ML20154E199

Affidavit of Dr Buchanan (Contentions 4b in part,4c,& 4d).* Supports Licensee Motion for Summary Disposition of Contentions.Supporting Documentation & Certificate of Svc Encl

ML20154E199
Person / Time
Site:	Three Mile Island
Issue date:	05/09/1988
From:	Buchanan D GENERAL PUBLIC UTILITIES CORP.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20154E131	List: ML20154E128 ML20154E163 ML20154E176 ML20154E199
References
OLA, NUDOCS 8805200126
Download: ML20154E199 (54)

Text

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V UNITED STATES OF AMERICA i NUCLEAT< REGULATCRY 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 ) Generated Water)

Station, Unit 2) )

AFFIDAVIT OF DAVID R. BUCHANAN (Contentions 4b in part. 4c and 4d)

County of Dauphin )

) ss.

Commonwealth of Pennsylvania )

DAVID R. BUCHANAN, being duly sworn according to law, deposes and says as follows:

1. My name is David R. Buchanan. My business address is P.O. Box 480, Middletown, Pennsylvania, 17057. I am employed by GPU Nuclear Corporation

("GPUN") as Manager, Recovery Engineering, at Three Mile Island Nuclear Station, Unit 2. In that position, which I have held since August, 1986, I am responsible for all engineering support, except for defueling, to the THI-2 Division. A mechanical engineer with more than 24 years of experience in the nuclear industry, I have worked in various engineering positions for GPUN (and its predacessor) in support of the recovery effort at TMI-2 since July 1980.

I previously spent over 16 years in engineering work at Westinghouse Electric Corporation's Bettis Atomic Power Laboratory. A summary of my professional qualifications and experience is attached hereto as Exhibit "A".

2. I make this Affidavit in support of Licensee's Motion for Summary Disposition of Contentions 4b (in part), 4c, and 4d. I have personal knowledge of the matters stated herein and believe them to be true and 8005200126 a00509 0 DR ADOCK 050

o correct. I'will first describe GPUN's proposed system to dispose of the processed, Accident-Generated Water ("AGW") at THI-2. Next, in response to Contention 4b, I will address the removal from the AGW of transuranics and other radionuclides, and the bases for our confidence in the disposal system's removal capability. I will then respond to Contention 4c by describing the-disposal system's monitoring and sampling program, and the safety systems incorporated to control atmospheric releases. Finally, I will address the concern raised'in Contention 4d about the feed rate to the evaporator.

The Accident-Generated Water Olsposal System Overview

3. On July 31, 1986, GPUN flied with the NRC a report on the disposal of the processed, Accident-Generated Water ("AGW") at THI-2. In the report, GPUN identified and evaluated three disposal options on the basis of relative technical feasibilty, regulatory compliance, environmental effects, costs, waste generated.-and time required to accomplish. On the basis of the careful evaluation documented in that report, GPUN selected and proposed for NRC approval the option of evaporation and burial of the residue as commercial low-level waste.

4. On February 16, 1988, GPUN filed with the NRC a Preliminary System Description for Accident-Generated Water Disposal (Rev. 0), which is attached hereto as Exhibit "B" and incorporated as a part of this affidavit. The System Description is a compilation of currently available design information, -

and is subject to change until the detailed system design is finalized. GPUN has entered into a contract with Pacific Nuclear Systems, Inc. to supply the disposal system. The supplier of the evaporator is Pacific Nuclear System's sub-contractor Licon, Inc., which has designed and installed evaporator units since 1975. In February 1988, GPUN authorized the vendor to proceed to final design and fabrication of the disposal system for the specific TMI-2 application.

5. The process water disposal system consists of: (a) a dual evaporator system designed to evaporate the processed water at a rate of 5 gallons per minute; (b) an electric powered vaporizer designed to raise the evaporator distillate temperature to 240*F and to release the resultant steam to the atmosphere via a flash tank and exhaust stack; (c) a waste concentrator designed to produce the final compact waste form; and (d) a packaging section designed to prepare the resultant waste for shipment consistent with commercial low-level waste disposal regulations. Exhibit C includes a block diagram of the disposal system and a flow diagram which depicts each of the operations in a specific color. In this affidavit, I will focus upon the evaporator and vaporizer sections and related instrumentation, which are the objects of the several concerns raised in Contention 4.

6. The main evaporator is a vapor recompression type unit with the designed flexibility to be configured as a spraying flim or climbing film evaporator. Vapor recompression units are designed to continually recycle the latent heat of vaporization (heat necessary to change water into steam) to sustain continued boiling at reduced pressures and, therefore, at lower

temperatures.

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7. The main evaporator employs a vapor dome, positioned over a l

horizontal tube heat exchanger, to collect the natural rising vapor from the evaporator process. This vapor collection is through two 12-inch diametrically opposed uptake pipes which feed an entrainment separator housed within the dome. The entrained water is screened by capillary action on the wires of two-stage mes' .mpingement screens that drain the separated solids to the bottom of the sep:, tor. There, the solids are extracted by the recycle pump and routed to the concentrate tank. The vapor compressor, taking a suction on the vapor dome, superheats this dried vapor by the heat of compression and discharges the heated vapor down through the tube side of the 520 ft 2heat exchanger. The vapor is condensed and then routed to the skid mounted distillate tank for ultimate vaporization and atmospheric release. If desired, the product distillate from the main evaporator can be routed to an interim staging tank for holding purposes -- such as radiochemical analysis, batching evolutions and system shutdown -- prior to being routed to the vaporizer assembly for atmospheric release.

8. The product concentrate, separated by the two-stage impingement screens and collected in the concentrate tank, will be recycled back through the main evaporator for further processing or, depending on the level of its concentrate, routed to the settling tank for second stage treatment by the auxiliary evaporator. The second stage treatment consists of increasing the level of solids concentrate to 100.000 to 500,000 ppm by forced evaporation in the auxiliary evaporator section whicn is similar in design and employs the same method of solids separation as the main evaporator.

9. The increased concentrate from this separation process is collected at the bottom of the auxiliary evaporator separator where it is extracted by the second stage recycle pump and returned to the settling tank. This increased concentrate will be recycled through the auxiliary evaporator for further processing or, depending on the solids concentrate level, extracted by the concentrate feed pump and routed to the blender / dryer section via the concentrate holding tank for final treatment prior to packaging operations.

The Evaporator

10. The principle utilized in a high vacuum vapor compressor distiller concentrator is similar to the refrigeration cycle except for the use of water as a refrigerant. As the system pressure is reduced, so is the boiling point of the product solution. Therefore, rapid evaporation takes place at a lower temperature and the latent heat of vaporization (heat necessary to change water into steam) can be continuously recycled b" the use of a vapor compressor.

11. Vapor recompression evaporation requires steam heat to initiate start-up and occasional supplementary heat to make up for heat losses during operation and feed heating requirements. This auxillary start-up and supplementary heat will be provided by the auxiliary evaporator which is designed to raise the start-up temperature to approximately 131'F. Once started, the main evaporator will boil the processea water under a vacuum on the shell side of the heat exchanger tubes at temperatures of 130*F to 140*F.

The excessive evaporator feed (that feed above the designed rate of

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r evaporation) will combine with the vapor generated and exit from the shell via twin 12-inch uptakes to the-separator.

12. The foaming tendency of the water during this process will completely "wet" the tubes, and the resultant vapor being generated will be in the form of minute-vapor bubbles. This action prevents the formation of large vapor bubbles which would insulate the tubes, raise the hydrostatic head and reduce heat transfer rates. The evaporation twin uptakes, diametrically opposed, discharge the larger water particles of the excess feed to the bottom of the separator. Any fine mist carried upward by the vapor impinges on the two-stage mesh, where it coalesces and drops to the bottom of the separator for extraction and recycling by the concentrate recyle pump. This feed and bleed action not only assures continuous wetting of the heat exchanger tubes, it provides the maximum concentration of the liquid for discharge to the auxiliary evaporator for additional processing.

13. The vapor compressor is designed to take suction from the vapor dome after the vapor has been dried by passing through the two-stage mesh separators. Flexible expansion joints will be incorporated to relieve any strain on the compressor housing. The rotary lobe compressor is a positive displacement blower with a capacity of about 5230 CFM at full load speed of 1750 rpm on the 125 HP compressor motor. Its designed application is to take suction on the rising vapor, heated by the latent heat of vaporization being collected in the vapor dome, and compress the vapor to create a rise in temperature due to the heat of compression.

14. The superheated vapor from the vapor compressor is discharged down through the annulus between the one-inch titanium sheaths of the heat exchanger where the vapor is condensed by the evaporating action from the processed boiling water. The condensate (distillate) is propelled to the back end of the titanium sheaths where it is sucked out through 1/4 inch stainless steel tubes and discharged to the distillate collection tank.

t The Vaporizer _

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15. The vaporizer section takes a suction from the product distillate  ;

supply. It is used to raise the product distillate temperatures to approximately 240'F under pressure, release the hedted distillate to '

atmospheric pressure via a flash tank and exhaust the resultant steam through a 100-foot high stack. The vaporizer assembly censists of: (a) three 300 KW ,

heaters used to elevate the distillate temperature to 240'F at 10 psig; (b) a  ;

24-inch diameter by 60-inch high stainless steel flash tank, used to expose the 240'F distillate to atmospheric pressure and to contain the re5Ultant steam; (c) a 7-1/2 HP pump, used to recirculate the d'" 11 ate in the flash j tank through the heaters; and (d) a 3-inch diameter by 100-foot high stainless steel exhaust stack, used to release the steam at a velocity of approximately ,

350 feet per second. The exhaust stack will be equipped with a sound abatement dampaner to modulate the sound levels during exhaust operations.

Removal of Radionuclides (4b)

16. It is important to recognize at the out set that the disposal l system under discussion here is not the only means by which the radionuclide content of THI-2 Accident-Generated Water has been and will be reduced. AGW l has also been treated by the Submerged Ocmineralizer System (505), EPICOR II, l

and the Defueling Water Cleanup System (OWCS), all of which employ ion I exchange processes and include particulate filtration. Prior to the initial use of S05, EPICOR II, and DHCS at THI-2, they were reviewed and approved by the NRC. [

17. It is also important to understand that the AGW is from a variety I

of sources, is stored in a number of different locations, and has diffe.'ent radiological characteristics. Through mid-1981, when the SOS began operation  !

to process water contained in the reactor building, approximately 1.3 million f gallons of water existed at THI-2. Of this volume, about 640,000 gallons were  ;

I located in the reactor building. Direct release from the reactor coolant i system contributed 69% of this water. An additional 28% was river water  ;

introduced via leaks in reactor building air coolers at the time of the accident, and the remaining 3% was added via the containment spray system t

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during the first several hours of the accident. Subsequent to 1981, most of the water was processed by both SOS and EPICOR II to reduce radionuclide levels to very low concentrations. In addition, approximately 570,000 gallons i of water existed in the auxiliary and fuel handling building tanks, most of  ;

which had been processed by EPICOR II by mid-1981. The reactor coolant system I contained an additional 96,000 as.'ons which also required processing by both j the 505 and the OWCS. Since 1981, the total inventory of processed water has ,

increased to the current volume of approximately 2.1 million gallons due to j continued additions from support systems and condensation from the reactor [

building air coolers during the summer months. The final volume of water requiring disposal is expected to be approximately 2.3 million gallons.

18. While the radiological content of the AGW at the individual source '

locations changes during defueling and decontamination detivities at THI-2, the total radiological content is known. Approximately 40% cf the AGW will be evaluated for possible pretreatment with the demineralization systems or batch cycle operations (described below) of the disposal system. This is the volume ,

of water currently in use for cleanup activities, and located principally in '

the Reactor Coolant System Fuel Pools-(A & B). Transfer Canal and building sumps. Tables 2-3 and 2-4 (attached) provide AGW source term information as presented in the July 1986 Report. The AGW will be pretreated to whatever extent is necessary to meet the constituent criteria, which I address below,  :

for processing in the disposal system.

19. All AGW will be processed through the evaporator prior to release ,

to the environment via vaporization. The designed flexibility of the disposal system permits the evaporator assembly to be de-coupled from the vaporizer assembly. In this configuration, the evaporator operates independent of the vaporizer and processes the water in a batch cycle method of operation.

Conversely, if the vaporizer is coupled to the evaporator during operations, the water will be processed in a continuous type method of operation. See Exhibit B, pages 21-22 for an expanded discussion of these two operational modes.

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20. The process control of atmospheric releases during the evaporator t i

and vaporization process will be implemented via the radiation monitoring and  !

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radlochemical sampling of the influent to the vaporizer section. Establishing  ;

process control at the vaporizer influent conservatively assumes a 100% [

carry-over fraction through the vaporizer assembly. There is no credit for f

plate out or solids separation in the heaters, flash tank or exhaust stack.

The radionuclides and their permissible level of concentrations as influent to  ;

. the vaporizer assembly for atmospheric releases are listed in Table 3-1 of f' 4

Exhibit B. This table conservatively assumes that certain radionuclides, not

positively identified in the AGW samples, nevertheless exist at the stated [

lowest limit of detection. These assumed radionuclides, identified by an asterisk, are included in the table. Table 3-2 of Exhibit B identifies the evaporator influent and effluent criteria for disposal system operation in the ,

I continuous cycle.

21. Precess operations by the evaporator coupled to the vaporizer i assembly or by the vaporizer assembly independent of the evaporator, will not be permitted until after it has been analytically deterrr.ined by NRC approved  !

process control procedures that the controlling constituents of the distillate f are at or below those levels of concentrations noted in the influent column of f the applicable table, (Exhibit B. Table 3-1, vaporizer influent criteria, and l Table 3-2, continuous cycle evaporator influent criteria), i I

22. The average influent to the vaporizer assembly, noted in Table 3-1, is approximately 2.16E-7 pC1/ml. This concentration, discharge <i at a rate of 5 GPM, limits the continuous release of non-tritium radioactive material (principally cesium-137, strontium-90, and carbon-14) to approximately 8.23E-5 ,

pCi/sec. This rate is less than 0.4% of the continuous particulate is ease i rate permitted by the TMI-2 Recovery Technical Specifications (0.024 pC1/sec) when averaged over any calendar quarter. It is also less ,

than the rate of release stated in PEIS Supplement No. 2, section 3.1.1.2 (0.00028 pCu/sec [2.8E-4]) which was calculated at a flow rate of 20 GPH.

The average release rate of tritium, at a water processing rate of 5 GPM, will be 38 pCi/sec, or 7% of the continuous release rate limit perinitted by the Technical Spectftcations.

23. The doses projected by both the NRC Staff and GPU Nuclear show that dispor.al system releases are within the numerical guidelines of Appendix I to 10 CFR Part 50. As reported in PEIS Supplement No. 2, the Staff computed a collective 50-year dose commitment to the 50-mile radius population (2.2 million people) to be less than 6 person-rem to the thyroid, 0.2 person-rem to the bone, and 3 person-rem to the total body. NUREG-0683, Supplement No. 2, p.3.7. I have considered whether there are any "items of reasonably demonstrated technology that, when added to the system sequentially and in order of diminishing cost-benefit returns, can for favorable cost-benefit ratio effect reduction in dose to the population reasonably expected to be within 50 miles of the reactor." I have not been able to identify any modifications to the proposed AGH disposal system which would further reduce the already insignificant doses for a cost of $1,000 per person-rem (the value provided in Paragraph II.0 of Appendix I).

24. The average carcy-over fraction for this disposal system is expected to be a minimum of 0.1% (i.e., a decontamination factor of least 1,000). This is based upon routine performance experience with typical evaporator systems used at nuclear power plants and in other applications throughout the United States. The Intervenors' questions during discovery reflect a perception that the use of an atmospheric release has some effect on disposal system performance. To the contrary, whether the condensate from evaporators is released into the atmosphere or recycled for plant use is irrelevant to the "set that the use of evaporators to remove liquid from a solution or slurry by vaporization of the liquid is well proven and well understood technology. In fact the evaporator portion of the AGH Disposal System for THI-2 operates in the closed cycle mode. The fact that the distillate is thereafter vaporized does not affect the performance (i.e., the carryover fraction) of the evaporator itself. An evaporator design which is a closed cycle, climbing / spray film, routinely achieves a decontamination factor of 1,000. See NUREG-0142 (H.H. Godbee and A.H. Kibbey, The Use of Evaporation to Treat Radioactive Liquids in Light-Water-Cooled Nuclear Power Plants, Oak Ridge National Laboratory, 1978), 1-3, 45-51; NUREG/CR-1992 (J.H. Mandler et al., In-Plant Source Term Measurements at Four PHRs, 1981), 58-71 and App. C.

25. If for some reason the evaporator does not meet performance expectations, the instrumentation and safety systems described below, along with the process control plan, will assure that releases do not exceed those estimated by the NRC staff in PEIS Supplement No. 2. In conclusion, there is reasonable assurance that the AGH disposal system will remove transuranics and other radionuclides to a level considerably below what is necessary to protect the public health and safety.

Monitoring and Sampling (4c)

26. The disposal system will employ well proven technology and be continually monitored and controlled with attomatic shutdown capabilities designed to terminate the vaporizer and atmospheric release process. With the exception of two controlled release points, one at the vaporizer section which will release the superheated steam to the atmosphere and the other at the waste processing section which will discharge the final waste to a collection point, the system will operate in a closed loop configuration.

27. The system design will provide conductivity monitoring at three independent system locations during the evaporator process. Conductivity monitors are designed to measure the electrical conductivity of process fluids as a method of product quality measurement. These types of instruments are routinely used on modern evaporators. Each of these monitoring points will be equipped with a sample point station for the extraction of process fluids for radiochemical analysis and a conductivity probe for the steady state monitoring of process 11guid quality. These monitoring locations are at the main evaporator feed, the evaporator effluent (distillate) and the vaporizer influent. Additionally, there will be a sample station located at the auxiliary evaporator concentrate discharge for concentrate sampling and a conductivity probe and sample station at the radiation monitor.

28. Operational experience and an accumulated data base accrued during actual evaporator operations will provide a sound basis for comparing these two methods of analysis -- physical sampling with laboratory analysis and steady state conductivity monitoring. After adequate demonstration of

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comparable analytical results and conductivity data, operational procedures may be modified to rely more extensively on the steady state conductivity instrumentation. However, until a data base can be compiled based on actual system operations, the control method utilized in procedures and operating programs will be the physical sampling and laboratvry analysis of process liquids. Radiation monitoring of the vaporizer influent will continue to be the essential method of process control of environmental release by the vaporizer assembly.

29. The vaporizer section of the system, which releaser the vaporized distillate into the atmosphere, will be monitored and controlled by a gamma radiation detector. This detector, located in the vaporizer assembly flow path, will monitor levels of gamma radiation in the distillate prior to the distillate being routed to the vaporizer heaters. The detector will be calibrated to sound an audible alarm and terminate atmospheric release by tripping off the vaporizer heaters and/or initiating valve closure to isolate the distillate supply to the vaporizer section. In the event an alarm condition occurs, the evaporator will continue to operate in a batch cycle mode, discharging the product distillate to a staging tank or recycling to through the the system until the system is secured or the alarm condition is removed. The ore-determined set points of the radiation detector are based on insuring the present THI-2 Technical Specification instantaneous release limit of 0.3 pCi/sec will not be exceeded. Monitoring equipment will be used which will allow a setpoint at 257. of this instantaneous release rate limit for particulates, which is 7.5E-2 pC1/sec.

30. The in-line radiation monitor being considered consists of three components: (1) a 11guld sampler, (2) a detector assembly in the sampler, and (3) a microprocessor based ratemeter/ controller. The liquid capacity of the sampler volume is 5800 cc (1.53 gallons). The detector assembly is a 2" x 2" canned, thallium-activated, sodium iodide crystal that is optically coupled to

! a photomultiplier tube. The detector assembly is mounted in a stainless steel I well which is located in the center of the sample chamber. The exterior of the sample chamber is completely surrounded in all directions by lead I shielding.

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4 131. The electronic signal from the detector assembly is connected to a microprocessor based ratemeter/ controller. The ratemeter has a dynamic range of 10'to 26 million counts-per-minute. The ratemeter display is updated every two seconds. The ratemeter/ controller-is also equipped with a failure alarm, a trend indicator, a warning (or alert alarm), and a high alarm. Another feature of the ratemeter/ controller is an energy spectrometer with a sensitivity of 100 millivolts 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.

32. Based on Table 3-2 of Exhibit B, the first nine (9) isotopes may be present in greater than detectable concentrations. Tritium and the beta en.itting isotopes will be determined by radioanalytical methods. Monitoring releases of these isotopes will be based on these analytical results and inlet flow rates to the vapor 12er.

33, The following is a list of the lower limit of detection (LLO) in microcuries/ml for the in-line radiation monitor:

Radionuclide Monitor Gam.ma LLO. uC1/ml Cesium-137 2.7E-8 Cesium-134 ~1.0E-8 Antimony 125/ Tellurium 125m 3.0E-8 Cobalt-60 1.2E-8 In the list of evaporator effluents of all the gamma emitting isotopes (Exhibit B, Table 3-2), Cs-137 is expected to be present in the most l

significant concentration or at 3.7E-8 pC1/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.

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34. Assuming the gamma emitting isotope Cs-137 is present in the i vaporizer influent at a concentration of 3.7E-8 pCi/ml, the level of concentraticr. permissible for continuous release per Table 3-1 (Exhibit B) and

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PEIS Supplement No. 2, then a corresponding maximum continuous release rate of 2.8E-4 pC1/sec for all the radionuclides is also present. This is the permissible rate of continuous release as bounded by PEIS Supplement No. 2.

35. This ratio of Cs-137 concentration to the maximum permissible

< continuous release rate yields a scaling factor of 1.32E-4. Using this scaling factor and the determined instantaneous release rate of 7.5E-2 pC1/sec, which is 25% of the Technical Specification maximum instantaneous release rate, it can be calculated that the-Cs-137 concentration of 9.9E-6 pC1/mi is the permissible limit for controlling the rate of instontaneous release. (1.32E-4 x 7.5E 9.9E-6)

36. The state of the art instrumentation, described above, will be installed and will be capcble of detecting this level of Cs-137, although it will be unable to detect minor variations in the extremely small quantities of most isotopes present. (Exhibit B, Table 3-1 notes that 22 1sotopes are expected to be present at levels below LLD). Others are of such small quantitles as to be a small fraction of the Technical Specification limits.

Therefore, this monitor is expecteo to detect "gross upsets" and terminate releases to the environment before the Technical Specification release limits are exceeded. Conservatively, assuaing a 100% carryover of the particulate content through the vaporizer, radioisotopic content of the influent to the vaporizer (i.e., the evaporation distillate) is the process control mechanism and will be controlled by sampling and conductivity monitoring. It is noteworthy that the radiation alarm set point is approximately the same as the limit for the average Cs-137 concentrations permissible in the evaporator influent. Thus, the set point limit of the detector provides reasonable assurance that the evaporator is not by-passed.

37. The question has been raised as to why GPUN has not made provision for the measurement of tritium releases. A satoling regimen for each water source to be processed by the evaporator will be established. The results of this sampling regimen will be used to establish the tritium concentration in each water source. All tritium will be assumed to be released to the environs from each water source. 3ased on the quarterly average concentration of 1.3E-1 pCl/mi of tritium, at a controlled processing rate of not greater than 5 gpm, the resultant quarterly average release rate would be 38 C1/sec

-- which is 7% of the allowable 570 pCi/sec calculated for average annual meteorological conditions at the site boundary. Thus, the evaporator process control and a sampling regimen ensures that release rates for tritium are not exceeded.

38. A final measurement of tritium in the evaporator stack would require the extraction and condensation of a representative sample from the steam-vapor component. Since the evaporator stack diameter is 3 inches, the construction of an extractor is not technologically feasible or advisable.

Special consideration nas been given to avoid formation of droplets in the steam released from the evaporator. The introduction of an extractor /

condenser would nullify the benefits of the system design.

39. Siminarly, there is no need to directly measure strontium in the vaporizer assembly flow path. A sa'pling m regime will be used to establish the Sr-90 from a Cs-137/sr-90 ratio for water sources to be processed by the evaporator. Radiochemical analysis is preferable to real time monitoring for accurately determining strontium releases. Therefore, Sr/Y90 releases will be determined by a pre-processing sampling regime.

40. The instrumentation I have described will be used in the Process Control Plan for the AGH disposal system. The Process Control Plan will provide a sequence of activities which describe the actions necessary to assure the success of an evolution such as the disposal of AGW by evaporation. These activities will be defined in TMI-2 written procedures.

The directions will include:

a) Feed preparation

• Selection of a volume of water to be processed

• Transfer of the water to feed itaging location

• Mix the contents

• Sample and analyze

• Evaluate the data

• Determine batch size

• Prepare a process instruction data sheet

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p-b) Processing e Complete prerequisites for processing

• Commence process e Monitor the process e Sample and analyze the effluent e Evaluate data c) Release to atmosphere (vaporizer) e Monitor the process

• Calculate release concentrations e Complete documentation.

41. I have described the disposal system's monitoring and sampling capabilities, which are more than sufficient to support the process control plan and to determine compilance with the TMI-2 Technical Specifications. In addition, I have described the automatic shutdown feature located on the vaporizer section, which will terminate releases to the atmosphere if the in-line monitor determines radiation levels to be unacceptable. These monitoring and safety systems provide the safeguards needed to protect the public health and safety during AGW disposal system operations.

Evaporator Feed Rate (4d)

42. At a February 26, 1987, meeting of the NRC's Advisory Panel for the Decontamination of THI-2, GPUN stated its expectation that the AGH 01sposal System would operate at an evaporator influent rate of anywhere from 3 to 20 gallons per minute. At that time, GPUN was evaluating the various proposals submitted by potential vendors, and a bidder had not been selected. The Pacific Nuclear system chosen is designed to operate at a rate of 5 gpm, and due to the physical size of the components (such as evaporator body, heat exchanger surface, vapor recompressor) cannot exceed that amount. Therefore, the concern about varying the influent rate from 3 to 20 gpm is not relevant to the disposal system GPUN is proposing for TMI-2.

43. The evaporator designer / fabricator, LICON, Inc., has over 100 years of experience and holds 27 patents in evaporator design. The particular unit being fabricated for the THI-2 application, although different in materials of

g I~ construction and instrumented controls, is similar in basic design and operational capacity (5 GPM) to four other LICON units -- three currently in operation and one in fabrication. One of these 5 GPM units has been in service for over one year by a company whose satisfaction with its performance is demonstrated by the procurement of the unit currently in fabrication. The other two operational units have more than two years each of operational experience. The typical carryover f action during operation of these units has been 0.1% or less.

44. The releases of radionuclides to the atmosphere as a result of disposal system operation are not meaningfully affected by the evaporator influent rate in any case. Evaporation of the AGH is expected to require about two years to complete. Day-to-day variations in the releases, which are determined mostly by the concentration of the particular water source being used as the influant, will not affect the environmental dose -- which is driven by the long-term climatic dispersion conditions.

• N/ n~~ '

David R. Buchanan Subscribed and sworn to before me this D day of M cuA, , 1988.

Cv Mb h Notar\y Public Ettu ulcMitti(160. notAeV Pusuc 10400#0EreY TWP., DAUPMI,4 C0t"#

NY COWWisS10tl(IPIREs stPt. Ii (qty My Commission expires: WW". PmnWee Asunnon oe u 5 TABLE 2-3 .

Tr11-2 PROCESSF.0 VATER SOURCE TERR 1S RADIONUCLIDE CONC [NTRAT10N

--a ACTUAL SOURCE TERrts ===

Sr-90 Cs-137 Cs-134 Sb-125 Co-60 VELUr1E SAr1PLE H-3 pCi/ml pCi/mi pCl/mi pCi/mi pCi/mi GALLONS DATE pCl/mi STORAGE DESCRIPil0N ---

67.286 3/7/86 .. 1.20E-O I 1.00E+00 2 60E-01 7.40E-05 3 60E-02 9 40E-03 RCS REACTOR COG. ANT SYSTErl 109.08I 2/22/86 3.00E-Ol 1.60E-05 6.80E-06 PWST-1 PROCESSED WATER STORAGE 480.134 2/24/06 2.80ECl 5.30E-05 4.40E-06 PwST-2 PROCESSED WATER STORAGE 101.5IS 3/3/86 5.60E-02 1.80E-04 4 40E-06 CO-T-1A CONDENSATE STORAE 9.00E-07 5.6 I0 4/12/83 1.30E-01 2.58E-05 9.40E-06 9.40E-07 -

WDL-T-9A EVAP. Core. TEST TAMC 1.30E-01 8.80E-0S 5.00E-% 3.50E-07 2.231 4/17/83 WDL-T-98 EVAP.C0te. TEST TANK 20.500 3/5/86 1.30E-01 5 80E-04 1.80E-04 5 00E-06 4.90E-05 CC-T-1 EPICOR l10FF-58EC 1.10E-04 6.50E-06 16.887 11/15/85 8.80E-02 3.00E-04 1.50E-04 CC-T-2 EPICORit CLEAN 241.698 3/2/86 4.50E-02 3.30E-05 3.60E-06 SFP-B SPENT FUEL POOL ~B*

7.60E-02 5.30E-03 9.00E-04 6 60E-04 373 3/14/86 SDS-T-lA SDS t10NITOR 7.30E-02 9.70E-04 1.00E-03 9.40E-04 6 90E-05 SDS NONITGt 497 3/8/86 SDS-T-18 2/24/86 8.50E-02 3.30E-02 9.30E-03 2.70E-05 4 60E-04 9 00E-05 RC BLEED HOLOUP 3.810 VDL-T-l A 3/7/86 1.30E-01 1.70E+00 2.00E-01 5 60E-03 3 40E-02 6 60E-03 RC BLEED HOLDUP 4.420 8.IOE-02 6 50E-03 WDL-T-16 10/31/85 1.70E-01 2.50E+ 00 1.70E-01 RC BLEED HOLOUP 57.116 2 70E-06 VDL-T-1C 3/4/86 6.60E-02 3.00E-04 1.30E-04 8.90E-06 BORATED WATER STORAE 458.915 BVST 2/28/86 9.00E-02 1.40E-01 1.90E-01 5.30E-03 MUTRAtl2ER 8.675 WDL-T-6A 3/1/86 6.80E-02 7.70E-02 1.80E-Of 5.30E-03 MUTRAtl2ER 8.605 WDL-T-68 2/28/86 6.90E-02 7.80E-02 1.70E-01 4.90E-03 3.712 WDL-T-2 I1tSCELLAMOUS WASTE HOLDUP 3.931 3/l/86 2.10E-05 2.70E-05 4.20E-05 9.30E-07 WDL-T-ilA CONTAf11NATED ORAINS 820 3/I/86 1.40E-05 1.10E-05 WDL-T-l18 CONTAf11NATED ORAINS 4.50E-02 1.10E-03 8.80E-04 3 40E-03 7 90E-06 1.680 3/2/86 CHEN CLEANING BLOG SurP 1.30E-CI I.20E-01 2.30E-02 5.917 10/4/85 AUXILIARY Bl.0G SUrP ,

43.082 4/26/85 2.60E-02 1.60E+00 490E+00 REACTOR 8 LOG SASEt1ENT  !

205.234 2/27/86 2.60E-01 3.20E-02 8.00E-03 2.40E-04 2.60E-03 2.50E-04 SPENT FUEL P0Q,. *A' SFP-A 3/12/86 3.00E-01 2 60E-02 8.60E-03 2.20E-04 2.90E-03 2.50E-04 58.685 --____________- --__ ,

DEEP END OF TRANSFER CANAL -

TOTAL AS OF t/1/86 1.908.417 pCl/ml - I.64E-0I 1.84E-01 I .2X-01 AVERAGE CONCENTRATIONS (BLANKS INDICATE lid VALUESOR DATA NOT AVAIL ABLEI 17

TABLE 2-4 -

it11-2 PAOCESSED WATER SOURCE terns ,

l l

TOTAL RADIOACTtvlTY

• *

• ACTUAL SOURCE TERNS * * *  :

Sr-90 Cs-137 Cs-134 Sb-125 Co-60 VOLUnE H -3 Ci C: Cl (i Ci GALLONS DATE Cl TANK DESCRIPTION ..... ---- . ..... --=

- ~ - - - _ - -- .....--

RE ACTOR C01 ANT SYSTEt1 67.286 3/7/86 . 3.06E+01 4.58E+02 6.62E+0! 188E+00 917E+00 2.39E +00 RCS 109.08l 2/22/06 1.24E*02 6.6 lE-03 2 8tE-03 PWST- 1 PROCESSED WATER STORAGE 480.134 2/24/06 5.09E+02 9.63E-02 8.00E-03 PwsT-2 PROCESSED WATER STORAGE 2.15E+0i 6 92E-02 169E-03 101.518 3/3/86 CO-T-IA CONDENSATE 5TORAGE 2.76E +00 SA8E-04 2.00E-04 2 00E-OS 1:9tE-05 EVAP.C0pe. TEST TAtst 5.610 4/12/83

• WDL-T-9A 1.10E+00 7A3E-04 4.22E-05 2.96E-06 2.231 4/17/83 WOL-T-98 EVAP.00Pe. TEST TAlet 20.500 3/5/86 1.0lE+01 4 SOE-02 1A0E-02 3 88E-04 3.00E-03 CC-T-1 EPICOR 110FF-SPEC 7 03E-03 4 15E-04 EPICOR il CLEAN 16.887 II/IS/85 5.62E+00 1.92E-02 9.59E-03 CC-T-2 4.12E + 01 3.02E-02 3.29E-03 SPENT FUEL POOL '8* 241.698 3/2/86 SFP-6 3/7/86 1.07E-01 7A8E-03 1.38E-03 9.32E-04 SDS tt0NITOR 373 SOS-T-lA 1.77E-03 1.30E-04 497 10/10/85 1.37E-01 1.82E-03 1.88E-03 SOS-T-le SDS t10NITOR RC BLEED HEDUP 3.810 2/24/06 1.23E+00 4.76E-01 1.3 4-01 3 89E-04 6 63E-03 1.30E-03 f 9

WDL-T-1A 2.17E+00 2.84E+01 3.3SE+00 9.37E-02 5.69E-01 1.10E-01 RC SLEED HOLDUP 4.420 3/7/86 I WDL-T-18 10/31/85 3.68E +01 SA0E+02 3.68E+01 1.75E+01 1.41E+00 RC BLEED HOLDUP S7. I lf. i WDL-T-lc 1.15E+02 6.60E-01 2 26E-01 1.55E-02 4 69E-03 8(RATED WATER STORAE 4S8.9 IS 3/4/86 i 8WST 2.96E+00 4.60E+00 6.24 00 1.74E-01 MUTRAll2ER 8.675 2/28/86 #

WDL-T-6A 2.2 tE*00 2.5IE+00 5 !,5E+00 1.73E-01 MUTRAtl2ER 8.605 3/1/86 WDL-T-68 9.69E-01 1.10E+00 2.39E+00 6.88E-02 3.712 2/28/86 WDL-T-2 tilSCELLAMOUS WASTE Hm.00P l.931 3/1/86 1.53E-04 1.97E-04 3.07E-04 6.80E-06 WDL-T-ll A CONTAt1NATED DRAINS 3 AIE-05 CONTANINATED DRAINS 820 3/1/86 4.35E-05 WDL-T-l18 3/2/86 2.86E-01 6.99E-03 5.60E-03 2.16E-02 5.02E-05 CHEN CLEANING BLD6 Sulf 1.680 5.917 10/4/85 2.91E+00 2.69E+00 5.15E-01 AUXILIARY 8tDO SIP")

13.082 4/26/85 4.24E+00 2.6IE+02 7 99E+02 MACTOR SLOG BASEffMT 205.234 2/27/86 2.02E+02 2A9E+01 6.84+00 1.86E-01 2.02E+00 194E-01 SFP-A SPENT FUEL P01 *A*

$6.685 3/12/86 6.66E +0! 5.78E+00 1.91E*00 4 89E-02 6A4E-01 5.55E-02 ,

DEEP END OF TRANSTER CMIAL .- -..____.______...._____._. . . _.....__ ,

1.908.417 1182.75 1331.17 929A9 TOTAL AS OF 1/1/86 13

4 n '

Exhibit A RESUME David R. Buchanan P.O. Box 480 Middletown, PA 17057 WORK HISTORY 07/80 - Present GPU Nuclear Corporation /GPU Service Corporation Current

Title:

Manager, Recovery Engineering, TMI-2 Dept./ Loc. : Site Operations, TMI-2 Responsible for all engineering support, except for defueling, to the TMI-2 Division. Activities

! include plant modifications, support to Operations

and Maintenance, Radiochemical Engineering, l Start-Up and Test, and Fire Protection. The section was formed September 1986, by combining the Site Engineering and Plant Engineering sections.

02/86 - 08/86 - Manager, Site Engineering, TMI-2. Provided on-site engineering support to ensure technical adequacy of I recovery efforts. Prepared and reviewed safety evaluations and modification packages, plus developed and managed the program for Important to Safety (ITS) determination to correctly classify I recovery programs work. Also, responsible for TMI-2 Start-Up t.nd Test activities.

12/84 - 2/86 - Task Leader, Reactor Disassembly and Defueling.

Responsible for provf ding progrannatic direction and technical overviiw for on-site recovery l

i activities related to reactor defueling/ disassembly as assigned by the Manager, Recovery Programs.

l Assignments included defueling plus defueling water i

clean-up systems, Waste Handling and Packaging Facility, and the Sediment Transfer System.

09/82 - 11/84 - Manager Site Engineering, TMI-?. Same as during February 1986 through August 1986 08/81 - 09/82 - Manager, Project Engineering. Managed the Project Engineering Section to include direction of l technical work, monitoring attainment of department cost / schedule goals and managing proiects such as RCS Processing, EPICOR Venting, and cagineering involvement in the Quick Look Entry, i

l l

t A

'd D. R. Buchanan Page 2 07/80 - 08/81 - Supervisor, Recovery Technical Planning.

Supervised technical planning efforts associated with initial recovery at TMI-2.

01/64 - 07/80 - Westinghouse Electric Corporation Emplo ed at Bettis Atomic Power Laboratory in the positions of Associate Engineer, Refueling Equipment Design and Operations; Senior Engineer, Fluid Systems; Supervisor / Manager. Manual Welding Support; Materials Evaluation Lt.sratory Engineering Manager; and Decontamination Engineering Manager.

07/59 - 12/63 - U.S. Steel Corporation Entered management training program. Majority of experience as Roll Designer for structural and plate mills.

EDUCATION B.S., Mechanical Engineering, Lehigh University,1959 LICENSES AND CERTIFICATES P.E. License, State of Pennsylvania,1965 i ..

.- 4 Exhibit D i .

l PRELIMINARY SYSTEM DESCRIPTION FOR ACCIDENT GENERATED WATER DISPOSAL Rev. 0 l

l l

l l

l I

// W

~

Mpared 3y anageMicovery Engineering

.2-a-se z.h

/ Dat'e A77 i Date l

- - - - - - - - +

-w ,%- ---c.,- -- . - .,- , . - . _y4,p---*, -p , ,gy  %.g.,,- -.-m---g ec,-=%~eww+w--wey.m #s.m-www-,~.-.ei-,y- r D-M e-

I, I

0 i

k l 1.0 PURPOSE. SCOPE AND ORGANIZATION l

l l

1.1 PurDose l

The purpose of this document is to describe the system and l

evolutions which will accomplish the controlled disposal of approximately 2.3 million gallons of "Accident Generated Water",

hereinafter referred to as processed water.

1.2 Scope o

The scope of this system description addresses the processing of this inventory by forced evaporation followed by a vaporization process and atmospheric release of the product distillate. It also includes the separation and final treatment of the solids removed and collected during the evaporation process and the preparation of the resulting waste product for shipment and burial at a comercial low level waste facility.

1.3 Orcanization Section 2.0 describes the process and contains a system description of the evaporator, the vaporizer and the associated waste processing operations.

1 0078H/3H

- Section 3.0 describes the control of process and the operational options.

2.0 OESCRIPTION OF THE PROCESSED WATER DISPOSAL SYSTEM

2.1 Background

The TMI-2 accident resulted in the production of large volumes of contaminated water, herein referred to as processed water. Through mid-1981, when the submerged demineralizer system (505) began operation to process water contained in the reactor building, approximately 1.3 million gallons of water existed at TMI-2. Of this volume, about 640,000 gallons were located in the reactor building. Direct release from the reactor coolant system contributed 69% of this water. An additional 28% was river water introduced via leaks in Reactor Building air coolers and the remaining 3% was added via the containment spray system during the first several hours of the accident. Subsequent to 1981, most of the water was processed by both 505 and EPICOR II to reduce radionuclide levels to very low concentrations. In addition, approximately 570,000 gallons of water existed in the auxiliary and fuel handling building tanks, most of which had been processed by EPICOR !! by mid-1981. The reactor coolant system contained an additional 96,000 gallons which also required processing by both the 505 and the defueling water clean-up system (0WCS). Since t

2 0078H/3H

'1981, the total inventory of processed water has increased to the current volume of approximately 2.1 million gallons due to continued additions from support systems and condensation f rom the reactor building air coolers during the summer months.

Considerable care has been exercised to minimize the additions of new water and to ensure that the commi'ngling of non-contaminated water with the processed water is restricted. Even with exercising care to minimize additions of new water, the final volt.me of water requiring disposal is expected to be 2.3 million gallons (as stated in Section 1.1).

2.2 Process Description 1

l l

The processed water disposal program consists of: (a) a dual l

t evaporator system designed to evaporate the processed water at a rate of five GPM; (b) an electric powered vaporizer designed to raise the evaporator distillate temperature to 240*F and release the resultant steam to the atmosphere via a flash tank and exhaust stack; (c) a waste concentrator designed to produce the final compact waste form, and (d) a packaging section designed to prepare the resultant waste for shipment consistent with commercial low level waste disposal regulations. If desired, the product distillate from the main evaporator can be routed to an interim staging tank for holding purposes, i.e.; to permit radiochemica) analysis, batching evolutions and system shutdown, prior to being 3 0078H/3H

routed to the vaporizer assembly for atmospheric release. The residual concentrate (bottoms) from the main evaporator section will be routed to the auxiliary evaporator for additional processing and then to the final concentrator where it will be processed into the final compact waste form. The project will employ well proven technology and be continually monitored and controlled with automatic shutdown capabilities designed to terminate the vaporizer and atmospheric release process. With the exception of two controlled release points, one at the vaporizer section, which will release the superheated steam to the atmosphere and the other at the waste processing section which will discharge the final waste to a collection point, the system will operate in a 1

closed loop configuration.

2.3 System Oescriotion The processed water disposal system consists of four major I component groups. They are: (1) the evaporator, (2) the vaporizer, (3) the blender / dryer concentrator, and (4) the waste 1., Process Flow Diagram) preparation sections. (See Attachment A contract agreement was entered into with the selected vendor for construction of these four component groups and authorization was issued February 1988 to proceed to final design and fabrication of the equipment for the specific TMI-2 application. Certain 4

0078H/3H

definitive design details necessary to prepare a comprehensive system description are not currently available as these final designs are an on-going effort. The descriptive information that is available and used extensively in the preparation of this system description is: (a) the vendor's contract proposal, (b) a system description for a unit similar to the one proposed for this application, and (c) preliminary design information submitted by the vendor January 1988 for review /consnent by GPU.

Given these limitations, the following provides a general system description pending completion of the final designs.

2.3.1 General The main evaporator is a vapor recompression type unit with the j

designed flexibility to be configured as a spraying film or climbing film evaporator. Vapor recompression units are designed l

to continually recycle the latent heat of vaporization (heat

)

necessary to change water into steam) to sustain continued boiling at reduced pressures and therefore at lower temperatures.

I The main evaporator employs a vapor dome, positioned over a horizontal tube heat exchanger, to collect the natural rising vapor from the evaporator process. This vapor collection is through two 12 inch diametrically opposed uptake pipes which feed an entrainment separator housed within the dome. The entrained 5

0078H/3H

water is screened by capillary action on the wires of two-stage mesh impingement screens that drain the separated solids to the bottom of the separator. There, the solids are extracted by the The vapor recycle pump and routed to the concentrate tank.

compressor, taking a suction on the vapor dome, superheats this dried vapor by the heat of compression and discharges the heated 2

vapor down through the tube side of the 520 ft heat exchanger.

The vapor is condensed and then routed to the skid mounted distillate tank for ultimate vaporization and atmospheric release.

If desired, due to batching evolutions, system shutdown or radiochemical analysis, the distillate can be routed to an interim staging tank.

The product concentrate, separated by the two-stat's impingement screens and collected in the concentrate tank, will be recycled l

back through the main evaporator for further processing or, l

depending on the level of its concentrate, routed to the settling The tank for second stage treatment by the auxiliary evaporator.

second stage treatment consists of increasing the level of solids concentrate to 100,000 to 500,000 ppm by forced evaporation in the auxiliary evaporator section which is similar in design and employs the same method of solids separation as the main evaporator.

I l

6 0078H/3H

1 s

i The increased concentrate from this separation process is co'lected at the bottom of the auxiliary evaporator separator where it is extracted by the second stage recycle pump and returned to the settling tank. This increased concentrate will be recycled through the auxiliary evaporator for further processing or, depending on the solids concentrate level, extracted by the concentrate feed pump and routed to th9 blender / dryer section via the concentrate holding tank for final treatment prior to packaging operations.

2.3.2 Evaporator l

i The principle utilized in a high vacuum vapor compressor distiller concentrator is similar to the ref rigeration cycle except for the use of water as a ref rigerant. As the system pressure is reduced,

! so is the boiling point of the product solution. Therefore, rapid evaporation takes place at a lower temperature and the latent heat of vaporization (heat necessary to change water into stean) can be continuously recycled by the use of a vapor compressor.

1 Vapor recompression evaporation requires steard heat to initiate start-up and occasional supplementary heat to make up for heat losses during operation and feed heating requirements. This auxiliary start-up and supplementary heat will be provided by the l

auxiliary evaporator which is designed to raise the start-up temperature to approximately 131*F. Once started, the main 7

0078H/3H l

evaporator will boil the processed water under a vacuum on the shell side of the heat exchanger tubes at temperatures of 130' to 140*F. The excessive evaporator feed, that feed above the designed rate of evaporation, will combine with the vapor generated and exit from the shell via twin 12 inch uptakes to the separator.

The foaming tendency of the water during this process will completely "wet" the tubes and the resultant vapor being generated will be in the form of minute vapor bubbles. This action prevents the formation of large vapor bubbles which would insulate the tubes, raise the hydrostatic head and reduce heat transfer rates.

The evaporator twin uptakes, diametrically opposed, discharge the larger water particles cf the excess feed to the bottom of the separator. Any fine mist carried upward by the vapor, impinges on the two-stage mesh where it coalesces and drops to the bottom of the separator for extraction and recycling by the concentrate recycle pump. This feed and bleed action not only assures continuous wetting of the heat exchanger tubes, it provides the maximum concentration of the liquid for discharge to the auxiliary evaporator for additional processing.

l The compressor action is described in Paragraph 2.3.4. The l

saperheated vapor from the vapor compressor is discharged down th.*ough the annulus between the 1 inch titanium sheaths of the heat exchanger where the vapor is condensed by the evaporating action l

l 8 0078H/3H l

from the processed boiling water. The condensate (distillate) is propelled to the back and of the titanium sheaths where it is sucked out through 1/4 inch stainless steel tubes and discharged to the distillate collection tank.

2.3.3 Vaporizer The vaporizer section takes a suction from the product distillate supply. It is used to raise the product distillate temperatures to approximately 240*F under pressure, release the heated distillate to atmospheric pressure via a flash tank and exhaust the resultant steam through a 100 foot high stack. The vaporizer assembly consists of: (a) three, 300 (KW) heaters used to elevate the l

l distillate temperature to 240*F at 10 psig; (b) a 24 inch diameter by 60 inch high stainless steel flash tank, used to expose the 240*F distillate to atmospheric pressure and to contain the resultant steam; (c) a 7-1/2 HP pump, used to recirculate the I

distillate in the flash tank through the heaters; and (d) a 3 inch i

diameter by 100 foot high stainless steel exhaust stack, used to release the steam at a velocity of approximately 350 feet per second. The exhaust stack will be equipped with a sound abatement dampener to modulate the sound levels during exhaust operations.

9 0078H/3H

2.3.4 vapor Compressor The vapor compressor is designed to take suction from the vapor dome after the vapor has been dried by passing through the two-stage mesh separators. Flexible expansion joints will be The incorporated to relieve any strain on the compressor housing.

rotary lobe compressor is a positive displacement blower with a capacity of about 5230 CFM at full load speed of 1750 rpm on the 125 HP comp. essor motor.

Its designed application is to take suction on the rising vapor, heated by the latent heat of vaporization being collected in the vapor dome, and compress the vapor to create a rise in temperature l

due to the heat of compression. This superheated vapor is then discharged into the tube side of the evaporator heat exchanger.

2.3.5 Auxiliarv Evaporator i

1 A small waste heat auxiliary evaporator using heat generated f rom l

r the before and after electric heater (s) and/or the 143*F product distillate from the main evaporator, will evaporate the product concentrate from the main evaporator at an approxinate temperature of 130'F. The vapor from the process will be routed to the main evaporator vapor dome to provide supplementary or start-up heat to the main evaporator. The increased concentrate (bottoms) from the 1

10 0078H/3H

auxiliary evaporator will be extracted by the recycle pump and routed to the settling tank. The concentrate will be recycled through the auxiliary evaporator and the settling tank until the level of concentrate is between 100,000 and 500,000 ppm at which time the a feed pump will take suction on the settling tank and route the concentrate to the concentrate holding tank.

2.3.6 Blender /Orver The blender / dryer will process the concentrate collected in the concentrate holding tank to the final waste form in a batch type process. The blender / dryer consists of a cylindrical, horizontal vessel equipped with an agitator for drying liquids and slurries to total dryness. The dryer body will be equipped with a 150 KW electrically heated jacket. The liquid in the waste slurry will be t

evaporated as it comes in contact with the heated body of the I vessel as the agitator moves the waste slurry from both ends of the dryer vessel toward a center discharge valve. The agitator l

consists of rotating helical ribbons which coritinually scrape the l

l dried product from the sides of the vessel and move the waste l

product to a center discharge valve. The drying process is

)

l I controlled so that the waste batch is discharged when the liquid is l

l removed, at which time the final waste product will be discharged l

directly into the collection section for packaging preparations.

1 l

l i

l 11 0078H/3H

The liquid from the dryer section will be returned to the main evaporator concentrate tank and reprocessed.

2.3.7 Packaaing Waste packaging options permit packaging by one of three methods, the selection of which is left to the discretion of the vendor.

All options are acceptable methods, relative to applicable ,

regulations, and all employ satisfactory volume reduction techniques. In the event a binder agent is required, to minimize the dispersion factors involved in calculation of release fractions during a postulated median transportation accident, its addition will not appreciably increase the estimated volume of waste generated as a result of any of these options. Option 1 utilizes a pelletizer to compact the waste into a pelletized form and then discharges the compressed product into a Spec. 17, 55 gallon transport drum. Option 2 discharges the waste product directly f rom the dryer into a 55 gallon drum, compacts the drum (and product) to a fraction of its original volume and loads the compacted drum into a transportation over-pac container. Option 3 discharges the waste product directly into a Spec. 17, 55 gallon l

transport drum and loads the drum, uncompacted, into a transportation over-pac container.

i l

l l

l 12 0078H/3H

The volume of waste generated as a result of any of these techniques is estimateo to be 4400 to 4500 ft . Inis volume represents a significant reduction to the estimated waste volume presented in the PEIS Supplement 2 wh1:h used as the reothod of 3

waste packaging solidifying the waste in 170 ft linars.

The base case presented in the PEIS Supplemer.t 2, which addresses 3

the solidification of waste with Portland cement in 170 ft liners, provides a waste volume estimate of between 27,000 to 46,000 ft , for 25 wt. % solids and 16 wt. % solids respectively,

' assuming a 0.35 cement to waste volume ratio. The base case further estimated that in the event of chemical impurities retsrding the curing rate and final strength of the concrete the projected volume of solidified waste could be as high as 88,000 ft .

l l

l 2.3.8 Instrumentation The system design will provide conductivity monitoring at three Each independent system locations during the evaporator process.

of these monitoring points will be equipped with a sample point i

station for the extraction of process fluids for radiochemical analysis and a conductivity probe for the steady state monitoring of process liquid quality. These monitoring locations are at the i

l l

l l

' 13 0078H/3H 1

l

main evaporator feed and at the main and suxiliary evaporator distillate discharge. Additionally, there will he a sample station located at the auxiliary evaporator concentrate discharge for concentrate sampling and a conductivity probe and sample station at the radiation monitor.

Operational experience and an accumulated data base accrued during actual evaporator operations will provide a sound basis for comparing these two methods of analysis, i.e., physical sampling with laboratory analysis and steady state conductivity monitoring.

I After adequate demonstration of comparcble analytical results and conductivity data, operational procedures may be modified to rely I more extensively on the steady state conductivity instrumentation, However, until a data base can be compiled based on actual system j

f operations, the control method utilized in procedures and operating programs will be the physical sampling and laboratory analysis of process liquids. Radiation monitoring of the vaporizer influent will continue to be the essential method of process control of environmental release by the vaporizer assembly.

The vaporizer section of the system, which releases the vaporized distillate into the atmosphere, will be monitored and controlled by a gamma radiation detector. This detector, located in the vaporizer assembly flow path, will monitor levels of gamma raciation in the distillate prior to the distillate being routed to l

1 14 0078H/3H I

the vaporizer heaters. The detector will be calibrated t' sound an audible alarm and terminate atmospheric release by tripping of f the vaporizer heaters and/or initiating valve closure to isolate the distillate supply to the vaporizer section. In the event an alarm condition occurs, the evaporator will continue to operate in a batch cycle mode, discharging the product distillate to a staging tank or recycling it through the system until the system is secured or the alarm condition is removed. The pre-determined set points of the radiation detector are based on insuring the present TMI-2 Technical Specification instantaneous release limit of 0.3

'uC1/sec. will not be exceeded. Monitoring equipment is available which will allow a setpoint at 25% of this instantaneous release rate limit for particulates which is 7.5E-2 uC1/sec.

Assuming the gamma emitting isotope Cs-137 is at a concentration of 3.7 E-8 uCi/ml., the level of concentration permissible for continuous release per Table 3-1 and the PE!S Supplement 2, is present in the vaporizer influent then a corresponding maximum i continuous release rate of 2.8E-4 uCi/sec. for all the radionuclides is also present. This is the permissible rate of continuous release as bounded by the PEIS Supplement 2.

i This ratio of Cs-137 concentration to the maximum permissible j

continuous release rate yields a scaling f actor of 1.32E-4. Using this scaling factor and the determined instantaneous release rate l

15 0078H/3H

(

of 7.5E-2 wCi/sec., which is 25% of the Technical ipecification maximum instantaneous release rate, it can be calculated that the Cs-137 concentration of 9.9E-6 vCi/ml. is the permissible limit for controlling the rete of instantaneous release.

(1.32E-4 X 7.5E-2 = 9.9E-6).

State of the art instrumentation will be installed which is capable of detecting this level of Cs-137 although it will be unable to detect minor variations in the extremely small quantities of most isotopes present. (Table 3 notes that 22 isotopes are expected to be pre *,ent at ie/els <LLO). Others are of such small quantities as to be A small fraction of the Technical Specification limits. Therefore, this monitor is expected to detect "gross upsets" and terminate releases to the environment before the Technical Specification release limits are exceeded.

Conservatively, assuming a 100% carryover of the particulate content through the vaporizer, radioisotopic e.ontent of the influent to tne vaporizer (i.e., the evaporation distillate) is the process control mechanism and will be additionally controlled by It is note worthy that the sampling and conductivity monitoring.

r&diation alarm set point is approximately the '.ame as the limit for the average Cs-137 concentrations permissible in the evaporator influent. Thus, the set point limit of the detector provides reasonable assurance that the evaporator is not by-passed.

i I

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16 0078H/3H

TA8LE 3-1 VAPORIZER INFLUENT CRITERIA Continuous Release (l)

Quantity Concentration Constituent .qj, uCi/mi Tritium 1.3 x 10-1 (Hydrogen-3) 1.02 x 103 Cesium-137 3,2 x 10-4 3.7 x 10-8 Cesium-134 7.66 x 10 6 8.8 x 10-10 Strontium-90 9.6 x 10-4 1.1 x 10-7 Antimony-125/

Tellurium-125m 2.0 x 10-5  ?.3 x 10-9 Carbon-14 8.7 x 10-4 1.0 x 10-7 Technetium-99 9.7 x 10-6 1.0 x 10-9 Iron-55 4.2 x 10-6 4.8 x 10-10 Cobalt-60 4.2 x 10-6 4.8 x 10-10 0.15 tons H 3803 3.0 ppm 8 Boron 0.011 tons NaOH .7 ppm Na+

Sodium

• Iodine-129 <S.? x 10-3 <6.0 x 10-7

• Cerium-144 <1.4 x 10-5 <1.8 x 10-9

• Manganese-54 <3.5 x 10-7 <4.0 x 10-11

• Cobalt-58 <3.5 x 10-7 '

<4.0 x 10-11

• Nickel-63 <5.2 x 10-' <6.0 x 10-10

• Zinc-65 <8.5 x 10-' <9.8 x 10-11

• Ruthenium-106/

Rhodium-106 <2.9 x 10-6 <3.3 x 10-10

• Silver-110m <4.9 x 10-7 <5.6 x 10-11 l

• Prome thi um-147 <4.2 x 10-5 <4.8 x 10-9

• Europium-152 <3.3 x 10-9 <3.8 x 10-13

• Europium-154 <3.8 x 10-7 <4.4 x 10-11

• Europium-155 <9.6 x 10-7 <1.1 x 10-10

• Uranium-234 <8.7 x 10-8 <1.0 x 10-11

• Uranium-235 <1.0 x 10-7 <1.2 x 10-11

• Uranium-238 <1.0 x 10-7 <1. 2 x 10-11

• Plutonium-038 <1.0 x 10-7 <1.2 x 10-11

• Plutonium-239 <1.2 x 10-7 <1.4 x 10-11

• Plutonium-240 <1.2 x 10-7 <1.4 x 10-11 i

l

• Plutonium-241 <5.7 x 10-6 <6.5 x 10-10

• bericium-241 <1.0 x 10'7 <1.2 x 10-11 I <1.0 x 10-10

• Curium-242 <8.7 x 10-7 l

l Totals l

Conc.entration (Average): 2.01 x 10-7 vCi/ml.

l Continuous Rate of Release at 5 GPM: 8.23 x 10-5 uti/sec.

l I

l *0enotes assumed constituents

< Oenotes less t.m level of detection (1) Release concentration average over any calendar quarter.

l 37 0076H/3H 4

n..- - _ , - - - . . - - - , ,

- TABLE 3-2 CONTINUOUS CYCLE EVAPORATOR INFLUENT / EFFLUENT CRITERIA Influent l Effluent l

l Quantity Concentration l

l Quantity Concentration Constituent l Q uCi/mi l Q uC1/mi l l Total volume l 2,300,000 gal. l l l Tritium l l 1.3 x 10-1 (Hydrogen-3) l 1.02 x 103 1.3 x 10-1 l 1.02 x 103 3.7 x 10-5 l 3.2 x 10-4 3.7 x 10-8 Cesium-137 l 3.2 x 10-1 8.8 x 10-10 Cesium-134 l 7.66 x 10-3 8.8 x 10-7 l 7.66 x 10-6 1.1 x 10-4 I 9.6 x 10-4 1.1 x 10-7 Strontium-90 l 9.6 x 10-1 Antimony-125/ l l Tellurium-125m i 2.0 x 10-2 2.3 x 10-6 l 2.0 x 10-5 2.3 x 10-9 1.0 x 10-4 l 8.7 x 10-4 1.0 x 10-7 Carbun-14 l 8.7 x 10-1 1.0 x 10-9 Technetium-99 l 8.7 x 10-3 1.0 x 10-6 l 8.7 x 10-6 4.8 x 10-7 l 4.2 x 10-6 4.8 x 10-10 Iron-55 l 4.2 x 10-3 4.8 x 10-10 Cobalt-60 l 4.2 x 10-3 4.8 x 10-7 l 4.2 x 10-6 3.0 ppm B Boron l 150 tons 3000 ppm 8 l .15 tons l H3903 l H3803 700 ppm Na+ .011 tons NaOH .7 ppm Na+

Sodium l 11 tons NaOH l x 10-3 <6.0 x 10-7 l<5.2 x 10-3 < 6.0 x 10-7

• lodine-129 l<5.2 < 1.8 x 10-9

• C6 r1 um-14 4 l<1.4 x 10-2 <1.8 x 10-6 l <1,4 x 10-5 x 10-4 <4.0 x 10-8 l<3,5 x 10-7 < 4.0 x 10-11

• Maaganese-54 l<3.5 < 4.0 x 10-11

• Cobalt-58 l<3.5 x 10-4 <4.0 x 10-8 l<3.5 x 10-7 x 10-3 <6.0 x 10-7  !<5.2 x 10-6 < 6.0 x 10-10

• Nickel-63 l<5.2 < 9.8 x 10-11 x 10-4 <9.8 x 10-8 l<8.5 x 10-7

• Zinc-65 l<8.5

• Rutheniom-106/ l l x 10-3 <3.3 x 10-7 l<2.9 x 10-6 < 3.3 x 10-10 Rhodium-106 l<2.9 < 5.6 x 10-11

• Silver-110m l<4.9 x 10-4 <5.6 x 10-8 l<4.9 x 10-7 x 10-2 <4.8 x 10-6 l<4.2 x 10-5 < 4.8 x 10-9

• Promethium-147 l<4.2 < 3.8 x 10-13

• Europium-152 l<3.3 x 10-6 <3.8 x 10-10 l<3.3 x 10-?

• Europium-154 x 10-4 <4.4 x 10-8 l<3.8 x 10-7 < 4.4 x 10-11

(<3.8 < 1.1 x 10-10

• Europium-155 l<9.6 x 10-4 <1.1 x 10-7 l<9.6 x 10-7 < 1,0 x 10-11

• Urintum-234 l<8.7 x 10-5 <1.0 x 10-8 l<8.7 x 10-8

• Uranium-235 l<1.0 x 10-4 <1.2 x 10-8 l<1.0 x 10-7 < 1.2 x 10-11

• Uranium-238 l<1.0 x 10-4 <1.2 x 10-8 l<1.0 x 10-7 < 1.2 x 10-11

• Plutonium-238 l<1.0 x 10-4 <1.2 x 10-8 l<1.0 x 10-7 < 1.2 x 10-11

• Plutonium-239 x 10-4 <1.4 x 10-8 l<1.2 x 10-7 < 1.4 x 10-11 l<1.2 < 1.4 x 10-11

• Plutonium-240 l<1.2 x 10-4 <1.4 x 10-8 l<1.2 x 10-7

<6.5 x 10-7 l<5.7 x 10-6 < 6.5 x 10-10

• Plutonium-241 i<5.7 x 10-3 x 10-7 < 1.2 x 10-11

• Americium-241 l<1.0  :: 10-4 <1.2 x 10-8 l<1.0

• Curium-242 l<8.7 x 10-4 <1.0 x 10-7 l<8.7 x 10-7 < 1.0 x 10-10 Effluent Totals Particulate Concentration: 2.61 x 10-7 vCi/ml.

Continuous Rate of Particulate Release at 5 GPM: 8.23 x 10-5 uCi/sec.

• Denotes assumed constituents

< Oenotes less than level of detection 18 0078H/3H u

3.0 PROCESS CONTROL AND OPERATIONAL OPTIONS 3.1 Process Control The process control of atmospheric releases during the evaporator and vaporization process will be implemented via the radiation monitoring and radiochemical sampling of the influent to the vaporizer section. Establishing process control at the vaporitor influen; conservatively assumes a 100% carry-over f raction through the vaporizer assembly. There is no credit tar plate out or solids separation in the he:ters, flash tank or exhaust stack.

l To establish a basis for this influent acceptability the criteria established in Section 2.0 of the PE!S Supplement II was used as a basis for comparison of the radiological constituents and respective concentrations acceptable for release to the atmosphere during operation of the vaporizer assembly. The average influent to the vaporizer assembly, noted in Table 3-1 is approximately l

2.61E-7 uCi/ml. This concentration, discharged at a rate of 5 GPM limits the continuous release of non-tritium radioactive l

l material, principally cesium-137, strontium-90, and carbon-14 to approximately 8.23E-5 uti/sec. This rate is less than 0.4% of i

the continueus particulate release rate permitted by the TMI-2 Recovery Tecnnical Specifications (0.024 uCi/ser..) when averaged i

19 0078H/3H

r over any calendar quarter. It is also less than the rate of release stated in the PE15 Supplement !!, section 3.1.1.2 (0.00028 wCi/sec. (2.8 E-4)) which was calculated at a flow rate of 20 GPM.

The radionuclides and their permissible level of concentrations as influent to the vaporizer assembly for atmospheric release are listed in Table 3-1. This table conservatively assumes that certain radionuclides, not positively identified in the process water samples, nevertheless exist at the stated lowest limit of detection. These assumed radionuclides, identified by an asterisk, are included in the table.

3.2 Operational Options The designed flexibility of the evaporator / vaporizer equipment permits the evaporator assembly to be de-coupled from the vaporizer j

assembly. In this configuration, the evaporator operates independent of the vaporizer and processes the water in a batch cycle method of operation. Conversely, if the vaporizer is coupled to the evaporator during operations, the water will be processed in a continuous type method of operation. The operational options addressed in this section describe these two methods of process i

cperaticns.

20 0078H/3H

D 3.2.1 Batch Cycle Operations In this configuration, the evaporator assembly will process water independent of the vaporizer assembly. The product distillate from the evaporator will be collected in a staging tank for sampling and radiochemical analysis. The benefits realized by this operational method are primarily in t'.e ar. a of radiological waste volume and occupational exposure reductions. By using the evaporator assembly ds a pretreatment technique for certain of the volumes of water, pretreatment by one of the icn exchange systems and the resulting Thus, contamination of demineralizer resins would be eliminated.

the handling and shipping of the resin liners for disposal purposes is eliminated.

l l

The collected product distil14tes, sampled at the staging tank, j

will be radiochemically analyzed for compliance with the controlling concentrations noted in Tables 3-1 or 3-2. Process operations by the evaporator coupled to the vaporizer assembly or by the vaporizer assembly independent of the evaporator, will not ,

be permitted until after it has been analytically determined by NRC approved process control procedures that the controlling constituents of the distillate are at or below those levels of l

concentrations noted in the influent column of the applicable table, (i.e., Table 3-1, vaporizer influent criteria, and Table 3-2, continuous cycle evaporator influent criteria),

I l

gj 0078H/3H l

4 0-3.2.2 Conti_nuous Cycle Operations In this configuration, the evaporator and vaporizer assemblies will  ;

be coupled and operate as a continuous cycle unit. The control of this operation will be initially established by the isolation of Once the body of water scheduled for continuous cycle evaporation.

this isolation is complete, a physical radiochemical analysis will be performed on the water and compared to the controlling l Process operations by radioactive constituents noted in Table 3-2.

the evaporator and vaporizer equipment will not be permitted until after it has been analytically determined by NRC approved process control procedures that the controlling constituents are at or i

! below those levels of concentration noted in the influent column of ,

the table.

I l

The imposition of these et aporator influent limits coupled with a l

conservative carry-over fraction of 0.15 assumed during evaporator i operations, will assure that the rate of atmospheric release of particulate radioactive material will be in compliance with the permissible release concentrations established in Section 3.1.

i l

l Operational experience and historical data accrued during actual operations (i.e., batch and continuous cycle operations) will provide a sound basis for the continued use of a 0.15 carry-over fraction for operational limits. Development of an operational i

h 22 0078H/3H e

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data base using physical sampling and radiochemical analysis may demonstrate that a less conservative carry-over f raction may be applied and the operational procedures modified accordingly.

However, until compilation of this data base during actual system operations, the 0.1% carry-over fraction will be assumed as the procedural control limit for continuous cycle operations.  ;

L 23 0078H/3H

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COL KE TEC-May 9, 1988 uskt 18 Mer 10 P7:13 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OTRCE 0f hnt 4D -

00CKlllNG A SEkVICE BRANCH 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 ) Generated Water)

Station, Unit 2) )

NOTICE OF APPEARANCE The undersigned, being an attorney at law in good standing k admitted to practice before the courts of the District of Columbia, hereby enters his appearance as counsel on behalf of GPU Nuclear Corporation in proceedings related to the 7

above-captioned matter.

Respectfully submitted, 4 d David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE 2300 N Street, N.W.

, Washington, D.C. 20037

, (202) 663-8474 i

, Yb ny s J^

.g:

COCK [iEp' May 9, 1988 MNRc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION gsregcf;g,9 ,,.,

Kll'hG A SEny,u-BRekcy BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

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

Station, Unit 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of:

Licensee's Memorandum Of Law In Support Of Motions For Summary Disposition; Licensee's Motion For Summary Disposition Of Contentions 4b (In Part), 4c And 4d; Licensee's Statement Of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contentions 4b In Part, 4c And 4d);

Affidavit Of David R. Buchanan (Contentions 4b In Part, 4c And 4d); and Notice Of Appearance Of David R. Lewis were served this 9th day of May, 1988, by U.S. mail, first cla.1, postage prepaid, upon the parties identified on the attached Se.

vice List.

w:= . k.

Thomas A. Baxter, P.C.

ys, 4

ie s.

~h.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

W In the Matter of )

)

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

) (Disposal of Accident- [

(Three Mile Island Nuclear ) Generated Water). l Station, Unit 2) )  ;

c 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 i Washington, D.C. 20555 Middletown, Pennsylvania 17057 Stephen H. Lewis, Esquire Adjudicatory File ,

Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board f Panel Docket i Office of the General Counsel U.S.-Nuclear Regulatory U.S. Nuclear Regulatory Commission [

Commission Washington, D.C. 20555  ;

Washington, D.C. 20555 j Docketing and Services Branch  ;

Secretary of the Commission  :

U.S.. Nuclear Regulatory Commission Washington, D.C. 20555 l k__ _ . _ _ _ _ _ _ _ _ . _ _ . . . _ _ . _ _ _ . _ _ _ _ _ _ _