ML20062J687
| ML20062J687 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/31/1980 |
| From: | Stoddart P Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20062J670 | List: |
| References | |
| NUDOCS 8011040500 | |
| Download: ML20062J687 (6) | |
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UNITED STATES OF AMERICA HUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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NRC STAFF TESTIMONY OF PHILLIP G. ST0DDART RELATIVE TO GROUNDWATER CONTAMINATION (BOARD QUESTION 9.b)
Q.1.
Please state your name and position with the NRC.
A.
My name is Phillip G. Stoddart. I am an employee of the U.S. Nuclear Regulatory Commission assigned to the Effluent Treatment Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
Q.2.
Have you prepared a statement of professional qualifications?
A.
Yes. A copy of this statement is attached to this testimony.
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4.3.
Please state the nature of the responsibilities that you have had with respect to the Three Mile Island Nuclear Station, Unit No. 1.
A.
I was responsible for reviewino part of TMI's response to the Commission Order of August 9, 1979. Specificall.y, I reviewed their proposed methods for achieving separation and/or isolation of-the inventory of radioactive i
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liquids at TMI-2 from TMI-1. I was also responsible for reviewing and -
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2 evaluating TMI-l's confermance with Appendix I of 10 CFR Part 50 and for reviewing and evaluating portions of TMI-1 responses to NUREG-0578.
Q.4.
What issues are you discussing in this testimony?
A.
I am addressing Board Question 9.b, which states:
"9.b.
What measures are taken to ensure against contamination of the groundwater under routine operations, accident conditions, and cleanup operations?"
The balance of Board question 9 is separately addressed in the testimony of r
Terry L. Johnson.
Q.5.
Describe the measures taken to ensure against contamination of the ground-water under routine, accident, and cleanup operations.
A.
The basic measures taken to ensure against contamination of the groundwater from routine, accident or cleanup operations are' contained in the design and construction of the plant. The plant was designed to accomodate gross failure or leakage of the radioactive liquid systems without significant impact on the groundwater. Another method is to rely on administrative and operational measures to minimize the potential for groundwater contamina-tion.
Prudent practice requires that both approaches be used, i.e.,
design the plant to prevent leakage to the g oundwater as the primary line of defense, and apply administrative or operational controls over the contents of tanks containing radioactive liquids as the secondary line of defense.
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Current guidance in the area of plant design to ensure against radioactive contamination of the groundwater is contained in Regulatory Guide 1.143.._
De, sign Guidance for Radioactive Waste Management Systems, Structures, aEd Components Installed in Light-Water-Cooled Nuclear Power Plants, July 1978. Guidance is provided for design and construction of radioactive liquid system tanks to conform to established ASME (American Society of Mechanical Engineers) codes, for seismic design of foundations and struc-tures of buildings containing radioactive waste management systems, for incorporation of design features such as curbs ard sills to control r
liquid spills, provisions to monitor liquid levels in tanks, provisions to alarm potential or actual overflow conditions, and provisions for drains and overflows to be routed to a liquid radioactive waste manage-ment system.
Regtlatory Guide 1.143 was issued in 1978 and the aesign of TMI-1 predates that by several years. The NRC's licensing process does not require, in most cases, that operating plants must meet guidelines established after a i
design has been approved for construction. Nonetheless, the staff has re-viewed the licensee's FSAR in the areas of concern, with respect to current Regulatory Guide 1.143 guidelines. The TMI-1 design meets Regula-tory Guide 1.143 in most respects and in some areas the TMI-1 radioactive liquid waste management system design exceeds current guidelines. For example, liquid tanks are of Seismic Class 1 design, even though most of the i
tanks are located inside a seismically-designed and qualified structure; Regulatory Guide 1.143 now recommends only that the enclosing building I
or structure be of seismic design to a height sufficient to retain the con-tents of the tanks and does not provide that the tanks be of seismic desJgn.
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TMI-1 does not meet Regulatory Guide 1.143 in that Regulatory Guide 1.143 recommends that tanks be surrounded by elevated thresholds or curbs and, for the most part, TMI-1 tanks are not provided with such features. For example, the Borated Water Storage Tank (BWST) at THI-1 is an outdoor tank but does not have a dike or retention pond capable of preventing run-off in the event of an uncontrolled release of liquid radioactive material due to spillage. However, the BWST at TMI-1 is designed as a Seismic Class 1 tank and is designed to withstand an earthquake without loss of integrity and is less likely to leak than a tank not so designed.
TMI-1 has three design features which are somewhat unique in that they are designed to remove groundwater that may seep into the plant. These consist of three sumps at below-grade elevations and are: (1) the Borated
!!ater Storage Tank Tunnel Sump, located beneath the BWST; (2) the Heat
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Exchanger Vault Sump; and (3) the Tendon Access Gallery Sump. Discharges of collected water from all three sumps are joined and continuously monitored for radioactivity before being discharged untreated to the blowdown of the mechanical draft cooling tower.
If any radioactive leakage should get into these sumps, as in the case of a leak from the BWST, the radioactivity would be detected by the monitor and the discharge would be aut_omatically diverted to a liquid radwaste management system for treatment.
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l All indcor tanks are inside buildings designed to seismic criteria such that the loss of contained liquids would be minimal, even in a seismic event.
T N staff does not consider the absence of curbs or thresholds to be a significant deficiency. With respect to the absence of a dike or retention pond capable of preventing runoff from a spill of the Borated Water Storage Tank, the staff has determined that there is not sufficient space available for the backfit installation of such a dike or pond; the Technical Specifications provide a limit on the radioactivity content.of this tank such that a spill to the groundwater could not cause, under worst conditions, a concentration in excess of 10 CFR Part 20 limits at the nearest potential point of water consumption.
Appendix B, Section 2.0, Limiting Conditions for Operation, of the TMI-1 Technical Specifications, specifically addresses chemical and radioactive discharges in liquids to the environment and provides administrative controls over the potential for leakage. A copy is attached to this testimony for reference.
k An additional factor in the limitation of the potential for discharge or leakage of radioactively contaminated plant fluids to the groundwater is that the licensee has committed to reducing leakage from systems con-taining radioactive fluids to as-low-as-practicable levels prior to restart of THI-1. (TMI-1 Restart SER, (NUREG-0680) Section 2.1.6.a. at page C8-31, which describes the licensee's program for leakage reduction.) The staff
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has reviewed the licensee's commitment and found it to be acceptable.
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r:r W.nel 0 alificaticas Sr..ary Phillip G. Stoddart
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Ef fluent Treatment Systems Branch Division of Systems Integration
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Office of fluclear Reactor Regulation l'y name is Phillip G' Sic.ddart.
I am a senior nuclear enginear in the Lif1.ent Treatr.ent Systems Branch, = Division of Systems Inte; ration in the Of fice of !!ucitar Reactor Regulation.
I attended the !:ew I:ixico School of ;;ines from 1947 to 1949. from 1949 to 1953 I was or active' duty with the United States Air force, assigned as a radiolt.gical instrd.antation specialist with the Armed forces Special 1.'sapons Cczand and as a radio-1c.gical safety instructor with a Strategic Air Comand special weapons unit.
from 1953 to 1973 I was on the radiation safety staff of the Aigonne I ational lahoratory, working from 1953 to 1957 at Argonne's lilinois site and from 1957 to 1973 at Argonne's test facilities at the I;aticr.a1 Reactor Training
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Station, Idaho falls, Idaho. I!y duties there included conduct of radiation safety programs, including ef fluent control and wa'ste management, for several rescarch and test reactors and a fuel recycle facility.
In 1973 I joined.the I;uclear Regulatory Cormission (formarly Atomic Energy l'
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Cccnission) as a puclear engineer in the Effluent Treate.2nt Systems Branch, Division of Systems Integra. tion.
In this position I am responsible for the review and evaluation of radioactive waste systems and for the calculation
.of releases of radioactivity from nuclear power reactors.
I am also respon,ible for determining the adequacy of instru.entation provided for caintaining the radic. active discharges from nuclear pr.<cr plants and for providing technical bases for guides and standards.
I hive participated in generic studies of the relationship between reactor cgeration and radio-active waste ger.cration and in the preparation of staff reports related to efflue,nt control technology and effluent monit,oring.
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