVIEW OF GPU NUCLEAR CORPORATIC4'S CLEANUP PLAN FOR TMI-2 AND was briefed by GPU Nuclear Corporation on f ts detailed Cleanup plan for TMI-2. Based on the above, we offer the following comments: THE NRC STAFF'S DRAFT SUPPLEMENT TO THE CLEANUP PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT 1. The TMI-2 GPU Recovery Staff appeared to be professional in their - approach, and they were thorough in their presentations. However. they do not appear to have on their staff (or serving as consul-During its 287th meeting. March 15-17, 1984, the ACRS considered the tants to them) an adequate number of people who have had prevfous reconsneedations of its Subcorsnittee on Reactor Radiological Effects direct experience in nuclear facility cleanup operations. The regarding the 'MI-2 cleanup. The Subcomunittee had the benefit of the Subcomunittee believes that the provision of such expertise would be presentations by the NRC's TMI Program Office and by GPU Nuclear "'I8 "I* I ? Corporation personnel during meetings on January 24 and February 24 I'O#* * " I* 2. The discussions of the cleanup at TMI-2 clearly indicated tnat Cs-137 accounts for a major part of the external exposures that are The ACRS approved forwarding the subcomunittee comments to you for your occurring. and those that are projected in terms of the collective consideration

• occupational doses for the total cleanup operation.

Accordingly, the Subcoenitee urges that GPU obtain the services of professional personnel expert in the chemical behavior of cesium so that they can effectively address the problems represented by this radionuclide. They apparently do not now have such expertise. 3. There appear to be several aspects of the recovery operations ha rma whereir a better understanding of the radiation protection problems and a better knowledge of more effective control measures would be Enclosure. Feb. 24 i984 Subcomunittee Coss=ents on TMI-2 helpful. These aspects include: Cleanup and Related Issues a. Nature of Airborne Radionuclides

Reference:

In connection with potential internal exposures of workers Prograscatic Environnental Impact Statement pelated to Decontamination within TP!-2 containment, there is a need to specify the and Disposal of Radfoactive Wastes Resulting front March 28, 1979 radionuclide corposition of the various airborne particulates Accident. Three Mile Island Nuclear Station. Unit 2 (Draft Supplement according to pamek size. Ns has not apparently been Dealing with Occupational Radiation Dose) NU#EG-0683. Supp. No. I. Draft done. yet it is essential to the assessment of the accompany-Report. 12/83 ing potential health hazard. The Subcomunittee believes that cc:

8. Snyder. TMIP0 L. Barrett. TMIPO H. Denton, NRR R. Minogue. RES

Ma ch 24*1984 c RE COPNENTS/TN1 CLEANUP 2 Dr. Bernard J. SnyderePr gram o Dir ector Three Mile Island Program Office RE:PEIS related to decontamination Office of Nuclear Reactor Regulation and disposal of r dioactive wastes a studies should be undertaken to more clearly delineate the U.S. NR C resulting fromMar ch 28,1979 accident nature of the airborne radionuclides. Walshingto:2, D. C. 20555 at TMI Unit 2 occupational r diation a b. Internal Versus Fxternal Exposures p, 33,, Workers enterino containment for decontamination and recovery It 1""r stated in NUREC 1060 that revised, inc eased, dose estimates "slightly r ise r a operations are ' currently required to wear full-scale protec-tive equipment, including respirators. Closer earnination of the chance cancer for the group {wo kers exposed to r diatkh in TMI Unit 2 a r the increased external exposures, because of the impediments clean-up) a a whole". Laused by the utilization of protective equips.ent, af ght show that it would be better to alter this approach (such as COMMENT: How can the NRC claim " slight r ises the chances of. cancer" when NO ONE a working faster without protective equipment). This needs Knows what the hitiating mechanism of cancer is? The Americad Cancer " society" is further evaluation. only now sta ting a su ver to attempt to find out if diet, wo k or other exposu e to r r r r chemicals and/or forms of radiation, heredity, etc., etc. could possibly be the trigger for the 1in 5 cancers ou " developed" socist y can expect. IF, aftesall thase yea s of r r collecting money to fight cancer and/or "to wipe out cancer in our lifetime", the mediaal expe ts still do not know WHAT causes cance, it seems beyond the scope of the r r expe tise othe NRC to c.laim that the rise in cancer r te will be slight. If the same r a of wo kers a e exposed to the new estimated exposu e, the cancer to be expected number r r r will rise propo tionately. e a e exposed at this higher estimated Ifasc mo e number r r r r diation exposu e, mo e cance a can be expected. Either way, there will be more a r r r cancer (s). Certainly the medical experts that now claim not to knowwhat trigge s r will be VERY reluctant to admit that r diation(ionizing) causes cancer, sf.nce a y cancer a r cancer for decades. Unfortunately omoting r <tation " treatment" fo they have been pr ro onetells the patient, enveloped as they a e in pain, emotionalto ment, and financial r r eatment" of r diaticas willinc ease their zum chances by 27 of c isis, that that "tr a r r developings a seconda y cancer as a result of that " treatment". r The inc eased r dention exposure, be it assessed to the estirated number COMMENT: r a of wo kers to cut individual exposure levels, must of wo kersor an increased number r r also take into account the synergistic effects of caetnicals used in this clean.ug.. The inc eased r diation exposure is considered only k in light of COMMENT: r a inc eased cancer. The aging processes must also be considered that give rise r to inc eased kidney disease, diabetes, and all the age-r lated diseases. Simply, e r the processes that cause reactor embrittIsment mest be transposed to human ambrittlement. IN CONCLUSdDN The assumption that there is a "natu al" r diation is falsg e a 4

$C1 Tire Street 2. Middletown. PA 1*0$7 April 1. 19 h Dr. Be na dJ.Snyde,Progr m Director. j Ma ch 24,1984 r r r a r Three Mile Island Pr gr m Office Dr. Sernard Srr/ der o a Office of Nuclear R eactor Regulation RE:PEIS -elated to decontamination Program Director. *:!IPO U.S. NR C and disposal of cadioactive wastes

• • 1. E'**
• y g Wa shington, D. C. 20 555

-esulting f om Ma ch 28,1979 accident r U.S. Nuclear Regulatory at TMI Unit 2 occupational-adiation C:smission dose,evisions NUR EC 1060 Washington. LJ 20$$$ natu al r diation" is based on measurements and/o. models and/o.. Dear Dr. Snyders TheEPA u r a assumptions that heada no JSE value in r eal life. The NAIURAL endiation of I attended the February 15.1984. ;IRC meeting at 741ddletown High the ea,th has been decaying, with the exception of added -adiation from School to comment on the Draft Supplement related to ""!I #2 cosmic sources, UNTIL the advent of the " atomic age". The MAN-MADE decon/defueling. r diation that hasis been acchulating in the environment since then is NCYT a "natur l", but man.c eated, so the EPA "intur l r diationa is incor r ect. Xy comments appear on pages 77 to 94 of the transcr.4 pts. In a r a a The only NATURAL r diation basis should be a declining factor in ea th's reviewing my notes it appears there is an omission of the text a r "Y enviamonment. But that ceased when man fir t began to extensively use coal s and then acceletpated when man sta ted "c eating" tr nsplutonium elements I asked Bernard Snyder why the licensee is not submitting the r r a r less fo ty yea-o ago That fact may well be the reason for the previously publicized plan for evaluating the possibility of mo e o r r escalating cancers and birth defects, in spite of our Padvanced" civilization. stopping decon work af ter the fuel is removed in hopes that recognized, we a e adding a human robotics technology will be available, in the future. With thirteen man.made isotopes now r (butnot humane) factor to the "natu al" r diation that has not been recognized r a Mr. Snyder said he could not answer my question. what it is.added r diation that is ny "natu al", but is countademt as such fo a r r ? in assessing risk / benefit of nuclea Unfo tunately the risk is assigned I find it very interesting that the State of, Pennsylvania would r activities. r r futu e gene ations, while the submit such a plan when for the past 5 years the licensee has h by those in power, and that risk is assumedfo r r .N * " benefit" is a self.inde ested factor of sho t te m du ation, to eithe-fulfill submitted these types of recommendations to the NRC. r r r r the" scientific" curiosity of a few individuals or sustain the jobs of those invdved I believe GPU and the NRO should be concentrating on one item-- in " managing" nuclear activities. the complete decontamination and defueling of TMI #2. Any thought of operating TMI #1 would be a serious distraction in terms of personnel and funding. I am very confused as to why the state of Pennsylvania will be submitting the proposal alluded to earlier and not GPU. For the record I feel it is necessary this be added to my comments 8 / and unfortunate the question was omitted from the transcript. NJM Sincerely., 3 4....

9. +

p g, y..pra*r'4. CNMN. Donald E. Hossler gy, p :--. ;.- "a a

• r2 ENERGT, BCX 2003 Yl. g;gg..T;IS RD.

gg% N.Y.12471 9404060276 940401 PDA ADOCM 05000209 H PDR

r f"% (A,g UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Cet411ed Coments of the Environmer'tal Protection Agency ) WASHINGTON. D C. 20460 on the U.S. Nuclear Regulatory Comisston's Draft Supplement No. I .w#y to the Programatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Waste Resulting from March 28,1979 Accident, Three Mlle Island Nuclear Station, Unit 2 (NUREG-0683, Supplement No. 1) M 2W axnnYaa aims 1. Projected collective doses to workers were estimated in 1981 as being in a range of 2,000 to 8,000 person-rem. The current projection increases ) Dr. Bernard J. Snyder Director the projected exposure to between 13,000 and 46,000 rem. In the Programatic three Mile Island Program Office Environmental Impact Statement the risk of fatal cancer frun the projected Office of Nuclear Reactor Regulation doses was estimated on the basts of risk estimates using an absolute U.S. Nuclea-Regulatory Comission risk projection provided in the 1972 NAS BEIR report. Risk estimates in Washington, D.C. 20555 the EIS Supplement are also based on these 1972 risk estimates.

Dear Dr. Snyder:

In 1980, the National Academy of Sciences (NAS) published new risk estimates in the NAS BEIR-3 report. Unitke their 1972 report, the 1980 In accordance with Section 309 of the Clean Air Act, as emended, the Biological Effects of Ionizing Radiation (BEIR) Comittee discontinued U.S. Environmental Protection Agency has reviewed the draft Supplement advocacy of 30 years as the duration of exprassion for radiogenic solid No. I to the Programatic Environmental impact Statement related to the cancers, as used in the Supplement. The Environmental Protection Agency decontamination and disposal of radioactive wastes resulting from March (EPA) has prepared Table 1, below. which compares 1980 BEIR Comittee 28, 1979 accident, Three Mile Island Nuclear Station Unit 2 (NUREG-0G83= estimates of the risk of fatal cancer due to occupational exposure with Supplement No. 1). This draft supplement addresses new estimates for those used by NRC in the EIS Supplement. The BEIR-3 estimates in Table I are for ages 18 to 65. We note that the NRC estimate uses a occupational radiation doses during the decontamination of the damaged unit. 3= mixed male and female population. Like BEIN-3, we have considered each The draft supplement does not consider the report of the 1980 National sex spearately. In fact, over 95 percent of the workers at Three Mile island are male. O Academy of Sciences Biological Effects of Iontzing Radiation Comittee (BEIR-3). EPA has used that report in Our review to compare the NRC health risk estimates to those derived from the BEIR-3 work. EPA suggests Like NRC estimates, the BEIR-3 risk shown in Table 1 is based on a that NRC incorporate the BEIR-3 work into the final EIS supplement. linear response model, designated L. L in the 1980 NAS report. The EPA This comparison and other coments are presented in the attactied detailed believes that a Itnear model is appropriate and not overly conservative coments. In keeping with EPA's procedt.res, we have rated this draft for evaluating risks at these exposure levels. From Table 1, it is supplement LO-2. seen that the NRC risk estimates are close to those obtained using the absolute risk projection model for males, but substantially below those Should you have any questions please call Dr. W. Alexander Williams obtained on the basis of a relative risk projection. (382-5909) of my staff. Table 2, below, compares NRC estimates of fatal concer due to a Sincerely, projected collective dose of 13,000 and 46,000 persons-rem with those for males based on the If near model in the 1980 NAS BEIR report. EPA

• g therefore believes the range of consequences due to the occupational f

y doses projected in the draf t supplement are greater than indicated therein. Allan Hirsch, Director Office of Federal Activities

r-t TA8LE 1 Table 2 Estimates of Fatal Radiogenic Cancer Among Make TMI Workers (8) Occuoational Workforce - Linear Resoonse Models for Exposures of 13,000 and 46.000 person-ren Estimated Fatal Cancers per 10* person-ren 'Model $ ingle coefficient tetC 131 BEIR-3 Absolute 163 Male 194 Average both sexes NRC 1.7 6.0 PEIR-3 Absolute 225 Female BEIR-3 Absolute Risk 2.2 (2.5) 7.5 (8 91 SEIR-3 Relative (a) 311 Male 359 Average both sexes BEIR-3 Relative Risk 4.0 (4.7) 14.3 (16.5) SEIR-3 Relative (a) 407 Female " E* "" I** (a)' Leukemia and bone-absolute risk; all other-relative risk. (b) This table multiplies the response estimates in table 1 by the NRC (b) This table shows the estimated number of fatal cancers per million estimated exposures to give risk estimates with the more recent rem exposure to a population for the indicated dose to response models. models for the indicated population. k@ d m

Bernard J. Snyder. 2. On page 1.1 ue recommend the typographical errors at the end of the first paragraph be corrected. Program Director TMIPO 3. GPU Nuclear issued a report in January.1984 uhich indicated projected occupational doses as follows: U.S.N.R.C. Dear Sirs Date of estimate Estimated occupational for decontamination please accept this letter as my 'commente upon the Draft Suppleaset to the 1980 10,000-40,000 person-ren TMI#2 Programmatic Ets. I submitted coments to the FEIS. Included in those 1981 9,000-24,000 person-m comments tore my doubts about the low exposures presumed by the PEIS. MF 1 16,M-28,000 persen-m doubts have shawa to be closer to the truth than the optimistic " reality" EPA recosamends that the fourth paragraph on page 1.3 be changed to reflect assuand by the NRC staff. There la no reason to believe that these mau q all of these estimates, exposures are still not optimistic, mad unrealistic. I an enclosing too itsee that the staff refuses to assess rumlistically.

1. sirconium fire'

2. upgrading of the polisher.

The chance of a sirconium fire increases the potential for esposures astronomically. If there is asirconium fire, much radioactive material can be loosed from the containment. The NRC has not looked at the possibility of a sitconium fire in an adequate aanmer. If there si a streonium fire and subsequent high exposures, not only will N this draft EIS be in error sbut also, livee will be endensered. This is only one area ttat is deficient. Because of those concerme, I respectfully roguest that the draft lie taken back and work be temporarily stopped until edequate p tection for workers is in place. Respectfully submitted, O h* M. I. LEWIS 6604 BRADFORD TERR. PHILA., PA.19149 m t _ m_

Chairman h111dino Commissioners cilinsky, Roberts,Asselstineand Bernthal, Sirs: In answer to the Petitioners concern A that "2irconium could have gone thru unknoun Please accept this latter an my petition for APPEAL & THE NRR DIRECTOR *3 DECISION temperature, time and hydrodymanic strese ptterns that could have easily harmed a of 2 ?.*-M denying my requent to postyne the headlift of TMI#2 for good cause. The normally resent non-pyrophorific oxide fila", the Director statee"(e2) the primary Director of NRR recently issued a denialcf Marvin Iawis' Request to postpone the system flow dynamica during the TMIp2 accident would not likely have trumsported Headlift of TMI#2(II) 8b4 2174) Due to deficiencies in the Director's D cision large quantities of pyrophoric material, if formed, to the top of the plenum." Petitioner asserts his right to appeal for good cause. The deficiencies in the director's answer here include Petititioner asserts that a headlift at TMI#2 can result in a fine whcih endangere a. the flow characteristico during the TMIp2 accident are still an unknowns therefore, workers and the public with zudioactive releases /. Furthee the work done by the any conjecture about where and what the fbu could have toen during the TMI#2 NRC staff and used as the basis for the Director's decision and denial ignores obvious accident is just that, conjecture. The " flow characteristics during the accident dangers and allows a dangerous headlif t without sufficient assurance for tie health and determined by the staff and repeated by the Director in his Denial is pure safety of the public arzi workers. The staff's research and experimental techniques demonstrat. conjecture and should be given no weight. incompetence, ignorance of sirconium properties, and purposeful obefucations. b. The concern that the accident conditione could lieve harmed the norum11y pesent Basis of Ntittwer's Pequant to stop Head 11fte oxide film is not explored at all in the Director's Denial. This concern is not Petitioner tased his request to stop headlif t upon three major deficiencies in the answered or even discussed. At a mialaua, the petitioner's concern about the damage staff's evaluation of the pyrophoricity ofethe sirconium Feeent.in the TMI#2 reactor. to the normally 3 resent oxide film should be discussed in the Director's Denial. A. Zircolloy has gone thru an unknown temperature, time and hydrodynamic strees

c. The Director states that"large quantities of pyrophorific material" would not have Inttern that could easily have harmed a normally 3 resent non-pyrophorific been transported to the top of the plenum. However no evaluation la forthcoming as oxide film.

to what amount of material would be needed to start or popagat, a fire to the B. The presence of hydrogen during the accident could have produced pyrophorific 3roperties. sirconius below the water line. Once afire starta, it could propogate on its own to f C. Contamination present in the accident could have increased pyrophoricity. the sirconium below the water line. Zirconium not only burns under water but does $ The Director's Decision mentions the above petitioner's concerns, but does not lay them so very well, once etarted out of wate:. This information is very necemeary and to rest. In fact the data that is used to answer the petitioners concerns increases the Commission should order that the amount of sirconium above the water line needed to the pe61tioner's concern as the argu.nents are very flawed and deficient. start a propogation of the fire to the sitconium below the water line be determined me Defielenelen and errnrs in tha Director's Dentale ratt of the pyroghoricity study at TMI#2. The most obvious deficiency is the slownese af the Director's Denial. Petitioner sent his letter in September 83. The Jensal was leeued on 3-24, over 6 months later. Under The Director also states,"(2) The presence of staam(i.e. an oxidising agent) the rules of the NRC, the issue of pyrophuricity use in limbo until the Director's would make it unlikely that significant quantittee of sirconius hydride in a pyrophoaific condition were produced during the accident." However The presence of hydrogen (Hattman Denial, not allowing Petitioner to bring any further action until the Director's Allegations), s e reducing agent, could easily have 3rodLced conditions favorable for Denial. This delay could very well have proven fatal.both legally and actually the formation of sirconium hydride. The presence of hydrogen in the RPV during the if a fire lud broken out at TMI#2 due to uncovering the come. accident is not discussed in the Director's Denial. This le truly unfair and a major The Director states that the " issue of pyrophoricity was addressed by the licensee deficiency to overlook obvious and continuing dangers. as prt of its underhead charesterization Study" and " extensively evaluated by the Also the Utrector stated, " Mix (ing ) with core debris... would prevent the developent NRC staff.." Although these studies were done, they did not answer this petitioner's of pyrophorific conditions." The petitioner has pointed out and the letters fr specific concerns. (See A, B, and C above.) ee 1x Cu1brannen have pointed out that sitconium hydride of ten becomes more dangerous when contaminated. The Director's statement on the contamination to prevent pyrophorific development ignores the empirical and comeercial hieteey of airconium. Contamination is used in the fireworks industry to produce airconium time delay fuses.

r- .no sampling technique to determine pyrophoricity is so devoid of basis that critique can easily sound like a harangue. Why only six anaples from the g core? How were these deter 61ned to be zwyresentative? Why only two "scrappings" scHoot or ENomatamo fron the plenum surface? Why are these representative? Was the problem of a fire t w eeu s,,,ca anne g.,, n, starting above the unter line and proposating to sirconium below the water explored at a11 either in expstment or thru research? How did " chemical analysis

• of filter selids Merch 2.1984 and scrappings determine lack of prophorific materials? What did.the chemical anlysis determine? Composition? Then give the composith a that was found.

How are the above testa regementative and what are they representative of? 6 4 r trace Philadelphia, PA. 19149 Dr Gulbransen's letter of krch 2, 190Ie. to earvin Iawis points out many deficiencies

1. "i

in the experimental technique. At aminimum. Dr Gulbransen's critique should be answered. I would also add that timing is very important in assessing the I received a copy of a letter to you by Harold R. Denton dated February 17, 1984 concerning your request to postpone lif ting of the pyrophoricity of sitconium. Zirconium left in aLrcan increase or dearense its reactor pressure vessel head at T.M.I. f 2 Power Station. Attached to ability to ignite. 7ttis depends on conditions such as time, tempenture and contaminants, the letter was the Director's oecision under 10 C.F.R. 2.206 denying I'"* **9"' I supported your request with a letter and a short paper some mention of the handling techniques for experimental samples is indicated and on the effects of oxygen, nitrogen and hydrogen on the sachanical not mentbned. These are all deficienties in the Director's Denial. properties of airconium. I would like to make several comments regarding the staffe review ? M of the pyrophoric reactions of airconium. 1

1). The airconium particles were identified as cossiercially available U1 Due to the deficiencies cited in the Director's Decision and denial of this N

of 62 microns or less. This is very indefinite. 62 microns Istitbners Request. Petitioner appeals his request and the Director's "enial is a rather large airconium particle, probably covered with an to the Commission. Titis is a dire emergenc' as thn waterline has been louered at oxide film and not very pyrophoric. Nobody ships pyrophoric TMIs2 and a fire is a present and likely possibility. 2) Th d us a f a icles are smaller 1.e. 3 microns and free from oxide films and other impurities on the surface. I have hade these ignite at room temperature. 700F in air. Respectfully submitted, 3) Fresh surfaces of fine airconitse particles or turnings readily ignite. These are the eine of particles and conditions I want g to warn people about. kQg k k /). j p [ 4) The experiments described in Mr. Dentan's letter may lead the uniformed to false conclusions. M. l. LEWIS I at glad you brought this question to the attention of the of fice of 6504 BRADFORD TERR. nuclear regulation. I am pleased that they considered the problem, but I don't PHILA.. PA.19149 feel they have explored the problem completely. Very truly yours. " )(Wd s - g H. ( g ags y ;c t ; p[s GL ' Sh2W5t'd Earl A. Culbrensen Research Processor see sENEDUM HALL PtTTSSUAGM en 15266

551N5 No.: 6835 IN 84-18 IN 84-18 March 7, 1984 Page 3 of 3 UNITED STATE 5 s break, and is nquW h ne Mant tecWeal specmcathns u k 0FFI F NSP N R MENT WASHINGTCN, D.C. 20555 operable whenever the unit is at power. Extensive stress corrosion cracking was identified during piping inspections. Unit I remained shut down untti mid-April 1983, when it was returned to power operation following repairs. Metallurgical examination of sections of pfping removed during the repair If INFORMATION NOTICE No. 84-18: STRESS CORROSION CRACKING IN PRESSURIZED effort disclosed extensive stress corrosion attack. A deposit of f ron omfde on WATER REACTOR SYSTEMS the inner wall of the pipe contained 79 to 110 ppe of chlorides, 114 to 204 ppe of sulfates, and 10 to 84 ppm of fluorides. The piping system was nomally stagnant and heat-traced to 180'F to keep the concentrated boric acid in solution. The source of the contaminants is believed to be impurities in the Addressees: purchased boric acid which were concentrated under stagnant, heated conditions. All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP). PWR accident mitigation systems are normally in a standby condition and hence provide a fertile environment for stress corrosion cracking. In addition to

Purpose:

technical specification surveillance requirements to exercise pumps and valves on a regular schedule, some Iftensees have initiated measures to recirculate This information notice is being issued to remind all holders of pressurized and test system flufds for potential contaminants to facilitate prompt removal of any identified contaminants. In this connection, Northern States Power Co. water reactor (PWR) Ifcenses and construction permits that PWR systems are susceptible to stress corrosion cracking in the presence of various corrodants. at Prairie Island is utfitzing ion exchange chromatography to detect the Information is also presented on actions which, if properly and conscientiously presence of potentially harmful contaminants and reports that this is a practical, effective tes.hnique. implemented, can significantly reduce the Ilkelihood of such cracking. ? Discussion: No specific action or response is required by this infomation notfCo. If you have any questions regarding this matter, please contact the Regicnal Admints-tyi w Stress corrosion cracking in befitng water reactor (8WR) primary pressure trator of the appropriate NRC Regional Office, or this office, boundary piping is currently receiving considerable industry and NRC attention. This circumstance may lead to an unwarranted conclusion that similar problems j do not occur in PWRs. The reactor enalant tvetem (W of a PWe Mt a hvornnen L_ overpressure maintained as an omvaen aettee durino power operation. As a Edw Jordan Director result, tne primary pressure boundary piping of PWRs nave generally not been Olvi n of Emergency Preparedness found to be affected by stress corrosion cracking. an Engineering Response Of fice of Inspection and Enforcement However, there are two Conditions where significant potential exists fJr inadvertent introduction of contaminants into PWR fluid systems. The first Technical

Contact:

J. 8. Henderson, IE opportunity is unacceptable levels of contaminants in the boric acid purchased. 492-9654 The second is the free surface of the spent fuel pool which can be a natural collector of airborne contaminants. During refueling operations there is

Attachment:

direct communication between the reactor coolant system and the spent fuel List of Recently Issued IE Information Notices o pool, as well as increased free surface to collect any airborne contaminants caused by concurrert maintenance activities. At Three Mile Island Unit 1 during the entended shutdown caused by the Unit 2 accident, sodium thiosulfate in some way was introduced into the reactor coolant system and caused extensive stress corrosion attack on the Inconel 600* steam generator tubes. The thio-sulfate solution was normally kept in a storage tank to be available as an

• Inconel 600 is an alloy trade name of International Nickel Company.

nemma

1" [] (' THE AovisORY PANEL FOR THE GECONTAMINATION OF THREE miLa ISLAND UNIT 2 c v.,g pg gvewoR / nogggi,pg E}^n/? Ss.g \\ 7 7g,(g is A f/fC6 &/* Eput/wrEA/ 7~ f TM/ 2 ma7^ ft/A S AT TM/ # / WWtAS A. Y /v Vo tl'EP w ~T H E ACC/DfA/[ NAP MOBJfpfs, Ax/p 75 7 W/s 947E ugios.Palladino 50 A/O T 4 P/AA'fA/M-f h*M t/P kMWk Q,h,",f,f*f,"C? N 8 Og 4/.556A/S t.#4 W/@ 8e:7 Dear Chairman Palladino (((/V//2g g/f/ ((Aff//f/4 /#M A/ During the April 12th meeting of the Advisory Panel on the Cleanup of Unit 2 at Three Mile Island, we again discussed the draf t b8 ~/7//t.) ///dd C# [kV

1. bp-Supplement to the PEIS.

The Panel offers the following comments on this document: 4E5/(4/~4/44-4e E /4A'ff [Af/

1) The staff should discuss fully the uncertainties in the cancer (and genetic) risk coefficient used to estimate the potential health effects to the

$ g/~ g gg46 M/[M f*I[8(( MN#$$G5 work, force associated with the cleanup of TMI-2. This discussion should reflect the range of expert T///5 p//E M 08 89t//#MYdI gg/f4 f /7,/ D opinion and any recent data that could impact the estimates of the BEIR Cousaittee or other advisory groups or organizations. /[jf7~/7 C4M M/[##/// /M/f FMI'4

2) The reported range in the estimated potential health effects to the work force should reflect f,

the uncertainty in the cancer risk coefficient f. as well as the uncertaiity in the radiation ex-posure to the work force. //5 [p{//f,;//gA/ 7~ /S 4 ,6 QTgg ?' Ro9 the Tan;9 in rotaatial c=**x*T ircifsr. e (morbidity) and fatalities (mortality) should be reported. WY $//O /S P f S C.< N U^S

4) The discussion of the uncertainty in the cancer risk coefficient and its implication regarding 64/ g g*#2 M

g / 6/. potential health effects should be summarized 2 in the front of the EIS and not just contained J[ in the Appendix. /G%

5) The statt should further examine the alternative i

of curtailing cleanup ef forts following fuel removal and gross decontamination of the reactor coolant system and reactcr building. The PEIS / g M4[84

Chairman Nunzio Palladino

1. h' April 16, 1984

'3,- Page 2 ,,,#M f states that increased risk to the public could be expected from this scenario. This alternative should be evaluated (quantitatively where possible) / with regard to the risk to the public associated W with leaving some residual radioactivity on-site ~ and the potential health impact to the workforce. Q The economic cost of the cleanup and the availability of funding and timing should be evaluated, if possible.

6) Cleanup plan alterntcives 1 and 2 would result in a delay ef fue'

-a-"al w!i's rssulting ir. ne significant M savings in occupational exposure. Because of this g7 delay, and the fact that little or no dose savings / will be achieved, alternatives 1 and 2 should not be d-adopted. I should note that relative to this comment, /4 g / that of the eight Panel members present, four voted in favor of this item and four abstained. It seems to me that more than four members may ag.ee with this / p opinion but the members abstaining did so because they g did not feel that we should be making a recomumendation to the NRC regarding which alternative to follows it was felt by those abstaining that comments on which f 4 y alternative to follow should be made after the PEIS Update has been finalized. 3 In closing I would like to offer the Panel's thanks to the NRC staff and the staff of the utility company for providing the expert people at our two Panel meetings which allowed us to better review the PEIS Update and make our recommendations. Pl. ease let me know if you have any questions. Sincerely,

0. t*L., f. W..w RTT [UROEC Arthur E. Morris, Mayor

[NCLLOW EO Chairman f) /f 76 7 j, g p AEM/dk cca Mike Mannik Members of the Advisory Panel l l

, g GPU Nwnew Cwpunha Attachment l' M[ Is,02T,'" dE -= 1 a %Q[,eanspaae sume. The discussion in Section 2.2.1.2, " Reactor Disassembly TELEX 84-23M and Defueling", needs to be modified to indicate that w,ne,s omioeinomt,; .although the PEIS supplement was written based on current conceptual designs, as more information becomes (717) 948-8461 available these designs may change. -Any change would need to be within the dose estimates contained ' 4410-84-L-0029 in the PEIS supplement in crder for that activity to stay within the scope of the PEIS. March 26, 1984 The discussion in Section 1.3, " Regulatory and Administrative Controls for Limiting Ocetpational Dose", should contain some explanation of the degree to which the NRC intends to 7?: -Pt ?!!! ss a :: !trsint 9.75 '"f7i.- li:9,2 as a:tritttis TMI Progras Office

• 4 a s a;..*: val : ;i:2 :;s !..:-2.:+ ::v+.7 c;;ic;;_as.

Attn: Dr. B. J. Snyder Program Director US Nuclear Regulatory Commission Althouch CPUNC concurs that the estimated occupational Washington, DC 20555 radiatica dose for the Tn:-2 recovery is adequataly scoped by tha 7I:3 su;;1a:ent, a::a :I tha tasi-a;acific ax; sure

Dear Dr. Snyder:

estimates may be low. For example, based on the historical expenditures listed in Table 1.1 for maintenance, safety, and Three Mile Island Nuclear Station, Unit 2 (TMI-2) sampling, Utility and System Maintenance could exceed Operating License No. OPR-73 the doses assigned to this task in approximately three Docket No.* 50-320 years which is a shorter time period than the expected Comments on Supplement 1 to the programmatic Environmental length of the recovery. Additior. ally, as shown on

=

;sct Statement Table 1.1, waste Management activities have already

= expended 183 person-rem with the greatly increased @[ The attachments to this letter contain 07Tr0's c==ents on amount of waste to be generated during the cleanup. the subject document. Attachment I contains general comments The total dose expended on *his activity could easily on une document. Attach ent : :--* ins sa:ti:n 3;a:if t: exceed the 485 person-rem listed as an upper range on the comments. dose estimate. The term "within the scope of the PCIS" has particular significance in the context of controlling If you have any questions or desire additional clarification, 1:ti"ities 1: TM -2. Theref:rs, in crder :: aroid any on any of the attached comments, please contact Mr. J. J. Byrne proolems wita detining the criteria for acceptance of a

~~ assif, specific activity by fitting it into a PEIS supplement task and determining how it compares with the PEIS supplement sincerely, for that task, the PEIS should state that its scope is the boundine person-rem doses and net the task specific doses.

,4 A " 3,- Aiditaanal-r, :he ;;;J 41. .11 als: s:A:a :a;: aa "?: :An /. ,, t authorize GPUNC to exceed the dose estimate for a specific task as B. K. Kangaf' long as the total dose estimate for the TMI-2 recovery Director, TMI-2 project is not exceeded. SKK/JJB / j eg A statement should be.added to Table 2.1, " Licensee's Attachments Goals for Dose Rate Reductien*, to indicate that these goals are only target values used as a basis for an CC: Oeputy Procram Director - TMI Program O*fice, estimate. They may not be attained and are not a Mr. L. F.. Barrett constraint for moving into another period on the 34C300CO31 32032b cleanup. Additionally, the periods listed in this PCR ACOcx 05C003 0 table are not consistent with the periods shown on ?C9 rigures 2.10 through 2.13 and as discussed in section ' Pa %c w C:t::ra:ca s a s.:1 r. 7 Crea 3.0 t us es : :: n::- 2.6.3.

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J 1.8 2 13 Change "the work" to read "each task". The following specific comments are provided on the Draft Supplement to 1.8 3 1 Change "done" to *perfnrmed"- the PEIS: 1.9 Figure 1.3 . Delete figure and replace with new Peg Paraeraph Cosuent figure from data in Attachment 4. Line Cover Sheet 4 9 Change "1700 person-rem to read and Abstract "1814.1 person-ren based on 2.1 Section 2.1.1 5 - Change "430,mren/hr* to "0.430 person-res/ self-reader data... required.. person-hour. 2.3 1 1 Change "140 mrem /hr" to."0.145 person-res/ 111 2 3 Change " August 1983 to " December 1983* 2.2 6 1-2 and "1700 person-ren" to "1814.1 person-hour". person-rem". These changes should 2.3 2 1 Change to read "...which is currently be made throughout this Supplement

its ?!!.

reached.. ". .3 2 4

.w ;e mir.izige< to eli=tnageo t,e,

11 1 15 Change "ther" to "their" and 'supplents. to " supplements". 2.4 1 1 Change "240 arem/hr" to "0.240 person-rem / person-hour". 1.1 2 5 Change " impact statement

• to read NEIS".

2.4 1 1 Cnange "110 ares /ne' to "0.110 person-rem / person-hour". 1.1 2 12-13 Change " August 22. 1983* to "Deceneer 31. 1983* and "1700 2.4 2 7 Change "120 mrem /hr" to "0.120 person-rem / person-rem" to "1814.1 person-rem *, person-hour". ? 11 3 1 Change " impact statement" to "PEIS". 2.4 2 9 Change "80 ares /hr" to "0.080 person-res/ m person-hour". c: 1.2 1.2 15 Change "280* to "310*. 2.4 2 9 Add: Dose rates on the reactor vessel / 1.a 1 2 Change "1982" to "19'3 serrice structure aters;ed 0.C55 person-ree/peson-heur. The 1.4 1 3 Change " August 1983* to " December 1923". average airborre activity within 1.2 1 3 Change '1700 persen-re ' t: "1112.1 the reactor buil, ding, based on 8ZA resal s, is 15.,.9C-c rs m r. person-rem". The radioisotopic mix is as follows: 1.4 Table 1.1 Delete table and replace with new Sr-90 6.5 MPCs table (Attachment 3). This revision Cs-13a 0.9 MPCs

-reides in':r stit- - t's es:: i'"

Cs-!!? 7.0 "'Os of TMI-2 tnrcagn tne eno of 1983 The data are more representative 2.4 3 7 Change the word " purified" to " processed". than those previously provided. It will be noted that the totals have 2.5 1 5-6 Delete: "Although..have been made". not changed significantly. Detailed descriptions of the exposore categories Add: "One individual descended to the and sub-groups are ava11rble from TMI-2 bottom step to collect a sample Radiological Engineering, of sludge from the floor of the 282-ft elevation. However, there are no routine entries made on this elevation at this tiee"

2.6 1 4 Change to read "282-ft elevation and above." 2.15 Section 2.2.1.1 Planning Department has issued a (Continued) Planning Study on Dose Reduction 2.6 1 g-10 Change to read 'The sump is not readily TP0/TMI-039. This plan describes accessible for dose rate measurements; however, samples have been collected both the overall program and details f,I 8"*II818'. some specific actions to be taken for dose reduction. The licensee considers 2.6 2 2-5 Delete: "The sludge...small.. this plan as the most representative source of information on their dose Add: "Only a small amount of the reduction program and as such. It radionuclides from the sludge should be the guideline in the discussions have leached into the on the objectives and goals of the dose decontamination water and have reduction program. TP0/TMI-039 was have been removed. Therefore, previously provided and should serve as a basis jon of the PEIS Supploent. Section source document) for the dose the sludge acts as a plar.e reduct source which contributes to t.ra ese rate." 2.2.1.1. Page 15. and Table 2.1. ..a

• sd e 2.2 Change "!"M ' to '1314.1'.

It snould 2.7 2 2 Change "done" to. performed.. 2.26 T M e 2.3 be noted tnat this change in person-res to date will impact on estimates that 2.7 3 14 Change " purified

• to " processed.

2.29 Table 2.4 have been made. Additional information 2 33 Table 2*5 is attached on systems in the auxiliary and fuel handling buildings that reguire 2.8 Section 2.1.2 20 The quoted estimate of 45.000 Kg 3.2 Table 3.1 decontamination LAttachment 4). 'It is of rubble and fines has not been estimated that it will take % 31.680 verified in any way. The document person-hours to complete for s 317 should reflect more strongly the person-rem. Appropriate adjustments ? fact that this is merely an should be made to the estimated m estimate based on engineering person-rem so that the total person-rem W judgement rather than a definitive values are not changed. number. 3.2 Ta W 3.1 No units are g M n. 2.10 3 1 Chane to read "of tne remainina 63 lead screws.. " 3.3 Saction 3.3 Data on health effects for exposure to 2.10 3 a-6 Change "A test.. head lift." to read ionizing radiation should be based on " Radiation measurements nave been the mst reccat scieatific work when made to determine the radiation it is available. Although BEIR !!! contribution from the parked lead (1980) and UNSCEAR (1982) were not screws." available when the PE!S was originally prepared they should not be ignored at this time. 2.10 5 6 Change " auxiliary and fuel-handling The NRC genetic risk estimator is very building" to " fuel handling building"- raf sleading. Since only a fraction of one generation will be exposed during 2.14 4 1 Change " schedule" to " program", the TMI-2 recovery effort, and since for finite populations the geometric 2.15 2 1 Change " schedule

• to " program".

mean of the equilibrium risk estimator actually overestimates the genetic risk. 2.15 Section 2.2.1.1 Revise in its entirety. In keepin9 it is more appropriate to use first with the licensee's Comitment to the generacToK risk estimators to calculate ALARA concepts and principles, dose genetic effects on progency. reduction is a major part of the recovery effart. To this end. the Director of IMI-2 established a Dose Reduction Task Force to evaluate and recomend a course of action. As a result of this e" ort, t%e Tecnnical

l J .9 1 t 3.3 Section 3.3 (Continued) .It is unrealistic to carry out the. ' 3.4 - . 5 4 Change "...(exclusive)..." to "...(exclusive...". . calculation for all time without et the 'same time providing a numerical estimate of the genetta disorders expected due 5.2 Add...Oose Reduction Planning Study. to the natural incidence. In the 1983. TP0/TMI-039". equilibrium case both parents are exposed and the denominator goes to . A.2 Add. James A. Flanigan GPUN$ Radiological I infinity, thus making comparisons Engineering". l impossible. It is appropriate to estimate incidence of genetic effects in progeny by adjusting for parental age sex of - the exposed worker, and also for the fraction of the 30-year generation exposed. The NRC should put genetic risk as-1 stien into :erssst W s. Sa a known population, it is roet aporopriate to use first generation effects and coopere with the 10% natural incidence in the general population. Statements which appear in Page 8.1 regarding the perspective of these risk estimators regarding natural incidence-need to be amplified and moved into _the main text. It would be useful to give examples of impacts using the TMI-2 g. population which will have occupational exposure compared to natural incidence. Examole: I worter s - eUects7 rg proceny7 = 2.6 7 T 260X10 8 Il0.000 workers 7 fl rem -- worter " -+ - S oared tc normal iec He-ca :f 1070 - in 10.000 progeny. 2.6/1070 - 0.25% increase over natural incidence frosi 1070 to 1073.

t is appropria*e to ~2s;1'j trise estimates by stating that if an older than average work force is involved and if doses are in fact,-

less than 1 rem per person on the average, effects will be reduced consensurately. p

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BIOMEDICAL METATECHNOLOGY,INCe 109 MAYNARD DR., EGGERT5VILLE. NY 14226 (716)-832-4200 February 13,1984 Dr.9ernard J.Snyder Three Mile Island Progran Office U.S. Nuclear Regulatory Commission Washington, DC 20555 9 ear Dr.snyder Since I have received a reminder notice on connentary for NUREC-1060 and -0583, it would anpear that ny intentions in ny letter of January 24, 1994 (and its enclosed letter) have been nisunderstood. This material was submitted as conmentary and this is stated in the first sentence of the letter. It was nv intention that this naterial would be used as nv connentary and I think this should be done. This letter is further connentarv. My point is that, as I had previously told !!RC, the eroosure estimates were underestimates by a factor of at least 10 and the rist estinates oer unit of exoosure are ch still underestinating the actual health effects by a "0 factor of 100. Thus the new estinate of 49,000 person rem for workers reoresents over 10,000 doublina doses for leukemta--a very serious hazard when the direct new risk ~ in the letter of Janitarv estinates of ny Yale oacer (cited 24,1994) are used in place of the obsolete indirect 3EI9 rists used by MRC. This nakes it inperative that '!9C recalculate the cost-benefit ratios for the two viable ontions here, renoval of the fuel rods vs. fiting then in concrete inside TMI-2 (*entonhment"). The costs of entombrent, both the dellars cost and the cost i,n genetic danage to workers and residents at fMI-2, are'oniv about 10% of the oroposed costs and the same ends are achieved with either ootion. It is absurd to endanger the oublic health and 5ankruot the utilities nerelv to preserve an P1RC requlation which certainly could he nodified in this instance to permit entonbnent, ve incerely y ' s, e .fge.t jftrw n 0.9 toss, .D. V oresident 31onedicti "etatechnotoqv,Inc. 8402210069 040213 CF SUBJ CF pf

Comments Received at the Feb. 15, 1984 Public Meeting ERIC EPSTEIN [Tr-17]: My name is Eric Epstein. I had sent a copy of four questions I had to you in certified mail, and never received a response, so this may be redundant to you, but I will address the questions to you anyway. I don't know if you ever received it or' net. [ Discussion] The first question I have is, in the report, you seem to maintain a link between lack of funding and worker safety, however direct or indirect. In a meeting I had with yourself, Mr. Dushare and Commissioner Ahearne last May, Commissioner Ahearne maintained that a lack of money has never been a problem. Well, it seems to be a problem, and I was wondering how you plan on attacking that problem, what pressure can the NRC exert on GPU and the nuclear industry to raise funds for cleanup of Unit 2, so that the extended radiation dosage to workers can be mitigated somewhat. [ Discussion] When you say " subsequent delays," and you correct me if I'm wrong, I believe ALARA in their safety code says what you had said before, cost-effective of economically feasible. What is meant by economically feasible or cost-effective? When you start trading off, you know, radiation exposure for cost-effectiveness -- [ Discussion] My second question is -- I'll paraphrase it -- the TMI site is not suit-able as a permanent repository for radioactive wastes generated by the accident, which I agree. However, there are few federal laws concerning interstate transportation, and there are new interstate compact laws which have arisen, and states which once welcomed waste are starting to have serious reservations. How can the NRC assure the public that these new developments will not result in a long and costly delay in transport-ing radioactive wastes from Three Mile Island? [ Discussion] I'm not talking about the history. I'm projecting into the future what would happen if things become more stringent about moving the wastes. I was just wondering if there would be any guarantees that the wastes would be removed, no matter what. [ Discussion] What I'm asking, is there any guarantees the NRC can give the people liv-ing around Three Mile Island that the wastes will be taken away no matter what? [ Discussion] Question three, again paraphrasing; a radiation worker may receive no more than three rem of radiation dose in a three month period. No worker may average more than five rem per year past the age of 18. I was just wondering if five rem a year is a high dosage, because I'm wondering if you take into account the background radiation somebody may receive. [ Discussion] A radiation worker may receive no more than three rem of radiation dose in a three month period. No worker may average more than five rem per year past the age of 18. I was just wondering -- it would seem that five rem a year is a high dose, since a worker may be receiving other radia-tion from background radiation from other sources. Do you feel that five rem is an acceptable dose per year for a worker at TMI, is what I'm asking. [ Discussion] A.63

Is five rem acceptable for a woman that is pregnant, in you opinion? [ Discussion] And also, you may receive as much as three rem 1n a three-month period. Is there any time period where you receive an excess? What I'm saying is, if you receive three rem in a day or if you receive three rem in three months, is that too much in the time schedule where you may receive a certain amount of dosage? [ Discussion] My other question, are there any studies planned to look at - more in the future to look at what has happened to women who may have been preg-nant during the cleanup or were pregnant during the cleanup or had been pregnant during the accident? Do you plan any studies of that nature? [ Discussion] Why wouldn't the NRC be doing that? Why would that be up to the State of Pennsylvania? [ Discussion] I'm talking about on-site. [ Discussion] Radiation doses received by women who may have been pregnant during the cleanup, and on-site doses. Why is there no studies planned or why have ? there not been studies? [ Discussion] Why do you have to look at detectable effects? [ Discussion] Is that an opinion, though, that the iose is not that great at five-tenths (of a rem], or is that an established scientific fact? .[ Discussion] Is it possible to look in another report and that report would say that that level is a damaging level? What I'm asking is, isn't that basically a duty you have? ~ [ Discussion] l E MARY O5 BORN [Tr27]: Mary Osborn, f rom Swatara Township. I have two ques-tions. On the chart, you show two to six additional fatal cancers. I 7 was wondering, how many people there that work get cancers that they will be living with? You only mention the fatal cancers. w T [ Discussion] I My other question: are the dose records that are kept on the GPU workers -- do they also keep records on, like, the people that I call sponges, that just come in and do cleanup work? I know that GPU is bragging about how low their doses are for the workers, but they don't seem to take into ) consideration all the other people that are not their employees. [ Discussion] E Do employees also get copies? [ Discussion] ? E JOHN MURDOCH [Tr-31]: Dr. Snyder, my name is John Murdoch, from Camp Hill, Pennsylvania. I have approximately four questions, addressed to various 9 members of the panel. Ms. Munson said that there were some remaining g unknown areas in the cleanup. I would appreciate knowing in general what those might be. g [ Discussion] 4 [ A.64

Secondly, you had said that various alternatives had been considered in preparing this draft supplement. Was entombment of Unit 2 one of those alternatives? And that has been suggested for possible study, suggested by the Commonwealth of Pennsylvania to the NRC, or is to be shortly. [ Discussion] The third question, and I'll address it to Dr. Snyder, is: has this draft supplement been discussed with TMI workers themselves? If so, where and when? And if it was discussed with them, did the workers express any particular concerns over the findings or the matters included in the supplement? [ Discussion] I'm compelled to make a comment in answer to that, Mr. Barrett, and that is, certainly if I were involved in an industry where my health was in question, I would want to attend any meetings to learn as much as I could about it. And if I interpret your answer correctly, it is that the employees do not appear to be overly concerned about this. Am I correct? [ Discussion) Finally, it was estimated, I believe, in this draft supplement that approximately 10,000 workers in toto will be involved in the cleanup before it is completed, is that correct? [ Discussion] The estimates of unfavorable results healthwise from that cleanup were estimated then in general as six to ten, in the ratio of those to 10,000; but is it not true that a number of those workers will be employed for considerably longer periods than others will be, and will be involved in more hazardous types of activities down there; so that a generalization of six to ten to 10,000 does not, to my mind at least, give a true picture of the adverse effects. It would seem to me that 5,000 or some other figure might be a more realistic approach. [ Discussion] ED CHARLES [Tr-37]: Ed Charles, Mechanicsburg, Pennsylvania. Thank you for leaving us have the opportunity to present some of our comments. Most of my questions deal primarily with something I found absent in the last environmental impact statement, at least in a quick reading. It is rather technical to me, but I find very little on the idea of transporta-tion mentioned. There's a footnote related back to the original environ-mental impact statement with the comments Linda made this evening. With the additional time, the additional entries needed, additional waste accumulated from clothing, et cetera, there will be a lost more trans-portation trips. Also, in the same line or related to the same transportation issue, the latest technology in the decommissioning or removing materials from the Shippingsport reactor requires a load limit to be shipped down by barge down the Mississippi River up through the Panama Canal to Washington. I am wondering, to remove that type of material from a much larger reactor than the Shippingsport reactor, how we're going tn move that type of weight limits. [ Discussion] Would it be timely or cost-effective to make those decisions now? [regarding ultimate disposition of the plant] [ Discussion] A.65

Is it a possibility?. [ Discussion] How is that decision made, and how far down -- [ Discussion] And that is approximately how many years down the road? [ Discussion] That gets into some of my transportation area. On 2.22 of the new environmental impact statement, all you have footnoted under the chart 2.2 is Waste Management and Transportation with a little footnote down to see the original environmental impact statement. There is no statement on the amount of transportation occurring. I don't see anything in the statement regarding additional needs for transportation of waste in the statement offhand. I might have missed it [ Discussion] But in your question-and-answer book, next to last question, number 94, truck drivers taking a 60 mile trip to Washington or Richland are receiving not above normal radiation, but they are receiving significant amounts. It says here, "For an extreme case, consider a truck driver who spends 2000 hours per year driving, half of that hauling radioactive material." He may receive various amounts of radiation on those trips to Washington or elsewhere. Those trips, even if they may be small, are not being added into the lengthy discussion I heard at the panel meeting the other night. Where does all this waste go, and is it being counted again and again as it's being packed, shipped, transported from one place to another? [ Discussion] So, -you're not using dose accumulations of people in Hanford or Albuquerque or Utica -- [ Discussion] Can you give me a number, roughly, how many trips to Washington? [ Discussion] I didn't see anything in the new one -- [ Discussion] Only projections in the original. '[ Discussion] Well, just a little calculation from your update, I have 219 loads plus 16 loads going to Washington at about $5,000 a trip. I have radioactive materials going from the island to 19 different states in shipments. I calculate roughly, by looked at a map plotting those various places, that that material has reached just about every state but nine in the United States. So, I'm saying, the waste is not only a problem in Middletown and Central Pennsylvania; ; that waste is being handled again and again, and where it ends up, how many times it's being handled -- [ Discussion] If it goes to Albuquerque - [ Discussion] I have 939 shipments leaving the island. [ Discussion] I'm referring to the log of waste transportation off the island. [ Discussion] That's not in the update, because there wasn't that much leaving -- [ Discussion] A.66

I understand, a lot of these are ve ry small shipments, samples. Nevertheless, it is posing somebody else handling that material, unpacking, testing, relaying -- Albuquerque, it has to be transported someplace else, a low-level waste site. How many times or much is this waste going to be handled before it reaches its destination? [ Discussion] You have 67 trips to Idaho already? [ Discussion] You calculate 400 trips; that's to Idaho, and in that it's being handled as research material. Therefore, it will be researched, handled, and then deposited someplace for a little bit of time? [ Discussion] From the mining to the end result, and to realize just the whole picture of -- not just the little picture of TMI, but the whole picture of this fuel cycle and exposing, researching, and how many cancers or how many genetic defects this whole process has -- [ Discussion] But that was not including the accident? [ Discussion: So, once it 1 caves the island, it's no problem to anyone else? [ Discussion] How many different sites do you ship to? [ Discussion] No, I'm talking low-level and high-level. [ Discussion] But right now you have, since the time of the accident, shipped to 39 different locations? [ Discussion) So, you don't feel any need for updating your estimates of the number of trips and locations and your upgrading of maps from the originals? BEVERLY DAVIS [Tr-50]: My name is Beverly Davis. I feel that we're getting to be on a first-name basis with all the people that are on this table, so I know at this point that you are all very professional and all very concerned and very human people. However, I find this whole statistical exercise very macabre and, I must say, obscene, because thinking of it in human terms, I'm asking really, if I had to pinpoint and point out -- I am going to say that there are going, to be six people, in Middletown, probably, or Hershey, that I'm picking out and giving a sentence. When I'm talking about genetic effects, I'm talking about not only this generation but many, many generations to come. And I find that the whole exercise as a commentary on the nuclear industry is a very inhuman kind of thing to do. Now, I realize your restrictions, and I realize your assignment. However, I have to make that comment. I also, after listening until midnight the other night to the experts in the field, I have to ask the question as to whether, when we get down to these figures of two to six fatalities and three to twelve genetic defects, if we're actually talking about only the middle of that bell curve, or have we somewhere in these figures accounted for these ends of the bell curve which are not as highly probably but are still possible. [ Discussion] A.67

I also was rather disturbed by the kind of discussion that was given there in that these were -- certainly some of them had to be, from the sound of the discussion, had to be some of the most outstanding experts in the country, the people who prepared the BEIR report, in fact. And those people admitted that they didn't really know. Their figures are based on Hiroshima and Nagasaki which, having attended the health con-ference last March here in Harrisburg or in Middletown, I find that those are certainly incomplete. And they're also based on some studies of mice, but they are not based on direct biological data of human popula-tions. I find it very disturbing to be making decisions based on that kind of data.. I realize that it may be inevitable and there may be no other way to do it, but I have to ask something, as very much an amateur. What ever happened to things like the Mancuso study, which were studying workers? [ Discussion] Well, I still come back to my original question about the Mancuso study, which - their discussion the other night really seemed to hinge upon the fact that there was that BEIR report, which is the one they mentioned most or seemed to be talking about most, which was based on a computer model. It was based on, as you say, geneticist's projections and so on, but it was not based on biological data in general. With studies like Mancuso, and certainly your knowledge of - pointing out that there are others, I don't understand why that is true and why we're making assumptions based on the computer models and projections instead of basing it on studies of workers. [ Discussion] The question, of course, in my mind is, why wouldn't there be -- I understand you're saying human populations. Obviously, Hiroshima and Nagasaki is a human population. But the rate of worker exposure would seem to be in this case so much more relevant or so much greater, that I would think that that would be the overriding kind of data on which you would base your conclusions, rather than simply on the broad, general picture which takes in a complete range of people or animals or whatever, you know, the hundreds of different settings seem to be. [ Discussion] One of the things that I find in the draft supplement, there was a flat statement made, and it was made again tonight, that obviously the island is a pcar place for storage of vaste. I wonder why they didn't think of that when they licensed them, but it is a poor place for the storage of wastes, and that therefore that's the beginning and the end of that discussion. But it seems to me that what we are weighing here is not I mean, we don't seem to be weighing simply how much exposure anything. We're just deciding whether to have this much exposure to workers or this much more exposures to workers in cleaning out this core. I'm not say that I know for sure, that I have a sound opinion on whether or not that core should be taken out, but it seems to me the discussion has not been fleshed out on whether we are making a choice that is really -- we have been told that that alternative is ruled out. I would wonder why we have not had more discussion about whether there is that much more danger. The reason I am concerned about is because Dr. Carl Morgan, when he was here last March, had indicated that he felt the cleanup should stop immediately, and that the only safe exposure to workeru was for the A.68

plant to be stopped at that point. That's a year ago. I have not heard other people comment on that, and I realize that there are obviously scientific differences of opinion. However, it would seem that maybe that discussion should be fleshed out a little so that if we're making a choice, that we would know exactly what that choice is. One. of the things in this statement that you have drawn into the supplement does indicate about thinking that half the core could be removed and the rest could be left there without danger of recriticality. The recriticality issue is one that we haven't heard enough discussion about, and I think it would be helpful. [ Discussion] Your statement about borated water being a crucial thing in keeping this from going critical again, there is a statement in this draft supplement which indicates that they were supposed to use deborated water. If you did figure out how to use water which did not contain boron, there was no discussion previously and I am wondering if I'm reading this correctly, and if there should be some discussion of whether putting deborated water into that highly radioactive basement poses a risk of criticality; also, what that would do, if indeed that is a serious proposal. [ Discussion] The last thing that I wanted to say is that I do not understand -- I understand you're giving a wide range, but I'm no sure you answered the question that was asked previously here, whether that wide range includes all of the raany scenarios which seem to be indicated but not spelled out in this draft supplement. There seem to be many, many dif ferent scenarios which -- each one is a building block. If this happens, then we do this; if this happens, we do this. Do you cut it up? Does it have a tolerance? All these questions seem to be remaining here. Does the wide range take into account the ultimate number of scenarios which might be suggested by the basic scenario which is put forth in here? [ Discussion) One last thing: this recent flap.over the Bechtel bill in the state legislatrure indicates that some of these companies and subcontractors would like very much to get out from under the liability which they should rightfully assume. Technicalities or not, it seems to me that that's a strong question, is it absolutely positive that the NRC's control of the ALARA and the ultimate exposure extends to all these subcontractors as well as GPU itself? [ Discussion] JANE LEE [Tr-64): My name is Jane Lee, Etters, Pennsylvania. I can't believe that after five years, we're still going to meetings. I've got meetings scheduled for every day this week in connection with nuclear power, every 7 day this week. Of course, I don't get paid like you do. I view this entire proceeding as a mere formality to fulfill the letter of the law, just as you constructed the EIS (phonetic), and just as I. knew when you used that as a guideline for what you're doing right now. Not too much has been said about the off-site exposures, those people who haven't volunteered to go into that plant and work. In view of the fact that you don't know the methods and procedures that you're going to use to clean up that plant, you therefore have no idea how much you're going to lose to off-site, the innocent victims who live near Three Mile Island. I s A.69 i

might state right here, too, that you're the same kind of experts who told us before the accident happened how safe and clean and cheap it all was. It's like ashes, not only in your mouth, but ours, too. So, you see, your credibility isn't any better today than it was yesterday or ten years ago. As for all those studies you talked about, Dr. Branagan, I know about some of those studies, too. I know how they skewered the reports on atomic veterans. I know how Dr. Tokahata (phonetic) skewered the infant mortality rates that he submitted to the federal government and very conveniently dropped 88 infants' deaths; and when an investiga-tion was never done on the huge increase in the crib deaths -- clustered, by the way, clustered in Lancaster County along with the hypothyroidism cases; clustered, by the way, in the exact same geographical location where the chickens are now dying by the millions because of a mutant growth. Incidentally, avian flu is a very common disease among chickens. The difference today is, it's now a mutant. And anybody, including many of our laypeople in this room, know that radiation will mutate. It will cause a mutant. Prove it? Of course we can't prove it, any more than we're going to be able to prove that we're going to be victims of cancer because of what you have donc, or are doing. I'm going to ask you a question, hypothetically. Supposing I was in an accident and I needed a victim to correct the accident, and I took the names of all five of you up there and put them in a hat, and I drew one of your names; and then I came back to you and I said very bluntly, "I'm sorry, but I have had an accident, and it's going to cost you your life." Now, ladies and gentle-men, what you're doing up there on that stage is determining who is going to die and who isn't going to die. This is a document of premediated 1 murder, that's what it is. In the most blunt terms, that's what it is. I cannot believe that we live in a society today that we parade before the world and we tell the whole world how free we are, and that we are concerned about human life; and then we promote this kind of monstrosity. The dimensions, the moral dimensions of your proposal are mind-boggling. You're willing to sacrifice unborn children, unborn children who have absolutely nothing to say, who will be brought into this world retarded, who will not be a proud individual, who will not be able to earn an income. How can you do this? Do you feel comfortable with yourself? Do you? There's got to be something wrong with a person's conscience some-where. Never mind me; as far as I'm concerned, I've lived my life. That's not important. I'm not pleading here for myself. I'm talking about a lot of innocent men, women and children, unborn, and you're willing to sacrifice them to just to boil water. That's all it is, just to boil water. And you come in here with your statistics; well, I've been down that road a thousand times, and you know what you can do with your statistics, because I know very well what the experts have done with the statistics. Do you depend on CPU to report exposure levels to the employees? Do you depend on GPU for those figures for worker exposure? [ Discussion] You are there when workers are being exposed? [ Discussion] You are right on site? [ Discussion] You know about some of the employees who sat in contaminated areas unaware that the area was contaminated? You are aware of that? That's A.70

even before your time, but I haven' t forgotten. My files are full of incidents at Three Mile Island where workers were exposed -- not five rems; way beyond. Don't tell us about worker expcsures. Don't tell us about your good, clean, typewritten pages and how neatly it's going to fit in to your proposal because we know better, we know better. And the idea that the Nuclear Regulatory Commission would still, after five years, rely on a company who has lied, who has been guilty of falsifica-tion of leak rates -- not just at Unit 2, but Unit 1 -- lied repeatedly about everything; and you think they're going to tell you the true dose of the exposure to workers? You really believe that? You're only fooling yourself; you're not fooling us, but for a second. Do you know if there are strict, accountable records of each employee at each nuclear power plant in this company and all of the dose rates that they have received in their entire life, the X-rays, the CAT scans, the bomb tests? Are they a veteran? Were they in bomb tests? Every dose is an overdose. Don't use the word " safe," Mr. Barrett. There's no such thing as a safe dose of radiation. [ Discussion] There is no such thing as a safe dose of radiation. Every dose is an overdose. Not only is it an overdose, it's cumulative. [ Discussion] I think you should strike the word " safe" from your conversation whenever you're discussing this type of a subject. [ Discussion] I asked a question. Do you keep records on the entire dose that a worker has gotten in his lifetime? [ Discussion] Do you agree that those doses are cumulative? [ Discussion] So that, all dental X-rays, all medical X-rays, CAT scans, anything at all that a worker is exposed to on the domestic scene is cumulative? [ Discussion] So that, we only compound the problem, do we not, by allowing workers five rems a year? [ Discussion] Do you feel comfortable allowing workers in there with that risk? [ Discussion] You think that's perfectly all right, to damage the genes of an individual who's going to pass that on to their offspring? [ Discussion] 1 hear you, but I can't believe what you're saying. Another thing that I found rather surprising, although at this point nothing really should surprise me, and that is the methods by which you intend to clean up the plant have not even been determined. [ Discussion] We still don't know the procedural methods, exactly? [ Discussion] We live in an era of robots. Have you considered robots in the cleanup? [ Discussion] Question 27: I would like to make a recommendation. "Do NRC regulations spell out how much radiation a worker can receive?" The response: "Yes. A radiation worker may receive no more than 3 rem of radiation dose in A.71

any three-month period. No worker may average more than 5 rem per year for each year past age 18." I respectfully request that the part of the sentence "for each year past age 18" be stricken. And I do that knowing how GPU operates, that you could juggle the figures, send them to work in a power plant at age 18 -- more like 35, 40, and so you could increase the amount of exposure to a worker and be within the letter of the law. [ Discussion] Well, if you believe'that, then you're a bigger fool that I thought you were. There isn't anybody in this room who believes that, including you, not really, you say what you have to say because you have to say it, but there isn't anyone' that' believes that. I've concluded my statements for this sham. That's what it is, a big sham. MARY MITCHENER [Tr-72]: My name is Mary Mitchener, M-I-T-C-H-E-N-E-R. I live here in Middletown, after the accident. I was very happy I wasn't here. What type of genetic changes do you think might occur, what basically, a couple of examples? [ Discussion] Such as without a hand or something of that nature? [ Discus'sion] Secondly, you have on there the table that shows different occupations and their dangers; and a fireman may be a very dangerous occupation. 'Down at the bottom, it says, nuclear workers, people working at TMI. A fireman doesn't have to worry about whether or not his kid and his child's child on down the line is going to have a genetic problem. Chesists might have a problem, I don't known, but firemen and a lot of other workers' don't have the unknown, and that is the problem here, that it is unknown. You cannot see radiation, you cannot feel it, and that is the problem. If.you can't trust people, like a lot of us here do not believe you can trust Met-Ed -- figures do get changed, because to somebody who doesn't read behind the lines, if you just looked at the surface and say, " Gee, this is a good job to have because it's safe." But you look behind the lines to your children and their children, it's not as it appears. [ Discussion] But don't you think there are other jobs that would be listed as much higher in occupational hazard as what you list nuclear workers here? And there really isn't any genetic effect. There is nothir.g that's as hidden as it is with radiation. [ Discussion] You also say that things are compounded, okay? Right here in Middletown, we got TCE in our water, okay? There's talk of EDB in food. It's all compounded. We have fallout f rom the tests in the sixties. We have fallout from the tests still going on, test's that now aren't as stated as they used to be; underground tests which once in a while leak like they did in '75, I think it was. It gets compounded. People back in the 1800's said, " Gee, look at this great big river. It isn't going to hurt to pour the wastes of this factory into it." And they did it and they did it and they did it until the Potomac was dead. Ten years ago, 15 years ago, the Potomac was considered dead. I went there with other people and we tested it. It was dead, okay? But 100 years ago, they said, " Gee, it's okay to keep polluting it." And the same thing is A.72

happening to our atmosphere. The same thing is happening to our water. And I'm.saying, it's compounded.. My kids have a better chance of having cancer 'than my generation and : the generation before them, not just because of TMI, but-because of the water problem, because of the problem -with food. And for you to sit.there and say, " Gee, it's acceptable," it isn't acceptable to me. And it's not acceptable to a hell of a lot of people who never came here. There's a lot of people who won't stand up here and talk, because they. don't know that it's so doggone easy. They don't understand _ you can read these things without being a scientist. And it makes me.very angry and it makes.ne upset that you drag things on. A, to stop people from coming because if you have meetings all the time, a lot of people aren't going to be like Jane Lee, and willing to come and willing to donate-their time. A lot of people like me who have four kids don't have that much time. So, if it's dragged on, it's not really fair to us. - You people have the time, because it's your occupation. I don't want it for - my second occupation, but I live near that plant. And people tell.me, "Why don't you move?" To where? Where are we going to move that there isn't fallout or radiation, that there isn't radiation from a plant accident or - it's not fair to us. And to say may, maybe we won't decommission it, well, I hope that it never comes to maybe that it won't be decommissioned, because I hope the people in this town won't stand for it ever opening again, especially Unit 2, because it was called the worst nuclear reactor accident, right, commercial reactor accident in i the country, correct?- [ Discussion] Then how come the Enrico Fermi plant, which also had a very bad accident, was shut down and decommissioned,-and they're still saying this one might run? Enrico Fermi in Detroit. -[ Discussion] Wasn't it also shut down. because if there had been another accident - there would have been more people : upset and the nuclear industry would never have,gotten as far as it has? And it's gotten on our backs. We pay - the taxes that..suppc t the dump that's going to be in Utah or wherever it ends up. We're-the ones who support it. Our children will support it. But really, we weren't told 20, 30 years ago what was going to be ahead of us down the line. You're talking about, " Decommissioning, we'll face,that problem when we come to it;" -it should have been faced =before the license.was given out. It's not fair to postpone it. It's just like the other things that were postponed and put on our children. It's not right. DONALD HOSSLER [Tr-77]: My name's Donald Hossler, from Middletown. I got i here kind of late.. I had a Little. League basketball game, so I didn't get dressed up. _ If I ask a question that may have been asked, please straighten me out.. When I received the. draf t in the mail, I started reading through it. And then I read in the paper where the Commonwealth -is going.to make a recommendation that other alternatives be looked at, and I sort of lost interest. But anyhow, I've got some of my notes here, and I just have a couple questions for you, really. .I note in the draft that you. talk about 10 millirems per hour as what you consider a normal dose rate'for a normal operation. I think they're talking about the 305 foot. level -- or is that for the entire reactor building? A.73 m

4

[ Discussion].

C And do you really'believe that eventually TMI-2, the containment bhilding - would eventually be gotten.down to 10 millirem? [ Discussion] 4 'Again, I understand that that's your. concern,.defueling and decontamina-I tion,'but you have : to remember that as a resident living in the area,,, ~

that 10 millirem per hour looks pretty good. After you've completed the

defueling and - decontamination, i you talk 'aboutt the marginal value o'f'the cleanup.,,I. guess you're talking.about robotics technology to try to get it.down'to 10 millirem eventually?

3 [ Discussion] On. page 2.5, i you talk ; about the 282 foot level, which you call the basement.: = It.looks like that is a very highly contaminated area, and it

looks?like :that's going - to be a very difficult area to really get at; Just making _ some commentsi as I look through-it.

Also on page 2.7, you ' talk..about the. airborne radioactive material that becomes redeposited on - clean, surfaces.. Are there cei tain areas that: were-being cleaned,- and -now you've. stopped cleaning them because of this? h,,~ -[ Discussion] s What specific areas, what foot levels of'the building are they going to ' decontaminate? _[ Discussion] On page 2.9,71t looks :like there's about seven foot of core area there that'sl unknown, something like that..What do you think is in there? Do - you.have any idea? y .[ Discussion] On:page 2.10,.you talk about-the uncovering of the-lead screws, that the ' handling of these"could be very significant'in terms of radiation dose or J -exposure _to the workers. Can you giveMme some idea of --_when you handle these,cdo you. handle them one at a time or ihree at a. time,. and what's the_ possible total' dose at ene job? [ Discussion] 'On.the top of page.2.11, it'looks like you talk about mechanically remov-1ing' fuel ~ particles from the-reactor; piping system. It looks'to me like -you're probably going-to leave the\\ particles in there for future-tearing . apart of-theLreactor piping. Is that right, you can't get to it? [ Discussion] On the. top ' of ~ page 2.14, what's really troubling to me, one of the L things,'is.we' read the glowing General Public Utilities reports that1 tdlk .about how well' the cleanup is going; yet I note in that first paragr.aph. 7 that, the auxiTiary )aod fuel-handling building still has major decon-tamination,.eff%rtswhicharestill' required. -You may not < be aware of it, s but I' know when - the utility talks of ' things, they usu' ally refer to the reactor building.. It looks like:it_is going to require alnajor effort to

get the halfway feed building decontaminated. - Sand th'en I go over to pa'ge.2.15, and I notice - that in tasks and sequencing that the last two items - ofi the five with large periods - - you sa', " reactor building and y

4 equipment cleanup, to_ proceed as resources allow," and then the next one, " cleanup of the auxiliary and fuel-handling building, presently underway, toncurrent with that reactor building work." What percentage of the radioactivity would you ' say -is 'in the auriliary fuel-handling building compared'to what's actually in'the containment building?. T s f ~ () i A.74 r ~ /g [ 1

[ Discussion] If 'its' a small percent, why -- it must be major decontamination because of-the~ cubicles-- - - [ Discussion]J They are hard to get to. ~[ Discussion] Would robotic technology be a good idea for those cubicles? '[ Discussion] .The fuel canister _s and particulate filters you talk about on 2.20, are . those readily ; available now,' and how many do you estimate -- I didn't - bring my final PEIS with me '-- but how many do you estimate will be necessary? ~[ Discussion] 1- .Would they be the same thing they might use for Shippingport? ~ [ Discussion]. And. particulate filters,- would you transport those in the same fuel canisters, or do you have-some way to transport those?

[ Discussion]

3 ~ Now,. I'm wondering, on page 2.23, the. third paragraph, how likely it really ;is that the immersion decontamination would be suggested by the licensee. I - know you do say that it. was not evaluated due to limited knowledge of its effectiveness.. I wonder if you just didn't through that in~ there just for the: sake of throwing it in.. Do you think it's likely, 4 that they.would want to fill it up with water and do some more processing on that magnitude? .[ Discussion] On page 2.31, I notice 'something that was already mentioned. It looks like the NRC may well be.willing to let half the fuel be removed and the ~ other half.t'o remain before you put it into what's considered a monitored .. interim storage. Would it be fair to say that? 4 [ Discussion] .The third paragraph on page 2.31, you talk about the fact that.only about . half the' fuel would have to be removed before the" chance of criticality would be inconceivable. Is that what that says? [ Discussion] Now, the next question would be, why didn't the licensee propose. the thing the Commonwealth is going to propose, _this other alternative? Why didn't the licensee i they seem to be proposing everything through the years. Why did the Commonwealth of' Pennsylvania have to -- E [ Discussion] Why wouldn't GPU advance that? [ Discussion]._ This ' proposal that the Conunonwealth is going to present, then, do you think this would decrease the need for immediate funding, or do you think .the funding level would remain about the same?. [ Discussion] The commonwealth's alternative. would not be accepted several years from jnow. so that actually the estimates for funding which we're looking at nowf uld probably be low. p .[ Discussion]

Finally, I.know you're all concerned about the cleanup, but I would just like to give you this scenario.

I know the push'is on to restart TMI-1. A.75 .A

T e p 'I ' know 'we ; are : not; here to; speak about that...But I think that one . consideration that those of.us-living around here through this, you know, ~ back in 1979 and 1980:- I remember.I went to the Forum. And you asked

ne, Dr. Snyder,'you said,."Well, Don, do you.want it cleaned up or don't you?" -I'said, "Sure, I want it cleaned up."

And now we're getting some .'different stories here about things getting ' lengthened out, certainly through no fault of-oura. 1 And one of the reasons why - when I started reading through the-draft after I heard about-the.Coimnonwealth's thing, I thought that ~. the possibility _.of getting. it completely cleaned up was ] being secretely considered or however you want to say it. The thing I want to 'just remind _ everyone about is that if THI-1L would ever restart, I personally. can see a : scenario _ coming about where GPU would say, ' "Gotta buy new-stream generators. We can't complete the cleanup until we've bought.new steam. generators and had them installed," particularly if the ftube problem does not work out like some people think it will. And I'd l -'just.like to relay to you that I believe we would be a hostage again if No. 31 were - allowed ' to ' start, because any kind of mechanical problems there, be they steam tubes.. steam generators or whatever, I could see GPU 'saying - and I. think you know that yourself -- saying to the NRC, "Well, we've got mechanical problems here with TMI-1,-and we have-to keep it in the rate base, because that's going to allow any cleanup." And so, all -of a: sudden, we're hostage again. And-I believe it's very important that t- - I know some ' of the ladies have used this idea before of the spilled ' milk. You know, when a child has spilled a glass of milk, you have to

get it clean'up.

If you don't, the milk might ruin the floor, the tile, a ~ orLsomebody might slip in it. Also, you really haven't taught the child how to handle things responsibly. I think people sometimes think of this ~ issue as a national nuclear issue. It really isn't, for me or for a lot of people. in this auditorium._ for the industry to prove that this can I think it's here in TMI. I think the thing we really want. to do is ~ really be. done. And we have to leave TMI-1 out of it. And I read the Harrisburg paper, ~ I guess 'in early February, an editorial the Patriot - wrote. on February 7. Tom Jerusky was saying about the Commonwealth's Lidea that if - they' were. to do' this proposal, that right about the time TMI-1 would be - finishing its operation, that it would - be time to take carei of c both the ' plants. I'm really surprised that the Commonwealth would come up with ' a comment like that. The point I'm trying to make [ here is that I think we need to just forget about TMI-1. You're probably sitting here wondering, why am I telling you this. I think the reason

why -is because you talk with the NRC staff, you-might talk with the f

Commissioners and maybe informally give them ideas on how the people e' -feel. I personally feel that probably about 85 to 90 percent of the anxiety about this whole cleanup'and everything would be gone if CPU and e its:boardtof' directors would'just decide to seek some'other way'to get THI-l-taken care of, working with the Public Utility Coinnission or some- - thing other than restartinh it. I really believe that. And I believe . that : we would be concerned about the cleanup; but I think you need to relay that for me to the. people at the NRC. I really believe that TMI-l ~ + is a tremendous stumbling block and has always been. And now that this cleanup is being lengthened, it appears -- and some cynics, I suppose, are wondering whether the fuel will ever get out; they wonder whether it will ever be completely decontaminated - it just is unconscionable, in A.76 x

~, - -. t ~ my= mind,1to: restart No.- 1 until the industry has really proven-that..TMI-2 x -cau be.'taken care of..'So, I appreciate the answers to some_of'my ques- -tions.. And ~ like I said,- in going ~ through, I was going to put_ something 1 in' writing. But when -I ' read the Commonwealth's possible proposal, it-sort'of stunned me.in a way. I was~very~ surprised. -But I wish you would carry-that message back to the NRC.- t[ Discussion]' .

• ELIZABETH [CHABEY[Tr-94]:

My name is Elizabeth Chabey. I' have been ' approached many -' times by people who live nearby, and they would like to know:what would happen if.the ultimate' test of the crane fails.. -[ Discussion]' ~F We'd'also like to know-if the public will be notified when this ultimate istep is taken. S' [ Discussion] 1Do you think'that'this possibly could be scheduled for~a. weekend, since our emergency-evacuation crew said that the only time that they could

really; function >is on a weekend?'

[ -[ Discussion]- ) JANET LEE ' [Tr-96]: - Will we be notified in ' advance [about the polar crane

test]?

[ Discussion]. i ~ ' PAUL 'SHOOPJ [Tr-97]: I'm Paul.Shoop, S-H-0-0-P, representative of the Inter-' . national. Brotherhood of Electrical Workers. I know the International ' Brotherhood of Electrical Workers'is concerned. We have members not only-4 in our. utility branch - :which~the local. union is here in Middletown -- . hich - is. located in we - also have members in..our building trades, w .Harrisburg.. The members-are concerned. They; have reviewed the 3_ supplemental PEIS. As you. stated earlier, you don't' hear a lot from the f . workers. They are very well educated. They are very well. trained. They know :what _ they're' doing.. They're ' not - very vocal when things like this meeting come about. However,'they do raise concerns. I am here because they ' arel concerned,- and they. requested that - I be. here.. The IBEW has 'about 11,000 members permanently _ assigned ~ to 'all ' the _ nation's operatin;; We ' have i tens 'of thousands of members: in the building power reactors.~_~ trades, from. vendor' specialty. crews, and members of the utility and other sites that rotatei hrough -the plants for major maintenance or refueling. t I 7 The IBEW is very concerned about the. exposure ' they get. The greatest hazard to the IBEW member is not radiation. It is not a lot of the _ things that.they have in there.. The biggest threat to.the'IBEW member is Every year, between 40 and 50 IBEW members are electro-electrocution. . cuted on ~ the ' job because of. one - reason. - we work equipment hot. The public demands uninterrupted ' electric service. We pay the penality, because of what society wants..We know what risks are. This is the risk that we ' pay, we - forfeit with out lives. So, w'e do understand risks.

Society wants lus to work equipment. hot so they have. electricity; they have electricity. Society _ demands that as radiation workers that we work

.in. radiation fields; we know that we have to receive radiation. Compared ~

with electrocution, all other threats pale.

Another way of 'looking at the ' total man-rem --' and pardon me, ' I still use " man-rem" instead of I A.77 4

." person-rem;" I've never been converted -- if you look at the man-rem for 1982, the ~ last published figures from the NRC, it was slightly -over 50,000 man-rem for all power reactors. The projected max for the nine year period is about 46,000. So, we are talking about the same risk to radiation workers in power reactors for the nine year period as we have during 1982. Another way to break that over -- you know, it's not going to be even increments over the nine years -- but if you look at the highest record man-rem for any station for 1982, it was almost 4,000 in Quad Cities. This, on an average over the nine years, it will be about 5,000, so they're somewhat equal. It should not be any greater risk at one station than at the other station. You're going to have a large ' number of people involved. Again, just in the supplemental PEIS, these are estimates based on the best you had available to you at the time. We will not be surprised, we would not be shocked if you have to revise the figures upward. We know these things. happen. You get in there and get better data; it could go up or it could get lower. If robotics come in, if -- and we're not counting on robotics coming in within the next nine years -- if it would happen, exposures to people would be a lot less. Robots can taken an awful lot of exposure. It's not unlimited, because they're electronic, and certain things happen to electronic devices because of. radiation. Worker are concerned. You don't often hear us comment on it, but the IBEW members in the building trades, the IBEW members in the utility branches in the area who are going to be doing the work there are very much concerned, and they have reviewed it. We can work - with - the figures that they have. And incidentally, we're not sponges. All. exposures at all power reactors are ALARA. This is one thing -- you do hear from us when we're convinced that they are not ALARA exposures. So, the 52,000 man-rem we had for 1982 were all ALARA. I am convinced that all the exposure for TMI-2 cleanup will all be ALARA. MARY OSBORN [Tr-100]: _ My name is Mary Osborn. I have a comment to make regarding Mr. Shoop. I had a friend who was an electrical worker at TMI. He quit before the accident, the year before. The reason why a lot of union people do not come to these meetings is fear of being blackballed by the unions. When people work 10, 12 hours a day, seven days a week at a _ nuclear _ power plant, you become fatigued and then you become electrocuted. Another thing -- before the accident, the men who worked -there didn't wear their badges. They had them in their boxes. So, a few things have happened and a few people have finally wised up. But it's good that the man was here to speak. But the men are not here because they don't want to learn -- they're afraid to show their faces because of all the harassment they get from the unions. I have a lot more to say, but I'll say it elsewhere. A.78

C_onunents Received at the April'12, 1984 TMI Advisory Panel Meeting BRUCE. MOLHOLT [Tr-112]: -My name ;is Bruce Molholt. I'm a Ph.D. I teach . genetics ~at Bryn Mawr' College.- I have done cancer research in the past, 4 and I am presently doing research. on-the molecular mechanisms of muta-- genesis, in DNA. I' appreciate the opportunity.to represent at least one segment of public opinion in the Panel discussion tonight; however, I . don't ' think this. is a very efficient forum for expression of public opinion, in that it'seems to.be more of a dialogue between the Panel and the NRC. :Therefore, I will?try to-limit my comments. I certainly will nct reiterate the written. comments that I-have already submitted to the NRC. I will just try to comment in terms of perspective, at least my perspective on what I've heard tonight. And one of the reasons I want to limit it,-too.-is that I, among my teaching obligations, have one early -in'the morning,'and that means that, like many of you, I'll have a tight schedule. I heard and read the expeditious cleanup philosophy supported in; terms of the NRC's mandate, again and again -- and I believe I'm quoting' from a number 'of sources, because it's reiterated -- as "to L . ensure the long-term health and safety of the public." Now, that particular rationale to support expeditious cleanup has a deja vu for me, because I heard - the same things being said four years ago, when various alternatives to decontamination of the containment building atmosphere were being considered, and, again, the rationale was for the health safety of the public, what would be the most rational approach. I 4 .believe that the approach that was taken at the time, supported by the .NRC staff, and not contested by comments to the environmental impact .thereof was in released beneficial consideration of public health and safety, and the rationdle was a strange one, and I believe has bearing on what we are trying to consider tonight, and what you've been considering for quite 'some - time. The rationale was that perhaps these materials

inside the containment building atmosphere, which were mainly, at that time, Krypton-85' gas about 43,000 curies of Krypton-85, that those

' materials : might - accidentally leak out and cause some type of harm; therefore, expeditiously, they were intentionally released into that same atmosphere over a two-week period, without much regard for meterologic conditions, although the Environmental Impact Statement said that those conditions would certainly be monitored. I see us in the same position now, but with a much more serious potential public hazard; and that is, we are expeditiously recommending decontamination of, not any longer r 43,000 curies, but a half-million curies. Now, I'm going to direct almost all of my comments to the core cleanup, per se, and hope that at the end of - my comments I might have time for a few questions that, partially may be - answered by the NRC staff and partially by members of the Panel. The half-million curies that are in the core include all of y the fission products of uranium, include many byproducts from neutron bombardment and other radiation of cladding and other reactor components, i include 150,000 curies 'of plutonium, and I believe there has been a somewhat cavalier assumption that defueling of that contaminated core is going to proceed in some manner or fashion similar to what defueling connotes; that is, an efficient underwater removal of 177 fuel packets in easy-to-remove, bundled form. The condition of the core, of course, is quite a bit different, much of it unknown. No probes, as far as I know, have been taken lower than four feet above the bottom -- that is, the exact condition of the four feet of rubble on the very bottom of the 4 A.79 i ,, ~ ~, -. - -.. -.. -, _.. -,. -,. -,, - -, -, -,, - -,.

=- D . reactor _ vessel is still an unknown entitity. As far as I know,'all . evidence indicates that there is not one fuel rod that has sustained the thermal shock at the time of' the accidmit, and there -is every reason to believe thet 90 to 95 percent of the fbtl is crumbled, fused and in one coherent mass, that:would be rather difficult to remove from the reactor vessel. Now, I-would like to address some of that difficulty in removal -a little bit-later. But my - point - is this. If. the rationale for expeditious removal of-that core is to protect the public, is to protect the public health and safety, then by no means should we start to do that operation prior to understanding whether the head and plenum are warped that once we open them we will never be able to reseal them. Indeed, we find scenarios more difficult than the worst case scenario that I see in the supplemental PEIS. Secondly, if we find that the fused fuel in the bottom of the core is in such a state that it requires excision by either robotic or manually operated separated devices, that will entail much more than the -- as I understood it tonight -- 500 person-rems in 1984 for beginning that operation. If we find that dissection by sawing or acetylene torches, or whatever devices will be used to separate that core underwater, in order to ' remove ' pieces of it, is considerably more complicated than I see addressed in either the original or supplemental Environmental Impact Statements, then I would suggest that it is not in the best interest of the public health and safety to start removing those pieces, but that, indeed, the public is in danger for exposure to that whole whooperie of radionuclides that exists within that core material. In addition, as has been brought up before, there is no safe repository for that material at present. So I -- if that's the only reason to be aexpeditious, I think it is not in the best interest of public health and safety. Now, in order to help me to assess whether that is the reason for expeditious approach to the core cleanup, I have a few questions that I'd like to ask, if the Chair will - tolerate these ' questions. I'm addressing them to anyone who is knowledgeable about the nature of the core at present. [ Discussion] The first question is, is the danger -- is the core, at present, in ' danger of assuming recriticality. [ Discussion] So, as I understand :t, then, the possible recriticality.of that core is not a reason, then,'ior expeditious cleanup. Is this correct? [ Discussion] I also understand that one curie of Krypton-85 is being released from the TMI-2 facility per day, on an average basis. Is that correct? [ Discussion]. Is that per entry, or is it just --- [ Discussion] per day? [ Discussion] Okay. My ~ rough calculation shows that if one curie of Krypton-85 is being made -- and I believe that can only be made through the fission -process -- that that is equivalent to abut.2 percent criticality. So my [ Discussion] l A 80 l l-u

c -

My physics tells -- and you're the physicist, Dr. Cochran, but my physics tells'me that if this were residual, that you would not have a constant amount on a daily basis over such a protracted period of time. Plus the fact that Krypton-85 would be eight time -- I believe eight years - or is it.8.3 I'm sorry; I don't remember that.-

'[ Discussion] And I vould - assume that both from the_ standpoint of decay and from the standpoint. of ' pollution operations, bleed-and-feed type operations..as was : used in venting, that the amount per day ought to decrease quite markedly,: but it _seems to be steady. The real question is has the -- has the, core, in its present~ state, any portion which is not being protected from neutron bombardment and, therefore is in a critical or sub-critical state - [ [ Discussion] Nov I'd like to return, then, to the issue of publiv health and - safety . with respect ~ to decontamination of that core, and ask a few more ques-tions about how the various ' portions of the core are to be removed. I understand that. the _ process will.first require removal of particulates from the primary coolant, feed a filtration apparatus, part of a filtra-tion apparatus, and then the soluble radionuclides will be removed by the submerged demineralizer system. My comment, then, addressed to the - what - happens to that particular filter, double-filter system, upon dissection of the core, upon dissection of, ~ like 100 tons of fused material?' If appears to me - and I must admit that I'm looking at this in a lay capacity - it appears to me that for every dissection operation of-that fused core, that you're going. to release many more particulates and many more soluable radionuclides into the primary coolant, and that -this. operation may take longer than visualized in either the PEIS or its -supplement, and that this will result in much higher worker exposure levels than found in the supplemental PEIS. [ Discussion] Each time that there is a dissection operation you're going to have this cloud of particulates re-entering the primary coolant. [ Discussion] Are you 'taking up the primary. coolant?- No. He's taking up the par-ticulates that are released that have crumble sides. You think that the vacuum operation will be able to remove all those particulates? [ Discussion] I-feel that we're working in a arena of uncertainty, because this type of cleanup operation has never been. [ Discussion] Well,' _ I think I can - save the Panel some time by just merely making a conclusory statement;. and that is that I keep hearing answers of certainty, when-it's at least admitted throughout the document I have in front'of me, the Supplement PEIS, that there are huge uncertainties, and I don't see those uncertainties taken into account in getting a range of dose estimates. The condition of the core is now know in much more i detail,'although, certainly, not by any means well e ough, compared to what we know at the time of the final PEIS, which was previously issued. That caused the approximately six-fold increase in worker exposure in the supplemental PEIS. -My caveat is that'I don't think we still know enough to dilemma what worker exposures will be. And I endorse the Panel's A.81 l .. ~. n

I discussion heretofore of what those final. person-rem exposures will be, and I'm suggesting, at the moment, it's whatever the range will be ' conservative. I endorse the Panel's discussion and the recommendations .that -.those person rems be translated.with a _ wider range of uncertainty into human genotoxy editions, either carcinogenic or mutagenic. I have a lot of'otherifine point questions, but I will not belabor those. _I guess .I still have time to put down some of those.into another final statement .by. April 20.- Thank you. A I ' A.8i m m

7__ APPENDIX B CONTRIBUTORS TO THE SUPPLEMENT i

r. . APPENDIX B CONTRIBUTORS TO THE SUPPLEMENT

The overall 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 Pacific Northwest Laboratory, and other consultants , indicated. below.. The assistance of GPU. personnel, particularly James A. Flannigan', is. greatly appreciated. - The individuals who were major contri-butors to the Supplement are listed below with their affiliations or expertise:- NAME -AFFILIATION FUNCTION OR EXPERTISE NRC Ronnie Lo-TMI Program Office Project Manager ' Bernard J. Snyder TMI Program Office Director Lake Barrett TMI Program Office Deputy Director Richard Weller TMI Program Office Nuclear Engineering John Nehemias' - Radiological Assessment Branch Radiological Effects Frank Congel Radiological Assessment Branch Radiological Effects

Kimberly Barr Inspection and Enforcement Radiation Specialist Barry O'Neill Inspection and Enforcement Radiation Specialist Michael Wangler Radiological Assessment Branch Radiological Effects i'

' Edward Branagan, Jr. Radiological Assessment Branch Radiological Effects ' Jerry Swift ' Radiological Assessment Branch Radiological Effects Pacific Northwest Laboratory (*} Glenn R. Hoenes Radiological Sciences Program Manager (PNL) Linda F. Munson Radiological Sciences Project Leader (PNL) (a) The Pacific Northwest Laboratory is operated for the Department of Energy by the Battelle Memorial Institute. B.1 i A, - - -,-n.- n - - - - - - - - - - - - ~ - - ~, ~ ~ ,.-.,.,--.--..-,.---,,,~,--,n.---n,~~,------------

1 1 NAME AFFILIATION FUNCTION OR EXPERTISE Pacific Northwest Laboratory (continued)' Leo.H. Munson Radiological Sciences Health Physics George J. Konzek Energy Systems Decontamination Jolene C.' Juneau Radiological Sciences Engineering Greg F. Martin-Radiological Sciences Health Physics Carl M. Unruh RadLological Sciences Senior Reviewer. Edwin C. Watson Radiological Sciences Environmental Science Thomas H. Essig Radiological Sciences Health Physics John G. Meyers Consultant -Health P'hysics Other Consultants Valmore Bouchard VIKEM Decontamination Rudolph Nelson VIKEM Decontamination i ) e i 7 6 B.2 6

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