ML20154E230
| ML20154E230 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/16/1988 |
| From: | Baxter T GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20154E212 | List: |
| References | |
| OLA, NUDOCS 8805200136 | |
| Download: ML20154E230 (4) | |
Text
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May 16, 1988 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
)
Generated Water)
Station, Unit 2)
)
LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTIONS 1, 2,
3 AND 6)
Pursuant to 10 C.F.R.
S 2.749(a), Licensee states, in sup-port of its Motion for Summary Disposition on Alternatives (Con-tentions 1, 2,
3 and 8), that there is no genuine issue to be heard with respect to the following material facts:
1.
Licensee has proposed to dispose of the processed accident-generated water at TMI-2 by forced evaporation, and off-site burial of the residue as low-level waste.
2.
Radiological releases from the evaporation method would be well within the limits set by the NRC in the TMI-2 Technical Specifications and in Appendix I to 10 C.F.R. Part 50.
3.
Licensee estimates that the average radiological expo-sure to a member of the 50-mile radius population from the 8805200136 080516 PDR ADOCK 05000320 0
s evaporation proposal will be 0.008 mrem to the total body, while the annual natural background dose is about 300 mrem.
4.
Licensee's proposal has the benefit of removing this radioactive liquid waste from the Three Mile Island site, thereby-advancing the cleanup of TMI-2 and removing the risk of continued storage.
5.
The occupational dose from evaporation of the AGW and the packaging of the evaporator bottoms (23 persen-rem) is a very small percentage of the 2,000 to 8,000 person-rem estimated for the TMI-2 cleanup.
6.
In order to dispose of the evaporator bottom vaste, a 3
burial volume of approximately 4,425 ft is required, and 8 truck shipments (with a practically zero probability of a traffic acci-dent or fatality) would be necessary.
7.
The suggested alternative of on-site solidification of 3
the AGW in cement, with off-site burial would require 467,000 ft of burial volume (58% of the Nation's "unusual volume" allocation for 1986 through 1992), 1,200 shipments from TMI to Hanforu (with an expected 4.9 traf fic accidents and 0.2 f atalities), and would i
cost $40.7 million (roughly 10 times the cost of the evaporation l
option).
8.
Off-site evaporation would require 460 truck shipments (with an expected 1.9 traffic accidents), would cost more than Licensee's proposal, and would require Department of Energy au-l thorization to use the evaporation site.
1 l
.4 9.
The alternative of distillation (closed cycle evapora-tion) of the AGW followed by on-site solidification and burial of the captured distillate is not feasible because of space limita-tions at TMI and the site's location within the 100-year flood plain, and would cost about $3 million more than Licensee's pro-posal.
10.
If the captured and solidified distillate (from Fact No. 9) is taken off-site for burial, the alternative has the same disadvantages stated above in Fact No. 7 for solidification of the AGW in cement and off-site burial.
11.
The radiological consequences of disposing of the AGW after 30 years of monitored storage in tanks would be essentially the same as disposal now because the critical organ and isotope are strontium dose to the bone.
12.
Construction of tanks alone for the 30-year storage would cost $1 million to $1.5 million.
Ultimate disposal costs would be added onto this.
13.
In the interim, the risks of an accidental release are present.
14.
Permanent in-containment storage of the AGW would re-sult in an occupational dose estimated at 4,070 to 5,106 person-rem (compared to 23 person-rem for the evaporation proposal),
would require exemptions to NRC's site suitability regulations l
under Part 61, and would exceed, in the long term, the cost of Licensee's proposal. l l
n.
15.
While the evaporation option does not result in the lowest doses to the public, the doses to the public from all of these options are so low as to be insignificant.
16.
None of the alternatives examined is obviously superior to Licensee's proposal when all relevant factors are considered.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE c-'=
Thomas A.
- Baxter, P.C.
Maurice A.
Ross Counsel for Licensee 2300 N Street, N.W.
Washington, D.C.
20037 (202) 663-8000 Dated:
May 16, 1988
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