ML20010F702

Forwards Rl Gotchy & R Weller Affidavits Attesting to Authorized Testimony in NRC 781215 Response to Memorandum Concerning ASLB Questions.Nrc Will Move ASLB to Enter Affidavits & Testimony Into Record

ML20010F702
Person / Time
Site:	05000514, 05000515
Issue date:	09/09/1981
From:	Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Bowers E, Jordan W, Martin W Atomic Safety and Licensing Board Panel
References
NUDOCS 8109110208
Download: ML20010F702 (6)

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Elizabeth S. Bowers, Esq., Chuiraan Dr. Willian E. Martin m

W Adninistrative Judge Administrative Judge and Atonic Rfety and Licensing Board Senior Ecologist U.S. Nuclear Regulatory Connission Battelle Meuorial Institute Washington, D.C.

40555 Columbus, Ohio 43201 DISTRIBUTION Shapar/Engelhardt Dr. Walter H. Jordan Christenbury/Scinto/Olmstead Aduinistrative Judge FF (2) 801 West Guter Drive Reis Oak Ridge Tennessee 37d30 Bordenick Black E. Adensam In the Itatter of P.Lecch Portland General Electric Company, et al.

NRC Central: LPDR/PDR (Pebble Springs Nuclear Plante Units 1 and 2)

Docket Hos. 50-514 ana 50-515

Dear Administrative Judges:

The Board's " Order Adjusting the Schedule and Relative to the Appendix I Issue" dated August 10, 1981 stated in part, as regards the Board generated

" Appendix I Issue," tnat

[t]here has been an open issue since the last pre-hearing conference in December 1979. Tr. 31 (correctly Tr. Sou4). The Staff asked if the Board was satisfied with the proposed [ additional] Staff testinony concerning Appendix I.

The testinony was filed on fiarch 7, 1979, but the Board had not re-ceived it at the time of the prehearing conference.

It was served again by the Staff on December 26, 1979.

The board has reviewed tne testinony, is satisfied and has no further questions.

It is not necessary for the Staff to present witnesses at the hearing on tnis issue but the testinony should be in affi-davit forn."

Pursuant to the above noted Board directive, enclosed are the recently exe-cuted "Affidevit of Dr. Richard Weller" and " Affidavit of Dr. Reginald L.

d 60tchy." Also enclosed, for the ready reference of the Board and parties, is hI l" a copy of the HRC Staff testinony (dated March,1979) referenced by Drs. Weller and Gotchy in their respective affidavits.

The URC Staff will nove the Board i

to incorporate the enclosed two affidavits, and Staff testimony dated March, OJ

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~. 1979, into the record as if read at the evidentiary hearing session presently scheduled to commence on December 1, 1981.

Sincerely.

Bernard H. bordenick Counsel for fiRC Staff

Enclosures:

As Stated cc:

(w/ enclosures)

Alan S. Rosenthal, Esq.

Ur. Lawrence R. Quarles Richard S. Salzman, Esq.

James W. Durhan Esq.

Warren llastings Esq.

Frank W. Ostrander, Jr., Esq.

lir. Donald W. Godard tir. Lloyd K. Ibrbet Ms. Bernice Ireland Atonic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board J. Carl Freedaan Frank Josselson, Esq.

Willian L. Hallpark, Esq.

R. Elaine lialls. ark Esq.

Kathleen 11. Shea, Esq.

Docketing and Service Section i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PORTLAllD GENERAL ELECTRIC Docket Nos. 50-514 COMPA!4Y, ET AL.

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50-515 (Pebble Springs Nuclear Plant, Units 1 and 2)

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AFFIDAVIT OF DR. REGINALD L. GOTCHY Na;; comes Reginald L. Gotchy, and being duly sworn, deposes and says as follows:

f 1.

I am employed by the Nuclear Regulatory Commission as a Senior Radiobiologist in the Radiological Assessment Branch, Office of Nuclear l

Reactor Regulation.

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2.

I am duly authorized to testify as set forth in pages 5-8 of the attached "NRC Staff Response to ' Memorandum Concerning Board Questions' l

l Dated December 15, 1978 Prepared By Dr. Reginald C. Gotchy and Dr. Richard Weller."

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. 3.

I hereby certify that the testimony given by me in the above referenced document is true and correct to the best of ny knowledge and belief.

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Reg 4ryfld L. Gotchy, PhD Subscribed and sworn to before me this 8 4 day of September,1981.

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Nofary Public f My Commission expire d / / 982 V

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PORTLAND GENERAL ELECTRIC

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Docket Nos. 50-514 COMPANY, ET AL.

50-515 (Pebble Springs Nuclear Plant,

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Units 1 and 2)

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AFFIDAVIT OF DR. RICHARD WELLER Now comes Richard Weller, and being duly sworn, deposes and says as follows:

1.

I am employed by the Nuclear Regulatory Comission as a Section Leader in the Safety Review Section of the Three Mile Island Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to testify as set forth in pages 2-4 ?.nd 8 and corrected Table 2 of the attached "NRC Staff Response to ' Memorandum Concerning Board Questions' Dated December 15, 1978 Prepared by Dr. Reginald L. Gotchy and Dr. Richard Weller."

1. 1A p.4

. 3.

I hereby certify that the testimony given by me in the above referenced document is true and correct to the best of ny knowledge and

belief, h

Richard Weller, PhD Subscribed and sworn to before me this ?_.ad day of September, 1981.

d'A% Sb Notary Public y

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/ My Commission expires: M 1,19 '51 -

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t March 1979 UNITED STATES OF A.' ERICA NUCLEAR REGULATORY COPf1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PORTLAND GENERAL ELECTRIU Docket Nos. 50-514 COMPANY, ET AL.

50-515 (Pebble Springs Nuclear Plant, Unit Nos. ' and 2)

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NRC STAFF RESPONSE TO " MEMORANDUM CONCERNING BOARD QUESTIONS" DATED DECEMBER 15, 1978 PREPARED BY DR REGINALD L. GOTCHY AND DR. RICHARD WELLER Introduction In a " Memorandum Concerning Board Questions" dated December 15, 1978, the Board stated that it has received the " Revisions to NRC' Staff Evaluation of Liquid Radwaste System" dated November 3, 1978. The Board noted that "the Staff assumed that 50% of the regenerant solutions will be discharged to the coolant reservoir without treatment." Under that assumption the Staff has estimated a release of 3.8 Ci/yr, over 100 times greater than estimated by the Applicant. However, the Staff's estimate of uhole-body dose to a nearby resident is only 0.033 mrem /yr, much less than estimated by the Applicant. Accordingly, the Board asked for further information from the Staff concerning the basis for the estimated reic:se rates and the calculation of dose.

P C OY 1)tA 600IIIO 318

. Response by Dr. Richard Weller The purpose of this response is to provide the Board with further infor-mation concerning the basis for the estimated release rates of secondary system liquid effluents to the Pebble Springs reservoir.

In addition, this response also includes and is attached as a corrected dose table, Table 2, of supplemental testimony, " Revisions to NRC Staff Evaluation of Liquid Radwaste Systems with Respect to Appendix I of 10 CFR Part 50 and Effect on Overall Cost-Benefit Balance," dated Nover. tar 3,1978, to account for input errors in the previous code calculation of the doses.

As shown in revised Table 2, the estimated doses associated with the nomal operation of the Pebble Springs Nuclear Plant, Unit Nos.1 and 2, meet the requirements of Sections II.A and II.D of Appendix I to 10 CFR Part 50. The discussion of the dose calculations is addressed below in a separate response by Dr. R.L. Gotchy.

The Staff's re-evaluation (November 3,1978 testimony) of the discharges of radioactive material in liquid effluents i:; based on the Applicant's submittal of Amendment 12 (June 1978) to the PSAP..

In Amendment 12, the applicant modified the manner in which the processing of wastes in the Dirty Radwaste System (DRS) is controlled. The modification con-sists of deleting the commitment to fix the setpoint of the DRS process radiation monitor at 10-6 uCi/cc to allow greater flexibility in the operation of the plant. This monitor determines whether the regenerant 1

s solutions will be directed to the DRS for processing or to the supple-menta'l waste holdup tank for ultimate discharge to the reservoir.

In view of the deletion of the comitment to the radiation monitor fixed setpoint and the planned greater flexibility in plant operation, the staff assumed that 50% of the regenerant solutions would be discharged to the coolant reservoir without treatment. The previous staff Appendix I testimony (July 29,1976) assumed that all of the regenerant solutions vrould be processed in the Dirty Radwaste System.

It should be noted that the Applicant's model assumes that all secondary system wastes are dis-charged to the reservoir without processing.

The staff assumption of 50% discharge of regenerant solutions is based on several considerations.

Firstly, the applicant has committed to satisfy the design objectives of Appendix I to 10 CFR Part 50, but has not committed to recycle wastes to the maximum extent practicable.

Thus, the staff has assumed a higher discharge fraction for the Pebble Springs liquid effluents than would be assumed for a plant with a maxi-mucm re.ycle comitment. Secondly, the staff assu'nption of 50% discharge of regenerant solutions permits the applicant to satisfy the design objectives of Appendix I while operating the plant with the desired flexibility. Since it is less costly to discharge regenerant solutions than to process them through the DRS, there is an economic incentive to discharge wastes to the maximum extent consistent with the objectives of Appendix 1.

The assumed discharge of 50% of the regenerant solutions N

1 results in a calculated liquid source term of 3.8 Ci/yr/ reactor (the design objective in the Annex to Appendix I is 5 Ci/yr/ reactor).

It should be noted that this source term is based on " expected" values, over the assumed 30 year life of the plant, of 1.12% failed fuel and primary to secondary system leakage of 100 lb/ day.

It should also be recognized that during the actual operation of the plant, the parameters for fraction of regenerant waste discharged, failed fuel, and primary to secondary leakage may vary significantly from the values cited above.

I For example, for those periods of operation when there is no primary to secondary leakage, all (100%) of the regenerant solutions could be discharged to the coolant reservoir with no resultant environmental impact. However, when the " expected" values for the above parameters prevail, the staff's evaluation indicates that total discharge of 100% of regenerant solutions without treatment would not be within the design objectives of Appendix I.

Conclusion For these reasons, the staff believes that its revised effluent release model is a realistic representation of the planned operation of the i

Pebble Springs nuclear plant.

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. I Response by Dr. Reginald L. Gotchy The Staff has reexamined its liquid pathway dose commitment estimates for Pebble Springs 1 and 2 as a result of releases through the " dirty radwaste system" (DRS) into the cooling reservoir. We have also examined the applicant's dose commitment estimates presented in their Amendment 12 (July 1978), Table II.2-12.

As a result of this review, the staff found the following:

(1) The tritium source term used by the Staff in its November 3,1978 dose commitment estimates was a factor of 10 low due to a card punch error. This was a significant error, since tritium accounts for most of the total body dose commitment. This error has been corrected.

i (2) The turnover rate for the reservoir which the staff had used was high by a factor of about 70. As a result, the reconcentration factor previously used was too low, and thus the corresponding dose commitments were too low. We have not been able to determine the source of this error, since the hydrologist who made the estimate is no longer with the NRC. Nevertheless, it has also been corrected, and the revised Table 2 of the November 3,1978 staff testimony (as noted in Dr. Weller's response above) is attached.

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(3) The major dose contributor to total body dose is tritium (about 80%) with the balance due almost entirely to cesium nuclides. Lyen though the applicant's source term for cesium is much larger than the staff's, there is less than a factor of 2 difference in the trititum source tems. Therefore, in terms of contributors to the total body dose commitment, there is not a large difference between the applicant and the staff's source terms.

(4)

In reexamining the Pebble Springs ER and PSAR, the staff concluded that its previous interpretation of potential exposure pathways is correct, but that the applicant has generally been overly conservative in their July 1978 Amendment 12. For example, unless PGE has modified their position, there will be no recreational activities permitted within the exclusion area, and land use (e.g., by Krebs Brothers, Inc.) will be limited to agricultural purposes (ER, p. 2.1-3, 2.1-9;PSAR,p.2.1-3).

Further, under terms of their agreement with PGE, Krebs is prohibited from grazing dairy animals on irrigated crops (ER, p.2.2-7; PSAR, p. 2.1-3).

However, Krebs is pemitted to water livestock at the southerly edge of the reservoir (ER, p.2.5-4; PSAR, p.2.1-3),

and the staff was unable to find an exclusion for watering dairy cattle or using irrigation water from the reservoir for growing food crops for human consumption.

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I As a result, the staff has calculated total body doses (as well as thyroid doses) for the following potential pathways:

(a) Reservoir water - beef and milk cows (watering)__. man (b) Reservoir water food crops - man (c) Reservoir water.__ grazing crops beef man The following pathways assumed by the applicant in Amendment 12 are in the staff's view overly conservative:

(a) Reservoir water man (drinking water)

(b) Waterfowl -nnsumption (c) Sunbathing (d) Swimming and boating i

(e) Ground contamination (requires living on irrigated grazing land).

When these pathways are removed, the applicant's estimated total body dose would be 0.066 mrem /yr which compares very well to the staff's revised estimate of 0.10 mrem /yr without the milk pathway or 0.21 mrem /yr with the milk pathway for an infant. Thus, the corrected staff estimate would be in reasonable agreement with the applicant for those pathways which could potentially exist.

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Conclusion In conclusion, the staff found and corrected some modeling errors and a punch card error in the tritium source term. The staff finds many of the applicant's assumed pathways are overly conservative and are excluded by written agreements with the land owner (Krebs Boos, Inc.) as stated in their ER. When the staff corrected previous errors and excluded those pathways assumed by the applice.it in their July 1978 Amendment 12 (Table II.2-12), the dose comitment estimates of the staff and applicant are in reasonable agreement.

Finally, it is concluded that the previous conclusions regarding the Appendix I analysis for liquid pathways at the Pebble Springs site remain the same, i.e., the liquid pathways for the proposed two unit station would not result in dose comitments in

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excess of Appendix I design objectives.

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TABL" ' (Revised January, 1979)

I COMPARISDN OF PEBBLt JRINGS NUCLEAR PLANT, UNIT NOS. a1 AND 2 WITH APPENDIX I TO 10 CFR 50, SECTION II.A (MAY 5, 197g) AND SECTION 11.0, ANNEX (SEPTEMBER 4, 1975) b Appendix la Annex Calculated c

l Criterion Design Objectives Design Objectives Doses l

l Liquid Effluents Dose to total body from all pathways (Adult) 3 mrem /yr/ unit 5 mrem /yr/ site 0.21 mrem /yr/ unit Dose to any organ from all pathways (infant thyroid) 10 mrem /yr/ unit 5 mrem /yr/ site 1.1 mrem /yr/ unit 1

Doses to Population within 50 mile radius Liqui'd Effluents Dose to total body from all pathways.

Units 1 and 2 1.4 man-rem /yr afederal Register, V. 40, p. 19442, May 5, 1975.

bFederal Register, V. 40, p. 40816, September 4, 1975.

Design Objectives given on a site basis.

Therefore, these design objectives apply to c

2 units at the site.

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