ML20151G660

Affidavit of Kl Harner.* Discusses Licensee Motion for Summary Disposition of Contentions 1,2,3,4b,5d,6 & 8.W/ Certificate of Svc

ML20151G660
Person / Time
Site:	Three Mile Island
Issue date:	07/19/1988
From:	Harner K GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20151G540	List: ML20151G537 ML20151G660
References
OLA, NUDOCS 8807290069
Download: ML20151G660 (4)

Text

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, UNITED STATES OF AMERICA 1 l

NUCLEAR REGULATORY COMMISSION l

l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of )

)

GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA

) (Disposal of Accident-(Three Mlle Island Nuclear ) Generated Water)

Station, Unit 2)

AFFIDAVIT OF KERRY L. HARNER County of Dauphin )

) ss.

Commonwealth of Pennsylvania )

KERRY L. HARNER, being duly sworn according to law, deposes and says as follows:

1. My name is Kerry L. Harner. My business address is P.O. Box 480, Middletown, Pennsylvania, 17057. I am employed by GPU Nuclear Corporation at Three Mlle Island Nuclear Station, Unit 2, as Radiological Chemistry Manager.

My_ responsibilities include providing chemical and radiochemical technical expertise to all projects supporting defueling, plant operations, radwaste processing, and accident generated water disposal. A summary of my professional qualifications and experience was flied on May 16, 1988, with my affidavits in. support of Licensee's Motion for Summary Disposition of Contention 5d, and Licensee's Motion for Summary Olsposition of Contentions 4b in part and 6 (Chemicals).

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2. I have reviewed "SVA/ THIA's Response to Licensee's Motion for Summary Olsposition on Contentions I, 2, 3, 4b. Sd, 6, and 8," dated June 20, 1988. On page 13 of that document, the Joint Intervenors state:

x) The NRC's assumption that the average concentration of radionuclides shown in Table 2.2, NUREG 0683, Supplement #2 is inaccurate. For example, while the average concentration of Tritium in the Table 2.2 is 1.3 E-1 Uci/ml, the concentration of tritium in the storage location, PHST 2, as of 11-07-86 is 2.1 Ucl/ml.

(Technical Specification for Processed Water Olsposal 12.4.86 P.43(7.3)

Because we have never measured tritium concentration even close to 2.1 uC1/ml, I undertook an inquiry to determine the accuracy of this statement.

3. The document cited by Joint Intervenors -- Technical Specifications for Processed Water Disposal -- was provided by Licensee during discovery. At the page of that document referenced by Joint Intervenors, the number 2.1 uC1/ml does appear. I have determined, however, that the entry is a typographical error. I have checked the laboratory analysis and results data for the PWST-2 sample (number 86-15668). The tritium value is 2.3E-1 uCl/ml, not 2.1 uC1/ml as erroneously reported in the bid procurement document.

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l K ry L. Harner Subscribed and sworn to before me this 19th day of July,1988.

NIQ A A41 Notary Public My Commission expires: August 21, 1989 .

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July 20, 1988 00LnEljE' V5NRt UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

I 0FF ILE J A'. MdVH 00CKE!mti  ! Ja*J-BRAttCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) .

) i I

GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA

) (Disposal of Accident-(Three Mile Island Nuclear ) Generated Water)

Station, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of counsel for Licensee's let-ter to the Licensing Board dated July 20, 1988 and "Affidavit of Kerry L. Harner" were served this 20th day of July, 1988, by U.S.

mail, first class, postage prepaid, upon the parties identified on the attached Service List.

Thomas A. Baxter, P.C.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA

) (Disposal of Accident-(Three Mile Island Nuclear ) Generhted Water)

Station, Unit 2) )

SERVICE LIST Sheldon J. Wolfe, Esquire Richard P. Mather, Esquire Atomic Safety and Licensing Department of Environmental Board Panel Resources U.S. Nuclear Regulatory Commonwealth of Pennsylvania Commission 505 Executive House Washington, D.C. 20555 Harrisburg, Pennsylvania 17120 Mr. Glenn O. Bright Ms. Frances Skolnick Atomic Safety and Licensing 2079 New Danville Pike Board Panel Lancaster, Pennsylvania 17603 U.S. Nuclear Regulatory Commission Ms. Vera L. Stuchinski Washington, D.C. 20555 315 Peffer Street Harrisburg, Pennsylvania 17102 Dr. Oscar H. Paris Atomic Safety and Licensing Dr. William D. Travers Board Panel Director, Three Mile Island U.S. Nuclear Regulatory Cleanup Project Directorate Commission P.O. Box 311 Washington, D.C. 20555 Middletown, Pennsylvania 17057 Stephen H. Lewis, Esquire Adjudicatory File Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board Office of the General Counsel Panel Docket U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Services Branch Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555