ML20149K880
| ML20149K880 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/15/1988 |
| From: | Skolnick F SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT |
| To: | GENERAL PUBLIC UTILITIES CORP. |
| References | |
| CON-#188-5659 OLA, NUDOCS 8802240023 | |
| Download: ML20149K880 (32) | |
Text
r 5bG9 February 15th.1988.
COCXE TEC-UNC UNITED STATES OF AMERICA NUCLEAR REGUIATORY CottiISSION M FEB 19 41:00 CM TkghyjlC[-
BRAncy BEFORE THE A104IC SAFEIY AND LICENSING BOARD In the Matter of )
)
GPU Nuclear Corporation
) Docket No.50-320-01A (hree Mile Island k lear (Disposal of accident Station, Unit 2) generated water)
SVA/MIA'S RESPONSES TO LICENSEE'S INTERROGATORIES AND REQUEST FDR DOCLENTS On Saturday, January 30th. SVA/ MIA received a set of Interrogatories and Document Request frce the Licensee. Enclosed is SVA/MIA's responses.
SVA/mIA has responded to the best of their knowledge and ability,and without the assistance of any experts who may be called as witnesses.
Time restraints placed on the Intervenor by the amount of time it took to prepare the Interrogatories for the NRC and GPU Nuclear meant that these responses have not been delivered within the 14 days allowd. -
An apology is offered to all parties for this delay.
These time restraints prevented contact with exoerts so that it might be detemined who will be called and available as w tness,and which contentions might b addressed by each witness. This information will be provided to thepartiesinthisproceedingassoonasitisavailabletofheIntervenor.
Regarding the request for the production of doctments, Licensee will observe frce the referenced materials that most are already'likely to be in their possession.
The following copies of materials are being sent to the Licensee:
"Select Ccruittee on Ontario Hydro Affairs Safety of Ontario Reactors" Tuesday, July 10,1979. P25-28 Diagram of "Exposure Pathways of Radionuclides" (Source unkncun)
Abstracts from: "Radiation Research, 58 (1974) P.91-100 8802240023 880215 DR ADOCK O y0 g()3
Radiation Research,66 (1976) P.615-625)
Radiation Research,77 (1979) P.117-127 l
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3 SVA/IMIA'S RESPONSES TO GENERAL INTERROGATORIES lia). State the name, present or last known address, and present or last known anployer of each person known to Joint Intervenors to have first-hand knowledge of the facts alleged, and upon which Joint Intervenors relied in fonnulating allegations, in each of the admitted contentions.
Answer: No person had first hand knowledge of the facts alleged and was relied upon in fon:ulating allegations in each of the admitted contentions.
(b). Identify those facts concerning which each such person has first-hand knowledge.
Answer: See (a)
(c). state the specific allegation in each contention which Joint Intervenors contend such facts support.
Answr: See (a) 2(a). State the nane, present or last known dddress, and present or last utployer of each person, other than affiant, who provided infomatien upon stich Joint Intervenors relied in answering each interrogatory herein.
Answr: Reliance in answering each interrogatory herein was placed on doctrents now in Intervenor's possession.
(b). Identify all such infomation which was provided by each such persen and the specific interrogatory response in which such infomation is contained.
Answr: See above 3(a). State the name, address, title, amployer and educationdl and professional qualificationsofeachpersonJointIntervenorsintendtocalkasanexpert witness or a witness relating to any adnitted contention.
T LC Answer: At this time Intervenors have not yet determined who all of their witnesses will be. Intervenor was taken by surprise by Interrogatories which l
requested that this kind of information be given within a period of 14 days.
Intervenor has received a ccmnittment frm Dr. K.Z. tergan to act as a witness, schedule permitting. There was not ample time to detennine the contentions which witness will address. All of this information will be provided as soon as possible.
3(b). Identify the contention (s) regarding which each such person is expected to testify.
Answer: See 3(a).
3(c). State the subject matter to which each such person is expected to testify.
Answer: See 3(a).
4(a). Identify all documnts in Joint Intervenors' possession, custody or control, including all relevant page citations, pertaining to the subject ratter of, and upon which Joint Intervenors relied in fonmlating allegations in each admitted contencion.
Answer,: EIS NUREG-0683 Vo 1&2 March 1981 EIS NUREG-0683 Supplement #2 June 1987 and all references.
GPU tbclear Proposal March 1986 N.E.P.A. 42 USCS $4332 P. 346-389 Goffman, J. "Radiation and Human Health", 1981, Sierra Club Books All transcripts derived fran meetings of the Citizens Advisory Panel for the Decontamination of Unit II 1986-1987 NUREG-0591 August 1979.
>l 4(b). Identify the contention (s) to which each such document realtes.
Answer: It is impossible to identify the contention to which each dce.nent relates since all the information derived fran each doctment allcred the In;ervenor to formulate ideas and questions regarding the admitted contentions.
1 k-i 4(c). State the specific allegation in each contention which Joint Intervonors contend each doctrnent supports.
Answer: See above.
5(a). Identify all doctrnents in Joint Intervenors' possession, custody or control, including all relevant page citations, upon which Joint Intervenors relied in answering each interrogatory herein.
Answer: See 4(a) and see answer to each Interrogatory at the bottan of which is a reference when required and/or when possible.
5(b). Identify the specific interrogatory response (s) to which each such document relates.
Answer: See above.
6(a). Identify any other source of infonration, not previously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.
Answer: See 5 (a).
6(b). Identify the specific interrogatory response (s) to which each source of infonration relates.
Answer: See 5 (a).
7(a). Identify all documents which Joint Intervenors intend to offer as exhibits during this proceeding to support the admitted contentions or which l
Joint Intervenors intend to use during cross-examination of witnesses presented l by Licensee and/or the NRC Staff on each admitted contention.
. Answer: No doctraents have as yet been identified which will be offered as exhibits. #
}
7(b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention.
Answer: See (a).
i i
l SVA/IMIA'S RESPONSES E
SPECIFIC ItfIERROGA1 DRIES 0-1. Is cost a relevant factor to consider in determining the appropriate method for disposal of the accident-generated water?
Answer: Yes, cost is a relevant factor. ,
(National Envirorrnental Policy Act of 1969:
42 USCS $ 4332, n 62 Pg. 368, paragraph 3) 0-2. Is there a safe level of exposure to radiation?
Answ r: No, there is not a safe level of exposure to radiation.
(NRC EIS, Supp.12.
NUREG-0683, pg. 7.24 section 7.5.3 Encyclopaedia Britannica "Hazards of I m -level Radiation" by Karl Z. Morgan P.216 - 229.)
0-3. Do the radiological release limitations adopted by the NRC and EPA provide adequate protection for the public?
Answ r: [t is Intervenor's position in this proceeding that there is no safe level of exposure to ionizing radiation and that all doses must be as low as possible.
See references for above, e
l l 0-4. If the answer to Interrogatory 0-3 is negative, Wave Joint Intervenors filed w;.th the NRC and/ or EPA petitions for rulemaking, seeking revisions to the release limits?
Answ r:
Intervenor feels this question to be objectionable since it does not appear to have any relevance to any of the contentions.
l
a 0-5. In a statenent on August 13, 1986, to the NRC's Advisory Panel for the Decontamination of IMI-2 (Tr. 77), Ms. Frances Molnick stated that she rejected the radiological dose limits set by the NRC and any other agency because there is no permissible dose which is not detrimental to human health and the environment. Is this Joint Intervenors' position in this proceeding?
Answer: The Joint Intervenors position in this procedure is as follows:
There is no safe level of exposure to radiation,and all exposures cust be kept as low as possible. -
(NRC EIS, Supp. #2 NUREG - 0683, Pg. 7.24 section 7.5.3 Encyclopaedia Britannica "Hazards of !.oW-lavel Radiation" by Karl Z. Morgan P. 216 - 229).
0-6. Contentions 2 and 8 together propose that the NRC consider or consider further three options: the "no action" alternative which supposes interim storage of the AGW in tanks on the TMI site and eventual disposal of the water (Tr. 65, prehearing conference of Decanber 8,1987); evaporation in a closed cycle with the bottans and condensate being solidified and shipped to a low level waste site; and pemanent storage inside contaiment.
(a). khich, if any, of these three options do Joint Intervenors propose be adopted?
Answer: khen more infomation is available it may be possible to identify !
a preferable option.
(b). If there is one option you advocate, why do you want NRC to evaluate the other two?
Answer: See (a)
(c). If there is not an option you advocate, is itdbecause you lack sufficient information to make a decision? State #any other reason.
Answer: Yes, w lack sufficient infomation. See (a).
(d). If you do not have sufficient infomation to arrive at a preference, why do you believe you have an adequate b& sis upon which to suggest that the NRC evaluate these options?
4 1
l Answar:
The NRC is mandated by the National Envirornental Policy Act of 1969 to evaluate these and other feasible options.
(National Envirornental Policy Act of 1969:
42 USCS 5 4332, n 52. pg. 360, paragraphs 1 & 2).
(e).
Do you contend that the NRC should expend resources assessing
, alternatives which you have not even concluded to be potentially superior?
Answer: Yes. See (a) - (d) .
1-1.
List the evaporation proposal and the "other methods of water disposal" U 4 to which Contention 1 refers, in order of Joint Intervenors' preference when evaluated against the ALARA principle.
Answer:
Joint Intervenors cannot rank disposal methods in order of prefer-ence until more detailed infonration is provided on alternatives,such as closed cycle evaporation and the Licensee's capabilities for interim or permanent storage in tanks on site.
1-2.
Identify and describe the bases for the ranking provided in respense to Interrogatory 1-1.
Answer: See 1-1. No rarking.
1-3.
Is river disposal more in keeping with the ALARA principle than the proposed disposal by evaporation?
Answer: No.
River disposal is not more in keeping with the AIARA principle.
1-4 )
If the answer to Interrogatory 1-3 is affinrative, would Joint Intervenors prefer river disposal of the accident-generated water over disposal by evaporation?
Answer: See 1-3.
,s 1-5 If the answer to Interrogatory 1-4 is negative, explain the reasons for the answer,any supporting basis,and any factors ccmsidered other than radiological releases.
. Answer: The reasons and supporting basis for the answer to 1-4 are:
- 1) The amount of tritim released to the enviroment is virtually the same sixe tritium cannot be rmoved from the water proir to disposal by either of these methods.
' 2) Similar to the evaporation method dmping the water into the river does not isolate radioisotopes from the enviroment as other methods of disposal might.
E.I.S Nureg 0683,Supp1 ment #2, June 1987,P.3.3-3.6 and P.3.27.
Factors other than radiological releases include:
- 1) Cnmicals contaminants will be released into the drinking water source.
- 2) The people do not want their drinking water contaminated.
- 3) It is contrary to the efforts of Federal and State agencies to clean up the Chesapeake Bay.
E.I.S Nureg 06B3,Supp1 ment #2, June 1987, P. A.51 totter #28 I.) Psychological stress incurred by the action of dumping 2.3 million gallens of radioactive water into a ecxmunity's drinking water source. ,
Prince-Embury,S. and Rooney,J.F. "Psychological Symptros of Middletcm ;
Residents Post-Restart of Three Mile Island" (1987) l
)
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e 1-6. Should societal considerations be assessed in traking an A1APA determin-ation? '
Answer: 'Ihe AIARA principle is based on the recognition that there is no safe level of radiation expcsure to the public, therefore societal consider-ations are ernbodied in the AIAPA principle.
1-7. Do societal considerations include local public and political preferences?
Answer: Societal considerations do include local public and political preferences since we asstrae that the p2blic and political bodies make the determination that the risks involved with any technology or project are exceeded by the benefits.
1-8. Do Joint Intervenors contend that AIARA requires selection of the disposal alternative with the lowest radiological consequerres?
Answer: Yes.
1-9. If the answr to Interrogatory 1-8 is affirmative, identify and describe any bases for the response. Address in particular how the NRC may ccrnply with NEPA and ignore non-radiological impacts in its decisien.
Answer: Intervenors contend that AIAPA requires selection of the dispsal alternative with the lowest radiological consequences and non-radiological consequences.
(EIS NUREG-0683 Vol. 1 Page 1-17, section 1.6 (b)
NEPA 42 USCS S 4332 N62 Para. 14 j NEPA 42 USCS S 4332 N66 Para. 1
'Ihe NRC nust comply with NEPA in determining the costs and benefits of any project.
1-10. If the answer to Interrogatory 1-8 is negative, explain how Joint Intervenors contend the ALARA principle should be used in carparing the alternatives.
Answer: See 1-8.
1-11. Do Joint Intervenors contend that the proposed evaporation method does not canply with the AIAPA principle?
Answr: Yes.
1-12 If the answr to Interrogatory 1-11 is affinrative, describe in detail the canner (s) in which evaporation does not carply with the AIARA principle and set forth in detail the basis for the answr.
Answer: From the infonration provided in the E.I.S Nureg 0683,Supplanent #2, and the GPU Nuclear Proposal,the evaporation method does not canply with the ALARA principle because:
a) it is not that option which will deliver the least 12npact upon the population b) Ccrpliance with 10 CFR Part 50, Appendix I has not been show with relation i the evaporator to be used.
l 1-13. Does Appendix I to 10 C.F.R. Part 50 apply to the oisposal of the accident-generated water? Set forth in detail the bases for your answ r.
l l Answer: Yes. Following selection of an option for the disposal of the
! water,10 C.F.R. part 50 Appendix I nust be canplied with. This includes the nunerical guidelines and the consideration of all itans which might reduce the dose to the population within 50 miler of the reactor.
See 10 C.F.R. part 50, Appendix 1.
e 1-14. Identify each of the "other methods of water disposal to which Contention 1 refers, which "would not release a quantity of radionuclides into the envirorment." Identify and describe the bases for the answr for each i thod.
Answar* Otk c ethods of disposal which would not release a quantity of radimides int a the envirorment as the evaporation method would, include:
- 1) distilla~. ion either on-site or off-site
- 2) off-site evapors' ion
- 3) interim moni u d on-site storage
- 4) permanent monitored on-site storage
- 5) on-site solidification with off-site burial khile Intervenors may disagree with the releases frcxu the various options, for the sake of this response, reliance is placed on the correctness of the relative impact frcm each disposal method,as shown in Table 5.1 EIS.
Option 1 is not included in this table. However, it is assumed that releases from a closed cycle evaporation method would be less than with an open cycle since the vapor with the contaminants would be collected and solidified or trucked off to a 1cw level waste site.
1-15. Identify each of the "other methods of water disposal" to which Contention 1 refers, which "would not release all the critiun into the envirotraent." For each method identified, quantify the amount of tritium released, describe where the remainder (not released) is, and set forth the bases for the answer. ,
Answr: The methods are:
- 1) distillation with burial off-site of all waste created
- 2) interim tronitored stcrc,,
l 3) pemanent tronitored storage l 4) solidification and burial off-site It is not possible for the Intervenors to quantify the amount of tritiun released at this time,because they are awaiting confimatior. of tritium content.
- l. 1-16. Do Joint Intervenors centend that modifications to the evaporator are necessary and/or appropriate to meet tdARA?
l Answer: At this point Joint Intervenors have not viewd plans for the l evaporator. NRC regulations require ccepliance witn 10 CFR Part 50, App.I.
! 1-1/. If the answr to Interrogatory 1-16 is affimative, idbntify the t:odifications and, for each, estimate the cost and dose reduction.
Describe the bases for each esticate.
Answr: See 1-16. ,
1 l
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2-1. (a) Do you contend the no-action alternative involves fewer costs and risks to the public than the proposed evaporation metbod?
Answer: Using Table 6.1 of the NRC's EIS, Supp. #2, NLTIG 0-6%, for a comparison of costs and risks, the answer is "yes".
2-1.(b) If your answer to the preceding Interrogatoty is affirmative, state in detail all of the facts which support your allegations that the no-action alternative involves fewer costs and risks to the public than the proposed evaporation method.
Answer; he no-action-alternative involves fewer costs and risks provided the Licensee uses proper tankage and conitoring instrunntation. Bere would be minimal releases to the public especially if the water was processed so that it contained the mininum amount of contaminants. Be risk of transportation accidents would be reduced.
EIS Nureg 0633,Suppluxnt #2, June 1987, Table 5-1 and P.3.32-3.34 2-2. In light of your contention (Tr. 65) that the "no-action" alter-native supposes interim storage of the AGW it, tanks on the B I site and eventual disposal of the water, please identify:
a) the estfrated length of storage (years) enecepassed in the no-action altemative; ,
Answer: De estimated length of storage equals the rmber of years for the radioactivity to decay to harmless levels.
b) the estirrated length of tank life enecmpassed in the no-action alternative; Answr: Not enough information provided by NRC or Licensee c) the esticated size of storage tanks enecepassed in the no-action alternative; Answr: Bose crost convenient to the Licensee '*hich cceply with all regulations.and give adequate protection to the wrkers and the public, l
e s.
d) the location on the 21 site where storage tanks would be placed; Answer: ~ That location which'is least hazardous to suployees and most
. accessible to radiation monitoring.
e) the program and system for monitoring and preventive maintenance.
you propose to ensure storage tank integrity;
' Answer: The program and system for monitoring and presentive maintenance is dependent upon the quality of storage tanks.
f) the eventual disposal method enecrnpassed in the no-action alternative.
Answer: That method which entails the least health impact on the surrounding population.
2-3. Inecxuplying with NEPA, should the NRC limit its consideration to environnental . impacts which occur in the near-term, ignoring those which would occur in 25 to 40 years?
Answer: No 2-4 (a). In light of your contention that the "no-action" alternative supposes interim storage of the AGW on the EI site and eventual disposal of the AGW, is it also your contention that the "no-action" alternative has no radiological i m et?
i Answer: The "na-action" alternative has less radiological imncet than other methods of disposal.
! 2-4 (b). If your answer to the preceding interrogatory is affirmative, state in detail all of the facts dich support your allegation that the i "no-action" alternative has no radiological impact.
1'
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Answer: See 2-4 (a) .
2-5 (a). Inlightofyourcontentionthatthe"no-action"a}ternative
' supposes interim storage of the AGW on the mI site and eventual disposal
> of the AGW, is it also your contention that the "no-action" alternative will cost almost zero dollars?
Answer: No.
2-5 (b). If your answer to the preceding interrogatory is affirmative, state in detail all of the facts which support your allegation that the "no-action" alternative will cost almost zero dollars, considering as well
o 1 l
your answer to interrogatory 2-2.
Answer: See 2-5 (a) 2-5 (c). If your answer to Interrogatory 2-5 (a) is negative, state your estimate of the cost and your bases for the estimate.
Answer: R2rther information would be needed to estimate the cost of the tanks. For example, the quality and therefore the cost of the tanks would be dependent on the amant of time the water would need to be stored.
1 0
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o 2-6. What are the benefits of postponing disposal of the accident-generated water?
Answer: Radioisotopic decay will occur with time.
Goffman, J.W.1981. "Radiation and linnan Health" P. 33-36, Sierra Club Books San Francisco Also more advanced technology.
2-7. Have you estinuted the risks of accidental release of the water (e.g. ,
tank failure) during the storage period? If so, state the estimate and the basis for it.
_ Answer: lb 2-8(a). r)o you contend the Staff's conclusion that the envirorre. ental kpacts from ultimate disposal wculd not be significantly different frca near-term disposal is incorrect?
Answr: It depends when ultirate disposal would take place, and the technology available for disposing of it.
(b). If your answer to the preceding interrogatery is affirmative, state
' in detail all of thefacts which support y:ur allegation that the enviromental impacts frca n1tirate disposal would be significantly different frcm near-te-disposal.
Answer: See (a).
2-9. Is it Joint Intervenors' position in this proceeding that Ihne Mile Island is a suitable site for long-term storage of the AG'd?
Answer: lb. It is our position that even thcugh Ihree Mile Island may not be a suitable site for long-term storage of the AG'J, it has been and id11 be a site used for storing Icu level waste. (GPU Nuclear Proposaj, March 1987.)
3-1 (a). Do ycu contend that the Staff's evaluation in the PEIS of the radio-logical effects of evaproation of the AGW is inadequate?
Answer: Yes.
(b) If your answer to the preceding interrogatory is affirrative, state in detail each alleged inadequacy in the Staff's evaluation and all of the facts which support each alleged inadequacy.
Answr: Ihe inadequacies and the facts which support each inadequacy are to e--- , . - - - - - - - - ~ _ . _ , ., .- - , - -
be found in the camients by the follodng:
- 1) Carl Johnson P. A137-A138
- 11) Karl Morgan P. A36- A40 iii) Richard Piccioni P.A102-A115 iv) Ernest Sternglass P. A116-A130 9 v) Michio Kaku P.A131-A134 Which are to be found in the EIS, Supp1 ment #2, NUREG 0683, 6/87.
The inadequacies of the EIS are also found in those statanenta found in the EIS, Supplanent #2, NUREG 0683, made by:
- 1) Frences Skolnick P. A62; A92
- 2) Vera Stucinski P. A89 3-2. State in detail all of the enviromental impacts you contend are assoc-iated with the release of radioactive material from the evaporation process ,
into the food chain, water, humans and ecosystm.
Answer: See attached diagram "Exposure Pathways of Radioactive effluents of
!belear Facilities".
4 3-3(a). Do you ccntend that the release of radioactive material fra the evaporation process into the food chain, water, hwans, and ecosystmi will
^
have any impaer. en hran health in the 50 mile area surrwading the mI site -
gar: Yes.
(b) If your answr to the preceding interrogatory is afficative, state in detail all of the facts which support your contention.
Ansar: hhen radioactivity is released to the enviroment it enters the food chain, the water and the ecosystm all of which provide pathways to the huran organism. Since there is no such thing as zero radiation because of natural background radiation there is then no such thing as zero impact. Since even backgremd radiation has an impact on the ecosysts and hyd health, it can be cone..uded that additional release frcrn evaporation whill have impact over and above the impact of background radiation.
See "Hazards of Im-trvel Radiation"by K.J. !trgan, Encyclopaedia Britannica, P. 216-229.
3-4 Assining the NRC Staff's esticate, in the PEIS, of the radiolegical releases frcm evaporation, identify each and every NRC regulation,1PA regulation, applicable permit and license condition which you contend would be siolatec by the releases. For each violation, state the requirenent and describe the canner in which the release violates it.
Answer: The Joint Intervenors position is that we have inadequate information about radiological releases frce evaporation since we have seen no plans for the evaporator, and have not reviewed the practical application of the Licensee's proposal.
3-5 (a). Do you contend that the Staff's evaluation of the risks and costs associated with the tn2cking of solidified waste frca the evaporation of the AGW to a low-level waste disposal site is inadequate?
Answer: At this time the Intervenors question the follodng:
"The most significant potential impact associated with any disposal alternative was identified as the risk of physical injury associated with transportation accidents (i.e., a maximum of 8 chances in 10 that an individual weald be fatally injured)." .
(NRC, EIS, Supp #2, WREG 0-6383, page vi.)
(b). If your answer to the preceding interrogatory is affimative, state !
in detail each alleged inadequacy in the Staff's evaluation and all of the facts which support each alleged inadepey.
Answer:See (a). We need further investigation and infomation to respcnd.
4-1. The NRC Staff, discussing the environmental impacts of the proposal, states: "Releases of 0.1% or less of the total particualte are routinely achieved,andthisreleasefractionhasbeenassumedforthe} evaporator effluent." NUREG-0683, supp. No. 2 at 3.6. Describe in detail any basis you have for challenging that asstaption.
Answer: We challenge the asstept'on because no infomation was advanced to support this claim.
I
4-2. Describe the experience Joint Interv:nors have with evaporator systm design, operation and perfonrance.
Answer; Experience is based on infonration advanced to the public by NRC and Licensee.
4-3. The NRC Staff also states: "Based on the expected radionuc.lide concent-ration in the influent to the evaporator, the release rate for non-tritim radioactive material, principally cesim-137, strontim-90, and carbon-14, is expected to be 0.00028uCi/sec." NUREG-0683, Supp. No. 2 at 3.6-7. Describe in detail any basis you have for challenging that estimate.
Answer: We challenge this estimate at this time for the following reasons:
- 1) It needs to be ascertained whether or not the "expected" concentration is indeed the same concentration as that which will actually go into the evaporator. Responses to Interrogatories to the NRC and the Licensee will be used by the Intervenor to detemine this.
- 2) It is unsure from the NRC statment in the EIS that all non-tritium radioactive traterial was included.
- 3) We challenge the representativeness of sanples taken.
- 4) The NRC is making all calculations based on the Licensee's sa:gle analysis.
4-4 Define the tem "filter out" as used in Contention 4b. In particular.
are you speaking of any rcm val mechanism?
Answer: The term "filter out" is meant to to my reeval mechanism, including i
a filter.
4-5. Identify each and every air quality regulathn of EPA and Pennsylvania, permit, license or other air quality requirment which you centend would be violated by the proposed evaporator effluenc. For each violation, state the requirement and describe the manner in which the release vio'. ares it.
Answer:Further infomation on the evaporator effluent and the ability of ,
the evaporator to perfom is needed prior te responding to this.
' i 4-6. If the tritim level in the evaporator influent is sa: p1 d and it is known that the tritium will be released to the atnesphere, why do ycu contend that the evaporator offluent should be cenitored for tritium?
Answr: The evaporator effluent should be monitored for tritium because the Licensee's technical specifications define allcwable releases into the air.
[GPU Proposal 3/86 P. 22]
4-7. Identify any instrumentation of which you are aware that is capable of casuring strontitrr.-90 at the levels predicted for the evaporater effluent.
Answr: We do not have any infomation in our possession abcut instrumentation for measuring anv. IcVels of strontium.
?
4-8. Joint Intervenors stated at the special prehearing conference that thc rate at which influent is fed to the evaporator "is particularly relevant because theparticulate release rate is dependent on the particulate concentr-ation in the water, and the feed rate to the evaporator, and the carry-over action for the evaporator." Tr. 35. Given that the rate of release is affected by the feed rate, nevertheless how is the population dose frcm the disposal of the AGW affected by the feed rate?
Answer: The dose to the population at any particular time is determined by a variety of factors which include, but are not limited to:
- 1) evaporator effluent ,
- 2) doses fran any other source
- 3) meteorological conditions at time of release
- 4) intake of particulates by any individual 4-9. In W.at ways do you contend that the public health and safety is jeopard-ized by a variation in the feed rate? State the bases for the answer.
Answer:Since the standard evaporator is expected to operate with a 0-3 gallon per minute feed rate, increasing the feed rate may affect the operability and effectiveness of the evaporator. Further, it has been noted in NRC docu-ments that evaporators have certain operational problans. These may be exacer-bated by increasing the feed rate.
See UJREG 0591 P. 23. ,
i 4-10. Is there any radiological 1. pact (leaving aside the pc;niation doce, l addressed in Interrogatory 4 8) which you contend would be affected by the -
t l feed rate?
piswr: At any time an additional dose of radiation to a mceber of the pblic may have nore detrimental effacts.
See: Select Ccrnittee on Ontario Hydro Affairs, Safety of Ontario Reactors,
'Ibesday July 10, 1979. Dr. Padford P. 27, Para. 5. )
4-11. If the answer to Interrogatory 4-10 is affinrative, identify each impact and describe how it would be affected by the feed rate. State in detail the bases for your answer. .
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Answer: See responses to 4-9 and 4-10.
No dose of radiation may be seen in isolation of doses received by a manber of the population fran other sources of radiation. All doses will contribute to the irc: pact at any one particular time. Therefore,as the feed-rate to the evaporator increases,the ammnt of contaminants released will increase and be added to the radiation in the envircanent fran other sources.
4-12. Do you contend that a feed rate of 5 gallons per minute is unsafe or hamful? If so, state the ways in which such a rate is unsafe or hamful, and the bases for your answer.
Answer: See Answers 4-9 to 4-11.
Early information to the public from the Licensee proposal indicated that the expected feed-rate was 0-3 gallons per minute (GPU Proposal P. 29), since this was the standard expected fran transportable industrial evaporators.
We have been provided with no further evidence to show that it is safe to evaporate at this or any other rate.
5-1. khat hamful properties do you contend are associated with tritim?
Answer: The hamful properties of tritiun include:
- 1) Its ability to give off ionizing radiation
- 2) Its ability to enter the body by direct penetration of intact skin.
("A Radiation bbnitoring Systan for thelear Pever Plants" Three Mile Island Nolic Health Fund,Decunber 1957.
- 3) Since the half life of tritium is 12.3 years,tritiun is a source of potential chranoscmal insult for scrne years and can tp rained down on virtually any area.
- 4) Because it is a radioactive isotope of hydrogen,it is r_adily incorporated into the body where it can becane a source of interral radiation.
5-2. khat are the types of health effects frcrn tritium that y)6u claim could occur or should be evaluated?
Answer: The types of health effects fran tritiun include:
a) cancer b) birth defects 5-3. For each property and health effect identified in response to Interrog-atories 5-1 and 5-2, describe in detail any bases for supposing that such properties exist and that such effects would occur. Identify any supporting studies or references, as required by General Interrogatory S.
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a 5-3. For eachproperty and health effect identified in respanse to Interroga-tories 5-1 and 5-2, describe in detail any bases for supposing that such- ,
properties exist and that st:ch effects would occut. Identify any supporting studies or references, as required by General Interrogatory 5.
Answ r: The bases for trititn's properties are reflected in the following literature:
EIS NUREG-0683, Suppl eent #2 6/87 P. 2.6 52.2.1.1.& 2.6 $2.2.1.2 Encyclopaedia Britannica, K.2. tbrgan P. 218 The bases for health effects:
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EIS NUREG-0683, Supplanent #2 6/87 P. 2.6 52.2.1.1 & 52.2.1.2 Encyclopaedia Britannica, K.Z. Morgan P. 216-229 Dobson, R. Imry, Cooper, Mary F. "Tritite Toxicity":
Effect of Im-level H.O.H. Exposure on Developing Farale Genn Cells in the Fbust."
Radiation Research 58,91-100 (1974).
Zamenof, S. Van Marthens, E. , "Ihe Ef fects of Chrenic Ingestion of Tritiated Water on Prenatal Brain Develo;nent": Radiation Research 77, 117-127 (1979). _
Dorsey, A.J. , Fbholt, B.Carrnt to the Draf t' i1C NUREG-0653, March 1931, P.ll .
See 5-1(2) P.32.
Such health effects could be seen to occur because there is no levek of e.posure to icnizing radiatico which qv be deened safe.
Encyclopaedia Britarr.ica, K.2. Morgan P. 216-229. ,
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5-4, Do you disrote the dose estimate in the NRC Staff's PEIS (NUREG-0683,C
- Sup;$. #2)?
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- I, Answr: Yes. ,
5-5. If the answer to interrogatary 5-4 is affrimative, state which estimates you dispute, describe your basis for disputing each, state your own dose estimates and the basis for each.
Answr:l ee S K.Z. Nrgan's ccrment is EIS Supp1 ment #2 NUREG-0683, 6/87 A37.
- 2) See Statment by Richard Piccioni, EIS Suppp1 ment #2 NUREG-0683 6/87 A102-A115. *
- 3) See Statment by Ernest Sternglass, EIS Supp1 ment #2 NUREG-0683 6/37 ,
A116-130.
Within these statments can be found those dose estimates and the basis for each
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for the infonration which we presently have. y 5-6. Quantify the health effects frce trititra you contend anld cccur frm the proposed disposal by evaporation, and describe the bases. for your answer. '
Answer: See answers to 5-2 and 5-3. ThosepreparingtheaasArstothese Interrogatories lack the knowledge to quantify the effets of critim. s 5-7. At page 43 of the transcript of the Deceber 8,1987 special prehearing conference, Ms Skolnick referred to Dr. Michio Kaku. Please. identify his studies or papers on which you rely.
Answer: Reliance was placed on Dr. Kaku's statment on the EIS, Supp1 ment #2, NUREG-0683 6/87 P. 131-134 , , .
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5-8. At the same page, Ms. Skolnick refers to tritium as teing detrimental ',
to fetuses. Please identify precisely the studies, papers et reports on which you are basing your claim.
Answer: Dobson, R.L. and Cooper, Mary F. 'Tritim Toxicity: Ef/ect of Lw-Irvel 3 H.O.H. Exposure on Develepinz Feale Germ Cells in the Mouse"
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Radiation Research 58,91-100 (1974). ,s Dobson, R.L. and Kwan, T.C. '%e RBE of Tritim Radiation Measured in Mcose
+ _0ccytes: Increa a at Iow Exposure levels": Radiation Research, 66 615-625 (1976)
- g y'-s' 5-9. Idmiify each alpha emitter and transuranic that you contend has been ignored by the NRC in its PEIS.
, . .' Answer: The chmica} and biclogical characteristics of the follwing trans-M v ,uranics and alpha csd.tters have been ignored:
a) Plutonium radionuclides b) Americium c) Curium
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, ' d) Neptunim x e) The Bersa? Lum
\ f) Californitra ,
s ?,h J Mendelrium " ?"
l' h) Tha11dru i) Lead
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i j) Birn:th, k) Polcnium
- 1) Radium '
m) Actinium
, n) Thorium o) Protractinim p)' Uranium Above list ine.ludes all inforcation presently available to Intervenors.
- 5-10. With respect to each radionuclide identified in responsp to Interrogatory
. 5-9, provide your estimate of the level present in the evaporgtor effluent
' N and your basis for each estimate.
Answer: 14 lack the knowledge and/or information to make an estimate of the level present in the evaporator effluent.
5-11. For each radionuclide identified in response to interrogatory 5-9, j identify the specific harmful properites present and the health effects which shuld be evaluated, ecd describe in detail your bases for claiming that each l
such effect would occur.
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Answer: All radionuclides are carcinogenic substances and since there is no safe level of exposure to these radionuclides, any exposure to the above may induce cancer in the body.
(See John Goffman: Radiation & Htrnan Health (1981) Sierra Club Books) 5-12. How do the health effects identified in response to Interrogatory 5-11 vay with dose?
Answer: We are not in the position to anse r this.
5-13. Quantify the health effects from alph mitters and transuranic's you contend would occur from the proposed disposal by evaporation, and describe the bases for your answr.
Answer: Additional information and an expert's analy. sis is needed.
l 5-14 At prehearing conference transcript page 44, Ms. Skolnick referred to EPA standards in picoeuries per liter. Identify specifically the standards to stich she referred.
Answer: See Lcxrent by Dr. Carl Johnston EIS Suppleent #2 NUREG-0683. A 26-27 6-1. khy should thre effects of chmicals on EPICOR be evaluated?
Answer: See NJREG-0683 Vol. 1 Section 7 6-2. khy should the effects of chmicals on SDS be evaluated?
Answer: See NUREG-0683 Vol. 1 Section 7.
6-3. khy should the effects of chmicals on the evaporator be evaluated?
Answer: Chcraicals may affect the operability and efficien:y of the evaporator to protect the health and safety of the public, j 6-4 khat chmicals are of con:ern in Contention 6?
Answer: Any and all chmicals used or to be used during clean-up of Unit II, and all those produced by clean-up.
6-5. khat adverse consequences would these chmicals have?
Answer: Additional information is needed about the chmicals in the water before answering this question.
6-6. How is the public health and safety and/or the enviroment affected by these ch micals?
Answer: See 6-5.
6-7. If the influent to the evaporator syste is monitored and influent criteria are adhered to, what is the relevance of the effects of chmicals on EPICOR and SDS?
Answer: In order to make an independent evaluation of the influent to the evaporator the effects of the chemicals on EPICOR and SDS cust be known.
6-8. Identify chmicals permitted by the evaporator influent criteria which would adversely affect syst m operation. Explain each adverse effect and the bases for supposing that each would cccur.
Anser: !;eed additional infomation on chmical content of the water.
8-1. In light of your contention that closed cycle evaporation would withold the contaminants (Tr. 64-65), identify each conta:r.inant which would be witheld.
Answer: Ihere is a need for more infonration on the evaporator operating in a closed cycle to respond the this question. HCwver, according to tUREG-06S3, Supp1 ment #2 the condensate would be collected and "airborne effluent frm the evaporator would be essentially zero."
8-2(a). Do you contend the use of closed-cycle evaporation and subsequent solidification of the recovered water results in no release of j trititra to the enviroment?
Answer: No.
(b). If your answer to the preceding interrogatory is affimative, state in detail all of the facts which support your contention.
Answr: See (a).
(c). If your answer to (a) above is affinrative, do you consider the area beyond the 50 mile radius surrounding IF.I-2 part of the envirement?
'O Answer: See (a) 8-3(a). Do you contend that the use of closed cycle evaporation and subsequent solidification of the recovered water is preferable to the no-action alternative?
Answer: Additional information is needed abcut the characterization of the water, and the closed cycle evaporator before making a choice.
(b). State in detail all of the facts which support your preference.
Answer: See (a) 8-4(a). Do you contend that the alternative of closed cycle evaporation with bcttoms and condensate being solidified and shipped to a Icw level waste site does not increase the amount of waste shipped to a low-level burial site above the amount assuned in any single alternative considered in the PEIS?
Answer: No.
(b). If your answr to the preceding interrogatory is affirrative, state in detail all of the facts which support your contention.
Answer- See (a) 8-5(a). Ib you contend that the alternative of closed cycle evaporation with bottcr.s and condensate being solidified and shipped to a leu level waste site does not increase the a:xunt of waste to be shipped and thus increase the risk of a transportation accident above the present estirates used for the evaporation proposal?
Answer: See response to 3-5(a).
(b). If your answer to the preceding interrogatory is affirmative, state in detail all of the facts which support your contention. ,
Answer: See response to 8-5(a) >
8-6(a). Do you contend that the alternative of closed cycle evaporation with bottcms and condensate being solidified and shipped to a low level waste site does not increase the amount of occupational exposure above the a:xunt asstrned in any single alternative considered in the PEIS?
Answer: Additional inforration about evaporator operating in a closed cycle, and the solidification of the condensate is needed.
8-6(b). If your answer to the preceding interrogatory is afficative, state in i detail all of the facts which support your contention.
Answer: See (a).
8-7. Under your proposal for inside-containnent storage of the AGW, where do you propose that the storage tanks be placed?
Answer: In that place which is safest for the workers and most easily conitored !
by the workers, and which is tnost protective of the health and safety of the public. .
l 8-8. Under your proposal for inside-containnent storage of the AGW, how cuch tankage space do you estimate would be required?
Answer: Ihat at: cunt which would allow for adequate storage including space -
to allow for build-up of gases.
8-9. Under your proposal for inside-contaiment storage of the AGW, what type of floor loading would be required?
Answer: Not enough infomation or expertise available to detemine floor load-ing.
i 8-10(a). Under your proposal for inside-containnent storage of the AGW, do you contend that deccmissioning of IMI-2 would not be necessary?
Answer: I do not contend that deccmissioning of INI-2 would not be necessary.
!tre infomation is needed about Post-Defueling !tnitored Storage.
(b). If your answer to the preceding interrogatory is affinative, state
- in detail all of the facts which support your contention.
1 Answer: See response to 8-10(a).
, 8-11(a). Do you contend taht the inside-contaiment storage proposal could be implanented without ecirpliance with 10 C.F.R. part 617 I
Answer: Presently we do not have 10 C.F.R. part 61 at our disposal.
(b) If your answer to the preceding interrogatory is af fimative, state in detail all of the facts which support your allegatien.
Answer: See (a)
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8-12. State your estimate of the costs of inside-contaiment storage of the AGW, and describe in detail the bases for your estimate.
Answer: Not encugh information available now to make a cost estimate. Cost would need to include:
a) tankage b) monitoring c) workers 8-13. Do you contend that the AGW must be retained on site until it meets EPA drinking water standards? If so, state that period of time and describe the bases for your estimate.
Answer: No 8-14 At a January 21, 1987 TMI Advisory Panel Meeting, Ms. Frances Skolnick stated that crititra "will be toxic for 120 years." PEIS Supp. No. 2 at A.64 Is this Joint Intervenors' position in this proceeding? If not, state why Ms. Skolnick was in error.
Answer: It is our position that trititra is a carcinogenic substance with a half-life of 12.3 years.
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v SERVICE LIST Sheldon J. Wolfe, Chairman Jchn R. McKinstry, Esq.
Administrative Judge Assistant Counsel Atomic Safety and Licensing Commonwealth of Penn.
Board Panel 505 Executive House U.S. Nuclear Regulatory Commission P.O. Box 2357 Washington, D.C . 20555 Harrisburg, Pe. 17120 Glenn O. Bright Thomas A. Baeter, Esq.
Administrative Judge Shaw, Pi t tmari, Potts c.
Atomic Safety and Licensing Trowbridge 2300 N Street, N.W.
Board Panel Washington, DC 20037 U.S. Nuclear Regulatory Commission Washington, D.C. 20111 Dr. Oscar H. Paris Stephen H. Lewis, Esq.
Administrative Judge Office of the General Atomic Safety and Licensing Counsel U.S. Nuclear Regulators Board Panel U.S. Nuclear Regulatory Ccani ss i on Commiss on Washington, D.C. 20555 Washington. DC 20555 Dr. William D. Travers Ms. Vera Stuchinski Dir. Three Mile Island Three Mile Island slert Cleanup Project Directore 315 Peffer Street P.O. Box 311 Harrisburg, Pa. 17102 Middletown, Pa. 17057 Dxkedng & Services Branch R. Rogan, Director Secretary of the Camission Licensing and tbc1 car Safety U.S.N.R.C. El 2 Middletmen, PA 17057 Washington,DC 20555.
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Frances Skolnick
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UNIIT.D STAIT.S OF AMERICA NUClIAR REGULATORY C0t+11SSION BEFORE THE ATOMIC SAFFIY AND LICENSING BOARD In the Matter of )
GPU Nuclear Corporation ) Docket No. 50-32')-otA Three Mile island Nuclear Station, ) Disposal of Ace!. dent-Unit 2 ) Generated Water
)
AFFADAVIT OF FMEES SKOLNICK I, Frances Skolnick, being first duly sworn, deposes and says that:
- 1. I am a nunber of The Susquehanna Valley Alliance and Three Mile Island Alert and represent those organizations as an intervening patty in the above captioned action.
- 2. I have read the foregoing responses to interrogatories, and the same are true to the best of my knculedge.
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FRANCES SKOLNICK
. DAT_T.D: February 16, 1988
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Sworn and subscribed before me on this M day of Februaryf9BS,
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U%RC 1B FB 19 41:00 February 14,1 lCE CF k oe.tae ,
CMEliNG 4 SE'4VICf.
lNITED STATES OF AMERICA
!OC'.IAR REGUIATORY C0tEISSION BEFDRE 13. ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of l GPU Nuclear Corporation ) Docket No. 50-320-01A Three Mile Island Nuclear Station, Disposal of Accident-l Unit 2 ) Generated k'ater
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing SVA/IMIA's Response to GPU Nuclear's Interrogatories were served this /6 th day of February upon GPU Nuclear .by Express trail and by first class postage prepaid mail on February 16, 1953, to tne reainder of the service list.
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Frances Skolnick e
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