ML20149M862
| ML20149M862 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/19/1988 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML20149M863 | List: |
| References | |
| CON-#188-5684 OLA, NUDOCS 8802290175 | |
| Download: ML20149M862 (50) | |
Text
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, ='%maa DOCKETED USNRC
'E FEB 24 P3 T@ruary 19, 1988 OFFICE N %vt iW<
UNITED STATES OF M ^ d' E H V K.I.
. NUCLEARREGULATORYCOMMIs_Ibh' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of )
)
GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA
) (Disposal of Accident-(Three Mile Island Nuclear ) Generated Water)
Station, Unit 2) ) i 4 LICENSEE'S ANSWERS TO SVA/ THIA'S INTERROGATORIES TO GPU NUCLEAR CORPORATION Licensee GPU Nuclear Corporation, pursuant to 10 CFR 2.740b, hereby submits the following responses to the SVA/ THIA interrogatories dated February 3, 1988, and received on February 8, 1988. The provision of answers to these interrogatories is not to be deemed a representation that Licensee considers the information sought to be relevant to the issues in this proceeding. l l INTERROGATORY NO. G1 - State the name, present or last known address, present or last known employer, professional and educational qualifications for the following persons:
- a. Those persons who attended meetings with the NRC Staff "to discuss items of information provided, to seek new information from the Licensee that might be needed for an adequate assessment," [EIS NUREG-0683 Supplement No. 2, Final Report, Juns 1987, p. ix). ;
- b. Those persons who evaluated the bids from the vendors for the evaporator, !
and who chose the vendor to deliver the evaporator. l
- c. All those persons involved in evaluating the disposal option. i l
1 8802290175 880219 PDR ADOCK 05000320 o PDR
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o - ANSWER NO. Gla. EDUCATIONAL PROFESSIONAL . NAME ADDRESS ' EMPLOYER QUALIFICATIONS QUALIFICATIONS J. J. Byrne P.O. Box 480 GPU Nuclear B.S. Civil Engineering, 14 years nuclear experience, Middletown, PA University of Pittsburgh 8 years of which are power plant 17057 related; registered Professional Engineer, State of Illinois M. J. Cooper P.O. Box 480 GPU Nuclear B.S. Chemistry, 10 years experience in Health Middletown, PA University of Maryland Physics; Certified Health 17057 Physicist J. A. Renshaw P.O. Box 480 GPU Nuclear Plymouth High Noc1; 20 years of service (US Navy), Middletown, PA various Nava .echnical 12 of which were in naval nuclear 17057 Schools and Officer power plant related experience; Candidate School 15 years nuclear industry experience R. E. Rogan P.O. Box 480 GPU Nuclear B.S. Math and Chemistry, 23 years of service (US Army); Middletown, PA Jacksonville State University; 4 years as THI-I Emergency Planning 17057 M.S. Nuclear Physics, Director; 3 years as THI-2, Tulane University Director, Licensing and Nuclear Safety F. R. Standerfer P.O. Box 480 GPU Nuclear B.S. Chemical Engineering, 32 years of nuclear experience, Middletown, PA University of Washington 19 of which are power plant 17057 related C. S. Urland Shady Grove Rd. Grove 8.S. Water Resources 4 years nuclear industry experience Rockville, MD Engineering Engineering Technology, 20850 Pennsylvania State Unversity R. P. Harren P.O. Box 480 GPU Nuclear B.S. Mechanical Engineering, 15 years nuclear experience, Middletown, PA Virginia Polytechnic 10 of which are power plant 17057 Institute related; registered Professional Engineer, State of Virginia ANSWER NO. Gib. EDUCATIONAL PROFESSIONAL,
! NAME ADDRESS -
EMPLOYER QUALIFICATIONS QUALIFICATIONS D. R. Buchanan P.O. Box 480 GPU Nuclear B.S. Machanical Engineering, 24 years nuclear industry Middletown, PA Lehigh University experience; registered Professional 17057 Engineer, State of Pennsylvanta T. Driscoll Shady Grove Rd. Bechtel North 8.S. Mechanical Engineering, 14 years nuclear industry Gaithersburg, MD American Power Cooper Union for the experience 20877 Corporation Advancement of Science and Art
- i. H. Lilien P.O. Box 480 GPU Nuclear B.S. and J.D., 5 years experience as a practicing Middletown, FA University of Maryland attorney, 2 years of which were '
17057 Deputy Attorney General of the Pennsylvania Department of Justice; 2 year: as TMI-Site Contracts Administrator; 6 years as TMI-Site Contracts Manager T. A. Schnoor P.O. Box 480 GPU Nuclear 2 years college credit 12 years of procurement experience; Middletown, Pl. towards business degree, 8 years as THI-Site Contracts 17057 Cuyahoga Community College & Administrator M111ersville University i
m 46-A.. m ___o - . 33.. ca ,.h e - A _.a 4 4 _~_ __ __ 4 - . ANSWER NO. G1c. , i 4 EDUCATIONAL PROFESSIONAL. NAME ADDRESS EMPLOYER QUALIFICATIONS QUALIFICATIONS N. J. Cooper P.O. Box 480 8.S. Chemistry,
~
GPU Nuclear 10 years experience in Health 5 Middletown, PA University of Maryland Physics; Certified Health
- 17057 Physicist l C. P. Deltete P.O. Box 6617 Analytical 8.S. Applied Mathematics, 17 years experience in the nuclear.
Hyomissing, PA Resources, U.S. Naval Academy; industry 19610 Inc. M.S. Nuclear Engineering, Renscelaer Polytechnic 4 Institute T. A. Grace P.O. Scx 480 GPU Nuclear 8.S. Environmental Biology, 7 years experience in environmental i Middletown, PA California State University licensing of nuclear power stations 1 17057 at San Diego; 1 M.E. Environmental Pollution Control, Pennsyivania State University K. J. Hofstetter 8.A. Chemistry, Savannah River E. I. Dupont 13 years of experience in Radio-Laboratory, Augustana College; chemistry
- Aiken, SC Ph.D. Chemistry, 29808 Purdue University C. A. Negin Shady Grove Rd. Grove 6.5. Mechanical Engineering, Over 20 years experience in the Rockville, MD Engineering Massachusetts Institute of nuclear industry; registered 20850 Technology; Professional Engineer State of M.S. Mechanical Engineering, Maryland Massachusetts Institute of Technology
, J. A. Renshaw P.O. Box 480 GPU Nuclear Plymouth High School: 20 years of service (US Navy), Middletown, PA various Naval Technical 12 of which were in naval nuclear 17057 Schools and Officer power plant related experience; Ca;:didate School 15 years nuclear industry experience j ' L_----_------_--_----_-----_-_____---_______... - . _ . _ _ _ . -
ANSWER NO. G1c. (Cont'd) EDUCATIONAL PROFESSIONAL, NAME ADDRESS EMPLOYER QUALIFICATIONS QUALIFICATIONS R. E. Rogan P.O. Box 480 GPU Nuclear B.S. Math and Chemistry, 23 years of service (US Army); Middletown, PA Jacksonville State University; 4 years as TMI-I Emergency Planning 17057 H.S. Nuclear Physics, Director; 3 years as TMI-2 Tulane University Director Licensing and Nuclear Safety. R. J. Sheppard P.O. Box 1212 Bechtel North B.S. Mathematics, 13 years nuclear industry Athens, AL American Power Michigan Technological experience 35611 Larporation Unversity; M.S. Nuclear Science, University of Michigan C. S. Urland Shady Grove Rd. Grove B.S. Water Resources 4 years nuclear industry experience Rockville, MD Engineering Engineering Technology, 20850 Pennsylvania State l':.versity following the technical evaluation, the disposal option recommendation was reviewed by GPU Nuclear management.
INTERROGATORY NO. G2 - Identify all communications between the Licensee and the NRC Staff concerning the evaluation and search for new information made by the NRC prior to the publication of the EIS, Supplement No. 2. June 1987. ANSWER NO. G2 - The following is a list of communications from the Licensee to the NRC concerning the evaluation and search for new soformation made by the NRC prior to the publication of the PEIS, Supplement No. 2. June 1987. LETTER TITLE LETTER NO. ___DATE Disposal of Processed Water 4410-86-L-0114 07-31-86 Disposal of Processed Water 4410-86-L-0178 10-21-86 Disposal of Processed Hater 4410-87-L-0018 02-03-87 Disposal of Processed Water 4410-87-L-0023 02-18-87 Disposal of Processed Water 4410-87-L-0082 05-la-87 Comment on PEIS Supplement No. 2 4410-87-L-0032 03-17-87 Comment on PEIS' Supplement No. 2 4410-87-L-0050 03-25-87 Comment on PEIS Supplement No. 2 4410-87-L-0058 04-14-87 rotected Species of PA 4410-87-L-0088 06-03-87 TSCR 56 4410-87-L-0029 02-25-87 TSCR 56 - Revised 4410-87-L-0057 04-13-87 INTERROGATORY NO. G3 - Identify all Technical Specifications relevant to the disposal of the water. ANSWER NO. G3 - The Technical Specifications will be produced for inspection. INTERROGATORY NO. 51 - If "the public perception that water is uniquely hazardous..." was a primary consideration in the selection process of the disposal of the water, state the basis upon which GPUN decided that evaporation of the water was more popular or acceptable than any other method of disposal? i l 1
. i
)
l ANSWER NO. S1 - The premise of the interrogatory is erroneous. Further, GPU Nuclear did not decide that evaporation of the water was more popular or acceptable than any other method of disposal. Rather, GPU Nuclear proposed the evaporation disposal method because it is technically feasible and environmentally safe. The river disposal method was not proposed by GPU Nuclear, however, because of apparent public, institutional and political concerns. As stated in GPU Nuclear's July 1986 report on Disposal of THI-2 Water (cited in subsequent answers as the "July 1986 Report"):
"On the bar's of overall technical merit, analysis indicates that the controlled ischarge of the processed, diluted water to the Susquehanna River is the simplest, least costly option and involves insignificant environmental impact, as do the competing options. However, GPU Nuclear has opted not to recommend discharge to the river in recognition of an existing public perception that unique hualth risks are Associated with this disposal option."
INTERROGATO'4Y NO. 'i2 - Describe the melrod by which GPUN determined the public's opinios :oncerning the disposal of Accident Generated Water (AGW) prior to choosing the evaporation method. ANSWER NO. S2 - As indicated in the response to Interrogatory hv. 51, public perception was important in GPU Nuclear's decision not to recommend Hur disposal, but was not the basis for selecting evaporation frce among the remaining alternatives. INTERROGATORY NO. S3 - Provide the architectural and engineering plans for the evaporator chosen to dispose the AGH. ANSWER NO. 53 - By letter of February 17, 1988, Licensee provided intervenors a copy of the Accident Generated Water Disposal Preliminary System Description
4 (cited in subsequent answers as ths "System Description"). As stated in the GPU Nuclear letter 4410-88-L-0012, February 16, 1988, forwarding the System Description to the NRC, the System Description is a compilation of the most accurate design information currently available, and may change as the final system design evolves. While the System Description is based in part upon p'reliminary design information submitted by the vendor for GPU Nuclear review / comment, there presently are no architectural and engineering plans for
- the disposal system.
INTERROGATORY NO. 54 - Identify the vendor chosen to supply the evaporator,
- a. Describe the prior experience of the vendor with evaporators.
- b. Identify the tub-contractors who will be involved in either construction of the evaporator, modifications, establishment onsite, or maintenancs.
ANSWER NO. S4 - Pacific Nuclear Systems, Inc. 15 the main contractor and will be responsible for supplying the disposal systen. The supplier of the evaporator is sub-contractor Licon, Inc. Licon. Inc. has designed and installed evaporator units since 1975. This particular evaporator, a vapor compression unit, is similar to units that tava been installed and are operating at several other locations. The sub-contractors are Bally Engineered Structures, Duren Controls, Grove
- Engineering, Teledyne Readco, and Licon, Inc.
l 1 INTERROGATORY NO. S5 - Are there any cross stockholders between GPU Nuclear and any of the named above in NO. 3 and NO. 4? Identify them. ANSWER NO. SS - No.
l INTERROGATORY NO. S6 - Describe specific criteria used for choosing the evaporator. ANSWER NO. 56 - The following criteria were used for selecting the evaporator l contractor: (1)
, system description of offered equipment / process (evaporation, volume reduction and system description),
(2) experience in the fleid, (3) schedule completion / capacity, (4) completeness of data submitted per specification, (5) exceptions taken to the specification, (6) required plant support (GPU Nuclear services and utilities), (7) QA Plan, and (8) cost competitiveness. INTERROGATORY NO. S7 - Describe changes, additions, and/or removals needed to be made to the evaporator so that it can operate in an open cycle. What is the cost of these modifications? Describe the purpose of each component which is added, modified, or removed. State the basis for all modifications. ANSWER NO. S7 - No such changes, additions, and/or removals need to be made to the basic evaporation unit. The total disposal system may operate in an open cycle configuration because of the elactrical powered vaporizer assembly connected at the effluent from the evaporator unit. The vaportzer is described in the System Description, 2.3.3 and Attachment 1. There is no separate cost estimate for this component. I i 9
INTERROGATORY NO. 58 - Descr'sbe the previous experience which the Licensee and vendor have in making the modifications to the evaporator so that it will operate in an open cycle. ANSWER NO. $8 - Not applicable. See response to Interrogatory No. 57. , INTERROGATORY NO. 59 - Describe the tests to be undertaken prior to use to demoastrate the efficiency of the evaporator in an open cycle mode. ANSWER NO. 59 - The acceptance tests to be undertaken prior to the disposal systems being utilized are described in Attachnent A, an excerpt from the GPU l Nuclear Technical Specification for Processed Water Disposal. t INTERROGATORY NO. 510 - If the chosen vendor would become insolvent, how would this affect:
- a. evaporator services
- b. solidification services !
ANSWER NO. S10 - If the chosen vendor becomes insolvent, GPU Nuclear will cot. tract with another expertenced/ qualified contractor to perform the services. ' t INTERROGATORY NO. $11 - GPU Proposal p. 28. - List those considerations for using the evaporator for the production of low concentrated borated water. l How will these considerations affect:
- a. modifications to be made to the evaporator
- b. the efficiency of the evaporator to operate e.nd remove contaminants in the water. :
What were the preliminary investigations undertaken to find how flexible the i systems werc? '
?
i r a v..
At45WER NO. 511 - One of the considerations in the initial scoping ant. lysis of July 1986 was to review what additional capabilities might be provided by the evaporator system. In this review, it was noted that an evaporator system could also provide an additional capability to deborate the Accident Generated Water for use in decontamination activities at THI-2. As noted in the response to Interrogatory No. S7, the closed cycle portion of the evaporator is not being modified for open cycle use, and thus, the efficiency of the evaporator to operate and remove contaminants in the water is-not affected. The preliminary investigations undertaken to find the degree of flexibility of various evaporator systems involved discussions with evaporator vendors and a summary review of various evaporator systems. INTERROGATORY NO. 512 - Explain the design and construction of the concrete pad. ANSWER NO. 512 - Design and construction of the concrete pad have not been initiated. GPU Nuclear has received preliminary equipment layout drrwings for the pad which, following the review and approval process, will be used in developing the pad design. , l
\
, I INTERROGATORY NO. 513 - Describe how the evaporator will be tied in with: I
- a. the holding tanks for the AGW j
- b. the EPICOR/SDS system Describe dimensions and plac; ment of pipes, shut off valves, safety systems, I and additional tanks.
1 ANSWER NO. 513 - The tie-in with the AGH holding tank will be at the existing pipe run located in the Unit 1/ Unit 2 corridor. Piping will be designed, installed, and tisted in accordance with ANSI /ASME Power Piping Code No. 831.1. The disposal system will not be tied in with the EPICOR/SDS System. The final details for the plant tie-in with the disposal system have not been completed. The dimensions, placement of pipes, shut-off valves and safety , systems (if required) will be addressed by issuance of an 3pproved Engineering Change Authorization. There are currently no plans for additional tanks. INTERROGATORY NO. S14 - What will be the criteria of selection for operations staff. Describe the required professional background for staff involved in:
- a. installation of the evaporator
- b. maintenance of the evaporator
- c. operation of the evaporator
- d. monitoring of the influent and effluent of the evaporator ANSWER NO. S14.
Present plans are as follews: a) Installation will be supervised by a Par.ific Nuclear Systems engineer. ! The Licon system will be installed undt;r the direction of Licon I personnel with previous installation experience. b) Pacific Nuclear disposal system maintenance personnel will have formal training and/or a minimum of five years experience in the maintenance of process equipment. , 1 4 <
. c) Disposal system operators will have a minimum of five years experience in the operation of nuclear related process equipment.
d) The selection criteria and the required professional background for the onsite staff involved in monitoring the influent and effluent of the evaporator / vaporizer are found in ANSI 18.1-1971, "American National Standard for Selection and Training of Nuclear Power Plant Personnel." The onsite monitoring staff will consist of qualified GPU Nuclear supervisors, Metropolitan Edison chemistry technicians, and contracted chemistry technicians. 1 1 INTERROGATORY NO. 515 - How many staff will be involved with: '
- a. installation
- b. maintenance
- c. operation
- d. monitoring ANSWER NO. 515.
dresent plans are as follows: a) Installation: 12-14 i i i b) Halntenance: 1 ' , i c) Operation: 3 .i I J i
,.c.,-,_
d) The monitoring will be done by-plant staff who work rotating shifts providing continuous coverage for samp1tng and analyses. The number of personnel or manhours necessary to support evaporator monitoring has not been determined at this time. It will depend on the requirements as set forth in the approved process control plan. I INTERROGATORY NO. S16 - How often will a sample be drawn from the evaporator?
- a. From where wt11 the sample be drawn?
- b. What will be the quantity of the sample drawn?
- c. What will be the professional background of the person drawing the ;
sample?
- d. How will the sample be prepared for analysis?
- e. Where will the sample be analyzed? '
- f. How long will it take to receive the results of the sample analysis?
- g. Will the agency or person responsible for analysis have the equipment capability to detect the full range of radioactive and non-radioactive substances expected to be present in water?
- h. List the radioactive substances and non-radioactive substances which the agency will be capable of measuring.
ANSWER NO. $16 - See System Description, Section 2.3.8, and response to i Interrogatory No. $14d. Detailed information such as frequency, quantitles, preparation, laboratory, equipment, and parameters for sampling and analysis , are not available at this time. This information will be prepared and included in the process control plan which will be developed before operating the evaporator / vaporizer.
)
l J
INTERROGATORY NO. 517 - What wlll be the feed rate to the chosen evaporator? Under what circumstances would this feet rate be: ,
- a. Increased '
- b. decreased
- c. stopped ANSWER NO S17 - The rate of evaporation will be five gallons per minute. The rate can be decreased should undefined circumstances require it. By design, ,
the rate cannot be increased. Circumstances in which vaporizer operation would be terminated are addressed in the System Description, Section 2.3.8. In addition, feed could be halted for scheduled maintenance, emergency shutdown, or declaration of a station event with an emergency classification of alert or higher. INTERROGATORY NO. S18a - How will the heat source be provided and maintained i to the contents of the evaporator?
- b. To what temperature will the water be heated?
- c. What is the optimum temperature for efficient operation of the evaporator? State the basis for this determination,
- d. What is the temperature which would cause the vaportzation of those radionuclides listed on "Estimated Average Concentration of Radionuclides Potentially Present in the THI-2 Water for Evaporation"?
(F. R. Standerfer 02-26 presented to the Citizen's Advisory Panel.) ' ANSWER NO. S18 - The heat source provided and maintained to the contents of the evaporator is described in the System Description, Sections 2.3.2 through 2.3.5. These optimum temperatures and pressures are based on the boiling point of water. With respect to the radionuclides present, tritium's most common form under tnese conditions will be as part of the water molecules (i.e., HTO). Thus, it will vaporize and be liberated with the water vapor. I With a vaportzer operating temperature of 240'F (ll5'C), vaporization of the other radionuclides listed in this reference will not occur. Of the other ! i
radionuclides present in the water, C-14 and 1-129 can have physical forms which could possibly vaporize; however, under the chemistry conditions of this : water, the carbon and todine will be in chemical forms that are not volatile : at these operating conditions. The vaporization thresholds (bolling point) '
. for the remainder of the radionuclides are in the range of 500-5000'C. The ;
very low concentrations of radionuclides which may be present in the water ! vapor (steam) released from the vaportzer are listed in Tables 3-1 and 3-2 of , the System Description, f INTERROGATORY NO. S19 - What is the form - gas, solid, particulate - of each of the contents of the AGH?
- a. What is the total particulate content?
ANSWER NO. S19 - T&ble 2-9 on Page 20 of the July 1985 Report sumarized the chemical concentrations for each of the sources of ACW. This table shows that, in addition to the radionuclides reported on Table 2-3, the AGW has near neutral pH with varying levels of conductivity (a measure of the tonic strength of the solids present in the water), sodium, boron, and low levels of miscellaneous contaminants (e.g., phosphates, sulfates, and chlorides). The "form" of these constituents is predominantly "solid (with the only exception teing tritium, which is physically bound to the matrix of the water molecule and will be liberated as a gas along with the water vapor upon bolling in the evaporator). These sollds exist in the AGW as either dissolved or suspended solids. The radionuclides also exist as either dissolved or suspended solids depending on ths particular species and how it interacted with the solids in the water, l
Upon evaporation of the AGH, the total solids present (both dissolved and suspended) will remain as the evaporator bottoms. Table 2-9 shows that the boran and sodium that is dissolved in the AGW 15 the major portion of the solids, equivalent to approximately 160 tons of solids in a dry form. INTERROGATORY NO. 520 - Tables 2 - 3 through 2 - 8 in GPU Proposal are not complete for all radioisotopes in the water. Identify the values for all radioisotopes expected to be present in the water. Ehere the radioisotopes are expected but not detected, list the lower level of cetectability. ANSWER NO. S20 - Table 3-2 on Page 18 of the System Deteription identif'es the concentrations of radioisotopes in the evaporator influent. Radioisotopes which may be present at levels below their Lower Level of Detectability (LLD) are listed with their LLD value. This information is also presented in Table 2.2 on Page 2.3 of the PEIS, Supplement No. 2. See also GPU Nuclear letter 4410-87-L-0023, dated February 18, 1987, which is printed in PEIS Supplement No. 2 at Page A.43. INTCRROGATORY No. 521 - If more recent sample analyses than the above are available, provide these to the Intervenor. ANSWER NO. 521 - The storage tanks listed in Tables 2-3 through 2-8 of the July 1986 Report have been sampled since that time. These tanks are a part of a dynamic radwaste handling system and as such have undergone many water transfers. As water is used for decontamination, radionuclides are , 1 transferred to the water from various surfaces. This increased concentration l of radionuclides is then processed through filters and ion exchangers until I the water is again at very low concentrations. Some storage tanks are sampled delly (e.g., RCS), some weekly (e.g., BNST), and others as needed. The sampling data is quite extensive. For example, there are approximately 25,000 samples for 1987, the documentation for which covers over 50,000 pages. These documents will be made avsilable for inspection. INTERROGATORY No. S22 - For the samples analyzed, state the following:
- a. meth00 of procurement of sample
- b. Quality c' sample drawn
- r. Upon what basis is it assumed that these samples are representative of the total contents of each location (for both radioactive and ron-radioactive substances)?
d, Fow was the saniple prepared for analysis?
- e. Who analyzed the sinpit?
ANSWER RQ ,)i2 a) Samoles of the referenced storage locations are obtained by following steps detailed in GPU Nuclear's procedures (work instructions). Each location has step-oy-step instructions for valve line-up and shutdown to assure that a representative sample is obtained in a safe manner. There is also a chemistry procedure which outlines the steps a technician follows to obtain a pure and accurate sample. These procedures will be ' made available for inspection, b&c) Before a sample is withdrawn from a storage location, the water is mixed or recirculated. The sample lines leading from the representatively mixed water then receive a minimum three line volume flush to ensure that "fresh" water is obtained. The sample is then placed in a new l container which is discarded after completion of the sample analysis. i
. ,, . . . . .. ~ .
d) Sample preparation for analysis is detailed in each different analysis procedure. Preparations such as volume, reagents and quantitles, geometry, chemical separations, filtration and temperature adjuttment are presented to the technicians in step-by-step procedures. These procedures (work instructions) will be made available for inspection. I e) The onsite sample analyses were performed by the GPU Nuclear, THI-2 Chemistry Department. Some offsite analyses were performed by Science Applications, Inc. and Westinghouse. , f [N((3ROGATORY NO. 523 - State which of these sample (s) originated in the raattor core at a time when boron concentration was at its highest. ANSNER NO. 513 - The boron concentration is currently at its highest figure, approximately 5600 ppm. Therefore, the most recent sbaples would be representative of tht: water durlog its highest concentration of boron to date. i j INTERROGATORY fiO. S24 - What is the total particulate content of the AGW in , each location at the end of clean-up and after processing through EPICOR/505? ANSWER NO. S24 - The total particu' ente content of the AGW processed to date ' has beer, less than 2 mg/l suspended solid 2. The treatment process of filtration. EPICOR/SDS, and evaporation wlil have effectively removed the l suspended matter from the AGW. Siart water is moved from tank to tank for various cleanup uses, the final concentrations cannot be determined at this time. However, the water being vaporirid will be essentially free of particulates.
1 , INTERROGATORY NO. 525 - What is the total ge: ecus content of the AGW in each location at the end of clean-up and af ter processing through EPICOR/SDS? ANSWER NO. S.2S - Since the AGW at various locations at the end of cleanup will have received much recirculation, aeration, ralxing and pressure / temperature fluctuation, it will be deaerated and coctain only the normal concentrations cf gases present in treated industrial waste water, The total gaseous content of AGW is dependent on the water temperature and tank pressure conditions : r under which it is stored. Further, the quantity of the gas contained in the water also will be dependent on the solubility of the particular gas relative to storage conditions. INTERROGATORY NO. 526 - What 17 the total solids content of the AGW in each location at the end of clean-up and after processing through the EPICOR II/SDS? : ANSWER NO. 526 - The total solics content of AGH present is composed of suspended solids (particulate) and dissolved solids (noletules or tons dispersed throughout the solution). The AGW in the various storage locations at the end of cleanup will have been processed thresgh filters and ion exchangers at some stage prior to final feeding to tr.1 vvatorator/ vaporizer. ! These treatments will renme particulates and some distotved solids. A large part of the beric acid nd sodium hydroxide added to the AGW for reactivity and corrosion control stili will remain dissolved in the v.ater at the end of cleanup. This quantity of dissolved solids will be l'ar in excess of the suspended solics (mca than 1000 times greater). Table 3-2 of the System ; Description provides a value of 150 Ons of boric acid and 11 tons of sodium I hydroxide contained in 2,300,000 gallons of AGW. The portion of this total l l l
F which is in any given location will change many times as water is moved in support of recovery. However, the total solid content for the AGW in aach l location should not deviate significantly from the above nucers. {,
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T-h INTF POGATOPY NO. 527 - Did GPU receive information DOut the core inventory
~
E cf tH tica G lowing the accident at any time since tne original esttrate w: S I-M ie in the original EIS? If yes,
- t. State the information received a
- b. State the source of the information
{ ANStiEf,J). 527, Yes. Since the original estimate in :ne ,* arch 1981 Fi!E [ (NUREG-05B3), there has been an additic' :1 estimate published at an inforcal E report from the idthe National Engineering Laboratory, entitiea "TMI-2 h 150700I0 INVENTORY CALCULATIONS", EGG-PBS-6798. The ostimate gisen is h' a.231E+03 Curtes t + shutdown (p. 40. Table A-6), or 3. ;9FE+03 Curies in $' arch
}
MD (p. 52, Table A-IS). The estimate is the result of .e comput:r E caic.uiatien of isotope production (ORIGEN) baseo on plint c;srAttonal history. [ H uev<r, much of this tritium is retained in the keactor V6ssel either acscciated with *.5*0 futl or bound to structural surfaces, Then;fors. the E inventory of tritNm repcrted in the l4 arch 1981 PEIS, whi;h was baseti on actual samale .tnelys95 of thi accident generated water, remai.1s the rnc3t - accurate ettinte of the tritium present in the accident generated water at that tire, f i INTERROGATORY NO. 528 - If the inftuent is found to exceed the certptable leveT for release, explain the procedure for dealing with this, and in particular, state how the eter will be made acceptable for the evaporator. - State the basis for the a numption that 1% of the particulates in the influe.% - to an evaporator is released when tha evaporator optrates 1.3 a." creh cycle. _
.r1
{ d
. e ANSWER NO. $28 - As explained in the System Description, it is the effluent from the evaporator unit which will be vaporized and released. The interrogatory erroneously presumes that the influent will be released. System Description Sections 3.1 and 3.2 describe the procedure for dealing with any evaporator effluent unacceptable for release. The average carryover fraction for this disposal system is expected to be 0.1%, and not 1% as stated in the interrogatory. This assumed fraction (0.1%) is based on routine performance experience with typical evaporator systems, and is also utilized by the NRC Staff in PEIS, Supplement No. 2 for r(lease calculations. The process control requirements for operation of this specific disposal system (System Description Sections 3.1 and 3.2) will assure that this release fraction, at a minimum, is achieved. Additionally, acceptance testing performed prior to placing the system in service will demonstrate that this release fraction will be accomplished as directed by the contract specifications. See the responte
- to Interrogatory No. 59.
1 INTERROGATORY NO. S29 - Would the presence of non-radioactive substances affect the ability of radionuclides to vaporize? Provide the basis for your response. ANSWER NO. 529 - The presence of non-radioactive Oubstances occurring in AGW will not affect the ability of radionuclides to vaporize. The operating 4 temperatures of the system are well below the temperatures necessary to actually vaportze radionuclides, except as discussed in response to Interrogatory No. S18. Radionuclides of very low concentrations may be i present as dissolved or suspended solids in water vapor (steam) released from the vaporizer. These concentrations are listed in Tables 3-1 and 3-2 of the i System Description. INTERROGATORY NO. 530 - Describe monitoring features and their function on the ' evaporator.
- a. Which of these featu,es have been added to the evaporator to enable it to operate in an open cycle?
- b. Which radioisotopes and in which form will these monitor (s) be able to detect?
- c. Describe any tests undertaken to prove the effletency of these acnttors when used in an evaporator operating in an open cycle?
ANSWER NO. S30 - The monitoring features and functions are described in the System Description, Section 2.3.8. The physical sampling requirements to validate these monitors are described in Section 3.2. See also the answers S16 and $33. These monitors will be calibrated to a nationally approved standard prior to, and periodically during, their use. INTERROGATORY NO. S31 - Describe the carry-over monitor and its method of operation,
- a. Is the carry-over monitor a detector or a collector of radioisotopes?
- b. Has this carry-over monitor been used before on an evaporator operating in an open cycle? If yes, state where and state any tests and results undertaken to prove the efficiency of the carry-over monitor on an opor cycle evaporator. ;
l , ANSWER NO. 531 - Based upon the current disposal system configuration, GPU Nuclear no longer plans to utilize a carryover monitor of the type discussed 1 at the February 1987 Advisory Panel meeting. Conductivity monitor prober, will I be located at the flow paths for the influent to and effluent from the evaporator, and at the flow path for the influent to the vaportzer. See
- System Description. Attachment 1. These types of instruments are used routinely on modern evaporators, whether vpen or closed cycle. The universal i 1
use of conductivity monitors on evaporator units demonstrates their proven i efficiency. In addition, these monitors will be supplemented by physical sampling. System Description, Sections 2.3.8 and 3.2. l 1
. INTERROGATORY NO. S32
- 1. By what mechanism will a sample stream of vapor be pulled?
- 11. How often will the sample be pulled?
111. What quantity of vapor will be pulled for a sample? tv. State.in what manner GPUN will use this sample as a scaling or guide for the operation of the evaporator?-(Hr. Urland, p. 26. Citizen's Advisory Panel Meeting for the 06 contamination of Unit 2, 2/87)
- v. Explain "condetse it with continuous conductivity probe" - reference as for 32 Iv above, and v1. Describe the method for determining the contents of the sample and list
, the radioisotopes search for. ANSWER NO. 532 - There will not be a sample stream of vapor taken at the exhaust stack. A more accurate sample point for the release will be located at the influent to the vaporizer while the water is still in its liquid state. See System Description, Section 2.3.8 and Attachment 1. l b INTERROGATORY NO. 533 - Describe the type of in-line monitor to be placed. ,
- a. Hnere will the inonitor be placed? '
- b. What are the lowest levels of detectability of the monitor for all radioisotopes expected in the water?
- l ANSWER NO. 533 - The typical in-line monitor being considered consists of three components
- (1) a liquid sampler, (2) a detector assembly in the 1'
sampler, and (3) a microprocessor based ratemeter/ controller. The liquid , i sampler consists of a smooth finish, stainless steel, bowl-shaped well with a l top inlet orifice and bottom outlet orifice. The 11guld capacity of the sampler volume is 5800 cc (1.53 gallons). See Attachment B. The detector assembly is a 2" x 2" canned, thallium-activated, sodium iodide crystal that ,
- is optically coupled to a photomultipiter tube. The detector assembly is ,
mounted in a stainless steel well which is located in the center of the sample ; l chamber. The exterior of the sample chamber is completely surrounded in all f directions by lead shielding. l l i
The electronic signal from the detector assembly is connected to a microprocessor based ratemeter/ controller. The ratemeter has a dynamic range of 10 to 20 million counts-per-riinute. The ratemeter display is updated every , The ratemeter/ controller is also equipped with a failure alarm, two seconds. a trend indicator, a warning (or alert alarm), and a high alarm. Another featureoftheratemeter/controllerisanenergyspectrometerwitha , 4 sensitivtty of 100 millivelts over the energy range of 100 Kev to 2.1 Mev. This energy range encompasses the energy range of all gamma emitters expected in the evaporator effluent. l The in-line monitor will be located on the influent to the vaporizer. See Attachment 1 System Description. I Based on Table .i-2 of the System Description, the first nine (9) isotopes may be present in greater than detectable concentrations. Tritium and the beta ; emitting isotopes will be determined by radioanalytical methods. Monitoring ! I
- releases of these isotopes will be based on these analytical results and inlet 1
flowrates to the vaporizer. ' The following is a list of the lower limit of detection (LLD) in i microcuries/ml for the liquid monitor: i Radionuclide Monitor Gamma LLD. uC1/ml ! Cestum-137 2.7E-8 ! Ces t u:n-134 -1.0E-8 Antimony 125/ Tellurium 125m 3.0E-8 Cobalt-60 1.2E-8 l I I I i< 1
J In the list of evaporator effluents of all the gamma emitting isotopes (Table 3-2 System Oescription), Cs-137 is expected to be present in the most significant concentration or at 3.7E-8 pCl/ml. Since Cs-137 is the principal gamma emitting isotope, it will be used for calibrations and alarm setpoint determination for the evaporator monitor system.
; INTERROGATORY NO. 534 - How will the beta emitting radioisotopes be monitored? Explain monitor type to be used and the lower level of detectability of the monitor for each beta emitter and frequency of analyses.
ANSWER NO. $34 - Section 2.3.8, "Instrumentation " of the System Description discusses the scaling factor which compares Cesium-137 concentrations to total particulate releases. This section also states that process control will be maintained by sampling and conductivity monitors. The frequency of samp1tng i and the specific details of the chemical and radiochemical analyses will be included in a process control plan. l INTERROGATORY NO. $35 - How will the alpha emitting radicisotopes be monitored? Explain type of monitor to be used and its lower level of l detectability for each alpha emitter. State frequency of analysis to determine ; presence of these radioisotopes. l ANSWER NO. 535 - See response to Interrogatory No. 534. -
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. INTERROGATORY NO. 536
- a. How will the gaseous effluents be measured?
- b. How often?
- c. Where will the analysis be undertaken?
ANSWER NO. _S36 - Gaseous effluents w'.ll not he separately measured. See responses to Interrogatories Nos. 332 and $33. INTERROGATORY NO. 537 - What height is the stack through which the contaminated vapor will be emitted into the air?
- a. Explain the means by which heat will be applied and maintatr.ed to ;he stack.
- b. In the event that the heating System in the stack would fail, what )
safety measure will be in place?
- c. State those parts which will require maintenance on ine evaporator anri how often each part will require maintenance.
- d. State the reasons why the parts will require maintenanse,
- e. j State the basis for the claim that the evaporator in u opn cycle eli gg operate 75% of the time. seus W>st is the life expectancy of the evaporator?
f. ANSW Q_NO. S 7 - Stack height will be a minimum of 100 feet.
-{
The exh?v t M stack will not be heated. The identification of c Aponents for malttonance J a and the schedule for maintenance are responsibilities of the vender inkr thh service contract (leased, vendor-operated equip.t.ent/ Service). The contract h specifications call for the system to operate '15% of the clme derir.; tne lease p I, period. s .7i q This was set as a reasonable operat.ag star.dsrd for tMi ewice.ent and as a basis for planning the duration of the riscasal tosk. Tnt 25% of
I down time allows for preventive and unplanned minhnanca. AGW t.utiability, f ;[ a' and THI-2 recovery schedule consideratior,s. The life expectar:ty of toe evaperator is well beyond the period of oce?ormance for which 4 t is tet :q l leased.
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. 1 IklERROGATORY NO. 519 - Citizen's Advisory Panel for the Decontamination of Unit 2, 2/87, p. 32, Mr. Standerfer.
- a. Explain "foaming" anc how it affects the operation of the evaporator.
- b. Explain the causes of "foaming".
- c. What steps will GPUN take to prevent it.
r d. Upon which basis do you determine that these are the correct steps to take to Avoid foaming?
- e. Explain how foaming affects the amount of solids rising with the vapor?
ANSHER NO. 539 - The term "foaming" as used by Mr. Standerfer in the referenced presentation is a description of an upset condition that can occur during evaporator operations. Foaming is simply the production of bubbly suds ; caused by the presence of decontamination "detergents" or organic chemicals containing chelating agents. The water in the evaporator is slightly agitated l to stimulate and enhance the boiling process. This agitation, coupled with the turbulence produced in pumping the water into the evaporator, provides the mechanism for the production of foam. 4 The evaporator is designed to operate under a vacuum so that the water in the ; evaporator reaches its boiling point at a lower temperature. The presence of excess foam in the evaporator adversely affects its operation. The foam ! reduces the heat transfer from the evaporator heaters to the water, and thus decreases the efficiency of the process and results in incomplete evaporation. Vapor produced by incomplete evaporation has a high moisture 4 content, and each water droplet in the vapor contains dissolved solids that ! I would otherwise have been removed by complete evaporation. Rising foam l l bubbles can also lead to a loss of vacuum which will cause the evaporator to I ) shut down until the condition is cleared. 9 i 1
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Foaming is generally prevented by the addition of commercially available anti-foaming agent to the water prior to evaporation. This method of pre-treatment for foaming control is standard-practice with evaporators as used throughout the industry. The evaporator to be used for Accident Generated Water Disposal will be operated to prevent excess foaming caused by the presence of decontamination chemicals. However, as noted in Section 2.3.2 of the System Gescription, the evaporator supplied by the vendor relles on "foaming" for the continuous wetting of the heat exchanger tubes. This foaming action is the result of the production of minute vapor bubbles and is not the same as foaming caused by the presence of decontamination chemicals.
'l INTERROGATORY NO. 540 - !s there an automatic shutdown on the evaporator? If yes, answer the following:
- a. Under what circumstances would the automatic shutdown go into effect?
- b. Will the number of times the evaporator is shutdown have an effect on the integrity of the system? State the basis for your answer.
- c. How much time iapses between shutdown of the evaporator and the stopping of releases through the stack?
ANSWER NO. 540 - Yes. The automatic shutdown features for the disposal system, and the circumstances under which they would be activated, are described in Section 2.3.5 of the System Description. As explained there, the automatic shutdown features are located on the vaporizer section, which will ll control the point of atmospheric release for the disposal system. The number of times the automatic shutdown condition occurs will not have an adverse 1 effect on the system, which essentially operates as a large electric heater. l l m
The elapsed time between the alarm condition and the termination of releases through the stack Will be no more than three minutes, even if all three vaportzer heaters are in operation at the time of the alarm. During this period of operation, the electric heaters are cooled to below 212'F by the recirculation of approximately 125 gallons of "acceptable for re. lease" water through the heater assembly. This water is part of the reserved inventory in the lower part of the flash tanks (a section of the vaporizer assembly) and has previously been monitored by the radiation detector and determined to be acceptable. INTERROGATORY NO. 541 - Are there any conditions, at either Unit 1 or Unit 2 under which the evaporator would be shutdown other than evaporator maintenance or preparing feed batch? If yes, explain those conditions? ANSWER NO. S41 - There are two conditions which would require shutdown of the evaporator end/or vaporizer. They are as follows: (1) Upon receipt of an .iarm from tne vaporizer influent radiation monitor,
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t the vaporizer would shutdown; I i (2) The declaration of a station event with an emergency classification of i i i alert or higher would require the shutdown of the vaporizer and l evaporator; ! i l 1
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, INTERROGATORY NO. 542 - Will the evaporator system be independent of all other plant systems at Unit I and Unit 2. If "no", answer: '
- a. How will the evaporator system be dependent?
- b. How will GPUN/NRC be able to deltneate emissions from the evaporator from the routine emissions from Unit I and Unit 2.
ANSWER NO. 542 - The disposal system will be independent of Unit 1. The dependenc.y upon Unit 2 will be for plant service support such as electricity. fir. water. and plant tie-ins to the holding tank (s) for AGW. The evaporator emissions will be an individual release point. Separate records of evaporator effluent emissions will be maintained. c l INTERROGATORY NO. 543 . Does the selected evaporator have a proven record for dealing with water with this particular chemistry? If "yes". provide this record. ANSWER NO. 543 - Water with this particular chemistry is unique to TMI-2. No two bodies of water have exactly the sr.me chemistry. However, the A.cident I Generated Water is similar to reactor coolant water found at most nuclear
- generating plants, and many nuclear plants utilize evaporators to purify or reclaim water for reuse in t'he plant systems.
I i INTERROGATORY NO. 544 - What is the capacity of the concentrates receiving tanks? ANSWER NO. S44 - The concentrates receiving tant as originally envisioned in 1 the July 1986 Report is no longer a part of the disposal system. However, the capacity of various system tanks are itsted in the System Description, Attachment 1. The capacity of the concer.trate holding tank, which is somewhat i i ( I
i analagous to the originally conceived concentrate receiving tank, has not yet ' been determined. However, it is envisioned that this tank will have a l capacity of l'00 to 120 gallons. ! t i INTERROGATORY NO. 545 - What special procedures will be used for transferring i the evaporator bottoms from the acentrates receiving tank to the solidification system? (p. 33, Gi.i Proposal.) l ANSWER NO. 545 - See response to Interrogatory No. 546. i r
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INTERROGATORY NO. 546 - Describe the piping modifications to be mede for the ! transfer of the evaporator bottoms to the solldtftcation system. (p. 33. GPU Proposal.) ANSWER NO. 546 - The discussions of evaporator bottoms processing presented on page 33 of the July 1986 Report were based on the assumption that the bottoms ; would be solidified with cement in large, standard'(6 ft. diameter x 6 ft. ; high) radioactive waste liners. It was enytstoned that this process would be supplied by a separate vendor and would take place on the 280'-6" elevation of j the Auxillary Butiding as this location has been used for process ( solidification work at TMI-2. Curient plant, call for the evaporator bottoms processing system to be supplied by one vendor and to be set up and operated as a complete package. No piping modifications will be required because all necessary piping and connections l will be provided by the vendor . The evaporator bottoms will be processed to l l l l J
4 i the maximum solid concentration and to dryness in the blender / dryer portion of the system prior to packaring s for disposal in Specification 17 (c), 55-gallon , drums as outlined in Sections 2.3.6 and 2.3.7 of the System Description. The j transfer of the concentrates to the blender / dryer and the packaging of the drums will not require special procedures as envisioned in the July 1986 R*e port . INTERROGATORY NO. S47 - Describe the cement binder to be used. ANSWER NO. 547 - There will be no cement binder used. See System Description, ; Section 2.3.7, Packaging. 1 INTERROGATORY NO. S48 - Identify the expected amount of solidified waste to be ; , created by the solidification of the evaporator bottoms? State the basis for l this expectation. AN3WER NO. 548 - There will be no solidified waste. The waste form and its estimated volume are described in the section 2.3.7 of the System Description. I
; INTERROGATORY NO. 549 - State those limitations imposed by the burial ground 1
- Ticense on the solidification binder. '
ANSWER NO. S49 - 10 CFR 61.55 requires that low-level radioactive waste be classified into one of three classes (A, 8 or C) based on the contentrations of the radionuclides present in the waste form. 10 CFR 61.56 specifies the 1
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waste form characteristics required for disposal. Class A waste must meet the minimum physical form requirements, including less than 1% (by volume) free i standing liquids in the disposal package and the exclusion of cardboard or i fiberboard boxes for waste packages. In addision to the minluum requirements described above, Class B waste and Clast, C waste must be packaged in a manner to ensure structural stability. Structural stability can be provided by processing the waste with the addition of binders that will yield a free standing monolith (in the disposal package) which exhibits a 50 pounds per f square inch compressability strength or by placing the waste in a specially 4 licensed and approved disposal container that has been designed to last 300 years in the burial environment. The July 1986 Report assumed that the evaporator bottoms resulting from t
, disposal of the AGW would be typical of other similar boric acid concentrates (i.e., maximuth solids concentration o' 25% by weight). Calculations I j demonstrated that these bottees would meet Class A limits and, thus, be subject to only the minimum physical form requirements. However, at a solids concentration of 25% by weight, the waste packages would not meet the standards for free standing 11gulds It was, therefore, assumed that a cement i
binder would be added to immobilize the free water. Cement originally was ' l chosen because it is an approved binder at the burial ground, and it is i compatible with the boric acid concentration waste form, Since the , i immobilized evaporator bcttoms are Class A, the binder would only have to meet the approval requirements of the burial ground and not the aforementioned stability requirements. 1 4
The disposal system to be supplied by the vendor will include a blender / dryer (System Description, Section 2.3.6) that will process the bottoms to the maximum solids concentration and to dryness. Since the evaporator bottoms will be dried and compressed, there will be no need to use binder, such as ' cement, to immobilize the free liquids. System Description, Section 2.3.7, states that it may be necessary to use a binder agent to minimize the dispersion factors involved in calculating the release fractions during a postulated median transportation accident. If these calculations show that a - binder is needed, one that is approved by the burial ground will be used. l Attachments C and 0 provide listing c' the solidification and stabilization media approved for use at the U.S. . ology low-level waste burial site in Hanford, WA. ; l t INTERROGATORY NO. SSO - Is there a bituminization process included with the evaporator? If "yes", answer the following:
- a. Is it acceptable to regulations for immobilization of the evaporator '
bottoms by use of asphalt. If not, what will replace it?
- b. State the modifications which will need to be made.
ANSWER NO. 550 - No. See response to Interrogatory No. S48. i INTERROGATORY NO. S51 - Has GPU sought permission from DER to bury the solidified AGH waste in an onsite industrial landfill?
, ANSWER NO. 351 - No.
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l INTERROGATORY N0. S52 - List the chemicals or other additives used in the-clean-up since the Accident in 1979 and explain where they were used and their quantitles. ANSWER NO. S52 - Chemicals used during the cleanup can be divided..by application, into two categories: additions to AGH and non-water system usage. I*. Additions to AGW A. Additions for Technical Specification Requirements: (1) additions of boric acid to RCS and make-up sources to maintain a boron concentration greater than 4950 ppm 8 but less than 6000 ppmB, and (2) additions of hydroxide to RCS and make-up sources to maintain a pH between 7.5 and 8.4. B. Additions to Resolve Water Problems: (1) periodic additions of hydrogen peroxide (totaling approximately 5000 gallons) to control the growth of microrganisms, and (2) additions of coagulants and diatomaceous earth to aid in DHCS filter efficiency. 1he qua.1tities are listed below: Coag.Jiants Betz 1182 - 38.6 gal Betz 1192 - 0.75 gal Calgon 289 - 3.4 gal Diatoruceous Earth Standard Super Cel - 880 lbs Celite 503 - 20 lbs l l l
l C. Introduction of Other Chemicals: (1) additions of hydraulic fluid to the RCS due to leakage from operating equipment systems, (2) additions of 2 to 3 gallons of Radiac Wash to the Auxiliary Building Sump, (3) additions of nitric acid to 20,000 gallons.of water, (4) additions of phosphoric acid to 12,000 gallons of water, and (5) additions of 350 gallons Triton-)'-100 to the AGH inventory. II. Non-water System Usage. Numerous chemicals have been approved (and used) in accordance with the Chemical Controls procedure. These materials can tie categorized as follows: A. Some liquid chemicals used for decontamination purposes are not compatible with ion-exchange materials (e.g., phosphoric acid). These chemicals are collected and removed from the plant via direct solidification. B. Other chemical used for decontamination are absorbed onto cloth, etc. and disposed of as solid waste material. C. A variety of lubricants, paints, organic seals, and toaps are l utilized throughout the plant. If contaminated, they are disposed of as solid material. i 4 l
, INTERROGATORY NO. SS3 - Did GPU consider the corrosive potential which the addition of the chlorine to the water would have on all parts and operation of:
- a. EPICOR II
- b. SDS
- c. Evaporator If "yes", 1) were tests undertaken? If so, explain.the tests and their results. 11) If "no", explain the basis for the assumption that no tests were needed.
ANSWER NO. SS3 - Yes. The corrosive potential of chlorine on stainless and carbon steel and other alloys is well documented. Because of its corrosive potential, GPU Nuclear does not use chlorine at THI-2. For this reason, GPU Nuclear did not perform any tests to determine the corrosive potential of the addition of chlorine. INTERROGATORY NO. S54 - List the chemical or other additives which the Licensee forsees it will have to use to achieve putting the plant into Post-Defueling Honitored Storage. ANSWER NO. 554 - At this time, GPU Nuclear does not know of any chemicals or other additives which would be required to put THI-2 into Post-Defueling Monitored Storage. If a chemical or other additive should be required it i would be purchased and used in accordance with GPU Nuclear's chemical control l l program. l l l I INTERROGATORY NO. 555 - What is the limit for all of the non-radioactive substances present in the water for the release into: ,
- a. air I
- b. water List the substances and their limits.
ANSHER NO. S55. Air Release Limits Any air release limit would be established by the Pennsylvania Department of Environmental Resources under Article II of Title 25 Pennsylvania Code-Air Resources. Water Release Limits ' Hater release limits for various substances are listed in Title 25 of the Pennsylvania Code. The limits for those substances listed on Table 2-9 of the July 1986 Report are as follows: Substance Limit Boron Per Request
- Sulfate 250 mg/l Chloride <l50 mg/'
Phosphate 2 mg/l pH 6-9 TOC 15 mg/l**
- While no specific limit exists relative to the release of boron, the National Pollutant Olscharge Elimination System (NPDES) permit for THI states that "the controlled rate of batch discharges of waste
, water containing total boron shall be approved by'the Department (Pennsylvania Department of Environmental Resources) in a letter amendment prior to discharge."
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** There are no specific Pennsylvania State regulatory limits for TOC (Total Organic Carbon). However, the NPDES Permit provides a limit for oil and grease of 15 mg/l (based on a monthly average) which would be used as the applicable limits for TOC.
INTERROGATORY NO. S56 - Does any of the non-radioactive substance (s) in the AGH ("base case and achievable") exceed the limit imposed by any permit required for by any governing agency - State, Local, or Federal - for disposal of the water? If "no", state the basis for this determination. If "yes", list the substances and their quantities. ANSWER NO. SS6 - With respect to releases into the atmosphere, GPU Nuclear letter 4410-87-L-0058, dated April 14, 1987 (see p. A-49 of PEIS, Supplement No. 2) provided an evaluation of particulate release into the atmosphere. See response to Interrogatory No. 555. With respect to releases to the water, although no release is proposed the July 1986 Report provided a list of' chemicals which are present in the AGW and their concentraticos. Based on the chemical concentrations listed in Table 2-9 and the limits listed in the response to Interrogatory No. 555, some water 1 chemistry adjustment would be required for certain water volumes prior to release. These adjustments are a normal industrial proc 0ss, however, and the existing variations from the limits would not present a major difficulty. The required adjustments can be readily performed prior to discharge. I i l l l
, INTERROGATORY NO. S57 - List those benefits provided by disposal of the water using the evaporation method which no other disposal method can provide. ANSWER NO. S57 - It is not necessary that the evaporation method provide benefits which no other disposal method can provide. Following the decision not to recommend river disposal (see answers above to Si and S2), GPU Nuclear r,ecommended forced evaporation with disposal of the concentrated evaporation residues at a licensed offsite Lcw-Level Waste Burial site. This method provides for permanent offsite disposal of the concentrated radioactive wastes. It results in very small and clearly acceptable environmental impacts. Given the small amount of solidified waste to be produced (4,400 to 4,500 cubic feet, System Description 2.3.7), there is also a very low risk of adverse consequences from the transportation of wastes to the offsite burial location. i INTERROGATORY NO. S58 - If GPU exceeds the low level waste allotments allowed by DOE before the end of clean-up, where will the excess low level waste be held. ANSWER NO. S58 - The Department of Energy granted GPU Nuclear an additional ! allocation of 46,000 cubic feet for disposal of evaporator bottoms. Since the volume of waste to be generated now is estimated to be 4,400 to 4,500 cubic feet (Sn tem Oescription, Section 2.3.7), exceeding the allocation is not a reasonable possibility. Nevertheless, if the 46,000 cubic feet allocation I were to be exceeded for a valid reason, it is expected that DOE would grant an additional allocation.
INTERROGATORY NO. S59 - Is the restart of Unit 2 a consideration in the selection of the method to dispose of the water? ANSWER NO. 559 - There has not been a decision to restart Unit 2, as this interrogatory presumes. Potential restart of Unit 2 was not a consideration in the selection of the method to dispose of the water. INTERROGATORY NO. 560 - Has GPU sought permission from DER to bury the solidified water in an onsite industrial landfill? ANSWER NO. S60 --No. INTERROGATORY NO. S61 - EIS 3.18, 3.2 Footnote (a). ! Provide documentation and water analysis results to show that the concentration for the specified (actinium - 227; americium - 241 and 242; californium - 249, 250, and 252; curium - 241, 243, 244, 245, and 246; neptunium - 237; protactinium - 231; plutonium - 238, 239, and 242; thorium - 228 and 230; and uranium - 232) does not exceed 1% of the total radioactivity. ANSWER NO S61 - Footnote (a) in Section 3.2 on Page 3.18 of PEIS (NUREG-0683) ' Supplement No. 2 is part of the NRC Staff's assessment of alternatives involving bulk liquid shipment. GPU Nuclear did not perform this evaluation. See the NRC Staff's response to Interrogatory No. 4 "SVA/TMIA's Interrogatories and Request for Production of Documents to Nuclear Regulatory Commission," January 31, 1988, on the same subject. See also GPU Nuclear letters 4410-87-L-0018, dated February 3, 1987, and 4410-87-L-0023, dated February 18, 1987, to NRC, reprinted in PEIS Supplement 2 at pages A.41-A.44. l
_ '*.M8 - 8 4 INTERROGATORY NO. S62 - What is the decontamination factor of the evaporator? State the basis for this determination. ANSWER NO. S62 - The average decontamination factor is 1,000. This is based 4 upon an average system carry-over-fraction of 0.1%. Y O P f r i
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l l 4.1.6 Testing ATTACHMENT A l . I 4.1.6.1 General: All hydrostEtic testing on piping shall be i performed at 1507. of operating pressure for 30 minutes, k 4.1.5.2 Vendor Shop Tests 4.1.6.2.1 The following shop tests and/or inspections shall be performed by the contractor: 4.1.6.2.2 Final cleaning and inspection prior to shipment. 4.1.6.2,3 All pumps, pipes and valves within the package shall be inspected prior to assembly and tested following assembly for leak tightness and operability. C 4.1.6.2.4 A performance test shall be carried out to demonstrate the ability of the proposed system to meet its performance requirements. Simulated waste solutions specified by GPUNC, less radioactivity, will be used and concentrated to specification requirements. Samples of feed and distillate will be taken and analyzed by ; vendor. Test report shall be submitted. In the l l procedure, contractor must clearly state what tests will be performed and how the results will be indicative of satisfactory performance. Unsatisfactory performance ( 16308 SE
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- during this demonstration phase mill be cause to reject i the contractor's proposed system, f
f . 4.1.6.2.5 Contractor shall assure the leak tight capability of the assembled evaporator package, for both liquids and gases, and shall outline in the proposal the intended procedures for accomplishing this objective, including gas tests to be performed and the acceptance standards for these tests. 4.1.6.2.6 A qualification test shall be performed to demonstrate the procedure to be used for cleaning of the evaporator package. 4.1.6.2.7 Operational Check - Operate all electrical and/or pneumatic components in correct sequence in accordance with contractor's approved procedures. Apply dummy signals where required for loop checks. Leak test all l pneumatic lines and operational check for correct setting of pressure switches, alarms, instru. mentation and other control devices to verify system performance. ! 1 1 4.1.6.2.8 System Test - A cceplete system checkout will be made by l the contractor's system inginter, qu&llfled per Article 2, Section 2.3. l 1630B SE I
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,, . 4.1.6.2.9 Calibration - Check calibration traceable to an appilcable standard of all t.w truments and fully document all inspection and tests. Affix Dal!hration labels to the calibrated instruwnts.
4.1.6.2.10 All testing, ins,Section and/or requM He repairs -
- required shall be setjact to the apprettk1 of GPUNC !
or its agents. Certifbd test certifir:ates and/or test reports shall be submitted for all indMoual ! items of equipment tested in addition to the ! complete package. ' 4.1.6.3 Field Tests , After installation ac TMI, a complete system performance , f- test will be conducted by contractor to demonstrate tt.e ; installed equipment will meet its performance l requirements. Haste solutions specified by GPUNC will be provided for this demonstration. Unsatisfactory ! performance during this test phase will be cause to { reject the contractors equipment. ! 4.1.7 Installation l 4.1.7.1 The evaporator equipment shall be shipped completely ] assembled ready for installation as tredified by para. 3.1.1.8. j l ( ( 1630B SE l
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APPENDIX C 1 APPROVED SOLIDIFICATION MEDIA Only approved solidification media can be used. Approved solidification rAdia vt:
- 1) A tech (Seneral Electric)
- 2) Aguaset I end II
- 3) Bitumen * (Wu te Chem and ATI)
- 4) Chem-Nuclear Cement
\
- 5) Concrete (Structural)
- 6) Delaware Custom Media I
- 7) Dow Media !
- 8) Envirostone
- 9) Hittman Grout
- 10) Petroset I and 11
- 11) Safe T Set i
- 12) Otho.r solidification Gedit a9d processM Aich have been approved by USNRC and/cr the Department.
l
- Note: For waste types that rMuire solidification, both oxidized bitumen and !
straight distilled are acceptable. ! l Solidification means a resultant waste form which is a free standing solid and i primarily relics upon a chemical reaction or- Enc 6psulation to contain the liquid. i Approved stabilization media may also be used as solidification agents without conducting tests necessary to verify stability provided the resulting waste form is a fre3 standing solid. ! It is the responsibility of the person orocessing the waste into a solid form to adhere to a quality control program to verify the waste fom is appropriate. If a i material can also be used as a sorbent, the restrictions noted for its use in Appendix F shall apply to its use as a solidification agent. 70s Tus STATE DEM.RTWENT OF aoCLA1. AND HEALTN SUtVj oc . . ............................... p, .,......,..-,,,,,,,,,,,,,,,, , , , , , , , , , , , , , , , , , ,, ,,,
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APPENDIX D APPROVED STABIL32ATf 0N MEDIA j Only processthose stabilization media which have bv.sn evaluatee) or tre in the of bein ments of the U.Io evaluated and are used with the 1.tability guidance require-
. Nuclear RUjulatory Commission's Lowdeval Licensing Branch, Technical Position on Waste Form or are specifically approved by th? l Ospartment ratics, mediaare are:consiiered acceptable staoilization media. Approved stabili-3
- 1) Aztech (General 21ectric)
- 2) Bitomen* (ATI and i'asie Chen)
- 3) Ct:em-Nuclear Cea.e^t
- 4) Concrete **
- 5) Dow Media (Vinyl Ester Styrene)
- 6) Envirostcae (b.b. Gpum Cement)
- 7) LN Tech t >iogies Cecen's C) 5tock Eqeipmerit Cement
- 9) Westirighouse - Hittrae Leent 10)
Other stablitzation mt<ita an6 processes which have been reviewed ant! approved form stability by U.S. NRC and/or the Department as meeting waste critaric.
- Note: Oxidized Bituren only.
} '"Concrete, wh*n used radioa tive matari.1 t as an encapsulaticq toedian around a 21al) *;31ume of crum than greater et,ntaining er equal toconcr,ete, 25f/) psi, shali hr.ve a fertaulated comprestsive str s POA THf FTATE DDARTMENT OF SOCIAL /WD SIEAT.nl U P7... . . . . .. ne w ou u49 .ws m ,r.-
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.' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS:0N 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In,the Matter of ) GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA I
) (Disposal of Accident-(Three Mile Island Nuclear ) Generated Hater)
Station, Unit 2) ) a I AFFIDAVIT OF F. R. STANDERFER s County of Dauphin ) ,f Commonwealth of Pennsylvania ) g i F; P F. R. Standerfer, being duly sworn according to law, deposes and says 5 '.' hat he is Director of THI-2 and Vice President, GPU Nuclear Corporation; that k Llansee's Answers to SVA/ THIA's Interrogatories to GPU Nuclear Corporation
?
$d are true and correct to the best of his information, knowledge, and belief; a nti that the sources of his information are the officers, employees, agents, ,, and contractors of GPU Nuclear Corporation.
/
'F. R. Standerfer /
Swcet, to and subscribed before methis/gdtf,dayofFebruary,1988. f M hA' n Notary Public
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