ML19249D372

NRC Responses to Susquehanna Valley Alliance Interrogatories,Set 1

ML19249D372
Person / Time
Site:	Crane
Issue date:	09/18/1979
From:	Jay Collins Office of Nuclear Reactor Regulation
To:
References
NUDOCS 7909240409
Download: ML19249D372 (31)

Text

e IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

)

SUSQUEHANNA VALLET ALLIANCE,

)

ET AL.,

)

)

Plaintiffs,

)

)

v.

)

Civil Action No.79-658

)

THREE MILE ISLAND NUCLEAR

)

REACTOR, ET AL.,

)

)

Defendants.

)

)

DEFENDANT NUCLEAR RECULATORY COMMISSION'S ANS'4RS TO PLAINTIFFS' INTERROCATORIES SET f1 I.

INTERROCATORY: Please state the amount of curies released in 1978 from Three Mile Island Reactors One and Two. Please list separately for each unit.

1.

RESPONSE: The information requested can be fcund in the following two semi-annual effluent release reports which the licensee is required to submit to the NRC pursuant to 10 CFR Part 50.36a(2)III. These reports contain complete data on the amount of activity, in curies, released in 1978 from Three Mile Island, Units I and 2.

References which trans-mitted these reports follow:

CQL 1463, August 30, 1978 J. G. Herbein (Met Ed) to B. H. Grier (USNRC), Radioactive Effluent Release Reports for TMI-I and TMI-2 (January 1 1978 to June 30 1978); and GQL 0269, March 2, 1979, J. G. Herbein to B. H. Grier, Radio-active Effluent Release Reports for TMI-I and TMI-2 (July 1, 1978 to December 31, 1978).

These reports are provided as Attachments I and 2.

2.

INTERROCATORY: Please state the percentages of those releases es between air and water emissions.

j 2.

RESPONSE: The reports listed in the response to #1 provide detail on how much of the release is in air emissions and how much is in water emissions.

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3.

INTERROCATORY: Please state the quality of the air and waste effluents in 1978, broken down by the type of isotopes released.

j 3.

RESPONSE: The reports listed in the response to il provide detail on the specific type of isotopes released.

4.

INTERROCATORY: Please state the total amount of tritium released in liquid effluents in 1978.

4.

RESPONSE: The reports listed in the response to il list the total amount of tritium released in liquid effluents in 1978.

5.

INTERROCATORY: Please state the total amount of noble gases dissolved in liquid effluents in 1978.

5.

RESPONSE: The reports listed in the response to #1 list the total amount of noble gases dissolved in liquid effluents in 1978.

6.

INTERROCATORY: Please state the concentration of each isotope measured in the af fluent in air and water from TMI One and Two in 1978. Please state separately for each unit.

6.

RESPONSE: The reports listed in the response to #I provide information concernir,3 the total release and the average release rate of air efflu-i en.ts from TMI Units I and 2.

This is the form that NRC bgulatory Guirle 1.21 ' requires this information and it is the form that is most useful in estimating offsite exposures. The reports listed in the res-ponse to #I list the total release and the average diluted concentrations in wate: effluents from TMI Units I and 2 as required iy NRC Regulatory l

Cuids 1.21.

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i 7.

INTERROCATORY: Please state the answers to Questions one through Six above for 1979, by month.

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8 7.

RESPONSE: The data requested for questions one (1) through six (6) were compiled in accordancs with Regulatory Cuide 1.21 on a quarterly basis. Since the March 28, 1979 accident, these data have been com-piled on a more frequent basis. Table I provides the data for the period March 28, 1979 to March 31 1979, and Table 2 provides these data for the months of April and May. For the period January I, 1979 through March 31, 1979, these data were compiled on a quarterly basis and are provided in Table 3.

Tables 4 and 5 provide an isotopic sumary of liquid releases.

Following the March 28, 1979 accident, both airborne and liquid releases were reported to the NRC as mixed releases from Units I and 2.

In accordance with Section 50.36a of 10 CFR Part 50, the licensee is required to report these data to the Comission. Therefore, for the period January through June 1979, these data should be available approximately September 1, 1979.

8.

INTERROCATORY: Please state the total number of curies, to date, ex-cluding crittum and dissolved gases, released into the Susquehanr.a River as a result of the accident at Three Mile Island on March 28, 1979.

8.

RESPONSE: A cumulative total of 0.42 Ci (as of May 31, 1979) of radioactive material, excluding tritium and dissolved gases, has been released to the Susquehanna River since the March 28, 1979 acci-dent.

9.

INTERROCATORY: Please state what you consider to be the absolute limits in terms of total number of curies that can be emitted from Three Mile Island Reactors One and Two in the ar%ient air.

l 9.

RESPONSE: The limitation on releases to ambient air from Three Mile

{

Island Units I and 2 are given in Section 2.I of the TMI-2 environ-mental technical specifications (Appendix B)

Limitations for gaseous effluents are based on the release rate from the plant and i

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. 9.

RESPONSE: (Continued) are excerpted from the technical specifications in Attachment 3.

The release rate limitation for each specific radionuclide is dependent upon the maximum permissible concentration (MPC) for each radionuclide.

10. INTERROCATORY: Please state what you believe to be the absolute number of curtes, excluding tritium and dissolved gases, that can be discharged into the Susquehanna River and the source on which you rely for this response.

10. RESPONSE: The TMI-2 environmental technical specifications (Appendix 5) limit radioactivity released in liquid effluents to less than 10 curies per reactor per calendar quarter for all radionuclides excluding tritium and dissolved gases.

I1.

INTERROCATORY : Please state the answer to the last question in terms of a total monthly quantity, total quarterly quantity, and and total annual quantity, 11.

RISPONSE: The response to Interregatory 10 gives the limitations on the release of liquid effluents, excluding tritium and dissolved r.oble gases, on a quarterly basis as provided in the TMI-2 environmental technical specifications (Appendix 5).

The TMI-2 environmental techni-cal specifications do not provide limitations on monthly or annual quantities.

12.

INTERROCATORY: Please state, if any, limits that you consider to be applicable to the TMI Reactors one and Two for tritium and dissolved gaseous being discharged into the Susquehanna or into the ambient air and the source on which you rely.

12. RESPONSE: As discussed in the TMI-2 environmental technical specifi-cations (Appendix B), tritium releases are limited in 10 CTR 20 Appendix 3, Table 2, to 3 x 10" uci/cc in liquids and 2 x 10"I uCi/cc in gases. Caseous releases of xenons are also limited by the same regulation to 3 x 10"I uCi/cc for Ie-133 and I x 10"I uci/cc for Ie-135.

Liquid xenon releases are limited, as establisned in the TMI-2 environ-

~3

= ental technical specifications (Appendix 8), to 5 x 10 uCi/cc for l

-3 00 Ie-133 and I x 10 uCi/cc for Ie-135.

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. !3. IhTERROCATORY: Pierse state the total liquid stcrage capacity for radioactive water surrently available on tha Three Mile Island Reactor site. Include capacity currently in use, by amount and location, and similarly for capacity still available for storage.

13. RESPONSE: Based on data reported by the licensee on daily tank levels, the following table sumarizes the total liquid storage capacity for radicactive water currently available at TMI Units I and 2 as of July 20, 1979.

TOTAL TOTAL TOTAL TANK CAPACITY CAPACITY USED REIMINING CAPACITY LOCATION (gallons)

(gallons)

(callons)

Unit I Aux. Bldg.

334,700 77,585 257,i15 Unit 2 Auz. Bldg.

317, 191 292,055 25,136 Unit 2 Fuel Handling i10,000 0

110,000 31da,, Jtorage Tanks i

Chemical Cleaning Bldg.

225,000 0

229,000 Tank (EPICOR-II)

It should be noted that not all of the remaining capacity listed in the table above is available for providing additional capacity for the water currently stored in the Unit 2 auxiliary building. First of all, it is not dasirable to use the remaining capacity in the Unit I auxiliary building tanks for the storage of Unic 2 vater sines it is advantageous to keep the contaminated water from Unit 2 separate from Unit 1.

Surge capacity in Unit I will only be used to handle Unit 2 wastes in emergency situations.

In addition, it is not desirable to use the remaining capacity in the Unit 2 fuel handling building (FH3) storage tanks for the scorage of the water in the Unit 2 auxiliary building. These tanks were construct-ed in the Unit 2 FE3 after the accident for the purposa of providing additional storage capability for the high icvel radioactive vaste water currently in the Unit 2 reactor building. Any other use of the tanks in the Unit 2 FH3 would compromise their original purpose. However, due to the current stable water levels in the reactor building sunp, surge capacity in the FH3 tanks can be us 1 to handle water in the Unit 2 auxiliary building tanks in emergency situations.

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13. RESPONSE (Continued)

Also the tanks in the chemical cleaning building (CCS) are currently

art of the EPICOR-II system which was designed by the licensee to treat the water in the Unit 2 auxiliary building. Any use of the tanks in the CC3 to store radioactive water would compromise its intended purposes as part of EPICCR-II. Therefore, these tanks would preferably only be used to store vaste in an emergency situation.

Thus, at the present time, theid is only the surg-capacity listed in the Unit 2 auxiliary building (23,15e gallons) which is available to hold the water in the Unit 2 auxiliary bui?cing.

j4. INTERLOCATORY: Please state whether it is your opinion that water con-tatning harWavel radioactive vaste is currently stored on the Three Mile Island taactor site.

14. RESPONSE: Current federal regulations do not define high-level radio-active vaste in the sense used in this interrogatory. However, water contained in the reactor building basement and the reactor coolant system is considered to be higbly radioactive when compared to levels of radio-activity nor:r. ally encountered (i.e., greater than 100 uCi/ml) in operat-ing PWRs. Water in the reactor coolant bleed tanks is considered to contain intermediate levels of radioactivity (i.e., between I and 100 uCi/ml) when compared to operating PWRs.

15. INTERROCATORY: Please describe where that water is being stored and how it is being monitored.

15. RES.TNSEt Water in the reactor coolant system (RCS) and the reactor coolant bleed tanks is being monitored by periodic sample collection and analysis. Radioactivity in the reactor building sump is being mon-itored by analytical methods which consider water balance and analyses or radioactive material in the RCS. Although procedures are being I

developed, there is no method for directly sa=pling water in the reactor building sump at this ti=e.

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i 16.

INTERPOCATORY: What structures or portions of structures have been built or begun on the site of the Three Mile Island Reactor since March 28, 19797

16. RESPONSEt The following structures have been built or begun since Harch 28, 19798 (1) Long-Te m Solid Waste Staging Facility (Concrete Structure)

(2) Short-Te m Solid Waste Staging Facility (3) EPICOR-II Contrr> Building (4) Ventilation syste. Building for EPICOR-II (5) Balance-of-Plant Electric Diesel Generator Building

17. INTERROCATORYt For all structures or portions of structures mentioned La response to the previous question above, provide the followings (a) state the type, purpose, and size of the structure; (b) state the data construction began, including the date the excavation for founda-tions, etc., comenced; (c) state the date construction ended or is planned to end; (d) state the date on which application for a pemit to construct such structures was filed by Metropolitan Edison or CPU, and the date on which approval was given by NRC; (e) if no permit appil-cation was deemed necessary, provide a copy of any prior permit or po -

tion of pemit NRC, GPU, or Met Ed relied on in determining that sv.o a structure could be built without additional pe mit(s).

17. RESPONSEt (1) Long-Tem Solid Waste Stag!xg Facility (Concrete Structure)

(a) Purposes To store profilter media and ion exchange resin from tte operation of EPICOR-I and -II.

Size: A modular structure with each module consisting of i

60 st: rage cells. fach module to be built on an as-needed basis. Dimension 57 feet wide by 91 feet long by 19 feet hi h with 3 feet thick base and 4 feet thick walls.

6 (b) July 16, 1979 (c) October 15, 1979 g

(d) No application for a pe mit to construct this structure was i

filed by Met Ed.

(e) The operating license of TMI-2, provided as Attachment 8 in j

the response to Interrogatory 25, in referencing Section 50.59 of 10 CTR Part 50

, was used in determining that this struc-ture could be built without additional permits.

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. 17. RESPONSE: (Continued)

(2) Short-Teru Solid Waste Staging Facility (a) Purpose To store profilter media and ion exchange resin frca EPICOR-I and -II until the long-term staging area is completed.

Size: Sixteen cells 4 5 feet in diameter by 8 feet high and twelve celle 7 feet in diameter by 8 feet high.

(b) Started construction: June 1, 1979 (c) Completed Construction: July 20, 1979 (d) See Response provided in (t)(d).

(e) See Response provided in (1)(e).

i (3) EPICOR-II Control Building (a) Purpose / Types This building is used to provide remota control operation for the EPICOR-II waste treatment system.

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frame building was constructed.

Size: 24 feet long by 20 feet wide by 15 feet in height.

(b) Started Construction: April 18, 1979 (c) C m leted Construction: May 10, 1979 (d) See Response provided in (t)(d).

(a) See Response provided in (1)(e).

(4) Ventilation System Building for EPICOR-II (a) Purpose / Types To maintain a negative pressure in the chemical cleaning building and to filter the exhaust from the chemical cleaning building. The building is a concrete slab and con-crate block building approximately 60 feet long by 20.5 feet wide by 15 feet high.

(b) Started Construction: April 13, 1979 (c) Completed construction: June 8, 1979 (d) See Response provided in (I)(d).

(e) See Response provided in (t)(e).

(5) Balanca-of-Plant Electr*c Diesel Generator Building (a) Purpose /Tvpe Used to provide redundant electric power to l

non-nuclear safety related equipment.

1002 168 17.

RESPONSE: (Continued)

Size 68 feet long by 42 feet wide by 11 feet to roof with-out a stack and 20 feet with a stack.

(b) Started construction: April 9, 1979 (c) Comoleted construction: May 9, 1979 (d) See Response provided in (1)(d).

g (e) See Response provided in (t)(e).

18.

INTERROCATORY: What structures, if any, are planned to be built on Three Mile Island that are not specifically approved as part of the existing construction pemit or operating licensef 18.

RESPONSE: See the response to Interrobatory 17.

In addition, Metro-politan Edison has proposed to build a vaste evaporator building in the area adjacent to the Unit 2 diesel building which would be used to pro-cess the highly contaminated waters in the reactor building sump and the primary system. This building is still in the planning phase and has not been reviewed by NRC.

19.

INTERROCATORY: With regard to any structures listed in response to the question above, were any applications for amendments to the operating license or for new construction permits submitted by CPU or Met Edf

19. RESPONSE: No applications for amendments to the operating license or for new cons:ruction permits have been submitted by Met Ed or GPU.

20.

INTERROCATORY: In reference to the structures listed in answer to qucation 18 above, has or will the NRC require either amendments to the operating license or construction permits be obtained by CPU or Met Ed7

20. RESPONSE: At the present ti.m $ ' M has not made a formal proposal to build a vasta evaperator *.a e

• ng.

Wen and if GPU decides to sub-mit a formal propos?1 u'

- wilding to house a veste evaporator s

o i

system, the NRC will +.cform ae. - Gluation to determine the applicability I

of requiring amendments to Met Ed's opei,ddng license or necessity for requiring a aew construction permit using similar criteria as was used l

in the response to Interrogatory 17(1)(e).

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21.

INTERROCATORY: Please state to the best of your ability where the steam released in the Three Mile Island accident fell.

21. RESPONSE: During and following the March 28 incident, radioactive materials in gaseous affluents were released from the auxiliary and fuel handling building ventilation systems which discharge to the environment through the Unit 2 plant vent. The corresponding dose from these releases to the population in the vicinity of the plant de-pends in part upon the local meteorological conditions, namely wind direction, wind speed, and plume dispersion characteristics, which varied during the period of radioactive release. Thus, there is no single location "where the steam releared in the THI accident fell."

However, throughout the accident period, the known meteorological con-ditions indicate that the NNW, ENE, and SSE sectors were the predominant directions from the plant in which radioactive material released from Unit 2 would be expected to be found. NUREG-0558 sum =arizes radiat!on measurements made at various times and locations around the Three Mile Island site. The staff made specific periodic estimates of the location and relative concentration of releases throughout the course of the accident. These estimates are referred to, but not specifically pre-sented, in NUREG-0558. NUREG-0558 is provided as Attachment 4 in the response to Interrogatory 23.

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22. INTERROCATORY: Please state whether any of this steam fell on the Susquenanna River and whether the addition of radioactivity to the River from this steam has been estimated. If such an estimate has been made, please provide.

22. RESPONSE: Some of the radioactivity released into the atmosphere as a result of the Three Mile Island incident came in contact with the Susquehanna River. Specific estimates were not =ade to determine the amount. However, total radioactivity in the rive r water from all sources was monitored by the licensee, personnel from the states of Pennsylvania and Maryland, and Department of Environ = ental Resources, Environmental Protection Agency, U.S. Geological Survey and U.S Nuclear Regulatory Co==is s ion. NRC measurements indicated no measurable increase in the 1002 170

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22. RESPONSE (Continued) amount of radioactivity in the river, within the limitations of the in-struments, due to the incident.

23. INTERROGATORY: Please list any and all environmental, public health, or other evaluations of the accident at Three Mile Island prepared by NRC or Met Ed and provide Plaintiffs with a copy of such report.

23. RESPONSE: The following is a listing of documents which deal with the environmental and public health evaluation of the accident at Three Mile Island.

(1) NUREG-0558, " Population Dose and Health Impact of the Accident at Three Mile Island Nuclear Station, Preliminary Estimates for the Period March 28 through April 7, 1979," May 1979, prepared by the Ad Hoc Interagency Dose Assessment Group made up of parti-cipants from NRC, EPA and HEW; (2) GQL 0693, May 15, 1979, J. G. Herbein (Met Ed) to B. H. Grier (USNRC). Interim Report on the Three Mile Island Nuclear Station Unit 2 (THI-2) Accident; (3) GQL 0780, June 18, 1979, J. G. Herbein to B. H. Grier, Second Interim Report on the Three Mile Island Nuclear Station Unit 2 (TMI-2) Accident (June 15, 1979); and (4) July 16, 1979, J. G. Hertain to B. H. Grier, Third Interim Report L

on the Three Mile Island Nuclear Station Unit 2 (TMI-2) Accident.

Copies of the above reports are provided as Attachments 4, 5, 6 and 7, respectively.

24.

INTERROGATORY: Please list (or provide page referene,es to) any and all significant adverse environmental or public health i= pacts dis-covered in any of the above reports.

24. RESPONSE: Discussions of health and/or environmental i= pacts can be found in Section IV of the Metropolitan Edison reports and in all sec-tions of NUREG-0558.

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25.

INTERROCATORY: Please provide the Plaintiffs vis copies of the

( O Facalley's Operating License Number DPR-73, Plus Attachments One and Two; (2) Report of Advisory Co=mittee on Reactor Safeguards, October 22, 1976; (3) Office of Nuclear Reactor Regulation, Safety Evaluation Report September 1976, and Supplements One and Two; (4) Final Safety Analysis Report and Amendments Enerato; ($) Applicant's Environmental Report, dated February 28, 1975, and Supplements thereto; (6) Draft Environmental Impact Statement, dated June 1972; (7) Final Environmental Statement dated December 1972; (8) Draft Supplement to Final Environmental Statement July 1976; and (9) Final Supplement to Final Environmental Statement, dated December 1976.

25. RESPONSE: Copies of items I, 2, 3, 6, 7, 8 and 9 are provided as i

Attachments 8, 9, 10, 11, 12 13 and 14, respectively. The 12 volume Final Safety Analysis Report and the 3 volume Environmental Report requested by items 4 and 5 can be obtained from the NRC's public docu-mant room located at the following locations:

(1) NRC Headquarters, 1717 H Street, Washington, DC.

(2) NRC PDR at the Government Publications Branch, State Library, I

Department of Education Building, Commonwealth and Walnut Streets, Harrisburg, Pennsylvania.

26. INTERROCATORY: Please state whether Metropolitan Edison Company has provided to NRC any written evaluation of additional construction or operation activities as a result of the accident at Three Mile Island, prior to any approvals obtained from the Director, Office of Nuclear Reactor Regulation.

26. RESPONSE: Yes, the NRC has received the following documents from the Metropolitan Edison Company:

(1) Safety Analysis Report for Transition to Natural Circulation.

April II,1979; (2) Revised E4fety Analysis Report for Transition to Natural Circula-tion, May 3, 1979; (3) PLR-Decay Heat Removal System, May 1, 1979; (4) The three Interin Reports, dated May IS, June I$ and July 16, 1979,

4entifin La the answer to Interrogatory No. 23.

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In addition to these formally submitted Co:uments, there were other written evaluations which the NRC staff has seen in the course of its continued presence at the Three Mile Island site.

27.

INTERROCATORT: Please list all such written evaluations received by NRC since the accident at Three Mile Island

27. RESPONSE: See response to Interrogatory 26.

28. INTERROCATORY: Were the environmental impacts from the accident at Three Mile Island, the subsequent cleanup, and alternatives to discharge into the Susquehanna ev.luated by the Commission and Metropolitan Edison in the final environmental statement? If yes, please provide page references.

28. RESPONSE: The environmental impacts resulting from loss of coolant accidents have been evaluated in the Final Supplement to the Final Environmental Statement related to the operation of Three Mile Island Nuclear Station Unit 2, NUREG-Cll2, dated December 1976. The specific accident which occurred at TMI was not evaluated. However, the environ-mental impact of a more severe accident, namely the loss of coolant accident resulting from a larger diameter pipe break, was evaluated in Section 7.2 of NUREG-Oll2. Also, the environmental impact of a similar accident, namely the loss of coolant accident resulting from a small diameter pipe break, was evaluated in Section 7.2 of NUREG-Oll2.

The environmental impact of the subsequent cleanup and alternatives to discharge was not evaluated in NUREO-Oll2. However, as indicated in the May 25 directive from the Co lssion to the NRC staff, no cleanup or discharge of the water generated as a result of the March 28, 1979 accident may begin until the NRC staff completes certain actions. An environmental assessment of the cleanup of this water and alternatives to discharge into the Susquehanna must be completed and the public must I

be provided with an opportunity to comment on the assessment. At this

1 time, the NRC staff is in the process of preparing

• the environmental.

assessment of the cleanup of the vaste water.

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. 29. U TERROCATORY: Please state vtether the annual total quantity of radio-active materials in liquid vaste for 1979, excluding tritium and dis-solved gases, has exceeded five curies for TMI-2.

29. RESPONSE: The total quantity of radioactive material in liquid vastes released from THI-I and -2 through May 31, 1979 is 0.46 Ci, excluding tritium and dissolved gases. Refer to response to Interrogatory 7.

30. INTERROCATORY: Please state vbether the annual dose to the whole body or any organ of an individual as a result of the accident at TMI-2 has exceeded five crem from the combined releases at TMI Units One and Two.

30. RESPONSE: As indicated in NUREG-0558 provided in the response to Inter-rogatory 23, the maximum dose to an individual as a result of the accident is less than 100 mrem. This is greater than the 5 mrem discussed in this interrogatory. However, it should be noted that the 5 mres is a design objectiva dose for normal plant operation. A discussion of the health impact of the exposure is given in NUREG-0558.

31.

INTERR0CATORY: Please state whether the effluent from the cooling covers at Three Mile Island has exceeded, excluding tritium and dis-solved gases 2 x 10-8 microcuries per milliliter since January 1, 1979, and state the dates on which such violations occurred.

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31. RESPONSE: The concentration level of 2 x 10 uci/ml in the cooling tower effluent is not an instantaneous concentration limit, nor is it i

an instantaneous specification limit. As indicated in the THI-2 en-vironmental technical specifications, it is a design objective to be met on an annual average basis to ensure that the instantaneous release rate for affluent discharges are within the limits of 10 CFR 20.

Release concentrations are provided in Tables I through 3 of the res-ponse to Interrogatory 7.

Based on the data in these tables, the value of 2 x 10-8 was exceeded durirg the period March 28 to April 30, but as indicated above, this does not represent a technical specification I

violation. The li=its of 10 CFR 20 specified in -he technical speci-t i

fications were not exceeded at any time.

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32. INTERROCATORY: Please stata whether the annual average concentration of trattum and liquid vasta prior to dilution in the environment has exceeded 5 x 10-6 microcuries per milliliter at any time during 1979, and state the date on which violations occurred.

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32. RESPONSE: The concentration level of 5 x 10 in the affluent is not an instantaneous concentration limit nor is it an instantaneous specifica-tion limit. As indicated in the TMI-2 environmental technical specifi-cations it is a design objective to be met on an annual average basis to ensure that the instantaneous release rate for effluent discharges are within the limits of 10 CTR Part 20.

Release concentrations are pro-vided in Tables I through 3 of the response to Interrogatory 7.

Based on the data in these tables, the value of 5 x 10 has not been exceeded i

during 1979. The limits of 10 CIR Part 20 specified in the technical specifications also have not been exceeded at any time.

33. INTERROCATORY: Please state whether the radioactive releases in the affluent from Reactors One and Two have exceeded the values in 40 CFR 20, Appendix "S", for unrestricted areas, at any tima during 1979; and state' the dates on which such violations occurred.

33. RESPONSE: See Tables I through 3 provided in the response to Interrog-atory 7 which provides liquid and gaseous releases, January 1, 1979 to May 31, 1979.

1.

Licuid Releases The iod'ne and tritium release concentrations i

given in I.B and I.C of Tables I through 3 are less than the 10 CTR Part 20, Appendix B, concentrations of 3 x 10-7 uCi/ml

~3 and 3 x 10 uCi/mi respectively. The concentrations given in Part I.A of Tables I through 3 are not listed by individual nuclides, however, these concentrations are less than the values in 10 CTR Part 20 for the nuclides most likely to be present in the affluents (e.g., cesiums, cobalts, strontiums, iodines, iron, manganese, zinc, and barium-lanthanum).

2.

Caseous Releases The iodine-131 releases given in II.B of Tables I through 3 are within the limits of 10 CTR Part 20. The noble gases appear to have exceeded the limits of 10 CTR Part 20 on a short term basis using the annual average =eteorological dis-l persion factors from the Final Supplement to the Final Environmental /

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33. RESPONSE's (Continued)

Statement, NUREG-Oll2. 10 CFR Part 20 does, however, permit averaging these releases over a period of one year.

Future calculations based on actual meteorology will be necessary to determine if 10 CFR Part 20 was actually exceeded. The exact dates of the release exceeding 10 CFR Part 20 vill be determined when actual meteorological data and better gaseous release date are available.

34. INTERROGATORY: Please state whether in any quarter the total release of radioactivity in liquid effluent from THI-l and -2, excluding trio *un and noble gases, has exceeded 10 curies per reactor.

34. RESPONSE:

No. As indicated in the response to Interrogatory 7 the release in liquid e: ?uents, excluding noble gases and tritium was O.15 curies for the...... quarter and 0.31 curies for the second quarter of 1979, through May 31, 1979.

35. INTERROGATORY: Please state whether tt.e maximum radioactivity contained in any one of the liquid radvaste tanks, excluding tritium and dissolved gases, exceeds 10 curies.

35. RESPONSE: Yes. Radioactivity levels in the Unit 2 liquid radvaste tanks exceed 10 curies, excluding tritium and dissolved noble gases.

36. INTERROGATORY: Please state where those liquid radvaste tanks are located.

36. RESPONSE: Radvaste tanks referenced in Interrogatory 35 are located in the Unit 2 auxiliary building.

permissible concentration (168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) of 5 x 10-gs exceeded the maximum INTERROGATORY: Please state whether Xenon-131 h 37.

microcuries per milli-liter at any tise in 1979, and state the dates on which such violations occurred.

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. 37. RESPONSE:

No. Discharges of le-133 in liquid effluents have not exceeded

~3 5 x 10 uCi/ml between January 1, and May 31, 1979.

38. INTERROCATORY: Please state whether the maxi::n.:m permissible concentra-tion of Xenon-135 (168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) has ever exceeded the level of I x 10-3 microcuries per milliliter, and state the dates on which such violations occurred.

38. RESPONSE No.

Discharges of Xe-135 in liquid effluents have not exceeded I x 10' uCi/ml between January 1, and May 31, 1979.

39. INTERROCATORY: Please provide the sources for the responses to Ques-tion 29 through 38.

39. RESPONSE: Sources for ansvers to Interrogatories 29 through 38 include data obtained from Metropolitan Edison and Babcock and Wilcox. This includes measured station effluent data and tank volume and radioactivity anulyses data. It also includes radiological dose data taken from KUREG-0558 provided in response to Interrogatory 23.

40.

INTERROCATORY: Please state the basis on which the dilution factor of the Susquehanna River of 250x was developed in the Three Mile Island, Unit Two, Facility Operating License Numbr

'PR-73.

40. RESPONSE: The dilution factor of 250 for Three Mile Island, Unit Two, was developed to determine expected doses from the finfish consu=p-tion pathway for use in the assessm o ts required by 10 CFR Part 50, Appendix I The specific estimate of 250 was based upon the dilu-tion of plant discharge by the average annual flow rate in the middle channel of the Susquehanna River at the site. The river flow is split at the head of TMI, such that during normal flow conditions, approxi-mately 30% of the average annual discharge of 34,000 cubic feet per second (CFS) is diverted tc the middle channel on the west side of the island. The average annual discharge of 34,000 cfs was based on records t

from the U.S. Geological Survey stream gage at Harrisburg, Pennsylvania.

1 1002 177 i

. 40. RESP 01tSE: (Continued) 4 The averaga annual plant discharge is expected to be 80 cfs. Therefore, the average dilution factor downstream of the discharge was calculated to be 125 It was assumed that an individual fish would be upstream of the diacharge point % of the tica and downstream of the discharge point % of the time.

The dilution was.therefore, calculated to be 250 for the region where finfish exis:t (within a one-quarter mile radius of the d*sebarge point).

41.

INTERROCATORT: Please state the number of people living within a ftve-mile radius of the Three Mile Island plant, a ten-mile radius of the TMI plant, and fifteen-mile radius of the plant.

41. RESPONSE: The projected 1980 population within a five-mile radius of TMI was estimated in the Final Safety Analysis Report for Unit 2 to be 28,821. Within a ten-mile radius the population for 1980 was projected to be 166,295. A projection for the fifteen-mile radius population was not made. However, the 1980 population projection for a twenty-mile radius.was I,178,584.

42. INTERROCATORY: Please state the exact dimensions of Three Mile Island.

e

42. RESPONSE: A map of the TMI site is provided as Attachment 15. This map is taken from the Final Safety Analysis Report for THI, Unit 2, Figure 2.4-13.

43. INTERROCATvRY: Please state whether additional liquid effluents could be stored on the reactor site at Three Mile Island.

43. RESPONSE: The respon.se to Interrogatory 13 lists the current re=aining storage capacity available at Three Mile Island, Units 1 and 2.

This is the only remaining storage capacity available onsite at this time.

l As indicated in that response, it is not planned to use the re=aining storage capacity in the Unit I auxiliary building, the fuel handling building, or the che ical cleaning building to acco=sodate additional effluents in the Unit 2 auxiliary building. However, this capacity j

could be utilized in an emergency situatian.

1 1002 178 44.

INTERROCATORY: Please list and produce the test results of any sound-Ings or drillings perfor=ed on the IMI Reactor site prior to the con-struction of facilities after the accident on March 23, 1979.

44.

RESPONSE: There was core drilling prior to the construction of both the short-term solid waste staging facility and the long-term solid vaste staging facility. The results are attached in a cover letter entftied, " Preliminary Soils Information Solid Waste Staging Facility."

(Attach:ient 16.)

45.

INTERROCATORY: Please state the esti=ated doses from liquid and air radicactive e;>. ions in 1978 and 1979, by month, fror Reactors One and Two, to the whole body for the calendar year, for milliress in a seven consecutive-day period and for millirems per hour.

45.

RESPONSE: The doses to the maximum individual 0.37 miles W4 of the site from January tlrough December 1978, due to liquid and gaseous effluents from Three Mile Island Units I and 2 are Unit 1 Iodines & Particulates in gases, total body adult 0.86 mres Noble gases, total body, adult 1.0 mrem Liquid, total body, adult 1.8 mrem Unit 2 Iodines & particulates in gasec, total body adult 0.12 mres Noble gases, total body, adult 0.0019 mrem Liquid, total body, adult 0.035 mrem Doses at other locations would be lover.

The dose due to radioactive affluents in 1979 are mostly from the March 28, 1979 incident. The best estimate for the maximu:n exposed individual is less than 100 mrem. Details of this analysis are con-tained in NUREG-0558, provided as Attachment 4.

46.

INTERROCATORY: Please list all documents on which you base your calcu-lations of human exposure to radioactivity from the Three Mile Island Nuclear Reactor. Please site specific page references to docu=ents in which ma*.hematical models or calculations relied on are contained.

i, 1002 179

l l l

46. RESPONSE: The following documents were used:

(1)

U.S. NRC Regulatory Guide I.109, " Calculation of Annual Doses to Man from Routine Releases of R actor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I."

(See Accach-ment 17.) The specific pages are 2 through 7, 12 through 17, 2J through 22, and 24 through 28.

(2) Final Supplement to the Final Environmental Statement related to operation of the.Three Mile Island Nuclear Station, Unit 2, NUREG-Oll2, December 1976, specifically Chapter 5.4.

47.

INTERROC. STORY: Please list NRC operating procedures, guidelines, in-carnal namoranda, and policies established for the operation of nuclear power plants that eremed perminible concentrations or total quantity of radioactivity within a particular period of time.

47. RESPONSE: The operating conditions imposed. on each nuclear power plant by NRC that exceed permissible concentrations or total quantity of radioactivity within a particular period oc time, can be found in the technical specifications for each operating facility.

48. INTERROCATORY: Please list all NRC operating procedures, guidance, memoranda, and policies for the preparation of environmental assess-ment statements for determining when a negative declaration is issued and for deter =ining when an environmental impact statement is required.

48. RESPONSE: NRC guidance for the preparation of environmental assessment statements is contained in 10 CFR Part 51#. This Part is currently being revised to conform with new CEQ regulations which become effective on 30 July 1979. In addition, there is a DOR Memorandum No. 5, dated 9 March 1977, which also gives some guidance in this area. (See 8.)

l

49. INTERROGATORY: Please state the name and address of the manufacturer of EPICOR-1 and EPICOR-II Treatment Systems.

'9.

RESPONSE: The EPICOR-I and EPICOR-II treatment systems were provided by EPICOR. Inc., 1375 Linden Avenue, I.inden, New Jersey.

I 1002 180

. 50. INTERROCATORY: Please list the specifics of the design system of

{

EPICOR-I and EPICOR-II.

6

50. RESPONSE: See attached EPICOR-I and EPICOR-II System Descriptit -

(Attachments 19 and 20, respectively).

51. INTERROGATORY: Please list any and all information concerning the manufacture and specifications, manufacture of component parts, prior installations, and produce prior performance data on EPICOR-I and EPICOR-II.

St. RESPONSE: Inforsation requested in Interrogatory 51 concerning system design is given in the response to Interrogatory 50.

With regard to system perfor=ance data, it should be noted that EPICOR-I and EPICOR-II are systems that use ion exchange to treat the water. The use of ion exchange in the treatment of radioactive vaste water is standard practice in nuclear power plants and the principles and per-for=ance data upon which they are based r.re described in NUREG/CR-0143, provided as Attachment 21.

The EPICOR-I system has been used onsite previously at Unit I and system decontamination factors were found to be satisfactory.

The EPICOR-II facility is similar to EPICOR-I. The major difference lies in the fact that EPICOR-II is located inside a ventilated and fil-

ared building. It is planned to use it to process liquid vastes that are of a higher activity level than those processed by EPICOR-I.

52. INTERROCATORY: Please state what NRC and Met Ed's projected performance capability of EPICOR-II was on April 15, on May 16, and on May 25, 1979.

52. RESPONSE: The EPICOR-II system was originally designed to process vastes with a cesium-137 and iodine-131 specific activity of no greater than 100 uci/ml. This design objective has not changed.

I

\\002 t

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53. INTERROGATORY: Please state the current characteristics in terms of concentration of various radioactive isotopes in the pri=ary coolant water, in all water held in tanks on the reactor site, in the reactor core and containment building.

53. RESPONSE: Concentrations of important radionuclides for radiological dose considerations at requested locations are presented in Tables 6 and 7.

54. INTERROGATORY: Please state how the various water systems are pre-sently segregated or inter-connected through plumbing mechanisms or leaks.

54. RESPONSE: Information concerning the variaus vaste systems can be obtained from tm

'. lowing drawings:

1.

Flow Diagram -

,aste Disposal Reactor Coolant Liquid DWG 2027.

2.

Flow Diagram - Radwaste Disposal - Miscellaneous Liquids, DWG 2045.

3.

Flow Diagram - Auxiliary Building Emergency Liquid Cleanup System, DWG M006.

4.

Flow Diagram - Fuel Pool Waste Storage System, DWG M014.

These drawings are provided as Attachments 22 through 25.

55. INTERROGATORY: Please list the projected treatment efficiency on primary coolant water for all radioactive components of EPICOR-II.

55. RESPONSE: EPICOR-II was not designed to process primary coolant system water.

56. INTERROGATORY: Please list all solid radioactive materials presently onsite, the level of radioactivity, and the disposal techniques anti-cipated.

56. RESPONSE: The current inventory of solid waste includes approxi=ately 700 drums (SS-gallons) of compacted low-level trash, 9 liners (50 cubic 4

I feet) of solidified evaporator bottoms, 46 boxes (4 feet by 4 feet by l

8 feet) of noncompactible low-level trash, 9 liners (180 cubic feet) of devatered resin, and 3 liners (ISO cubic feet) of devatered filter i

t

56. RESPONSE: (Continued) medium. All of these containers qualify as Low Specific Acti~ity (10 CFR Part 71.4

) material and will be transported to a licensed burial facility for ultimate disposal.

57. INTERROCATORY: Please state whether, to the Defendants' knowledge, there is any method currently known to determine the amount of cell da= age caused by radiation as experienced from the Three Mile Island Reactor.

57. RESPONSE: We are not aware of any method to determine the amount of a, ell damage in hu=ans caused by low doses of radiation (i.e., about 100 mrem). In N" REG-0558 (Attachment 4) the dose to a hypothetical offsite maximum individual was estimated to be less than 130 mrem.

i Recently Dr. Joseph Gong of the State University of New York at Buffalo presented a talk on the erythroid effects of radiation of rats in the I roentgen (R) range (Symposium on Biological Effects, Imaging Tech-niques and Dosimetry of Ionizing Radiation, Bureau of Radiological Health, June 1979). At this symposium Dr. Cong stated that he has detected an increase in the amount of normoblasts for bled rats at doses as low as 50 mR.

To the best of our knowledge, this is the lowest level of exposure at which cell damage has been observed in animals. However, we are not aware of any studies that have shown similar effects in humans at doses of 100 mrem or less.

I, John Collins, Deputy Director, T5ree Mile Islana Support Staff, declare under penalty of purjury that the foregoing answers were prepared under my direction and supervision and that they are true and correct to the best of my knowledge and belief.

kl.)

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[/

JOHN T. COLLINS 1002 183 i

I

REFERI!:CES (1) Title 10, CFR Part 50.36a, " Technical Specifications in Effluents from Nuclear Power Reactors."

(2) Regulatory Guide 1.21, '9 Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Release of Radioactivity in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Rev. 1.

(3) NUREG-0432, Three Mile Island Nuclear Station, Unit No. 2, Environmental Technical Specifications (Appendix B), Section 2, " Radioactive Discharges,"

February 8,1978.

(4) Title 10, CFR Part 20. " Standards for Protection Against Radiation."

(5) Title 10, CFR Part 50.59, " Changes, Tests and Experi=ents."

(6) Title 10. CFR Part 50, Appendix I, " Numerical Guides for D* sign Objectives and LLsiting Conditions for Operation to Meet the Criterion 'As Low As Practicable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."

(7) Metropolitan Edison Co., Final Safety Analysis Report, Three Mile Island Nuclear Station, Unit No. 2, April.1974.

(8) Title 10, CFR Part 50, " Licensing and Regulatory Policy and Procedures for Environmental Protection."

(9) Title 10, CFR Part 71.4, " Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions, Definitions."

1 6

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TABLE I PERIOD 3/28/79 - 3/31/79 I.

Su==ary of Releases (Liquid)

A.

Curies Discharged (excluding tritium & distolved 1.lE-1 noble gases)

Concentration (uci/ce)-

I.32E-7 B.

Iodine-131 Released Total Curies 3.063E-l Concentration (uci/cc) 1.24E-7 C.

Tritium Releases Total curies 5.5E-1 Concentration (uci/cc) 6.61E-7 II. Su=sary of Releases (Airborne)

A.

Noble Gases Total Curies 8.83E+6 Release Rate (Ci/sec) 1.12 B.

Iodine. Releases Total Curies 4.57 Release Rate (uci/sec) 5.8E-l t

4 i

I 1002 185 I

I TAILE 2 PE.1!OD PERIOD 4/01/79 - 4/30/7o, 5/01/79 - 5/31/79 I.

Su=msry of Releases (Liquid)

A.

Curies Discharged (excluding 2.74E-1 4.0E-2 tritium & dissolved gases)

Concentration (uci/cc) 4.39E-8 6.2tE-9 B.

Iodine-131 Released Total Curies 1.28E-!

5.lE-3 Concentration (uci/cc) 2.lE-8 7.8E-10 C.

Tritium Releases Total curies 10.12 4.7 Concentration (uci/cc) 1.62E-6 7.3E-7 II. Su=ury of Releases (Airborne)

A.

Noble Cases Total Curies I.IIE+6 1.4E+3 Release Rate (Ci/sec) 1.41E-i 1.74E-4 B.

Iodine Releases Total curies 9.5 7.8E-2 Release Rate (uci/sec) 1.20 9.9E-3 e

6' 1002 M I

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i TABLE 3 3

PERIOD 1/01/79 - 3/31/79 I.

Su=sary of Releases (Liquid)

A.

Curies Discharged (excluding tritium & dissolved 1.5E-l noble gases)

Concentration (uci/cc) 8.03 E-9 5.

Iodine-131 Released Total Curies 3.07E-l Concentration (uci/ce) 5.7E-9 C.

Tritium Released Total Curies 26.1 Concentration (uci/cc) 1.54E-6 II. Summary of Releases (Airborne)

A.

Noble Cases Total curies 8.83E+6 Quarterly Release Rate (Ci/sec) 1.12 B.

Iodine-131 Releases Total Curies 4.57 Quarterly Release Rate (uci/sec) 5.8E-1 I

t i

1002 187

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TA3LE 4 l

SDa%RY OF LIOUID PADIO:MCLIDES DISCHARCED BY ISOTOPE PERIOD 1/1/ 79 THROUGH 3/27/79 Radionuclide Activity Ci H-3 2.54E +1 Cr-51 1.65E -3 Ma-54 3.36E -4 Co-58 2.13E -2 Fe-59 I.33E -4 Co-60 1.19E -3 Zn-65 3.94E +5 Nb-95 1.43E -3 Zr-95 7.71E -5 Zr-97 8.SSE -5 Mo-99 8.56E -6 Ru-103 7.37E -5 Ag-llo 8.32E -4 Sb-122 5.78E -5 Sb-124 3.77E -5 I-13I 2.54E -4 Ie-1313 2.60E -5 I-132 I-133 Xe-133m 2.60E -5 Ye-133 9.95E -3 Cs-134 3.21E -3 Cs-136 1.22E -5 Cs-137 4.55E -3 Ba-140 2.88E -5 La-140 3.94E -4 l

t 1002 188 i

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TABLE 5 LIQUID RADIOPUCLIDE DISCIL*JGES 3Y ISOTOPE 3/28/79-4/30/79 5/1/79-5/31/79 Radionuclide Activity (Ci)

Activity (Ci)

H-3 10.670 4.7 Cr-51 3.5E -4 1.64E -3 Mn-54 4.IIE -4 1.57E -4 Co-58 0.022 1.24E -2 Co-60 6.9E -3 1.41E -3 Nb-95 1.82E -4 5.17E -4 Zr-95 4.83E -5 7.22E -5 Ag-IIDs 1.25E -3 9.37E -4 I-131*

0.235 5 05E -2 Ie-13!m 7.25E -4 I-132 3.44E -4

..I-133 1.4E -4 1.43E -5 Ka-133 0.012 7.5E -5 Cs-134 2.llE -3 2.18E.-3 Cs-136 2.7E -4 1.3E -3 Cs-137 5.61E -3 4.83E -3 Ba-140 5.99E -4 5.43E -3 La-140 1.29E -3 4.09E -3

• I-131 is the only radionuclide of significance released to the river from Unit 2 accident of 3/28/79. Other radionuclides case pri=arily from Unit 1.

\\002 189 i,

TABLE 6 ESTII' ATE OF CONCENTE.'. TION OF ACTIVITY IN IJASTE LIOUIDS i

(As of July 1, 1979)

ACTIVITY REACTOR C0"AIN1ENT (uci/cil)

COOLANT

_S UI'P*

H-3 0.2-0.3 1.0-1.5 Sr-89 305-330 300-400 Sr-90/Y-90 17-19 10-18 I-131 0.5-0.6 0.5-1.5 Cs-134 18-22 30-40 Cs-137/Ba-137m 90-110 200-260 Ba-140/La-140 4-5 0.5-1 lot:a1 of Others 0.1-5 0.1-10 aRanges are estmated (sar::ple has not been obtained for analysis).

is 1002 190 o

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TABLE 7 f

CO::CE!;TRATIONS OF PRINCIPAL I'L'CLIDES IN TMI 1";IT 2 AUXILIARY SUILDII!G TAiKS AS OF JU:iE 15, 1979 tuci/ml)

Reactor Coolant Reactor Coolant Reactor Coolant

_ Bleed Tank A Bleed Tank B Bleed Tank C I-131 1.9 2.8 3.0 Cs-134 6.5 7.6 7.7 Cs-136 O.28 0.29 0.28 Cs-137 28 35 35 Ba-140 0.09 0.3 0.29 H-3 0.23 0.27 0.29 Evapora'.or Miscelfaneous Waste Condensate Holdup Tank Auxiliary Tanks; Con-Neutralizar Neutralizer Bldg Sump & Sump Tank; taminated Tank A Tank B _

Miscellaneous Su::rps Drain Tanks

~I I-131 0.15 0.18 1.0

/.10

~I Os-134 0.56 0.72 2.4

< 10

~I Cs-136 0.01 0.02 0.08

<10

-I Cs-137 2.5

.3 10.I

< lo

~I 3a-140

.01 0.03 0.8 4,10 H-3 NA*

NA*

0.98 NA*

• Not analyzed as yet. ' H-3 levels are estimated to be less than 0.2 uCi/g:n.

o 1002 IU i

t